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