ML20297A253
| 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===
- 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 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.
- 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
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:
More detailed discussion in Timing of follow-up based on
- Use nine safety culture traits assessment letters licensee readiness (preferred)
Leverage planned 9500x if
- Use three cross-cutting areas available Cannot close CCI based solely on reduction in findings
Questions