ML18346A517
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| ML18346A517 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 12/12/2018 |
| From: | Gutherman B Nuclear Energy Institute |
| To: | Haile Lindsay NRC/NMSS/DSFM/IOB |
| Lindsay H | |
| Shared Package | |
| ML18338A059 | List:
|
| References | |
| Download: ML18346A517 (10) | |
Text
Brian Gutherman for the Nuclear Energy Institute NRC REG CON December 12, 2018 The Role of NEI 12-04 In Improving the Focus on Safety
NEI 12-04 Endorsement Status
- NEI 12-04, Revision 2 submitted to NRC in September 2018 Deletes appendices and modifies the document to remove references to those appendices Corrects a section numbering error
- Endorsement is expected via a revision to Regulatory Guide 3.72
- Draft RG summer 2019
- Licensees and CoC holders awaiting formal endorsement to incorporate the revised guidance into 72.48 training programs
Part of Broader Regulatory Improvements The value of 72.48 guidance is limited to the information not requiring NRC approval to change Graded approach project seeks to increase the 72.48 change scope based on safety and risk, akin to Part 50 TS improvement program Long term value depends on the NRC having confidence that industry 72.48 processes will consistently identify those issues requiring NRC approval NRC inspection and enforcement program visibility increases with increased industry responsibility
Accomplishments of NEI 12-04
- Distinguishes between specific licensees, general licensees, and CoC holders, where appropriate
- Identifies the 72.212 Report as a licensing basis document requiring review for proposed activities (RIS 2012-05)
- Addresses unique needs of CoC holders having 72.48 authority and no history of 50.59 authority
- Addresses general licensee - CoC holder interface GL processing of CoC holder changes Cask FSAR revision(s) of record for GLs
- Brings 72.48 guidance into alignment with 50.59 for changes involving Methods of Evaluation (MOE)
- Solidifies the basis for licensee and CoC holder training programs
Lessons Learned
- Enforcement actions of 2000s resulted in lingering confusion for both industry and NRC
- 50.59 guidance did not translate to 72.48 as directly as imagined for general licensees and CoC holders
- Industrys request for NRC endorsement could have been defined better
- Some enforcement actions were based on different industry and NRC understanding of the rule and guidance rather than mistakes
What is Expected of Industry?
- Understand that the need, appropriateness, and technical quality of changes is assured before the 72.48 review
- Implement a rigorous 72.48 training/qualification program
- Ensure 72.48 documentation matches the elements of the 72.48 guidance, especially MOE changes
- Frequently and critically review your 72.48 training and implementation programs (solicit outside feedback)
- Embrace conservative decision-making and questioning attitude
- Licensees should critically review CoC holder work
What is Expected of the NRC?
- Consistency among Regions and individual inspectors
- Risk-informed decision-making
- More 72.48 knowledge in the Regions to improve inspection process efficiency
- Hold industry accountable for the integrity of the process
What Does Success Look Like?
- Industry better understands the 72.48 rule and guidance evidenced by fewer mistakes
- NRC increases confidence in 72.48 implementation and allows more information to be under licensee/CoC holder change control
- Fewer 72.48 enforcement actions
The Bottom Line
- 1. 10 CFR 72.48 intends for the NRC to review changes having a nexus to the original safety basis with a focus on public health and safety
- 2. Updating the 72.48 implementation guidance was necessary but not sufficient for long-lasting regulatory process improvement
- 3. Right-sizing information in licenses and CoCs will put change control authority where it belongs and better focus resources on safety
Questions?
mar@nei.org gutherman@comcast.net