ML23256A001

Generic Issues Program Presentation - ROP Public Meeting

ML23256A001
Person / Time
Issue date:	09/20/2023
From:	Angela Wu Office of Nuclear Reactor Regulation
To:
References
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 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

Stage 1:

Screening (9-18 months)

Stage 2:

Assessment (1-3 years)

Stage 3:

Regulatory Office Implementation (5-10 years)

Recent Modifications to the GI Program Sep 2012:

Generic Issues Program Tiger Team (Business Process Improvement Approach)

Jan 2015:

Revision to Management Directive (MD) 6.4 (Current)

Jan 2019:

Office of Inspector General Audit Jul 2019:

Revision to TEC-002 (Current)

Present:

EMBARK/RES Review 3

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

Stakeholder Interviews / Improvement Areas 26 5

Interviewees Internal External 5

Conducted 31 open-ended interviews to gain a well-rounded perspective sample:

Reasonable, functional program that serves its purpose with some areas for improvement Pros Cons (Improvement Areas) 7 screening criteria in Stage 1, Screening Timeliness and lack of decision-making in Stage 2, Assessment GI Program Dashboard /

Supplements to NUREG-0933, Resolution of Generic Safety Issues Potential for better use of regulatory tools for information gathering Technical engagements between NRC/external stakeholders Increase application of risk Perception of inefficiency compared to other agency processes External:

Electric Power Research Institute; Nuclear Energy Institute (NEI);

Organization for Economic Co-operation and Development, Nuclear Energy Agency; Southern Nuclear; Union of Concerned Scientists

Four Recommendations Annual Evaluation in Assessment Stage Best Practices for Information Gathering Team of Experts to Screen Generic Issues Consistency in MD 6.4 and TEC-002 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 Worksheet (2 weeks) 1x/year Issue Results to RES Director RES Director -

Agree/Disagrees with Recommendation 7

Annual Evaluation Worksheet Questions:

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

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?

8

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 Generic Letter 50.54(f) 9 Existing regulatory tools to formally request information from licensees Information exchanges with independent entities and/or licensees

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

Questions 13

BACK UP SLIDES 14

Submitting a Proposed GI 15 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.

Status & Progress of GIs 16 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

7 Screening Criteria of the GI Program 17

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.

Office Instruction, TEC-002, Appendix B, Risk Criteria 18 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