ML20274A133
| ML20274A133 | |
| Person / Time | |
|---|---|
| Issue date: | 11/12/2020 |
| From: | Chris Miller NRC/NRR/DRO/IRIB |
| To: | Ho Nieh Office of Nuclear Reactor Regulation |
| Heather Jones NRR/DRO/IRIB | |
| Shared Package | |
| ML20247J590 | List: |
| References | |
| Download: ML20274A133 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 12, 2020 MEMORANDUM TO: Ho. K. Nieh, Director Office of Nuclear Reactor Regulation FROM: Christopher G. Miller, Director /RA/
Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
COMPREHENSIVE REVIEW OF THE REACTOR OVERSIGHT PROCESS PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION PROGRAM In SECY19-067 Recommendations for Enhancing the Reactor Oversight Process, the staff committed to performing a comprehensive review of the Problem Identification and Resolution (PI&R) inspection program. The staff working group has completed its review. The results, with associated supporting information, are documented Agencywide Documents Access and Management System (ADAMS) Accession No. ML20247J590. In addition to this memo and the PI&R working group report (ADAMS Accession No. ML20247J602), also included in the ADAMS package are the following documents:
- Attachment 4, Basis and History (ADAMS Accession No. ML20247J599)
- Attachment 6, Feedback Form Adjudication (ADAMS Accession No. ML20247J601)
- Approval of Charter for Comprehensive Review of PI&R Inspection (ADAMS Accession No. ML19212A017)
- Assessment Option 1 Proposed Methodology (ADAMS Accession No. ML20262G982)
A multi-disciplinary team of staff, with members from every Region and the Office of Nuclear Reactor Regulation (NRR) conducted the review. The review focused on two main areas: (1)
PI&R procedure guidance and implementation; and (2) the U.S. Nuclear Regulatory Commissions (NRCs) overall assessment of a licensees PI&R program.
The team concluded that Inspection Procedure (IP) 71152, Problem Identification and Resolution, is an effective oversight tool to assess the acceptability of licensee actions to identify, prioritize, evaluate and correct plant problems. The team also concluded that there are opportunities to enhance the current procedure, including the guidance associated with NRC assessment of licensee corrective action programs.
CONTACT: Russell Gibbs, NRR/DRO (301) 415-8578
H. Nieh 2 The report includes options and team recommendations to enhance IP 71152. The team shared the report with the Regions, and feedback from that review is included in the report. The report also identifies other perspectives that differ from the teams perspectives.
I am very appreciative of the teams thoughtful work, which included some innovative out of the box thinking, and good insight from experienced practitioners in this area. Their work included not only a detailed review of PI&R history and inspection performance, but also recommendations where improvements could be made. The team also considered some of the resource expenditures needed to implement the initial changes and resources that may be required to continue the program with the changes made. Discussions regarding path forward for these recommendations will need to be informed by more detail on resource expectations for the industry and the NRC. I recommend pursuing alignment discussions with our internal stakeholders (initially) to determine which of these options should be pursued in the near term.
Regarding the teams inspection program recommendation Option 1 - Current Inspection Requirements with Small Enhancements, I believe this option provides some useful considerations of changes that may improve this inspection with a relatively low impact on the NRC and licensee resources. Option 1 addresses stakeholder feedback regarding the need for clear and consistent inspection guidance. Additionally, this option redistributes inspection resources in a more risk-informed manner. It provides for the most efficient use of the staff and industry resources, and it can be implemented in the near term. I support this option.
With respect to the teams recommendations for assessment enhancement options for PI&R Inspection Program Improvements, I would like our decision-making efforts to carefully consider what problem we most want to address in assessment space. The objective statement in the inspection procedure To evaluate the effectiveness of the licensees corrective action program in identifying, prioritizing, evaluating, and correcting problems has given inspectors difficulty because it does not currently address in detail how to make this assessment. The ways we have addressed this issue in the past are not always consistent, and some clarification and additional guidance on this issue would be helpful. I found it notable that earlier versions of IP 71152 did not have this objective, but rather focused on supporting objectives such as assessment of performance issues that could lead to action matrix threshold changes, assessment of establishing a safety conscious work environment, follow up on previous compliance issues, and determining compliance with regulations regarding corrective actions (e.g., see IP 71152 issued 1/5/06 , ADAMS Accession No. ML053490187).
The objectives in the current procedure do not call for a numerical grading of licensee efforts regarding the thousands of corrective actions that are documented each year. Rather, it seeks an evaluation of how the corrective action program is working at a site. This information is assessed and communicated in many ways. Currently, the results of the inspection are documented and provided for consideration to decision makers during various portions of a yearly assessment cycle. This includes robust discussions at end of cycle meetings where inspection plans are adjusted to address specific performance issues for each site. The team has provided recommendations to make this assessment easier for inspectors and managers to implement. I believe the approach that better clarifies what issues should be considered and how to communicate those results consistently would provide for the best use for our resources.
That is one of the reasons I support the approach of Option 3 - Qualitative Evaluation of PI&R Areas. I would also point out in support of Option 3 that the teams analysis using the BeRiskSmart framework identified significant work that would be needed if Assessment Options 1 or 2 were chosen. It is clear from the supporting attachments that some of the work involves developing more detail into how the assessments would work, and some of the ideas were
H. Nieh 3 presented merely as a strawman or placeholder for additional detail to be added. Some of the details discussed included items that would be a significant change from our existing ROP practices, including among other things, a grading approach for the licensees PI&R program, aggregation of findings, and the potential for double-weighting cross-cutting issues (CCI) by assessing cross-cutting aspects in both the CCI and PI&R programs. Pursuing those recommendations in Option 1 and 2 could risk expending significant resources to address concerns that may not merit those resources, given the teams description of the current inspection as an effective oversight tool.
The Division of Reactor Oversight intends to work with NRR, NSIR and the Regions to discuss and develop any needed changes to the PI&R Inspection Procedure as a result of this report, including public discussions of any changes that may be anticipated to impact our stakeholders.
Enclosures:
- 1. Team Report of the Reactor Oversight Process Comprehensive Review of the Problem Identification and Resolution Inspection Program
Package: ML20247J590 Memo: ML20274A133 *Via e-mail NRR-106 OFFICE NRR/DRO/IRSB NRR/DRO/IRIB NRR/DRO NAME *RGibbs *HJones *CMiller DATE 9/30/2020 11/12/2020 11/12/2020