ML24129A138
| ML24129A138 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/08/2024 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML24129A138 (1) | |
Text
©2024 Nuclear Energy Institute 1 Inspections of Centralized Programs Public Workshop May 9, 2024
©2024 Nuclear Energy Institute 2 Multiple inspections during the year at a utility with a centralized program imposes undue burden on program staff and unnecessary overlap or duplication of effort by NRC inspectors.
Applicable to inspections of centrally-led programs, including:
- Security areas such as AA/FFD
- Cybersecurity
- 10 CFR 50.69 Inspections of Centralized Programs
©2024 Nuclear Energy Institute 3 CONFIDENTIAL - NEI MEMBERS ONLY Breakdown of Part 170 Charges
Inspection hours account for ~50% of charges
Covers:
Direct Inspection Indirect Inspection Prep & Doc Travel Communication SDP
©2024 Nuclear Energy Institute 4 Direct vs Indirect Inspection
©2024 Nuclear Energy Institute 5 Develop/update NRC guidance to provide flexibility in inspection planning for programs with centralized functions:
- IMC 0305 As part of development of inspection plans, allow Branch Chief to coordinate w/ licensee to pursue efficient inspection scheduling
- IMC 2515, App A For fleets across multiple regions:
- Coordinate inspection plans and resources across the regions Provide different inspection approaches in guidance Recommendations
©2024 Nuclear Energy Institute 6 Same inspection team and team leader One entrance meeting for the fleet First week at centralized location interviewing program staff, reviewing program documents, etc
Off-week On-site at first site Off-week Repeat as needed One exit meeting One IR covering all sites
Findings would be docketed to impacted sites, based on implementation Example #1
©2024 Nuclear Energy Institute 7 3 sites: one prep week, at central location, offsite, onsite, offsite, onsite, offsite, onsite, doc (9 total weeks)
Historical - prep week, onsite, offsite, onsite, doc (4 weeks) x 3 sites = 12 weeks Considerations:
Would complete multiple inspections in shorter period than separate inspections, freeing up licensee and NRC resources for remainder of inspection cycle Inspector familiarity and continuity by using same inspectors Requires availability of NRC inspectors and licensee program staff for longer duration Disposition of a generic issue could involve citing all dockets Example #1 (contd)
©2024 Nuclear Energy Institute 8 Ex #1 in reverse Perform all site walkdowns/samples first Collect questions/issues of concern and reconvene at central location to interview program staff Considerations:
Similar to Example #1, multiple inspections completed in shorter time period Inspectors have earlier opportunity to walk down sites and identify issues for review during final week Similar to Example #1, requires availability of NRC and licensee staff for longer duration Example #2
©2024 Nuclear Energy Institute 9 First inspection in the fleet includes review of program and common inspection elements.
Subsequent inspections could credit activities performed in previous inspections.
Findings would be docketed to site receiving inspection.
Considerations:
Subsequent inspections could be more efficient Provides flexibility to account for differences in fleet programs Most efficient results requires same NRC inspectors for each subsequent inspection Example #3
©2024 Nuclear Energy Institute 10 Questions