ML20239A834
| ML20239A834 | |
| Person / Time | |
|---|---|
| Issue date: | 09/21/2020 |
| From: | Garmon A NRC/NRR/DRO/IRAB |
| To: | |
| Alex Garmoe, NRR/DRO/IRAB, 415-3814 | |
| Shared Package | |
| ML20239A806 | List: |
| References | |
| Download: ML20239A834 (5) | |
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1 2019 Cross-Cutting Issues (CCI) Program Effectiveness Review CCI Program History This document forms a portion of the complete package of information surrounding the 2019 Cross-Cutting Issues (CCI) Program effectiveness review. The effectiveness review report if available in Agencywide Documents Access and Management System (ADAMS) as Accession No. ML20239A835 and the package of all information in available in ADAMS as Accession No. ML20239A806.
The cross-cutting concept has been a part of the Reactor Oversight Process (ROP) since initial development. Section 6 of SECY-99-007, Recommendations for Reactor Oversight Process Improvements, discussed that certain aspects of licensee performance were seen as cross-cutting and potentially impacting more than one ROP cornerstone. Three cross-cutting areas were included in the initial iteration of the ROP: human performance (HU), problem identification and resolution (PI&R), and safety conscious work environment (SCWE).
Early insights into the new oversight process were discussed in SECY-00-0049, Results of the Revised Reactor Oversight Process Pilot Program, and SECY-01-0114, Results of the Initial Implementation of the New Reactor Oversight Process, both of which included discussion of CCIs. Early data obtained from initial implementation suggested that there was a correlation between CCIs and crossed thresholds consistent with the premise of the process and efforts were continued to clarify ROP guidance on the identification and disposition of CCIs.
The February 27, 2001, version of Inspection Manual Chapter (IMC) 0610 defined CCIs as, those concerns related to the areas of human performance, problem identification and resolution, and safety-conscious work environment which have the potential to affect multiple cornerstones. Additional guidance was included to describe cross-cutting aspects of a finding in the summary and description. When multiple findings had a common cause in one of the three cross-cutting areas this accumulation of findings could be viewed as a significant CCI and would represent an additional finding. While not specifically defined, this version of IMC 0610 used the term substantive cross-cutting issue to describe the performance trend revealed by multiple findings with a common cause in a cross-cutting area.
The Davis-Besse Lessons Learned Task Force Report (LLTFR), issued on September 30, 2002, discussed numerous causes of the Davis-Besse vessel head degradation including contributions related to SCWE and the lack of a questioning attitude. Section 3.3.4 of the LLTFR stated that the implementation of NRCs guidance relative to the inspection and assessment of employee concerns programs and SCWE did not result in the identification of existing problems at Davis-Besse within these areas, as discussed in Section 3.2.5.
Recommendation 3.3.4(5)) was included in the report and stated:
The NRC should review the range of NRC baseline inspections and plant assessment processes, as well as other NRC programs, to determine whether sufficient programs and processes are in place to identify and appropriately disposition the types of problems experienced at DBNPS [Davis-Besse Nuclear Power Station]. Additionally, the NRC should provide more structured and focused inspections to assess licensee employee concerns programs and safety conscious work environment.
In its March 26, 2003, Staff Requirements Memorandum (SRM) in response to SECY-02-0166, Policy Options and Recommendations for Revising the NRCs Process for Handling Discrimination Issues, the Commission directed the staff to develop guidance that would
2 identify best practices to encourage a SCWE. Based in part on the SRM for SECY-02-0166, Davis-Besse LLTFR Recommendation 3.3.4(5), and Government Accountability Office Report GAO-04-415, Nuclear Regulation - NRC Needs to More Aggressively and Comprehensively Resolve Issues Related to the Davis-Besse Nuclear Power Plants Shutdown, the staff developed and included Option 3B, Enhance the ROP treatment of CCIs to more fully address Safety Culture, and to allow for more agency action as the result of the identification of a cross-cutting issue, in SECY-04-111. In its SRM for SECY-04-111, Recommended Staff Actions Regarding Agency Guidance in the Areas of Safety Conscious Work Environment and Safety Culture, the Commission approved Option 3B to enhance the ROP treatment of CCIs to more fully address safety culture.
In SECY-05-0187, Status of Safety Culture Initiatives and Schedule for Near-Term Deliverables, the staff provided a status update on actions being taken in response to the SRM for SECY-04-111. In SRM M050525B dated June 30, 2005, the Commission directed the staff to continue efforts to improve the guidance on substantive cross-cutting issues (SCCIs).
The staff provided its plans to enhance the ROP to more fully address safety culture in SECY-06-0122, Safety Culture Initiative Activities to Enhance the Reactor Oversight Process and Outcomes of the Initiatives. The resulting enhancements to the ROP, developed at Commission direction with stakeholder participation, included alignment of the three cross-cutting areas to those aspects of performance that are important to safety culture and additional guidance to better define both an SCCI and the actions to be taken once one is identified. The existing three cross-cutting areas were revised to reflect nine safety culture components that were further subdivided into 27 cross-cutting aspects. Additionally, a category of Other cross-cutting components was created that included components of safety culture that were deemed to not be within the scope of the three existing cross-cutting areas. It was determined that these other components would only be used during supplemental inspections, not during baseline inspection. New actions were identified that could be taken for repetitive SCCIs, including requesting that the licensee perform an assessment of safety culture and additional actions for plants not in Column 1 of the Action Matrix. The structure of the cross-cutting areas is shown in Table 1.
3 Table 1: Cross-Cutting Components and Aspects Reflected in SECY-06-0122 Human Performance SCWE Decision Making H.1(a): Systematic Process H.1(b): Conservative Assumptions H.1(c): Communicate Decisions Resources H.2(a): Design Margins H.2(b): Training H.2(c): Documentation H.2(d): Facilities and Equipment Work Control H.3(a): Work Planning H.3(b): Work Management Work Practices H.4(a): Human Error Prevention H.4(b): Procedural Compliance H.4(c): Work Oversight Environment for Raising Nuclear Safety Concerns S.1(a): Free Flow of Information S.1(b): Alternative Process Preventing, Detecting, and Mitigating Perceptions of Retaliation S.2(a): Training S.2(b): Discrimination S.2(c): Chilling Effects PI&R Other Corrective Action Program P.1(a): Identification P.1(b): Trending P.1(c): Evaluation P.1(d): Corrective Action P.1(e): Alternate Process Operating Experience P.2(a): Communication P.2(b): Institutionalize OpEx Self and Independent Assessment P.3(a): Assessment P.3(b): Trending P.3(c): Communicate Results Accountability Accountability Management safety standards Worker safety focus Continuous Learning Environment Adequate training Personnel strive to improve Organizational Change Management Systematic Process Safety Policies Reinforce the right to raise safety issues Training Organizational decisions consistent with policies Senior management reinforces safety These changes were rolled out in the June 22, 2006, revision of IMC 0305. A cross-cutting theme was defined as a site having four or more findings with a common cross-cutting aspect in the HU or PI&R cross-cutting areas. An SCCI was identified if, in addition to a theme, assessment of subjective criteria at the mid-cycle and end-of-cycle meetings determined that the agency had a concern with the licensees scope of efforts or progress in addressing the cross-cutting theme.
The CCI program remained unchanged until the 2013 timeframe when the safety culture common language initiative, an effort begun in 2011 following the publication of the Commissions Safety Culture Policy Statement, incorporated the new language into the existing structure of the CCI program. The purpose of the common language initiative was to develop a shared set of terms to describe safety culture that would be used by the nuclear power industry and NRC in the respective safety culture assessment processes. Following numerous public workshops the resulting language was published by the NRC as NUREG-2165, Safety Culture Common Language. The initiative resulted in the set of traits of a healthy nuclear safety culture listed below.
4 Leadership Safety Values and Actions Problem Identification and Resolution Personal Accountability Work Processes Continuous Learning Environment for Raising Concerns Effective Safety Communication Respectful Work Environment Questioning Attitude Decision Making Once the common language was agreed upon, the NRC translated the information into the existing CCI program. The concept of cross-cutting components was removed and a revised set of 23 cross-cutting aspects was developed, shown in Table 2. Exhibit 1 of IMC 0310 maps the relationship between the safety culture traits and the cross-cutting aspects and Exhibit 2 shows how the old cross-cutting aspects mapped to the new cross-cutting aspects. Figure 1 below shows the extent to which the 3 cross-cutting areas are related to the ten safety culture traits.
Table 2: Cross-Cutting Areas and Aspects Based on the Common Language Initiative Human Performance SCWE H.1 Resources H.2 Field Presence H.3 Change Management H.4 Teamwork H.5 Work Management H.6 Design Margins H.7 Documentation H.8 Procedure Adherence H.9 Training H.10 Bases for Decisions H.11 Challenge the Unknown H.12 Avoid Complacency H.13 Consistent Process H.14 Conservative Bias S.1 SCWE Policy S.2 Alternate Process S.3 Free Flow of Information PI&R Other P.1 Identification P.2 Evaluation P.3 Resolution P.4 Trending P.5 Operating Experience P.6 Self-Assessment X.1 Incentives X.2 Commitment to Safety X.3 Roles and Authorities X.4 Constant Examination X.5 Leader Behaviors X.6 Standards X.7 Job Ownership X.8 Benchmarking X.9 Work Process Communication X.10 Expectations X.11 Challenge Assumptions X.12 Accountability for Decisions Figure 1: Relationship Between Safety Culture Traits and Existing Cross-Cutting Aspects The ROP Independent Assessment report (ADAMS ML14035A571), dated February 14, 2014, included a recommendation to perform a comprehensive analysis to determine whether the use of CCIs and safety culture provided regulatory value in terms of licensee safety performance for the resources expended. The report also recommended that the staff clarify and document the goals, purposes, uses, and desired outcomes associated with the inclusion of CCIs and safety culture in the ROP. This aligned with the staffs planned efforts to review the CCI program as part of an ongoing look in the 2013 timeframe at possible enhancements to the ROP. The effectiveness review report was transmitted on April 23, 2014 (ADAMS ML14099A171). An
5 NRC staff working group subsequently recommended the following changes to the CCI program (ADAMS ML14309A612):
Increase the threshold for a cross-cutting theme to six for all cross-cutting aspects, except for SCWE.
The subjective questions should be revised to set more objective criteria for opening an SCCI.
For Column 4 plants, all SCCIs would be closed out in the Confirmatory Action Letter (CAL) closing out the 95003 inspection.
Develop a backstop at the cross-cutting area level.
Develop standard SCCI closure criteria.
Consider additional actions for licensees after the second consecutive assessment cycle with the same SCCI.
Program changes based on the 2014 effectiveness review were implemented in the April 9, 2015, revision to IMC 0305. Cross-cutting areas and aspects were not modified, though the threshold for a cross-cutting theme was elevated from four to six findings with a common aspect. Backstops were added such that a cross-cutting theme would also be defined as 20 total findings in the HU cross-cutting area and 12 total findings in the PI&R cross-cutting area.
Along with adjusting the definition of a cross-cutting theme, the subjective criteria for considering whether to open an SCCI were removed. The revised program also resulted in removal of the term substantive such that a cross-cutting issue would be opened once a cross-cutting theme was present for three consecutive assessment periods.
Table 3: Cross-cutting theme and CCI thresholds for pre-2015 and 2015+ program iterations 2006-2014 2015-present Theme:
SCCI:
4+ findings in any single HU or PI&R aspect Theme present + agency concern with licensee actions Theme:
CCI:
6+ findings in any single HU or PI&R aspect 12+ findings in the PI&R area 20+ findings in the HU area Theme present for three consecutive assessment periods SCWE Theme:
1+ finding in any single SCWE aspect; Chilling effect letter; Escalated enforcement involving discrimination Theme:
1+ finding in any single SCWE aspect; Chilling effect letter; Escalated enforcement involving discrimination affecting more than one individual SCCI:
Impact on SCWE is not isolated +
agency concern with licensee actions CCI:
Theme present for four consecutive assessment periods The changes implemented in 2015 were given several years of run-time before the staff in 2019 commenced an effectiveness review of the CCI program based on the 2015 changes.