Text

Industry Input to NRCs 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

©2019 Nuclear Energy Institute 2 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 Overview

INSPECTION PROGRAM

©2019 Nuclear Energy Institute 4 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 Inspection Program Principles

©2019 Nuclear Energy Institute 5 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 Operating Experience

©2019 Nuclear Energy Institute 6 Mature & NRC-Accepted Integrated Safety Analysis (ISA) Programs Reduced the Risk Profile of Operations Strong Defense in Depth Comprehensive CAP MC&A Emergency Preparedness (EP)

Current Effective Licensee Programs Radiation Protection Criticality Safety Physical Security, INFOSEC, Control of Classified Info Plant Modifications Comprehensive and Formal Reporting, e.g., Incidents, Results Fire Protection Chemical Safety

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 Fleet Risk Profile

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

Maintenance/Surveillance (IP88025) & Reduce to 32 Hours Total to Reflect Integrated Licensee Programs Delete Annual Fire Protection (IP88055) & Combine with Triennial (IP88054) & Reduce to 64 Hours Total Safety Operations Reduce Frequency & Hours for Criticality Safety to 2/yr for Cat I, 1/yr for Cat III; 128 & 32 Hours, Respectively Remove/Reduce Overlaps: Sec 02.01(b)(3) references Criticality, Fire, & Radiation Safety Controls which overlap with IP88015 (Crit),

IP88055 (Fire) and IP 88030 (Rad)

©2019 Nuclear Energy Institute 10 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 Safeguards

©2019 Nuclear Energy Institute 11 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.

Radiological Controls

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

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 Facility Support (continued)

Credit to Smarter Core for Good Performance

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

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 Concept for Credit to Smarter Core Program (cont)

Minor, Non-Cited or SL IV Violations Would Not Negatively Impact Consideration of Credit if Licensee has Comprehensive CAP Reportable Events that Do Not Result in Significant Violations Would Not Negatively Impact Consideration of Credit Low Doses, Low Number of Contamination, WM or Transportation Events Examples of Criteria* for Determining Credit ISAs that Rely on Defense-in-Depth (e.g., > 2 IROFS) in a Given Sequence Robust Management Measures Result in Available and Effective IROFS Effective Self or Independent Assessments Would be Additional Bases for Consideration of Credit Continued or Repetitive Periods of Performance under LPR Resulting in an Area not Needing Improvement

Single, Stand-Alone Criteria

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 Suggested Credits to Smarter Core Program

LICENSING PROGRAM

©2019 Nuclear Energy Institute 20 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 Licensing Program Principles

©2019 Nuclear Energy Institute 21 Suggested Licensing Program Improvements Increased Use of Routine Status Calls Between NRC and Licensee, (e.g., Current NRR biweekly calls on Topical Reports under NRC review)

Increased Use of Site Visits for More Complex Licensing Actions, Prior to and/or After Submittal, (e.g.,

DFP)

Establish Meaningful Licensing Milestones for Most Submittals to Include All NRC Offices and Centers of Excellence Involved, (e.g., not needed for actions requiring < 45 days)

Combine Acceptance and Approval Letters for Simple Actions, (e.g.,

Approval of Surety Bonds)

Consider Calls and Issuance of Draft RAIs & Responses to Ensure Clear Communication and Reduce Likelihood of Multiple Rounds Positive Experiences with NMSS/DSFM Public Release of NRC Licensing Handbook (redacted?)

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 Suggested Licensing Program Improvements (cont)

©2019 Nuclear Energy Institute 23 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!

Conclusions

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

ML19214A262

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