ML20297A253: Difference between revisions

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Review Objectives
Review Objectives
* Information and data considered:
* Information and data considered:
  - CCI program objective, history, and guidance
- CCI program objective, history, and guidance
  - CCI program and plant assessment data, including all aspects assigned since 2006
- CCI program and plant assessment data, including all aspects assigned since 2006
  - Principles of Good Regulation
- Principles of Good Regulation
* Main components of data review:
* Main components of data review:
  - Did the program identify plants that actually had concerns in cross-cutting areas?
- Did the program identify plants that actually had concerns in cross-cutting areas?
  - Were plants that exhibited performance concerns identified by the program and should they have been?
- Were plants that exhibited performance concerns identified by the program and should they have been?
  - Is there a relationship between program insights and performance?
- Is there a relationship between program insights and performance?


Review Conclusions Changes made in 2015 resulted in a program that while still providing some encouragement to monitor cross cutting aspects, may be less responsive to cross-cutting behavior indicators, may provide only limited communication about cross-cutting themes, and introduced concerns about whether the program would proactively identify cross-cutting concerns consistent with the program objective.
Review Conclusions
* Changes made in 2015 resulted in a program that appears to be less responsive to cross-cutting behavior indicators
* Changes made in 2015 resulted in a program that appears to be less responsive to cross-cutting behavior indicators
* Introduced concerns about whether the program would proactively identify cross-cutting concerns consistent with the program objective
* Introduced concerns about whether the program would proactively identify cross-cutting concerns consistent with the program objective
* Review of seven Column 4 and recent outlier plants found the current program would not have opened a CCI in any case prior to performance decline
* Review of seven Column 4 and recent outlier plants found the current program would not have opened a CCI in any case prior to performance decline
* There is a predictive relationship between increasing numbers of cross-cutting aspects and future movement in the Action Matrix or future occurrence of precursor events
* There is a predictive relationship between increasing numbers of cross-cutting aspects and future movement in the Action Matrix or future occurrence of precursor events Changes made in 2015 resulted in a program that while still providing some encouragement to monitor cross cutting aspects, may be less responsive to cross-cutting behavior indicators, may provide only limited communication about cross-cutting themes, and introduced concerns about whether the program would proactively identify cross-cutting concerns consistent with the program objective.


Review Recommendations
Review Recommendations
* Final report available in ADAMS Package ML20239A806 Monitoring for CCIs             Identification of a CCI         Follow-up of a CCI Simplify the assignment and       Eliminate the three assessment Pre-establish follow-up guidance trending of cross-cutting aspects period waiting time            and objectives in baseline IP via one of two options:
* Final report available in ADAMS Package ML20239A806 Monitoring for CCIs Identification of a CCI Follow-up of a CCI Simplify the assignment and trending of cross-cutting aspects via one of two options:
More detailed discussion in   Timing of follow-up based on
Use nine safety culture traits (preferred)
* Use nine safety culture traits  assessment letters            licensee readiness (preferred)
Use three cross-cutting areas Eliminate the three assessment period waiting time More detailed discussion in assessment letters Pre-establish follow-up guidance and objectives in baseline IP Timing of follow-up based on licensee readiness Leverage planned 9500x if available Cannot close CCI based solely on reduction in findings
Leverage planned 9500x if
* Use three cross-cutting areas                                  available Cannot close CCI based solely on reduction in findings


Questions}}
Questions}}

Latest revision as of 14:55, 29 November 2024

Cross-Cutting Issues Program Effectiveness Review
ML20297A253
Person / Time
Issue date: 10/28/2020
From: Garman D
NRC/NRR/DRO/IRAB
To:
Alex Garmoe, NRR/DRO/IRAB, 415-3814
References
Download: ML20297A253 (6)


Text

Cross-Cutting Issues Program Effectiveness Review October 28, 2020 ROP Public Meeting Alex Garmoe Office of Nuclear Reactor Regulation Division of Reactor Oversight 1

=

Background===

  • Annual effectiveness reviews are a part of the IMC 0307 ROP self-assessment process
  • Several of the 99 ROP Enhancement recommendations suggested reviewing, revising, or eliminating the CCI program
  • CCI program was due for an effectiveness review of significant program changes implemented in 2015
  • An effectiveness review could address both the ROP self-assessment and the ROP Enhancement recommendations

Review Objectives

  • Information and data considered:

- CCI program objective, history, and guidance

- CCI program and plant assessment data, including all aspects assigned since 2006

- Principles of Good Regulation

  • Main components of data review:

- Did the program identify plants that actually had concerns in cross-cutting areas?

- Were plants that exhibited performance concerns identified by the program and should they have been?

- Is there a relationship between program insights and performance?

Review Conclusions

  • Changes made in 2015 resulted in a program that appears to be less responsive to cross-cutting behavior indicators
  • Introduced concerns about whether the program would proactively identify cross-cutting concerns consistent with the program objective
  • Review of seven Column 4 and recent outlier plants found the current program would not have opened a CCI in any case prior to performance decline
  • There is a predictive relationship between increasing numbers of cross-cutting aspects and future movement in the Action Matrix or future occurrence of precursor events Changes made in 2015 resulted in a program that while still providing some encouragement to monitor cross cutting aspects, may be less responsive to cross-cutting behavior indicators, may provide only limited communication about cross-cutting themes, and introduced concerns about whether the program would proactively identify cross-cutting concerns consistent with the program objective.

Review Recommendations

  • Final report available in ADAMS Package ML20239A806 Monitoring for CCIs Identification of a CCI Follow-up of a CCI Simplify the assignment and trending of cross-cutting aspects via one of two options:

Use nine safety culture traits (preferred)

Use three cross-cutting areas Eliminate the three assessment period waiting time More detailed discussion in assessment letters Pre-establish follow-up guidance and objectives in baseline IP Timing of follow-up based on licensee readiness Leverage planned 9500x if available Cannot close CCI based solely on reduction in findings

Questions