SECY-18-0113, Presentation on the Withdrawal of Rop Secy Paper 18-0113 and Secy Paper 19-0067 - August 2021
| ML21236A306 | |
| Person / Time | |
|---|---|
| Issue date: | 08/25/2021 |
| From: | Kimyata Morgan-Butler NRC/NRR/DRO |
| To: | |
| Kimyata Morgan-Butler, NRR/DRO 415-0733 | |
| References | |
| SECY-18-0113, SECY-19-0067 | |
| Download: ML21236A306 (15) | |
Text
Withdrawal of SECY-18-0113 (Engineering Inspection) and SECY-19-0067 (ROP Enhancement)
Background
- On August 5, the Commission issued a staff requirements memorandum (SRM) on SECY-18-0013 and SECY-19-0067 which approved both staffs request to withdraw the papers
- Staffs intent is to evaluate the bases for the previous recommendations and re-engage internal and external stakeholders, including regional inspection staff, members of the public, and the nuclear industry, on the continued validity of these and any other proposed changes to the Reactor Oversight Process, as appropriate.
2
Staffs current strategy
- As deemed appropriate and following the evaluation of the updated basis for the recommendations which require commission approval, the staff will consider using one or more Commission papers (Notation Vote Papers).
- Staff does not intend to address items below in those papers:
- Items completed (e.g., revisions to inspection procedures and inspection manual chapters)
- Items no longer being pursued (e.g., licensee self-assessments)
- Items not requiring Commission approval per management Directive 8.13, Reactor Oversight Process 3
SECY-18-0113 Original Recommendations
- Develop a Combined Engineering Team Inspection (CETI) which combine Design Basis Assurance Inspection (DBAI) - Teams Inspection (21.M), 50.59, and heat sink procedures
- Recommend a 4-year engineering inspection cycle (with options of a 3-year or 5-year cycle)
- Licensees receive one engineering inspection each year during the cycle. The CETI, and a Focused Engineering Inspection (FEI) (previously 21.N DBAI (program) inspection), with Fire Protection being one of the FEIs.
- Staff consider if Licensee Self-Assessments can be used in-lieu of one of the FEIs per cycle.
5
ROP Engineering SECY 18-0113 Recommendation Factors to Consider Proposed MD 8.13 Requirement (recent experience, (Commission approval, notification, pandemic lessons learned, or none) stakeholder feedback, etc.)
Recommendations Requiring Commission Approval to Move Forward 4 Year Engineering Inspection Evaluate additional 2 years Commission Approval Cycle of engineering inspection experience Recommendations Requiring Commission Notification to Move Forward Focused Engineering Inspections Evaluate the effects and Commission Notification (FEI) timing of the next inspection cycle CETI (Combined Engineering Evaluate the effects and Commission Notification Team Inspection) timing of the next inspection cycle Recommendation No Longer Being Pursued by Staff Licensee Self-Assessment Staff and industry no longer None - staff provided Commission supporting notification that staff would no longer pursue 6
SECY-19-0067 Original Recommendations
- Eliminate the four-quarter requirements for GTG inspection findings to remain open and instead close them upon completion of the supplemental inspection
- Revise the treatment of GTG PIs in the Action Matrix to be consistent with GTG findings by remaining a GTG input until supplemental inspection completion
- Revise sample sizes and resource estimates for baseline inspection procedures
- Revise PI&R inspection frequency from biennial to triennial
- Revise EP SDP to limit potential GTG findings to only planning standard functions that can impact public health and safety
- Revise the Enforcement Policy to support implementation of revised labels/descriptors for White and Yellow assessment inputs 8
SECY-19-0067 Original Additional Activities Already Completed By Staff
- Commission Notification:
- Eliminate redundant Summer Readiness sample from IP 71111.01, Adverse Weather Protections
- Other items discussed in SECY-19-0067:
- OPA reinforcement of existing guidance on press releases for White findings
- Revise IP 95001 to clarify expectations related to inspection of causal evaluations
- Clarify guidance in IMC 2515 related to modifications to inspection resource estimates
- Revise SDP for beyond-design-basis events
- Incorporate lessons learned and program efficiencies into Security baseline inspections
- Evaluate ISFSI inspection program and make appropriate changes 9
ROP Enhancement SECY 19-0067 Recommendation Factors to Consider Proposed MD 8.13 Requirement (recent experience, pandemic (Commission approval, notification, or none) lessons learned, stakeholder feedback, etc.)
Recommendations Requiring Commission Approval to Move Forward EP SDP revisions Evaluate if any changes to the Commission Approval original EP assessment are necessary Treat GTG PIs Evaluate if any changes to our Commission Approval consistent with assessment of consistency GTG findings between PIs and findings occurred Remove 4-quarter Evaluate if there are any Commission Approval requirement changes to the original assessment of early closeout of GTG findings Revise biennial Evaluate results of recently Commission Approval PI&R to triennial completed PI&R review and its effect on frequency, if any Revise description Evaluate if any changes to the Commission Approval of White and original pros and cons for the Yellow Inputs changes to the Enforcement Policy are necessary 10
ROP Enhancement SECY 19-0067 Recommendation Factors to Consider Proposed MD 8.13 Requirement (recent experience, pandemic (Commission approval, notification, or lessons learned, stakeholder none) feedback, etc.)
Recommendations Requiring Commission Notification to Move Forward Revisions to sample Evaluate additional 2 years of ROP Commission Notification sizes and resources experience and recent and for several baseline pandemic experiences inspection procedures 11
Other Recommendations Recommendation Factors to Consider Proposed MD 8.13 Requirement (recent experience, pandemic lessons (Commission approval, notification, or none) learned, stakeholder feedback, etc.)
Eliminate redundant Summer Complete Formal approval/notification not necessary Readiness sample from IP 71111.01, Adverse Weather Protections Press releases for White findings Complete - OPA reinforced existing Formal approval/notification not necessary guidance with public affairs officers IP 95001 minor revisions Complete - revised IP 95001 issued to Formal approval/notification not necessary clarify expectations related to inspection of causal evaluations Clarify guidance in IMC 2515 related to Complete Formal approval/notification not necessary modifications to inspection resource estimates Revise SDP for beyond-design-basis Complete Formal approval/notification not necessary events in IMC 0609, Appendix O Incorporate lessons learned and Review complete and changes Formal approval/notification not necessary program efficiencies into Security Implemented baseline inspections Evaluate ISFSI inspection program and Review complete and changes Formal approval/notification not necessary make appropriate changes implemented Revise requirement to notify Governors Evaluate the appropriate language to Formal approval/notification not necessary of transition to Column address during the next guidance revision 2 using established protocols 12
- Staff completed a Problem Identification and Resolution (PI&R) comprehensive review in (ML20274A133)
- PI&R report recommendations and management disposition:
- Several options to enhance IP 71152 were proposed.
- NRC decided to implement Option 1 (Current Inspection Requirements with Small Enhancements) and Option 3 (Qualitative Evaluation of PI&R Areas).
- Staff completed the CCI effectiveness review report recommendations and management disposition (ML20239A806)
- WG Recommendations Approved to Move Forward:
- Provide more detailed discussion of CCI insights and decisions in assessment letters.
- CCI follow-up could be scoped into an existing planned supplemental inspection.
13
Near-term Path Forward
- Staff is evaluating the bases of the recommendations presented in the withdrawn Commission papers.
- Staff will seek internal and external stakeholder feedback. Will discuss timeline in a future ROP Monthly meeting:
- New information to be considered, if needed, to update the bases
- Perspectives on relative importance/impact of the recommendations 14
Questions?
15