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Industry Proposal 2 Smarter Program for Fuel Cycle Facilities
	ML19312A886
Person / Time
Site:	Nuclear Energy Institute
Issue date:	11/08/2019
From:	Link B, Schlueter J; Nuclear Energy Institute
To:	; Office of Nuclear Material Safety and Safeguards
	Cuadrado-Caraballo L
References
	Download: ML19312A886 (19)
	v • d • e

Industry Proposal 2 Smarter Program for Fuel Cycle Facilities Bob Link, NEI Consultant Janet Schlueter, NEI November 15, 2019 at NRC

Overview

Areas of NRC and Industry Alignment

Industry Proposal 2 -FLEX hours for decreased risk profile

Cat I Resident Inspector considerations

Licensee Performance Review (LPR) process

Two risk-reduction examples used to identify and focus risk-informed adjustments to inspection program

Additional Smarter Programs issues needing resolution

Areas of NRC & Industry Alignment Maintenance FLEX hours and recognize site-Surveillance specific risk and combined into performance Plant Ops NRC Staff Waste Option 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> management for Plant Ops merged with and Crit Safety Environmental for Cat III Protection and facilities Transportation Triennial Fire Protection eliminated in lieu of biennial inspection

Industry Proposal 2 =

Hybrid of NRC Staff Options 1&2 and Industrys Proposal 1

Recognition of a Decreased Risk Profile*

Effective CAP Mature Site-Specific Integrated Safety Analysis (ISA)

Demonstrated Safe Operations - e.g., low number of significant violations and events

Current Decreased Risk Profile of Fleet

Consistent with NRC Provides incentive to Staff Option 1 ATTAIN and MAINTAIN (FLEX concept) extra margin FLEX Recognizes extra margin Defined range of Hours for already built into ISAs adjustment by facility Decreased and operations Risk Profile Recommend 20% range Maintains core to assure for each IP adequate protection

BASIS OF INDUSTRY PROPOSAL 2 Context for Industry Proposal 2

Industry Concerns with Lack of Predictability and Risk Basis for Staff Option 1, e.g., large pool of FLEX hours, lack of detail on Comprehensive 5-year review

Hybrid Proposal Utilizes Best Features of Earlier Options and Proposal 1, e.g.,

Concept of FLEX Hours, Reduced Inspection Hours for Support Areas; While Efficiently Utilizing NRC and Industry Resources

Industry Proposal 2 is Earnest Attempt at Convergence and Focus on Safety Significant Programs

Category I Fuel Fabrication Facilities -

Inspector Scope

Resident Inspector Performs

Reduce Safety Operations from Daily Observations, e.g., Plant Proposed 180 Hours to 90 Hours Ops, Criticality, MC&A, Mods, Radiation Protection

Reduce MC&A annual to 90 Hours

IMC 2600 says 797 Hours vs due to Low Risk and Historical 1510 Direct Billable Hours Stable and Mature Programs

Resident Inspector Assesses

Maintain Plant Ops and Fire Licensees Actions to Resolve Protection with the Resident as is Issues and Items of More than currently implemented today Minor Safety Significance

Licensee Performance Review Process Used to Inform Inspection Program Adjustments:

1 Use of Living ISAs to Periodically Assess Risk Profiles and Safety Margins 2 Insights on effectiveness of CAP 3 Creates Basis on a Continuing Review to Adjust Program Within FLEX Range of Inspection Hours 4 Additional Means of Oversight Continue as Tool to Further Provide Reasonable Assurance of Adequate Protection

Overview of Two Industry Risk-Reduction Examples Examples help demonstrate Each IROFS is assigned a failure potential use of site-specific ISAs: probability range in accordance with NRC-approved methodology

1) How licensees utilize ISAs to prevent and mitigate risk at the facilities, and Overall Likelihood is compared to

2) When evaluating and applying IP applicable limit for corresponding adjustments to reflect risk profile consequence category, e.g., High, Intermediate, or Low Numerical values of Likelihood are approximate orders of Limit for high consequence event is magnitude based on NRC- typically 10-4 approved methodology

Industry Risk-Reduction Example 1 Moderator Release onto Process Equipment (Press)

Sequence has 4 IROFS - 2 Active Engineered Controls; 1 Administrative Control; 1 Passive Engineered Control

These IROFS provide a total of 10-8 failure probability

This is 4 orders of magnitude greater than the regulatory required performance criteria of 10-4 for high consequence event Additional barriers provided, thus reducing the risk well beyond requirements

Industry Risk-Reduction Example 2 Moderator Spill Into Vacuum Cleaner

Sequence has 3 IROFS - 1 Passive Engineered Control; 2 Administrative Controls

These IROFS provide a total of 10-7 failure probability

This is 3 orders of magnitude greater than the regulatory required performance criteria of 10-4 for high consequence event This example of risk reduction could tolerate an administrative IROFS failure and still meet required performance criteria

Additional Smarter Program Issues Needing Resolution Make transparent the NRC self assessments and analyses conducted in conjunction with the Smarter Programs initiative Address IP overlaps and redundancies highlighted by industry Address efficiency concerns over inspection prep, doc, etc Resolve inconsistencies between NRC Options 1 and 2 Consider altering (extending) timelines as dictated by current WG Charters Integrate efforts and results of parallel ISFSI Enhancement Team

Industry Proposal 2 (Submitted to NRC 10/15/2019)

ML19312A886

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