ML20178A474

for 7/9/2020 Public Meeting - Draft COM-106 Revision 6; Safety Significance Determination Quick Reference Guide; and Ssd Tool

ML20178A474
Person / Time
Issue date:	07/08/2020
From:	Booma Venkataraman NRC/NRR/DORL/LPL3
To:
Venkataraman B
References
Download: ML20178A474 (68)

Text

ADAMS Accession No. ML20178A474 DRAFT OFFICE OF NUCLEAR REACTOR REGULATION COM-106, Revision 6 Technical Assistance Request (TAR) Process Volume XXX NRC Interfaces Approved By: This is a draft version of COM-106, Rev. 6, that is being made public to solicit comments.

Date Approved:

Effective Date: This draft version is made available July 9, 2020 in a public teleconference for comments to be collected and discussed at a future public engagement approximately two weeks later.

Certification Date:

Responsible Organization: Division of Operating Reactor Licensing (DORL)

Primary

Contact:

Booma Venkataraman 301-415-2934 booma.venkataraman@nrc.gov Summary: This issuance of COM-106, Revision 6, Technical Assistance Request (TAR)

Process, establishes an overhauled and rebranded version of COM-106, Revision 5, Control of Task Interface Agreements [TIA]. It merges relevant portions of the process contained in NRO Office Instruction, NRO-COM-108, Revision 1, NRO Construction Inspection Interfaces with Region II (ADAMS Accession No. ML113220316) into this revision of COM-106. NRO-COM-108, Revision 1, is rescinded with this update. This office instruction is effective XX, XX, XXXX, and applies to operating reactors and reactors under construction. Additionally, it incorporates a new graded approach with enhanced guidance and streamlined tools to address program lessons learned and focus resources commensurate with the significance of the issue to meet stakeholder needs effectively and efficiently.

Training:

ADAMS Package Accession Number: ML TABLE OF CONTENTS

1. POLICY ...........................................................................................................................1

2. OBJECTIVES ..................................................................................................................1

3. BACKGROUND...............................................................................................................1

4. BASIC REQUIREMENTS ................................................................................................2

5. RESPONSIBILITIES AND AUTHORITIES ....................................................................31

6. PERFORMANCE MEASURES ......................................................................................37

7. PRIMARY CONTACT ....................................................................................................37

8. RESPONSIBLE ORGANIZATION .................................................................................37

9. EFFECTIVE DATE ........................................................................................................38

10. CERTIFICATION DATE ................................................................................................38

11. REFERENCES ..............................................................................................................38

DRAFT Office Instruction: COM-106, Revision 6, Technical Assistance Request (TAR) Process Dated: XX, XXXX ADAMS Package Accession No: ML *- e-mail concurrence OFFICE NRR/DORL/LPL3 NRR/DORL/LA* NRR/EVS* NRR/DEX/EENB*

NAME BVenkataraman JBurkhardt Sanderson MMcConnell DATE 01/29/20 02/03/20 02/20/20 02/10/20 OFFICE NRR/DRA/APOB* NRR/DRO/IOEB* NRR/VPO/VPOB* NRR/DORL/LPL4*

NAME DHelton BBenney TFredette Treed DATE 02/07/20 02/07/20 02/10/20 02/06/20 OFFICE OE* RI/DRP/PB3/SBRO* RII/DRP/RPB5/WBRO* RIII/DRS/EB1 NAME NHilton PCataldo WDeschaine MHolmberg DATE 02/19 /20 02/11/20 02/10/20 02/06/20 OFFICE RIV/DRS/PSB* RI/DRP/DD* RII/DRP/D* RIII/DRP/DD*

NAME RKellar BWelling MMiller (J Heisserer for) MShuaibi DATE 02/10/20 03/13/20 03/13/20 03/17/20 OFFICE RIII/DRS/DD

• RIV/DRS/D* NRR/DSS/D* NRR/DEX/D*

NAME DCurtis RLantz JDonoghue EBenner DATE 03/17/20 03/06/20 03/12/20 03/05/20 OFFICE NRR/DRA/D* NRR/DRO/DD* OE/D* NRR/VPO/VPOB/BC*

NAME MFranovich MYoung GWilson VHall DATE 03/13/20 03/11/20 03/12/20 03/31/20 OFFICE OGC/NLO* NRR/DORL/LPL3/BC* NRR/VPO/D* (concur) NRR/DORL/D*

(concur)

NAME KGamin NSalgado MKing CErlanger DATE 06/25/20 / /20 / /20 / /20 OFFICE NRR/DRMA/D NRR/DORL/D (approval/sign)

NAME MKhanna CErlanger DATE / /20 / /20 OFFICIAL RECORD COPY

DRAFT NRR Office Instruction COM-106, Revision 6 Page 1 of 38

1. POLICY It is the policy of the Office of Nuclear Reactor Regulation (NRR) to address questions raised by other Nuclear Regulatory Commission (NRC) organizations in a timely manner with a level of effort commensurate with the significance 1 of the underlying issue. As such, the Technical Assistance Request (TAR) process is used to offer information assistance to organizations within the NRC regarding operating nuclear reactors and their related regulatory and oversight programs and reactors under construction either under Title 10 of the Code of Federal Regulations (10 CFR) Part 50 construction permits or 10 CFR Part 52 combined license processes. The process ensures that NRR responses and recommendations are promptly communicated to appropriate stakeholders.

The general purpose of this office instruction (OI) is to provide guidance to NRR and other NRC organization staff for initiating and processing TARs. The NRR management expects that TARs will be processed in a manner consistent with NRCs principles of good regulation (i.e., independence, openness, efficiency, clarity, and reliability) and organizational values (i.e., integrity, service, openness, commitment, cooperation, excellence, and respect).

2. OBJECTIVES To respond efficiently to the needs of both internal and external stakeholders, specific objectives include:

• Provide NRR and other staff an enhanced framework for processing TARs

• Promote consistency in processing TARs

• Guide effective scoping, screening, evaluation, and resolution of issues

• Ensure the TAR process is applied to plant-specific inquiries

• Effect agile referrals to alternate processes where appropriate

• Promote a holistic and integrated view of safety while processing a TAR

• Focus level of effort, rigor, and resources commensurate with issue significance

• Ensure effective engagement among internal and external stakeholders

• Meet timeliness goals

3. BACKGROUND COM-106 was first issued on November 26, 2001, and had several subsequent revisions as part of self-assessment and continuous improvement of the program (see Appendix A for Change History). The TAR program was formerly known as the Task Interface Agreement (TIA) program. In January 2019, an agency working group (WG) was 1 Commensurate with the significance - A graded approach to focus resources on issues that are typically more significant to public health and safety. The term significance means primarily risk-informed safety significance (i.e., all relevant principles of integrated decision-making, from NRR Office Instruction LIC-504). However, the term may apply to issues that may be significant for other reasons (e.g., high public interest, allegation related, reactor construction schedule, regulatory stability, etc.).

DRAFT NRR Office Instruction COM-106, Revision 6 Page 2 of 38 established to complete a major enhancement, called the TIA Revitalization Project.

The project had the following drivers:

• Align the program with the NRC organizational expectations to be an effective risk-informed regulator and modernize its decision-making

• Incorporate, as appropriate, recommendations from the NRR Low Safety Significant Issue Resolution (LSSIR) initiative (ADAMS Accession No. ML19260G224)

• Integrate best practices from offices of Nuclear Material Safety and Safeguards (NMSS) and New Reactors (NRO)2 and identify the needs of merging the NRO Construction TAR program into the COM-106 program

• Holistically redesign the program with fresh stakeholder dialogue to fulfill the agency mission and vision Specifically, the WG considered several sources of insights including the operating experience of past TIAs, best practices from other offices, and feedback from agency staff surveys. Highlights of internal stakeholder feedback are available in ADAMS Accession No. ML. Additionally, to enhance the TIA process, the WG considered industry recommendations received in the public engagement on March 19, 2019 (ADAMS Accession Nos. ML19077A297 and ML19074A141). On May 29, 2019, the WG held a public meeting to provide an update on the project and address the industry recommendations. The summary of the May 29, 2019, meeting is available at ADAMS Accession No. ML19156A428.

Revision 6 of COM-106 overhauls and streamlines the TIA program and incorporates the recommendations and feedback as noted above.

4. BASIC REQUIREMENTS This section describes the procedure for initiating and processing TARs requested by other NRC organizations. This OI is intended to guide NRR staff in providing information assistance to other organizations and helping to ensure compliance with NRC rules, regulations, and applicable requirements. This section provides the procedures for the main process and includes several supporting sections applicable to the operating reactor process, the construction TAR process, or both.

2 The offices of NRR and NRO merged on October 13, 2019, into NRR.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 3 of 38 Main TAR Process Snapshot Screening and In-Depth Review Intake Phase Evaluation Phase (Section 4.8) Phase (Section 4.10)

(Section 4.9)

Construction TAR (Appendix B) 4.1 Introduction The TAR process is a fact-gathering and issue evaluation exercise that informs decision-making in other NRC processes such as licensing, oversight, enforcement, and backfitting. A TAR is a request for technical or information assistance, most often from a regional office, but it may also come from another NRC headquarters office. A TAR could also be used to obtain technical assistance on an allegation-related issue. A TAR should be viewed as an extension of the regulatory process it serves; for example, a TAR related to an unresolved item (URI) referred from an inspection should be considered as an extension of the inspection process. No final agency action is taken, or regulatory decision provided within the TAR process itself. It will be up to the requesting office to take any appropriate action based on the information gathered and the recommendations or results provided by the TAR process.

A TAR addressing new reactor construction activity is unique in that it may adversely impact the construction schedule for an NRC regulated facility covered by 10 CFR Part 50 or Part 52. For these reasons, construction TARs are processed using the guidance detailed in Appendix B of this OI.

The goal of the TAR process is to support other NRC organizations efficiently and effectively. As such, TARs are not intended to replace informal discussions or other routine processes that take place among NRR staff and other NRC offices. In these routine processes, NRC staff exchanges opinions and evaluates plant configurations and operating practices in the light of regulatory requirements, staff technical positions, and good engineering practices. Occasionally, however, when routine channels are exhausted for resolving an issue, or the issue has become protracted or stagnant, a TAR may be needed to ensure that the issue receives focused attention in NRR in order to be routed or resolved with an effort commensurate with its significance and with appropriate documentation.

The TAR process has a three-phase structure3 to enable the review effort to be commensurate with the significance of the issue. The process includes templates and 3 Construction TARs will only be processed in the TAR intake and branch off to the steps described in Appendix B.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 4 of 38 tools for safety significance screening, information intake, and recording and communicating responses. An overview of the three-phase approach is provided below:

• Intake ( 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 4 level of effort):

The TAR Coordinator leads initial discussions to complete issue intake and gather facts from the requestor for pre-screening of the issue. Facts gathered should typically include voluntary licensee inputs. If a resolution or a referral to an alternate process is achieved in this phase, then the issue is closed out with a record in the TAR SharePoint site and the licensee or applicant is notified. Refer to Section 4.8 of this OI for details.

When a construction TAR is identified, it will be processed using guidance in Appendix B of this OI, with a goal of resolving the construction-related technical issue in a timely manner (typically 30 days) so as not to impact closeout of construction inspection activities.

• Screening and Evaluation ( 30-day goal):

An Integrated Team (IT), which includes the TAR Coordinator, the requestor, and other individuals such as members from the Office of General Counsel (OGC), conducts a screening and evaluation of issues submitted in the Intake phase in order to align on the path forward. The IT performs a structured assessment, including assessing the issues safety significance. The Screening and Evaluation results memorandum, with concurrences from the IT members and its Chairperson, will document the path forward including a response, if any. This phase will include notification to licensees and an opportunity for licensee inputs. Refer to Section 4.9 of this OI for details.

This phase will not apply to Construction TARs.

• In-Depth Review ( 80-day goal):

The TAR Coordinator leads a focused collaboration with NRR technical staff, OGC, and the Office of Enforcement (OE) (if required), coordinating with the requestor and engaging the licensee systematically as appropriate, to provide an In-Depth review for issues referred from the screening and evaluation phase. In this phase, the staff will verbally inform the licensee of the facts supporting the draft results, as the staff understands them. The output of this phase is a clear, concise, fact-based, and timely response, with NRRs Division of Operating Reactor Licensing (DORL) management sign-off. Refer to Section 4.10 of this OI for details. This phase will not apply to Construction TARs.

All days indicated throughout this OI are in calendar days, unless noted otherwise.

4 Level of effort unit in hours refers to work hours and not clock hours throughout this document.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 5 of 38 Table 1. Cross-Referencing Supporting Sections/Appendices with Main TAR Process Supporting Description Applicable Applicable to Applicable to In- Applicable to Section Ref to Intake Screening and Depth Review Construction erence Phase? Evaluation Phase? TAR?

(Section 4. Phase? (Section 4.10) (Appendix B)

8) (Section 4.9) 4.1 Introduction Yes Yes Yes Yes 4.2 Pre-Screening Yes No No Yes 4.3 Closure of Issues Yes Yes Yes Yes 4.3.1 Search for Precedents Yes Yes No Yes 4.3.2 Generic Implications Yes Yes Yes Yes 4.3.3 Backfitting and Issue Finality Yes Yes Yes Yes Considerations 4.3.4 Considerations of Enforcement Yes Yes Yes Yes 4.4 Safety Significance Yes Yes No No Considerations 4.5 Acceptance Criteria Yes Yes Yes Yes 4.5.1 TAR Intake Acceptance Criteria Yes Yes Yes Yes 4.5.2 TAR Screening and Evaluation No Yes No No Acceptance Criteria 4.5.3 TAR In-Depth Review No No Yes No Acceptance Criteria 4.6 Interface with NRC Staff and Yes Yes Yes Yes Management 4.7 External Stakeholder Yes Yes Yes Yes Interactions 4.7.1 Verbal Interactions Yes Yes Yes Yes 4.7.2 Written Interactions Yes Yes Yes Yes 4.7.3 Voluntary Supplemental Yes Yes Yes Yes information 4.11 TAR Related to Allegation Yes Yes Yes Yes 4.12 Deviations from the Process Yes Yes Yes Yes 4.13 TAR withdrawals Yes Yes Yes Yes 4.14 Resolving Requestor Office No Yes Yes No Disagreements 4.15 Continuous Improvement Yes Yes Yes Yes Appendix C TAR Intake Form Yes No No Yes Appendix C Screening and Evaluation No Yes No No Authorization e-mail template Appendix C Screening and Evaluation No Yes No No Results Memo template Appendix C In-Depth Review Response No No Yes No Memo template Appendix D Operating Reactor TAR Yes Yes Yes No Summary of Action Steps

DRAFT NRR Office Instruction COM-106, Revision 6 Page 6 of 38 4.2 Pre-Screening 5 Issues to Determine an Early Path Forward The goal is to use the most expedient method for resolving questions or issues.

Therefore, a TAR generally should not be used when:

• The response is straightforward and readily available

• The issue has been pre-determined to be clearly of very low safety significance and the requesting office could disposition 6 it under the VLSSIR effort 7 (see Section 4.4.1 of this OI)

• The NRC staff has previously expressed a clear and definitive position regarding the issue

• The question or concern could be referred to another process (e.g., backfitting, generic issues 8 program, differing professional opinion, legal interpretations, etc.)

• The question could be resolved by relying on a licensee or vendors evaluation or informal NRC staff resolution without compromising the NRCs regulatory function Specific pre-screening areas and respective instructions are described in Sections 4.3 and 4.4 of this OI. The TAR acceptance criteria are described in Section 4.5 of this OI.

4.3 Closure of Issues: Response, Referrals or Other Recommendation When a TAR is closed, three outcomes are possible (Figure 1):

(1) the issue is resolved in the TAR process. This will be documented either in the Screening and Evaluation Results memorandum, the In-Depth Review Response memorandum, with an entry to the Intake form technical response field for Construction TARs only, or recorded in the TAR SharePoint site for issues that are closed out in the Intake phase (2) a referral is made to another process (e.g., backfitting) and the issue will no longer be tracked in the TAR process. The basis for this referral will be documented in the Screening and Evaluation results memorandum or the In-Depth Review Response memorandum, or in the TAR SharePoint site (if referred in the Intake phase).

(3) the issue is recommended for no further regulatory action due to its very low safety significance and licensing basis standing. This will be documented on the Screening and Evaluation Results memorandum 5 The pre-screening guidance is primarily for the TAR Coordinator and staff in the intake phase.

However, this guidance may be used for pre-TAR activities to determine if a TAR is appropriate.

6 Disposition means to close out the issue to require no further regulatory action.

7 VLSSIR stands for Very Low Safety Significance Issue Resolution. The criteria do not apply to construction TARs.

8 Generic Issues program is owned by NRCs Office of Research.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 7 of 38 From routine processes Unresolved question If the issue is of very low safety TAR PROCESS significance and the licensing basis (A 3-phase, graded approach) standing is indeterminate Refer to an alternate Resolve/ May recommend no further regulatory action TAR Outcomes process Respond Figure 1. TAR Block Diagram The TAR closure documentation in any of the three phases is not intended as an agency action, but rather is intended to inform the process the TAR serves. It is the responsibility of the requesting office to take necessary actions in the associated process using the recommended disposition, referral, or response from the TAR documentation.

For issues outside of the scope of the TAR process (e.g., that do not meet the acceptance criteria or other circumstances), the TAR Coordinator should take action to ensure the issue is referred to the applicable process and the appropriate program contact as early as possible, with communication to the requesting office and the plant PM. See Section 4.5.1 of this OI for various alternate processes. Once the issues raised in the TAR are entered into the alternate process after a TAR referral, the TAR Coordinator should re-status the TAR from the open list to the closed list on the monthly TAR status report. The TAR Coordinator should then close the Enterprise Project Identifier (EPID) number(s) associated with the TAR, if it is in the Screening and Evaluation or In-Depth review phases.

The following sections (Sections 4.3.1 to 4.3.4) provide instructions on specific areas that may be useful in screening, scoping, and effecting closure of issues in the TAR process.

4.3.1 Search for Precedents and Previous Staff Positions As applicable, during TAR Intake or Screening and Evaluation, the TAR Coordinator with the help of the applicable team (e.g., the integrated team in screening and evaluation) or other staff should conduct a search to ensure that

DRAFT NRR Office Instruction COM-106, Revision 6 Page 8 of 38 the particular issue has not already been addressed. Searching for and identifying precedent staff positions may preclude the need for a TAR or other staff action, thereby saving resources and ensuring appropriate consistency with previous NRR conclusions.

Previous staff positions may be located in standard review plans, branch technical positions, regulatory guides, generic letters, bulletins, etc. The TAR SharePoint site should be searched for TIA or TAR precedents on similar topics to determine if a solution already exists and may be applicable to the issue of concern.

The Agencywide Documents Access and Management System (ADAMS) and the NRR Operating Experience (OpE) Information Gateway https://drupal.nrc.gov/nrr/ope search tools could also be useful for this purpose.

Licensee documents such as the Updated Final Safety Analysis Report (UFSAR) and responses to violations may provide additional insights on how a licensee addressed an applicable NRC staff position.

Even if a staff position already exists, the fact that a question was raised could indicate that a position or policy is not well understood. Accordingly, the NRC staff should consider the following options for restating a previously documented position:

• Issue a Regulatory Issue Summary.

• Update to inspection manual chapters and procedures

• Redistribute the documentation of the position or policy.

• Send a reminder via e-mail to regional counterparts.

• Incorporate the existing position or policy into higher level documents that normally contain applicable NRC staff positions.

Note: The above functions are outside the TAR process except redistributing documentation and sending a reminder.

4.3.2 Issues with Generic Implications 4.3.2.1 Generic Issues The TAR Coordinator and cognizant NRR technical staff should review the proposed TAR against the screening criteria listed in Management Directive (MD) 6.4, Generic Issues Program. If the issue is identified as a potential generic issue (program administered by Office of Research), it should be submitted into that process rather than the TAR process. This screening may provide an early referral of the issue away from the TAR process.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 9 of 38 4.3.2.2 Generic Concerns or Communications Once it has been determined that the issue involves generic implications, the TAR Coordinator should coordinate a meeting between the requesting organization (issue requestor, branch chief, and division director or delegate), DORL branch chief, NRR technical branches, the NRR Division of Reactor Oversight (DRO) Generic Communications and Operating Experience Branch, DORL plant project manager (PM), and the appropriate DORL deputy director.

The purpose of this meeting is to discuss whether to proceed with the review or proceed with the closure of the TAR and the initiation of the review as a generic communication. The staff will begin discussions on the type of product that will be issued (rulemaking, regulatory issue summary, regulatory guide, etc.).

4.3.3 Backfitting and Issue Finality Considerations A TAR is not intended to establish a new agency position for the purposes of backfitting. If it is determined at any time that the issue under consideration is outside the plant licensing basis, then the TAR process is not the appropriate process to follow and the issue could be referred to the backfit and issue finality process. The TAR Coordinator should ensure the appropriate backfitting Community of Practice Point of Contact or Subject Matter Expert (SME) is included in the discussion as early as possible to determine if the issue should be referred to backfitting and issue finality process. Backfitting and issue finality guidance and policy can be found in MD 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and Information Requests.

Often, questions referred to the TAR process relate to the plant licensing basis.

Licensing basis information is unique to the plant and may lack detail or present ambiguity (e.g., multiple descriptions about one topic in different places), or complexity (e.g., information on a complex design). Determining whether the issue is in the licensing basis is key to routing the issue appropriately.

Enclosure 2 of the LSSIR recommendations memorandum dated February 5, 2020 (ADAMS Accession No. ML19260G224), provides high-level guidance for determining if the issue is in the licensing basis or not and this may be used in the pre-TAR discussions as well as the TAR screening and evaluation activities.

Once it has been determined that the issue (includes Construction TARs) is not within the licensing basis and further pursuit of the issue could result in imposing a new requirement, the TAR Coordinator should arrange a meeting among the requesting organization (issue requestor, branch chief and division director or delegate), DORL branch chief, cognizant NRR technical branches, backfitting SME, DORL PM, and the appropriate DORL deputy director. The purpose of this meeting is to discuss the closure of the TAR and initiate discussions for potential referral to the backfitting and issue finality process. The meeting discussions should include passing on relevant TAR safety significance determination information to the backfitting and issue finality process to help make its decisions early, if applicable. This can happen in the Screening and Evaluation phase and sometimes even in the In-Depth review phase of the TAR.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 10 of 38 4.3.4 Considerations of Enforcement The staff does not take or recommend enforcement actions through the TAR process. Enforcement-related decisions are outside of the scope of the TAR process. The requesting organization is responsible for any enforcement-related decisions.

4.4. Safety Significance Considerations for Operating Reactors 4.4.1 LSSIR Recommendations The LSSIR initiative applies to issues that are both not clearly within the plants licensing basis and of insufficient safety significance to warrant the expenditure of significant additional agency resources. 9 One of the LSSIR recommendations is the Very Low Safety Significance Issue Resolution (VLSSIR) process, with updated guidance in Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, which allows inspectors to disposition issues, when VLSSIR criteria are met.

When an issue is referred from the inspection process to the intake phase of this OI, the TAR Coordinator discussion with the requestor should include any previous efforts to assess the issues safety significance and research the plant licensing basis in accordance with the aforementioned IMC 0612 guidance. The agency public documentation for dispositioning the issue, if originating from the inspection process, should be executed by the requesting office (e.g., in the inspection reports under IMC 0611).

If the inspection issue is referred to the TAR process and was not previously screened out and dispositioned using the IMC 0612 guidance on safety significance standing, it could still be screened out and dispositioned in the screening and evaluation phase of the TAR process, as described in Section 4.9 of this OI. Additional information gathered in this phase, together with the perspectives of the TAR integrated team may lead to the conclusion that the issue is of very low safety significance and does not warrant further agency efforts on the issue.

4.4.2 Exceptions

Effort Not Commensurate with Safety Significance A wide range of inspection issues may enter the TAR process including those known to be of very low safety significance. These issues may be accepted, if they meet the TAR acceptance criteria. The issue screening and evaluation or a resolution, if achievable, is expected to be completed in the Screening and Evaluation phase, by the integrated team in accordance with Section 4.9 of this OI. In exceptional cases (see Section 4.12 of this OI), the integrated team may refer the issue to the In-Depth Review phase (Section 4.10 of this OI) due to its high stakeholder value, or other reasons, which then will need the approval of the office directors of NRR and the requesting office to authorize resources for the 9 See Low Safety Significance Issue Resolution Working Group Recommendations (ADAMS Accession No. ML19260G224).

DRAFT NRR Office Instruction COM-106, Revision 6 Page 11 of 38 In-Depth review. Under such scenarios, the TAR effort would not be commensurate with the safety significance of the issue.

4.5. Acceptance Criteria A TAR contains questions on subjects within the scope of NRR's mission and responsibilities. The TAR process is to be used to address plant-specific 10 issues.

Issues concerning generic applicability (including generic issues), plant backfitting, enforcement decisions, and disagreements with previous staff positions cannot be accepted in the TAR process. The following types of questions are typically associated with an issue identified at a specific plant:

• regulatory requirements

• plant licensing basis

• URI or inspection finding resolution

• NRR staff technical positions

• safety or risk significance of certain plant configurations or plant operating practices

• specific plant events

• construction-related technical issues 4.5.1 TAR Intake Phase Acceptance Criteria The following conditions should be met to enter TAR intake:

• The issue is plant-specific

• TAR request initiated by the requesting office (see Section 4.8) 4.5.2 TAR Screening and Evaluation Phase Acceptance Criteria The following conditions should be met to enter TAR screening and evaluation:

• Completed information on Intake form

• The issue has not been previously determined to meet the criteria for LSSIR disposition (as discussed in Section 4.4 of this OI)

• Requesting Office division management authorization (e-mail to DORL management (see Appendix C) 4.5.3 TAR In-Depth Review Phase Acceptance Criteria The following conditions should be met to enter TAR In-Depth review:

• The issue is plant-specific 10 An issue that applies to one specific plant.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 12 of 38

• The issue is (1) not of very low safety significance as determined by the application of the TAR Safety Significance Determination tool, or (2) the safety significance is indeterminate.

o Exceptions may be granted based on agreement between NRR and requesting Office Directors, where safety significance alone is not a driving factor (e.g., an issue of high public interest). See Section 4.12 of this OI

• A well-defined, focused set of questions has been formulated by the integrated team in the Screening and Evaluation phase and recommended for In-Depth review o Questions accepted in the Screening and Evaluation phase to be recommended to the In-Depth review cannot be changed unless the process is exited and restarted in the Intake phase 4.6 Informing and Interfacing with NRC Staff and Management 4.6.1 TAR SharePoint Site The TAR Coordinator should maintain a log of completed and active TARs on the internal agency SharePoint site. 11 This site serves as a historical reference library of completed TARs. This database will also include the ADAMS references for the completed Intake forms for construction and operating reactor TARs.

4.6.2 Quarterly Briefing of NRR Executive Team The TAR Coordinator will provide a TAR status update to engage the NRR Executive Team (ET). This will allow the ET to engage and inform regional management, ensuring agency alignment on open issues related to the items in progress in the TAR program. As needed, urgent TAR issues can be relayed through monthly ET regional counterpart calls.

4.6.3 Workload Management Status Reporting The TAR Coordinator will provide a status report for the monthly NRR workload meetings.

4.7 External Stakeholder 12 Interactions The goals of the TAR process include engaging external stakeholders effectively and efficiently to get information and providing timely communication and notifications on the issue under review. The TAR process should be viewed as an extension of the process it serves. Thus, if the TAR process receives an unresolved question from the inspection process, or a technical issue identified through construction inspection, it becomes an 11 https://usnrc.sharepoint.com/teams/NRR-Technical-Assistance-Request.

12 External Stakeholders means licensees or applicants.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 13 of 38 extension of the inspection process. As such, interactions with the stakeholders should follow the needs of the process the TAR serves and address the specific issue at hand while every effort should be made to make the process transparent whenever possible.

Due consideration should be given to balance transparency with the potential consequences of sharing preliminary or pre-decisional information. The licensee or applicant should be engaged as early as possible and throughout the TAR process to obtain substantive and timely information pertaining to the TAR. Staff should follow any overarching guidance from the referring process that relates to these interactions. For instance, when an operating reactor inspection issue is referred to the TAR process, the guidance documents to supplement this OI would be IMC 0620, Inspection Documents and Records, which provides staff guidance on types of draft information that can and cannot be shared with a licensee, vendor, or applicant, and IMC 0330, Guidance for NRC Review of Licensee Draft Documents, which provides staff guidance on review and handling of licensee draft documents provided to the NRC. The goal of interactions is to ensure the availability of clear, accurate, and complete facts about the issue.

4.7.1 Verbal Interactions The TAR Coordinator will work with the requesting office and/or the plant PM for discussions in the TAR phases, depending on the process the TAR serves (e.g.,

URI or a general question). The requesting organization should interface with the licensee or applicant to gather facts as early as possible (pre-TAR intake activities). These should be informal exchanges. These exchanges are not typically public meetings because the TAR is primarily a fact-gathering process.

The nature of the discussions should be purely information exchanges for fact-gathering, clarification or notification rather than problem-solving, and no decisions or agreements should be made. However, if the issue referred to the TAR process is of specific public interest or of high stakeholder value, the interactions may be made public, with due consideration given to balancing openness and the consequences of sharing preliminary or pre-decisional review information. 13 More details of verbal interactions in TAR Intake, Screening and Evaluation and In-Depth review phases are provided in the Sections 4.8, 4.9, and 4.10, respectively, of this OI.

4.7.2 Voluntary Supplemental Information The TAR process encourages the licensee or applicant to participate in the process as early as possible, providing its position or submitting supplemental information to support the review. These could be in the form of position papers, white papers, or a formal submittal on the docket. To support timely execution of the TAR process, this information should represent the best available information. In particular, new and detailed computational analysis or experimentation should not be encouraged if its primary purpose is to influence the assessment of safety significance.

13 Because TAR is an internal fact gathering exercise that informs decisionmaking in other processes, TAR response, referral, or recommendations documentation (Construction TAR process, Intake, Screening and Evaluation or In-Depth phases) will be issued to the requesting office and not made publicly available. The requesting office could publish (e.g., in inspection) reports the actions taken as a result of a TAR response, referral, or recommendations publicly.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 14 of 38 Relevant licensee- or applicant-provided information should be collected by the requesting office early during the information gathering stage (e.g., TAR Intake) to enable the TAR team to characterize the issue and become aware of alternate licensee positions. Further details unique to TAR Intake, Screening and Evaluation and In-Depth review phases are available in the Sections 4.8, 4.9, and 4.10, respectively, of this OI.

4.7.3 Written Interactions On occasion, the NRR staff or requesting organization may need additional information beyond that which could be obtained by the requesting office in the intake phase. In such cases, the TAR Coordinator will request the additional information working in coordination with the requesting office and/or the plant PM depending on the process the TAR serves. The TAR Coordinator will issue the request to the licensee (this may typically happen in the TAR In-Depth review) working with the requesting office, if the issue is related to a URI. For all other requests, the TAR Coordinator will work with the requesting organization and the plant PM to issue the request.

The licensee or applicant may submit the information voluntarily by e-mail to the requesting office or the plant PM on an agreed upon schedule. The TAR Coordinator should put the document in ADAMS and it will be referenced in the In-Depth review response, if used to support the staffs TAR conclusion. Further details on written interactions unique to the TAR screening and evaluation and In-Depth review are available in the Sections 4.9 and 4.10, respectively, of this OI.

4.8 Intake Phase The TAR Intake (see Figure 2) is the initial fact-gathering framework. The TAR Coordinator facilitates an information exchange with the requesting office to pre-screen the issue (Section 4.2 of this OI) to achieve an early resolution, a referral to an alternate process or a referral to the Screening and Evaluation phase. Interactions are expected to happen at the staff and/or branch chief level in this phase. Although this phase is focused on gathering facts, the staff is encouraged to resolve the issue within 8 work hours, if possible.

4.8.1 Logistical Considerations The Intake process is typically expected to be preceded by informal discussions with the TAR Coordinator to discuss the TAR process instructions and acceptance criteria (see Section 4.5 of this OI) and is initiated with the requesting office submitting a request to the TAR Coordinator to enter the TAR process.

This could be an e-mail from the requesting office staff (requestor) with a copy to the respective branch chief.

The requestor and the TAR Coordinator, using the TAR acceptance criteria, should weigh the complexity, significance, and necessity of a TAR to direct the technical issue to the most efficient process for resolution (e.g., phone call, e-mail, or TAR). During these discussions, the TAR Coordinator will perform an initial screening (pre-screen) of the request in the areas described in

DRAFT NRR Office Instruction COM-106, Revision 6 Page 15 of 38 Sections 4.3, 4.4, and 4.5 of this OI to determine if it should enter the TAR process or be routed to an alternate process. The TAR Coordinator should be sensitive to the nature of the issue and timeframe needed for resolution (inspection schedule or licensee impact) and take these factors into consideration in responding to the request.

Figure 2. Intake Phase Flowchart Appendix C describes the Intake form, which allows the TAR Coordinator and the requestor to focus initial discussions on requisite fact-gathering. The requestor will be required to provide as much information as possible with the request to enter the TAR process.

Informal discussions and pre-screening should include a determination of whether an issue is construction-related. The following question should be posed: Is the issue related to on-going construction of a power reactor or research/test reactor facility, or an isotope production facility? If the answer is Yes and safety significance determination consideration is not driving the issue, then further screening and evaluation of the issue is not applicable. The Intake form will be completed accordingly (Box 10 checked YES) and the TAR Coordinator and requestor will initiate the Construction TAR process using the guidance in Appendix B of this instruction.

4.8.2 Work Planning Planning and processing of a TAR is critical in ensuring the work is completed in a timely and effective manner. The TAR Coordinator is responsible for

DRAFT NRR Office Instruction COM-106, Revision 6 Page 16 of 38 scheduling and coordinating the review and keeping the staff and management informed throughout the life of the TAR. The TAR Coordinator and NRR technical staff will charge their time to a pre-existing, non-fee billable EPID that is available from respective NRR and the requesting office Divisions for the work in this phase. This EPID must not be specific to the TAR. The TAR Coordinator should:

• Initiate a TAR, when a request (e-mail or memorandum) is received from the requestor with an Intake form attached (Appendix C), as complete as possible.

• Assign a TAR number and enter in the SharePoint to track it until closeout.

TAR numbering will be sequential by calendar year (e.g. 2019-01, 02, etc.)

and Construction TARs will include a suffix letter C (e.g. 2019-01-C).

• Notify the DORL BC and management on the receipt and processing of the TAR request.

• Pre-screen the issue (Sections 4.3, 4.4, and 4.5 of this OI), to resolve, refer the issue to an alternate process, or refer the issue for TAR screening and evaluation.

• Coordinate activities with an effort to be completed in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> includes time for the TAR Coordinator to facilitate a structured and focused conversation with the requesting office, plant PM, relevant technical staff, including DRO Operating experience technical staff and any other appropriate staff, to attempt to resolve14 the issue (at the staff or branch chief level) if possible and complete the Intake form initiated by the requestor.

• Status the TAR as Closed and capture information about the issue in the SharePoint site, if a resolution or referral is achieved in this phase. If licensee inputs were used, gathered informally, to close out the issue, then the TAR Coordinator should notify the licensee through the requestor or plant PM of the TAR closure. For example, if a region refers a URI to TAR, the communication will be provided by the requesting region staff (e.g., inspector) to the licensee. If another NRC organization refers a question to TAR, then the plant PM will communicate the closed TAR status to the licensee, provided licensee inputs were used.

• Store the completed Intake form for the issue on the SharePoint site and in non-public ADAMS. For the TARs that move to screening and evaluation phase, the Intake documentation will be included with the Screening and Evaluation documentation. For allegation-related TARs, coordinate with the 14 TAR Intake is primarily for gathering facts; however, resolution of an issue may be possible in some cases. For example, if the TAR Coordinator is pre-screening an issue for precedent information or previous positions and coordinates the research in the 8-hour window with other NRR staff on the issue, and is able to resolve the issue, then the TAR Coordinator should inform the requestor, record the issue resolution in the TAR SharePoint Site as resolved and the TAR closed. There will be no separate documentation issued.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 17 of 38 Allegation Review Board (ARB), and documentation must not be placed on the SharePoint Site or ADAMS (See Section 4.11).

• Coordinate with the requestor to create a complete non-public ADAMS package containing the completed Intake Form and all supporting materials.

4.8.3 Moving an Issue to TAR Screening and Evaluation Phase If resolution or referral is not achieved in the Intake phase, the TAR Coordinator should refer the issue to TAR screening and evaluation phase, once the TAR Coordinator determines sufficient information is provided to conduct a screening and evaluation of the issue. Within 3 working days of the completion of the Intake phase and discovery that the issue needs to move to screening and evaluation, the TAR Coordinator should work with the requestor for the requestors division management to submit the Screening and Evaluation authorization e-mail (Appendix C) to the DORL division management with a request to move the issue up to a screening and evaluation status. This initiates the screening and evaluation review.

4.9 Screening and Evaluation Phase The Screening and Evaluation phase (Figure 3) builds on the Intake phase and provides a formal framework to perform the following primary functions: issue screening, evaluation, scoping, and documentation of the conclusion in order to route the issue appropriately. The Screening and Evaluation phase will not perform the function of driving the issue to resolution. In some cases, it may be possible to resolve the issue as a by-product of performing the other functions; resolution is not an intended primary function of this phase. An integrated decision-making team, assembled by the TAR Coordinator, performs focused reviews to reach alignment on the issues path forward with a graded approach, commensurate with the significance of the issue, with a timeliness goal of 30 days from the team kickoff meeting. As a general guidance, the IT should use the first 15 days to scope, screen, evaluate, and align on the path forward and use the latter 15 days to draft, concur, and complete the TAR conclusion documentation. It is expected that under limited circumstances, extensions beyond 30 days to continue and complete the screening and evaluation may be allowed with appropriate justifications. Extension may be given in situations such as extensive new information received from the licensee, complexity in scoping of the issue, and lack of available resources.

4.9.1 Logistical Considerations Within 7 working days of the initiation of screening and evaluation (Section 4.8.3 of this OI), the TAR Coordinator should work with DORL management to stand up an IT and organize a kickoff meeting. During this time, the TAR Coordinator should inform the applicable technical divisions, SMEs (e.g., backfitting), OE, and OGC about the TAR initiation, request assignment of dedicated staff to the IT and provide a copy of the relevant supporting information. The TAR Coordinator should request DORL management to expeditiously identify a Chairperson for the IT, typically an SES manager.

The IT will be generally comprised of a Chairperson, the requestor, TAR Coordinator, plant PM, technical staff, SMEs (e.g., generic concerns, backfits),

DRAFT NRR Office Instruction COM-106, Revision 6 Page 18 of 38 NRR risk analyst 15 and OGC. In addition, the team may include an OE member (if needed). If it is known in advance that a particular skill set is not needed (e.g.,

a risk analyst in the case of an allegation-related TAR where safety significance will not be assessed by the IT), that skill set need not be included on the IT. The team will engage through meetings or conferences as necessary to complete the screening, evaluation, possible response, and the necessary decision-making and documentation.

Appendix C provides information on the Screening and Evaluation Results memorandum which will be used by the IT to record the conclusions in this phase including a response if achieved.

Figure 3. Screening and Evaluation Phase Flowchart 4.9.2 Work Planning Following are the work planning steps for the Screening and Evaluation phase:

• Requestors division management issues a TAR screening and evaluation initiation memorandum to DORL management.

15 If an issue has received significant evaluation by a Regional senior reactor analyst (SRA) prior to entering the TAR process, it may be more efficient to have the Regional SRA participate on the IT, with NRR/DRAs general awareness.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 19 of 38

• The TAR Coordinator should obtain an EPID through RPS- Licensing (a non-fee billable charge code) within 2 working days of the TAR screening and evaluation initiation. The EPID will also establish the milestones and the deadlines to complete for the TAR screening and evaluation and may be extended to TAR In-Depth review, as needed. The TAR Coordinator will identify the following typical milestones (assuming no licensee inputs are added in this phase):

Screening and Evaluation initiation Kick-off meeting (7 working days from initiation)

Initial Safety Significance Screening Completed (10 days from kickoff)

Other Screening, Scoping, Evaluation and Resolution (if applicable) completed (10 days from kickoff)

IT meeting to make final decision on path forward (15 days from kickoff)

Screening and Evaluation Results memorandum signed off (30 days from kickoff)

• The TAR Coordinator should identify dedicated resources for the IT within 7 working days of the TAR screening and evaluation initiation. DORL management will be requested to assist, if necessary, to ensure that resources are available to complete the work in the short period of time.

• The TAR number assigned in the TAR Intake phase should be continued.

• Track the TAR screening and evaluation to completion and ensure documentation and distribution of the TAR screening and evaluation conclusion. The TAR Coordinator should organize and facilitate all meetings, and maintain a record of significant discussions, agreements and action items, including the progression of changed or refined questions from the Intake Form as necessary.

• For an issue that is closed out in the TAR screening and evaluation (resolution, referral, or recommendation for no further action), the TAR Coordinator should coordinate with the requestor and/or the plant PM to ensure that the licensee or stakeholder is informed of the issues closure or exit the TAR process.

4.9.3 Conduct of Operations 4.9.3.1 IT Activities The TAR screening and evaluation IT activities include the following:

• Hold a kickoff meeting to review the initial request, assess any special expertise needs, and identify roles and responsibilities.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 20 of 38

• Identify incomplete information on the Intake Form, if any, and with the TAR Coordinators lead, obtain additional information such as licensee inputs.

• Rigorously scope and refine the Intake questions in this phase.

Perform iterations and discuss with the requesting office, assign questions to necessary review areas, and identify any early answers. Legal questions should be referred to OGC. The IT should hold detailed discussions with the requestor in the beginning to understand the issue of concern, the requestors proposed questions, the basis, and collect any details necessary for the respective team members to perform their reviews.

• Perform the screening for safety significance with the TAR Safety Significance Determination tool (Appendix C).

• For questions that relate to licensing basis, the IT should discuss all available information and facts including any disputed facts recorded on the intake form and supporting documentation. In addition, the IT should collect additional facts as necessary pertaining to determining LB standing, including research and seeking licensee information if necessary. The technical staff, backfitting SME, OGC, TAR Coordinator, plant PM and other staff should discuss whether the issue is clearly in or outside the licensing basis or if the licensing basis is indeterminate.

• Within 15 days from the kick-off, the IT should meet and discuss the issue and the steps undertaken in the screening and evaluation. The Chairperson should make the decision described below based on the facts presented with the results of the safety significance determination, licensing basis discussions, the final questions on the underlying issue as agreed with the requestor, and other relevant inputs from the team and licensee.

• Consider disputed facts and integrate them early in the review.

• Identify and grant issue exceptions with respect to TAR acceptance criteria (see Section 4.5.3) and route the issue with well-defined questions to In-Depth review for resolution with office directors approval from NRR and the requesting office.

• Achieve one of the following five TAR screening and evaluation outcomes with the Chairperson as the decision maker:

(1) The Chairperson of the IT makes a recommendation for no further regulatory action on the issue, based on the results of the safety significance evaluation and the indeterminate

DRAFT NRR Office Instruction COM-106, Revision 6 Page 21 of 38 licensing basis standing of the issue (not relevant for allegation-related TARs)

(2) After assessing safety significance and team collaboration, the IT provides a documented referral of the issue to the In-Depth Review phase (Section 4.10 of this OI), with a well-defined set of questions that meet the acceptance criteria, based on the issues not very low safety significance status (not relevant for allegation-related TARs)

(3) The IT achieves an early resolution of an issue, irrespective of its safety significance, because:

The IT arrives at an answer for part or the entire issue within 2 weeks into screening and evaluation. If, during this phase, the issue is determined to be in the licensing basis, then the IT will provide a response to the requesting office documenting the response in the Screening and Evaluation Results memorandum (4) The IT identifies an existing staff position (see Section 4.3.1 of this OI), which may resolve the issue or may be used in the evaluation (5) Refer the issue to an alternate process. For example, if the screening and evaluation results indicate the issue is clearly outside the licensing basis, the IT will refer the issue to the backfitting process (Section 4.3.2).

• Document the decision using the Screening and Evaluation Results Memo template (Appendix C).

4.9.3.2 Safety Significance Determination The risk analyst and topical area SME team members will apply the TAR Safety Significance Determination Tool (see Appendix C) using the information provided in the completed Intake form for the issue (except for allegation-related TARs). The results of this assessment will be briefed out to the IT to ensure that all relevant technical information was incorporated into the assessment. The outcome of the safety significance determination worksheet is a recommendation to the IT that the issue is or is not of very low safety significance. The results of this review will be documented on the Screening and Evaluation Results memorandum, and the safety significance evaluation information will either be attached to the memorandum or else stored in ADAMS with the accession number reference on the screening and evaluation template. For occasions where the safety significance screening tool cannot be satisfactorily applied (e.g., where safety significance is indeterminate or not applicable), the team will record this result and the basis for this determination in the Screening and Evaluation Results and the IT will refer the issue to the

DRAFT NRR Office Instruction COM-106, Revision 6 Page 22 of 38 TAR In-Depth review phase, after scoping and developing a set of well-defined questions for In-Depth review and resolution. For allegation-related TARs, the safety significance assigned by the ARB as part of the allegations process will be used, to the extent that safety significance needs to be factored in to prioritizing resources.

4.9.3.3 Licensee or Other Stakeholder Interactions During Screening and Evaluation Phase Once a TAR screening and evaluation is accepted and initiated and around the time of the kick-off meeting, the TAR Coordinator should work with the requesting office and plant PM to hold a call with the licensee to inform it about the issue entry in the TAR process. The licensee should be provided information about the proposed questions and facts of the issue in this call. The timing of the call should be chosen to increase effectiveness of the interface. As discussed in Section 4.7.1, these interactions are not typically public exchanges.

Informing the licensee affords it an opportunity to provide information voluntarily to support the TAR screening and evaluation. The licensee may submit any information not already collected in the Intake phase, with a potential for a follow-up clarifying conference call if necessary.

Staff should rely on the best available information. In order to promote process timeliness, staff should not await the results of new and detailed analytical studies or experimentation. In some rare instances, the IT may request additional information (Section 4.7.2) from the stakeholder to support the screening and evaluation.

The staff should ask the licensee to provide any voluntary information for NRC consideration within 5 days of the call or by a certain agreed-upon date. The additional information, if any, should then be considered through the requesting organization to verify it does not obviate the need for the TAR or change the questions as defined.

Further, the requesting organization should advise the NRR staff as to whether the information should be included as a part of the TAR review.

The TAR Coordinator will confirm with the requesting office that any licensee inputs on the issues or questions raised are accurately captured on the TAR Intake form and, if necessary, the requesting office will update the form to reflect the current licensee position on these issues.

4.9.3.4 Issue Scoping, Evaluation, and Conclusion The TAR IT screening and evaluation activities should ensure the requestors questions are well-framed and refined with necessary iterations, are not overly broad or speculative, are in scope (with respect to Sections 4.3, 4.4, and 4.5 of this OI), and consider all relevant stakeholder inputs. There should be a free exchange of information between the requesting organization and the IT to ensure that the questions frame the requestor issue accurately and can be

DRAFT NRR Office Instruction COM-106, Revision 6 Page 23 of 38 answered by NRR. Agreement should be reached with the requestor on the set of questions that need to be answered or referred to In-Depth review as appropriate. Thus, the IT should be able to characterize the issue effectively, with well-defined and succinct questions, and together with the safety significance determination, should recommend a path forward with a graded approach. The TAR Coordinator should coordinate the question formulation process and the final agreed questions should be recorded in the Screening and Evaluation Results memorandum. The requestor should keep his or her management informed on major changes to scope and bring any concerns to the Chairperson promptly. If a resolution is achieved, the team should document the response in the Screening and Evaluation Results memorandum and close out the TAR.

The TAR Coordinator will draft the Screening and Evaluation Results memorandum (Appendix C) and coordinate concurrence from the IT.

The Screening and Evaluation Results memorandum will include a section for the requestor to provide comments on the process of handling the issue and any other concerns or comments if applicable.

The TAR Coordinator will notify the requesting office that the screening and evaluation is completed and distribute the document in non-public ADAMS (except for allegation-related TARs where the document cannot be placed in ADAMS).

4.9.3.5 Moving an Issue to the In-Depth Review Phase For issues that meet the TAR In-Depth review acceptance criteria (Section 4.5 of this OI) or for which an exception is granted, the questions formulated in the screening and evaluation by the IT become the designated questions for review within the In-Depth review, and should not change during the TAR In-Depth review process. Within 2 working days of the screening and evaluation documentation recommending the referral of the issue to TAR In-Depth review, the TAR Coordinator will provide e-mail notification to requesting office management about the outcome from the TAR screening and evaluation, including a description of the issue and the questions with the completed Intake and Screening and Evaluation attachments, and status the EPID in RPS-licensing program for extension. This initiates the In-Depth review phase.

4.9.4 Multiple Issues Referred to the TAR Process Screening and Evaluation and Staggering Teams The above guidance describes the activities applicable to a single issue in the process. It is possible that there could be several different requests to enter TAR screening and evaluation from various requesting organizations. NRR staff should control and prioritize activities depending on staff availability for integrated teams. Closeout dates may be negotiated, with substantial deviations

DRAFT NRR Office Instruction COM-106, Revision 6 Page 24 of 38 documented per Section 4.12 of this OI. NRR staff will give special attention to the following when considering priority:

• Issues involving significant safety issues

• issues that could involve the loss of power production (i.e., a plant shutdown, derating, or delay in startup)

• issues related to an allegation

• TARs involving inspection findings or URIs

• issues where uncertainties or conflicting views are impairing the publics confidence in the regulatory process 4.10 In-Depth Review Phase In-Depth review provides a focused and detailed review and a clear and concise response to the issues.

4.10.1 Work Planning This section describes the TAR Coordinators responsibilities for scheduling and coordinating the TAR review. During the review, if the schedule for responding to a TAR needs to be revised, the change should be communicated and agreed upon with the requesting office. Once the TAR In-Depth review is initiated (see Section 4.9.3.5) and the review questions are established, as documented in the Screening and Evaluation Results memorandum, changes are not permitted other than minor editorial clarifications. If substantive changes are necessary after an issue enters the TAR In-Depth review process, the TAR should be withdrawn by the requesting office (Section 4.13 of this OI) and resubmitted as a new request.

Activities to take place under the In-Depth review are broken down into seven milestones, where T stands for time in calendar days and L is the time taken by the licensee to submit additional information, if applicable, during the review.

When no licensee information is necessary, L will be entered as 0 in RRPS (default).

In-Depth Review Milestones T=0 In-Depth review TAR Initiation T=7 Kick-off Meeting T=35+L Evaluation and Follow Up with Stakeholders T=40+L Draft TAR Response from the NRR technical staff to TAR Coordinator T=60+L NRR ET Brief T=70+L TAR Team Debrief and Call with the Licensee T=80+L Issuance of Final TAR Response

DRAFT NRR Office Instruction COM-106, Revision 6 Page 25 of 38 Figure 4. In-Depth Review Phase Flowchart 4.10.2 Establishment of TAR Review Team The TAR Coordinator will establish a TAR review team with dedicated resources necessary to accomplish reviews of the issues identified by the requesting office within 5 days of the initiation of the In-Depth review TAR. The TAR Coordinator will provide copies of the proposed TAR (Intake form and Screening and Evaluation results) to the affected organizations and request assignment of dedicated staff to the TAR review team.

The TAR review team will typically consist of a representative from the applicable technical area, the TAR Coordinator, the plant PM, and the NRR Division of Risk Assessment (DRA) Risk Analyst, if needed. The review will also include OGC and OE as appropriate. If possible, individuals from the screening and evaluation IT including the OGC representative may be retained for continuity and efficiency in processing the request. The goal of the TAR review team is to complete reviews required to support resolution of issues within 80 days unless a different schedule was agreed upon to support the requesting office. The TAR Coordinator will establish milestones and schedules in RRPS using the same EPID that was opened in the TAR Screening and Evaluation phase.

4.10.3 Kick-off Meeting The TAR review team, led by the TAR Coordinator, will conduct a kick-off meeting (this is typically a non-public conference call), with the requesting

DRAFT NRR Office Instruction COM-106, Revision 6 Page 26 of 38 office staff and the licensee. The kick-off meeting is intended to inform stakeholders that the issues have been accepted into the In-Depth Review phase of the TAR process and discuss verbally the following:

(1) The issue characterization and the questions as referred by the IT from screening and evaluation (2) The scope and depth of the review (3) Planned interim milestones and schedule and any potential challenges or new developments (e.g., licensee voluntary action)

(4) Determine if additional resources are warranted (5) Understand the licensees view of the facts, including identification of disputed facts, if any (6) If additional information will be necessary (7) Proprietary information in the review No regulatory decisions will be made in the kick-off meeting and no regulatory or enforcement debates should be conducted in this meeting. The TAR Coordinator should document the discussion from the kick-off meeting in a note to file.

4.10.4 Licensee or Stakeholder Interaction during In-Depth Review During the kick-off meeting, the NRR staff should discuss all the details of the NRCs screening and evaluation of the issue including the facts of the underlying issue with supporting references and safety significance considerations as appropriate. Offering this opportunity to the licensee early provides transparency and also opens the path for licensee clarification and additional inputs that are germane to the In-Depth review. If a licensee would like to voluntarily provide additional information, then this should be provided within 7 days to support a timely review. An extension beyond 7 days will be approved by the DORL Director in coordination with the technical division director after the impact to the schedule or significance is assessed. The additional information should then be considered through the requesting organization to verify it does not obviate the need for the TAR. Furthermore, the requesting organization should advise the NRR staff as to whether the information should be included as a part of the TAR review. If the information needs to be part of the TAR review, the response schedule should be reviewed and adjusted, as necessary.

4.10.5 NRR Staff Evaluation and Follow-Up with Stakeholders During the NRR staff review, if additional information is needed from the requesting office or an external stakeholder, the TAR review team will meet to discuss and assess how this impacts the ability to meet the established TAR

DRAFT NRR Office Instruction COM-106, Revision 6 Page 27 of 38 timeliness metrics. Additionally, the team should be aware of constraints that may exist on discussing the issues with the licensee (e.g., issues involving allegations, proprietary, or pre-decisional concerns). Following these reviews, the cognizant NRR technical staff should draft a response using the response template (Attachment C).

The TAR review team members should focus the scope of the TAR review on areas that ensure a clear and concise response can be provided to the questions identified in the TAR. The TAR response should not discuss areas outside of those required to address the TAR issues of concern. Proprietary or pre-decisional information should be handled in accordance with agency policy. Where there are differing views or disputed facts among staff and stakeholders that have a legal aspect (e.g., in understanding the licensing basis), the counsel of OGC should be sought as soon as possible and not solely when the TAR is ready for concurrence. During this review, the technical staff should keep the TAR Coordinator apprised of the review status and any issues impacting completion of the review. The TAR Coordinator will arrange for conference calls as needed throughout the technical review to keep the requesting office informed of developments in the review and to facilitate any necessary exchange of information.

4.10.6 Draft TAR Response Once the technical reviews are completed for a TAR item, team members from the technical branches document the results using the TAR Response Memorandum Template (Appendix C). The lead NRR review branch may receive inputs from other technical staff and provide a compilation. The draft TAR response should be provided to the TAR Coordinator, who will compile the final response, including inputs from other staff or organizations.

The requesting office does not concur on the TAR response; however, at this point, the TAR Coordinator should share the draft response with the requestor and requestors division management and offer 7 days to provide any comment or concerns. This will allow the requestor an opportunity to raise any concerns about the review and the TAR conclusion prior to finalization. The TAR Coordinator should promptly coordinate conference calls with the requestor, the technical staff, and OGC (if needed) to resolve any concerns or elevate the issue to management, as appropriate. After the requestors concerns have been resolved and after briefing and aligning with DORL management, the TAR Coordinator will set up the ET briefing.

4.10.7 NRR ET Brief The TAR Coordinator will schedule a briefing for NRRs ET. If there are any concerns or issues raised during the ET briefing, the TAR Coordinator should update the draft TAR response appropriately or follow-up with the technical staff for resolution.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 28 of 38 4.10.8 Team Debrief and Call with the Licensee The TAR Coordinator will schedule a team debrief with the requestor and the review team after the ET briefing, if needed. Following the team debrief, a call will be scheduled, led by the TAR Coordinator, which will include the requestor, the NRR technical staff as appropriate, and the licensee to share the conclusion and the supporting facts of the draft TAR response.

4.10.9 Issuance of TAR Response Once the team debrief is completed and the call with the external stakeholder is completed, the TAR Coordinator will then route the document for concurrence. This concurrence will typically include the lead NRR technical staff members, respective branch chiefs, and the lead NRR technical division director that conducted the review of the TAR issue. Following concurrence from the technical divisions, the TAR response will also be concurred on by NRRs enforcement specialist (if required) and OGC (no legal objection) as appropriate. The TAR Coordinator will then seek final signature authority/approval on the TAR response from the DORL Deputy Director.

The TAR Coordinator will enter the TAR response addressed to the requesting office into ADAMS, as non-publicly available, and distributed within 3 days (except for allegation-related TARs where these documents cannot be placed in ADAMS). When added to ADAMS, the title should have the following format: TAR Response (Plant or Subject under Review), Issue. Additionally, the TAR Coordinator should forward the response to the generic communications and operating experience branch staff in NRR to review the issue, considering factors that contribute to the significance of the issue and the potential for generic applicability that may have become more evident during the resolution of the technical issues. The requestor or the plant PM (depending on the process the TAR serves) should notify the external stakeholder or licensee of the exit of the issue from the TAR process.

4.10.10 Exit Path for TAR In rare circumstances, the TAR process may be exited after issues are entered and accepted into the TAR In-Depth review process as discussed below:

• The requesting office elects to withdraw a TAR (see Section 4.13 of this OI). For example, circumstances may have changed that negate the need to continue the review (e.g., licensee completes actions that correct the issue of concern) or the content/subject of the TAR requires substantive revision (see Section 4.10.1 of this OI).

• The TAR review team identifies that the TAR issue should be resolved in an alternative process (e.g., referral to the generic issues, see Section 4.3 of this OI). These situations should typically be identified and avoided during the intake or screening of issues for TAR acceptance. Guidance in Section 4.3 of this OI should be followed to close out the TAR.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 29 of 38 The TAR Coordinator and the requesting office should discuss the case-specific circumstances to discontinue the TAR review and have a mutual understanding of the basis for using the exit path strategy. It is possible that only portions of the TAR may need to be resolved through an alternate process and that the other portions could still be answered through the TAR process.

Such considerations should be discussed and agreed upon before pursuing activities.

4.11 TAR Related to Allegation A requesting organization may ask for technical assistance through the TAR process to resolve issues (including construction-related issues) raised in an allegation. The ARB with responsibility for the allegation should designate a member or the cognizant Office Allegation Coordinator (OAC) to support the TAR process. The allegation team designee should be involved in intake discussions, the integrated team and the TAR review team activities, as applicable, and should also be placed on concurrence for the Screening and Evaluation memorandum or the In-Depth Review response.

Allegation-related issues cannot be dispositioned on safety significance and licensing basis standing considerations. An allegation-related issue should be processed in the intake phase to collect facts using the Intake form (Appendix C). If the allegation is not resolved or referred to another process in the intake phase, then it should be referred to the Screening and Evaluation phase with the approval of the ARB Chairperson or a designee. An integrated team will be assembled and may include members of the ARB.

The Safety Significance Determination Tool will not be exercised for an allegation-related issue and the issue cannot be recommended for dispositioning. The safety significance assigned by the ARB as part of the allegations process will be used, to the extent that safety significance needs to be factored into prioritizing resources. The integrated team may resolve the issue (if possible), make a recommendation to refer it to another process, or make a recommendation to refer it to the In-Depth review phase. In all cases, the issue will be evaluated with respect to the TAR Acceptance criteria (Section 4.5.3), with the exception of the Safety Significance assessment. Since these issues are exempt from safety significance considerations, no approval is needed from the NRR and requesting office managements to spend resources in the In-Depth review phase. The TAR review schedules should align with the allegation team needs for a timely response in the allegation process.

TAR documentation related to allegations should be distributed on a need-to-know basis and should not be placed in ADAMS or stored on network drives. If the Intake form is used to collect information and supporting facts, these documents should not be placed in ADAMS. Additional guidance on how to handle an allegation can be found in MD 8.8, Management of Allegations. Protection of the concerned individual(s) will be maintained as provided in MD 8.8.

4.12 Deviations from the Process For various reasons, the staff may find it necessary to deviate from the process outlined above (e.g., availability of staff resources, issue complexity, etc.). As the OI is considered staff guidance, occasional variances in the process can be accommodated.

Any substantial deviations from the process will be documented in ADAMS as a

DRAFT NRR Office Instruction COM-106, Revision 6 Page 30 of 38 memorandum from the TAR Coordinator to the appropriate DORL branch chief, with description of the basis of the deviations.

In the Screening and Evaluation phase (Section 4.9 of this OI), for issues where safety significance alone is not a determining factor for significance, the integrated team should obtain approval from the NRR office director and the director of the requesting office for an exception with the concurrence of these directors on the Screening and Evaluation Results memorandum.

4.13 TAR Withdrawals There are cases where the TAR process has been initiated but is no longer warranted (applies to any phase). In these cases, the TAR should be withdrawn from the process.

The TAR Coordinator should document the justification for the withdrawal in ADAMS as a memorandum from the TAR Coordinator to the responsible DORL branch chief. This serves as a record for the resources expended on the TAR effort prior to withdrawal.

The deputy director of the requesting organization may request to withdraw the TAR (screening and evaluation or In-Depth review). This can be accomplished with an e-mail to the appropriate DORL Deputy Director. The TAR Coordinator will create an ADAMS package containing the withdrawal request and the errata or applicable information supporting the withdrawal. This also serves as a record for the resources expended on the TAR effort prior to withdrawal.

4.14 Resolving Requesting Office Disagreements on TAR Results Under circumstances where the requesting office may not align or agree with either the TAR screening and evaluation results for issues that do not meet the TAR acceptance criteria or the TAR In-Depth review response, the requesting office, with concurrence of its office director, can submit a memorandum to the TAR Coordinator identifying the need for another opportunity to review the issues with a basis of the concern. The requesting office will provide this request in a memorandum to the TAR Coordinator within 2 weeks of obtaining the screening and evaluation results or the In-Depth review final response in ADAMS. The TAR Coordinator will then forward this memorandum to the NRR Office Director with a request for an independent review of the requesting office request and basis as documented in the memorandum. For this review, the affected NRR organizations will assign staff members not assigned to the original review (IT or the In-Depth review team) and make a final determination as to whether a sufficient basis has (or has not) been established to warrant expenditure of additional NRR and OGC resources and other expertise within the TAR process. The results of this independent review should be provided within 2 weeks of the independent panel kickoff meeting and will be documented and placed in a non-public ADAMS package (except for allegation-related TARs, for which the documentation is not placed into ADAMS at all) together with the requesting office memorandum and the TAR Screening and Evaluation Results memorandum or the In-Depth Review Response that was originally provided.

The TAR Coordinator should monitor and track the progress of the process. If the independent review indicates there is sufficient basis to reopen or clarify the issue, either the original TAR will be withdrawn and the issue will be reentered as a new TAR or a clarification will be communicated to the requesting office to close out the issue. All closing documentation will be placed in a non-public ADAMS package (except for allegation-related TARs) with the requesting office memorandum, the independent panel

DRAFT NRR Office Instruction COM-106, Revision 6 Page 31 of 38 recommendations, closing clarification, and the final screening and evaluation document or the In-Depth review response, as applicable.

4.15 Continuous Improvement To promote continuous improvement of the TAR process, NRR provides quality surveys to the requesting organization upon completion of a TAR request. In addition, staff can offer suggestions for process improvement through the TAR Process Feedback Form on the TAR SharePoint site.

Further, the current revision of the COM-106 guidance includes the recommendations of internal and external stakeholders on the TIA Revitalization Project, which was executed in 2019-2020.

5. RESPONSIBILITIES AND AUTHORITIES All staff who support or use the TAR process are responsible for reading, understanding, and applying this OI. They are also responsible for identifying possible improvements to the guidance and submitting suggestions to their management or to the primary contact of this OI.

The following describes the key roles and responsibilities associated with the TAR process:

A. NRR Director (may be delegated to NRR Deputy Director)

1. Responsible for the effective implementation of the policy and procedures regarding the TAR process.

2. Grants exceptions to specific issues referred by Screening and Evaluation integrated team to move to In-Depth review, in concurrence with the requesting office director.

3. Approves an independent panel to review the issue for disagreements or concerns raised by requesting office after the TAR results are documented.

4. Engages and informs regional management or other requesting office management, ensuring agency alignment on open issues related to the items in progress in the TAR program, as needed.

B. Requesting Office Director (may be delegated to Deputy Director)

1. In collaboration with the NRR director, grants exceptions to specific issues referred by Screening and Evaluation integrated team to move to In-Depth review.

2. Approves disagreements or concerns raised by requesting office after the TAR results are documented to be raised for an independent panel review.

3. Provides support to the program as necessary and provides feedback on the program to NRR for continuous improvement from the requesting office perspective.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 32 of 38 C. NRR Division of Operating Reactor Licensing (DORL) Deputy Director

1. Develops program guidance and training to ensure the consistency of the program implementation across NRR and requesting offices, specifically for the regions (the largest internal stakeholder).

2. Periodically discusses the program with regional managers and other NRC organizations to assess the effectiveness of the program and solicit suggestions for possible improvements.

3. Helps the TAR Coordinator with the standing up of an IT for a TAR screening and evaluation expedited effort by reaching out to NRR division management and OGC for resources.

4. Recommends a Chairperson for the IT or helps the TAR Coordinator select a Chairperson for the IT.

5. Concurs and signs the In-Depth review TAR response to provide a supporting document to inform agency decisions or actions in the process the TAR serves.

D. Requesting Office Division Director (may be delegated to Deputy Director)

1. Supports the program and provides suggestions for possible improvements to the DORL management.

2. Ensures the requesting office staff are collaborating or supporting the process effectively and timely (e.g., prioritizing staff effort in screening and evaluation, communication with the licensee to get information needed, etc.)

3. Authorizes initiation of Screening and Evaluation phase of TAR by coordinating with region staff and branch chief after making the assessment the issue needs a screening and evaluation.

4. May identify disagreements with NRR TAR screening and evaluation or In-Depth review results and generate a memorandum to the TAR Coordinator for independent review with the requesting office director concurrence for NRRs consideration.

5. Authorizes and approves initiation of Construction TARs, as needed, after assessment that formal resolution is needed for a construction-related issue.

E. Chairperson of the Integrated Team

1. Convenes IT meetings.

2. Is the decision maker for the IT.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 33 of 38

3. Ensures appropriate screening and evaluation in a timely manner.

4. Ensures appropriate decision and documentation.

5. Signs the TAR Screening and Evaluation Results memorandum to provide a supporting document to inform agency decisions or actions in the process the TAR serves.

6. Works with NRR office director and the requesting office to clarify or resolve any disagreements in screening and evaluation decisions, when elevated to an independent panel.

F. DORL Branch Chief

1. Ensures that staff and other resources are provided to manage and execute the TAR program, including assignment of the TAR Coordinator.

2. Ensures TARs are making progress and timeliness goals are met and report and rectify issues working with management.

3. Serves as the process owner and ensures the suggestions for the improvement are captured and coordinate revisions to the guidance as appropriate.

G. TAR Coordinator

1. Serves as the primary point of contact for all TAR related activities and is responsible for effective implementation of the TAR program and the office guidance. The TAR Coordinator is a designated role with a designated backup assigned by the cognizant DORL branch.

2. Coordinates TAR activities with the regions, other NRC organizations and NRR staff.

3. Coordinates with staff requestors to articulate issues, formulate questions, etc. in completing TAR intake templates.

4. Assigns the TAR number, opens the EPID and assigns milestones, shepherds the TAR action from cradle to closeout and is responsible for the quality and timeliness of the TAR final documentation.

5. Tracks and reports NRRs performance through monthly reports and participating in workload management meetings.

6. Provides training and information sessions to staff as necessary.

7. Promotes continuous improvement of the program by conducting surveys and capturing feedback from various avenues and leading the periodic updates of the guidance.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 34 of 38

8. Coordinates disagreements with the requestor and the independent panel review when appropriate.

(Note: more specific TAR Coordinator activities are included in the sections above)

H. Office of General Counsel (OGC)

1. Serves as a member of the IT for screening and evaluation of the issue, reviews and provides no legal objection (NLO) on the Screening and Evaluation results memorandum, and provides legal advice.

2. Provides legal counsel on backfitting and issue finality aspects of the issue, if any.

3. Reviews TAR in--depth review response for legal adequacy and defensibility, takes part in review discussions and provides NLO on the final TAR response.

I. Office of Enforcement (OE)

1. Participates in TAR screening and evaluation or In-Depth review discussions as necessary, if the issue is related to an enforcement action.

2. Provides support with respect to the non-concurrence process and Differing Professional Opinion program, where applicable.

J. Requesting Office Staff (or Requestor) in TAR Screening and Evaluation

1. Member of the IT and participates in scoping, screening, and evaluation activities, including aligning on the path forward of the issue.

2. Responsible for collection of all information on the Intake form.

3. Helps interface with the licensee or stakeholder as appropriate.

4. Helps formulate the final TAR questions related to the issue in coordination with the IT.

5. Concurs on the Screening and Evaluation Results memorandum.

6. Identifies disagreements, if applicable, to be elevated to an independent panel after the IT decision.

K. Requesting Office Staff (or Requestor) in TAR In-Depth Review

1. Participates in kick-off and review follow-up meetings with NRR staff.

2. Helps to verify and collect new information and interfaces with the licensee as appropriate.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 35 of 38

3. Reviews draft TAR response when it is ready and coordinates the requesting office management inputs.

4. Identifies disagreements, if applicable, to be elevated for an independent panel after the TAR response issuance.

L. Requesting Office Staff (or Requestor) in Construction TAR Initiation and Processing

1. Engages with TAR Coordinator to determine a path to resolution for construction issue(s).

2. Collection of information to complete TAR intake template.

3. Interfaces with licensee or other stakeholders as appropriate.

4. Assists in articulating and formulating construction issues and questions for formal resolution.

M. NRR Technical Staff

1. Staff should work with the TAR Coordinator to ensure the process plan in RRPS is complete in scope, resources, and schedule.

2. Technical branch chiefs are responsible for assigning staff and aligning with the TAR Coordinator on the proposed milestones in RRPS.

3. Due to the expedited nature of TAR screening and evaluation, technical branch chiefs should assign dedicated resources promptly and discuss priority conflicts with the DORL branch chief.

4. Technical staff are responsible for screening and evaluation, in collaboration with the IT, which includes analysis of the issues, with consideration of safety significance, review of licensee inputs and defining the questions that need to be answered.

5. Assigned lead technical staff will concur on the documentation in both screening and evaluation and In-Depth review phases.

6. For In-Depth review, technical staff will provide inputs using the In-Depth response template to the TAR Coordinator, who will assemble the complete response.

7. For Construction TARs, assigned technical staff are responsible for developing and providing response inputs to the TAR Coordinator.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 36 of 38 N. Risk Analyst 16

1. Participates in the screening and evaluation integrated team as a member.

2. Completes the Safety Significance Determination in coordination with other SMEs and the requestor.

3. Participates in the screening and evaluation activities and aligns on the path forward in screening and evaluation with input to the documentation.

4. Concurs on the screening and evaluation documentation and the Safety Significance Determination worksheet.

5. If needed, provides inputs to the technical review during In-Depth review phase.

O. NRR/DORL Plant Project Manager (Plant PM)

1. Provides support or expertise with plant licensing basis.

2. Helps TAR Coordinator interface with the licensee or stakeholder as appropriate.

3. Participates in the activities in the screening and evaluation IT as a member and concurs on the screening and evaluation results documentation.

4. Participates in In-Depth review and concurs on the In-Depth review response.

P. NRR Subject Matter Experts 17

1. Participate as members of the screening and evaluation IT to provide specific expertise (e.g., backfitting, generic implications). A specific topical area SME will be assigned to work with the risk analyst in completing the Safety Significance Determination.

2. Participates in the screening and evaluation activities and aligns on the path forward with input or concurrence to the results documentation as necessary.

3. Support development of responses to construction-related TARs, as assigned.

16 This would typically be staff from NRR/DRA. However, there could be occasions where it is more effective to have a Regional SRA or an experienced risk analyst from RES perform this function.

17 For backfitting and issue finality discussions, SMEs are also referred to as Community of Practice points of contact.

DRAFT NRR Office Instruction COM-106, Revision 6 Page 37 of 38

6. PERFORMANCE MEASURES A TAR is considered open upon receipt of the formal request memorandum or e-mail from the requesting office at the Intake. A TAR is closed out as described in Section 4.3 of this OI with documentation. During the initial TAR discussions, NRR and the requesting organization may negotiate the priority for NRRs TAR responses based on available resources and the nature of the issue. Refer to Section 4.9.4 of this OI for considerations of priority for screening and evaluation.

Timeliness goals will be tracked for each open TAR in the NRR workload management system as follows:

Screening and evaluation kickoff 7 working days from TAR screening meeting: and evaluation initiation (EPID start date)

Screening and evaluation TAR 30 days from kickoff meeting or as completion: agreed In-Depth review TAR entrance 7 days from In-Depth review initiation meeting:

In-Depth review TAR completion: 80 days from In-Depth review initiation or as planned with licensee input consideration All intermediate milestones will be reported as status items. Exclusion or deviations will be discussed in the management meetings with the justifications and path forward.

Construction TARs initiated in accordance with the process outlined in Appendix B are expected to be completed in as timely a manner as possible in keeping with construction schedules and associated inspection and oversight. The nominal expectation for completion of construction TARs is 30 days. Other intermediate goals for Construction TAR processing are outlined in Appendix B.

For the operating TARs, NRRs performance measure is that 80 percent of the operating TAR inventory for screening and evaluation should be completed (documentation with recommendations or closure of TAR) by the established target date and 95 percent of TAR inventory for In-Depth review should be completed (closure of TAR) by the established target date.

7. PRIMARY CONTACT Booma Venkataraman 301-415-2934

8. RESPONSIBLE ORGANIZATION NRR/DORL

DRAFT NRR Office Instruction COM-106, Revision 6 Page 38 of 38

9. EFFECTIVE DATE XX/2020

10. CERTIFICATION DATE XX/2020

11. REFERENCES

• Management Directive (MD) 6.4, Generic Issues Program

• MD 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and Information Requests

• Inspection Manual Chapter (IMC) 0330, Guidance for NRC Review of Licensee Draft Documents

• IMC 0611, "Power Reactor Inspection Reports

• IMC 0612, Appendix B, Issue Screening

• IMC 0620, Inspection Documents and Records

Enclosures:

1. Appendix A - Change History

2. Appendix B - Construction TAR Process

3. Appendix C - Documentation Template Descriptions

4. Appendix D - Operating Reactor TAR Summary of Action Steps

DRAFT Appendix A Office Instruction COM 106 Change History Method Used to Announce &

Date Description of Changes Distribute Training 11/26/01 Initial Issuance E-mail to NRR staff DLPM PM Briefing 12/24/02 This Office Instruction COM-106, E-mail to NRR staff DLPM PM Control of Task Interface Briefing Agreements, update provides; 1) a general revision to increase management oversight of the process,

2) requires a statement regarding plant applicability for the TIA response, 3) adds a 30 day response requirement for the requesting organization on the draft TIA, 4) changes the goal to 80%

of the draft responses sent to the requesting organization by latest agreed upon schedule, and 5) several editorial changes.

11/30/05 The changes implement the guidance E-mail to NRR staff DORL PM in MD 8.8 and NRR OI OVRST-200 for Briefing processing TIAs related to allegations; incorporate the guidance in NRR OI LIC-401 for interacting with NRR/DIRS/OE and DPR/GCPU on potential generic issues; changes the timeliness goal for draft TIA responses to 100%, and implements the NRR reorganization. Other changes include providing a step by step process.

03/17/08 These revisions reflect the E-mail to NRR staff DORL PM reorganization of NRR and the Briefing coordination of the TIA program by the Special Projects Branch in the Division of Policy and Rulemaking and process modifications based upon a best practice examination and Regional/NRR Division feedback. The changes include the incorporation of a Concurrence Method and a Letter Method for completing TIA responses, and revised performance metrics for completion.

Enclosure 1

DRAFT Method Used to Announce &

Date Description of Changes Distribute Training 12/30/13 These revisions reflect regional E-mail to NRR staff DORL PM suggestions for improvement and Briefing lessons learned from continued use of the process, including the Concurrence Method added in the last revision. The changes include increased communication mechanisms and a restructuring that aims to better detail the process steps and differences between the Letter Method and Concurrence Method. This revision also provides consistent methods for communicating with the licensee/industry, improving the public transparency of the process.

11/20/15 This is Revision 5 of Office Instruction E-mail to NRR staff DORL PM COM-106, Control of Task Interface Briefing Agreements. Revisions reflect the OIG recommendation to revise the TIA timeliness goals as well as process modifications based upon headquarters and regional feedback and lessons learned from continued experience.

XX/XX/20 This is Revision 6 of Office Instruction E-mail to NRR staff NRR and NRR COM-106, renamed Technical Region Staff Assistance Request (TAR) Process, briefings/

with complete overhaul of Revision 5, training Control of Task Interface Agreements sessions

[TIA]. This revision merges relevant portions of the process contained in NRO Office Instruction, NRO COM 108, Revision 1, NRO Construction Inspection Interfaces with Region II.

Guidance NRO COM-108 is being rescinded. Additionally, it incorporates a new graded approach with enhanced guidance and streamlined tools to address program lessons learned to focus resources commensurate with the significance of the issue and meet stakeholder needs effectively and efficiently.

-A2-

DRAFT Appendix B Office Instruction COM-106 Construction TAR Process Introduction A construction TAR is the mechanism that NRC personnel (usually construction inspectors) use to formally clarify construction-related technical or inspection requirements for facilities licensed and built under the purview of the Office of Nuclear Reactor Regulation (NRR). The construction TAR process is used to facilitate the assignment of appropriate resources to respond to an identified issue in a timely manner, and to provide a method to document the resolution of the issue for future reference.

Construction TARs are processed in a unique manner compared to non-construction TARs because construction TARs typically require resolution in a much shorter time frame. This allows construction inspection activities to remain aligned with a rapidly evolving construction environment. Expediting construction TARs enables construction inspectors to perform required inspections while structures, systems, and components (SSCs) are accessible, and provides licensees or construction permit holders regulatory clarity and confidence that construction activities will not be adversely impacted. The overall goal is to resolve construction TARs by an agreed upon due date (nominally 30 days) that supports the construction inspection schedule.

Processing Construction TARs

1. Intake and Pre-screening.

a. Complete Intake Form. The construction TAR requestor initiates a construction TAR by completing a TAR Intake Form (template) in accordance with Appendix C and Section 4.8 of this OI. The requestor designates the TAR as a construction TAR by checking YES in field #10 of the template. Note that the low safety significance issue resolution (LSSIR) portion of the template is not applicable to construction TARs.

b. Perform Pre-Screen. Pre-screening of the construction TAR is accomplished by the TAR Coordinator with the assistance of the construction TAR requestor in accordance with the pre-screen instructions of this OI. Supporting information is compiled for detailing and articulating the specific construction issue(s), and technical questions related to the issue are formulated. Pre-screening of construction TARs should be accomplished within 1 working day of receiving the completed TAR Intake Form.

c. Obtain Management Approval. Construction TAR submittal is approved by the requestors branch chief.

d. Enter TAR into TAR Database. The TAR Coordinator will log the TAR in the database.

2. Construction TAR Evaluation

a. Establish Need Date. The TAR Coordinator and the construction TAR requestor establish a need date for resolution of the construction TAR. The need date should be Enclosure 2

DRAFT established such that the impact on construction of the facility and performance of construction inspections is minimized.

b. Identify Technical Support. The TAR Coordinator identifies the NRR branch or organization that has the technical expertise to support resolution of the construction TAR. This may require multiple branches or organizations depending on the complexity of the construction TAR.

c. Conduct Initial Meeting. The TAR Coordinator facilitates a meeting or phone conference with the construction TAR requestor and the cognizant technical branches or organizations. The purpose of this meeting is to ensure that the technical staff responsible for evaluation of the construction TAR fully understand the construction TAR questions and the need date. This meeting should occur within 5 working days of construction TAR initiation, or sooner depending on the construction TAR need date. If necessary, the construction TAR requestor changes the construction TAR questions as agreed upon in this meeting.

d. Perform TAR Evaluation. The technical support branches or organizations complete the construction TAR evaluation. The evaluation should be complete by the TAR need date or as soon as possible if the need date cannot be met. If an extension is needed beyond the nominal timeliness of 30 days, or the established need date, then the TAR Coordinator should work with the requestor, NRR staff, and management as needed, to establish an acceptable new need date. A new need date will be assigned, taking into consideration other technical support staff priorities.

e. Conduct Resolution Meeting. The TAR Coordinator facilitates a meeting or phone conference with the TAR requestor and the technical support staff. The purpose of this meeting is to ensure that the construction TAR evaluation provided by the technical support staff fully answers the construction TAR questions and to identify any additional questions that need to be answered to resolve the underlying issue. The TAR Coordinator may engage OGC counsel to review the TAR response, as necessary. The output of this meeting is either a finalized construction TAR evaluation or an amended construction TAR with additional questions.

f. Perform Additional Evaluation. If the construction TAR is amended in step e. to request additional information, or if it is determined that additional questions need to be answered, an Additional Evaluation should be conducted if:

1) this is the first additional evaluation, and

2) the additional evaluation will not challenge the need date for the TAR response in support of construction inspection activities.

If either criterion is not met, then an executive manager (Director level) briefing will be conducted with NRR and the requesting office to determine if an additional evaluation need to be conducted, and what/how additional questions will be answered.

-B2-

DRAFT

3. Completing the Construction TAR

a. Logging the TAR Evaluation. Once the construction TAR evaluation is finalized, the TAR Coordinator will close the TAR in the database.

b. Uploading to ADAMS. The TAR Coordinator will ensure that the completed construction TAR and supporting documentation is uploaded to non-public ADAMS and distributed appropriately, except for allegation--related TARs where the documents cannot be placed in ADAMS.

-B3-

DRAFT Construction TAR Process Initial Coordination Constructionrelated Technical Meeting:

Issue Identified (COM (TAR Coordinator, 106, Section 4.8) Requestor, Tech Staff)

Perform TAR Construction TAR Evaluation(s) (Tech Process Staff, et. al) and Initiated Additional Evaluation as necessary Resolution Meeting:

Complete Intake (TAR Coordinator, Template: Refine Requestor, Tech Staff, and Issue/Question(s) OGC as needed)

Management Approval TAR Database Entry No Consensus/

Agreement?

Evaluation:

Establish Need Yes Date ID Tech Staff Completion &

Closeout: Database, ADAMS Entry by TAR Coordinator

-B4-

DRAFT Appendix C Office Instruction COM-106 Documentation Template Descriptions

1. TAR Intake Form with Instructions (non-public ADAMS Accession No. ML)

As described in Section 4.8.2 of this OI, the Intake Form is a tool for NRR to collect facts relevant to the issue for consistency and efficiency. The requesting office will complete the information with TAR Coordinator assistance in the Intake phase, using the TAR Intake Form in ADAMS or located on the internal TAR SharePoint site:

https://usnrc.sharepoint.com/teams/NRR-Technical-Assistance-Request

2. TAR Screening and Evaluation Authorization Email Template (non-public ADAMS Accession No. ML)

For moving an issue to TAR Screening and Evaluation, as described in Section 4.8.3 of this OI, the requesting office division management should submit an e-mail to the DORL division management using this NRC Screening and Evaluation Authorization E-mail template.

3. TAR Screening and Evaluation Results Memorandum Template (non-public ADAMS Accession No. ML)

As described in Section 4.9.3, in the Screening and Evaluation phase of TAR, the integrated team will document the results, using this template to inform the requesting organization of the results and recommendations.

4. TAR Safety Significance Determination- Quick Reference Guide, Background, and Basis (ADAMS Accession No. ML)

This document guides the risk analyst and topical area subject matter expert in performing a safety significance assessment, as part of the screening and evaluation effort. The assessment includes issue description, assessing the associated change in risk, assessing safety margins and defense-In-Depth, addressing opportunities for feedback, and assimilating the information to form the basis of the recommendation to the integrated team. For each element, several different options are provided based on existing regulatory guidance. The background and basis portion address more detailed aspects of implementing the approach, including addressing specific items that have arisen during the development and early implementation of the approach.

5. TAR Safety Significance Determination Template (ADAMS Accession No. ML)

This document provides a template that can be used by the risk analyst and topical area subject matter expert in documenting the safety significance assessment as part of the screening and evaluation effort. The completed template can then be attached to the screening and evaluation results memorandum as the basis for safety significance determination or uploaded to non-public ADAMS separately.

Enclosure 3

DRAFT

6. TAR In-Depth Review Response Memorandum Template (non-public ADAMS Accession No. ML)

The results of the In-Depth review will be documented using this memorandum template.

The TAR response will consist of a short concise summary of the review results and, if possible, consist of a Yes or No type response to the questions posed or issues identified. A summary of the issue of concern need not be repeated, as this information is documented by the requesting office on the TAR Intake form. The draft response should state the facts reviewed, brief issue statement, and the conclusion with the facts supporting the answer. The response should include supporting information as attachments including the screening and evaluation results.

The support information should identify meetings or conference calls held for the TAR issues with the licensee and relevant information used in the conclusions.

-C2-

DRAFT Appendix D Office Instruction COM-106 Operating Reactor TAR - Summary of Action Steps No. Action Action-taker General (Gen) Program Actions:

Gen1 Maintain a log of completed and active TARs on SharePoint TAR Coordinator Gen2 Perform periodic NRR Executive Team briefing on active TARs TAR Coordinator Gen3 Submit status report for monthly NRR workload meetings TAR Coordinator Intake (Int) Phase: ( 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> level of effort)

Int1 Initiate a TAR via email to the TAR Coordinator, using a partially-populated RO Staff/BC TAR Intake form Int2 Assign a TAR # to the incoming, add to TAR log, and notify DORL BC and TAR Coordinator management of the incoming and identify schedule priorities Int3 Review TAR Intake form, and discuss pre-screening applicability criteria TAR Coordinator including acceptance (Section 4.2 - 4.5) with RO (as necessary)

Int4 If a decision has been reached to close the TAR, proceed to closure at the TAR Coordinator bottom of this table (Closure Outcome 1 or 2)

Int5 Complete TAR Intake form with all supporting documents and factual TAR Coordinator information from all relevant sources 18 (put package in non-public ADAMS) and RO Int6 Obtain RO management authorization to proceed to Screening and TAR Coordinator Evaluation if acceptance criteria are met and RO Int7 Grant authorization to proceed to S&E and request to DORL management RO Division to move issue to next phase (S&E initiation) Management Screening and Evaluation (S&E) Phase: ( 30 days from S&E Integrated Team (IT) Kickoff Meeting) 19 S&E1 Identify and engage the SES Chairperson for the Integrated Team with TAR Coordinator DORL management support S&E2 Obtain an EPID through RRPS (non-fee-billable charge code), including TAR Coordinator establishment of milestones S&E3 Stand up the IT 20 (within 7 working days of S&E initiation) TAR Coordinator S&E4 Work with the RO and/or plant PM (when relevant) to hold a conference TAR Coordinator call (typically non-public) with the licensee regarding the start of a new TAR S&E5 Lead the IT Kickoff Meeting Chairperson and TAR Coordinator S&E6 Hold meetings or calls as necessary to expeditiously scope the request TAR Coordinator and iterate and frame appropriate unresolved TAR questions and IT members S&E7 Engage licensee, if relevant (e.g., if there are disputed facts). 5 days or as TAR Coordinator, IT, agreed to voluntarily submit any new information with respect to the Intake and licensee form 21 S&E8 Assess the issues significance using the TAR Safety Significance Risk analyst and Determination Instructions and associated Template Topical SME 18 Assumes licensee information collected prior to entering intake 19 Days are calendar days unless specifically mentioned otherwise 20 Integrated Team: Lead Chairperson (typically an SES executive), TAR Coordinator, DORL plant PM, RO staff, NRR topical SME, SME (backfitting, generic concerns etc.), OGC, OE (if required), and NRR risk analyst(s) 21 Additional voluntary information from the licensee may be submitted by e-mail.

Enclosure 4

DRAFT No. Action Action-taker S&E9 Perform screening for referral to other processes or evaluate for early IT resolution if easily achievable, including review of LB standing with the gathered facts S&E10 IT holds interim meeting to discuss ongoing assessment and refine IT and Chairperson understanding of issue, as needed, and holds a meeting to align on the path forward with the Chairperson as the decision-maker. IT will document the results and conclusion in the Screening and Evaluation Results Memorandum 22 to the RO S&E11 If the IT concludes the TAR should be closed, proceed to closure at the TAR Coordinator bottom of this table (Closure Outcome 1, 2 or 3) using the Screening and Evaluation Results Memorandum Template, including licensee notification (when relevant) through the RO and/or plant PM S&E12 If the IT has reached an impasse, elevate to resolve disagreements Chairperson, TAR (optional guidance) Coordinator, Office management S&E13 If an exception to the entrance criteria for In-Depth review is being TAR Coordinator pursued, take associated actions of seeking higher authorization at office director level from both NRR and RO organizations S&E14 If the issue should proceed to an In-Depth review, the Screening and TAR Coordinator Evaluation Results Memorandum should document the acceptable questions for the In-Depth review and notify RO Division management (In-Depth review initiation)

S&E15 Distribute Screening and Evaluation Results Memorandum to RO and TAR Coordinator others (non-public in ADAMS)

In-Depth Review (IDR) Phase: ( 80 days from IDR Initiation)

IDR1 In-Depth Review Phase initiation and status the EPID for continuation of TAR Coordinator TAR IDR2 Identify the TAR review team 23 TAR Coordinator IDR3 Facilitate a kick-off meeting or call (non-public typically) with the requestor TAR Coordinator and the licensee, and TAR review team, share relevant information and TAR questions IDR4 Licensee additional information 7 days or as agreed upon Licensee IDR5 During evaluation of the issue, facilitate follow-ups with RO and OGC, as TAR Coordinator needed IDR6 Compile draft TAR response and transmit to RO for 7-day comment TAR Coordinator period 24 IDR7 Transmit comments on draft TAR response to TAR Coordinator RO IDR8 Schedule and facilitate an NRR Executive Team alignment brief TAR Coordinator IDR9 Schedule and facilitate a de-brief with the RO and review team TAR Coordinator IDR10 Schedule a call with the licensee and share conclusion and facts of the TAR Coordinator draft TAR response with NRR technical staff in attendance IDR11 Record the In-Depth review result and conclusion using the In-Depth TAR Coordinator Response Memorandum Template. Route the TAR response for concurrence, including NRR, OGC (NLO), and OE (as needed)

IDR12 Sign final TAR response addressed to RO Division management DORL Deputy Director 22 IT concurs on the Screening and Evaluation Results memorandum 23 TAR Review team (In-Depth review): TAR Coordinator, DORL plant PM, NRR technical staff, OGC, OE (if required) 24 RO does not concur on IDR TAR response

-D2-

DRAFT No. Action Action-taker IDR13 Distribute the IDR TAR response to RO and others (non-public ADAMS) TAR Coordinator IDR14 Proceed to closure below (Outcome 1 or 2) TAR Coordinator IDR15 RO staff or DORL plant PM notifies licensee (if relevant) of closure of the RO staff or DORL TAR plant PM Closure (Clo):

Clo1 Close the TAR in the log with one of the three possible outcomes:

1. Issue is resolved including response to the requesting office

2. A recommended referral is made to another process

3. The issue is recommended for no further action based on safety significance and licensing basis standing DORL = NRRs Division of Operating Reactor Licensing IT = Integrated Team RO = Requesting Office SME = Subject Matter Expert TAR = Technical Assistance Request TAR Coordinator = Technical Assistance Request Program Point of Contact and Coordinator

-D3-

DRAFT TAR Safety Significance Determination - Quick Reference Guide, Background, and Basis

DRAFT Rev. 7 - June 10, 2020 TAR Safety Significance Determination - Quick Reference Guide, Background, and Basis (ADAMS Accession No. ML)

A documentation template is provided separately in ADAMS Accession No. ML Quick Reference Guide Figure 1: Overview of the Worksheet Process Guidance regarding purpose, workflow, peer review, etc., is provided in the Background & Basis section, which immediately follows this quick reference guide.

Section A - Issue

Description:

Some aspects of issue characterization will already be documented as part of the overarching process that led to this significance determination (e.g., the intake form from NRR Office Instruction COM-106). Use the associated safety significance determination template (contained in the same ADAMS package) to document basic information about the issue. This step relies on good communication at multiple steps as discussed in the Background & Basis.

Section B - Associated Change in Risk Using one of the following approaches as a guide, document the basis for why there would be, or would not be, a significant increase in risk to the public, should the issue be dispositioned without further action.

Approach B1 - Inspection Guidance / IMC 0609 (preferred approach)

Approach B2 - Risk Triplet Discussion Approach B3 - Scoping PRA Estimate Each approach is described further in the Background & Basis document. This stage of the process should lay the groundwork for identifying those elements of plant response that are and are not captured by the evaluation of the change in risk, thus establishing where overlaps in the risk, safety margin, and defense-in-depth evaluations exist. Alternatively, if it can be shown that there is no identifiable increase in risk, or a decrease in risk, associated with the issue, that should be documented in lieu of, or in conjunction with, following one of these approaches.

Worksheet - Page 1

DRAFT Rev. 7 - June 10, 2020 Section C - Safety Margin Using one of the following approaches, and specifically considering the extent to which the assessment of risk significance informs the present element, document the basis for why there would, or would not be, significant erosion of safety margin in risk-significant SSCs or plant capabilities, should the issue be dispositioned without further action.

Approach C1 - Risk Triplet (preferred approach)

Approach C2 - 50.69 Categorization Approach C3 - LIC-504, Revision 5, Appendix E, Section 2.3 Each approach is described further in the Background & Basis document. The analyst needs to make a distinction between instances where degradation of engineering margin impacts the overall finding that the facility poses no undue risk, versus instances where it does not. The integration of safety margin with risk information and defense-in-depth is the means of making this more holistic assessment. Erosion of safety margin already adequately captured by the risk assessment should be documented here, but not double counted. Alternatively, if the risk assessment adequately captures all significant elements of safety margin, that should be documented in lieu of, or in conjunction with, following one of these approaches.

Section D - Defense-in-Depth:

Using one of the following approaches, and specifically considering the extent to which the characterization of risk significance and safety margin has informed the present element, document the basis for why there would be, or would not be, significant erosion of defense-in-depth should the issue be dispositioned without further action.

Approach D1 - Regulatory Guide 1.174, Rev. 3, Section 2.1.1.3 (preferred approach)

Approach D2 - 50.69 Categorization Approach D3 - 50.69 Guidance - NEI-00-04, Revision 0, Section 6 Each approach is described further in the Background & Basis document. The degree to which defense-in-depth should be viewed as something that is being established (a licensing perspective) versus something that is being eroded (an oversight perspective) will depend on the nature of the issue. Limitations in the risk assessment should be considered in the assessment of defense-in-depth. Conversely, facets of defense-in-depth erosion already adequately captured by the risk assessment (e.g., general common-cause failure mechanisms, a particular electrical board being required for successful operation of multiple pieces of equipment) should not be double-counted. Alternatively, if the risk and safety margin assessment adequately captures all significant elements of defense-in-depth, that should be documented in lieu of, or in conjunction with, following one of these approaches.

Section E - Performance Monitoring / Feedback:

Using one of the approaches below, document the basis for why there would be, or would not be, sufficient performance monitoring (feedback) opportunity via other mechanisms inherent in the situation. To be relevant, these feedback mechanisms would need to reasonably reveal to Worksheet - Page 2

DRAFT Rev. 7 - June 10, 2020 the NRC staff significant mistakes in judgment associated with dispositioning the issue without further action, prior to an unacceptable outcome.

Approach E1 - Oversight Approach E2 - Regulatory Reporting Approach E3 - A more generic feedback mechanism No feedback opportunity Put differently, if a determination to sunset the issue is reached, and if that determination turns out to be ill-founded, are there feedback mechanisms that will re-focus the agencys attention on the issue? This step is not intended as an opportunity to leave the issue open beyond its disposition, but rather to arm the decision maker with the knowledge of whether this type of feedback exists.

Section F - Wrap-up:

Prior to making a determination, document the known sources of uncertainty (parameter, modeling, and/or completeness) that have not been captured in the foregoing documentation and would be expected to significantly influence the foregoing evaluation. The purpose of doing this is not to drive the outcome, but rather to ensure that future readers remain aware of the associated uncertainties at the time the determination was reached.

Based on the totality of the foregoing information, and from the perspective of whether the agency should expend significant additional resources investigating this issue (versus other issues), document whether the issue has apparent safety significance in each of the assessed areas. The documentation template offers suggested language.

If the issue was judged to be clearly of very low safety significance, 1 it should be recommended for disposition on the basis of this evaluation. If one or more does not entries have been selected, the issue may still be of very low safety significance, but a higher level of buy-in amongst the integrated team may be needed to disposition the issue on the basis of this evaluation.

Separately, if the assessment cannot conclude that the issue is of very low safety significance, yet it is apparent that the issue does not have sufficient significance to meet the Safety Goal Evaluation criteria in NUREG/BR-0058, Draft Revision 5 (Section 2.4, and Figure 2-3 therein),

this should be documented. The intent is to document cases where it is clear how such an evaluation would turn out, so as not to lose that insight. In some cases, the TAR safety significance evaluation will not provide sufficient information to draw a conclusion in this regard.

While exploration of the issue would nominally proceed, this additional information may guide the level-of-effort later, should it become evident that the issue is likely outside of the current licensing basis.

1 It is acknowledged that differing agency processes use differing terminology with respect to safety significance.

Here, very low safety significance is generally intended to mean a level of safety significance where the agency would be unlikely to take further regulatory action or require additional assurance. Relative to processes that use a binary description of safety significance (e.g., 10 CFR 50.69), this would be the lower bin. Relative to processes that use a tertiary (or higher) description of safety significance (e.g., IMC 0609, LIC-504), this worksheet would view very low safety significance to be the lowest of these bins.

Worksheet - Page 3

DRAFT Rev. 7 - June 10, 2020 The above assessment should reflect an agreement between the risk analyst and the topical area subject matter expert. If alignment cannot be reached, the safety significance should be considered indeterminate, or alignment should be sought by engaging the integrated team. If others involved in the assessment have a differing view, that should be communicated to the integrated team but otherwise pursued through the agencys broader differing views process.

Worksheet - Page 4

DRAFT Revision 7 - June 10, 2020 Background & Basis General:

• Purpose - The purpose of this worksheet is to guide a structured approach to assessing the safety significance of an emergent plant-specific issue that has entered the TAR process. It guides the involved staff in considering the right facets, engaging the right counterparts (e.g., the requesting office, the TAR integrated team), and documenting the right considerations. It envisions a level-of-effort and level-of-rigor that is more than a back of the envelope or value judgment exercise, but less than a LIC-504 evaluation, 2 a Regulatory Guide 1.174 evaluation, or a Significance Determination Process detailed risk evaluation. The ultimate decision on whether an item has sufficient safety significance to warrant further agency resource expenditure necessarily requires judgment.

• Desired outcome - A completed and documented analysis that has engaged the issue owner up-front, considered real-time feedback from the broader integrated team, and resulted in a determination by the risk analyst 3 and topical area subject matter expert (SME).

• Terminology: safety-significance vs. risk-significance - This worksheet uses the term safety significance in lieu of risk significance in a manner consistent with NRR Office Instruction LIC-504, Revision 5, which states that, in addition to considering changes in risk, one must ascertain that degradations to safety margins and defense in depth are minimal.

• Terminology: Use of the term Very Low - Different agency processes use terms like low to very low to mean similar things. Choice of wording is often driven by other contextual factors, rather than the denotation of the words. Here, the term very low is used to mean that an issue has insufficient safety significance to warrant further agency resource expenditure. This process is not to be used re-calibrate the thresholds associated with any other particular process. Figure 2 illustrates the differing terminology used in various NRC processes, in the context of risk-significance. This figure is based on CDF, but the same concepts apply to large early release frequency.

• Workflow - Regarding how to manage the work associated with this safety significance determination, Table 1 provides a suggested workflow. The risk analyst and topical area SME should approach the work in the way that is most efficient for their work style and availability. However, attention should be paid to how resources are being expended, since this process is a prioritization of resources and not a solution to the question or issue being posed. If a conclusion of very low safety significance cannot be determined within a total level-of-effort of (approximately) 10 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, the issue is likely not 2 This primarily refers to a LIC-504 evaluation following the guidelines in Appendix C or D of that document. A LIC-504 evaluation associated with an issue that is determined to be of very low safety significance may in fact be analogous to the treatment intended here.

3 It is generally envisioned that the role of risk analyst will be filled by a qualified risk and reliability analyst from the Division of Risk Analysis. There may be instances where it is more efficient to have a Regional Senior Reactor Analyst fill this role.

Instructions - Page 1

DRAFT Revision 7 - June 10, 2020 clearly of very low safety significance, and a recommendation of indeterminate should be made to the integrated team.

• Flexibility in selecting an approach - For each section of the evaluation, the approach that is most suitable to the issue being evaluated should be selected. It is acknowledged that different approaches could lead to different outcomes, and this is judged to be an acceptable limitation, relative to the benefit of using existing approaches and promoting flexibility for the user. In anticipation that the process will be used most often in an inspection context (but with unresolved licensing basis aspects), Approach 1 from each element is the preferred approach (i.e., the approach that is most widely suited for this context). That said, the decision of which approach to use for each element is ultimately left up to the user. In rare cases, it may make sense to use a combination of approaches.

Figure 2: Illustrative Comparison of Varying Process Terminology

• Uncertainty - The worksheet does not include a specific step associated with treatment of risk uncertainty (in contrast to DID or SM uncertainty), but it does include some aspects of how one accounts for uncertainty in risk-informed decisionmaking. More specifically, the risk evaluation can provide information about parameter and model uncertainty, via propagation of individual parameter uncertainties and conduct of sensitivity analyses. However, this is left here to the users judgment as to whether that is a necessary step of this resource prioritization determination. Meanwhile, the elements of safety margin, defense-in-depth, and performance monitoring are primary Instructions - Page 2

DRAFT Revision 7 - June 10, 2020 means (in general) of accounting for completeness uncertainty. These concepts are discussed in detail in NUREG-1855, Revision 1 (e.g., see Figure 2-1 and Section 2.3 of that document). The user is directed to document significant sources of uncertainty that are not otherwise considered in Section F.

• Peer review - Evaluations performed using this worksheet that lead to sunsetting an issue (partially) based on its safety significance would not generally fall under the auspices of ADM-405, NRR Technical Work Product Quality and Consistency, in that an issue would not be clearly of very low safety significance if the evaluation was technically complex, involved new methodologies/technologies, represented a significant departure from past activities, or fit one of the other descriptors in Section 4.1 of that document. That said, and as ADM-405 states, if judgment plays a substantial role in the COM-106 response, or otherwise meets the characteristics described in Section 4.1 of ADM-405, the evaluation could be subject to that guidance. In this case, the risk analyst and topical area SME should identify the need for a peer review to the Integrated Team Chair, and seek their approval to initiate a review using the guidance in ADM-405. They should also notify their branch chiefs of this recommendation.

Table 1: Suggested Workflow Activity Participants1: Total effort (hrs)

Review intake material and other background R, S 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Part One: Sync-up and analysis:

0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Call with issue owner or integrated team to assure I, R, S 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> understanding of the concern and its implications 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Risk analyst and SME perform initial evaluation of risk, R, S 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> safety margin, and defense-in-depth 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Discuss Section B-D results, as well as Section E R, S 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Offline: Follow up on any open items R, S 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Part Two: Refinement and finalization 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Brief out preliminary results to broader integrated team I, R, S Separate 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Perform any additional work prompted by the above R, S 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Update writeup, complete Section F, and sign R, S 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Total hours 15 hrs 1 I = integrated team; R = risk analyst; S = topical area subject matter expert Section A - Issue

Description:

• Communication and coordination - For inspection issues, this step relies on good upstream interactions between the inspector and the regional SRA to arrive at an understanding of the degraded condition and how it impacts the plant response. This is not an activity that can be done solely by either party, as it requires judgment about how the condition will affect various functions in concert with an understanding of how those functions relate to a broad array of postulated accidents. Further, this step relies on a good handoff of that information to the individuals performing the safety significance determination here. The integrated team kickoff meeting is the prime opportunity for this, but the risk analyst should also consider reaching out to the regional SRA. All of the above is made more difficult in situations where the nature of the condition and its Instructions - Page 3

DRAFT Revision 7 - June 10, 2020 impact on plant response is still evolving. For this reason, it is also important that any key assumptions made at this point in the process are documented.

• Additional Issue Complexities - This entry is intended to capture any synergistic effects that are known about the issue that would demonstrably cause its safety significance to otherwise be under-represented. It should not go beyond the typical tenets of the routine process that referred the issue to TAR (e.g., for an inspection issue it should not aggregate disparate concerns or factor in aspects beyond the licensees ability to foresee and prevent). It is not intended to be open-ended, and any information captured should have a clear nexus to the issue's safety significance. An example of a legitimate synergy would be an issue relating to the plants ability to mitigate an accident during a particular configuration, when combined with the knowledge that the plant routinely enters that configuration without factoring this issue in to the risk management assessment (e.g., concern about monitoring level at mid-loop for a plant that routinely does early mid-loop operations).

Section B - Associated Change in Risk Approach B1 - Inspection Guidance - Using IMC 0612 and the relevant attachments and appendices to IMC 0609, determine if the issue would meet the criteria for minor. If it would not, determine if the proximate and posited degraded condition would (were the issue to have an associated performance deficiency) screen out of warranting additional evaluation (i.e.,

would be a finding of very low safety significance without the need to proceed to a Phase 2 assessment, a Detailed Risk Evaluation, or an Appendix M evaluation). In general, issues within these categories (minor or not requiring additional evaluation), would be expected to result in changes in risk to the public that would support a determination of being clearly of very low safety significance. Avoid using the SDP color scheme. If the issue would not screen out due to limitations in the coarse nature of that guidance, but is nevertheless of very low risk significance, consider using one of the other two approaches outlined below.

Approach B2 - Risk Triplet Discussion - Relate the issue to its proximate impact on the plant, by characterizing (i) what can go wrong, (ii) how likely it is to occur, and (iii) what the consequences would be. More specifically, describe qualitative or semi-quantitatively how the issue would be expected to manifest in (i) an increase in initiating event frequency, (ii) a decrease in the capability of specified SSCs or operator actions to mitigate an accident, and (iii) the consequences associated with an accident. When applicable, characterize the fraction of time that, and the circumstances under which, the issue is relevant. Place the above impacts in the context of their relative plant-specific risk significance (e.g., using the Plant Risk Information E-Book), and make a judgment as to whether this risk is generally above or below the level at which the agency would typically respond (e.g., reactive inspection criteria in Management Directive 8.3) or approve a license amendment (e.g., within Region III of RG 1.174, Revision 3). Based on the totality of information, and using judgment, decide if the assessed change in risk would support a determination of being of very low safety significance.

Approach B3 - Scoping PRA Estimate - Identify the impacts of the issue on initiating event likelihood, impairment of SSC functionality, impairment of operator action reliability, and/or other aspects of how the issue affects risk to the public. Perform Standardized Plant Analysis Risk (SPAR) model calculations to identify the highest contributing core damage accident sequences and cut sets for the change in risk. Consider whether these high-contributing accident sequences would contribute to large early release frequency. Characterize the significance of the estimated increase in risk using the guidance in LIC-504, Revision 5, or Instructions - Page 4

DRAFT Revision 7 - June 10, 2020 Regulatory Guide 1.174, Revision 3. For the purposes of this evaluation, this characterization represents the risk significance, not the overall safety significance. That said, for a resulting change in risk that is below the LIC-504, Revision 5, criterion of very low safety significance or within Region III of RG 1.174, Revision 3, the assessed change in risk would support a determination of being of very low safety significance.

Additional points of clarification and background on the above approaches:

• Exposure Time - Processing of findings often includes the concept of exposure time, i.e., that the degraded condition only persisted for a finite period of time. The term Exposure time is defined in IMC 0609, while the RASP Handbook includes instructions on how to estimate exposure time when it is not specifically known. Conceptually, the use of exposure time implies that the degraded condition has already been fixed. Here, it is quite possible that the condition will not be fixed (or at least that the agency will have no plans to confirm completion of the fix). In such cases, it may be necessary to assume an indefinite exposure time, and this alone may invalidate the utility of using some of the SDP screening questions. In such instances, the analyst may be better served by using Approach B3, because: (a) the IMC 0609 infrastructure is designed around a finite 1-year assessment cycle in SDP that also presumes the issue has been entered in to the corrective action program and (b) the Regulatory Guide 1.174 and LIC-504 processes are designed to compare to annualized risk measures.

• SDP Independence - Care should be taken to not imply that an SDP is being conducted, but rather that the tools associated with SDP are being utilized. This is most easily accomplished by not invoking the SDP color schemes. IMC 0308, Attachment 3 (issued June 2016) states, The color of an SDP result carries with it an assurance that all of the specific applicable process provisions of the overall SDP have been met. Other forms of significance determination may not have the same process attributes, definitions, or assurances, and therefore should not be characterized using the SDP color scheme Keeping the SDP color scheme independent from other forms of significance determination also aids in ensuring clear and consistent public representations that inspection findings with colors are inputs to the ROP assessment of licensee performance.

Section C - Safety Margins Approach C1 - Risk Triplet - Using engineering judgment, articulate why the erosion of safety margin (e.g., the degree to which the factor-of-safety has been reduced for an affected system) does or does not lead to an important change in (i) initiating events that can occur; (ii) SSC and operator response to postulated beyond design basis accident sequences; and (iii) the potential consequences from these accident sequences. Recognizing that the degree of margin above the design envelope is often not precisely known, articulate whether the degradation is likely in a regime more proximate to expected nominal performance versus expected failure, and describe the extent to which the potential degraded performance is or is not explicitly captured by the risk assessment. Further, assess to what extent the change in likelihood, mitigation, or consequence caused by the degraded margin translates to a change on the facilitys overall impact on public health and safety. Based on the totality of information, and using judgment, decide if the assessed erosion of safety margin would support a determination of being of very low safety significance.

Instructions - Page 5

DRAFT Revision 7 - June 10, 2020 Approach C2 - 50.69 Categorization - If the licensee has an approved 10 CFR 50.69 program, and it has categorized the relevant functions and systems under that program, identify whether the degraded plant response associated with the issue exclusively involves SSCs categorized as RISC-3 or RISC-4 (i.e., LSS in the 50.69 binning scheme). If this is the case, and given the way in which that program considers safety margin in categorization, the issue would be expected to result in a degree of safety margin erosion that would support a determination of being of very low safety significance.

Approach C3 - LIC-504, Revision 5, Appendix E, Section 2.3 provides a discussion of safety margin that can be used to frame this assessment. Based on the totality of information, and using judgment, decide if the assessed change in safety margin would support a determination of being of very low safety significance.

Additional points of clarification and background on the above approaches:

• Meaning and use of the term safety margin - The term safety margin is often used to describe two related, yet separate, concepts. Codes and standards routinely refer to terms-of-art like margin-of-safety and safety factor (and at times safety margin) to articulate (for instance) that degree of cushion that exists between a prescribed load and an estimated capacity. This is usually done in the context of a particular structure, system, or component (SSC) or a particular analysis, and reflects the traditional engineering practice of over-designing in light of uncertainty (i.e., engineering margin).

The NRC continues to rely on this engineering practice as part of ensuring that plants are licensed safely. Meanwhile, as part of risk-informed regulation, the Commission and staff have routinely emphasized that risk information be used in conjunction with traditional engineering practices in ensuring no undue risk. In the 1995 Commission Policy Statement on use of probabilistic risk assessment (PRA), the Commission used the terms defense-in-depth and engineering margin to describe these traditional practices. Meanwhile, in subsequent regulatory guidance (e.g., Regulatory Guide 1.174) and its common description of integrated (a.k.a., risk-informed) decision making, the staff has used the terms defense-in-depth and safety margin. Thus, the intersection of the different terminology has become blurred. Clearly the use of engineering margin in the context of a particular SSC or analysis has a nexus to safety margin in terms of a plant-wide safety impact that might cause undue risk, when considered in an integrated fashion with PRA results and defense-in-depth. One can think of the former as a constituent contributor to the latter. Alternatively, one can think of individual instances of engineering margin as potential influencers on overall safety margin, depending on whether that particular SSCs margin erosion is important to public health and safety (not all SSC margin is influential to overall safety). In identifying what specific constituent margins are of relevance to the issue at hand, it may be helpful to refer to discussions of safety margin such as that contained in Inspection Procedure 71111.21M. However, this margin should not be open-ended, but rather should be tied to particular assumptions in the risk assessment, or related to an impact on public health and safety that the risk assessment did not address. In other words, when assessing a specific issues significance, one should develop an understanding of what margin (analytical, operational, maintenance-oriented, or otherwise) is being eroded, but ultimately the erosion of that individual margin must be viewed in terms of its impact on facility safety.

Again, LIC-504, Revision 5, Appendix E, Section 2.3, provides additional discussion.

Instructions - Page 6

DRAFT Revision 7 - June 10, 2020 Section D - Defense-in-Depth Approach D1 - Regulatory Guide 1.174, Revision 3, Section 2.1.1.3 provides discussion on defense-in-depth, including 7 principles that can be used to frame the degree to which defense-in-depth is impacted. (Alternatively, LIC-504, Revision 5, and IMC 0609 Appendix M (issued January 2019) both contain similar discussion.) Describe how the issue impacts these 7 principles, and describe the associated risk significance of this impact. This review would not be as detailed as the analogous exercise performed for license amendment requests and safety evaluation reports.

Approach D2 - 50.69 Categorization - If the licensee has an approved 10 CFR 50.69 program, and has categorized the relevant functions and systems under that program, identify whether the degraded plant response associated with the issue exclusively involves SSCs categorized as RISC-3 or RISC-4 (i.e., LSS in the 50.69 binning scheme). If this is the case, and given the way in which that program considers defense-in-depth in categorization, the issue would be expected to result in a degree of defense-in-depth preservation that would support a determination of being of very low safety significance.

Approach D3 - 50.69 Guidance - NEI-00-04, Revision 0, Section 6, provides a framework for assessing the degree of impact on defense-in-depth. Using this construct, identify the specific impacts on defense-in-depth. Use of this framework will lead to a conclusion that the issue (and more specifically its impact on how the plant will behave under accident conditions) falls in to the category of either potentially safety significant or low safety significance confirmed. The latter is synonymous with very low safety significance in the context of the TAR worksheet.

Section E - Performance Monitoring / Feedback Approach E1 - Oversight - Articulate why existing inspection scope or performance indicators could reasonably identify unanticipated and unrecognized faults in this assessment.

For instance, if the issue would be expected to cause an increase in plant scrams, but this assessment concluded that the impact of this increase would not be safety-significant, would the Initiating Events Cornerstone Performance Indicators highlight errors in this judgment? Based on the totality of information, and using judgment, decide if there is sufficient opportunity for feedback.

Approach E2 - Regulatory Reporting - Articulate why existing regulatory reporting requirements (e.g., Licensee Event Reports) could reasonably identify unanticipated and unrecognized faults in this assessment. This could include licensee Maintenance Rule activities, or licensee performance monitoring strategies implemented as part of previously approved license amendments, if the agency has sufficient visibility into these activities.

Approach E3 - If there are no applicable feedback mechanisms that would highlight a significant error in judgment, yet all other factors point to an issue of very low safety significance, work with the integrated review team chair to consider whether a more generic feedback mechanism is appropriate (e.g., if the issue might not be very low safety significance for other plants, propose an inspection smart sample).

Instructions - Page 7

DRAFT Revision 7 - June 10, 2020 Section F - Wrap-Up

• Integrated decisionmaking - Be aware that EPRI Report 3002014783 provides an industry perspective on how the various inputs to integrated decisionmaking can be best incorporated. Figure 4-1 and Section 4 of that report describe a process very similar to the one being invoked here, but which focuses on assessing Defense-in-Depth and Safety Margin ahead of the risk assessment rather than visa versa. Both approaches are reasonable, and they are both iterative processes in reality. The appendices of the EPRI report also provide Case Studies and presentation rubrics that may be helpful in brainstorming.

• Senior Level Advisor Consultation - While it is envisioned that the determination will be made primarily based on the technical expertise of the involved risk analyst and topical area SME, in consultation with the integrated team, consider reaching out to the relevant senior level advisors for advice on particular technical issues.

References:

ADM-405 Revision 3, NRR Technical Work Product Quality and Consistency, Month, 23, 2020.

EPRI 3002014783 A Framework for Using Risk Insights in Integrated Risk-Informed Decision-Making, February 2019 IMC 0308 Att. 3 Significance Determination Process Technical Basis Document, June 16, 2016 IMC 0609 Significance Determination Process, October 12, 2018 - various attachments and appendices are referenced or implied IMC 0612 Issue Screening, May 3, 2017 - various appendices are referenced or implied IP 71111.21M Design Bases Assurance Inspection (Team), December 8, 2016 LIC-504 Revision 5, Integrated Risk-Informed Decision-Making Process for Emergent Issues, March 9, 2020.

MD 8.3 NRC Incident Investigation Program, June 25, 2014 NEI-00-04 Revision 0, 10 CFR 50.69 SSC Categorization Guideline, July 2005 NUREG-1855 Revision 1, Guidance on the Treatment of Uncertainties Associated with PRAs in Risk-Informed Decision Making, March 2017 RASP Handbook Revision 2.02 Risk Assessment of Operational Events Handbook -

Volume 1 - Internal Events, December 2017 RG 1.174 Revision 3, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, January 2018 Instructions - Page 8

DRAFT Safety Significance Determination Template

DRAFT Rev. 7 - June 10, 2020 Safety Significance Determination Template (ADAMS Accession No. ML)

A separate quick reference guide, basis, and background document is available at ADAMS Accession No. ML.

< Insert TAR # and Issue Title >

Section A - Issue

Description:

ISSUE CHARACTERIZATION Affected Structures, Systems, Components (SSCs), Operator Actions, and Risk-Relevant Functions:

Click here to enter text.

Conditions when the issue would manifest Itself (e.g., type of event, plant configuration):

Click here to enter text.

Exposure Time:

Click here to enter text.

Is Recovery of the Failed Function Credible? Yes No If yes, describe under what conditions.

Additional Issue Complexities (e.g., known synergy with other ongoing issues at the facility), if any:

Click here to enter text.

Licensees Perspective on the Issue, if known:

Click here to enter text.

COORDINATION AND COMMUNICATION Has the above issue characterization been discussed with the regional SRA?

Click here to enter text.

Are there key assumptions being made at this point in the process about the degraded condition and its associated impact on plant response?

Click here to enter text.

Section B - Associated Change in Risk

< Provide a bridge between the issue characterization above (i.e., the degraded condition and its effect on plant response) and the assessment of risk, by identifying which elements of the plant response are and are not captured in the risk evaluation. A sample table is provided for consideration:

Effect of condition Modeled in characterization of Notes risk?

E.g., RHR Train B may be Yes, RHR Train B is treated as This may be an over-estimation unavailable following a LOOP, if failed in relevant accident of the impact, since RHR Train an ECCS signal occurs sequences B may not actually be damaged E.g., Flooding may occur in area No, flooding effects are not This should be considered at the xyz due to equipment damaged treated in the modeling Defense-in-Depth and/or Safety by the water hammer Margin stage E.g., A new ISLOCA pathway Yes, in that a sensitivity study This sensitivity should inform could be created if RHR piping on LERF is being provided consideration of this aspect in is damaged outside of the Defense-in-Depth and/or containment Safety Margin stage Enclosure

DRAFT Rev. 7 - June 10, 2020

< Insert a description of the evaluation of the associated change in risk; include lists of high-contributing accident sequences and importance measures when relevant >

Section C - Safety Margin

< Insert a description of the evaluation of safety margin >

Section D - Defense-in-Depth:

< Insert a description of the evaluation of defense-in-depth >

Section E - Performance Monitoring / Feedback:

< Insert a description of the consideration of feedback >

Section F - Wrap-up:

Topic Item Outcome Key uncertainties

• Item #1; not otherwise

• Item #2 considered Safety The change in risk is very low/small Yes / No /

significance Indeterminate summary Adequate safety margin is retained Yes / No /

Indeterminate Sufficient defense-in-depth is maintained Yes / No /

Indeterminate There is adequate opportunity for feedback / monitoring Yes / No /

(or sufficient alternative means have been considered) Indeterminate On the whole, the issues safety significance appears to Very low /

be: elevated /

indeterminate Were the issue to be subject to the Safety Goal Yes / No /

Evaluation 1 in NUREG/BR-0058 (as part of a backfit Unknown evaluation), the issues significance would likely meet these criteria.

Potential Evaluation shared with Regional SRA, as courtesy, and Yes / No / NA additional actions for awareness relative to other risk-informed evaluations for this facility?

SPAR Model Feedback Form submitted for potential Yes / No / NA adjustment of the baseline model?

1 More specifically, this refers to Section 2.4 of NUREG/BR-0058, Draft Revision 5 (ML17100A480), and Figure 2-3 therein. The intent is to document cases where it is clear how such an evaluation would turn out, so as not to lose that insight. In some cases, the TAR safety significance evaluation will not provide sufficient information to draw a conclusion in this regard, and Unknown should be chosen.

2

DRAFT Rev. 7 - June 10, 2020 Risk Analyst:

Printed/typed name Title Organization Signature Date Topical Area Subject Matter Expert:

Printed/typed name Title Organization Signature Date 3