ML23072A357
| ML23072A357 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/2023 |
| From: | Douglas Bollock NRC/NRR/DRO/IOEB |
| To: | Mark Franke, Ryan Lantz, Julio Lara, Samson Lee NRC/RGN-I/DORS, Division of Reactor Safety II, NRC/RGN-III/DORS, NRC/RGN-IV/DORS |
| References | |
| Download: ML23072A357 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 23, 2023 MEMORANDUM TO: Samuel Lee, Director Division of Operating Reactor Safety, Region I Mark Franke, Director Division of Reactor Safety, Region II Julio F. Lara, Director Division of Operating Reactor Safety, Region III Ryan E. Lantz, Director Division of Operating Reactor Safety, Region IV Signed by Felts, Russell FROM: Russell Felts, Director on 03/23/23 Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
ESTABLISHMENT OF COMMERCIAL GRADE DEDICATION INSPECTION AND AGE-RELATED DEGRADATION INSPECTION CROSS REGIONAL PANELS PURPOSE:
The purpose of this memorandum is to document the establishment of a Cross Regional Panel to promote consistent application and resolution of inspection findings and proposed enforcement action identified during inspections of licensee Commercial Grade Dedication (CGD) programs per U.S. Nuclear Regulatory Commission (NRC) inspection procedure 711111.21N.03, Commercial Grade Dedication and Age-Related Degradation (ARD) inspections under NRC inspection procedure 71111.21N.04, Age-Related Degradation.
BACKGROUND:
Beginning in calendar year 2023, the NRC will commence inspection of licensee CGD programs using NRC inspection procedure 711111.21N.03, which is an area that the NRC has not conducted focused inspection activities in several years. Then, beginning in July 2023, the NRC will commence inspection of licensee ARD programs using NRC inspection procedure 711111.21N.04. Because of the limited inspection experience in these areas and the lessons learned when implementing the Environmental Qualification and Power Operated Valve CONTACT: Douglas Bollock, NRR/DRO (301) 415-6609
S. Lee et.al 2 inspections, a Commercial Grade Dedication inspection Cross Regional Panel and an Age-Related Degradation inspection Cross Regional Panel, that consists of technical experts from the Office of Nuclear Reactor Regulation and Branch Chiefs from each regional office in the Division of Reactor Safety/Division of Reactor Operating Reactor Safety has been established to assist inspectors in the evaluation and assessment of potential inspection findings and enforcement actions from each inspection. Establishment of such panels has proven to be an effective approach to ensure inspection issues are evaluated in a consistent and timely manner across the four regional offices. This panel will follow the guidance outlined in a December 11, 2018, memorandum from Christopher Miller, Director, Division of Reactor Inspection and Regional Support to the Directors of the Division of Reactor Projects and Safety in the Regional Offices. (ML18232A192). Members of the panel are listed in Attachment (1) of this memo.
METHODOLOGY:
The CGD and ARD Cross Regional Panels will meet following the completion of each CGD or ARD inspection and review all inspection findings, including minor violations, and proposed enforcement actions identified during the conduct of inspection activities prior to the issuance of the subject inspection report. Although the frequency and length of the meetings will be determined by the Board Chairperson or their designee, it is recommended to expedite the meeting decision process and minimize discussion time that all proposed findings should be provided to board members several working days in advance of the meeting date.
Proposed findings can be viewed by board members using Reactor Program System (RPS) for the applicable inspection report under the Sites Directory or distributed to the board members following the guidance in the template included in Attachment 2. All performance issues, e.g.
those that have been identified at the inspection exit meeting as minor or more than minor must be documented in the template or RPS and discussed at the panel meeting. The template or RPS entry should be completed by a knowledgeable inspector or the inspection team leader.
The panel chair will facilitate the discussion and help the panel reach consensus on the final disposition of the issue of concern, performance deficiency, and inspection finding. Similar to Significance Determination Process/Enforcement Review Panels (SERPs) consensus decision-making, unanimous agreement of the cross-regional panel voting members is not needed to establish consensus; rather, a consensus decision is one in which all members at least generally accept the position, agreement, or decision reached. Each panel member may question or challenge any of the information and analyses presented. If consensus is not reached at the conclusion of the panel, the issue will be elevated by the regional branch chief responsible for the inspection, to a discussion with the decision makers (regional (Division of Reactor Safety)/(Division of Operating Reactor Safety) Division Directors or their designees, with the Division of Reactor Oversight Director/Deputy Director facilitating the decision making.
For potentially greater than green issues, the SERP process will be followed (IMC 609, , Significance and Enforcement Review Panel (SERP) Process). The panels decision will serve as the final minor/more-than-minor determination for these performance deficiencies.
Following the meeting, the lead inspector or inspection team leader will document the final findings in RPS and the inspection report in accordance with NRC policies and procedures. The CGD and ARD programmatic lead will document meeting minutes to capture final decisions made during the panel and save the minutes on a DRO SharePoint site.
S. Lee et.al 3 This CGD and ARD panels are intended to be temporary and can be disbanded once there is sufficient familiarity and consistency with how to disposition such inspection findings and issues(6 months to 1 year). This will be indicated when the panel provides little to no added value to the findings the inspectors have prepared. Disbanding of the panel will be at the discretion of the Director, Division of Reactor Oversight.
Enclosure:
- 1. Attachment 1
- 2. Attachment 2
S. Lee et.al 4
SUBJECT:
ESTABLISHMENT OF POWER-OPERATED VALVE CROSS REGIONAL PANEL Dated: March 23, 2023 DISTRIBUTION:
RidsNrrDro RidsRgn1MailCenter RidsRgn2MailCenter RidsRgn3MailCenter RidsRgn4MailCenter ADAMS Accession No. ML23072A357 NRR-106 OFFICE NRR/DRO/IRIB NRO/DRO/IRIB NRR/DRO NAME DBollock THipschman RFelts DATE 3/13/2023 3/20/2023 3/23/2023 OFFICIAL AGENCY RECORD
Attachment 1 Table 1: List of Participants Panel Member Role IRIB/IRAB Branch Chief or designee* * **Chair/Participant Regional DRS/DORS Branch Chief
- Participant responsible for inspection or designee*
Inspection Team Leader or inspector
- Presenter knowledgeable in the inspection and findings*
Other regional BCs and inspectors Observers/Participants Enforcement Representative, as needed Participant NRR technical leads for CGD, as needed Participant Regional Senior Reactor Analyst, as needed Participant Regional Counsel, as needed Participant
- required for quorum
- only one DRO BC is required Att 1-1
Attachment 2 Commercial Grade Dedication Panel Worksheet Note: RPS in lieu of this worksheet.
Date of Panel Inspection Date Licensee Exit Date Region Report Number Lead Inspector Performance deficiency (including regulation or standard not met)
Brief summary of the issue Minor/more-than-minor (including basis) and proposed significance Cross-cutting aspect and basis(optional)
Enforcement (if applicable)
Comments Att 2-1