ML18214A432
| ML18214A432 | |
| Person / Time | |
|---|---|
| Issue date: | 08/09/2018 |
| From: | Hayes B NRC/NRO/DLSE |
| To: | |
| Hayes B | |
| Shared Package | |
| ML18214A427 | List: |
| References | |
| Download: ML18214A432 (24) | |
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PUBLIC MEETING NRO TRANSFORMATIVE ACTIVITIES: ENHANCING FOCUS ON SAFETY, SECURITY, RISK AND/OR ENVIRONMENTAL SIGNIFICANCE IN REVIEWS August 9, 2018 1:00PM - 4:00 PM Commissioners Hearing Room, HQ Office of New Reactors
NROs Transformative Activities: Enhancing Focus on Safety, Security, Risk, and/or Environmental Significance in Reviews Public Meeting - Category 3 PURPOSE: Broad engagement with stakeholders on recent and potential future transformative activities of the Office of New Reactors (NRO)
Agenda and slides:
https://www.nrc.gov/pmns/mtg?do=details&Code=20180761 Webinar: Please join from your computer, tablet or smartphone here:
https://global.gotomeeting.com/join/137286533 Phone: 877-917-1550, passcode 3718645#
Barbara Hayes; Barbara.Hayes@nrc.gov ; 301-415-7442 2
3 Opening Remarks (10 minutes)
F. Brown, NRO Session 1 (75 minutes)
Enhancing Licensing Tools and Processes:
R. Taylor, NRO Requests for Additional Information, Audits, and the SRP Advanced Reactors: Enabling the Safe and Secure Use of J. Monninger, NRO Nuclear Materials Rulemaking for Part 50/52 Alignment & Lessons Learned A. Bradford, NRO Break (15 minutes)
Session 2 (up to 70 minutes)
Registered Stakeholder Remarks (up to 5 minutes each plus Q&A)
Policy Issues Ed Lyman, Union for Concerned Scientists NEI perspective on Part 50/52 rulemaking Russ Bell, Nuclear Energy Institute Example approach to streamlining certification Mike Keller, Hybrid Power review for passive safety features on an advanced reactor Technologies, LLC Additional Stakeholder Remarks (up to 20 minutes)
Next steps and Closure (10 minutes)
F. Brown, NRO AGENDA
NROs Transformative Activities: Enhancing Focus on Safety, Security, Risk, and/or Environmental Significance in Reviews Enhancing Licensing Tools and Processes: Requests for Additional Information, Audits, and the Standard Review Plan Robert M. Taylor Director, Division of Licensing, Siting, and Environmental Analysis 4
Enhancing Licensing Tools and Processes:
Requests for Additional Information, Audits, and the SRP 5
Requests for Additional Information October 2016: NRO revised its internal process for preparing, reviewing, approving and issuing RAIs. An existing internal RAI Job Aid was updated to reflect lessons learned in previous reviews.
(See ML16278A574).
2018: NRO started an internal audit of RAIs Focused short term assessment of the quality of RAIs issued Only RAIs issued after October 2016 process changes May 2018: Based on the audits results, the audit team determined that revision of the RAI Office Instruction and Job Aid could be implemented immediately for near-term benefits.
July/August 2018: RAI procedures revised to reflect results of audit.
Enhancing Licensing Tools and Processes:
Requests for Additional Information, Audits, and the SRP 6
RAI Audit Methodology: A sample of 32 RAIs issued since October 2016 were independently rated by audit team members based on 6 attributes of high quality RAIs:
Necessity Is this RAI necessary (i.e., requested information is not located in the application, in other docketed material or could not be reasonably inferred by the staff without the licensees response)?
Technical Relevance Is the requested information technically relevant to the safety evaluation for a reasonable assurance finding (i.e., information is not just nice to know information)?
Regulatory Basis Is the regulatory basis and underlying guidance clearly stated in the body of the RAI?
Clarity Does the RAI clearly state what information is required or what information has been omitted or has been presented in an unclear fashion?
Conciseness Is the RAI written in a concise manner (i.e., does not contain unnecessary detail)?
Comprehensiveness Does the RAI ask the entire question or are there other subject matter for the same topic that should be considered, described and asked when formulating the question?
Enhancing Licensing Tools and Processes:
Requests for Additional Information, Audits, and the SRP 7
RAI Audit: Results and Actions Results: The RAIs sampled since the 2016 changes were of good quality based on the 6 attributes but some deficiencies were noted.
Finding: More consistent focus on 6 attributes of high quality RAIs via process changes can result in more consistent high quality RAIs Resulting actions: NRO processes have been changed as follows:
Revised internal approvals needed before an RAI is issued Review of each RAI against the 6 attributes as part of approvals Emphasis on ensuring RAIs clearly communicate the safety, security, risk and/or environmental significance.
Emphasis on using other tools to ascertain needed information before issuing RAI (e.g. teleconferences, audits, etc.)
NROs Office Instruction and NROs Job Aid are currently being updated to reflect revised internal approvals and new requirements for review against the 6 attributes
Enhancing Licensing Tools and Processes:
Requests for Additional Information, Audits, and the SRP 8
Regulatory Audits FY 2016 efforts included another initiative focused on audits.
October 2016: An Audit Job Aid was developed and distributed to staff (See ML16278A574).
2018: NRO will be assessing best practices and lessons learned from the Clinch River ESP review The overall review will be broken out by activities (pre-app, acceptance review, safety review, and environmental review phases)
The review will include quantitative and qualitative analysis Applicability to other license review processes (DC, COL) to be considered Completion envisioned in the fall of 2018 with subsequent communications and implementation of any resulting recommendations
Enhancing Licensing Tools and Processes:
Requests for Additional Information, Audits, and the SRP 9
Revisions to the Standard Review Plan Revisions to SRP sections underway provide opportunities to reinforce focus on reasonable assurance of adequate protection.
Key opportunity to focus guidance consistent with Commission policy on risk-informed, performance based regulation.
Current work on updating SRP 2.4 sections will serve as an example.
Staff looking to see how to apply concepts used in SRP 2.4 example to refocus other sections of the SRP.
Enhancing Licensing Tools and Processes:
Requests for Additional Information, Audits, and the SRP 10 SRP Section 2.4, Hydrology Concept Apply risk-informed, performance-based regulatory philosophy to SRP Update Results in shorter SER focused on principle factors contributing to risk at a given site and more efficient and effective NRC review Example 50.54(f) hydrology reviews focused on consequential flood-causing mechanisms SRP Update focuses the reviews on consequential flood-causing mechanisms Abridged review and documentation for mechanisms that do not contribute to risk Timeline FRN Notice soliciting public comments - September 2018 Public Meeting - Fall 2018 to request comments on new approach
NROs Transformative Activities: Enhancing Focus on Safety, Security, Risk, and/or Environmental Significance in Reviews Advanced Reactors: Enabling the Safe and Secure Use of Nuclear Materials John Monninger Director, Division of Safety Systems, Risk Assessment, and Advanced Reactors 11
Advanced Reactors: Risk-Informed and Performance-Based 12
- SECY-18-0060: Achieving Modern Risk-Informed Regulation
- An overarching theme that emerged from internal and external stakeholder outreach is the need for systematic and expanded use of risk and safety insights in decisionmaking. Out of this theme, the Team identified the need to appropriately scale the scope of review and level of detail needed from an applicant to enable the staff to make licensing decisions, consistent with the standard of reasonable assurance of adequate protection of public health and safety.
- Industry recommendation on the safety focus of new plant reviews
- NRC Principles of Good Regulation
Advanced Reactors: Regulatory Planning Framework 13
Advanced Reactors: How are we going to get there?
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- Paradigm shift
- Current regulations and guidance are LWR-centric
- Technology-inclusive, risk-informed, and performance based licensing approach
- Licensing modernization project
- Consideration of inherent safety characteristics, source term, safety margins
- Build from the enhanced safety focused review approach
- Integrated reviews using multi-disciplinary core review team
- Flexible review approaches and regulatory engagement plans
Advanced Reactors: Evaluating Potential Policy Issues 15
- Consequence based security
- Containment functional performance
- Siting
- Licensing modernization project
- Part 53 rulemaking
NROs Transformative Activities: Enhancing Focus on Safety, Security, Risk, and/or Environmental Significance in Reviews Rulemaking for Part 50/52 Alignment &
Lessons Learned Anna Bradford Deputy Director, Division of Licensing, Siting, and Environmental Analysis 16
Rulemaking for Part 50/52 Alignment & Lessons Learned SECY 15-002 (January 2015) outlined the staffs proposals and justifications for the Parts 50/52 Alignment & Lessons Learned Rulemaking.
- Improving Alignment Between New Reactor Licensing Processes
- New Reactor Licensing Lessons Learned
- Rulemaking Is the Best Approach to align New Reactor Licensing Process 17
Rulemaking for Part 50/52 Alignment & Lessons Learned Examples of issues expected to be in rulemaking
- Improving Alignment Between New Reactor Licensing Processes 10 CFR Part 52 Three Mile Island Requirements
- New Reactor Licensing Process Lessons Learned Review Clarify the requirements for application, review, and approval for renewal of a DC.
Examples of issues to be considered in rulemaking
- Clarifying 10 CFR 50.59 or similar regulations to better define scope and threshold for prior NRC approval
- Incorporation of Petition for Rulemaking regarding flexibility for COL holders to utilize 50.69 18
Rulemaking for Part 50/52 Alignment & Lessons Learned Where Do We Go from Here with the Parts 50/52 Alignment & Lessons Learned Rulemaking?
Incorporation of information developed to date Review of other petitions for rulemaking or policies that could be incorporated into the Part 50/52 rulemaking In FY19, staff develops the Rulemaking Plan and associated schedule Public engagement 19
NROs Transformative Activities: Enhancing Focus on Safety, Security, Risk, and/or Environmental Significance in Reviews Registered Stakeholder Remarks
Policy Issues Ed Lyman, Union of Concerned Scientists
NEI perspective on Part 50/52 rulemaking Russ Bell, Nuclear Energy Institute
Example approach to streamline in licensing Mike Keller, Hybrid Power certification for passive safety features on Technologies, LLC advanced reactors 20
Information for External Oral Comments by M. Keller of Hybrid Power Technologies LLC 21
Information for External Oral Comments by M. Keller of Hybrid Power Technologies LLC 22
NROs Transformative Activities: Enhancing Focus on Safety, Security, Risk, and/or Environmental Significance in Reviews Additional Stakeholder Remarks 23
NROs Transformative Activities: Enhancing Focus on Safety, Security, Risk, and/or Environmental Significance in Reviews Thank you!
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