ML20064G914
| ML20064G914 | |
| Person / Time | |
|---|---|
| Issue date: | 03/11/2020 |
| From: | Philip Mckenna NRC/NRR/DRO/IRSB |
| To: | Chris Miller NRC/NRR/DRO |
| Mayer A, NRR/DRO, 415-1081 | |
| Shared Package | |
| ML20064G913 | List: |
| References | |
| Download: ML20064G914 (4) | |
Text
C. Miller UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 11, 2020 MEMORANDUM TO: Christopher G. Miller, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: Philip J. McKenna, Chief /RA/
Reactor Oversight Process Support Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
REACTOR OVERSIGHT PROCESS PERFORMANCE METRIC REPORT FOR CALENDAR YEAR 2019 The Reactor Oversight Process (ROP) self-assessment program evaluates the effectiveness of the ROP by measuring its success in meeting its pre-established ROP goals and intended outcomes. The staff performed the calendar year (CY) 2019 performance metric analysis in accordance with Inspection Manual Chapter (IMC) 0307, Reactor Oversight Process Self-Assessment Program, dated November 23, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15216A347) and IMC 0307 Appendix A, Reactor Oversight Process Self-Assessment Metrics, dated August 25, 2017 (ADAMS Accession No. ML17186A115).
Under Element 1 of the ROP self-assessment process described in IMC 0307, the staff measures the effectiveness of, and adherence to, the current ROP program using objective and measurable metrics. The staff uses a graded approach of Green, Yellow, and Red thresholds in order to measure performance against the metrics. In Appendix A of IMC 0307, the staff aligns and categorizes the ROP performance metrics with the five Principles of Good Regulation:
independence (I), openness (O), efficiency (E), clarity (C), and reliability (R). The staff uses the metric analyses as an input to the annual Commission paper providing the results of the ROP self-assessment.
As a result of its analysis, which is summarized in Enclosure 1 and provided in detail in , the staff found that all but three of the ROP performance metrics met the Green criteria as defined in Appendix A to IMC 0307. Specifically, the staff found that 23 out of 26 ROP performance metrics satisfied the Green criteria, 1 metric met the Yellow criteria, and 2 metrics were found to be Red. A metric found to be Red represents unexpected performance and necessitates further evaluation and likely staff action to address the cause(s) for the failed CONTACT: Andrea G. Mayer, NRR/DRO (301) 415-1081
C. Miller 2 metric. A metric found to be Yellow indicates performance that warrants further evaluation and potential staff action to correct before the acceptance criterion is exceeded.
The staff found the ROP metric associated with metric E-6, Responsiveness to ROP Feedback Forms, to be Red for the third year. However, the staff made significant improvements from the previous 2 years in this area. The staff dispositioned 62 percent of the feedback forms opened in CY 2019 (almost three times the CY 2018 closure rate), compared to the Green criterion of 90 percent. As of February 1, 2020, 114 feedback forms remain in the backlog, about a 50 percent decrease from CY 2018. Starting in CY 2020, the staff will measure its efficiency in dispositioning feedback forms via the new ROP data trending program, and has removed formal ROP metric E-6 from IMC 0307, Appendix A. The staffs action to address this Red metric included issuance of revisions to IMCs and Inspection Procedures that closed several feedback forms. The staff also piloted an improved feedback form process that implements a semiannual regional screening and prioritization approach for all feedback forms.
The second Red metric for CY 2019 was E-5, Completion of Final Significance Determinations which measures whether the staff meet timeliness goals for finalizing inspection finding significance. Because there were only two Greater-than-Green findings for CY 2019, any one finding that exceeded the E-5 timeliness goal would turn the metric to Red, since the Green threshold is 95 percent. In CY 2019, one White finding at Clinton Power Station (ADAMS Accession No. ML19092A212) was finalized in greater than 90 days. This extended timeline was due, in large part, to the time required for staff review of over 2,000 pages of supplemental information provided by the licensee after the Regulatory Conference. Accordingly, the staff determined that this Red metric did not represent a programmatic weakness in the significance determination process program.
The single Yellow metric for CY 2019 was O-5, Issuance of ROP Public Meeting Notices and Summaries, which measures regional and headquarters staff timeliness in posting public meeting notices and summaries in accordance with NRC guidance. For CY 2019, the staff noticed and summarized public meetings within established timeliness goals 91 percent of the time (the Green criterion is 95 percent). The large proportion of missed timeliness goals occurred because of inconsistencies between regions for how less formal public engagement activities (e.g., poster sessions, open houses) are handled in terms of meeting notices and summaries. The program office staff has received clarification from the Office of Public Affairs and provided guidance to the regions on proper public meeting noticing and administration procedures for less formal public engagement activities that count as annual assessment meetings. The staff plans to revise its Inspection Manual guidance in this area in CY 2020 to clarify the requirements for noticing less formal regional public engagement activities.
Lastly, the staff notes that ROP metric C-4, Maintenance of ROP Governance Documents, was not evaluated for CY 2019 due to inconsistences in how the metric has been counted and due to the fact that the metric definition is not in accordance with the NRR Office Instruction OVRST-102, NRR Procedures for Processing Inspection Manual Documents, which specifies that ROP governance documents should be reviewed and reissued every 5 years, not every 4 as metric C-4 measures. The staff has revised this metric, effective CY 2020, to conform to OVRST-102 with a 5-year IMC and IP periodic review requirement. Additionally, to ensure staff
C. Miller 3 awareness and action in accordance with OVRST-102 and the revised ROP metric, the NRR Inspection Manual Coordinator will identify and track all IMCs and IPs that require periodic reviews in CY 2020 to ensure that they are completed in a five-year interval or as otherwise required.
Enclosure:
- 1. Self-Assessment Metrics Overview/Dashboard
ML20064G913 Package ML20064G914 Memo ML20064G915 (Enclosures 1 and 2)
- concurred via email OFFICE: NRR/DRO/IRSB* NRR/DRO/IRSB NRR/DRO NAME: AMayer PMcKenna CMiller DATE: 2/28/2020 3/11/2020 3/10/2020