VR-SECY-22-0086, Recommendations for Revising the Reactor Oversight Process Assessment Program (Crowell)

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VR-SECY-22-0086: Recommendations for Revising the Reactor Oversight Process Assessment Program (Crowell)
ML23066A031
Person / Time
Issue date: 03/06/2023
From: Crowell B
NRC/OCM/BRC
To: Brooke Clark
NRC/SECY
Shared Package
ML23066A024 List:
References
SECY-22-0086, SRM-SECY-22-0086 VR-SECY-22-0086
Download: ML23066A031 (2)


Text

POLICY ISSUE NOTATION VOTE RESPONSE SHEET TO: Brooke P. Clark, Secretary FROM: Commissioner Crowell

SUBJECT:

SECY-22-0086: Recommendations for Revising the Reactor Oversight Process Assessment Program Approved X Disapproved Abstain Not Participating COMMENTS: Below Attached X None Bradley R. Digitally signed by Bradley R. Crowell Crowell Date: 2023.03.06 13:05:05 -05'00' Entered in STAR Signature Yes X No

Commissioner Crowells comments on SECY-22-0086, Recommendations for Revising the Reactor Oversight Process Assessment Program In SECY-22-0086, the staff presents options for the treatment of greater-than-green (GTG) inspection findings and performance indicators (PI), which are used in the NRCs Reactor Oversight Process (ROP) to assess the safety performance of each commercial nuclear power reactor. One of the primary goals of the SECY is to address inconsistencies in how inspection findings and performance indicators are currently addressed by licensees and NRC inspectors and how both sets of information are presented on the NRCs reactor Action Matrix. The staffs recommendation would eliminate the minimum four-quarter requirement for GTG inspection findings and revise the treatment of GTG PIs to simplify their input to the ROP Action Matrix.

The staff notes that one of the advantages of this approach is that GTG inspection findings and PIs will be treated consistently. In addition to enhancing the reliability and clarity of the ROP assessment process, these changes will incentivize the prompt implementation of corrective actions and subsequent completion of NRC supplemental inspections for GTG performance issues. I believe the benefits of promptly addressing inspection findings and implementing corrective actions outweigh related concerns regarding how performance trend data is captured on the Action Matrix. As such, I approve the staffs recommendation (Option 3).

However, I remain concerned about the manner in which Action Matrix data is currently presented on the NRC website and that none of the options presented by staff adequately address this shortcoming. Data and related information regarding both inspection findings and performance indicators should be easily accessible and understandable to the general public and non-technical stakeholders. The current format of the Action Matrix falls well short of this goal and should be appropriately addressed as part of any reform to the ROP process for inspection findings and performance indicators. As a starting point for doing so, I appreciate the staffs ongoing efforts to enhance the presentation and communication of ROP information via the NRCs public webpage. The Operating Reactor Analytics page is a good start for creating an interactive tool to explore the ROP Action Matrix, inspection findings, and performance indicator data. However, the staff should further build upon this effort to enhance NRC websites usability and accessibility of ROP information in a manner that allows a reasonably informed member of the public to easily locate and interpret ROP Action Matrix data and supporting information. Implementing such improvements should be treated as a first order priority in meeting the basic thresholds embodied in the NRC Principles of Good Regulation.