ML22307A272

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Presentation Slides for the November 2022 Nuclear Energy Institute Regulatory Issues Task Force Public Meeting
ML22307A272
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Site: 99902028
Issue date: 11/08/2022
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Division of Operating Reactor Licensing
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Download: ML22307A272 (1)


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Public Meeting with the Nuclear Energy Institute Regulatory Issues Task Force NOVEMBER 8, 2022

2 Agenda Time Topic 2:00 p.m. - 2:10 p.m.

Opening remarks by NRC and NEI 2:10 p.m. - 2:30 p.m.

Innovation/EMBARK Update on Mission Analytics Portal External (MAP-X) 2:30 p.m. - 2:40 p.m.

Discussion on risk-informed initiatives 2:40 p.m. - 3:00 p.m.

Discussion on risk-informed process for evaluations (RIPE) lessons learned from the first use 3:00 p.m. - 3:20 p.m.

Request for confirmation of information (RCI) process overview (LIC-115, Processing Requests for Additional Information) and discussion on best practices in communications for licensing review actions 3:20 p.m. - 3:30 p.m.

Break 3:30 p.m. - 3:45 p.m.

Discussion on staffing, budgeting, and resources 3:45 p.m. - 3:55 p.m.

NRC forthcoming process changes/updates/improvements 3:55 p.m. - 4:10 p.m.

Effort and Schedule Estimate (EASE) tool overview 4:10 p.m. - 4:25 p.m.

Status of Radioactive Source Security and Accountability Rulemaking 4:25 p.m. - 4:40 p.m.

2023 Regulatory Information Conference 4:40 p.m. - 4:50 p.m.

Opportunity for public comments 4:50 p.m. - 5:00 p.m.

Closing remarks by NRC and NEI 5:00 p.m.

Adjourn 2

Opening Remarks Mike King Deputy Director for Reactor Safety Programs and Mission Support Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Brett Titus Technical Advisor Nuclear Energy Institute 3

MAP-X Update NRC Public Meeting with Nuclear Energy Institute (NEI) Regulatory Issues Task Force (RITF)

November 8, 2022 Nicole Fields, MAP-X Lead, NRR/EMBARK Tim Mossman, Managing Director, NRR/EMBARK 4

MAP-X A user-authenticated web portal that improves the way that the agency can exchange data and information with our external stakeholders EMBARK Change organization housed within the Office of Nuclear Reactor Regulation (NRR)

Facilitating innovation and data improvements across the agency Strong partnership with program data owners and users and the Office of the Chief Information Officer (OCIO) 5

MAP-X Status

  • Active MAP-X Modules

(integrated into MAP-X as a module)

  • Event Notification (Form 361: Power Reactors, Form 361A: Fuel Cycle and Materials, Form 361N: Non-power Reactors)
  • MAP-X Modules under Development
  • Licensee Event Reports (Form 366)
  • General Submission (Similar to EIE General Form) 6

Potential MAP-X Benefits External Users

  • Individual access from anywhere - not tied to a specific computer/physical location
  • Due to user credentialling and authentication, portal access and submission viewing is secure -

can share sensitive or curated information

  • Email record/proof of submission
  • Form field validation / auto-populated fields
  • View/clone previous submissions NRC
  • Receives information as structured data rather than narrative text or attachments (as applicable)
  • Can support streamlining and monitoring incoming data processes
  • Routing and availability of information within the NRC is enhanced 7

Building a Smarter Web Form

  • Clone function for forms
  • Drop down lists
  • Required fields
  • Validation of data field formatting (dates, phone numbers)
  • Conditional input fields
  • Ghost text to show expected input
  • Autopopulation of fields based on user information
  • Ability to expand/minimize parts of forms 8

Recent MAP-X Progress

  • Revised Relief Request/Proposed Alternative form approved by OMB and now available for use
  • Upgrades to improve the user experience with complex text inputs based on user feedback
  • Deployment of Form 361N for Non-Power Reactors
  • Upgrades to Form 361, 361A, and 361N made and screen shots were submitted to OMB for approval
  • Transitioned to a new MAP-X application development contractor
  • Revision 3 of MAP-X User Guide and MAP-X FAQ now available
  • User Warning Banner added for information security 9

MAP-X Upgrades On The Horizon

  • Finish development of Licensee Event Report module and request OMB clearance
  • Develop and deploy General Submission module
  • Continued MAP-X User Experience Improvements
  • Adapt application to be scalable to more forms/processes and more groups of external users, especially considering the Administrator functionality
  • More reporting/interactive functionality within the application for NRC users
  • Upgrading MAP-X to intake sensitive (but not SGI or classified) information
  • Continue to explore possible future MAP-X modules
  • Reactor Operating Licensing, Fitness for Duty, Radioactive Material Shipments 10

Advice for MAP-X Users

  • If you may have a near-term use for MAP-X, sign up for a user account today!
  • Be prepared to go through ICAM Level Gold credentialling to use MAP-X
  • Requires both a recent photo and a photo ID (State Drivers License is acceptable)
  • Telling your NRC project manager that you want to use MAP-X will help ensure the process goes smoothly; you can also contact MAP-X.resource@nrc.gov with any issues or questions
  • Once you are credentialled, login to the portal https://mapx.nrc-gateway.gov/ to become familiar with the application, your roles/permissions, and the forms

11

MAP-X Looking Forward This Photo by Unknown Author is licensed under CC BY 12

Discussion on risk-informed initiatives

Discussion on risk-informed process for evaluations (RIPE) lessons learned from the first use

15

IDP PRA RIPE (using existing regulations)

Integrated Decision-making Panel (IDP) Reviews Key Engineering Principles Demonstrated Probabilistic Risk Assessment Acceptability RIPE Leverages Previous Risk-Informed Initiatives 16

1st Application Submitted Under RIPE

  • The RIPE submittal requested a partial exemption to eliminate the Diverse Auxiliary Feedwater Actuation System (DAFAS) requirement only
  • SE completed and issued on March 23, 2022, within 81/2 weeks

NRC Lessons Learned - Training Just In Time (JIT) Training Risk-Informed Decision Making (RIDM)

Workshops ET/LT Briefings 18

NRC Lessons Learned

- Process

  • Staff to create SE template
  • Encourage/recommend that licensee requests pre-submittal meeting for applications submitted under RIPE
  • Encourage licensees to streamline applications submitted under RIPE
  • Encourage licensees to make IDP available for review by staff (via portal is acceptable)

Defense-in-depth Safety margins 19

NRC Lessons Learned - Guidance Revise NRR guidance to:

  • Provide additional information regarding defense-in-depth and safety margins review for very low safety significant issues
  • Clarify purpose and scope of the no technical objection review 20

Recent Accomplishments and Future Work

  • Expanded RIPE to allow Technical Specifications changes - guidance issued June 2022 (ADAMS Accession No. ML22088A140)
  • Will implement initial lessons learned based on recommendations from first RIPE review
  • Continue working with the PWROG on Risk Assessment Process for Topical Reports (RAPTR),

a generic process for topical reports

  • Other RIDM/RIPE opportunities/next steps?

21

Potential Benefits of RIPE

  • Focus NRC and licensee resources on the most safety significant issues
  • Address low safety significance compliance issues in an efficient and predictable manner consistent with NRC's Principles of Good Regulation
  • Leverage existing regulations and risk insights

Questions/Feedback?

23

Request for confirmation of information (RCI) process overview (LIC-115, Processing Requests for Additional Information) and discussion on best practices in communications for licensing review actions

25 NRR Office Instruction LIC-115 and Request for Confirmation of Information (RCI) Process Overview Samson Lee Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Brian Harris Division of New and Renewed Licenses Office of Nuclear Reactor Regulation

LIC-115, Revision 1, Processing Requests for Additional Information

  • Requests for Additional Information (RAIs) enable the NRC staff to obtain information needed to make a regulatory decision on a licensing action.
  • LIC-115, Revision 1, added a Request for Confirmation of Information (RCI) process.

- RCI is a type of RAI.

Request for Confirmation of Information (RCI)

  • NRC staff identifies detailed licensees information that the NRC staff needs to make a regulatory decision.
  • RCI is an efficient means to place that information on the licensees docket for the NRC staff to rely on in its decision.

27

RCI RCI Characteristics:

  • Low complexity
  • High confidence
  • Factual information NRC staff has already identified the likely answer Licensees can typically respond with a short yes-or-no to confirm the accuracy

RAI/RCI Structure Regulatory Basis Technical or Regulatory Issue Information Needed RAI example: Provide analysis or justification...

RCI example: Confirm Note: Not necessary to specifically refer to an information request as an RCI.

29 29

RCI Example from the NRC Staff Audit

  • Based on the review of Procedure X during an audit, the NRC staff noted that this procedure contains aspects of the erosion management program.
  • Confirm that the requirements in this procedure also apply to the licensees erosion program.

30

RCI Example from the NRC Staff Review

  • Confirm that the events described in the UFSAR that credit the system are limited to those 12 events.

31

RCI Example of Potential Inconsistency 32 The licensees license amendment request describes a certain pump as Class 1E. However, the UFSAR describes this pump as neither Class 1E nor seismically qualified.

Confirm that the pump is Class 1E.

RCI Potential Efficiencies

  • NRC staff perspective:

- Confirmation of NRC staff-identified low complexity, high confidence, and factual information

- Efficient process for docketing licensees information to support a regulatory decision

- Opportunity for reducing response time from typical RAI response time (30 days).

  • Licensee perspective:

- Typical yes or no response

- Option for detailed response similar to an RAI, if appropriate.

33

Break

Discussion on staffing, budgeting, and resources

Discussion on NRC forthcoming process changes/updates/improvements

Doug Broaddus Senior Project Manager for Workload Management & Data Analysis Tools Division of Operating Reactor Licensing Data Driven Licensing Tools Effort And Schedule Estimator (EASE) 37

Increased availability of data and analytic tools Effectively visualize and assess current and historical results Enhance information available to internal and external stakeholders Data Tools to Improve Review Estimates 38

Provide staff data needed to develop more accurate estimates Rapid access to licensing data to respond to internal and external requests More meaningful information available* to applicants Effort And Schedule Estimator (EASE) Interactive Tool

  • www.nrc.gov/reactors/operating/licensing/resource-estimator.html 39

Effort And Schedule Estimator (EASE) Demo 40

RADIOACTIVE SOURCE SECURITY AND ACCOUNTABILITY RULEMAKING 41 Andrew Carrera Office of Nuclear Material Safety and Safeguards

42 Consistent with the Commissions direction in SRM-SECY-17-0083, the staff is conducting a rulemaking to revise the radioactive source security and accountability (RSSA) regulations in 10 CFR The RSSA rulemaking would require:

- Safety and security equipment and facilities to be in place for certain applicants before NRC would issue a license

- License verification for licensees transferring category 3 quantities of radioactive material through the License Verification System (LVS) or by contacting the license-issuing authority for the licensee Key Messages

43 The rulemaking would affect applicants for a radioactive material license and licensees who transfer category 3 quantities of radioactive material.

The rulemaking would address recommendations from several U.S. Government Accountability Office reports and would further deter someone with malicious intent from purchasing category 3 quantities of radioactive material.

The staff intends to submit a draft proposed rule to the Commission for approval by December 2022. Assuming approval by the Commission, the NRC plans to publish the proposed rule in the Federal Register in early 2023.

Key Messages

44 SRM-COMJMB-16-0001 - Directed NRC staff to evaluate the NRC regulations governing source protection and accountability for category 3 quantities of radioactive material SECY-17-0083 - Recommended rulemaking to enhance the security and accountability of category 3 quantities of radioactive material SRM-SECY-17-0083 - Approved to initiate rulemaking RSSA Rulemaking Background

45 Requirements for the safety and security equipment and facilities to be in place before NRC issues a license for certain applicants:

10 CFR 30.33(a), 40.32(c), and 70.23(a)

Help address the concern related to individuals using a fictitious company or providing false information to obtain a valid license or radioactive materials Proposed RSSA Revisions:

Safety and Security Equipment and Facilities

46 Requirements for license verification for transfers of category 3 quantities of radioactive materials:

License Verification System (LVS) or by contacting the license-issuing authority 10 CFR 30.41(d), 40.51(d), and 70.42(d)

Help address the concerns:

o altering a valid license o

use of counterfeit license Proposed RSSA Revisions:

License Verification

47 Provide new definition Provide new Appendix F to 10 CFR Part 30 Revise recordkeeping requirements Proposed RSSA Revisions:

License Verification (continued)

48 Remove obsolete verification method Administrative, clarifying and conforming changes to various provisions in 10 CFR Proposed RSSA Revisions:

Other Changes

49 Website with frequently asked questions (FAQ) to provide guidance o

Safety and security equipment and facilities requirements o

License verification requirements Provide accelerated guidance update to licensees Proposed RSSA Revisions:

Guidance

50 Next Steps Submit RSSA proposed rule to Commission (December 2022)

Publish in the Federal Register in 2023 (assuming approval by the Commission)

Conduct further stakeholder engagements

51 Please contact:

- Andrew Carrera, 301-415-1078, Andrew.Carrera@nrc.gov, or

- Anita Gray, 301-415-7036, Anita.Gray@nrc.gov.

Have Questions?

2023 Regulatory Information Conference Holly Cruz, RIC Co-Champion Division of Advanced Reactors and Non-power Production and Utilization Facilities Office of Nuclear Reactor Regulation Luis Betancourt, RIC Co-Champion Division of Systems Analysis Office of Nuclear Regulatory Research

The 2023 RIC will be in person, with virtual components Presenters and panelists are expected to attend in person Preliminary Agenda o Tuesday, March 14, 8:00 am to 5:00 pm (ET) o Wednesday, March 15, 9:00 am to 5:00 pm (ET) o Thursday, March 16, 8:30 am to 12:00 pm (ET) 6-7 plenary sessions, 24 technical sessions, 17 digital exhibits Conference agenda and technical program currently being finalized Registration to open in January 53

Opportunity for Public Comments

Closing Remarks Mike King Deputy Director for Reactor Safety Programs and Mission Support Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Brett Titus Technical Advisor Nuclear Energy Institute

Acronyms ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations EIE Electronic Information Exchange FAQ Frequently Asked Questions NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation OMB Office of Management and Budget PRA Probabilistic Risk Assessment PWROG Pressurized Water Reactor Owners Group RAIs Requests for Additional Information SE Safety Evaluation