ML21211A574
| ML21211A574 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/2021 |
| From: | Chris Miller NRC/NRR/DRO/IRAB |
| To: | Daniel Merzke NRC/NRR/DRO |
| Daniel Merzke NRR/DRO/IRAB, 4251457 | |
| References | |
| Download: ML21211A574 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 18, 2021 MEMORANDUM TO:
Daniel J. Merzke Division Reactor Oversight Office of Nuclear Reactor Regulation FROM:
Christopher G. Miller, Director /RA by e-mail/
Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
APPROVAL OF REVISED CHARTER FOR COMPREHENSIVE BASELINE INSPECTION PROGAM REVIEW This memorandum approves the team charter for the working group tasked with conducting a comprehensive baseline inspection program review as part of the calendar year (CY) 2021 Reactor Oversight Process (ROP) self-assessment. This multi-disciplinary working group, with representation from all four regions and headquarters staff, will review all ROP baseline inspection procedures (IPs) and recommend revisions to inspection program guidance to incorporate COVID-19 public health emergency (PHE) lessons learned for the purpose of standardizing implementation of baseline inspections in the event of another PHE or extenuating circumstances that restricts site access for NRC inspectors.
Enclosure:
Revised Comprehensive Baseline Inspection Program Review Charter CONTACT: Daniel J. Merzke, NRR/DRO/IRAB 301-415-1457
SUBJECT:
APPROVAL OF CHARTER FOR COMPREHENSIVE BASELINE INSPECTION PROGAM REVIEW DATED: AUGUST 18, 2021 DISTRIBUTION:
Public RidsNrrDro Resource DMerzke AMasters THipshman CMiller ADAMS Accession Number: ML21211A574
- via e-mail OFFICE NRR/DRO/IRAB NRR/DRO/IRAB NRR/DRO/IRIB NRR/DRO NAME DMerzke AMasters*
THipshman*
CMiller*
DATE 7/21/2021 7/21/2021 8/5/2021 8/18/2021 OFFICIAL RECORD
Enclosure Revised Comprehensive Baseline Inspection Program Review Charter I.
Background
As described in Inspection Manual Chapter (IMC) 0307, Appendix B, Reactor Oversight Process Self-Assessment Baseline Inspection Program Monitoring and Comprehensive Review, dated May 29, 2020, the staff will conduct a comprehensive baseline inspection program review every fifth year (the year after NRR has completed Reactor Oversight Process (ROP) implementation audits for all four regions). This review will holistically evaluate the entire baseline inspection program. The staff completed the audit for Region IV in Calendar Year (CY) 2020.
In CY 2019, the staff completed a comprehensive review of every baseline inspection procedure as part of the ROP enhancement initiative. The staff made several recommendations to revise inspection procedures (IPs) that were documented in SECY-19-0067, Recommendations for Enhancing the Reactor Oversight Process, dated June 28, 2019 (Agency Documents Access and Management System (ADAMS) Accession No. ML19070A036).
In late CY 2020, the staff completed a comprehensive review of the impacts to the ROP due to the COVID-19 public health emergency (PHE) and documented the results in a report, Initial Report on Challenges, Lessons Learned and Best Practices from the 2020 COVID-19 Public Health Emergency; Focus on Regulatory Oversight of Operating Nuclear Reactors, dated January 2021 (ADAMS Accession No. ML20308A389). A 17-member team was established to identify lessons learned and best practices and to make recommendations to improve NRC readiness for future emergencies and non-emergency conditions. Survey results indicated that most resident inspectors believe they could perform certain aspects of their job remotely on a more routine/fixed basis. In the report, the working group recommended an expansion of remote work practices for resident inspectors.
II.
Objective Establish a working group to conduct a limited comprehensive baseline inspection program review with a focus on recommending revisions to inspection program guidance to incorporate PHE lessons learned for the purpose of standardizing implementation of baseline inspections in the event of another PHE or extenuating circumstances that restricts site access for NRC inspectors.
III.
Proposed Action Establish a working group comprised of members from the NRRs Reactor Inspection Branch (IRIB), the Radiation Protection and Consequence Branch (ARCB), the Office of Nuclear Security and Incident Response (NSIR), and each of the Regional offices. Working group members reviewing reactor safety procedures shall have resident inspector experience, with senior resident inspector experience preferred, and/or experience implementing Division of Reactor Safety (DRS) inspections. Regional members will be expected to brief regional management and staff throughout the review and provide regional feedback to the group for consideration.
The Director, Division of Reactor Oversight (DRO) will assign a Senior Executive Service (SES) sponsor for the baseline inspection program review who will provide oversight, guidance, and assistance with change management and resolving differing views, as requested by the review team.
Considering the experience gained by inspectors in completing the baseline inspection program during the PHE, and to ensure more consistent implementation of remote inspection activities at operating nuclear power plants, the working group will evaluate all baseline IPs focusing on lessons learned during the PHE. The working group will:
utilize the survey results from the COVID lessons learned effort; review each IP to determine what elements can be accomplished remotely, and which elements must be accomplished onsite for the IP to be considered complete; identify potential compensatory or alternate inspection activities, if any, in lieu of the required elements if circumstances preclude inspectors from being onsite to complete specific required elements of IPs; and interview inspectors to identify best practices for accomplishing inspections, both in person and remotely.
Once the review is complete and recommendations are developed, the review team will present their results and recommendations to DRO management and branch chiefs, the regional technical support branch chiefs and team leads, and regional DRP/DRS management. Once these presentations are complete and the team has made any necessary adjustments to ensure alignment, the review team will issue a memo documenting the results of the review and any recommendations.
Upon issuance of the memo, the working group will be disbanded.
IV.
Projected Timeline V.
Team Membership SES Sponsor - Russell Felts Team Lead - Daniel Merzke IRIB Members - Doug Bullock, Eric Duncan, Jeff Bream ARCB - Ed Stutzcage NSIR - Scot Sullivan, Don Johnson, Jared Justice Region I - Chris Highley, David Kern Region II - Matt Fannon Region III - Rob Ruiz, Jorge Corujo-Sandin Region IV - Andrew Siwy Consult with appropriate IP leads.
VI.
Meetings Team meetings will be scheduled bi-weekly during the review period from March to May.
Meeting schedules will be adjusted as necessary.
VII.
Time Reporting All activities will be documented in HRMS using CAC No. A11018 Activity Month Lead Participants Identify working group members Mid-February BIPR Team Lead Alignment meeting Early March BIPR Team Lead DRO management Issue charter. Commence review.
Early March BIPR Team Lead BIPR Team Communicate with baseline IP leads, regional staff, RIs, DRO staff as necessary to complete review.
March - May BIPR Team Lead BIPR Team, others as necessary Progress review Early April BIPR Team Lead DRO management Complete review and develop recommendations.
August BIPR Team Lead BIPR Team Present results and recommendations to DRO, DRS, DRP management.
Address feedback.
August BIPR Team Lead BIPR Team, Division Directors Document conclusions and recommendations in memo to DRO Director. Upon issuance of the memo, the working group will be disbanded.