ML19077A297
| ML19077A297 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 03/19/2019 |
| From: | Riti T Nuclear Energy Institute |
| To: | Division of Operating Reactor Licensing |
| Venkataraman B | |
| References | |
| Download: ML19077A297 (9) | |
Text
©2019 Nuclear Energy Institute Tim Riti Senior Project Manager, Regulatory Affairs Enhancements to the Task Interface Agreement Process March 19, 2019
©2019 Nuclear Energy Institute 2 Increase Process Rigidity Greater Emphasis on Backfit Include an Appeal Process Eliminate Pre-decisional Consideration Establish Exit Criteria for Low Safety Significance Issues TIA Process Enhancements
©2019 Nuclear Energy Institute 3 Screening Criteria for entry developed Licensee access to questions during initial development Defined communication requirements with the Licensee Licensee position captured during development of draft TIA Ensure engagement with DORL and OGC throughout, if licensing basis impacted Documentation and durability of decisions Specific criteria for engaging other offices Increase Process Rigidity
©2019 Nuclear Energy Institute 4 Use of staff positions and applicability to licensee must be clear Procedure requirements/details on when to conduct a backfit review throughout the process including the final outcome Ensure interpretations of licensing basis are considered for backfit Provision for CRGR review/engagement if requested by the Staff or Licensee Adherence to Backfit
©2019 Nuclear Energy Institute 5 Licensee should be afforded the right to appeal Opportunity for the Licensee to engage beyond fact check at the end of the process Include an Appeal Process
©2019 Nuclear Energy Institute 6 Process transparency and openness Should be considered an extension of inspection and/or review activity Ensure finalized TIA questions are provided to the Licensee to support increased engagement Eliminate Pre-decisional Consideration
©2019 Nuclear Energy Institute 7 An assessment of safety significance needs to occur prior to, and continuing throughout the TIA process Issues of sufficiently low safety significance should be dispositioned as requiring no further action on the part of the licensee or NRC The basis for decisions should be well-documented to ensure durable issue closure, as well as providing a basis to reexamine the issue if new or different information becomes available in the future Consistent with the Principles of Good Regulation Establish Exit Criteria for Low Safety Significance Issues
©2019 Nuclear Energy Institute 8 Initial focus of the low safety significance issue resolution (LSSIR) effort should be on the resolution of licensing basis questions that do not involve clear non-compliance with legally binding requirements (such questions may arise in various contexts)
Insights may yield efficiencies that also improves resolution of compliance issues TIAs often involve resolution of questions regarding the interpretation of the approved licensing basis stemming from lack of clarity, or other ambiguities As opposed to situations that involve clear non-compliance with legally binding requirements Establish criteria for assessing the safety-significance Establish Exit Criteria for Low Safety Significance Issues
©2019 Nuclear Energy Institute 9 We see a great opportunity to enhance the TIA process to make it more effective and efficient for both Staff and Licensees, ensuring the appropriate focus on safety.
Thank you for your consideration!
Summary