ML21313A119
| ML21313A119 | |
| Person / Time | |
|---|---|
| Issue date: | 11/30/2021 |
| From: | Harrison D NRC/NMSS/DFM/IOB |
| To: | |
| Tomeka Terry NMSS/DFM/IOB 301-415-1488 | |
| Shared Package | |
| ML21313A118 | List: |
| References | |
| Download: ML21313A119 (11) | |
Text
Very Low Safety Significance Issue Resolution (VLSSIR) Initiative Donnie Harrison November 2021 1
Original Paradigm for Addressing Issues 2
Clearly NOT in Licensing Basis Scope Clearly in Licensing Basis Scope Evaluate issue to determine regulatory actions:
- Generic Issue Screening
- Order
- Backfit (72.62)
Address issue with appropriate regulatory tools:
- Enforcement
- Order
- Consider Prompt Corrective Action
- Corrective Action
- Change Licensing Basis (72.7 Exemption, 72.56 Amendment, etc.)
- Change Requirement (Rulemaking)
Region of Uncertainty if in or out of Licensing Basis Scope May involve significant resources to decide issue status via TAR process
- Technical Assistance Request (TAR)
Very Low Safety Significant Issue Resolution (VLSSIR)
Initiative Situations in which an inspector/reviewer is not sure an issue is required to be addressed in the licensing basis In the past, significant effort (resources and time) has been expended to determine if an issue is in/out of licensing basis before considering its significance Put in place internal process enhancements to consider significance of an issue for situations where it is not clear if an issue is within the licensing basis scope Purpose Statement
Revised Concept for Addressing Issues 4
Clearly NOT in Licensing Basis Scope Clearly in Licensing Basis Scope Safety Significant Evaluate issue to determine regulatory actions:
- Generic Issue Screening
- Order
- Backfit (72.62)
Address issue with appropriate regulatory tools:
- Enforcement
- Order
- Consider Prompt Corrective Action Address issue with appropriate tools (achieve compliance or change licensing basis) such as:
- Corrective Action
- Change Licensing Basis (72.7 Exemption, 72.56 Amendment, etc.)
- Change Requirement (Rulemaking)
Limited effort to determine issue is outside licensing basis & of (very) low safety significance:
- Stop Pursuing to Full Resolution
- Document Decision with Bases
- Re-focus Resources Low Safety Significant Potential for Near-Term Improvements
- Technical Assistance Request (TAR)
VLSSIR -
Background
Building off similar initiative in NRR Working team formed within NMSS to share insights in implementing a consistent approach across business lines Includes representatives from each business line, regions, and general counsel.
Augmented with staff involved with a specific topic under consideration (e.g., Addressing Tornado Hazard during ISFSI STOs).
VLSSIR -
Within Inspection Arena Document Rationale for NOT Pursuing to Full Resolution VLSSIR outcomes are different than inspection findings Issue is not formally resolved, but provides the information/rationale for not pursuing issue further and no additional significant effort is spent trying to fully close issue If information arises that indicates the issue is within licensing basis or is not of VLSS then the issue can be revisited LOWER LEFT QUADRANT
Very Low Inspector Identifies Issue Not clear if issue needs to be addressed in licensing basis Inspector et al evaluate licensee information Nominal Effort Determine Safety Significance Continue Normal Inspection Processes Not Very Low Document Issue with Rationale (Use TAR process for further, more detailed, evaluation)
Document Rationale in Inspection Report for NOT Pursuing to Full Resolution Clearly in Licensing Basis In LB Scope Still Not Sure Issue Not Pursued Further Out LB Scope
VLSSIR -
Interface with TAR Process Means by which many Licensing Basis Questions are Addressed Additional revisions to draft TAR procedure will be implemented as tabletop exercises of example issues are conducted and/or as lessons learned Procedure under revision (still draft)
Interfaces with VLSSIR approach Need to gain experience in use
VLSSIR -
Issues Within Licensing Basis Arena The VLSSIR concept can also apply to issues within the licensing basis, but it is implemented differently The VLSSIR process considers significance in determining the appropriate option(s) to address issues within the licensing basis Aspects of licensing review scope, focus, and level of detail also consider significance LOWER RIGHT QUADRANT
Concept for Addressing Issues 10 Clearly NOT in Licensing Basis Scope Clearly in Licensing Basis Scope Safety Significant Evaluate issue to determine regulatory actions:
- Generic Issue Screening
- Order
- Backfit (72.62)
Address issue with appropriate regulatory tools:
- Enforcement
- Order
- Consider Prompt Corrective Action Address issue with appropriate tools (achieve compliance or change licensing basis) such as:
- Corrective Action
- Change Licensing Basis (72.7 Exemption, 72.56 Amendment, etc.)
- Change Requirement (Rulemaking)
Limited effort to determine issue is likely outside licensing basis & is of (very) low safety significance:
- Stop Pursuing to Full Resolution
- Document Decision with Bases
- Re-focus Resources Low Safety Significant Potential Near-Term Improvements
- Technical Assistance Request (TAR)
VLSSIR -
Discussion &
Questions