ML23313A148
| ML23313A148 | |
| Person / Time | |
|---|---|
| Issue date: | 11/08/2023 |
| From: | Sarah Obadina NRC/NRR/DRO/IRIB |
| To: | |
| References | |
| Download: ML23313A148 (1) | |
Text
Problem Identification and Resolution Sarah Obadina, Reactor Operations Engineer Zack Hollcraft, Senior Reactor Operations Engineer NRR/DRO/IRIB
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Background===
- SECY 19-0067, Recommendations for Enhancing the Reactor Oversight Process (ML19070A036)
- Comprehensive Review completed fall 2020 (ML20247J590)
- SECY 19-0067 withdrawn fall 2021 (ML21217A284)
- IP 71152 revision issued in winter 2021 (ML21281A181)
- SECY-22-0087, Recommendations for Problem Identification and Resolution Team Inspection Frequency to maintain biennial frequency
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 22-0087, 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 corrective action abilities 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
- Reformatted IP and aligned it with IMC 0040
- Added assessment guidance for documentation - did NOT add any additional oversight mechanisms
- ROP feedback forms and lessons learned actions
- Updated IMC 0611 App D governance for documentation (ML22339A153 and ML17129A591), and IMC 0308 Att 2 inspection bases (ML19056A200)
- PI&R team inspection conduct should remain the same
Significant Changes
- Biennial Team Inspection
- Qualitative criteria in different areas
- Areas include identification, evaluation, and correction of plant problems, appropriate use of OE, effectiveness of licensee audits and self assessments, and SCWE
- Performance Attributes
- Combined into qualitative criteria
- PI&R program compliance with NRC regulations
- Inspection requirement added
Biennial Team Inspection
- Area: Identification
- Requirement: Assess the licensees ability to identify and enter issues into their PI&R program
- Guidance
- Related CCAs
- Success criteria:
- Licensee staff enter conditions into PI&R program at low threshold.
- For NRC-identified issue(s), the licensee did not miss opportunities to identify the problem(s)
- Observations:
- A failure to identify or enter a significant condition adverse to quality (SCAQ) into the PI&R program.
- Multiple NRC identified trends during the assessment period not previously identified by the licensee.
Compliance With NRC Regulations
- Requirement: Confirm that the licensees PI&R program complies with NRC regulations and any self-imposed or other standards necessary for continued participation in the Reactor Oversight Process.
- Applicable regulations, guidance, and industry standards
- 10CFR Part 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants
- Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
- NEI 16-07, Improving the Effectiveness of Issue Resolution to Enhance Safety and Efficiency
- Requirement added is not new
- Language included in Biennial Team Inspection report cover letters
- Provides guidance associated with inspection objective
Questions?