ML23199A308

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Charter for the Region II Calendar Year 2023 Reactor Oversight Process Implementation Audit
ML23199A308
Person / Time
Issue date: 07/24/2023
From: Philip Mckenna
NRC/NRR/DRO/IRAB
To: Russell Felts
Office of Nuclear Reactor Regulation
References
Download: ML23199A308 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 24, 2023 MEMORANDUM TO: Russell N. Felts, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation Signed by McKenna, Philip FROM: Phillip J. McKenna, Chief on 07/24/23 Reactor Oversight Process Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUBJECT:

CHARTER FOR THE REGION II CALENDAR YEAR 2023 REACTOR OVERSIGHT PROCESS IMPLEMENTATION AUDIT Reactor Oversight Process Implementation Audit Basis The purpose of this audit is to appraise regional program performance in terms of effectiveness of Reactor Oversight Process (ROP) implementation, implementation of the ROP in accordance with program governance documents, and to ensure predictable, reliable, and uniform ROP implementation across all four regions. Additionally, this audit may also identify opportunities for improvements to ROP governance documents for how regional offices carry out their functions related to the ROP.

As noted in Inspection Manual Chapter (IMC) 0307, Reactor Oversight Process Self-Assessment Program, dated May 3, 2022 (ADAMS Accession No. ML21341B399), the staff performs an ROP implementation audit each year at one of the regions on a rotating basis (except for the fifth year, when a comprehensive baseline inspection program review is performed). The ROP implementation audit will be conducted in accordance with IMC 0307, Appendix C, Reactor Oversight Process (ROP) Self-Assessment ROP Implementation Audit, dated March 24, 2023 (ML23024A117) and this charter.

Further ROP implementation audit guidance is documented in IMC 0307, Appendix C.

Region II is the designated recipient of the calendar year 2023 ROP Implementation Audit conducted as part of the ROP self-assessment program.

CONTACT: Alex Garmoe, NRR/DRO/IRAB 301-415-3814

R. Felts 2 Audit Objectives

1. Appraise regional program performance in terms of effectiveness and uniformity of ROP implementation pursuant to 10 CFR 1.43(e).
2. Ensure transparent, objective, predictable, scrutable, reliable, and uniform ROP implementation across all NRC regions and in accordance with NRR program office policies, programs, and procedures.
3. Determine whether revisions to ROP policies, programs, or procedures are warranted to promote effective and uniform regional ROP implementation.

Audit Scope The audit will consist of two parts. First, the audit team will evaluate a standardized set of audit items that cover all four ROP program areas (Assessment, Significance Determination Process, Inspection, and Performance Indicators) as described in Attachment 1 to IMC 0307, Appendix C. Additionally, the team will evaluate two focus areas via a deep-dive review in accordance with the objectives of IMC 0307, Appendix C, and this charter. The two focus areas are as follows:

1. Maintenance of IMC 1245 qualification records for initial and subsequent qualifications
2. Review of inspection sample selections During their review, the team members will also assess whether there are any necessary improvements to ROP governance documents for how regional offices carry out ROP-related functions.

In order to achieve Audit Objective #1 above, Regions I, III and IV will perform their own independent review of the two focus areas above and report the results of this review in their audit response letters after the completion of the Region II audit.

Audit Schedule The ROP audit will be conducted both remotely and onsite. Prior to the onsite week, members of the team will remotely evaluate most of the standardized items, begin auditing the deep dive focus areas, and prepare for meetings and discussions that will occur during the onsite week.

This remote work will occur the week of September 5, 2023. Some members of the audit team will be onsite at the Region II office from September 11 to September 14, 2023, with some of the team continuing to participate remotely.

Audit Team Members Alex Garmoe (DRO/IRAB), Team Lead Doug Bollock (DRO/IRIB) (participating remotely)

Nicole Fields (DRO/IRAB)

Aaron McCraw (RIII/DORS)

Audit Team Guidance In all efforts, the team will be dedicated to objectively and thoroughly evaluating the

R. Felts 3 standardized audit items and the designated focus areas. The review team will use objective evaluation standards to document whether Region II meets or does not meet current requirements in ROP governance documents and whether the regions approach to accomplishing ROP-related functions is uniform with other regional approaches. Should the audit team desire, they may choose to include regional best practices that they observe in how to carry out ROP functions. Additionally, the audit team should document any potential gaps or inconsistencies regarding program office/ROP governance document guidance to the regions.

The audit team will complete (to the maximum extent possible) evaluation of the standardized audit items prior to the onsite audit week of September 11, 2023. As able, the team should also request information relating to the focus areas ahead of the onsite audit week in order to promote efficiency and prepare for the audit activities. Additional time with regional office members may be scheduled, if necessary, to meet the objectives of the audit, but efforts should be made to limit the onsite office visit to one week or less.

The audit team leader will coordinate with the Region II Technical Support and Assessment Branch to accomplish the standardized audit items and requests for information, as well as the support requirements for the onsite audit week portion of the audit, taking into account the regions schedule of activities. The audit team lead, coordinating with region, will conduct an entrance meeting with regional management at an appropriate time during the audit week with DRO management participating as available. Throughout the audit week, the team leader will discuss the teams findings with the appropriate regional management. The team leader, in coordination with the audit team members, will conduct an exit meeting near the end of the audit week, with DRO management participating as available.

A draft report will be prepared by the team leader, with inputs from all team members, within 30 days of the exit meeting. This report will summarize the results of the standardized implementation audit items and the results of the deep-dive review of the audit focus areas, as well as any areas where the NRR program office is requested to provide additional clarification or guidance. A final report will be issued within 60 days of the exit meeting.

All time expended on ROP implementation audit activities should be charged to CAC A11018.

This charter may be modified should the team develop significant new information that warrants review. Should you have any questions concerning this charter, contact me via email or Microsoft Teams.

R. Felts 4

SUBJECT:

CHARTER FOR THE REGION II CALENDAR YEAR 2023 REACTOR OVERSIGHT PROCESS IMPLEMENTATION AUDIT DISTRIBUTION:

M. Ferdas, Region I S. Smith, Region II A. McCraw, Region III A. Agrawal, Region IV A. Garmoe, NRR/DRO/IRAB D. Bollock, NRR/DRO/IRIB N. Fields, NRR/DRO/IRAB RFelts, NRR/DRO PMcKenna, NRR/DRO/IRAB ADAMS Accession Number: ML23199A308 OFFICE NRR/DRO/IRAB NRR/DRO/IRAB NAME AGarmoe PMcKenna DATE 7/21/23 7/24/23 OFFICIAL RECORD COPY