ML20294A039

October 28-29, 2020, Cumulative Effects of Regulation Public Meeting: NEI Powerpoint Presentation

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

Flexibility to Smarter Core Inspection Program for Good Performance October 28, 2020

©2020 Nuclear Energy Institute

Background

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

©2020 Nuclear Energy Institute 2

Inspection Program Principles 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

©2020 Nuclear Energy Institute 3

Fuel Cycle Fleet Risk Profile 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

©2020 Nuclear Energy Institute 4

Concept of Flexible Adjustments 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

©2020 Nuclear Energy Institute 5

Examples of Criteria* for Determining Potential Flexible Performance Based Adjustments

• No Escalated Violations (i.e., > SL III)

• Low Worker and Public Doses

• If Licensee has Comprehensive CAP,

• ISAs Rely on Defense-in-Depth (e.g.,

Minor, Non-Cited and SL IV Violations > 2 IROFS) or Performance Criteria Would Not Negatively Impact Margin Consideration of Adjustments

• Robust Management Measures

• Reportable Events that Do Not Result Result in Available and Effective in Significant Violations Would Not IROFS Negatively Impact Consideration of

• Effective Self or Independent Adjustments Assessments Would be Additional

• Low Number of Contamination, Basis for Consideration of Adjustment Waste Management or Transportation

• Continued or Repetitive Periods of Events Performance under LPR Resulting in an Area not Needing Improvement

• Single, Stand-Alone Criteria

©2020 Nuclear Energy Institute 6

Suggested Flexible Adjustments to Smarter Core Inspection Program 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

©2020 Nuclear Energy Institute 7

Future Actions 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!!

©2020 Nuclear Energy Institute 8

Acronyms 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

©2020 Nuclear Energy Institute 9