ML21022A417
| ML21022A417 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/2021 |
| From: | Daniel Merzke NRC/NRR/DRO/IRAB |
| To: | |
| Daniel Merzke NRR/DRO/IRAB, 4251457 | |
| References | |
| Download: ML21022A417 (17) | |
Text
Graded Approach to an Integrated Regulatory Program Dan Merzke U.S. Nuclear Regulatory Commission
Integrated Regulatory Program
- Step 1: Identify the combination of functions and/or the suit of facilities that need to be simultaneously addressed under the regulatory program.
Regulatory Functions Licensees
- Rulemaking
- Nuclear Power Plants
- Authorizations - Construction
- Review and Assessment - Operating
- Inspection - Decommissioning
- Enforcement
- Research & Test Reactors
- Communication/Consultation with
- Fuel Cycle Facilities Interested Parties
- Materials licensees 2
U.S. Licensees Licensees Numbers New Reactors Nuclear Power Plants - 6 Early Site Permits Operating 94 - 6 Design Certifications Under Construction 2
- NuScale SMR application under Decommissioned 25 review Research and Test Reactors 31 - 14 Construction/Operating Licenses (6 Under Construction 2 terminated)
Fuel Cycle Facilities 10 Materials NRC 2209 Agreement States 16455 3
Integrated Regulatory Program
- Step 2: Determine which factors are applicable to the decision, and how those factors are ranked.
- Statutory requirements (organizational structure, budget)
- Number and type of licensees
- Regulatory body experience
- Emergency response
- Licensee performance
- Urgency
- Emergent work 4
Integrated Regulatory Program
- Step 3: Integrate the applicable factors into the decision-making process.
- How are resources allocated to accomplish all regulatory functions efficiently for all licensees in a graded approach?
- Budget!
- How are resources reallocated in response to events, licensee performance, emergent work?
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Budget
- NRC budget development
- Regulatory body experience - 46 years
- Baseline budgeting - start with most recent approved budget, adjust for known and anticipated increases or decreases in work.
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Budget
- Example - Operating NPP inspection resource requirements
- 2 resident inspectors at every site (3 at 3-unit sites) (56 sites)
- Region-based and HQ inspectors for security, rad protection, emergency preparedness Inspection Area Hours 71111 (Reactor Safety) Procedures 1286 71114 (EP) Procedures 88 71124 (Radiation Protection) Procedures 142 71130 (Security) Procedures 278 Other Procedures (71151, 52, 53) 505 Plant Status 699 Total Hours 2998 7
Budget
- Example - RTR inspection resource requirements
- No resident inspectors
- 31 sites
- Inspection requirements significantly less than for NPPs due to lower risk to public (most conducted annually or biennially)
- 10 dedicated inspectors
- 13 staff dedicated to licensing 8
Budget
- Recent budget requested 1755 staff for reactor safety
- Licensing - 100
- Technical reviewers; risk analysts - 220
- New reactors (licensing and inspection) - 285 (17 dedicated to inspection of Vogtle 3&4 (2-unit AP1000)
- Oversight program - 70
- Enforcement - 21
- Inspectors
- Security inspectors 9
Budget Office of Nuclear Material Safety and Safeguards provides the regulatory functions for spent fuel storage and transportation, nuclear materials users, decommissioning and low-level waste, and fuel facility business lines, as well as rulemaking.
- 462 staff 10
Resource Summary Business Line Staff Requested Operating Reactors 1470 New Reactors 285 Spent Fuel Storage and Transportation 102 Nuclear Materials Users 201 Decommissioning and Low-Level Waste 86 Fuel Facilities 73 11
Adjusting Resources Emergent work may require reprioritizing or shedding other budgeted work Factors Source of emergent work Due dates Negative impact to performance metrics 12
Adjusting Resources Licensee performance Declining performance leads to increased inspection Graded approach based on level of performance Potential increase in licensing actions Increase in enforcement actions 13
Adjusting Resources Event Response 9/11 Creation of Office of Nuclear Security and Incident Response (NSIR)
~200 staff Increased security inspections from 98 hours0.00113 days <br />0.0272 hours <br />1.62037e-4 weeks <br />3.7289e-5 months <br /> annually to 278 hours0.00322 days <br />0.0772 hours <br />4.596561e-4 weeks <br />1.05779e-4 months <br /> Increased regulation (10 CFR 50.54(hh)(1)) - mitigation from potential aircraft threat 14
Adjusting Resources Event Response Fukushima EOC staffed around the clock Urgency due to very high degree of stakeholder and public concern Regulations - several Orders issued to operating NPPs, eventually codified within the regulations Inspections - seismic and flooding 15
Adjusting Resources Risk-Informed Decision-Making
- Risk insights are considered together with other factors to establish requirements that better focus licensee and regulatory attention on design and operational issues commensurate with their importance to public health and safety.
- Applies to NRC rulemaking, licensing, inspection, assessment, enforcement, and other decision-making.
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Questions 17