ML23256A001

Generic Issues Program Presentation - ROP Public Meeting

ML23256A001
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Issue date:	09/20/2023
From:	Angela Wu Office of Nuclear Reactor Regulation
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Download: ML23256A001 (1)

Text

Recommendations for the NRCs Generic Issues Program EMBARK Venture Studio &

Office of Research (RES)

SEPTEMBER 20, 2023 ANGELA WU, THOMAS WEAVER, VANCE PETRELLA, EDWARD ODONNELL

What is the Generic Issues (GI) Program?

Definition of a GI:

Issue involving public health and safety, the common defense and security, or the environment that could affect multiple entities under NRC jurisdiction GI Program (Housed in RES):

• NRCs approach to complying with the 1974 Energy Reorganization Acts requirement to document & track resolution of GIs Stage 3:

Stage 1: Stage 2:

Regulatory Office Screening Assessment Implementation (9-18 months) (1-3 years)

(5-10 years)

• Issue resolution may involve new or revised rules or guidance that affect nuclear power plant licensees, nuclear material certificate holders, or holders of other regulatory approvals 2

Recent Modifications to the GI Program Sep 2012: Jan 2019:

Generic Issues Office of Present:

Program Tiger Team Inspector EMBARK/RES (Business Process Improvement Approach) General Audit Review Jan 2015: Jul 2019:

Revision to Revision to Management TEC-002 Directive (MD) (Current) 6.4 (Current) 3

Review Methodology Overview of GI Engage Identify Form Program Stakeholders Improvement Areas Recommendations 4

Stakeholder Interviews / Improvement Areas

• Conducted 31 open-ended interviews to gain a well-rounded perspective sample: Interviewees Reasonable, functional program that serves its purpose with 5 some areas for improvement Pros Cons (Improvement Areas) 7 screening criteria in Timeliness and lack of decision-making Stage 1, Screening in Stage 2, Assessment 26 GI Program Dashboard / Potential for better use of regulatory Supplements to NUREG-0933, tools for information gathering Resolution of Generic Safety Issues Internal External Technical engagements between Increase application of risk External:

Electric Power Research Institute; NRC/external stakeholders Nuclear Energy Institute (NEI);

Organization for Economic Co-operation Perception of inefficiency and Development, Nuclear Energy Agency; Southern Nuclear; Union of Concerned Scientists compared to other agency processes 5

Four Recommendations Annual Best Practices Team of Experts Consistency in Evaluation in for Information to Screen MD 6.4 and Assessment Gathering Generic Issues TEC-002 Stage 6

Recommendation #1:

Annual Evaluation in Stage 2, Assessment

Purpose:

Improves the timeliness and efficiency of the program

• Assess whether the issue should stay/exit the GI Program

• Management oversight

• Clear goals and timelines towards issue resolution Annual Assessment Process:

Complete Annual Evaluation RES Director -

Issue Results to Worksheet (2 weeks) Agree/Disagrees with RES Director 1x/year Recommendation 7

Annual Evaluation Worksheet

1) Does the issue still affect public health and safety, the common defense and security, or the environment?

Questions:

2) Is continued operation acceptable?

3) Can the research required to complete the assessment be completed in a timely manner? If no, would a long-term study or experimental research be required to establish the risk or safety significance?

4) Are there clear goals and timelines for the resolution of the generic issue? Be specific on dates, goals, resources, and perceived challenges.

5) Does the updated understanding of the qualitative and quantitative risk warrant continued expenditure of agency resources? Criteria from TEC-002, Appendix B, Risk Criteria can be used to assess implications to safety.

6) Is there another regulatory process better suited to address the issue without the need for further assessment?

7) Should this issue remain in the Generic Issues Program?

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Recommendation #2:

Best Practices for Information Gathering

Purpose:

Leverage different avenues to gain and seek further understanding of information required to resolve generic issues Bulletin 50.54(f) Generic Letter Information exchanges with Existing regulatory tools to formally independent entities and/or licensees request information from licensees 9

Recommendation #3:

Team of Experts to Screen Generic Issues

Purpose:

Formalize the practice of engaging with subject matter experts in the Screening stage

• Depending on the issue, the project manager may not always have the technical knowledge to make the screening determination

• Ensures proper technical expertise is applied to the screening decision 10

Recommendation #4:

Consistency in MD 6.4 and TEC-002

1. Enhance TEC-002 to consider how risk significance is influenced by uncertainties and assumptions in the risk analysis

2. Multiple additional editorial revisions between MD 6.4 and TEC-002 11

Next Steps Continue NRC Revisions to Concurrence of Issue Public Report MD 6.4 and TEC-002 Proposed Changes 12

Questions 13

BACK UP SLIDES 14

Submitting a Proposed GI NRC staff and members of the public can submit a proposed GI through the NRC public website or by emailing a NRC Form 833 to GIP.Resource@nrc.gov.

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Status & Progress of GIs

• Public Generic Issues Dashboard reports the status and progress of ongoing and closed issues

• Semi-Annual Generic Issue Management Control System reports capture the status of active issues

• Supplements to NUREG-0933, Resolution of Generic Safety Issues document the resolution of all resolved GIs and the assessment of work remaining on unresolved GIs 16

7 Screening Criteria of the GI Program

1. The issue affects public health and safety, the common defense and security, or the environment (with respect to radiological health and safety). For issues that are not amenable to quantification using risk assessment, qualitative factors may be developed and applied as necessary to assess safety/risk significance.

2. The issue applies to two or more facilities and/or licensees/certificate holders, or holders of other regulatory approvals.

3. The issue is not being addressed using other regulatory programs and processes; existing regulations, policies, or guidance.

4. The issue can be resolved by new or revised regulation, policy, or guidance.

5. The issues risk or safety significance can be adequately determined in a timely manner (i.e., it does not involve phenomena or other uncertainties that would require long-term study and/or experimental research to establish the risk or safety significance).

6. The issue is well defined, discrete, and technical.

7. Resolution of the issue may involve review, analysis, or action by the affected licensees, certificate holders, or holders of other regulatory approvals.

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Office Instruction, TEC-002, Appendix B, Risk Criteria Figures Based On: Regulatory Guide 1.174, Revision 3, An Approach for using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis 18