ML21209A993

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Dispositioning of Cross-Cutting Issues Program Effectiveness Review Recomendations
ML21209A993
Person / Time
Issue date: 09/17/2021
From: Masters A
NRC/NRR/DRO/IRAB
To: Christopher Regan
NRC/NRR/DRO
Alex Garmoe, NRR/DRO/IRAB 415-3814
References
Download: ML21209A993 (3)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 17, 2021 MEMORANDUM TO: Christopher Regan, Acting Director Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: Anthony D. Masters, Chief /RA by e-mail /

Reactor Oversight Process Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUBJECT:

DISPOSITIONING OF CROSS-CUTTING ISSUES PROGRAM EFFECTIVENESS REVIEW RECOMMENDATIONS The purpose of this memo is to document the recommendations that the agency will take action on in the near term regarding the effectiveness review of the Reactor Oversight Process (ROP)

Cross-Cutting Issues (CCI) Program. On September 21, 2020, an effectiveness review of the CCI Program was completed and documented in a report available in ADAMS Package Accession No. ML20239A806. The review was conducted by a multi-disciplinary team that included extensive inspection and ROP background, qualified safety-culture assessment expertise, and experience from numerous agency offices, and was performed as part of the ROP self-assessment process prescribed in Inspection Manual Chapter 0307. Several CCI program recommendations were documented in the report following, and derived from, a thorough data-driven assessment of the program.

Recommendations were documented in the report in two groups - Group 1, which could be implemented with a lower level of resources that could lead to small improvements in implementation of the CCI program, and Group 2, which would make significant meaningful improvements to the CCI program but would come at a higher resource cost.

Recommendations included in the report are:

Group 1:

  • Provide more detailed discussion of CCI insights and decisions in assessment letters (report recommendation 3.d)
  • Timing of follow-up actions should be based on licensee readiness (report recommendation 4.a)
  • Establish standardized CCI follow-up inspection guidance with objectives (report recommendation 4.d)
  • CCI follow-up could be scoped into an existing planned supplemental inspection (report recommendation 4.c)
  • CCIs should not be able to be closed solely based on a reduction in inspection findings (report recommendation 4.d)

CONTACTS: Anthony D. Masters, NRR/DRO/IRAB Alex Garmoe, NRR/DRO/IRAB 770-846-4740 301-415-3814

C. Regan 2 Group 2:

  • Monitor findings using the nine safety culture traits (2.a is also an acceptable though less preferable approach; 2.g and 3.c are inherently included in this recommendation) (report recommendation 2.b)
  • Remove the requirement that a theme be exceeded for three consecutive periods before a CCI is opened; open a CCI once a threshold is reached (report recommendation 2.d)

Upon review of the recommendations in spring 2021, the Office of Nuclear Reactor Regulation, in consultation with the Office of Nuclear Security and Incident Response and Regional offices, determined that moving forward with report recommendations 3.d and 4.c would be most appropriate at this time. This was based on the understanding that the current CCI program continues to provide some assessment value, and the additional effort necessary to make more substantial improvements to the program may not be worth the investment at this time. Staff plans to complete the necessary inspection guidance revisions in the next fiscal year. The remaining recommendations may be re-considered in the future, and the report and substantial supporting data remains available in ADAMS for consultation.

C. Regan 3

SUBJECT:

DISPOSITIONING OF CROSS-CUTTING ISSUES PROGRAM EFFECTIVENESS REVIEW RECOMMENDATIONS DATED SEPTEMBER 17, 2021 DISTRIBUTION:

CRegan AMasters AGarmoe ADAMS Accession Number: ML21209A993 *Via e-mail NRR-601 OFFICE NRR/DRO/IRAB NRR/DRO/IRAB NAME *AGarmoe *AMasters DATE 8/26/2021 9/17/2021 OFFICIAL RECORD COPY