ML19143A158
| ML19143A158 | |
| Person / Time | |
|---|---|
| Issue date: | 05/29/2019 |
| From: | Carleen Parker Plant Licensing Branch 1 |
| To: | |
| Parker C, NRR/DORL/LPL1 | |
| References | |
| L-2019-PMP-0002 | |
| Download: ML19143A158 (11) | |
Text
Current Status of Low Safety Significant Issue Resolution (LSSIR)Office of Nuclear Reactor RegulationPublic MeetingMay 29, 2019Tim Reed, Office of Nuclear Reactor Regulation Presentation PurposeProvide current status of LSSIR effort and draft working group recommendations 2
Background
- LSSIR W look ed at previous tasks t o identifyunderlyin g root c aus e themes*ntent was t o:-Identify i n current processes w here enhancements could be made, and-Identify a ny new processes t hat might mitigate these situations
- The themes correlat ed wit h the time period:
- eflect the mindset pr ior t o recent ef forts to enhance backfitpolicy an d guidance*The followi ng ar e draft r ecommendations int ended to address t he major areas 3 Inspection Manual Chapter Low safety significant (LSS) i ssue c an be address ed in current i nspection guidance, but t here is a tendency to drive issues to closur e even i n view of t he low s afety significanc e and high resource expenditure*T he WG concludes that the most ef ficient means f or addr essi ng LSS i ssues arisi ng is ear lyon, duri ng inspection
- IMC could be revised t o enhance issue
s c r eeni ng and support doc umentationfor LS S i s sues (under the constraints below)*Thes e enhancements to the IMC w oul d be to provi de an improv ed structure to support c losure of LSS issues w her e t he followi ng exists:-The li censee concl udes it i s notwithi n the licensi ng basis (LB)
-The NRC, after a nominal ef fort, has not pr oduced fact s that disput e the licensee's c onclusion on it s LB-The NRC determi nes the safety signifi cance is low-T he NRC determi nes additional r esour ces will not be ex pended to continue to challenge
t he licensee's conclusion (i.e., N RC determines it i s better t o focus resources on m ores afety si gnificant activities)
-The facility can be left "as is" (observati ons to be provided to t he li censee for its discretion
to address)
-The NRC can document closur e of the LSS i ssue 4 Licensing ReviewLSS issues arise during licensing reviews both in terms of the LB and in terms of requested forward fits:
- Issues hav e aris en duri ng reviews concerni ng the adequacy of the LB:-Such i ssues woul d be addr essed in a similar m anner as envisioned for t he IMC*Ther e is also potential t o enhanc e and improve NRC
procedures t hatgovern (but not limited to) license amendment r eviews t o address"for war d fits"*Most i ssues t hat ar is e duri ng licensi ng reviews are "forwar d fit" situations
-Thi s i s wher e the NRC want s to condition its approval o n the licensee upgrading its approach t o addressing a requirement
-B y its natur e forward fit s are clearly outsi de t he existi ng LB-Use of LS SIR in thi s context w oul d be to assist in more efficiently addressi ng "forward fits" from a safety si gnifi cance perspective
-For ex ample: If it can be readily determi ned that ther e is littl e to no safety or security enhancement associat ed wit h the forward fit, the staff woul d not pur sue it*Final MD 8.4 may impact t his s o use of LS SIR f or f orwar d fits depends on thefina l MD 8.4 (NRC ackfittingpolicy)5 Backfittingand Licensing Basis A them e for previous issues was the evidence of the pre-2 017 mindset for backfittingincludi ng consideration of the licensi ng basis in that context:
- Ongoi ng efforts to update and enhance the backfittingpolicy andguidance, s uppor ted with training for N RC staff andmanagem ent ha been beneficial for addressing LSSIR
-Previous traini ng occurred i n lat e 2017 ("res et") and i n mi d2018("workshop" training) and incl uded bot h backfittingand licensingbas is-Followi ng issuanc e of final MD 8.4 and revis ed NUREG-14 09longerterm traini ng (permanent) will be put int o place*The WG ex pects that these changes and the associ ated longerterm training will c ontinue to benefit the efforts to address LS Sissues 6 Safety Significance Determination
-General Tenets of Development
- Rely o n the well-e stablishe d principles o fintegrated decisionmaking*Drive an integr ated team approach*Be flexible enough to handle different s ituations*Allow use of di fferent existingtools/approaches
- Let t he circum stances and the team's expertisedictate the best c ombination of a pproaches*Get t o a well-f ounde d determ ination at areasonable levelofeffort 7 7 W orksheet low ollows IDM principles 8 8DRAFT CONCEPT Each IDM principle has a menu of approaches 9 9DRAFT CONCEPT
-All details are preliminary 1 2 3 4 Other Enhancements
- T IA effort will be discuss ed this afternoon:
-Inc ludes the LSSIR appr oac h as par t of the new process*Improv ed dec is i onmaking:-Th theme that c ontribut ed to a lack of t imely decisions-E fforts are underway t o improve decisi onmaking (includi ng bot h risk-inform ed decis i onmak i ng and addressi ng a r ange of v iews)-Thes e efforts will benefit al l agency activities but should be particularlybenefic ial for t he complex and often challengi ng issues typicallyencounter ed i n backfitand licensi ng basis*Conformi ng changes t o t he Enforcement Manual (as nec essary):-If needed these changes woul d provi de greater clarity to supportdispos iti on of LS S i ssues w ithi n traditional enforcement
- T raini ng for staff and management (i.e., bey ond backfittingandlicensi ng bas is):-Tr aini ng of staff and management to implement LSSIR*Organiz ational expectations