ML17271A266
| ML17271A266 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/2017 |
| From: | Human Performance, Operator Licensing & ITAAC Branch |
| To: | |
| Gaslevic J, NRO/DCIP | |
| Shared Package | |
| ML17263A152 | List: |
| References | |
| Download: ML17271A266 (6) | |
Text
1 Enclosure 1 ITAAC Demonstration Project Action Plan Recommendation Detailed Action Items Lead and Supporting Roles Due Date (Calendar Year) Weekly Public Meetings
- 1. Utilize weekly public meetings to facilitate resolution of critical issues associated with ITAAC closure notification (ICN) and uncompleted ITAAC closure notification (UIN) reviews, including items such as the intent of an ITAAC, ICNs with challenges, methods for resolution of issues, and informed decision making.
In addition, establish standing agenda items during the weekly public meeting to discuss expected ICN submittal workloads to allow early notification of resource needs and critical process points.
Increase the frequency of public meetings to accelerate the resolution of emerging ITAAC closure issues as the surge approaches.
This recommendation has been implemented. Staff is currently using the public meetings to effectively discuss and address ICN and UIN issues.
NRC-REG-103, "Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Closure Verification Process," will be updated and publicly released to include process and the purpose of meeting. Lead = DCIP/HOIB Support = DNRL Complete
1 Qtr 2018 Clarity in Existing Industry Guidance
- 2. Develop an FAQ-type process to provide a forum to document discussions and resolutions of issues associated with the content of ICNs and UINs, which may be due to gaps in existing guidance or interpretation discrepancies.
Assess existing guidance and determine if there is still a need for a new process to deal with generic issues associated with the content of ITAAC notificati ons, or if issues will be dealt under the public meeting process in Recommendation 1.
Document staff assessment.
NRO/DCIP/HOIB 4 Qtr 2017
1 Qtr 2018 2 Recommendation Detailed Action Items Lead and Supporting Roles Due Date (Calendar Year) 3. Work with stakeholders to identify complex ITAAC issues by reviewing early submittals of uncompleted ITAAC notifications and develop clear expectations for the content of the associated ICN submittals. This effort will include identifying when complex ITAAC will be completed during the construction schedule.
Update and publicly release NRC-REG-103 to capture definition of complex ITAAC, how complex ITAAC are assessed, and how issues will be resolved.
NRO/DCIP/HOIB 1 Qtr 2018 NRC Processes Guidance Enhancement
- 4. Revise applicable NRO office instructions to ensure lessons learned and enhancements for the ICN process, identified during this demonstration project, are institutionalized. The revision should include, but is not limited to, the development of the criteria of when technical reviewer referral is needed during the reviews of ITAAC notifications, the evaluation of the requirement of completing half of targeted ITAAC before completing verification of non-targeted ITAAC within an ITAAC family, and the involvement of technical staff for all ITAAC notifications related to security and emergency-preparedness.
Make the revised NRC office instruction NRO-REG-103 publicly available to give stakeholders insight into the NRC's ITAAC notification review
process.
Update and publicly release NRC-REG-103 to capture:
- 1) lessons learned and enhancements to the ITAAC review process that enable staff to
resolve ITAAC closure issues consistently and efficiently
- 2) the evaluation of the requirement of completing half of targeted ITAAC before completing verification of non-targeted ITAAC within an ITAAC family
- 3) criteria for including technical reviewer during reviews of ITAAC notifications
NRO/DCIP/HOIB 1 Qtr 2018
3 Recommendation Detailed Action Items Lead and Supporting Roles Due Date (Calendar Year)
- 5. Enhance NRC processes, including associated governing documents, communications, and training, to ensure timely identification and resolution of concerns or findings material to ITAAC, such that ITAAC inspection results support key activities and milestones in the ITAAC closure verification process.
- a. Enhance/develop, as applicable, the following processes: technical assi stance requests (TARs), unresolved items (URIs), ITAAC inspection findings, allegations and petitions, and ITAAC post closure notifications (IPCNs). For TARS, consider the frequency of performing this process; the timeliness of TAR processing; and interactions with licensees for visibility purposes.
- b. For inspection findings, consider enforcement
actions and internally and externally disputed findings. Consider which NRC process activities, if any, can be done in parallel with the evaluation of an ITAAC technical concern.
Complete each of the following items for NRC processes TARs, URIs, ITAAC inspection findings, allegations, and IPCNs. 1) Pilot process enhancement for two topics: Inspection Inputs and ICN Inspection Schedule Accountability, in order to identify
lessons learned and incorporate into the
Action Plan for other processes.
- a. Develop timeliness metrics for Inspection Inputs and ICN Inspection Schedule Accountability.
- b. Execute pilot and evaluate effectiveness of metrics and process enhancements.
- c. Finalize metrics from pilot lesson learned.
- d. Incorporate lessons learned into the development process of additional timeliness metrics (Step 2). 2) Develop process enhancements for the
following areas: TARs, URIs, ITAAC inspection findings, allegations and petitions, and IPCNs.
- a. Develop timeliness metrics for the above areas.
- b. Execute and evaluate effectiveness of metrics and process enhancements.
- c. Finalize metrics from lesson learned.
- d. Incorporate lessons learned into the development process of additional timeliness metrics, as determined. RII
Complete
4 Qtr 2017 4 Qtr 2017
4 Qtr 2017
4 Qtr 2017
1 Qtr 2018
1 Qtr 2018 1 Qtr 2018
4 Recommendation Detailed Action Items Lead and Supporting Roles Due Date (Calendar Year) 3) Determine if additional guidance is needed for each process affecting ITAAC closures. Create working level guidance (i.e. Desktop Guides) for RII and NRO staff. Revision of guidance documents, such as inspection manual chapters (IMCs) and inspection procedures (IPs), will be completed under the regularly scheduled update for each of those documents. 4) Develop and implement change management plan for training needs and communication plan, which includes follow up public meeting, with the licensee and the public.
2 Qtr 2018
2 Qtr 2018 Performance Dashboards
- 6. Create an integrated, highly visible, internal, color-coded performance dashboard to track the
status of each step for ICN reviews and inspection process for early identification of ITAAC closure related issues for management attention and
resolution.
Specific process steps to measure should include:* The status of each step for ICN reviews.
- Key aspects of the inspection process, including the timeliness of report issuance, inspection initiators, and inspection outcomes Develop performance dashboards to track the status and timeline ss of ICN reviews and ITAAC inspections based on program metrics.
Develop performance dashboards for
inspections that affect ITAAC closures to highlight issues based on program metrics.
NRO/DCIP/HOIB and RII 4 Qtr 2017
4 Qtr 2017
5 Recommendation Detailed Action Items Lead and Supporting Roles Due Date (Calendar Year)
- Potential inspection scheduling or resource
issues Inspection Scheduling
- 7. Determine the most efficient location and time for inspections. Continue to focus on short-duration construction activi ties, such as installing the reactor vessel, which are unlikely to be repeated for additional inspection opportunities.
Additionally, verify that test procedure inspections are scheduled when procedures are issued and available versus when the tests are being performed.
Incorporate scheduling process lessons learned into Desktop Guide(s) including decision making on how to schedule different types of inspections.
Produce a schedule of pre-op test procedure reviews and tests to verify inspections are scheduled ahead of tests.
RII 1 Qtr 2018
2 Qtr 2018
Timeliness of Inspection Reports
- 8. Establish timeliness requirements for inspection disposition including inspection completion in CIPIMS and inspection report issuance to support the ITAAC surge and the 10 CFR 52.103(g) finding.
Review existing process(s) for inspection report timeliness requirements, including dispositioning inspection findings for potential efficiencies.
Create or revise working level guidance (i.e. Desktop Guides) for RII and NRO staff to capture efficiencies for inspection report timeliness. Revision of guidance documents, such as IMCs and IPs, will be completed under the regularly scheduled update for each of those documents.
Lead = DCIP/CIPB Support = RII 1 Qtr 2018
2 Qtr 2018
6 Recommendation Detailed Action Items Lead and Supporting Roles Due Date (Calendar Year) Maintain Qualified Staff
- 9. To ensure continued ICN review and inspection capacity, cross-train additional staff to support ICN workflow capacities and ITAAC inspections.
For inspector qualification, the NRC will incorporate construction inspector training into IMC-1245.
Update and publicly release NRC-REG-103 to capture the cross-training procedure, including developing a metric to track amount of staff cross-trained and number of ICN reviewed in a given year to maintain proficiency in ICN reviews. Construction inspector qualification will be incorporated into IMC 1245 Appendix C-15 DCIP/HOIB
RII 1 Qtr 2018
Complete Organizational Structures
- 10. Establish a temporary organizational structure with senior executive leadership approximately 12-months before projected fuel load. This organization would oversee and coordinate the ITAAC closure verification process to ensure appropriate decision making and the prompt identification and resolution of issues.
Develop and capture in a memorandum the criteria for establishing a temporary organization to oversee the ITAAC closure verification process.
NRO 1 Qtr 2018 External Stakeholders
- 11. Create a message map on key aspects and updates of the ITAAC process for external stakeholders. Update this message map on a quarterly basis.
Develop a message map that includes key aspects of the ITAAC process.
Update and publicly release NRC-REG-103 to capture that the message map will be reviewed and updated on a quarterly basis.
NRO/DCIP 4 Qtr 2017
1 Qtr 2018