ML18346A517

Presentation Slides: Gutherman - Regulatory Improvements - 72.48

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: ML18338A060 ML18338A063 ML18338A064 ML18338A065 ML18338A066 ML18338A067 ML18338A068 ML18338A069 ML18346A506 ML18346A511 ML18346A517 ML18346A519 ML18346A520 ML18346A523 ML18346A527 ML18346A528 ML18346A529 ML18346A530 ML18346A531 ML18346A532 ML18353A748 ML18353A749
References
Download: ML18346A517 (10)

Text

Brian Gutherman The Role of for the Nuclear Energy Institute NEI 12-04 In Improving the NRC REG CON December 12, 2018 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