ML20099A149

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Recommendation II_1 (Categoryii) Rirp for Grading Reviews
ML20099A149
Person / Time
Issue date: 04/08/2020
From: Paul Kallan
NRC/NRR/DNRL/NRLB
To:
Kallan P
References
I-20-05
Download: ML20099A149 (2)


Text

SPENT FUEL STORAGE AND TRANSPORTATION ISSUE RESOLUTION PLAN Issue Number: I-20-05 Performance Margins Recommendation: II-1 (Cat 2)

Rev. 3.26.2020 Note: This document is DRAFT and the positions noted therein are preliminary NRC staff positions. This DRAFT is being made publicly available to support discussions at an April 2020 public workshop.

Title:

Develop acceptance review grading process that would assign varying levels of review to an application based on risk insights.

I. Summary of Resolution Plan The NRC staff is evaluating an industry recommendation, Recommendation II-1 in the Nuclear Energy Institutes (NEIs) Spent Fuel Performance Margin White Paper Agencywide Documents Access and Management System (ADAMS) Accession No. ML19318D971), where licensing applications would be assigned varying levels of review depending on risk insights. This recommendation to grade licensing applications would require NRC to develop an internal review guidance.

Prior to receiving NEIs Spent Fuel Performance Margin White Paper, NRC staff had already been developing a process to grade licensing applications with the goal of improving efficiency. This proposed process considers risk insights from risk studies and from other insights from staff subject matter experts who have extensive knowledge in reviewing licensing applications (e.g., complexity, quality of application).

The NRC effort will include public meetings for sharing information with stakeholder (i.e., industry and public) at development intervals as appropriates. The developmental activities include the following steps:

  • Development of a high-level grading process
  • Form a working group (WG) of senior staff reviewers encompassing all the licensing technical areas
  • WG evaluate acceptability of the proposed process and grading criteria
  • Collect and resolve comments and suggestions from WG and work with developer for resolution
  • Conduct a public workshop to discuss draft process with stakeholders
  • Evaluate and incorporate, as appropriate, the feedbacks from stakeholders
  • Pilot the approach on license applications
  • Conduct WG review of results of pilot applications
  • Conduct public meetings to inform stakeholders
  • Complete NRC review guidance and maintain it as a living document to include new insights Enclosure 2

II. Proposed Actions and Due Dates ACTION RESPONSIBLE PARTY DUE DATE

1. Develop a draft approach for grading and NRC Done review levels for licensing applications
2. Form WG for evaluation NRC Done
3. Collect and resolve comments and NRC On going suggestions from WG and work with developer for resolution
4. Conduct a public workshop to discuss draft All April 2020 approach and receive feedback from stakeholders
5. Resolve issues and comments on criteria NRC July 2020 for grading the levels of review
6. Draft detail criteria for grading levels and NRC September 2020 identify possible conservatisms and non-conservatism in the grading process and how these could be resolved
7. Conduct public meeting to present revised All October 2020 draft guidance
8. Select pilot application to test acceptance NRC October 2020 review grading process.
9. Gather lessons learned on the pilot review NRC TBD
10. Conduct a public meeting to review NRC TBD lessons learn/modify process as needed
11. Develop NRC review guidance to NRC TBD incorporate acceptance review grading process
12. Hold public meeting on draft guidance NRC TBD
13. Finalize review guidance and utilize for NRC TBD upcoming reviews 14.

15.

Enclosure 2