ML19289D291

NRR-COM-106 Revitalization (October 17, 2019)

ML19289D291
Person / Time
Issue date:	10/17/2019
From:	Office of Nuclear Reactor Regulation
To:
Rowley J
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Download: ML19289D291 (11)

Text

NRR-COM-106 Revitalization TAR Technical Assistance Request TIA Task Interface Agreement Office of Nuclear Reactor Regulation (NRR)

RITF Public Meeting October 17, 2019 Program Coordinator Booma Venkataraman

COM-106 Program Revitalization TIA (TAR)

Risk-informing Modernized Decision-making Other Key Drivers Project Status 3-step, graded risk-informed approach proposed Program rebranding to TAR to align with NRO/NMSS Preliminary draft COM-106 completed NRR/NRO program components merge underway 2

• LSSIR: Low Safety Significance Issue Resolution

Industry Recommendations on TIA Process*

Increase Process Rigidity Greater Emphasis on Backfit Establish Exit Criteria for Low Safety Significance Issue Resolution Include an Appeal Process Eliminate Pre-decisional Consideration Enhance Communication Enhance TIA Coordinator Position

• Inputs received in public meetings on Feb. 21, and March 19, 2019 3

TIA Program Challenges

1. Timeliness

2. Effectiveness Effort on low safety significant issues Delayed hand-offs to other processes Issues outside the scope of the TIA Lack of early and/or inconsistent alignment Inconsistent licensee engagement 4

New Graded Approach to Efficient and Effective Issue Scoping, Routing and Resolution

• Boosted collaboration with requestor

• Enhanced 3 licensee Safety engagement at Significance every step 2 1 IN-DEPTH REVIEW SCREENING AND Unresolved INTAKE EVALUATION question(s) from routine TAR

~ 8 hr. goal ~ 30 day goal

Response

processes Memo Intake forms TAR Screening and TAR referral, Evaluation Results response or Memo recommendations

• Early alignment: Integrated Team Actions/

• Diverse facts: OGC on board early Decisions in

• Rigor in scoping/ framing questions Routine Processes 5

Featuring LSSIR Principle within TAR and ROP ROP issue of IMC 612 Is it of very Yes Inspection Public concern LSSIR low safety durable Criteria Disposition:

report per related to LB* significance document No or IMC 611 standing applicable per IMC 609? no further Indeterminate regulatory action and met Actions or Decisions by ROP NRR-COM-106 TAR Acceptance Criteria Met?

TAR Process Screening Intake and In-depth Review Phase Evaluation Phase Phase Facts Please Safety Significance Determination TAR If issue is of insufficient safety significance and of indeterminate LB Recommend-standing, it may be recommended for no further action ation 6 Non-public

• LB- Licensing Basis document

Next Steps Completion of draft merged COM-106 by October 31, 2019 Industry engagement with table tops November 7, 2019 Rollout and training by early December 2019 Merged NRR COM-106 completion by January 2020 7

Revitalized and Merged COM-106 Restructured as a fact gathering exercise to inform decision-making No agency action or decision taken within TAR Applies effort commensurate with the significance of the issue Merged TAR Components New Reactors Operating Reactors Construction TARs Revitalized TIA Process (NRO COM-108) Merged (NRR COM-106)

Leverage current process SharePoint Major overhaul Refined templates Site New templates and tools 8

Backup Slides 9

New: Safety Significance Determination Tool Integrated (In Screening and Evaluation) Decision-making 10

High safety Not clearly within the Clearly within the existing licensing basis existing licensing basis Evaluate issue to determine regulatory actions with tools such as: Address issue with appropriate tools such as:

• 50.54(f) or generic communication

• Enforcement

• Backfittting

• Order

• If generic - screen as a generic issue

• Consider prompt corrective actions (CAP)

• Use LIC-504 and TIA as applicable Address issue with appropriate tools (i.e., either the Not within the licensing basis + clearly low safety - licensee comes into compliance or changes the EXIT: licensing basis):

• Document decision

• Corrective actions (CAP)

• Make public record

• Enforcement discretion

• Change the licensing basis (50.59, LAR, relief, exemptions, etc)

• Assess adequacy of the requirement (i.e.,

rulemaking) 11 Low safety