ML19163A273
| ML19163A273 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/31/2019 |
| From: | Nuclear Energy Institute |
| To: | Mark King, Ladonna Suggs Office of Nuclear Material Safety and Safeguards, NRC/RGN-II |
| Marcano J | |
| References | |
| Download: ML19163A273 (10) | |
Text
Building Smarter NRC Inspection and Licensing Programs - Industrys Input and Perspectives NEI and its Fuel Cycle Facility Members NRC Public Meeting May 2019
© 2019 Nuclear Energy Institute
GUIDING PRINCIPLES 2
NRC Principles of Good Regulation SECY-18-0060 Achieving Modern Risk-Informed Regulation NMSS Dapas Memo Atomic Energy Act Reasonable Assurance of Adequate Protection
CURRENT REGULATORY PROGRAM IS NOT BROKEN 3
Robust Licensing Basis Mature ISAs Strong and Improving Industry Performance Over Decades Efficiencies Can Be Gained Benchmark with Others Strong Project Management to help Ensure Timely and Effective Resolution of Issues Staff and Management Turnover Pose Challenges Success of Our Efforts Must be Measurable Continuous Learning
END-STATE 4
Optimized Programs Lead to Reduced Resource Expenditures
3 CURRENT FOCUS AREAS - INSPECTION PROGRAM Area 1: Acknowledgement of Good Performance
- What does that mean?
- What criteria should be used to define it?
- e.g., sustained plant performance with no violations; self-identification
- How can License Performance Review process and findings be utilized in decision making?
- How does credit manifest itself? e.g.,
- Reduced scope or frequency of inspection or both? (NMSS procedures allow a 50% reduction in frequency for certain materials licensees)
- Reduced total number of hours 5
© 2019 Nuclear Energy Institute
INSPECTION PROGRAM Area 2: Optimizing Inspection Procedures
- In-depth review of baseline/core hours; re-assess regulatory basis for each
- Re-scope content, focus, priorities based on historical inspection findings, operational events & conditions, expert judgment, ensure inspection activities have a safety benefit, etc.
- Bundle more Inspection Procedures
- Conduct biennial EP inspection and biennial EP observed drill in alternating years
- Transfer additional IPs to Resident Inspectors at Category I facilities, e.g.,
Waste Management, Transportation, Maintenance/Surveillance
- Remove PI&R inspection for those with accepted CAP
- Credit for robust self-assessments or internal/external independent audits, e.g., DOE-Navy, NUPIC, corporate cyber 6
© 2019 Nuclear Energy Institute
INSPECTION PROGRAM Area 3: Managing Inspection Resources
- Preparation and Post Inspection Time: review of current practices; determine whether ratios are consistent among inspectors and appropriate for IP; establish maximum allowed; ensure appropriate scope for document requests
- Time on site: review of current IP hours; determine whether appropriate based on risk; establish maximum hours and allow for inspectors to reduce hours while on site if appropriate
- Travel Time and Related Costs -review of current practices; ensure travel time and related costs are efficient and cost effective e.g., inspection team members share rental cars 7
© 2019 Nuclear Energy Institute
3 CURRENT FOCUS AREAS - LICENSING PROGRAM
- Area 1: Requests for Additional Information
- Clear regulatory basis for each RAI documented
- Decision re: whether RAI issued in draft or final - pros/cons
- Limited number of rounds of RAIs
- Area 2: Licensing Milestones
- Solicit input from licensee and establish overall timeline that is documented on all licensing actions
- Solicit input from licensee re: milestones from when licensing action is accepted until a final licensing decision/amendment or license is issued which are provided to licensee/applicant 8
© 2019 Nuclear Energy Institute
LICENSING PROGRAM
- Area 3: Licensing Process
- Benchmark with other NRC regulatory programs could identify efficiencies and management tools to ensure continuity
- Renewals should focus only on areas of program change since licensees have living programs; diagnostic on past renewals
- Continuity of quality and efficiency of licensing process is maintained despite staff and/or management turnover
- Particularly challenging with protracted and more complex licensing actions - even more reason for established licensing milestones 9
© 2019 Nuclear Energy Institute
ENFORCEMENT PROGRAM EFFICIENCIES
- Does industry have suggestions for improvements to NRCs Enforcement Program or how it is implemented?
- Alternate Dispute Resolution
- All stakeholders must participate to avoid surprises
- Current Severity Level enforcement examples 10