ML19016A368

Action Matrix Proposal 20190116

ML19016A368
Person / Time
Issue date:	01/16/2019
From:	Office of Nuclear Reactor Regulation
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Download: ML19016A368 (4)

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Proposed Changes to Action Matrix ROP Enhancement Recommendation 2B.1 Explanation of Changes Below is a description of the current and proposed contents of the Reactor Oversight Process (ROP)

Action Matrix1. A mark-up of the Action Matrix (Figure-1 from NRC Inspection Manual Chapter 0305) is provided at the end of this document. Cells within that table are identified by their column (letters A-H) and row (numbers 1-11) to help in locating the proposed changes.

Change Column Headings Current [Row 1]: [The Action Matrix currently uses descriptive text and numbers to label the columns (e.g., Licensee Response Column (Column 1)). The current labels for Action Matrix Columns 1 and 2 give no sense of the relative significance of column changes.

Proposed [Row 1]:

a) [Cells C1-D1] Reword the first two column headings to clarify that licensee performance is normal in both columns.

b) [Cell E1] Remove the designation Column 3 from the heading of Action Matrix Column 3.

c) [Cell F1] Remove the designation Column 4 from the heading of Action Matrix Column 4.

Basis: The proposed change in column headings corresponds to the change in labeling White findings as of low safety significance that was recommended by industry and the expectation that occasional White findings are part of normal performance.

Change Results (Column Entry Criteria)

Current [Cell E2]: The criteria for entry into Action Matrix Column 3 currently are 3 or more white inputs or 1 yellow input, or 3 white inputs in any strategic performance area.

Proposed [Cell E2]: Revise criteria to read 3 or more white inputs in same cornerstone or 1 yellow input, or 3 white inputs in any strategic performance area.

Basis: The proposed change is editorial, to clarify that the degraded cornerstone is one in which three or more White inputs occur. A degraded cornerstone is not to be declared when any three White inputs occur in some combination of Whites across various cornerstones.

Change Response Rows Current [Cells A3-D6]: The Response entries for current Action Matrix Column 2 signal a significant escalation from the responses shown in current Action Matrix Column 1. The NRC Responses should be revised to reflect the true, de minimis change in safety significance associated with a White finding or performance indicator.

Proposed [Cells D3-D6]: In current Action Matrix Column 2, change the following:

a) Regulatory Performance Meeting entry [Cell D3] says meeting is to occur with the regional Branch Chief or Division Director; eliminate the or Division Director, to reflect the sufficiency of Branch Chief contact for response to White findings.

1 Figure 1 in NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program, June 21, 2018, ADAMS ML18059A337.

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Proposed Changes to Action Matrix ROP Enhancement Recommendation 2B.1 b) Licensee Action entry [Cell D4] specifies that licensee root cause evaluation will be available; per NEI 16-072, replace the mention of root cause evaluation with causal evaluation.

c) NRC Inspection entry [Cell D5] specifies Baseline and Supplemental Inspection IP 95001);

follow-up by Region; replace this with Follow-up by Resident Inspector with assistance from regional specialist if necessary.

d) Regulatory Actions entry [Cell D6] specifies Supplemental inspection only. Change this to Adjustment to Baseline sample areas as necessary.

Basis: The proposed changes clarify the level of NRC response is consist is editorial, to clarify that the degraded cornerstone is one in which three or more White inputs occur. A degraded cornerstone is not to be declared when any three White inputs occur in some combination of Whites across various cornerstones.

Change Communication Rows Current [Cells A7-D10]: As above, the Communication entries for current Action Matrix Column 2 convey a significant escalation from the responses shown in current Action Matrix Column 1. The Communications should be revised to reflect the true, de minimis change in safety significance associated with a White finding or performance indicator.

Proposed [Cell C7]:

a) Assessment Letter entry [Cells C7-D7] says Branch Chief or Division Director reviews and signs assessment letter with inspection plan; eliminate the or Division Director, to reflect the sufficiency of Branch Chief review of the response to White findings.

a) Annual Involvement of Public Stakeholders entry [Cell D8] specifies that the Branch Chief or Division Director should consider these options; eliminate or DD to reflect the sufficiency of Branch Chief involvement.

b) External Stakeholders entry [Cell D9] specifies contacting the state governors affected; eliminate this contact to reflect the de minimis change in safety significance of a White finding or performance indicator.

2 NEI 16-07, Improving the Effectiveness of Issue Resolution to Enhance Safety and Efficiency, Revision 0, transmitted to NRCs Michael R.

Johnson by NEIs Joseph Pollock letter dated April 18, 2018.

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Proposed Changes to Action Matrix ROP Enhancement Recommendation 2B.1 Proposed Figure 1: Reactor Oversight Process Action Matrix A B C D E F G H Normal Degraded Multiple/Repetitive Unacceptable 1 IMC 0350 Process1 Regulatory Performance5 Regulatory Performance Degraded Cornerstones Performance High Regulatory Good Regulatory One degraded Repetitive degraded Overall unacceptable Plants in a shutdown Performance: All Performance: One or cornerstone (3 or more cornerstone, performance; condition with assessment inputs two white inputs in a white inputs or 1 yellow Multiple degraded Plants not permitted to performance problems (performance strategic performance input), or cornerstones, operate within this band; are placed in the indicators and area; 3 white inputs in any Multiple yellow inputs, or Unacceptable margin to IMC 0350 process 2 inspection findings) Cornerstone objectives strategic performance One red input; safety (i.e., removed from the green; met with low impact on area; Cornerstone objectives met ROP)

RESULTS Cornerstone objectives safety performance Cornerstone objectives with longstanding issues or fully met met with moderate significant degradation in degradation in safety safety performance performance Regulatory None Branch Chief with Regional Administrator or EDO/DEDO or designee EDO/DEDO or designee RA/EDO or designee Performance licensee designee meets with meets with senior licensee meets with senior meets with senior 3

Meeting senior licensee management licensee management licensee management management.

Licensee Action Licensee corrective Licensee causal Licensee cumulative root Licensee performance Licensee performance action evaluation and cause evaluation with improvement plan with improvement & restart 4

corrective action with NRC oversight NRC oversight plan with NRC NRC oversight oversight NRC Inspection Risk-informed baseline Follow-up by Resident Baseline and Baseline and supplemental Baseline and inspection program Inspector with supplemental inspection inspection (IP 95003) supplemental as assistance from IP95001 for isolated practicable; 5

specialist if necessary Yellow finding Special inspections IP 95002 for findings with per restart checklist.

relational consequences

RESPONSE

Regulatory None Adjustment to related Supplemental inspection 10 CFR 2.204 DFI; Order to modify, CAL/Order requiring Actions2 Baseline samples if only; 10 CFR 50.54(f) letter; suspend, or revoke NRC approval for 6 necessary Plant discussed at AARM CAL/Order; license; restart; if conditions met Plant Discussed at AARM Plant discussed at Plant discussed at AARM AARM Assessment Branch Chief reviews Branch Chief Regional Administrator Regional Administrator N/A. RA or 0350 Letters and signs assessment reviews/signs reviews/signs reviews/signs assessment Panel Chairman 7 letter w/ inspection plan assessment letter w/ assessment letter w/ letter w/ inspection plan review/ sign 0350-inspection plan inspection plan related correspondence Annual Various public Various public Regional Administrator or EDO/DEDO or designee N/A. 0350 Panel Involvement of stakeholder options stakeholder options designee discusses discuss performance with Chairman conducts 8 Public involving the senior involving the Branch performance with senior senior licensee periodic public status COMMUNICATION Stakeholders resident inspector or Chief licensee management management meetings Branch Chief External None None State Governors, DHS, State Governors, DHS, State Governors, DHS, 9

Stakeholders3 Congress Congress Congress Commission None None Possible Commission Commission meeting with Commission meeting Commission meetings Involvement meeting if licensee senior licensee with senior licensee as requested; 10 remains for 3 years management within management Restart approval in 6 months.4 some cases.

11 ..INCREASING SAFETY SIGNIFICANCE Page 3 of 4 Revised 20190116

Footnotes to Figure 1 above 1 The IMC 0350 Process category is included for illustrative purposes only and is not necessarily representative of the worst level of licensee performance. Plants in the IMC 0350 oversight process are considered outside the auspices of the ROP Action Matrix. See IMC 0350, Oversight of Reactor Facilities in a Shutdown Condition due to Significant Performance and/or Operational Concerns, for more information.

2 Other than the CAL, the regulatory actions for plants in the Multiple/Repetitive Degraded Cornerstone and IMC 0350 categories are not mandatory NRC actions. However, the regional office should consider each of these regulatory actions when significant new information regarding licensee performance becomes available.

3 These specific stakeholders shall be notified if a plant is moving to the specified category because of security-related issues.

4 The timing of the meeting shall be based on a collegial determination by the Commission informed by a recommendation from the EDO, and may exceed the six-month requirement 5 The first category of performance is labeled normal regulatory performance given that issues arising in this category are very low or low safety significance. Issues in this category pose little to no risk to the public health and safety and are considered normal, random variations in performance.

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