ML19338E029

Draft COM-106, Revision 6 Technical Assistance Request (TAR) Process

ML19338E029
Person / Time
Issue date:	12/05/2019
From:	Booma Venkataraman NRC/NRR/DORL/LPL3
To:
Venkataraman B
References
COM-106, Rev 6
Download: ML19338E029 (65)

Text

OFFICE OF NUCLEAR REACTOR REGULATION COM-106, Revision 6 Technical Assistance Request (TAR) Process Volume XXX NRC Interfaces Approved By: This is an interim draft version of the COM-106, Revision 6, that is being made public to facilitate stakeholder awareness.

Date Approved: A later draft will be issued in conjunction with a public meeting to solicit public feedback.

Effective Date: This interim version was made publicly available in December 2019.

Certification Date:

Responsible Organization: Division of Operating Reactor Licensing (DORL)

Primary

Contact:

Booma Venkataraman 301-415-2934 booma.venkataraman@nrc.gov Summary: This issuance of COM-106, Revision 6, Technical Assistance Request (TAR)

Process, establishes an overhauled and rebranded version of the COM-106, Revision 5, Control of Task Interface Agreements [TIA]. It merges relevant portions of the process contained in NRO Office Instruction, NRO-COM-108, Revision 1, NRO Construction Inspection Interfaces with Region II (ADAMS Accession No. ML113220316) into this revision of COM-106. This office instruction is effective XX, XX, XXXX, and applies to operating reactors and reactors under construction. Additionally, it incorporates a new graded approach, with enhanced guidance, streamlined tools and an improved SharePoint site 1 to address program lessons learned, to focus resources commensurate with the significance of the issue and meet stakeholder needs effectively and efficiently.

Training:

ADAMS Package Accession Number: ML--------

TABLE OF CONTENTS

1. POLICY ...........................................................................................................................1

2. OBJECTIVES ..................................................................................................................1

3. BACKGROUND...............................................................................................................2

4. BASIC REQUIREMENTS ................................................................................................2

5. RESPONSIBILITIES AND AUTHORITIES ....................................................................31

6. PERFORMANCE MEASURES ......................................................................................37

7. PRIMARY CONTACT ....................................................................................................37

8. RESPONSIBLE ORGANIZATION .................................................................................37

9. EFFECTIVE DATE ........................................................................................................38

10. CERTIFICATION DATE ................................................................................................38

11. REFERENCES ..............................................................................................................38 Appendix A - Change History Appendix B - Construction TAR Appendix C - Documentation Template Descriptions Appendix D - Operating Reactor TAR Summary of Action Steps 1 link to NRC SharePoint (TBD)

Office Instruction: Number, Technical Assistance Request (TAR) Process Dated: XX, XXXX ADAMS Package Accession No: ML--------

OFFICE NRR/DORL/PM NRR/DORL/LA NRR/DSS/WG NRR/DE/WG NAME BVenkataraman JBurkhardt SAnderson MMcConnell DATE / /19 / /19 / /19 / /19 OFFICE NRR/DRA/WG NRR/DIRS/WG NRR/Vogtle/WG RI/WG NAME DHelton BBenney TFredette PCataldo DATE / /19 / /19 / /19 / /19 OFFICE RII/WG RIII/WG RIV/WG RI/DRS or DRP/D NAME WDeschaine MHolmberg RKellar DATE / /19 / /19 / /19 / /19 OFFICE RII/DRS or DRP/D RIII/DRS or DRP/D RIV/DRS or DRP/D NRR/DORL/LSPB/BC NAME BC DATE / /19 / /19 / /19 / /19 OFFICE NRR/XXXX/XXX/BC OGC OE QTE NAME Vogtle BC DATE / /19 / /19 / /19 / /19 OFFICE NRR/DIRS/D NRR/DRA/D NRR/DSS/D NRR/DE/D NAME DATE / /19 / /19 / /19 / /19 OFFICE NRR/Vogtle 3&4/D NRR/DORL/D NRR/DRMA/D NRR/D NAME DATE / /19 / /19 / /19 / /19 OFFICIAL RECORD COPY

NRR Office Instruction COM-106, Revision 6 Page 1 of 38

1. POLICY It is the policy of the Office of Nuclear Reactor Regulation (NRR) to address questions raised by other Nuclear Regulatory Commission (NRC) organizations in a timely manner with a level of effort commensurate with the significance 2 of the underlying issue. As such, the Technical Assistance Request (TAR) process is used to offer information assistance to organizations within the NRC regarding operating nuclear reactors and their related regulatory and oversight programs and reactors under construction either under Title 10 of the Code of Federal Regulations (10 CFR) Part 50 construction permits or 10 CFR Part 52 combined license processes. The process ensures that NRR responses and recommendations are promptly communicated to appropriate stakeholders.

The general purpose of this office instruction (OI) is to provide guidance to NRR and other NRC organization staff for initiating and processing of TARs. The NRR management expects that TARs will be processed in a manner consistent with NRCs principles of good regulation (i.e., independence, openness, efficiency, clarity, and reliability) and organizational values (i.e., integrity, service, openness, commitment, cooperation, excellence, and respect).

2. OBJECTIVES To respond efficiently to the needs of both internal and external stakeholders, specific objectives include:

• Provide NRR and other staff an enhanced framework for processing TARs

• Promote consistency in processing TARs

• Guide effective scoping, screening, evaluation and resolution of issues

• Ensure the TAR process is applied to plant-specific inquiries

• Effect agile referrals to alternate processes where appropriate

• Promote a holistic and integrated view of safety during processing a TAR

• Focus level of effort, rigor, and resources commensurate with issue significance

• Ensure effective engagement among internal and external stakeholders

• Meet timeliness goals 2 Commensurate with the significance - A graded approach to focus resources on issues that are more significant to public health and safety. The term significance implies primarily risk-informed safety significance (i.e., all relevant principles of integrated decision-making, from NRR Office Instruction LIC-504). However, the term may apply to issues which may be referred to NRR to be significant for other reasons (e.g., high public interest, allegation related, reactor construction schedule, etc.).

NRR Office Instruction COM-106, Revision 6 Page 2 of 38

3. BACKGROUND COM-106 was first issued on November 26, 2001 and had several subsequent revisions (See Appendix A for Change History) as part of self-assessment and continuous improvement of the program. The TAR program was formerly known as the Task Interface Agreement (TIA) program. In January 2019, an agency working group was established to complete a major enhancement, called the TIA Revitalization Project.

The project had the following drivers:

• Align the program with the NRC organizational expectations of effective risk-informing and modernized decision-making

• Incorporate, as appropriate, recommendations from the NRR Low Safety Significant Issue Resolution (LSSIR) initiative (ADAMS Accession No. ML--------)

• Integrate best practices from other offices NMSS and NRO and identify the needs of merging with NROs program

• Holistically redesign the program with fresh stakeholder dialogue to fulfil the agency mission and vision Specifically, the working group considered several sources of insights including the operating experience of past TIAs, industry feedback (ADAMS Accession No. ML19077A297 and ML19074A141), other office best practices (e.g., NMSS), and feedback from agency staff surveys. A summary of the key feedback considered in the enhancements from various sources is available in ADAMS Accession No. XX(TBD).

Revision 6 of COM-106 overhauls and streamlines the TIA program (COM-106, Revision 5) and incorporates the recommendations and feedback as noted above.

4. BASIC REQUIREMENTS This section describes the procedure for initiating and processing TARs from other NRC organizations. This OI is intended to guide NRR staff in providing technical and assistance to other organizations and present the means to help ensure compliance with NRC rules, regulations, and applicable requirements (e.g., facility license) and thus ensure reasonable assurance of safety is maintained. The procedures in this section

NRR Office Instruction COM-106, Revision 6 Page 3 of 38 also address how the objectives as indicated in Section 2 of this OI will be achieved.

This section provides the procedures for the main process and includes several supporting sections applicable to the operating reactor and construction TAR process. A cross-reference lookup is included in Table 1.

Main TAR Process Snapshot Screening and In-depth Review Intake Phase Evaluation Phase (Section 4.8) Phase (Section 4.10)

(Section 4.9)

Construction TAR (Appendix B) 4.1 Introduction The TAR process is a fact-gathering and issue evaluation exercise that informs decision-making in other NRC processes within the NRCs licensing, oversight, and enforcement regulatory functions (e.g., the TAR may inform a plant-specific backfit). A TAR is a request for technical or information assistance, most often from a regional office, but it may also come from another NRC headquarters office. A TAR could also be used to obtain technical assistance on an allegation-related issue. A TAR should be viewed as the primary extension of the regulatory process it serves; for example, a TAR related to an unresolved item (URI) from an inspection should be considered as an extension of the inspection process. The decision of what, if any, agency action should be taken based on the information gathered in the TAR process will be up to the requesting office; no final agency action is made or communicated within the TAR process itself. Further, no agency position is communicated, or a regulatory decision made within the TAR process (See Figure 1).

A TAR addressing a new reactor construction activity is unique in that it may impact Part 52 construction Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) or may adversely impact the construction schedule for any NRC-regulated facility covered by 10 CFR Part 50 or Part 52. For these reasons, construction TARs are processed using the guidance detailed in Appendix B of this OI.

The goal of the TAR process is to support other NRC organizations efficiently and effectively. As such, TARs are not intended to replace the routine processes (e.g.,

informal discussions) that take place among NRR staff and other NRC offices. In these routine processes, NRC staff exchanges opinions and evaluates plant configurations and operating practices governed by regulatory requirements, staff technical positions, and good engineering practices. Occasionally, however, when the routine channels are exhausted for resolving an issue (e.g., issue has become protracted or stagnant) a formal mechanism (i.e., TAR) may be needed to ensure that the issue receives focused attention in NRR to be routed or resolved with an effort commensurate with its significance and with documentation as appropriate.

NRR Office Instruction COM-106, Revision 6 Page 4 of 38 The TAR process has a formal three-phase structure 3 to enable the review effort to be commensurate with the significance of the issue. The process includes templates and tools for safety significance screening, information intake, and recording and communicating responses.

An overview of the three-phase approach is provided below:

• Intake ( 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> level of effort):

The TAR Coordinator leads initial discussions to complete issue intake and gather facts from requestor for pre-screening of the issue. Facts gathered should typically include licensee inputs. If a resolution or a referral to an alternate process is achieved in this phase, then the issue is closed out with a record in the TAR SharePoint site. Refer to Section 4.8 of this OI for details.

When a construction TAR is identified, it will be processed using guidance in Appendix B of this OI, with a goal of resolving the construction-related technical issue in a timely manner (typically 30 days) so as not to impact closeout of construction inspection activities.

• Screening and Evaluation ( 30-day goal):

An Integrated Team (IT) which includes the TAR Coordinator and the requestor and other individuals such as members from the Office of General Counsel (OGC), conducts a screening and evaluation of issues submitted in the Intake phase, in order to align on the path forward. The IT performs a structured assessment, including to assess the issues safety significance.

The Screening and Evaluation results memorandum, with concurrences from the IT members and its Chairperson, will document the path forward including a response, if any. Refer to Section 4.9 of this OI for details. This phase will not apply to Construction TARs.

• In-depth Review ( 80-day goal):

The TAR Coordinator leads a focused collaboration with NRR technical staff, OGC, Office of Enforcement (OE) (if required), coordinating with the requestor as necessary, and engaging the licensee systematically as appropriate, to provide an in-depth review for issues referred from screening and evaluation phase. The output of this phase is a clear, concise, fact-based, and timely response, with NRRs Division of Operating Reactor (DORL) management sign-off. Refer to Section 4.10 of this OI for details.

This phase will not apply to Construction TARs.

All days indicated throughout this OI are in calendar days, unless noted otherwise.

3 Construction TARs will only be processed in the TAR intake and branch off to the steps described in Appendix B.

NRR Office Instruction COM-106, Revision 6 Page 5 of 38 Table 1. Cross-referencing Supporting Sections/ Appendices with Main TAR Process Supporting Description (may be Applicable Applicable to Applicable to Applicable to Section abbreviated) to Intake Screening and In-depth Construction Reference Phase? Evaluation Review Phase? TAR?

(Section Phase? (Section 4.10) (Appendix B) 4.8) (Section 4.9) 4.1 Introduction Yes Yes Yes Yes 4.2 Pre-Screening Yes No No Yes 4.3 Closure of Issues Yes Yes Yes Yes 4.3.1 Search for precedents Yes Yes No Yes 4.3.2 Generic Implications Yes Yes Yes Yes 4.3.3 Backfit and Issue Finality Yes Yes Yes No Considerations 4.3.4 Considerations of enforcement Yes Yes Yes Yes 4.4 Safety Significance Yes Yes No No Considerations 4.5 Acceptance Criteria Yes Yes Yes Yes 4.5.1 Issues outside TAR Yes Yes Yes Yes 4.5.2 Acceptance Criteria for No Yes No No Screening and Evaluation 4.5.3 Acceptance Criteria for In-depth No No Yes No Review 4.6 Interface with NRC Staff and Yes Yes Yes Yes Management 4.7 External Stakeholder Yes Yes Yes Yes Interactions 4.7.1 Verbal interactions Yes Yes Yes Yes 4.7.2 Written interactions Yes Yes Yes Yes 4.7.3 Voluntary Supplemental Yes Yes Yes Yes information 4.11 TAR Related to Allegation Yes Yes Yes Yes 4.12 Deviations for the Process Yes Yes Yes Yes 4.13 TAR withdrawals Yes Yes Yes Yes 4.14 Resolving requestor office No Yes Yes No disagreements 4.15 Continuous Improvement Yes Yes Yes Yes Appendix C TAR Intake Form Yes No No Yes Appendix C Screening and Evaluation No Yes No No Authorization e-mail template Appendix C Screening and Evaluation No Yes No No Results Memo template Appendix C In-depth Review Response No No Yes No Memo template Appendix D Operating Reactor TAR Yes Yes Yes No Summary of Action Steps

NRR Office Instruction COM-106, Revision 6 Page 6 of 38 4.2 Pre-Screening 4 of Issues for Determining an Early Path Forward The goal is to use the most expedient method for resolving questions or issues.

Therefore, the formality of a TAR generally should not be used when:

• The response is straightforward and readily available

• The issue has been pre-determined to be of clearly of very low safety significance and the requesting office could disposition 5 it under LSSIR, (Section 4.4 of this OI) effort 6

• The NRC staff has previously expressed a position regarding the issue

• The question or concern relates to another process and could be referred accordingly (e.g., backfit, generic issues, differing professional opinion, legal interpretations etc.)

• Choosing a more efficient process of answering the question would not compromise the NRCs regulatory functions (e.g., would rely on a licensees or vendors evaluation, staff informal resolution, etc.)

Specific pre-screen areas and respective instructions are described in Sections 4.3 and 4.4 of this OI. TAR acceptance criteria are described in Section 4.5 of this OI.

4.3 Closure of Issues: Response, Referrals or Other Recommendation When a TAR is closed, three outcomes are possible (Figure 1):

(1) the issue is resolved in the TAR process with a response to the requesting office formally documented in the Screening and Evaluation results memorandum or the in-depth review response memorandum, or with an entry to the Intake template technical response field for Construction TARs only, or recorded in the TAR SharePoint site, if the issue is closed out in the Intake phase (2) a recommended referral is made to another process (e.g., backfit) according to the applicable process and the issue will no longer be tracked in the TAR process (3) the issue is recommended for no further regulatory action due to its safety significance status and licensing basis standing as documented on the Screening and Evaluation results memorandum 4 The pre-screening guidance is primarily for the TAR Coordinator and staff in the formal intake phase.

However, this guidance may be used for pre-TAR activities to determine if a TAR is appropriate.

5 Close out the issue on its safety significance status and licensing basis standing to require no further regulatory action 6 The LSSIR criteria does not apply to construction TARs.

NRR Office Instruction COM-106, Revision 6 Page 7 of 38 From routine processes Unresolved question TAR Process If effort not commensurate with safety significance NRR COM-106 and other criteria met Refer to alternate process (e.g., backfit)

Recommend no further Resolution or Response regulatory action Figure 1. TAR Block Diagram The TAR closure documentation in Screening and Evaluation or In-depth review phases is not intended as an agency action or agency position and is intended to inform the process the TAR serves (e.g., inspection, enforcement, allegation, etc.). It is up to the requesting office to take necessary actions in the appropriate process using the disposition recommendation, referral or response from the TAR documentation.

For issues outside the scope of the TAR process (e.g., that do not meet the acceptance criteria or other circumstances), the TAR Coordinator should take action to ensure the issue is referred to the applicable process as early as possible to the appropriate program contact, with communication to the requesting office and the plant PM. Once the issues raised in the TAR are entered into the alternate process (See Section 4.5.1 of this OI for various alternate processes) after a TAR referral, the TAR Coordinator should prepare a memorandum to the requesting organization referencing the appropriate documents, stating that the issue was entered into another process and that the TAR is now considered closed. Next, the TAR Coordinator should re-status the TAR from the open to closed list on the monthly TAR status report. The TAR Coordinator should then close the Enterprise Project Identifier (EPID) number(s) associated with the TAR, if it is in the Screening and Evaluation or In-depth review phases.

The following sections (Sections 4.3.1 to 4.3.4) provide instructions on specific areas which may be useful in screening, scoping, and effecting closure of issues in the TAR process.

NRR Office Instruction COM-106, Revision 6 Page 8 of 38 4.3.1 Search for Precedents and Previous Staff Positions As applicable, during TAR Intake or Screening and Evaluation, the TAR Coordinator with the help of applicable team (e.g., the integrated team in screening and evaluation) or other staff should conduct a search to ensure that the particular issue has not already been addressed and has been documented related to the identified issues. Searching for and identifying precedent staff positions may prevent the need for a TAR or other staff action. This would therefore help save resources and ensure consistency of NRR conclusions.

Previous staff positions may be located in standard review plans, branch technical positions, regulatory guides, generic letters, and bulletins, etc. The TAR SharePoint site should be searched for TIA or TAR precedents on similar topics to determine if a solution already exists and may be applicable to the requested issue.

The Agencywide Documents Access and Management System (ADAMS) and the NRR Operating Experience (OpE) Information Gateway https://drupal.nrc.gov/nrr/ope searches could also be useful.

Licensee documents such as the Updated Final Safety Analysis Report (UFSAR) and responses to violations may provide additional insights on how a licensee addressed an applicable NRC staff position.

Even if a staff position already exists, the fact that a question was raised could indicate that a position or policy is not well understood. Accordingly, the NRC staff should consider the following options for restating a previously documented position:

• Issue a Regulatory Issue Summary.

• Redistribute the documentation of the position or policy.

• Send a reminder via e-mail to regional counterparts.

• Incorporate the existing position or policy into higher level documents that normally contain applicable NRC staff positions.

4.3.2 Issues with Generic Implications 4.3.2.1 Generic Issues The TAR Coordinator and associated NRR technical staff should review the proposed TAR against the screening criteria listed in Management Directive (MD) 6.4, Generic Issues Program. If the issue is identified as a potential generic issue, it should be submitted into that process rather than the TAR process. This screening may provide an early referral of the issue away from the TAR process.

NRR Office Instruction COM-106, Revision 6 Page 9 of 38 4.3.2.2 Generic Concerns or Communications Once it has been determined that the issue involves generic implications, the TAR Coordinator should coordinate a meeting between the requesting organization (issue requestor, branch chief, and division director or delegate), DORL branch chief, NRR technical branches, the NRR Division of Reactor Oversight (DRO) Generic Communications and Operating Experience Branch, DORL plant project manager (PM), and the appropriate DORL deputy director. The purpose of this meeting is to discuss whether to proceed with the review and/or proceed with the closure of the TAR and the initiation of the review as generic communication. The staff will begin discussions on the type of product that will be issued (rulemaking, regulatory issue summary, regulatory guide, etc.).

4.3.3 Backfit and Issue Finality Considerations A TAR is designed not to establish a new agency position. If it is determined that during the pre-TAR discussions or any of the TAR formal phases, that there is a potential for a new or changed staff position or requirement (e.g., a question related to the plant licensing basis which may potentially impose new requirements on the licensee), then the TAR process is not the appropriate process to follow; the issue should be referred to the backfit process. The regulatory function of backfitting and its associated activities are outside the scope of the TAR process. The TAR Coordinator should ensure the appropriate backfitting Community of Practice Point of Contact or Subject Matter Expert (SME) is included in the discussion as early as possible to determine if the issue should be referred to backfit. Backfit guidance and policy can be found in MD 8.4, Management of Backfitting, Issue Finality, and Information Requests.

Often, questions referred to the TAR process relate to the plant licensing basis.

Licensing basis information is unique to the plant and may lack sufficient detail or present ambiguity (e.g., multiple descriptions about one topic in different places),

or complexity (e.g., information on complex design). Determining if the issue is in the licensing basis or not is key to routing the issue appropriately. Enclosure X of LSSIR recommendations memo dated XX (ADAMS Accession No. ML--------)

provides a high-level guidance for determining if the issue is in the licensing basis or not and this may be used in the pre-TAR discussions as well as the TAR screening and evaluation activities.

Once it has been determined that the issue involves backfit considerations (i.e.,

that the issue is not within the licensing basis, and that further pursuit of the issue would require imposing a new requirement), the TAR Coordinator should coordinate a meeting between the requesting organization (issue requestor, branch chief and division director or delegate), DORL branch chief, NRR technical branches, backfit SME, DORL PM, and the appropriate DORL deputy director. The purpose of this meeting is to discuss the closure of the TAR and the initiation of the review as backfit in accordance with MD 8.4. This can also happen after the of the Screening and Evaluation phase of the TAR referral to backfit.

NRR Office Instruction COM-106, Revision 6 Page 10 of 38 4.3.4 Considerations of Enforcement Enforcement-related decisions are outside of the scope of the TAR process. The TAR informs decision-making related to enforcement on applicable issues. The requesting organization is responsible for all enforcement related decisions.

Additionally, if the requesting office refers an issue to the TAR process with a conscientious expression of a judgment or position that differs from an established staff view, agency practice, management decision or policy position involving an issue, that is specific to a plant, this issue will not belong in the TAR process. It should be referred to the Differing Professional Opinion (DPO) program, with the governing policy and procedures in MD 10.159, NRC Differing Professional Opinion Program. The TAR Coordinator should close out the TAR and the associated EPID, if applicable, after referring the requesting office with a memorandum or e-mail with a copy to the DPO program manager in OE.

4.4. Safety Significance Considerations for Operating Reactors 4.4.1 LSSIR Recommendations Under the LSSIR initiative 7, one area of focus is on issues that are not clearly within the plants licensing basis and are also of insufficient safety significance to warrant the expenditure of significant additional agency resources. This initiative provides NRC staff tools and guidance to characterize safety significance, including the disposition and documentation of issues when appropriate, before resources are spent researching a plants licensing basis that are incommensurate with the associated benefit to public health and safety. This includes updated guidance in Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, with the criteria for inspectors to disposition 8 issues reliably, clearly and efficiently, when the relevant circumstances exist.

When an issue is referred from the inspection process to the intake phase of this OI, the TAR Coordinator discussion with the requestor should include any previous efforts to assess the issues safety significance and research of the plant licensing basis in accordance with the aforementioned IMC 0612 guidance, if applicable. The agency public documentation for dispositioning the issue, if originating from the inspection process should be executed by the requesting office (e.g., in the inspection reports under IMC 0611).

If the inspection issue is referred to the TAR process and was not previously screened out and dispositioned using the IMC 0612 guidance on safety significance standing, it could still be screened out and dispositioned in the screening and evaluation phase of the TAR process, as described in Section 4.9 of this OI. The standup of an integrated team, using the guidance provided, may result in additional information and perspectives that leads to a conclusion that the issue is of very low safety significance to warrant no further agency efforts on the issue.

7 ADAMS Accession No. ML--------

8 In the case of IMC 0612, this involves screening the issue using existing inspection issue significance tools to see if it is clearly of very low safety significance, in addition to meeting other criteria related to the issues licensing basis standing.

NRR Office Instruction COM-106, Revision 6 Page 11 of 38

4.4.2 Exceptions

Effort Not Commensurate with Safety Significance A wide range of inspection issues may enter the TAR process including those known to be of very low safety significance (e.g., an issue known to be clearly in the licensing basis, a contested violation in the ROP, an issue that could not be dispositioned per LSSIR, etc.), and accepted, if they meet the TAR acceptance criteria. In such cases, the issue screening or a resolution, if achievable, is expected to be completed in the Screening and Evaluation phase of TAR, using the resources of the integrated team and timeliness in accordance with Section 4.9 of this OI. In exceptional cases, the integrated team may refer the issue to an in-depth review due to its complexity, high stakeholder value or other reasons, whereupon additional resources will be authorized under higher authority per Section 4.12 for exceptions, to receive an in-depth review in accordance with Section 4.10 of this OI. Under such scenarios, the TAR effort will not be commensurate with the safety significance of the issue.

4.5. Acceptance Criteria A TAR contains questions on subjects within the scope of NRR's mission and responsibilities. The TAR process is to be used to address plant-specific issues. The following types of questions/issues are typically associated with an issue identified at a specific plant:

• policy or regulatory requirements

• plant licensing bases

• URI or inspection finding resolution

• NRR technical positions

• safety or risk significance of certain plant configurations or plant operating practices

• specific plant events

• construction-related technical issues 4.5.1 Questions or Issues Outside of the TAR Process The following types of questions/issues are not suitable for the TAR process:

• generic issues

• enforcement actions

• plant backfit analyses

• disagreement with a previously stated staff position 4.5.2 TAR Screening and Evaluation Phase Acceptance Criteria The following conditions should be met to enter TAR screening and evaluation:

• Completed intake information on Intake form

• The issue has not been previously determined to meet the criteria for LSSIR disposition (as discussed in Section 4.4 of this OI)

NRR Office Instruction COM-106, Revision 6 Page 12 of 38

• Requesting Office Division management authorization (e-mail to DORL management (See Appendix C) 4.5.3 TAR In-depth Review Phase Acceptance Criteria The following conditions should be met to enter TAR in-depth review:

• The issue is plant specific

• The issue is of elevated safety significance as determined by the application of the TAR Safety Significance Determination tool, or the safety significance is indeterminate.

o Exceptions may be granted based on agreement between NRR and requesting Office Directors, where safety significance alone is not a driving factor (e.g., issue of high public interest), see Section 4.12 of this OI

• A well-defined, focused set of questions has been formulated in the Screening and Evaluation phase by the integrated team and recommended for in-depth review o Questions accepted in the Screening and Evaluation phase to be recommended to the in-depth review cannot be changed unless the process is exited to start over in Intake 4.6 Informing and Interfacing with NRC staff and Management 4.6.1 TAR SharePoint Site The TAR Coordinator should maintain a log of completed and active TARS on the internal agency SharePoint site. This site serves as a historical reference library of completed TARs. This database will also include the ADAMS references for the completed Intake Forms for construction and operating reactor TARs.

4.6.2 Quarterly Briefing of NRR Executive Team The TAR Coordinator will provide a TAR status update to engage the NRR Executive Team (ET). This will allow the ET to engage and inform regional management, ensuring agency alignment on open issues related to the items in progress in the TAR program. As needed, urgent TAR issues can be relayed through monthly ET regional counterpart calls.

4.6.3 Workload Management Status Reporting The TAR Coordinator will provide a status report for the monthly NRR workload meetings.

NRR Office Instruction COM-106, Revision 6 Page 13 of 38 4.7 External Stakeholder 9 Interactions One of the goals of the TAR process is to meet the needs of external stakeholders (licensees, applicants, etc.) effectively and efficiently, in addition to the internal stakeholders (e.g., requesting office). The TAR process should be viewed as an extension of the process it serves. Thus, if the TAR process receives an unresolved question from the inspection process (e.g., a URI), or a technical issue identified through construction inspection, it becomes as extension of the inspection process. As such, interactions with the stakeholders should follow the needs of the process the TAR serves and address the specific issue at hand while every effort should be made to make the process transparent whenever possible. Due consideration should be given to balance transparency with the potential consequences of sharing preliminary or pre-decisional information. The licensee or other stakeholder(s) should be engaged as early as possible and throughout the TAR process to obtain substantive and timely information pertaining to the TAR. The goal of interactions is to ensure the availability of clear, accurate, and complete facts about the issue.

4.7.1 Verbal interactions The TAR Coordinator will work with the requesting office and/or the plant PM for discussions in the formal TAR phases, depending on what process the TAR serves (e.g., URI or a general question). The requesting organization should interface with the licensee or stakeholder to gather facts as early as possible (pre-TAR intake activities). These should also be informal exchanges unless a public meeting is deemed appropriate (i.e., aligned to the needs of the issue and the process the TAR is serving). These exchanges are not typically public meetings because the TAR is a fact-gathering process to inform decision-making in processes like allegation, enforcement, and inspection. The nature of the discussions should be purely information exchanges for clarification and fact gathering rather than regulatory or enforcement debates, and no decisions or agreements should be made. More details of verbal interactions in TAR Intake, Screening and Evaluation and In-depth review phases are provided in the Sections 4.8, 4.9, and 4.10, respectively, of this OI.

4.7.2 Written Interactions On occasion, the NRR staff or requesting organization may need additional information beyond that which could be obtained by the requesting office. In this case, the TAR Coordinator will request the additional information working in coordination with the requesting office and/or the plant PM depending on the process the TAR serves. The TAR Coordinator will issue the request to the licensee or stakeholder (this may typically happen in the TAR screening and evaluation or in-depth review) working with the requesting office if the issue is related to a URI. For all other requests, the TAR Coordinator will work with the requesting organization and the plant PM to issue the request.

Requests for additional information for TARs related to licensees are unique compared to requests for additional information for license amendment requests 9 External stakeholders does not include members of the public

NRR Office Instruction COM-106, Revision 6 Page 14 of 38 because the information requested will be used to answer a TAR, not to provide a product to a licensee. They are often used as a basis to close a URI from a regional inspection. To facilitate obtaining the response, TAR requests for additional information should be provided to the licensee with a requested due date. Further details on written interactions unique to TAR screening and evaluation and in-depth review are available in the Sections 4.9 and 4.10, respectively, of this OI.

4.7.3 Voluntary Supplemental Information The TAR process encourages the licensee or other stakeholder to participate in the process as early as possible, providing its position or submitting supplemental information to support the review. These could be in the form of position papers, white papers, or a formal submittal on the docket. To support timely execution of the TAR process, this information should represent the best available information. In particular, new and detailed computational analysis or experimentation should not be encouraged if its primary purpose is to influence the assessment of safety significance.

Relevant stakeholder-provided information should be collected by the requesting office early during the information gathering stage (e.g., TAR Intake) to enable the TAR team to characterize the issue, become aware of alternate licensee positions (if any), and screen/evaluate and reach a conclusion promptly. Further details unique to TAR Intake, Screening and Evaluation and In-depth review phases are available in the Sections 4.8, 4.9, and 4.10, respectively, of this OI.

4.8 Intake Phase The TAR Intake (see Figure 2) is the formal, initial fact-gathering framework, focused on the TAR Coordinator facilitating an information exchange with the requesting office to pre-screen the issue (Section 4.2 of this OI) to achieve an early resolution or referral (if possible) or refer the issue for further screening and evaluation by the IT in the Screening and Evaluation phase. Interactions are expected to happen at the staff and/or branch chief level in this phase. While this is the initial fact-gathering for the TAR, the staff is encouraged to also problem solve the issue, if possible. The goal of expending no more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is geared to complete gathering facts and resolve the issue, if practical, within this phase.

NRR Office Instruction COM-106, Revision 6 Page 15 of 38 Figure 2. Intake Phase Flowchart 4.8.1 Logistical Considerations The Intake process is typically expected to be preceded by informal discussions with the TAR Coordinator to discuss the TAR process instructions and acceptance criteria (see Section 4.5 of this OI) and is initiated with the requesting office submitting a request to the TAR Coordinator to enter the TAR process (this could be an e-mail from the requesting office staff (requestor) with a copy to the respective branch chief).

The requestor and the TAR Coordinator, using the TAR acceptance criteria, should weigh the complexity, significance, and necessity of a TAR to direct the technical issue into the most efficient process for resolution (e.g., phone call, e-mail, or TAR). During these discussions, the TAR Coordinator will perform an initial screening (pre-screen) of the request in the areas described in Sections 4.3, 4.4, and 4.5 of this OI to determine if it should enter the TAR process (i.e., take detailed intake information) or be routed to an alternate process. The TAR Coordinator should be sensitive to the nature of the issue and timeframe needed for resolution (inspection schedule or licensee impact) and take these factors into consideration in responding to the request.

Appendix C describes the Intake form which allows the TAR Coordinator and the requestor to focus initial discussions on requisite fact-gathering, and the requestor will be required to provide as much information described in the Intake form as possible with the request to enter the TAR process.

Informal discussions and/or pre-screening should include a determination of whether an issue is construction-related. The following question should be

NRR Office Instruction COM-106, Revision 6 Page 16 of 38 posed: Is the issue related to on-going construction of a power reactor or research/test reactor facility, or an isotope production facility? If the answer is YES, there is no safety significance consideration to the issue and further screening and evaluation of the issue is not applicable. The Intake template will be completed accordingly (Box 10 checked YES) and the TAR Coordinator and requestor will initiate the Construction TAR process using the guidance in Appendix B of this instruction.

4.8.2 Work Planning Planning and processing of a TAR is critical in ensuring the work is completed in a timely and effective manner. The TAR Coordinator is responsible for scheduling and coordinating the process and keeping the staff and management informed throughout the life of a TAR. The TAR Coordinator and NRR technical staff will charge their time to a pre-existing non-fee billable EPID that is available from respective NRR Divisions for the work in this phase (this is not specific to the TAR). The TAR Coordinator should:

• Initiate a TAR, when a request (e-mail or memorandum) is received from the requester with an Intake form attached (Appendix C), as complete as possible.

• Assign a TAR number and enter in the SharePoint log to track it till closeout.

TAR numbering will be sequential by calendar year (e.g. 2019-01, 02, etc.)

and Construction TARs will include a suffix letter C (e.g. 2019-01-C).

• Notify DORL BC and management on the receipt and processing of the TAR request.

• Pre-screen the issue (Sections 4.3, 4.4, and 4.5 of this OI), to resolve, refer the issue to an alternate process, or refer to TAR screening and evaluation.

• Coordinate activities with a goal to be completed in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> includes time for the TAR Coordinator to facilitate a structured and focused conversation with the requesting office, plant PM, relevant technical staff including DRO Operating experience technical staff and/or any other appropriate staff, to attempt to resolve 10 the issue (at the staff or branch chief level) if possible and complete the Intake form initiated by the requestor.

• Status the TAR as Closed and capture as much information about the issue in the SharePoint site, if a resolution or referral is achieved in this phase.

• Store the completed Intake form for the issue in the SharePoint site and in non-public ADAMS (for the TARs that move to screening and evaluation, as 10 TAR Intake is primarily for gathering facts; however, resolution of an issue may be possible in some cases. For example, if the TAR Coordinator is pre-screening an issue for precedent information or previous positions and coordinates a research in the 8-hour window with other NRR staff on the issue, and is able to find an answer, then the requestor should be informed, the issue should be recorded in the TAR log (by the TAR Coordinator) as resolved and the TAR closed. There will be no separate documentation issued.

NRR Office Instruction COM-106, Revision 6 Page 17 of 38 the Intake documentation will be included with the screening and evaluation documentation and/or handed to the process the TAR serves).

• Working with the requestor and make a complete ADAMS non-public package of the completed Intake Form and all supporting materials 4.8.3 Moving an Issue to TAR Screening and Evaluation phase If resolution or referral is not achieved in the Intake phase, the TAR Coordinator should refer the issue to TAR screening and evaluation phase, once the TAR Coordinator determines sufficient information is provided to conduct a screening and evaluation of the issue. Within 3 working days of the completion of the Intake phase and discovery that the issue needs to move to screening and evaluation, The TAR coordinator should work with the requestor for the requestors division management to submit the Screening and Evaluation authorization an e-mail (Appendix C) to the DORL division management with a request to move the issue up to a screening and evaluation status. This initiates the screening and evaluation review.

4.9 Screening and Evaluation Phase The Screening and Evaluation phase (Figure 3) builds on the Intake phase and provides a formal framework to perform the following primary functions: issue screening, evaluation, scoping, and documentation of the conclusion in order to route the issue appropriately. The Screening and Evaluation phase will not perform the function of driving the issue to resolution. In some cases, it may be possible to resolve the issue, as a by-product of performing the other functions and resolution is not an intended primary function of this phase. An integrated decision-making team, coordinated by the TAR Coordinator, performs focused reviews to reach alignment on the issues path forward with a graded approach, commensurate with the significance of the issue with a timeliness goal of 30 days from the team kickoff meeting. Due to the expedited nature of the work within 30 days, as a general guidance, the IT should use the first 15 days to scope, screen, evaluate, resolve (if reached anyway), and align on the path forward and use the latter 15 days to draft, concur, and complete the TAR conclusion documentation.

It is expected that under limited circumstances, extensions beyond 30 days could be allowed with appropriate justifications (e.g., due to extensive new information received from the licensee, complexity in scoping of the issue, available resources etc.) to continue and finish the explicit functions of screening and evaluation.

NRR Office Instruction COM-106, Revision 6 Page 18 of 38 Figure 3. Screening and Evaluation Phase Flowchart 4.9.1 Logistical Considerations Within 7 working days of the initiation of screening and evaluation (Section 4.8.3 of this OI), the TAR Coordinator should work with the DORL management to stand up an IT and organize a kickoff meeting, because of the timeliness needs of the phase. During this time, the TAR Coordinator should inform the applicable technical divisions, SMEs (e.g., backfit), OE, and OGC offices about the TAR screening and evaluation initiation and request assignment of dedicated staff to the IT and provide a copy of the relevant supporting information. The TAR Coordinator should work with DORL management to identify a Chairperson for the IT, typically an SES manager.

The IT will be generally comprised of a Chairperson, the requestor, TAR Coordinator, plant PM, technical staff, SMEs (e.g., generic concerns, backfits) or other staff, NRR risk analyst 11, OGC, and OE (if required). Further to the team identification, and the kickoff meeting, the team will engage through meetings or conferences as necessary to complete the screening, evaluation, response (if possible), and the necessary decision-making and documentation.

Appendix C provides information on the Screening and Evaluation Results memorandum which will be used by the IT to record the conclusions in this phase including a response if achieved.

11 If an issue has received significant evaluation by a Regional senior reactor analyst (SRA) prior to entering the TAR process, it may be more efficient to have the Regional SRA participate on the IT, with NRR/DRAs general awareness.

NRR Office Instruction COM-106, Revision 6 Page 19 of 38 4.9.2 Work Planning For the TAR screening and evaluation, the following work planning steps should happen:

• The TAR Coordinator should ensure that the issue could not be resolved or referred to another process in TAR Intake and has received sufficient information on the Intake form to further the issue in TAR screening and evaluation.

• TAR screening and evaluation initiation memorandum is received from the requestors division management.

• The TAR Coordinator should obtain an EPID through the RRPS (Non-fee billable charge code) within 2 working days of the TAR screening and evaluation initiation. The RRPS EPID will also establish the milestones and the deadlines to complete for the TAR screening and evaluation and may be extended to TAR in-depth review, as needed. The EPID milestones are as follows typically (assuming no licensee inputs added in this phase):

Screening and Evaluation initiation Kick-off meeting (7 working days from initiation)

Safety Significance Screening Completed (10 days from kickoff)

Other Screening, Scoping, Evaluation and Resolution (if applicable) completed (10 days from kickoff)

IT meeting to make final decision on path forward (15 days from kickoff)

Screening & Evaluation memorandum signed off (30 days from kickoff)

• The TAR Coordinator should identify dedicated resources for the IT within 7 working days of the TAR screening and evaluation initiation. Due to the higher priority and the need of dedicated resources to work over a short period of time, DORL management should help as appropriate to ensure the team is stood up at the earliest.

• The TAR number was already assigned in TAR Intake phase and should be continued.

• Track the TAR screening and evaluation to completion and ensure documentation and distribution of the TAR screening and evaluation conclusion. The TAR Coordinator should organize all meetings, keep notes of discussions including the progression of changed or refined questions from the Intake Form as necessary.

NRR Office Instruction COM-106, Revision 6 Page 20 of 38

• For an issue that is closed out in TAR screening and evaluation (resolution, referral, or recommendation for no further action), the TAR coordinator should coordinate with the requestor and/or the plant PM (as appropriate to the process) to ensure that the licensee or stakeholder is informed of the issues closure or exit from TAR.

4.9.3 Conduct of Operations 4.9.3.1 IT Activities The TAR screening and evaluation IT activities include the following:

• Convene a kickoff meeting to review the initial request, assess any special expertise needs and identify the roles and responsibilities.

• Identify incomplete information on the Intake Form, if any and with the TAR Coordinators lead obtain additional information at the earliest opportunity (e.g., licensee inputs with necessary interactions).

• Rigorously scope and refine the Intake questions in this phase, performing iterations and discussions with the requesting office and assigning questions to necessary review areas (e.g., requests for regulatory interpretations should be referred to OGC) and identify any early answers. Detailed discussions should happen with the requestor in the beginning to understand the issue of concern, the requestors proposed questions, the basis, and collect the necessary details necessary for respective team members (technical staff, risk analyst etc.) to perform their reviews.

• Perform the screening for safety significance with the TAR Safety Significance Determination tool.

• For questions that relate to licensing basis clarity, subjectivity or ambiguity, the IT should discuss all available information and facts including any differing facts recorded on the intake form and supporting documentation. In addition, the IT should collect additional facts as necessary at the earliest to determine LB standing, including research and seeking licensee information if necessary. The technical staff, backfit SME, OGC, TAR Coordinator, plant PM and other staff should discuss and arrive at the licensing basis standing of the issue.

• Within 15 days from the kick-off the IT should meet and discuss the issue and the steps undertaken in the screening and evaluation and the Chairperson should make the decision based on the facts presented with the results of the safety significance determination, licensing basis standing, the final questions on the

NRR Office Instruction COM-106, Revision 6 Page 21 of 38 underlying issue as agreed with the requestor and other relevant inputs from the team and stakeholders.

• Achieve one of the following four TAR screening and evaluation outcomes with the Chairperson as the decision maker:

1) Based on the safety significance evaluation, along with an indeterminate licensing basis standing, the IT collaborates and at the discretion of the Chairperson, makes a recommendation for no further regulatory action on the issue

2) The IT provides a recommendation after assessing safety significance to direct the issue with a well-defined set of acceptable questions to the in-depth review phase of this OI, based on its elevated safety significance status

3) The IT achieves an early resolution of an issue, irrespective of its safety significance using other screening and acceptance criteria (Sections 4.3 and 4.5 of this OI) and scoping activities, if easily achieved:

Through identification of an existing staff position that resolves the issue (Section 4.3.1 of this OI).

A quick answer emerges for part or the entire issue within 2 weeks into screening and evaluation, as a result of the scoping and refining questions activities (Note: If the issue is of very low safety significance and is clearly in the licensing basis, the IT will provide a response to the requesting office documenting this in the screening and evaluation results memo).

4) Refer the issue to an alternate process (e.g., backfit or generic issues program). For example, if the screening and evaluation results indicate the issue is clearly outside the licensing basis, the IT will refer the issue to the backfit process (Section 4.3.2)

• Consider and integrate disputed facts in information collected on the underlying issue (e.g., requestor, licensee) early with OGC representation in the team

• Identify and grant issue exceptions with respect to TAR screening and route the issue with well-defined questions to in-depth review for resolution (for example issues where safety significance alone may not be a considering factor) with office directors approval from NRR and the requesting office.

• Document decision using the Screening and Evaluation Results Memo template (Appendix C) 4.9.3.2 Safety Significance Determination

NRR Office Instruction COM-106, Revision 6 Page 22 of 38 The risk analyst and topical area SME team members will apply the TAR Safety Significance Determination Tool 12 (see Appendix C) using the information provided in the completed Intake form for the issue.

The results of this assessment will be briefed out to the IT to ensure that all relevant technical information was incorporated into the assessment. The outcome of the safety significance determination worksheet is a recommendation to the IT that the issue is of very low safety significance, or not. The results of this review will be documented on the Screening and Evaluation Results memorandum, and the safety significance evaluation information will either be attached, to the memorandum or else stored in ADAMS with the Accession No. reference on the screening and evaluation template.

For occasions where the safety significance screening tool cannot be satisfactorily applied (e.g., indeterminate or not applicable), the team will record this result and the basis for this determination in the Screening and Evaluation Results and the IT will refer the issue to the TAR in-depth review phase, after scoping and developing a set of well-defined questions for in-depth review and resolution.

4.9.3.3 Licensee or Other Stakeholder Interactions During Screening and Evaluation Phase Once a TAR screening and evaluation is accepted and initiated and around the time of the kick-off meeting, the TAR Coordinator should work with the requesting office and/or plant PM (depending on the process the TAR serves) to hold a call with the licensee or stakeholder to inform about the issue entry in the TAR process (with information about the proposed questions and facts). The timing of the call should be chosen to increase effectiveness of the interface. As discussed in Section 4.7.1, these interactions should not be public exchanges unless it is necessary, aligned to the process. Informing the licensee or stakeholder of the TAR process affords them an opportunity to provide information voluntarily or formally at the TAR screening and evaluation. The licensee may submit any information (if not already collected in the Intake phase), including any newly available information, with a potential for a follow-up clarifying conference call if necessary. It should represent the best available information, and new and detailed analytical studies or experimentation solely intended to influence the safety significance determination should be avoided, to promote process timeliness. In some rare instances, the IT may request additional information (Section 4.7.2) from the stakeholder to support the screening and evaluation.

The licensee or stakeholder should provide information (voluntary or requested) within 5 days of the call or as agreed, for NRC consideration, due to the expedited nature of the screening and 12 The Safety Significance Tool is owned by NRR/DRA and is used by the TAR process in the Screening and Evaluation phase. It consists of a Safety Significance template and a quick reference guide (Appendix C).

NRR Office Instruction COM-106, Revision 6 Page 23 of 38 evaluation. The additional information, if any, should then be considered through the requesting organization to verify it does not obviate the need or change the questions for the TAR. Further, the requesting organization should advise the NRR staff as to whether the information should be included as a part of the TAR review.

The TAR Coordinator will confirm with the requesting office that any licensee inputs on the issues/questions raised are accurately captured on the TAR Intake form and if necessary the requesting office will update this template to reflect the current licensee position on these issues.

4.9.3.4 Issue Scoping, Evaluation, and Conclusion The TAR IT screening and evaluation activities should ensure the requestors unresolved questions are well-framed, refined with necessary iterations, are not overly broad or speculative, and are in scope (with respect to Sections 4.3, 4.4, and 4.5 of this OI) and consider all relevant stakeholder inputs. There should be a free exchange of information between the requesting organization and the IT to ensure that the questions frame the requestor issue and can be answered by NRR. Agreement should be reached with the requestor on the set of questions that need to be answered or referred to in-depth review as appropriate, with necessary iterations as needed.

Thus, the IT should be able to characterize the issue effectively, with well-defined and succinct questions, and together with the safety significance determination, should recommend a path forward with a graded approach (as noted in Section 4.9.3.1 of this OI). The TAR Coordinator should coordinate the question formulation process and the final agreed questions should be recorded in the Screening and Evaluation Results memorandum. The requestor should keep its management informed on major changes to scope and bring any concerns to the Chairperson promptly. Due to the focused review in this phase and availability of staff expertise, some or all of the questions may be answered, though this is not an intended function in this phase. If a resolution is achieved, the team should document the response in the Screening and Evaluation Results memorandum and close out the TAR.

The TAR Coordinator will draft the Screening and Evaluation Results memorandum and coordinate concurrence from the IT. The Screening and Evaluation Results memorandum will include a section for the requestor to provide comments on the process of handling the issue and any other concerns or comments if applicable. The TAR Coordinator will notify the requesting office that the screening and evaluation is completed and distribute the document in non-public ADAMS, as the TAR does not provide an agency decision.

4.9.3.5 Moving an Issue to the In-depth review phase

NRR Office Instruction COM-106, Revision 6 Page 24 of 38 For issues that meet the TAR in-depth review acceptance criteria (Section 4.5 of this OI) or an exception is granted, the questions/issues formulated within the screening and evaluation screening and evaluation by the IT become the designated questions for review within the in-depth review TAR process and should not change during the TAR in-depth review process. Within 2 working days of the screening and evaluation documentation recommending the referral of the issue to TAR in-depth review, the TAR Coordinator will provide e-mail notification to requesting office management about the outcome from TAR screening and evaluation including a description of the issue and the questions with the completed Intake and Screening and Evaluation attachments, and status the EPID for the TAR in RRPS for extension. This initiates the in-depth review phase.

4.9.4 Multiple Issues Referred to the TAR Process screening and evaluation and Staggering Teams The above guidance describes the activities as applicable to a single issue in process. It is possible that there could be several different requests to enter TAR screening and evaluation from various requesting organizations. NRR staff should control and prioritize activities depending on staff availability for integrated team and closeout dates may be negotiated, with substantial deviations documented per Section 4.12 of this OI. NRR staff will give special attention to the following when considering priority:

• questions involving significant safety issues

• issues that could involve the loss of power production (i.e., a plant shutdown, derating, or delay in startup)

• issues related to an allegation

• TARS involving contested violations, inspection findings, or URIs

• issues where uncertainties or conflicting views are impairing the publics confidence in the regulatory process 4.10 In-depth Review Phase The in-depth review (Figure 4) is expected to provide a focused detailed NRR staff review to result in a clear and concise response to the issues that were scoped, screened and evaluated in TAR Screening and Evaluation phase and referred to in-depth review and were determined to meet the in-depth review TAR acceptance criteria as discussed in Section 4.5 of this OI.

NRR Office Instruction COM-106, Revision 6 Page 25 of 38 Figure 4. In-depth Review Phase Flowchart 4.10.1 Work Planning This section describes the TAR Coordinators responsibilities for scheduling and coordinating the TAR review. During the review, if the schedule for responding to a TAR needs to be revised, the change should be communicated and agreed upon with the requesting office. The TAR Coordinator will ensure that the written TAR request has been established based on the issues or questions for resolution as documented in the Screening and Evaluation Results memorandum, and changes are not permitted (other than minor editorial clarifications). If changes are necessary after an issue enters the TAR in-depth review process, the TAR should be withdrawn by the requesting office (Section 4.13 of this OI) and resubmitted as a new request.

Activities to take place under the in-depth review are broken down into seven milestones, where T stands for time in calendar days and L is the time taken by the licensee to submit additional information, if applicable, during the review.

When no licensee information is necessary, L will be entered as 0 in RRPS (default).

In-depth Review Milestones T=0 In-depth review TAR Initiation T=7 Kick-off Meeting T=35+L Evaluation and Follow Up with Stakeholders T=40+L Draft TAR Response from the NRR technical staff to TAR Coordinator T=60+L NRR ET Brief T=70+L TAR Team Debrief and Exit Meeting

NRR Office Instruction COM-106, Revision 6 Page 26 of 38 T=80+L Issuance of Final TAR Response 4.10.2 Establishment of TAR Review Team The TAR Coordinator will establish a TAR review team with dedicated resources necessary to accomplish reviews of the issues identified by the requesting office within 5 days of the initiation of the in-depth review TAR. The TAR Coordinator will provide copies of the proposed TAR (Intake form and Screening and Evaluation results) to the affected organizations and request assignment of dedicated staff to the TAR review team.

The TAR review team will typically consist of a representative from the applicable technical area, the TAR Coordinator, the plant PM, the NRR Division of Risk Assessment (DRA) Risk Analyst, if needed, and OGC and OE as appropriate. If possible, individuals from the screening and evaluation IT including the OGC representative may be retained for continuity and efficiency in processing the request. The goal of the TAR review team to complete reviews required to support resolution of issues within 80 days unless a different schedule was agreed upon to support the requesting office. The TAR Coordinator will establish milestones and schedules in RRPS using the same EPID that was opened in TAR Screening and Evaluation phase.

4.10.3 Kick-off Meeting The TAR review team, led by the TAR Coordinator, will conduct a kick-off meeting (this is typically a non-public conference call or meeting, unless a public meeting is necessary depending on the process the TAR serves) with the requesting office staff and any additional stakeholders (such as the licensee or another NRC organization). The kick-off meeting is intended to inform all stakeholders that the issues have been accepted into the in-depth review phase of the TAR process and discuss verbally the following:

(1) The issue characterization and the questions as referred by the IT from screening and evaluation (2) The scope and depth of the review (3) Planned interim milestones and schedule and any potential challenges or new developments (e.g., licensee voluntary action)

(4) Determine if additional resources are warranted (5) Understand if differing views exist with any stakeholder (6) If additional information would be necessary (7) Pre-decisional or proprietary component in the review No regulatory decisions will be made in the kick-off meetings and no regulatory or enforcement debates should be conducted in this meeting. The TAR Coordinator should document the discussion from the entrance meeting in a note

NRR Office Instruction COM-106, Revision 6 Page 27 of 38 to file. If information obtained during one of these discussions is used to support NRRs TAR response, then either the information should be cited in the TAR response or the TAR Coordinators note to file that contains the information should be placed in ADAMS and included with the TAR response.

4.10.4 Licensee or Stakeholder Interaction during In-depth review During the kick-off meeting, NRR should discuss all the details of the NRCs screening and evaluation of the issue including the facts of the underlying issue with supporting references and safety significance considerations as appropriate.

Offering this opportunity to the licensee or stakeholder early, provides transparency and also opens the path for licensee clarification and additional inputs that are germane to the in-depth review. If a licensee would like to provide formal or informal information, then this should be provided within 7 days to support a timely review. An extension beyond 7 days should be approved by the DORL Director in coordination with the technical division director after the impact to the schedule or significance is assessed. The additional information should then be considered through the requesting organization to verify it does not obviate the need or change the questions for the TAR. Furthermore, the requesting organization should advise the NRR staff as to whether the information should be included as a part of the TAR review. If the information needs to be part of the TAR review, the response schedule should be reviewed and adjusted, as necessary.

4.10.5 NRR Staff Evaluation and Follow-up with Stakeholders During the NRR staff review, if additional information is needed from the requesting office or an external stakeholder, the TAR review team will meet to discuss and assess how this impacts the ability to meet the established TAR timeliness metrics. Additionally, the team should be aware of constraints that may exist on discussing the issues with the licensees or other external stakeholders (e.g., issues involving allegations, proprietary, or pre-decisional concerns). Following these reviews, the applicable NRR technical staff should draft a response using the response template (Attachment C).

The TAR members should focus the scope of the TAR review on areas that ensure a clear and concise response can be provided to the questions identified in the TAR. If possible, questions should be answered directly (ideally with a Yes or No type response) and reference the supporting information. The TAR response should not discuss areas outside of that required to address the TAR issues of concern. Proprietary or pre-decisional information should be handled appropriately. Where there are differing views among staff and stakeholders on a particular answer, the counsel of OGC should be sought as soon as possible and not when the TAR is ready for concurrence. During this review, the technical staff should keep the TAR Coordinator apprised of the review status and any issues impacting completion of the review. The TAR Coordinator will arrange for conference calls as needed throughout the technical review to keep the requesting office informed of developments in the review and to facilitate any necessary exchange of information.

NRR Office Instruction COM-106, Revision 6 Page 28 of 38 4.10.6 Draft TAR Response Once the technical reviews are completed for a TAR item, the team member(s) from the technical branch(s) document the results using the TAR Response Memorandum Template (Appendix C). The lead NRR review Branch may receive inputs from other technical staff and provide a compilation. The draft TAR response should be provided to the TAR Coordinator who will compile the final response including inputs from other staff or organizations.

The requesting office does not concur on the TAR response; however, at this point, the TAR Coordinator should share the draft response with the requestor and its division management and offer 7 days for any comment or concerns, to provide an opportunity to raise any concerns about the review and the TAR conclusion to avoid any surprises down the line. The TAR Coordinator should promptly conduct conference calls with the requestor and technical staff and OGC (if needed) to resolve any concerns or elevate the issue as appropriate to management. When the requestor concerns are resolved, the TAR Coordinator will set up the ET briefing.

4.10.7 NRR ET Evaluation Brief The TAR Coordinator will schedule a briefing for NRRs ET. If there are any concerns or inputs from the ET, the TAR Coordinator should update the TAR response appropriately or circle back to the technical staff.

4.10.8 Team Debrief and Call with the External Stakeholder The TAR Coordinator will schedule a team debrief with the requestor and the review team after the ET briefing, if needed. Following the Team debrief, a call will be scheduled led by the TAR Coordinator, which will include the requestor, the NRR technical staff as appropriate and the licensee or external stakeholder, to share the conclusion and the supporting facts of the draft TAR response.

4.10.9 Issuance of TAR Response Once the team debrief is completed and the call with the external stakeholder is completed, the TAR Coordinator will then route the document for concurrence.

This concurrence will typically include the lead NRR technical staff members, and respective branch chiefs and the lead NRR technical division director that conducted the review of the TAR issue. Following concurrence from the technical divisions, the TAR response will also be concurred on by NRRs enforcement specialist (if required) and OGC (no legal objection) as appropriate. The TAR Coordinator will then seek final signature authority/approval on the TAR response from the DORL Deputy Director.

The TAR response addressed to the requesting office will be entered into ADAMS, as non-publicly available, and distributed within 3 days. When added to ADAMS, the title should have the following format: TAR Response (Plant or Subject under Review), Issue. Additionally, the TAR Coordinator should forward the response to the generic communications staff in NRR to review the issue, considering factors that contribute to the significance of the issue and the

NRR Office Instruction COM-106, Revision 6 Page 29 of 38 potential for generic applicability that may have become more evident during the resolution of the technical issues. The requestor or the plant PM (depending on the process the TAR serves) should notify the external stakeholder or licensee of the exit of the issue from the TAR process.

4.10.10 Exit Path for TAR In rare circumstances, the TAR process may be exited after issues are entered and accepted into the TAR in-depth review process as discussed below:

• The requesting office elects to withdraw a TAR (see Section 4.13 of this OI). For example, circumstances may have changed that negate the need to continue the review (e.g., licensee completes actions that correct issue of concern) or the content/subject of the TAR requires substantive revision (see Section 4.10.1 of this OI).

• The TAR review team identifies that the TAR issue should be resolved in an alternative process (e.g., referral to the generic issues, see Section 4.3 of this OI). These situations should typically be identified and avoided during the Intake or screening of issues for TAR acceptance. Guidance in Section 4.3 of this OI should be followed to close out the TAR.

The TAR Coordinator and the requesting office should discuss the case-specific circumstances to discontinue the TAR review and have a mutual understanding of the basis for using the exit path strategy. It is possible that only portions of the TAR may need to be resolved through an alternate process and that the other portions could still be answered through the TAR process.

Such considerations should be discussed and agreed upon before pursuing activities.

4.11 TAR Related to Allegation A requesting organization may ask for technical assistance through the TAR process to resolve issues (including construction-related issues) raised in an allegation. The Office Allegation Coordinator (OAC) with responsibility for the allegation should become an integral part of the communication and project support during the TAR process. The OAC should be involved in initial discussions, the draft TAR request discussions, any requests for additional information or stakeholder interactions, the draft response, comment periods, etc., and should also be placed on concurrence for the final TAR.

TARs related to allegations should be distributed on a need-to-know basis and should not be placed in ADAMS or stored on network drives. When complete, the TAR response will be assessed as to whether it can be made publicly available or placed in ADAMS; however, protection of the concerned individual will be maintained as provided in MD 8.8. Additional guidance on how to handle an allegation can be found in MD 8.8, Management of Allegations.

4.12 Deviations from the Process For various reasons, the staff may find it necessary to deviate from the process outlined above (e.g., availability of staff resources, issue complexity, etc.). As the OI is

NRR Office Instruction COM-106, Revision 6 Page 30 of 38 considered staff guidance, occasional variances in the process can be accommodated.

Any substantial deviations from the process will be documented in ADAMS as a memorandum from the TAR Coordinator to the appropriate DORL branch chief, with sufficient description of the basis of the deviations.

In the Screening and Evaluation phase (Section 4.9 of this OI), for issues where safety significance alone is not a determining factor for significance, the integrated team should obtain approval from the NRR office director and the director of the requesting office, for an exception with the concurrence of these directors on the Screening and Evaluation Results memorandum. Further, after approval, the IT will refer the issue to TAR in-depth review, after developing a set of well-defined questions for in-depth review.

4.13 TAR Withdrawals There are cases where the TAR process has been initiated but is no longer warranted (applies to any phase). In these cases, the TAR should be withdrawn from the process.

The TAR Coordinator should document the justification for the withdrawal in ADAMS as a memorandum from the TAR Coordinator to the responsible DORL branch chief. This serves as a record for the resources expended on the TAR effort, prior to withdrawal.

There may be instances after a TAR has been closed where the staff re-evaluates the TAR and its conclusions. The staff may determine that the conclusions were incorrect or determine that other regulatory tools are more suitable to address the concerns. In this instance, the deputy director of the requesting organization may request to withdraw the closed TAR (screening and evaluation or in-depth review). This can be accomplished with an e-mail to the appropriate DORL Deputy Director. The TAR Coordinator will then send an e-mail to ADAMS IM requesting that the closed TAR documentation be removed from the public domain (if applicable) and create an ADAMS package containing the closed TAR documentation and the withdrawal request. This also serves as a record for the resources expended on the TAR effort, prior to withdrawal.

4.14 Resolving Requesting Office Disagreements on TAR Results (Optional- will be decided later to keep or not to keep)

Under circumstances where the requesting office may not align or agree with the TAR screening and evaluation results for issues that do not meet TAR acceptance criteria or the TAR response in in-depth review, the requesting office with concurrence of its office director, can submit a memorandum to the TAR Coordinator identifying the need for another opportunity to review the issues with a basis of the concern. The requesting office will provide this request in a memorandum to the TAR Coordinator within 2 weeks of obtaining the screening and evaluation results or the in-depth review final response in ADAMS. The TAR Coordinator will then forward this memorandum to the NRR Office Director with a request for an independent review of the requesting office request and basis as documented in the memorandum. For this review, the affected NRR organizations will assign staff members not assigned to the original review (IT or the in-depth review team) and make a final determination as to whether a sufficient basis has (or has not) been established to warrant expenditure of additional NRR and OGC resources and other expertise within the TAR process. The results of this independent review should be provided within 2 weeks of the independent panel kickoff meeting and will be documented and placed in an ADAMS package together with the requesting office memorandum, the TAR Screening and Evaluation results or the in-depth review

NRR Office Instruction COM-106, Revision 6 Page 31 of 38 response that was originally provided. The TAR Coordinator should monitor and track the progress of the process and if the independent review indicates there is sufficient basis to reopen or clarify the issue, then either the original TAR will be withdrawn and the issue will be reentered as a new TAR and processed, taking into account the basis of the requesting office or a clarification will be communicated to the requesting office to close out the issue. All closing documentation will be placed in an ADAMS package with the requesting office memorandum, the independent panel recommendations, closing clarification, and the final screening and evaluation document or the in-depth review response, as applicable.

4.15 Continuous Improvement To promote continuous improvement of the TAR process, NRR provides quality surveys to the requesting organization upon completion of a TAR request. In addition, staff can offer suggestions for process improvement through the TAR Process Feedback Form on the TAR SharePoint site.

Further, this current revision of the COM-106 guidance includes the recommendations of an agency working group on the TIA Revitalization Project which was executed in 2019.

5. RESPONSIBILITIES AND AUTHORITIES All staff (NRR and from other organizations) who support or use the TAR process are responsible for reading, understanding, and applying this OI. They are also responsible for identifying possible improvements to the guidance and submitting suggestions to their management or to the primary contact of this OI.

The following describes the key roles and responsibilities associated with the TAR process:

A. NRR Director (may be delegated to NRR Deputy Director)

1. Responsible for the effective implementation of the policy and procedures regarding the TAR process.

2. Grants exceptions to specific issues referred by Screening and Evaluation integrated team to move to in-depth review, in concurrence with the requesting office director.

3. Approves an independent panel to review the issue for disagreements or concerns raised by requesting office after the TAR results are documented.

4. Engages and informs regional management or other requesting office management, ensuring agency alignment on open issues related to the items in progress in the TAR program, as needed.

NRR Office Instruction COM-106, Revision 6 Page 32 of 38 B. Requesting Office Director (may be delegated to Deputy Director)

1. Collaborating with the NRR director, grants exceptions to specific issues referred by Screening and Evaluation integrated team to move to in-depth review.

2. Approves disagreements or concerns raised by requesting office after the TAR results are documented to be raised for an independent panel review.

3. Provides support to the program as necessary and provides feedback on the program to NRR for continuous improvement from the requesting office perspective.

C. NRR Division of Operating Reactor Licensing (DORL) Deputy Director

1. Develops program guidance and training to ensure the consistency of the program implementation across NRR and requesting offices, specifically for the regions (the largest internal stakeholder).

2. Periodically discusses the program with regional managers and other NRC organizations to assess the effectiveness of the program and solicit suggestions for possible improvements.

3. Helps the TAR Coordinator with the standing up of an IT for a TAR screening and evaluation expedited effort by reaching out to NRR division management and OGC for resources.

4. Recommends or helps the TAR Coordinator find the Chairperson for the IT.

5. Concurs and signs the in-depth review TAR response to provide a supporting document to inform agency decisions or actions in the process the TAR serves.

D. Requesting Office Division Director (may be delegated to Deputy Director)

1. Supports the program and provides suggestions for possible improvements to the DORL management.

2. Ensures the requesting office staff are collaborating or supporting the process effectively and timely (e.g., prioritizing staff effort in screening and evaluation, communication with the licensee to get information needed, etc.)

3. Authorizes initiation of Screening and Evaluation phase of TAR by coordinating with region staff and branch chief after making the assessment the issue needs a screening and evaluation.

4. May identify disagreements with NRR TAR screening and evaluation or in-depth review results and generate a memorandum to the TAR Coordinator for independent review with the requesting office director concurrence for NRRs consideration.

NRR Office Instruction COM-106, Revision 6 Page 33 of 38

5. Authorizes and approves initiation of Construction TARs, as needed, after assessment that formal resolution is needed for a construction-related issue.

E. Chairperson of the Integrated Team (generally an SES manager)

1. Convenes IT meetings.

2. Is the decision maker for the IT.

3. Ensures appropriate screening and evaluation in a timely manner.

4. Ensures appropriate decision and documentation.

5. Signs the TAR Screening and Evaluation Results memorandum to provide a supporting document to inform agency decisions or actions in the process the TAR serves.

6. Works with NRR office director and the requesting office to clarify/resolve any disagreements in screening and evaluation decisions.

F. DORL Branch Chief,

1. Ensures that staff and other resources are provided to manage and execute the TAR program, including assignment of the TAR Coordinator.

2. Ensures TARs are making progress and timeliness goals are met and report and rectify issues working with management.

3. Serves as the process owner and ensures the suggestions for the improvement are captured and coordinate revisions to the guidance as appropriate.

G. TAR Coordinator

1. Serves as the primary point of contact for all TAR related activities and is responsible for effective implementation of the TAR program and the office guidance.

2. Coordinates TAR activities with the regions, other NRC organizations and NRR staff.

3. Coordinates with staff requestors to articulate issues, formulate questions, etc. in completing TAR intake templates.

4. Assigns the TAR number, opens the EPID and assigns milestones, shepherds the TAR action from cradle to closeout and is responsible for the quality and timeliness of the TAR final documentation.

5. Tracks and reports NRRs performance through monthly reports and participating in workload management meetings.

NRR Office Instruction COM-106, Revision 6 Page 34 of 38

6. Provides training and information sessions to staff as necessary.

7. Promotes continuous improvement of the program by conducting surveys and capturing feedback from various avenues and leading the periodic updates of the guidance.

8. Coordinates disagreements with the requestor and the independent panel review when appropriate.

(Note: more specific TAR Coordinator activities are included in the sections above)

H. Office of General Counsel (OGC)

1. Serves as a member of the IT for screening and evaluation of the issue to provide legal counsel, helps in integrating diverse views, answers legal questions, aligns on the issue path forward, reviews documents, and provides NLO as appropriate.

2. Provides legal counsel on backfit aspects of the issue, if any.

3. Reviews TAR in-depth review response for legal adequacy and defensibility, takes part in review discussions and provides NLO on the final TAR response.

I. Office of Enforcement (OE)

1. Participates in TAR screening and evaluation or in-depth review discussions as necessary if the issue is related to an enforcement action.

2. Engages with the OAC in the lead for allegation related TARs.

3. Provides support with respect the non-concurrence process and Differing Professional Opinion program where applicable.

J. Requesting Office Staff (or Requestor) in TAR screening and evaluation

1. Member of the IT and participates in scoping, screening and evaluation activities including aligning on the path forward of the issue.

2. Responsible for collection of all information on the Intake form.

3. Helps interface with the licensee or stakeholder as appropriate.

4. Helps perform iterations on the questions related to the issue to come to the agreed set of questions to be answered.

5. Concurs on the Screening and Evaluation results memorandum and the Safety Significance Determination worksheet.

6. Identifies disagreements to be elevated for an independent panel.

NRR Office Instruction COM-106, Revision 6 Page 35 of 38 K. Requesting Office Staff (or Requestor) in TAR in-depth review

1. Participates in kick-off and review follow-up meetings with NRR staff.

2. Helps to verify and collect new information and interfaces with the licensee as appropriate.

3. Reviews draft TAR response when it is ready and coordinates management inputs.

4. Identifies disagreements to be elevated for an independent panel.

L. Requesting Office Staff (or Requestor) in Construction TAR initiation and processing

1. Engages with TAR Coordinator to determine a path to resolution for construction issue(s).

2. Collection of information to complete TAR intake template.

3. Interfaces with licensee or other stakeholders as appropriate.

4. Assists in articulating and formulating construction issues and questions for formal resolution.

M. NRR Technical Staff

1. Staff should work with the TAR Coordinator to ensure the process plan in RRPS is complete in scope, resources, and schedule.

2. Technical branch chiefs are responsible for assigning staff and agree or renegotiate the milestones identified in RRPS.

3. Due to the expedited nature of TAR screening and evaluation, technical branch chiefs should assign dedicated resources promptly and discuss priority conflicts with the DORL branch chief.

4. Technical staff are responsible for screening and evaluation, in collaboration with the IT, which includes analysis of the issues, with consideration of safety significance, review of licensee inputs and defining the questions that need to be answered.

5. Assigned lead technical staff will concur on the documentation in both screening and evaluation and in-depth review phases.

6. For in-depth review, technical staff will provide inputs using the in-depth response template, to the TAR Coordinator who will assemble the complete response.

NRR Office Instruction COM-106, Revision 6 Page 36 of 38

7. For Construction TARs, assigned technical staff are responsible for developing and providing response inputs to the TAR Coordinator.

N. Risk Analyst 13

1. Participates in the screening and evaluation integrated team as a member.

2. Completes the Safety Significance Determination in coordination with other SMEs and the requestor.

3. Participates in the screening and evaluation activities and aligns on the path forward in screening and evaluation with input to the documentation.

4. Concurs on the screening and evaluation documentation and the Safety Significance Determination worksheet.

5. If needed, provides inputs to the technical review during in-depth review phase.

O. NRR/DORL Plant Project Manager (plant PM)

1. Provides support or expertise with plant licensing basis.

2. Helps TAR Coordinator interface with the licensee or stakeholder as appropriate.

3. Participates in the activities in the screening and evaluation IT as a member and concurs on the screening and evaluation results documentation.

4. Participates in the review activities in in-depth review and concurs on the in-depth review response.

P. NRR Subject Matter Experts 14

1. Participates as members of the screening and evaluation IT as members to provide specific expertise (e.g., backfit, generic implications).

2. Participates in the screening and evaluation activities and aligns on the path forward with input or concurrence to the results documentation as necessary.

3. Support development of responses to construction-related TARs, as assigned.

13 This would typically be staff from NRR/DRA. However, there could be occasions where it is more effective to have a Regional SRA or an experienced risk analyst from RES perform this function.

14 For backfit discussions, SMEs are also referred to as Community of Practice point of contacts

NRR Office Instruction COM-106, Revision 6 Page 37 of 38

6. PERFORMANCE MEASURES A TAR is considered open upon receipt of the formal request memorandum or e-mail from the requesting office at the Intake. A TAR is closed out as described in Section 4.3 of this OI with documentation. During the initial TAR discussions, NRR and the requesting organization may negotiate the priority for NRRs TAR responses based on available resources and the nature of the issue. Refer to Section 4.9.4 of this OI for considerations of priority for screening and evaluation.

Timeliness goals will be tracked for each open TAR in the NRR workload management system as follows:

Screening and evaluation kickoff 7 working days from TAR screening meeting: and evaluation initiation (EPID start date)

Screening and evaluation TAR 30 days from kickoff meeting or as completion: agreed In-depth review TAR entrance 7 days from in-depth review Initiation meeting:

In-depth review TAR completion: 80 days from initiation or as planned with licensee input consideration All intermediate milestones will be reported as status items. Exclusion or deviations will be discussed in the management meetings with the justifications and path forward.

Construction TARs initiated in accordance with the process outlined in Appendix B are expected to be completed in a timely a manner as possible in keeping with construction schedules and associated inspection and oversight. The nominal expectation for completion of construction TARs is 30 days. Other intermediate goals for Construction TAR processing are outlined in Appendix B.

For the operating TARs, collectively, NRRs performance measure is that 80 percent of the operating TAR inventory for screening and evaluation should be completed (documentation with recommendations or closure of TAR) by the set target date and ninety five percent of TAR inventory for in-depth review should be completed (closure of TAR) by the set target date.

7. PRIMARY CONTACT Booma Venkataraman 301-415-2934

8. RESPONSIBLE ORGANIZATION NRR/DORL

NRR Office Instruction COM-106, Revision 6 Page 38 of 38

9. EFFECTIVE DATE XX/2020

10. CERTIFICATION DATE XX/2020

11. REFERENCES TBD

Enclosures:

1. Appendix A - Change History

2. Appendix B - Construction TAR Process

3. Appendix C - Documentation Template Descriptions

4. Appendix D - Operating Reactor TAR Summary of Action Steps

Appendix A Office Instruction COM-106 Change History COM-106 Change History - Page 1 of 1 Method Used to Announce &

Date Description of Changes Distribute Training 11/26/01 Initial Issuance E-mail to NRR staff DLPM PM Briefing 12/24/02 This Office Instruction COM-106, E-mail to NRR staff DLPM PM Control of Task Interface Briefing Agreements, update provides; 1) a general revision to increase management oversight of the process, 2) requires a statement regarding plant applicability for the TIA response, 3) adds a 30 day response requirement for the requesting organization on the draft TIA, 4) changes the goal to 80% of the draft responses sent to the requesting organization by latest agreed upon schedule, and

5) several editorial changes.

11/30/05 The changes implement the E-mail to NRR staff DORL PM guidance in MD 8.8 and NRR OI Briefing OVRST-200 for processing TIAs related to allegations; incorporate the guidance in NRR OI LIC-401 for interacting with NRR/DIRS/OE and DPR/GCPU on potential generic issues; changes the timeliness goal for draft TIA responses to 100%, and implements the NRR reorganization. Other changes include providing a step by step process.

Enclosure 1

COM-106 Change History - Page 1 of 1 Method Used to Announce &

Date Description of Changes Distribute Training 03/17/08 These revisions reflect the E-mail to NRR staff DORL PM reorganization of NRR and the Briefing coordination of the TIA program by the Special Projects Branch in the Division of Policy and Rulemaking and process modifications based upon a best practice examination and Regional/NRR Division feedback. The changes include the incorporation of a Concurrence Method and a Letter Method for completing TIA responses, and revised performance metrics for completion.

12/30/13 These revisions reflect regional E-mail to NRR staff DORL PM suggestions for improvement and Briefing lessons learned from continued use of the process, including the Concurrence Method added in the last revision. The changes include increased communication mechanisms and a restructuring that aims to better detail the process steps and differences between the Letter Method and Concurrence Method. This revision also provides consistent methods for communicating with the licensee/industry, improving the public transparency of the process.

11/20/15 This is Revision 5 of Office E-mail to NRR staff DORL PM Instruction COM-106, Control of Briefing Task Interface Agreements.

Revisions reflect the OIG recommendation to revise the TIA timeliness goals as well as process modifications based upon headquarters and regional feedback and lessons learned from continued experience.

XX/XX/19 TBD E-mail to NRR staff DORL PM Briefing

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Appendix B Office Instruction COM-106 Construction TAR Process Introduction A construction TAR is the mechanism that NRC personnel (usually construction inspectors) use to formally clarify construction-related technical or inspection requirements for facilities licensed and built under the purview of the Office of Nuclear Reactor Regulation (NRR). The construction TAR process is used to facilitate the assignment of appropriate resources to respond to an identified issue in a timely manner, and to provide a method to capture the resolution of the issue for future reference.

Construction TARs are processed in a unique manner compared to non-construction TARs because construction TARs typically require resolution in a much shorter time frame. This allows construction inspection activities to remain aligned with a rapidly evolving construction environment. Expediting construction TARs enables construction inspectors to perform required inspections while structures, systems and components (SSCs) are accessible, and provides licensees or construction permit holders regulatory clarity and confidence that construction activities will not be adversely impacted. The overall goal is to resolve construction TARs by an agreed upon due date (typically within 30 days) that supports the construction inspection schedule.

Processing Construction TARs

1. Intake and Pre-screening.

a. Complete Intake Form. The construction TAR requestor initiates a construction TAR by completing a TAR Intake Form (template) in accordance with Appendix C and Section 4.8 of this OI. The requestor designates the TAR as a construction TAR by checking YES in field #10 of the template.

Note that the low safety significance issue resolution (LSSIR) portion of the template is not applicable to construction TARs.

b. Perform Pre-screen. Pre-screening of the construction TAR is accomplished by the TAR Coordinator with the assistance of the construction TAR requestor in accordance with the pre-screen instructions of this OI.

Supporting information is compiled for detailing and articulating the specific construction issue(s), and technical questions related to the issue are formulated. Pre-screening of construction TARs should be accomplished within 1 working day of receiving the completed TAR Intake Form.

c. Obtain Management Approval. Construction TAR submittal is approved by the requestors branch chief.

d. Enter TAR into TAR Database. The TAR Coordinator shall log the TAR in the database.

Enclosure 2

2. Construction TAR Evaluation

a. Establish Need Date. The TAR coordinator and the construction TAR requestor establish a need date for resolution of the construction TAR. The need date should be established such that the impact on construction of the facility and performance of construction inspections are minimized. If the construction TAR does not impact the construction schedule or the inspection schedule, then a need date of 45 days from the construction TAR initiation date is assigned.

b. Identify Technical Support. The TAR coordinator identifies the NRR branch or organization that has the technical expertise to support resolution of the construction TAR. This may require multiple branches or organizations depending on the complexity of the construction TAR.

c. Conduct Initial Meeting. The TAR coordinator facilitates a meeting or phone conference with the construction TAR requestor and the cognizant technical branches or organizations. The purpose of this meeting is to ensure that the technical staff responsible for evaluation of the construction TAR fully understand the construction TAR questions and the need date. This meeting should occur within 5 working days of construction TAR initiation, or sooner depending on the construction TAR need date. If necessary, the construction TAR requestor changes the construction TAR questions as agreed upon in this meeting.

d. Perform TAR Evaluation. The technical support branches or organizations complete the construction TAR evaluation. The evaluation should be complete by the TAR need date or as soon as possible if the need date cannot be met. The TAR coordinator should consider issuing a yellow ticket or using some other formal tracking mechanism if necessary to ensure that NRC management is aware of potential delays and that the proper NRC resources are being assigned to TAR resolution. However, if the construction TAR has no impact on the construction schedule or on construction inspections, then the TAR need date may be delayed beyond 45 days from TAR initiation. A new need date shall be assigned taking into consideration other technical support staff priorities. The new need date shall be agreed upon by the TAR coordinator and the TAR requestor.

e. Conduct Resolution Meeting. The TAR coordinator facilitates a meeting or phone conference with the TAR requestor and the technical support staff.

The purpose of this meeting is to ensure that the construction TAR evaluation provided by the technical support staff fully answers the construction TAR questions and to identify any additional questions that need to be answered to resolve the underlying issue. The output of this meeting is either a finalized construction TAR evaluation or an amended construction TAR with additional questions.

f. Perform Additional Evaluation. If the construction TAR is amended in step e.

to request additional information, then repeat steps d. and e. as necessary until the construction TAR is resolved.

-B2-

3. Completing the Construction TAR

a. Logging the TAR Evaluation. Once the construction TAR evaluation is finalized, the TAR coordinator shall close the TAR in the database.

b. Uploading to ADAMS. The TAR coordinator shall ensure that the completed construction TAR and supporting documentation is uploaded to non-public ADAMS and distributed appropriately.

-B3-

Construction TAR Process Initial Coordination Constructionrelated Technical Meeting:

Issue Identified (COM (TAR Coordinator, 106, Section 4.8) Requestor, Tech Staff)

Perform TAR Construction TAR Evaluation(s) (Tech Process Staff, et. al)

Initiated Resolution Meeting:

Complete Intake (TAR Coordinator, Template: Refine Requestor, Tech Staff)

Issue/Question(s)

Management Approval TAR Database Entry No Consensus

/

Agreement?

Evaluation:

Establish Need Yes Date ID Tech Staff Completion &

Closeout: Database, ADAMS Entry by TAR Coordinator

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Appendix C Office Instruction COM-106 Documentation Template Descriptions

1. TAR Intake Form with Instructions (non-public ADAMS Accession No. ML19228A002)

As described in Section 4.8.2 of this OI, the Intake Form is a tool for NRR to collect facts relevant to the issue for consistency and efficiency. The requesting office will complete the information with the TAR Coordinator assistance using the TAR Intake Form in ADAMS or located on the TAR SharePoint site (link TBD) in the Intake phase.

The form will include the following major information for the staff to provide:

• Identify issue of concern and if it meets the TAR acceptance criteria

• Identify proposed unresolved questions, with underlying facts

• Include background information, quotes, supporting documents etc.

• Provide appropriate licensee perspectives with supporting documents, if any

• Provide sources of other diverse facts with supporting documents, if applicable

• Provide information to support safety significance evaluation of the issue

• Identify or explain if the issue is of very low safety significance and any prior efforts to disposition it before seeking a TAR

• Requesting Branch Chief sign-off with date

• Documented outcome of the TAR Intake Phase: (issue is resolved or referred to another process or recommended to be routed to the Screening and Evaluation phase) by TAR Coordinator with date

2. TAR Screening and Evaluation Authorization Email Template (non-public ADAMS Accession No. ML19282A001)

For moving an issue to TAR Screening and Evaluation, as described in Section 4.8.3 of this OI, the requesting office division management should submit an e-mail to the DORL division management using this NRC Screening and Evaluation Authorization E-mail template.

3. TAR Screening and Evaluation Results Memorandum Template (non-public ADAMS Accession No. ML19282A002)

As described in Section 4.9.3, in the Screening and Evaluation phase of TAR, the integrated team will document the results using this template to inform the requesting organization of the results and recommendations.

4. TAR Safety Significance Determination- Quick Reference Guide, Background, and Basis (ADAMS Accession No. MLXX)

This document guides the risk analyst and topical area subject matter expert in performing a safety significance assessment, as part of the screening and evaluation Enclosure 3

effort. The assessment includes issue description, assessing the associated change in risk, assessing safety margins and defense-in-depth, addressing opportunities for feedback, and assimilating the information to form the basis of the recommendation to the integrated team. For each element, several different options are provided based on existing regulatory guidance. The background and basis portion address more detailed aspects of implementing the approach, including addressing specific items that have arisen during the development and early implementation of the approach.

5. TAR Safety Significance Determination Template (ADAMS Accession No. MLXX)

This document provides a template that can be used by the risk analyst and topical area subject matter expert in documenting the safety significance assessment, as part of the screening and evaluation effort. The completed template can then be attached to the screening and evaluation results memorandum as the basis for safety significance determination or uploaded to non-public ADAMS separately.

6. TAR In-depth Review Response Memorandum Template (non-public ADAMS Accession No. ML19282A003)

The results of the in-depth review will be documented using this memorandum template.

The TAR response will consist of a short concise summary of the review results and, if possible, consist of a Yes or No type response to the questions posed or issues identified. A summary of the degraded condition of issues of concern need not be repeated, as this information is documented by the requesting office on the TAR Intake Form. The draft response should state the facts reviewed, brief issue statement, and the conclusion with the facts supporting the answer. The response should include supporting information as attachments including the screening and evaluation results.

The support information should identify meetings or conference calls held for the TAR issues with the licensee and relevant information used in the conclusions.

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Appendix D Office Instruction COM-106 Operating Reactor TAR - Summary of Action Steps No. Action Action-taker General (Gen) Program Actions:

Gen1 Maintain a log of completed and active TARs on SharePoint TAR Coordinator Gen2 Perform periodic NRR Executive Team briefing on active TARs TAR Coordinator Gen3 Submit status report for monthly NRR workload meetings TAR Coordinator Intake (Int) Phase: ( 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> level of effort)

Int1 Initiate a TAR via email to the TAR Coordinator, using a partially-populated RO Staff/BC TAR Intake Form Int2 Assign a TAR # to the incoming, add to TAR log, and notify DORL BC and TAR Coordinator management of the incoming and identify schedule priorities Int3 Review TAR Intake Form, and discuss pre-screening applicability criteria TAR Coordinator including acceptance (Section 4.2 - 4.5) with RO (as necessary)

Int4 If a decision has been reached to close the TAR, proceed to closure at the TAR Coordinator bottom of this table (Closure Outcome 1 or 2)

Int5 Complete TAR Intake Form with all supporting documents and factual TAR Coordinator information from all relevant sources 15(put package in non-public ADAMS) and RO Int6 Obtain RO management authorization to proceed to Screening and TAR Coordinator Evaluation if acceptance criteria is met and RO Int7 Grant authorization to proceed to S&E and request to DORL management RO Division to move issue to next phase (S&E initiation) Management Screening and Evaluation (S&E) Phase: ( 30 days from S&E Integrated Team (IT) Kickoff Meeting) 16 S&E1 Identify and engage the SES Chairperson for the Integrated Team with TAR Coordinator DORL management support S&E2 Obtain an EPID through RRPS (non-fee-billable charge code), including TAR Coordinator establishment of milestones S&E3 Stand-up the IT 17 (within 7 working days of S&E initiation) TAR Coordinator S&E4 Work with the RO and/or plant PM (when relevant) to hold a conference TAR Coordinator call (typically non-public, depends on the process the TAR serves) with the licensee regarding the start of a new TAR S&E5 Lead the IT Kickoff Meeting Chairperson and TAR Coordinator S&E6 Hold meetings or calls as necessary to expeditiously scope the request TAR Coordinator and iterate and frame appropriate unresolved TAR questions and IT members S&E7 Engage licensee, if relevant (e.g., if there are diverse facts). 5 days or as TAR Coordinator, IT, agreed to submit any new information (voluntary or additional 18) with and licensee respect to the intake form 15 Assumes licensee information collected prior to entering intake 16 Days are calendar days unless specifically mentioned otherwise 17 Integrated Team: Lead Chairperson (typically an SES executive), TAR Coordinator, DORL plant PM, RO staff, NRR topical SME, SME (backfit, generic concerns etc.), OGC, OE (if required), and NRR risk analyst(s) 18 Additional information- these are not like RAIs in license amendment requests. They can be submitted by e-mail.

Enclosure 4

No. Action Action-taker S&E8 Assess the issues significance using the TAR Safety Significance Risk analyst and Determination Instructions and associated Template Topical SME S&E9 Perform screening for referral to other processes or evaluate for early IT resolution if easily achievable, including review of LB standing with the gathered facts S&E10 IT holds interim meeting to discuss ongoing assessment and refine IT and Chairperson understanding of issue, as needed, and holds a meeting to align on the path forward with the Chairperson as the decision-maker. IT will document the results and conclusion in the Screening and Evaluation Results Memorandum 19 to the RO S&E11 If the IT concludes the TAR should be closed, proceed to closure at the TAR Coordinator bottom of this table (Closure Outcome 1, 2 or 3) using the Screening and Evaluation Results Memorandum Template, including licensee notification (when relevant) through the RO and/or plant PM S&E12 If the IT has reached an impasse, elevate to resolve disagreements Chairperson, TAR (optional guidance) Coordinator, Office management S&E13 If an exception to the entrance criteria for in-depth review is being pursued, TAR Coordinator take associated actions of seeking higher authorization at office director level from both NRR and RO organizations S&E14 If the issue should proceed to an in-depth review, the Screening and TAR Coordinator Evaluation Results Memorandum should document the acceptable questions for the in-depth review and notify RO Division management (in-depth review initiation)

S&E15 Distribute Screening and Evaluation Results Memorandum to RO and TAR Coordinator others (non-public in ADAMS)

In-Depth Review (IDR) Phase: ( 80 days from IDR Initiation)

IDR1 In-Depth Review Phase initiation and status the EPID for continuation of TAR Coordinator TAR IDR2 Identify the TAR review team 20 TAR Coordinator IDR3 Facilitate a kick-off meeting or call (non-public typically) with the requestor TAR Coordinator and the licensee, when relevant and TAR review team, share relevant information and TAR questions IDR4 Licensee additional information (voluntary or otherwise) 7 days or as Licensee agreed18 IDR5 During evaluation of the issue, facilitate follow-ups with RO and OGC, as TAR Coordinator needed IDR6 Compile draft TAR response and transmit to RO for 7-day comment TAR Coordinator period 21 IDR7 Transmit comments on draft TAR response to TAR Coordinator RO IDR8 Schedule and facilitate an NRR Executive Team alignment brief TAR Coordinator IDR9 Schedule and facilitate a de-brief with the RO and review team TAR Coordinator IDR10 Schedule a call with the external stakeholder (e.g., licensee) and share TAR Coordinator conclusion and facts of the draft TAR response with NRR technical staff attending 19 IT concurs on the Screening and Evaluation Results memorandum (includes requesting office staff and BC) 20 TAR Review team (in-depth review): TAR Coordinator, DORL plant PM, NRR technical staff, OGC, OE (if required) 21 RO does not concur on IDR TAR response

-D2-

No. Action Action-taker IDR11 Record the in-depth review result and conclusion using the In-depth TAR Coordinator Response Memorandum Template. Route the TAR response for concurrence, including NRR, OGC (NLO), and OE (as needed)

IDR12 Sign final TAR response addressed to RO Division management DORL Deputy Director IDR13 Distribute the IDR TAR response to RO and others (non-public ADAMS) TAR Coordinator IDR14 Proceed to closure below (most likely Outcome 1) TAR Coordinator IDR15 RO staff or DORL plant PM notifies licensee (if relevant) of closure of the RO staff or DORL TAR plant PM Closure (Clo):

Clo1 Close the TAR in the log with one of the three possible outcomes:

1. Issue is resolved including response to the requesting office

2. A recommended referral is made to another process

3. The issue is recommended for no further action based on safety significance and other criteria DORL = NRRs Division of Operating Reactor Licensing IT = Integrated Team RO = Requesting Office SME = Subject Matter Expert TAR = Technical Assistance Request TAR Coordinator = Technical Assistance Request Program Point of Contact and Coordinator

-D3-

Safety Significance Determination Template Rev. 5 - December 4, 2019

Enclosure:

Safety Significance Determination A separate quick reference guide and basis/background document is available.

< Insert TAR # and Issue Title >

Section A - Issue

Description:

ISSUE CHARACTERIZATION Affected Structures, Systems, Components (SSCs), Operator Actions, and Risk-Relevant Functions:

Click here to enter text.

Conditions when the issue would manifest Itself (e.g., type of event, plant configuration):

Click here to enter text.

Exposure Time:

Click here to enter text.

Is Recovery of the Failed Function Credible? Yes No If yes, describe under what conditions.

Additional Issue Complexities (e.g., known synergy with other ongoing issues at the facility), if any:

Click here to enter text.

Licensees Perspective on the Issue, if known:

Click here to enter text.

COORDINATION AND COMMUNICATION Has the above issue characterization been discussed with the regional SRA?

Click here to enter text.

Are there key assumptions being made at this point in the process about the degraded condition and its associated impact on plant response?

Click here to enter text.

Section B - Associated Change in Risk

< Provide a bridge between the issue characterization above (i.e., the degraded condition and its effect on plant response) to the assessment of risk, by identifying which elements of the plant response are and are not captured in the risk evaluation. A sample table is provided for consideration:

Effect of condition Modeled in characterization of Notes risk?

E.g., RHR Train B may be Yes, RHR Train B is treated as This may be an over-estimation unavailable following a LOOP, if failed in relevant accident of the impact, since RHR Train an ECCS signal occurs sequences B may not actually be damaged E.g., Flooding may occur in area No, flooding effects is not This should be considered at the xyz due to equipment damaged treated in the modeling Defense-in-Depth andor Safety by the water hammer Margin stage E.g., A new ISLOCA pathway Yes, in that a sensitivity study This sensitivity should inform could be created if RHR piping on LERF is being provided consideration of this aspect in is damaged outside of the Defense-in-Depth andor containment Safety Margin stage Enclosure 1

Safety Significance Determination Template Rev. 5 - December 4, 2019

< Insert a description of the evaluation of the associated change in risk; include lists of high-contributing accident sequences and importance measures when relevant >

Section C - Safety Margin

< Insert a description of the evaluation of safety margin >

Section D - Defense-in-Depth:

< Insert a description of the evaluation of defense-in-depth >

Section E - Performance Monitoring / Feedback:

< Insert a description of the consideration of feedback >

Section F - Wrap-up:

Topic Item Outcome Key uncertainties

• Item #1; not otherwise

• Item #2 considered Safety The change in risk is very low/small Yes / No /

significance Indeterminate summary Adequate safety margin is retained Yes / No /

Indeterminate Sufficient defense-in-depth is maintained Yes / No /

Indeterminate There is adequate opportunity for feedback / monitoring Yes / No /

(or sufficient alternative means have been considered) Indeterminate On the whole, the issues safety significance appears to Very low /

be: elevated /

indeterminate Were the issue to be subject to the Safety Goal Yes / No /

Evaluation 1 in NUREG/BR-0058 (as part of a backfit Unknown evaluation), the issues significance would likely meet these criteria.

Potential Evaluation shared with Regional SRA, as courtesy, and Yes / No / NA additional actions for awareness relative to other risk-informed evaluations for this facility?

SPAR Model Feedback Form submitted for potential Yes / No / NA adjustment of the baseline model?

1 More specifically, this refers to Section 2.4 of NUREG/BR-0058, Draft Revision 5 [ML17100A480], and Figure 2-3 therein. The intent is to document cases where it is clear how such an evaluation would turn out, so as not to lose that insight. In some cases, the TAR safety significance evaluation will not provide sufficient information to draw a conclusion in this regard, and Unknown should be chosen.

Enclosure 2

Safety Significance Determination Template Rev. 5 - December 4, 2019 Risk Analyst:

Printed/typed name Title Organization Signature Date Topical Area Subject Matter Expert:

Printed/typed name Title Organization Signature Date Enclosure 3

TAR Safety Significance Determination - Quick Reference Guide Rev. 5 - December 4, 2019 TAR Safety Significance Determination - Quick Reference Guide Background & Basis follows A documentation template is provided separately Figure 1: Overview of the Worksheet Process Guidance regarding purpose, workflow, peer review, etc. is provided in the Background & Basis section, which immediately follows this quick reference guide.

Section A - Issue

Description:

Some aspects of issue characterization will already be documented as part of the over-arching process that led to this significance determination (e.g., the intake form from NRR Office Instruction COM-106). Use the associated safety significance determination template (contained in the same ADAMS package) to document basic information about the issue. This step relies on good communication at multiple steps as discussed in the Background & Basis.

Section B - Associated Change in Risk Using one of the following approaches as a guide, document the basis for why there would be, or would not be, a significant increase in risk to the public, should the issue be dispositioned without further action.

Approach B1 - Inspection Guidance / IMC 0609 (preferred approach)

Approach B2 - Risk Triplet Discussion Approach B3 - Scoping PRA Estimate Each approach is described further in the Background & Basis document. This stage of the process should lay the groundwork for identifying those elements of plant response that are and are not captured by the evaluation of the change in risk, thus establishing where overlaps in the risk, safety margin, and defense-in-depth evaluations exist. Alternatively, if it can be shown that there is no (zero, or even negative) identifiable increase in risk associated with the issue, that should be documented in lieu of, or in conjunction with, following one of these approaches.

Section C - Safety Margin Using one of the following approaches, and specifically considering the extent to which the assessment of risk significance informs the present element, document the basis for why there Worksheet - Page 1 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE

TAR Safety Significance Determination - Quick Reference Guide Rev. 5 - December 4, 2019 would, or would not be, significant erosion of safety margin in risk-significant SSCs or plant capabilities, should the issue be dispositioned without further action.

Approach C1 - Risk Triplet (preferred approach)

Approach C2 - 50.69 Categorization Approach C3 - LIC-504, Revision 4, Appendix D, Section 2.3.1 Each approach is described further in the Background & Basis document. The analyst needs to make a distinction between instances where degradation of engineering margin impacts the overall finding that the facility poses no undue risk, versus instances where this it does not. The integration of safety margin with risk information and defense-in-depth is the means of making this more holistic assessment. Erosion of safety margin already adequately captured by the risk assessment should be documented here, but not double counted. Alternatively, if the risk assessment adequately captures all significant elements of safety margin, that should be documented in lieu of, or in conjunction with, following one of these approaches.

Section D - Defense-in-Depth:

Using one of the following approaches, and specifically considering the extent to which the characterization of risk significance and safety margin has informed the present element, document the basis for why there would be, or would not be, significant erosion of defense-in-depth should the issue be dispositioned without further action.

Approach D1 - Regulatory Guide 1.174, Rev. 3, Section 2.1.1.3 (preferred approach)

Approach D2 - 50.69 Categorization Approach D3 - 50.69 Guidance - NEI-00-04, Revision 0, Section 6 Each approach is described further in the Background & Basis document. The degree to which defense-in-depth should be viewed as something that is being established (a licensing perspective) versus something that is being eroded (an oversight perspective) will depend on the nature of the issue. Limitations in the risk assessment should be considered in the assessment of defense-in-depth. Conversely, facets of defense-in-depth erosion already adequately captured by the risk assessment (e.g., general common-cause failure mechanisms, a particular electrical board being required for successful operation of multiple pieces of equipment) should not be double-counted. Alternatively, if the risk and safety margin assessment adequately captures all significant elements of defense-in-depth, that should be documented in lieu of, or in conjunction with, following one of these approaches.

Section E - Performance Monitoring / Feedback:

Using one of the approaches below, document the basis for why there would be, or would not be, sufficient performance monitoring (feedback) opportunity via other mechanisms inherent in the situation. To be relevant, these feedback mechanisms would need to reasonably reveal to the NRC staff significant mistakes in judgment associated with dispositioning the issue without further action, prior to an unacceptable outcome.

Approach E1 - Oversight Approach E2 - Regulatory Reporting Approach E3 - A more generic feedback mechanism No feedback opportunity Worksheet - Page 2 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE

TAR Safety Significance Determination - Quick Reference Guide Rev. 5 - December 4, 2019 Put differently, if a determination to sunset the issue is reached, and if that determination turns out to be ill-founded, are there feedback mechanisms that will re-focus the agencys attention on the issue? This step is not intended as an opportunity to leave the issue open beyond its disposition, but rather to arm the decision maker with the knowledge of whether this type of feedback exists.

Section F - Wrap-up:

Prior to making a determination, document the known sources of uncertainty (parameter, modeling, and/or completeness) that have not been captured in the foregoing documentation and would be expected to significantly influence the foregoing evaluation. The purpose of doing this is not to drive the outcome, but rather to ensure that future readers remain aware of the associated uncertainties at the time the determination was reached.

Based on the totality of the foregoing information, and from the perspective of whether the agency should expend significant additional resources investigating this issue (vice other issues), document whether the issue has apparent safety significance in each of the assessed areas. The documentation template offers suggested language.

If the issue was judged to be clearly of very low safety significance, 1 it should be recommended for disposition on the basis of this evaluation. If one or more does not entries have been selected, the issue may still be of very low safety significance, but a higher level of buy-in amongst the integrated team may be needed to disposition the issue on the basis of this evaluation.

Separately, if the assessment cannot conclude that the issue is of very low safety significance, yet it is apparent that the issue does not have sufficient significance to meet the Safety Goal Evaluation criteria in NUREG/BR-0058, Draft Revision 5 (Section 2.4, and Figure 2-3 therein),

this should be documented. The intent is to document cases where it is clear how such an evaluation would turn out, so as not to lose that insight. In some cases, the TAR safety significance evaluation will not provide sufficient information to draw a conclusion in this regard.

While exploration of the issue would nominally proceed, this additional information may guide the level-of-effort later, should it become evident that the issue is likely outside of the current licensing basis.

The above assessment should reflect an agreement between the risk analyst and the topical area subject matter expert. If alignment cannot be reached, the safety significance should be considered indeterminate, or alignment should be sought by engaging the integrated team. If others involved in the assessment have a differing view with the outcome, that should be communicated to the integrated team but otherwise pursued through the agencys broader differing views process.

1 It is acknowledged that differing agency processes use differing terminology with respect to safety significance.

Here, very low safety significance is generally intended to mean a level of safety significance where the agency would be unlikely to take further regulatory action or require additional assurance. Relative to processes that use a binary description of safety significance (e.g., 10 CFR 50.69), this would be the lower bin. Relative to processes that use a tertiary (or higher) description of safety significance (e.g., IMC 0609, LIC-504), this worksheet would view very low safety significance to be the lowest of these bins.

Worksheet - Page 3 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE

TAR Safety Significance Determination - Background & Basis Revision 5 - December 4, 2019 TAR Safety Significance Determination - Background & Basis General:

• Purpose - The purpose of this worksheet is to guide a structured approach to assessing the safety significance of an emergent plant-specific issue that has entered the TAR process. It guides the involved staff in considering the right facets, engaging the right counterparts (e.g., the requesting office, the TAR integrated team), and documenting the right considerations. It envisions a level-of-effort and level-of-rigor that is more than a back of the envelope or value judgment exercise, but less than a LIC-504 evaluation, a Regulatory Guide 1.174 evaluation, or a Significance Determination Process detailed risk evaluation. The ultimate decision on whether an item has sufficient safety significance to warrant further agency resource expenditure necessarily requires judgment.

• Desired outcome - A completed and documented analysis that has engaged the issue owner up-front, considered real-time feedback from the broader integrated team, and resulted in a determination by the risk analyst 2 and topical area subject matter expert (SME).

• Terminology: safety-significance vs. risk-significance - This worksheet deliberately uses the term safety significance in lieu of risk significance in a manner consistent with NRR Office Instruction LIC-504, Revision 4, which states it should be clear that the risk impact is very small, and there is minimal degradation of defense-in-depth or safety margin. All five key principles of risk-informed regulation as defined in RG 1.174 should be considered to the extent warranted. The compliance element of integrated decisionmaking is deliberately omitted here because the purpose is to assess whether further resource expenditure to determine compliance is warranted.

• Terminology: Use of the term Very Low - Different agency processes use terms like low to very low to mean similar things. Choice of wording is often driven by other contextual factors, rather than the denotation of the words. Here, the term very low is used to mean that an issue has insufficient safety significance to warrant further agency resource expenditure. This process is not to be used re-calibrate the thresholds associated with any other particular process. Figure 2 illustrates the differing terminology used in various NRC processes, in the context of risk-significance. This figure is based on CDF, but the same concepts apply to large early release frequency.

• Workflow - Regarding how to manage the work associated with this safety significance determination, Table 1, provides a suggested workflow. The risk analyst and topical area SME should approach the work in the way that is most efficient for their work style and availability. However, attention should be paid to how resources are being expended, since this process is a prioritization of resources and not a solution to the question or issue being posed. If a conclusion of very low safety significance cannot be determined within a total level-of-effort of (approximately) 10 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, the issue is likely not clearly of very low safety significance, and a recommendation of indeterminate should be made to the integrated team.

• Flexibility in selecting an approach - For each section of the evaluation, the approach that is most suitable to the issue being evaluated should be selected. It is acknowledged that different approaches could lead to different outcomes, and this is judged to be an 2

It is generally envisioned that the role of risk analyst will be filled by a qualified risk and reliability analyst from the Division of Risk Analysis. There may be instances where it is more efficient to have a Regional Senior Reactor Analyst fill this role.

Instructions - Page 1 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE

TAR Safety Significance Determination - Background & Basis Revision 5 - December 4, 2019 acceptable limitation, relative to the benefit of using existing approaches and promoting flexibility for the user. In anticipation that the process will be used most often in an inspection context (but with unresolved licensing basis aspects), Approach 1 from each element is the preferred approach (i.e., the approach that is most widely suited for this context). That said, the decision of which approach to use for each element is ultimately left up to the user. In rare cases, it may make sense to use a combination of approaches.

Figure 2: Illustrative Comparison of Varying Process Terminology

• Uncertainty - The worksheet does not include a specific step associated with treatment of risk uncertainty (in contrast to DID or SM uncertainty), but it does include some aspects of how one accounts for uncertainty in risk-informed decisionmaking. More specifically, the risk evaluation can provide information about parameter and model uncertainty, via propagation of individual parameter uncertainties and conduct of sensitivity analyses. However, this is left here to the users judgment as to whether that is a necessary step of this resource prioritization determination. Meanwhile, the elements of safety margin, defense-in-depth, and performance monitoring are primary means (in general) of accounting for completeness uncertainty. These concepts are discussed in detail in NUREG-1855, Revision 1 (e.g., see Figure 2-1 and Section 2.3 of that document). The user is directed to document significant sources of uncertainty that are not otherwise considered in Section F.

• Peer review - Evaluations performed using this worksheet that lead to sun-setting an issue (partially) based on its safety significance would not generally fall under the auspices of ADM-405, NRR Technical Work Product Quality and Consistency, in that an issue would not be clearly of very low safety significance if the evaluation was technically complex, involved new methodologies/technologies, represented a significant Instructions - Page 2 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE

TAR Safety Significance Determination - Background & Basis Revision 5 - December 4, 2019 departure from past activities, or fit one of the other descriptors in Section 4.1 of that document. That said, and as ADM-405 states, if judgment plays a substantial role in the COM-106 response, the evaluation could be subject to that guidance. In this case, the risk analyst and topical area SME should identify the need for a review to the Integrated Team Chair, and a review should be conducted using the guidance in ADM-405.

Table 1: Suggested Workflow Activity Participants1: Total effort (hrs)

Review intake material and other background R, S 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Part One: Sync-up and analysis:

0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Call with issue owner or integrated team to assure I, R, S 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> understanding of the concern and its implications 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Risk analyst and SME perform initial evaluation of risk, R, S 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> safety margin, and defense-in-depth 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Discuss Section B-D results, as well as Section E R, S 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Offline: Follow up on any open items R, S 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Part Two: Refinement and finalization 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Brief out preliminary results to broader integrated team I, R, S Separate 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Perform any additional work prompted by the above R, S 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Update writeup, complete Section F, and sign R, S 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Total hours 15 hrs 1 I = integrated team; R = risk analyst; S = topical area subject matter expert Section A - Issue

Description:

• Communication and coordination - For inspection issues, this step relies on good upstream interactions between the inspector and the regional SRA to arrive at an understanding of the degraded condition and how it impacts the plant response. This is not an activity that can be done solely by either party, as it requires judgment about how the condition will affect various functions in concert with an understanding of how those functions relate to a broad array of postulated accidents. Further, this step relies on a good handoff of that information to the individuals performing the safety significance determination here. The integrated team kickoff meeting is the prime opportunity for this, but the risk analyst should also consider reaching out to the regional SRA. All of the above is made more difficult in situations where the nature of the condition and its impact on plant response is still evolving. For this reason, it is also important that any key assumptions made at this point in the process are documented.

Section B - Associated Change in Risk Approach B1 - Inspection Guidance - Using IMC 0612 and the relevant attachments and appendices to IMC 0609, determine if the issue would meet the criteria for minor. If it would not, determine if the proximate and posited degraded condition would (were the issue to have an associated performance deficiency) screen out of warranting additional evaluation (i.e.,

would be a finding of very low safety significance without the need to proceed to a Phase 2 assessment, a Detailed Risk Evaluation, or an Appendix M evaluation). In general, issues within these categories (minor or not requiring additional evaluation), would be expected to result in changes in risk to the public that would support a determination of being clearly of very low safety significance. Avoid using the SDP color scheme. If the issue would not screen out due to Instructions - Page 3 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE

TAR Safety Significance Determination - Background & Basis Revision 5 - December 4, 2019 limitations in the coarse nature of that guidance, but is nevertheless of very low risk significance, consider using one of the other two approaches outlined below.

Approach B2 - Risk Triplet Discussion - Relate the issue to its proximate impact on the plant, by characterizing (i) what can go wrong, (ii) how likely it is to occur, and (iii) what the consequences would be. More specifically, describe qualitative or semi-quantitatively how the issue would be expected to manifest in (i) an increase in initiating event frequency, (ii) a decrease in the capability of specified SSCs or operator actions to mitigate an accident, and (iii) the consequences associated with an accident. When applicable, characterize the fraction of time that, and the circumstances under which, the issue is relevant. Place the above impacts in the context of their relative plant-specific risk significance (e.g., using the Plant Risk Information E-Book), and make a judgment as to whether this risk is generally above or below the level at which the agency would typically respond (e.g., reactive inspection criteria in Management Directive 8.3) or approve a license amendment (e.g., within Region III of RG 1.174, Revision 3).

Based on the totality of information, and using judgment, decide if the assessed change in risk would support a determination of being of very low safety significance.

Approach B3 - Scoping PRA Estimate - Identify the impacts of the issue on initiating event likelihood, impairment of SSC functionality, impairment of operator action reliability, and/or other aspects of how the issue affects risk to the public. Perform a Standardized Plant Analysis Risk (SPAR) model calculation(s) to identify the highest contributing accident sequences and cut sets for the change in risk. Characterize the significance of the estimated increase in risk using the guidance in LIC-504, Revision 4, or Regulatory Guide 1.174, Revision 3. For the purposes of this evaluation, this characterization represents the risk significance, not the overall safety significance. That said, for a resulting change in risk that is below the LIC-504, Revision 4, criterion of clearly of low safety significance or within Region III of RG 1.174, Revision 3, the assessed change in risk would support a determination of being of very low safety significance.

Additional points of clarification and background on the above approaches:

• Exposure Time - Processing of findings often includes the concept of exposure time, i.e., that the degraded condition only persisted for a finite period of time. The term Exposure time is defined in IMC 0609, while the RASP Handbook includes instructions on how to estimate exposure time when it is not specifically known. Conceptually, the use of exposure time implies that the degraded condition has already been fixed. Here, it is quite possible that the condition will not be fixed (or at least that the agency will have no plans to confirm completion of the fix). In such cases, it may be necessary to assume an indefinite exposure time, and this alone may invalidate the utility of using some of the SDP screening questions.

• SDP Independence - Care should be taken to not imply that an SDP is being conducted, but rather that the tools associated with SDP are being utilized. This is most easily accomplished by not invoking the SDP color schemes. IMC 0308, Attachment 3 (issued June 2016) states, The color of an SDP result carries with it an assurance that all of the specific applicable process provisions of the overall SDP have been met. Other forms of significance determination may not have the same process attributes, definitions, or assurances, and therefore should not be characterized using the SDP color scheme Keeping the SDP color scheme independent from other forms of significance determination also aids in ensuring clear and consistent public representations that inspection findings with colors are inputs to the ROP assessment of licensee performance.

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TAR Safety Significance Determination - Background & Basis Revision 5 - December 4, 2019 Section C - Safety Margins Approach C1 - Risk Triplet - Using engineering judgment, articulate why the erosion of safety margin (e.g., the degree to which the factor-of-safety has been reduced for an affected system) does or does not lead to an important change in (i) initiating events that can occur; (ii)

SSC and operator response to postulated beyond design basis accident sequences; and (iii) the potential consequences from these accident sequences. Recognizing that the degree of margin above the design envelope is often not precisely known, articulate whether the degradation is likely in a regime more proximate to expected nominal performance versus expected failure, and describe the extent to which the potential degraded performance is or is not explicitly captured by the risk assessment. Further, assess to what extent the change in likelihood, mitigation, or consequence caused by the degraded margin translates to a change on the facilitys overall impact on public health and safety. Based on the totality of information, and using judgment, decide if the assessed erosion of safety margin would support a determination of being of very low safety significance.

Approach C2 - 50.69 Categorization - If the licensee has an approved 10 CFR 50.69 program, and it has categorized the relevant functions and systems under that program, identify whether the degraded plant response associated with the issue exclusively involves SSCs categorized as RISC-3 or RISC-4 (i.e., LSS in the 50.69 binning scheme). If this is the case, and given the way in which that program considers safety margin in categorization, the issue would be expected to result in a degree of safety margin erosion that would support a determination of being of very low safety significance.

Approach C3 - LIC-504, Revision 4, Appendix D, Section 2.3.1 provides a series of 6 questions that can be used to frame this assessment. In that document, the safety margin assessment is used to frame the potential risk assessment, whereas in this document, the risk assessment is assumed to occur in parallel. In reality, it is recognized that the two steps (safety margins and risk assessment) can be iterative. Based on the totality of information, and using judgment, decide if the assessed change in safety margin would support a determination of being of very low safety significance.

Additional points of clarification and background on the above approaches:

• Meaning and use of the term safety margin - The term safety margin is often used to describe two related, yet separate, concepts. Codes and standards routinely refer to terms-of-art like margin-of-safety and safety factor (and at times safety margin) to articulate (for instance) that degree of cushion that exists between a prescribed load and an estimated capacity. This is usually done in the context of a particular structure, system, or component (SSC) or a particular analysis, and reflects the traditional engineering practice of over-designing in light of uncertainty (i.e., engineering margin).

The NRC continues to rely on this engineering practice as part of ensuring that plants are licensed safely. Meanwhile, as part of risk-informed regulation, the Commission and staff have routinely emphasized that risk information be used in conjunction with traditional engineering practices in ensuring no undue risk. In the 1995 Commission Policy Statement on use of probabilistic risk assessment (PRA), the Commission used the terms defense-in-depth and engineering margin to describe these traditional practices. Meanwhile, in subsequent regulatory guidance (e.g., Regulatory Guide 1.174) and its common description of integrated (a.k.a., risk-informed) decision making, the staff has used the terms defense-in-depth and safety margin. Thus, the intersection Instructions - Page 5 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE

TAR Safety Significance Determination - Background & Basis Revision 5 - December 4, 2019 of the different terminology has become blurred. Clearly the use of engineering margin in the context of a particular SSC or analysis has a nexus to safety margin in terms of a plant-wide safety impact that might cause undue risk, when considered in an integrated fashion with PRA results and defense-in-depth. One can think of the former as a constituent contributor to the latter. Alternatively, one can think of individual instances of engineering margin as potential influencers on overall safety margin, depending on whether that particular SSCs margin erosion is important to public health and safety (not all SSC margin is influential to overall safety). In identifying what specific constituent margins are of relevance to the issue at hand, it may be helpful to refer to discussions of safety margin such as that contained in Inspection Procedure 71111.21M. However, this margin should not be open-ended, but rather should be tied to particular assumptions in the risk assessment, or related to an impact on public health and safety that the risk assessment did not address. In other words, when assessing a specific issues significance, one should develop an understanding of what margin (analytical, operational, maintenance-oriented, or otherwise) is being eroded, but ultimately the erosion of that individual margin must be viewed in terms of its impact on facility safety.

Section D - Defense-in-Depth Approach D1 - Regulatory Guide 1.174, Revision 3, Section 2.1.1.3 provides discussion on defense-in-depth, including 7 principles that can be used to frame the degree to which defense-in-depth is impacted. (Alternatively, LIC-504, Revision 4, and IMC 0609 Appendix M (issued January 2019) both contain similar discussion.) Describe how the issue impacts these 7 principles, and describe the associated risk significance of this impact. This review would not be as detailed as the analogous exercise performed for license amendment requests and safety evaluation reports.

Approach D2 - 50.69 Categorization - If the licensee has an approved 10 CFR 50.69 program, and has categorized the relevant functions and systems under that program, identify whether the degraded plant response associated with the issue exclusively involves SSCs categorized as RISC-3 or RISC-4 (i.e., LSS in the 50.69 binning scheme). If this is the case, and given the way in which that program considers defense-in-depth in categorization, the issue would be expected to result in a degree of defense-in-depth preservation that would support a determination of being of very low safety significance.

Approach D3 - 50.69 Guidance - NEI-00-04, Revision 0, Section 6, provides a framework for assessing the degree of impact on defense-in-depth. Using this construct, identify the specific impacts on defense-in-depth. Use of this framework will lead to a conclusion that the issue (and more specifically its impact on how the plant will behave under accident conditions) falls in to the category of either potentially safety significant or low safety significance confirmed. The latter is synonymous with very low safety significance in the context of the TAR worksheet.

Section E - Performance Monitoring / Feedback Approach E1 - Oversight - Articulate why existing inspection scope or performance indicators could reasonably identify unanticipated and unrecognized faults in this assessment.

For instance, if the issue would be expected to cause an increase in plant scrams, but this assessment concluded that the impact of this increase would not be safety-significant, would the Initiating Events Cornerstone Performance Indicators highlight errors in this judgment? Based Instructions - Page 6 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE

TAR Safety Significance Determination - Background & Basis Revision 5 - December 4, 2019 on the totality of information, and using judgment, decide if there is sufficient opportunity for feedback.

Approach E2 - Regulatory Reporting - Articulate why existing regulatory reporting requirements (e.g., Licensee Event Reports) could reasonably identify unanticipated and unrecognized faults in this assessment. This could include licensee Maintenance Rule activities, or licensee performance monitoring strategies implemented as part of previously-approved license amendments, if the agency has sufficient visibility into these activities.

Approach E3 - If there are no applicable feedback mechanisms that would highlight a significant error in judgment, yet all other factors point to an issue of very low safety significance, work with the integrated review team chair to consider whether a more generic feedback mechanism is appropriate (e.g., if the issue might not be very low safety significance for other plants, propose an inspection smart sample).

Section F - Wrap-Up

• Integrated decisionmaking - Be aware that LIC-504, Enclosure 5 provides some guidance for making an integrated decision, and more broadly, that document provides the NRCs perspective on use of integrated decisionmaking in exploring emergent issues. Meanwhile, EPRI Report 3002014783 provides an industry perspective on how the various inputs to integrated decisionmaking can be best incorporated. Figure 4-1 and Section 4 of that report describe a process very similar to the one being invoked here, but which focuses on assessing Defense-in-Depth and Safety Margin ahead of the risk assessment rather than visa versa. Both approaches are reasonable, and they are both iterative processes in reality.

• Senior Level Advisor Consultation - While it is envisioned that the determination will be made primarily based on the technical expertise of the involved risk analyst and topical area SME, in consultation with the integrated team, consider reaching out to the relevant senior level advisors for advice on particular technical issues.

References:

COM-106 NRR Office Instruction for the Task Interface Agreement / Technical Assistance Request process - revision under development EPRI 3002014783 A Framework for Using Risk Insights in Integrated Risk-Informed Decision-Making, February 2019 IMC 0308 Att. 3 Significance Determination Process Technical Basis Document, June 16, 2016 IMC 0609 Significance Determination Process, October 12, 2018 - various attachments and appendices are referenced or implied IMC 0612 Issue Screening, May 3, 2017 - various appendices are referenced or implied IP 71111.21M Design Bases Assurance Inspection (Team), December 8, 2016 Instructions - Page 7 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE

TAR Safety Significance Determination - Background & Basis Revision 5 - December 4, 2019 LIC-504 Revision 4, Integrated Risk-Informed Decision-Making Process for Emergent Issues, May 30, 2014 MD 8.3 NRC Incident Investigation Program, June 25, 2014 NEI-00-04 Revision 0, 10 CFR 50.69 SSC Categorization Guideline, July 2005 NUREG-1855 Revision 1, Guidance on the Treatment of Uncertainties Associated with PRAs in Risk-Informed Decision Making, March 2017 RASP Handbook Revision 2.02 Risk Assessment of Operational Events Handbook -

Volume 1 - Internal Events, December 2017 RG 1.174 Revision 3, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, January 2018 Instructions - Page 8 DRAFT WORK-IN-PROGRESS - SUBJECT TO CHANGE