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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

©2019 Nuclear Energy Institute 2 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 Overview

©2019 Nuclear Energy Institute 3 Areas of NRC & Industry Alignment Maintenance and Surveillance combined into Plant Ops FLEX hours recognize site-specific risk and performance NRC Staff Option 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for Plant Ops and Crit Safety for Cat III facilities Waste management merged with Environmental Protection and Transportation Triennial Fire Protection eliminated in lieu of biennial inspection

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

Recognition of a Decreased Risk Profile*

Mature Site-Specific Integrated Safety Analysis (ISA)

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

Consistent with NRC Staff Option 1 (FLEX concept)

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

BASIS OF INDUSTRY PROPOSAL 2

©2019 Nuclear Energy Institute 8 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 Context for Industry Proposal 2

©2019 Nuclear Energy Institute 9 Resident Inspector Performs Daily Observations, e.g., Plant Ops, Criticality, MC&A, Mods, Radiation Protection IMC 2600 says 797 Hours vs 1510 Direct Billable Hours Resident Inspector Assesses Licensees Actions to Resolve Issues and Items of More than Minor Safety Significance Category I Fuel Fabrication Facilities -

Inspector Scope Reduce Safety Operations from Proposed 180 Hours to 90 Hours Reduce MC&A annual to 90 Hours due to Low Risk and Historical Stable and Mature Programs Maintain Plant Ops and Fire Protection with the Resident as is currently implemented today

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

2 3

4

1) How licensees utilize ISAs to prevent and mitigate risk at the facilities, and

2) When evaluating and applying IP adjustments to reflect risk profile Numerical values of Likelihood are approximate orders of magnitude based on NRC-approved methodology Each IROFS is assigned a failure probability range in accordance with NRC-approved methodology Overall Likelihood is compared to applicable limit for corresponding consequence category, e.g., High, Intermediate, or Low Limit for high consequence event is typically 10-4

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 Industry Risk-Reduction Example 1 Additional barriers provided, thus reducing the risk well beyond requirements

©2019 Nuclear Energy Institute 13 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 Industry Risk-Reduction Example 2 This example of risk reduction could tolerate an administrative IROFS failure and still meet required performance criteria

©2019 Nuclear Energy Institute 14 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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