ML24023A618

Us Dept. of Commerce, National Institute of Standards & Technology - Nuclear Program Assessments Response and Leadership Accountability

ML24023A618
Person / Time
Site:	National Bureau of Standards Reactor
Issue date:	01/23/2024
From:	Adams J US Dept of Commerce, National Institute of Standards & Technology (NIST)
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24023A617	List: ML24023A618 ML24023A619 ML24023A620 ML24023A621 ML24023A622 ML24023A623
References
Download: ML24023A618 (4)

Text

January 23, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 2055-0001

Subject:

Nuclear Program Assessments Response and Leadership Accountability Ref: NBSR Facility License TR-5, Docket 50-184

Dear Sir or Madam:

This submittal addresses several sections and action requirements of the NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY, CENTER FOR NEUTRON RESEARCH - CONFIRMATORY ORDER (CO), EA 21-148, August 1, 2022. Specifically:

• V.2.b.ii Nuclear Program Assessment(s) - Requirement Within 3 months of issuance of the assessment report(s) (or within 3 months of the issuance of the last report, if multiple contracts are awarded), NCNR will submit a copy of the safety assessment report(s) and NCNRs written response to the assessment report(s) to the NRC. NCNRs written response will either address how it will implement the recommendations and corrective actions of the assessment report(s), including a proposed timeline; or provide an explanation and justification for why the recommendation(s) and corrective action(s) will not be implemented.

• V.2.e Safety Culture Monitoring Panel (SCMP) - NCNR is providing an update in the V.7.b Leadership Accountability Section

• V.7.b Leadership Accountability - Requirement Within 12 months of the contract award discussed in Provision 2.b, NCNR will conduct training for all senior leaders, with support of the nuclear consultant selected under Provision 2.b, and which will include training on NUREG-2165, Safety Culture Common Language (INPO 12-012, Traits of a Healthy Nuclear Safety Culture, Revision 1). NCNR will incorporate this leadership training into an annual required safety culture refresher training for senior leaders.

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V.7.b Leadership Accountability During the week of November 27, 2023, the NCNR held Nuclear Safety Culture Training for its senior leadership. Twelve leaders representing NCNR Reactor Operations and Engineering (ROE) participated, including full-time attendance by the NCNR Director, Deputy Director and Chief of ROE, and the Chiefs of Reactor Operations, Engineering, Health Physics, and Aging Reactor Management. Additional participants included the Quality Assurance Program Manager, Safety Program Coordinator, Project Management/Employee Concerns Representative, Scheduling Specialist, Operations Training Supervisor, and the Safety Evaluation Committee (SEC) Chairman.

This training consisted of three major sections: Safety Culture Common Language training and workshop, Roleplay and Case Studies, and a facilitated Safety Culture Monitoring Panel (SCMP) using contemporary facility data as outlined in the Nuclear Energy Institute (NEI) 09-07 Fostering a Strong Nuclear Safety Culture, and the NCNR NSCMP Charter, previously submitted to the NRC in June of 2023.

A post-training report is available for inspection, including a training critique, the training materials and attendance sheets, and a draft SCMP Report. The final completed SCMP Report with Corrective Action Program (CAP) items and assignments is under review and will be available for inspection when complete.

An outcome of the overall training task was the development of a SCMP Implementing Procedure (update to V.2.e SCMP) to ensure sustainability of the process. This procedure is presently in review.

V.2.B.ii Nuclear Program Assessment(s) - written response The NCNR performed five program assessments to address the six Confirmatory Order (CO)-

mandated assessment areas (the SAC and SEC program areas were completed by a single assessment). The final program assessment, Problem Identification and Resolution, was completed, and the report issued on December 6, 2023. These assessments resulted in a total of 49 Areas for Improvement (AFI), Areas Needing Attention (ANA), and recommendations that were collectively evaluated, risk-ranked, and prioritized by the NCNR ROE Leadership (by a team whose composition was similar to those who took the Nuclear Safety Culture training), for developing plans forward that will result in an Integrated Performance Improvement Plan (IPIP).

The IPIP is envisioned to be a living document with clear delineation between CO-mandated items and improvements that the NCNR identifies as necessary but beyond the scope of the CO.

Figure 1 provides an overview of the IPIP development scheme.

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Figure 1. Integrated Performance Improvement Plan Development and Inspection Readiness The first phase of the collective evaluation combined all AFI, ANA, and recommendations from all CO assessments, including the Initial Nuclear Safety Culture Assessment, as well as other CO-defined actions (such as the outcomes of the December 2023 SCMP) into seven initiative areas:

• Integrated Safety Culture

• Performance Improvement

• Communications

• Training

• Procedures

• Work Management

• Resource Strategy The strategy for the Integrated Safety Culture and the Training initiatives has been developed, and the initial task orders are moving towards contract issuance. The other five initiative areas are currently under development.

A timeline projection is presented in Figure 2. The NCNR is focused on the following major milestones:

• Completion of the Event Root Cause Re-evaluation and integration by the end of the 2nd quarter of CY24.

• Completion of the seven Initiative Strategy Task Force efforts by the mid-2nd quarter CY24.

• Conduct of the Collective Evaluation Phase 2 by mid-3rd quarter of CY24. This will consolidate all efforts to date, the Event Root Cause Re-Analysis findings, and the strategy efforts of the seven initiative areas into one document that provides traceability from source to action and completes the initial draft of the IPIP.

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Figure 2. Timeline Projection Please contact Dr. Thomas H. Newton with any questions regarding the information presented herein. Dr. Newton may be contacted at 301-975-6260 or Thomas.newton@nist.gov.

Sincerely, Dr. James M. Adams Director NIST Center for Neutron Research Attachments:

• Independent Nuclear Safety Consultant Assessment of the Root Cause Analysis Performed by NCNR into the February 3, 2021 Event at the NIST Center for Neutron Research, July 11, 2023

• Problem Identification and Resolution (PI&R) Performance Area Assessment Report, December 6, 2023

• Independent Nuclear Safety Consultant Assessment of Training at the NIST Center for Neutron Research (NCNR), September 1, 2023

• Assessment of NCNR-ROE Procedures Program, October 23, 2023

• Final Report Safety Evaluation Committee (SEC)/Safety Assessment Committee (SAC),

September 5, 2023 Page 4 of 4