ML20065H300

March 5 Public Webinar Building a Smarter Fuel Cycle Inspection Program

ML20065H300
Person / Time
Issue date:	03/05/2020
From:	Office of Nuclear Material Safety and Safeguards
To:
Marcano-Lozada J
References
Download: ML20065H300 (24)

Text

Meeting Agenda

• Please mute your microphone and/or phone

• Please state your name and organization when speaking 1

Building a Smarter Fuel Cycle Inspection Program Jonathan Marcano, P.E.

NMSS/DFM March 5, 2020

Agenda

• Review approach and scope

• Results

- Assessment of inspection procedures (IPs) and inspection areas

- Decision-making methodology

- Recommendations

• Next Steps

• Questions 3

Review approach and scope

• Included all areas of safety and safeguards as referenced in Inspection Manual Chapter (IMC) 2600 and IMC 2683

• Excluded, physical protection, classified material and information security

• Stakeholder engagement

- Held 9 public meetings

- Proactive engagement with stakeholders

- Received multiple letters from NEI and UUSA 4

Results

• Gaps and Overlaps in current IPs

- No major gaps

- Increase sample and improve guidance for chemical safety

- Overlaps: Maintenance/Surveillance, Waste Management

• Areas of major interest

- Resident Inspector Program

- Leveraging the Integrated Safety Analysis (ISA)

- Corrective Action Program

- Flexibility of core inspection hours 5

Decision-making methodology

• Qualitative factors used for ranking risk importance of technical areas as Tier 1, Tier 2, Tier 3

- Integrated Safety Analysis

• Risk insights from accident sequences and consequences for each area

- Operating Experience

- Regulatory Requirements

- Reputational Risk 6

Decision-making methodology Accident Operating Regulatory Reputational Sequences Experience Requirements Risk Criticality High High Medium Low Chemistry High High Low Low Fire Medium Medium Medium High Environmental Low Low Low High Radiation Medium Low Low High Protection Transportation Low Low Medium Low Emergency Medium Medium Low Medium Preparedness Material Control &

N/A Medium High Low Accounting 7

Results of Ranking 8

Results of Ranking

• Tier 1

- Annual Frequency and minimum of 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />

- Benefit from team inspections

• Tier 2

- Biennial Frequency and minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />

- Benefit from team inspections

• Tier 3

- Triennial Frequency and minimum of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />

- Included range of hours (30 - 60)

• Corrective Action Program

- Frequency changes for some Tier 2 and Tier 3 inspection areas 9

Recommendations

• In-depth assessment of resident inspector IPs

• Increase effort on chemical safety

• Frequencies and resources

- Tier 1 areas - annual inspection frequency and a minimum of 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />.

- Tier 2 areas - biennial inspection frequency and a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.

- Tier 3 areas - triennial inspection frequency and a minimum of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (30-60) 10

Recommendations

• Frequency reduction for Tier 2 and Tier 3 areas for facilities with NRC-approved CAP

• Flexibility - allowed variance in core hours

• Incorporation of OpE and Self-assessments into program 11

Next Steps

• No decision has been made

• March 10, 2020: Regulatory Information Conference Session

• March 31, 2020: Issuance of report and final decision

• April-December 2020: Implementation of changes to inspection guidance

• January 2021: Implementation of inspections using updated inspection guidance 12

Questions 13

Working Group Proposed Recommendation 14

Working Group Proposed Recommendation 15

Working Group Proposed Recommendation 16

Appendix B - Current and Proposal 17

Building a Smarter Fuel Cycle Licensing Program Donnie Harrison NMSS/DFM March 5, 2020

Agenda

• Review approach and scope

• Results

- Recommendations

- Prioritization

• Next Steps

• Questions 19

Review approach and scope Objective: Identify areas that would improve the efficiency and effectiveness of the Fuel Cycle Licensing Program

• Working Group members from fuel cycle, spent fuel, and NRR

• Stakeholder engagement

- Held numerous public meetings

- Proactive engagement with internal and external stakeholders

- Received multiple letters: NEI and UUSA 20

Results 37 Suggestions

• Considered principles of good regulation (Openness, Clarity, Efficiency, Reliability, Independence)

• Considered additional working group insights

• Identified recommended actions to address suggestions

• Prioritized individual suggestions (using 3-step process)

- Recognize that many suggestions are inter-related and should be implemented together 21

Matrix of Suggestions High Priority Medium Priority Low Priority Focus Area Suggestions Suggestions Suggestions Guidance and 14, 15, 20, 23, 24, Tool 19, 31, 32 10, 16, 17 25a, 25b, 26, 30 Development Planning and 1, 2, 3, 4, 6a, 7b, 5, 28, 29 6b Processing 18, 27 Performance 7a, 8, 9a, 9b, 11, and 22 12, 13a, 13b, 21 Documentation 22

Next Steps

• Today: Collect any additional insights

• March 11, 2020: NRC RIC Session

• March 31, 2020: Issuance of final report

• April 15, 2020: Decision on recommended actions

• April 30, 2020: Develop integrated implementation plan for approved recommended actions

• May-December 2020: Implementation of approved near-term recommendations

• January 2021 and beyond: Implement longer-term recommendations consist with the implementation plan 23

Questions 24