ML22339A153
| ML22339A153 | |
| Person / Time | |
|---|---|
| Issue date: | 12/29/2022 |
| From: | Manuel Crespo NRC/NRR/DRO/IRIB |
| To: | |
| References | |
| CN 22-029 | |
| Download: ML22339A153 (1) | |
Text
NRC INSPECTION MANUAL IRIB INSPECTION MANUAL CHAPTER 0611 APPENDIX D GUIDANCE FOR PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORTS Effective Date: 01/01/2023
Issue Date: 12/29/22 1
0611 App D At the completion of biennial team inspection, the inspection team shall document their assessment of the licensees Problem Identification and Resolution (PI&R) programs. This assessment should consider activities that were not only observed during this inspection but should more broadly consider previously documented inspection activities that occurred since the last biennial team assessment as they relate current licensee performance.
The inspection team shall document an assessment of the licensees performance in the following areas:
- 1. The effectiveness of the corrective action program which includes problem identification, problem prioritization and evaluation, and corrective actions
- 2. The use of operating experience
- 3. Completed self-assessments and audits
- 4. The health of the licensees Safety Conscious Working Environment (SCWE) which includes any underlying factors that would produce a reluctance to raise nuclear safety concerns or prohibit the free flow of information. [C1]
Note: The assessment of the licensees SCWE should be based on the results of the biennial inspection interviews of plant staff and any relevant insights obtained from the review of the licensees most recent safety culture and other relevant assessments.
Unlike other baseline inspection procedures, (IP) 71152 biennial team inspections seek to assess elements of the PI&R programs that may not rise to the level of ROP findings.
Consequently, these inspections may, in some instances, document qualitative observations, minor performance deficiencies, and minor violations. The following guidance supplements that the guidance contained in IMC 0611.
- 1. The report summary should briefly summarize the assessment conclusions in the areas described above.
- 2. The inspection report should describe the observations and basis for each assessment conclusion. The report outline below contains the inspection requirements for each assessment area in a logically organized format.
Negative assessment conclusions should be supported by examples performance deficiencies. When documenting such performance deficiencies, the discussion must include a disposition of the performance deficiency consistent with IMC 0612 and the Agencys enforcement process. Other conclusions should be supported by a brief basis statement and should include the scope of material reviewed in reaching the conclusion.
- 3. Report Cover Letters Inspection report cover letter guidance is contained in IMC 0611 Exhibit 4, Cover Letter Templates. IMC 0611 Exhibit 4 contains a report cover letter template that can be modified to create a biennial PI&R inspection report cover letter. The cover letter should contain a brief description of the teams overall conclusion regarding the effectiveness of the licensees PI&R programs in each of the areas reviewed and assessed (Corrective Action Program Effectiveness, Operating Experience, Self-Assessment and Audits, and Safety Conscious Work Environment).
Issue Date: 12/29/22 2
0611 App D REPORT OUTLINE:
- 1. Corrective Action Program Effectiveness (a) Inspection Scope Problem Identification1 - Identify the documents that were reviewed, the standards that the licensee was evaluated against, and if applicable, the other activities that were competed to determine whether the licensee is identifying problems at the proper threshold and entering them into the corrective action system.
Problem Prioritization and Evaluation1 - Identify the documents that were reviewed, the standards that the licensee was evaluated against, and if applicable, the other activities that were competed to determine whether the licensee is adequately prioritizing and evaluating problems. Identify the prioritizations and evaluations which were reviewed and were associated with previously documented NRC findings or inspection activities. Include pertinent reference numbers (e.g., condition report numbers, NRC finding numbers).
Corrective Actions1 - Identify the documents that were reviewed, the standards that the licensee was evaluated against, and if applicable, the other activities that were competed to determine whether corrective actions are effective, timely, and in the case of significant conditions adverse to quality, prevent recurrence. Identify the corrective actions which were reviewed and were associated with previous documented NRC findings or inspection activities. Include pertinent reference numbers (e.g., condition report numbers, NRC finding numbers).
(b) Assessment Problem Identification1 - Document a conclusion regarding the licensees effectiveness in problem identification. Include the bases for the conclusion. Discuss issues and relevant observations regarding problem identification.
Problem Prioritization and Evaluation1 - Document a conclusion regarding the licensees effectiveness in prioritizing and evaluating problems. Include the bases for that conclusion. Discuss issues relative to:
the effectiveness of the licensees process for prioritizing problems for resolution, technical adequacy and depth of evaluations (including root cause analysis where appropriate),
adequate consideration of operability and reportability requirements, and appropriate consideration of risk in prioritizing or evaluating problems for resolution Corrective Actions1 - Document a conclusion regarding the licensees ability to develop and implement effective corrective actions. Include the bases for the conclusion. Discuss issues and relevant observations regarding corrective actions, 1 These three areas may be combined into a single write-up
Issue Date: 12/29/22 3
0611 App D including, for significant conditions adverse to quality, issues associated with corrective actions taken to prevent recurrence
- 2. Use of Operating Experience (a) Inspection Scope - Identify documents critically reviewed and if applicable, the other activities that were completed to determine whether the licensee appropriately used operating experience information.
(b) Assessment - Document a conclusion regarding the licensees use of operating experience information. Include the bases for the conclusion.
- 3. Self-Assessments and Audits (a) Inspection Scope - Identify documents critically reviewed and if applicable, the other activities that were completed to determine whether conducted licensee self-assessments and audits of their corrective action and quality assurance programs appropriately assessed performance and identify areas for improvement.
(b) Assessment - Document a conclusion regarding the licensees self-assessments and audits. Include in the conclusion if issues identified by those self-assessments and audits were addressed. Include the bases for the conclusion.
- 4. Safety Conscious Work Environment (a) Inspection Scope - Identify the documents reviewed and as applicable, other activities that were completed such as Employee Concerns Program reviews and employee interviews to assess whether issues exist that may represent challenges to the free flow of information, and to determine whether underlying factors exist that would produce a reluctance to raise nuclear safety concerns. [C1]
(b) Assessment - Document the existence of issues that may represent challenges to the free flow of information, and underlying factors that could produce a reluctance to raise nuclear safety concerns. [C1] Based on inspection interviews and insights obtained from safety culture and other relevant assessments, document a conclusion as to whether the conditions at the site were conducive to a Safety Conscious Working Environment.
Issue Date: 12/29/22 Att1-1 0611 App D : Revision History for IMC 0611 Appendix D Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Number (Pre-Decisional, Non-Public Information)
ML031610702 06/24/03 CN 03-021 Initial Issuance C1 ML061560471 06/22/06 CN 06-015 PI&R Team Inspection Report format revised to accommodate the safety culture initiative described in Staff Requirements - SECY-04-0111 -
Recommended Staff Actions Regarding Agency Guidance in the Areas of Safety Conscious Work Environment and Safety Culture, dated August 30, 2004 Yes 07/01/2006 ML061570081 ML111881201 10/28/11 CN 11-024 Relocated example cover letter guidance to IMC 0612 Exhibit 4.
ML12345A022 08/13/13 CN 13-017 Revised to address regional reliability effort change recommendations. Removed sample inspection report for future incorporation into IMC 0612 Exhibit
- 3.
ML13052A347 FF 0612D-1785, 1827, 1843, 1844, 1845, 1846, 1847 ML17130A997 12/13/17 CN 17-029 Editorial update made to reflect the splitting IMC 0612 into IMC 0611 for documentation and IMC 0612 for issue screening.
ML22339A153 12/29/22 CN 22-029 Completed five-year review. IMC 0611 App D.
FBFs 1616 & 2470 remain open.
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