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

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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 correcve acon abilies 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