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
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- SECY 19-0067 withdrawn fall 2021 (ML21217A284)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?