ML24289A087
| ML24289A087 | |
| Person / Time | |
|---|---|
| Issue date: | 11/05/2024 |
| From: | Gregory Stock Office of Nuclear Reactor Regulation |
| To: | Andrea Veil Office of Nuclear Reactor Regulation |
| References | |
| Download: ML24289A087 (1) | |
Text
MEMORANDUM TO:
Andrea Veil, Director Office of Nuclear Reactor Regulation FROM:
Russell N. Felts, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
UPDATED DISPOSITIONING OF SAFETY CULTURE PROGRAM EFFECTIVENESS REVIEW RECOMMENDATIONS The purpose of this memorandum is to provide a final updated disposition to each of the recommendations that the agency planned to implement related to the Safety Culture Program Effectiveness Review. This update is in consideration of the passage of the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024, in part, to make the oversight and inspection programs more efficient. The basis for the recommendations and original dispositions is documented in a memorandum entitled Dispositioning of Safety Culture Program Effectiveness Review Recommendations, dated September 7, 2023, Agencywide Documents Access and Management System (ADAMS)
Accession No. ML23208A187. Each of the recommendations and the final disposition are listed below.
Recommendation 1: [Inspection Manual Chapter] (IMC) 0305, Operating Reactor Assessment Program, and Inspection Procedure (IP) 95001, Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response) Inputs, should be updated to allow for an independent NRC evaluation of safety culture for plants in Column 2 of the [Reactor Oversight Process] ROP Action Matrix if the circumstances warrant. This would not necessarily constitute requiring the licensees to perform an independent third-party safety culture assessment. It would provide for independent NRC consideration of the need for sampling and assessing safety culture.
Final Disposition: Recommendation 1 will not be implemented. It was previously not recommended for implementation in ML23208A187.
CONTACT:
Molly Keefe-Forsyth, NRR/DRO Greg Stock, NRR/DRO (301) 415-5717 (570) 449-4306 November 5, 2024 Signed by N. Felts, Russell on 11/05/24
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Recommendation 2: Improve the training available to inspectors to better meet Commission objectives stated in SRM-SECY-04-0111 [Recommended Staff Actions Regarding Agency Guidance in the Areas of Safety Conscious Work Environment and Safety Culture]. (Note that steps are already in process that will support this recommendation, as the Office of Nuclear Reactor Regulation (NRR) has a User Need open with the Office of Nuclear Regulatory Research (RES) to enhance training on safety culture based on review of ongoing inspector feedback and projected workload needs.)
Final Disposition: Recommendation 2 will be implemented. Recommendations for enhancements to training have been approved and training modules are being updated.
Additional details regarding specific training and qualification enhancements are documented via memorandum in Safety Culture Training Working Group Recommendations, dated October 18, 2024 (ML24277A260, non-publicly available).
Recommendation 3: IP 93100, Safety Conscious Work Environment Issue of Concern Followup, should be revised to cover all aspects of safety culture, in addition to Safety Conscious Work Environment. This will provide the NRC with a tool that can be used for following up on safety culture concerns to encourage meaningful action before licensees are assessed in Column 3 of the ROP Action Matrix.
Final Disposition: Recommendation 3 will not be implemented. It was previously not recommended for implementation in ML23208A187.
Recommendation 3.a: IP 71152, Problem Identification and Resolution (PI&R), review of specific safety culture attributes should be expanded with a reference to the revised IP 93100 to provide guidance for a more comprehensive review of safety culture as necessary.
Considerations already factored into resource allocations for PI&R inspections, including review of data trends and inspector observations, should add consideration for including a qualified safety culture assessor on the team if warranted. The team estimates that this option would be essentially resource neutral.
Updated Final Disposition: Recommendation 3.a will not be implemented. It was previously recommended for partial implementation in ML23208A187.
Recommendation 3.b: Adjustments should be made to the existing inspection framework to allow for safety culture assessment when indicated using the revised IP 93100 procedure. This would leave IP 93100 as an App. C procedure, available for use at Regional Administrator (RA) discretion using criteria to be developed separately if this option is chosen. IP 93800, Augmented Inspection Team, and IP 93812, Special Inspection, should be updated to reference the revised IP 93100 and consideration of including a qualified safety culture assessor on the inspection team, as well as to emphasize the importance of reviewing safety culture attributes within the scope of the fact-finding purpose of the inspection, to better align the use of these procedures with the intent of changes initiated in response to the original Commission direction.
Updated Final Disposition: Recommendation 3.b will not be implemented. It was previously recommended for partial implementation in ML23208A187.
Recommendation 3.c: A regular safety culture assessment, based on the revised IP 93100, should be included as part of the baseline inspection program on a tri-/biennial basis. This could be performed through a graded assessment allotting greater or fewer resources depending on
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safety culture/Safety Conscience Work Environment (SCWE) related data amassed throughout the inspection cycle. This may require additional inspection resources beyond what is currently allocated, approximately 4-5 (which could include team members who are training to be qualified) team members on site for a week resulting in an estimate of 60-80 inspection hours.
Although SRM-SECY-04-0111 specifically decided against a baseline inspection option for safety culture in lieu of the current approach, this effectiveness review finds that the cross-cutting issues program in combination with a periodic safety culture assessment would more effectively meet the stated objectives of the program.
Final Disposition: Recommendation 3.c will not be implemented. It was previously not recommended for implementation in ML23208A187.
Alternative Recommendation: During discussions with NRC regional administrators (RAs) and Division Directors, an alternative recommendation was proposed which leverages the existing IMC 0305 quarterly ROP assessment review of licensee performance. The recommendation is to revise existing assessment guidance to prompt NRC Management discussions with licensees on any safety culture aspects discussed during quarterly reviews. This recommendation would encourage licensee action to address safety culture aspects before significant performance degradation occurs. This recommendation would not require additional inspection or significant additional resources, consistent with the graded approach in SRM-[SECY]-04-0111 for licensees in Column 1 or Column 2 of the ROP Action Matrix.
Final Disposition: The Alternative Recommendation will be implemented. A revision to IMC 0305, Operating Reactor Assessment Program, is targeted for issuance by the end of Calendar Year 2024 to provide guidance on the discussion of safety culture aspects during quarterly reviews and with the licensee when appropriate.
ML24289A087 NRR102 OFFICE NRR//24O/IRAB NRR/DRO/IRAB Region I Region II NAME MKeefeForsyth DAird RLaorson LDudes DATE 10/17/24 10/21/24 11//1/24 11/1/24 OFFICE Region III Region IV NSIR NRR/DRO NAME JGiessner JMonninger MKohen RFelts DATE 11/1/24 11/1 10/22/24 11/5/24