ML23136A589

PI&R Procedure Brief for May 2023 ROP Public Meeting

ML23136A589
Person / Time
Issue date:	05/16/2023
From:	Zachary Hollcraft, Sarah Obadina NRC/NRR/DRO/IRIB
To:
References
Download: ML23136A589 (8)

Text

Problem Identification and Resolution Sarah Obadina, Reactor Operations Engineer Zack Hollcraft, Senior Reactor Operations Engineer NRO/DRO/IRIB

Background

• SECY 19-0067, Recommendations for Enhancing the Reactor Oversight Process (ML19070A036) had two recommendations

- Triennial Team Inspection

- Comprehensive PI&R Review

• Comprehensive Review completed fall 2020 (ML20247J590)

• SECY 19-0067 retracted fall 2021 (ML21217A284)

• IP 71152 revision issued in winter 2021 (ML21281A181)

- Updated format

- Updated SCWE guidance

- Moved daily review to IMC 2515D, Plant Status (ML22251A314)

Inspection Frequency

• Thecomprehensive review of the inspection objectives and data did not produce data that supports or refutes shifting the team inspection from biennial to triennial.

(ML20247J590, pg. 5)

• SECY 21-0087, Recommendation for Problem Identification and Resolution Team Inspection Frequency, (ML22145A448) submitted fall 2022 to recommend maintaining biennial frequency

Commission Direction

• SRM-SECY-22-0087 (ML23062A686) issued in early 2023

- approved maintaining the PI&R team inspection at a biennial frequency

- also stated that the current inspection hours for the procedure should be maintained

Comprehensive Review Recommendations

• Focus effort on assessment of licensees identification, prioritization, evaluation, and correc ve ac on abili es

• Incorporate audits, self-assessments, and operating experience inspection efforts into other elements

• Update and clarify SCWE inspection, revise questions, clarify guidance on when and how teams can and should shift to IP 93100 guidance and qualification requirements for focus group facilitators

• Incorporate guidance for the team to use to develop inspection insights for more consistent and repeatable "assessment" of licensee's PI&R programs

IP 71152 Revision in Progress

• Addresses Comprehensive Review recommendation to add assessment guidance for documentation - does NOT add any additional oversight mechanisms

• Does NOT remove separate requirements to review licensee audits, self assessments and operating experience programs

• Continues to reformat procedure to modernize it and bring it into current IMC 0040 requirements

• Will close all outstanding ROP feedback forms and lessons learned actions related to IP 71152

• Will also update IMC 0611 governance for documentation (ML22339A153 and ML17129A591), and IMC 0308 inspection bases (ML19056A200)

• Intention is that the final revision will not substantively change how a PI&R team inspection is currently conducted, but will provide clearer guidance for inspectors when documenting their assessments

Questions Assessment Option 3

• Performance criteria for assessment in the areas of identification, evaluation, correction of plant problems and SCWE

- In each of these areas, there are success criteria that demonstrate what an effective PI&R program looks like

• Example: Licensee staff enter conditions into the licensees PI&R program at a low threshold.

- The guidance also includes observations

• Example: A failure to identify or enter an SCAQ into the PI&R program.

• The goal is to provide clearer guidance on how to assess the effectiveness of the licensees PI&R program