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Industry Input to Nrc'S Smarter Program for Fuel Cycle Facilities
	ML19214A262
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/08/2019
From:	Link B, Schlueter J; Nuclear Energy Institute
To:	; Office of Nuclear Material Safety and Safeguards
	JMarcano NMSS/FCSE/LOB 415.6731
References
	Download: ML19214A262 (27)
	v • d • e

Industry Input to NRCs Smarter Program for Fuel Cycle Facilities Bob Link, NEI Consultant Janet Schlueter, NEI August 8, 2019 at RII Office

Overview Inspection: Industry Bases, Justification for Modifications to Inspection Manual Chapter 2600, Appendix B, Table 1 (submitted to NRC 6/24/19; public meeting held 6/27/19), e.g.,

Revised Frequencies

Revised Hours

Integrated/Combined Inspection Procedures

Credit for Good Performance Licensing: Industry Suggested Efficiency Improvements in Licensing Process, e.g.,

Clear Bilateral Communication

Need for Licensing Review Milestones

Increased Use of Site Visits

INSPECTION PROGRAM Inspection Program Principles

Comprehensive NRC Oversight Program is Key Attribute of NRCs Principles of Good Regulation

Risk and Performance-Based Insights Justify Efficiencies to Current Core Program

Continued Use of Special or Reactive Inspections Potential Relevant Reactor Oversight Enhancements Ongoing

Operating Experience

Low Number* of Violations, e.g., zero in Environmental Program

Zero Escalated* (Level III or above) Violations in Fire Protection; Material, Control & Accounting (MC&A); Radiation Protection (RP);

Waste Management (WM); Transportation; Maintenance/Surveillance (M/S); and Permanent Plant Modifications (Mods)

Comprehensive Corrective Action Programs (CAPs)

Low Number* of Reportable Safety Significant Issues & Decreasing

Licensee Performance Reviews Show Improved Performance

Routine Use of Benchmarking, Sharing of Operational Experience

Based on Industry Review of Inspection Data for 2014-2018

Current Effective Licensee Programs

Mature & NRC-Accepted

Radiation Protection Integrated Safety Analysis

Criticality Safety (ISA) Programs

Physical Security, INFOSEC,

Reduced the Risk Profile Control of Classified Info of Operations

Plant Modifications

Strong Defense in Depth

Comprehensive and Formal

Comprehensive CAP Reporting, e.g., Incidents,

MC&A Results

Emergency Preparedness (EP)

Fire Protection

Chemical Safety

Fleet Risk Profile Low Risk Profile in Many Program or Functional Areas, e.g.,

RP - Low and Decreasing Doses to Worker & Public; Effective ALARA Programs*

MC&A - Low Strategic Significance for Category III Facilities Material

WM - Facilities Continue Reducing Production and Volume of Low-Level Radioactive Waste (LLW)

Transportation - Nuclear Industrys High Safety Record on Thousands of Shipments, e.g., LLW, nuclear fuel, sources NRR Staff Proposes to Retire ALARA IP and Reduce Frequency of RP IPs (71124) at Nuclear Power Plants Based on Performance and Risk

Deeper Dive on Industry Suggestions for Modifications to IMC 2600, Appendix B, Table 1 (6/24/2019 submittal to NRC)

Safety Operations

Combine Plant Ops (IP 88020) &

Reduce Frequency & Hours for Maintenance/Surveillance Criticality Safety to 2/yr for Cat I, (IP88025) & Reduce to 32 Hours 1/yr for Cat III; 128 & 32 Hours, Total to Reflect Integrated Respectively Licensee Programs

Remove/Reduce Overlaps: Sec

Delete Annual Fire Protection 02.01(b)(3) references Criticality, (IP88055) & Combine with Fire, & Radiation Safety Controls Triennial (IP88054) & Reduce to which overlap with IP88015 (Crit),

64 Hours Total IP88055 (Fire) and IP 88030 (Rad)

Safeguards

MC&A - 1 Annual Inspection for Cat I, Cat III, and Enrichment Facilities with 96, 32 and 32 Hours, Respectively

Mature Programs and Historical Good Performance

Physical Protection - IP 81700.02, .04, and .05 - 18 Hours, 32 Hours, and 64 Hours, Respectively - No Change to Frequency

Licensees Observe Experienced Inspectors Ability to Complete Module in Fewer Hours than Current IP Dictates

Fitness-for-Duty - IP 81700.08 Transferred to Resident Inspector Program

Classified Material Control and INFOSEC - IP 81820 Reduce Hours to Range of 48-96 Hours for Enrichment Facilities

Licensees Observe Experienced Inspectors Ability to Complete Module in Fewer Hours than Current IP Dictates

Radiological Controls Several Functional Areas Ripe for Efficiencies and Consolidation

Due to Very Low Risk Profiles; Ever Improving Performance, Low Doses/Discharges, Significantly Below Regulatory Limits

NRC Should Benchmark with Department of Transportation Combine RP, EP, WM and Transportation for Combined Biennial Inspection of 32 Hours:

RP - Very Low Risk; Low to Nonexistent Emissions; Oversight via Routine Required Reports

EP - Stable Programs; Very Low Releases (1-3% of regulatory limits); Oversight via Routine Required Reports

WM - Licensees Observe IP Successfully Performed in 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months or Less Due to Decreases in Onsite Waste Generation/Storage and Shipment

Transportation - Licensees Observe IP Successfully Performed in 10 Hours or Less; IP 86740.04 Estimates Onsite Hours can range from less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at materials licensee facilities.to more than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months at reactors.

Facility Support

Combine M/S (IP 88025) with Operational Safety (IP 88020)

Combine Annual EP (IP 88050) and Biennial EP (IP 88051) into 1 Biennial Inspection for a Total of 48 Hours

Mature & Stable Programs; Low Number of Cited Violations

Delete Plant Mods Annual (IP 88070) if Triennial (IP 88072) is Performed; After Complete Round of (IP 88072), determine if IP 88070 Needed or Some Combination of Two is Appropriate

Eliminate Overlaps/Redundancies:

Section 02.04 Review of Management Measures (IP 88020) &

Sections 02.01(b)(4) and 02.03(b)(1) both require Management Measures Verification

Facility Support (continued)

Eliminate Overlaps/Redundancies (continued):

Section 03.04 (d) - Adequate Periodic Testing (IP 88025) Section 02.02(b) Requires Exam of Surveillance Testing

Section 03.04(f) - Determine Identification of Issues and Entry into CAP Timely and Adequate - Most Licensees Have No License Requirement, Regulatory Basis Not Clear

Section 03.06 - Review of License Amendments and SERs, Verify 11 Listed Design Criteria Addressed; If Amendment Has Been Granted, These Verifications Have Been Done

Credit to Smarter Core for Good Performance

Concept for Credit to Smarter Core Program

Use Existing LPR Process to Assess & Evaluate Each Licensee in its Normal Cycle:

Determine Whether Credit Can Be Applied to Reduce Frequency and/or Duration of Smarter Core Program

During Each LPR Review, Staff Collects Performance Data to Include But Not Limited to:

Numbers of Violations, Reportable Events, and Both Self-Identified and Self-Revealing Safety or Security Events

Review to Include Inspection Results and Consider NRC Observations as Recorded

Concept for Credit to Smarter Core Program (cont)

If Available, Results of Self-Assessments and/or Independent Assessments Would be Considered

Regardless of Whether a CAP is NRC-Approved or Not, Inspectors May Consider CAP Strengths as Input to LPR

External Stakeholder Input Should be Considered

Examples of Criteria* for Determining Credit

No Escalated Violations (i.e., > SL III)

ISAs that Rely on Defense-in-Depth

Minor, Non-Cited or SL IV Violations (e.g., > 2 IROFS) in a Given Sequence Would Not Negatively Impact

Robust Management Measures Result Consideration of Credit if Licensee has in Available and Effective IROFS Comprehensive CAP

Effective Self or Independent

Reportable Events that Do Not Result Assessments Would be Additional in Significant Violations Would Not Bases for Consideration of Credit Negatively Impact Consideration of

Continued or Repetitive Periods of Credit Performance under LPR Resulting in

Low Doses, Low Number of an Area not Needing Improvement Contamination, WM or Transportation Events

Single, Stand-Alone Criteria

Suggested Credits to Smarter Core Program

Frequency of IP Would Be Reduced by 50% if:

2 or More Sequential LPRs With No Improvement Needed

Zero Significant Violations or Reportable Events in an Area

Credits in a Given Area Can Be Waived (i.e., Not Granted) if There is a Formally NRC-Identified Generic Safety or Security Concern Across the Industry

Credits Are Not Cumulative, i.e., Credits Must Be Earned Each LPR Period

Special and Reactive Inspections Are Independent of Any Granted Credits and Can Be Basis of Revocation of Any Credit

LICENSING PROGRAM Licensing Program Principles

Comprehensive NRC Licensing Program is Key Attribute of NRCs Principles of Good Regulation

Risk and Performance-Based Insights Justify Efficiencies to Current Practices

Current Licensing Process Works But Could be Improved by Additional, Timely and Effective Communication Including Expanded Use of Site Visits for Major Amendment, Renewal Reviews and Applications

Current Effective Licensee Programs Provide Transparent Basis for More Efficient and Effective Licensing Reviews

Suggested Licensing Program Improvements Increased Use of Routine Status Combine Acceptance and Approval Calls Between NRC and Licensee, (e.g., Current NRR biweekly calls on Topical Letters for Simple Actions, (e.g.,

Reports under NRC review) Approval of Surety Bonds)

Increased Use of Site Visits for Consider Calls and Issuance of More Complex Licensing Actions, Draft RAIs & Responses to Ensure Prior to and/or After Submittal, (e.g., Clear Communication and Reduce DFP) Likelihood of Multiple Rounds Establish Meaningful Licensing Positive Experiences with Milestones for Most Submittals to NMSS/DSFM Include All NRC Offices and Public Release of NRC Licensing Centers of Excellence Involved, Handbook (redacted?)

(e.g., not needed for actions requiring < 45 days)

Suggested Licensing Program Improvements (cont)

NRC Review of Renewal Applications Limited to Program Changes Since Last Renewal:

Current Approved License Provides Basis for Acceptance Review and Limited NRC Review

Licensee to Clearly Identify Program Changes Since Last Renewal in Application

No Review of a Specific Program Area if:

No Licensee Changes to a Stable Program Area, e.g., RP, EP, WM and Transportation

No New or Revised NRC Relevant Requirements CY2020: Holistic Review With Industry Input on Recent Renewals to Identify Lessons-Learned and Future Efficiency Gains

Conclusions

Licensees Agree that Comprehensive Oversight is Required and Desirable and More Efficient Licensing is Needed and Desirable

Licensees Remain Committed to Continuous Improvement Including Comprehensive and Effective CAPs, Benchmarking, Sharing of OE, Lessons-Learned, etc.

Significant Opportunities for NRC Program Efficiencies Exist While Continuing to Assure Adequate Protection Thank You!

Industry Suggested Smarter Core Submitted to NRC 6/24/2019

Industrys Smarter Core Program June 19

ML19214A262

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