ML20294A039
| ML20294A039 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 10/28/2020 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Material Safety and Safeguards |
| OSPerez NMSS/DFM/FFL 301.415.7827 | |
| References | |
| Download: ML20294A039 (9) | |
Text
©2020 Nuclear Energy Institute Flexibility to Smarter Core Inspection Program for Good Performance October 28, 2020
©2020 Nuclear Energy Institute 2 April 2019 - NRC Formed WG to Perform Holistic Assessment of Fuel Cycle Oversight Program April-December 2019 - Multiple Public Meetings March 2020 - WG Implementation Plan with Recommendations for Notable Adjustments to IMC 2600 & Appendix B April & July 2020 - Public Meetings on Project & Status October 2020 - Await NRC Proposed Revisions to IMCs and Related IPs
Background
©2020 Nuclear Energy Institute 3
Comprehensive NRC Oversight Program is Key Attribute of NRCs Principles of Good Regulation
Risk and Performance-Based Insights Justify Efficiencies to Smarter Core Inspection Program
Continued Use of Special or Reactive Inspections Industry Respectfully Submits there Remains Potential Improvements with Regard to Flexibility of the Smarter Core Based on Licensee Performance Inspection Program Principles
©2020 Nuclear Energy Institute 4 Low Risk Profile in Many Program or Functional Areas, e.g.,
Radiation & Environmental Protection - Low and Decreasing Doses to Worker and Public; Effective ALARA Programs Material, Control & Accounting - Low Strategic Significance of Category III Facilities Material Waste Management - Facilities Continue Reducing Production and Volume of LLRW Transportation - Industrys Excellent Safety Record on Thousands of Shipments, e.g., LLRW, Nuclear Fuel, Radiation Sources Fuel Cycle Fleet Risk Profile
©2020 Nuclear Energy Institute 5 Use Existing LPR Process to Assess and Evaluate Each Licensee in its Normal Review Cycle:
Determine Whether Flexible Adjustments Can be Applied to Reduce Frequency and/or Duration of Smarter Core Inspection Program During Each LPR, Staff Collects Performance Data to Include But Not Limited to:
Number 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 of Flexible Adjustments
©2020 Nuclear Energy Institute 6 No Escalated Violations (i.e., > SL III)
If Licensee has Comprehensive CAP, Minor, Non-Cited and SL IV Violations Would Not Negatively Impact Consideration of Adjustments Reportable Events that Do Not Result in Significant Violations Would Not Negatively Impact Consideration of Adjustments Low Number of Contamination, Waste Management or Transportation Events
- Single, Stand-Alone Criteria Examples of Criteria* for Determining Potential Flexible Performance Based Adjustments Low Worker and Public Doses ISAs Rely on Defense-in-Depth (e.g.,
> 2 IROFS) or Performance Criteria Margin Robust Management Measures Result in Available and Effective IROFS Effective Self or Independent Assessments Would be Additional Basis for Consideration of Adjustment Continued or Repetitive Periods of Performance under LPR Resulting in an Area not Needing Improvement
©2020 Nuclear Energy Institute 7 Frequency or Duration of IP Would Be Reduced by 50% in a Given Area if:
2 or More Sequential LPRs With No Improvement Needed Zero Significant Violations Flexibility 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 Adjustments Are Not Cumulative, i.e., Flexibility Must Be Earned Each LPR Period Special and Reactive Inspections Are Independent of Any Flexible Adjustments and Can Be Basis of Revocation of Any Flexibility Suggested Flexible Adjustments to Smarter Core Inspection Program
©2020 Nuclear Energy Institute 8 Continue Public Dialogue to Reach Common Ground on Principles of Performance Based Adjustments Solicit Stakeholder Input for Assessment of Potential Changes Consider Whether Piloting Flexible Adjustments is Worthwhile Determine Timeline and Decision Points for Project Thank You!!
Future Actions
©2020 Nuclear Energy Institute 9 ALARA - As Low As Reasonably Achievable CAP - Corrective Action Program IMC - Inspection Manual Chapter IP - Inspection Procedure IROFS - Items Relied on For Safety ISA - Integrated Safety Analysis LLRW - Low-Level Radioactive Waste LPR - License Performance Review SL - Severity Level WG - Working Group Acronyms