ML25014A010

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2025 January 15 Public Meeting Slides Final
ML25014A010
Person / Time
Issue date: 01/15/2025
From: Brian Benney
NRC/NRR/DRO/IOEB
To:
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Download: ML25014A010 (28)


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Public Meeting ADVANCE Act Section 507 Reactor Oversight Process January 15, 2025

ADVANCE Act Section 507 Public Meeting January 15, 2025 Non-NRC participants, please send an email to Brian.Benney@nrc.gov to record your attendance.

Materials are available at the following link:

https://www.nrc.gov/pmns/mtg?do=details&Code=20241443 Time Topic Speaker 9:30am Introductions and Opening Remarks NRC & NEI 9:35am Opening Remarks from the Core Team NRC 9:40am Update to Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024 (ADVANCE Act) Section 507 Oversight and Inspection for Operating Reactors Phil McKenna, NRC 10:10am Open Discussion NRC, NEI, Industry 10:40am Additional Opportunity for Public Comments Members of the Public 11:45am Action Items & Closing Remarks NRC & NEI Noon Meeting Adjourn

Introductions and Opening Remarks

Purpose To share information and gather comments on ADVANCE Act Section 507 - Improving Oversight and Inspection Programs through:

  • An Overview of ADVANCE Act Section 507
  • A Discussion of NRC Staff Ideas Considerations
  • Identification of Opportunities This meeting was first noticed on December 11, 2024

ADVANCE Act Overview

NRC Core Team For the Implementation of the ADVANCE Act of 2024 Luis Betancourt, Executive Technical Assistant Annie Ramirez, Executive Technical Assistant Aaron McCraw, Sr. Communications Specialist Opening Remarks

To Stay Informed of Progress Follow NRCs ADVANCE Act implementation with this Dashboard

For Upcoming and Past Meetings For NRCs public meeting information on ADVANCE Act

Provide Comments or Feedback As we assess the considerations we are presenting here today, we welcome any feedback from the industry or members of the public.

https://www.nrc.gov/about-nrc/governing-laws/advance-act/contactus.html

ADVANCE Act Section 507 Reactor Oversight Process Phil McKenna Deputy Director Division of Reactor Oversight NRR/DRO Philip.McKenna@nrc.gov

ADVANCE Act Implementation Section 507 of the ADVANCE Act requires that not later than 1 year (July 9, 2025) the Commission shall submit a report to Congress that identifies specific improvements to the nuclear reactor and materials oversight and inspection programs that the Commission may implement to maximize the efficiency of such programs through, where appropriate, the use of risk-informed, performance-based procedures, expanded incorporation of information technologies, and staff training.

Report Contents:

(1) assess specific elements of oversight and inspections that may be modified by the use of technology, improved planning, and continually updated risk-informed, performance-based assessment, including (A) use of travel resources; (B) planning and preparation for inspections, including entrance and exit meetings with licensees; (C) document collection and preparation, including consideration of whether nuclear reactor data are accessible prior to onsite visits or requests to the licensee and that document requests are timely and within the scope of inspections; and (D) the cross-cutting issues program

ADVANCE Act Implementation Report Contents (cont):

(2) identify and assess measures to improve oversight and inspections, including

  • (A) elimination of areas of duplicative or otherwise unnecessary activities;
  • (B) increased use of templates in documenting inspection results; and
  • (C) periodic training of Commission staff and leadership on the application of risk-informed criteria for (i) inspection planning and assessments; (ii) agency decision-making processes on the application of regulations and guidance; and (iii) the application of the Commissions standard of reasonable assurance of adequate protection; (3) assess measures to advance risk-informed procedures, including
  • (A) increased use of inspection approaches that balance the level of resources commensurate with safety significance
  • (B) increased review of the use of inspection program resources based on licensee performance;
  • (C) expansion of modern information technology, including artificial intelligence and machine learning, to risk-inform oversight and inspection decisions; and
  • (D) updating the Differing Professional Views or Opinions process to ensure any impacts on agency decisions and schedules are commensurate with the safety significance of the differing opinion

ADVANCE Act Implementation Report Contents (cont):

(4) assess the ability of the Commission, consistent with the mission of the Commission, to enable licensee innovations that may advance nuclear reactor operational efficiency and safety, including the criteria of the Commission for imely acceptance of licensee adoption of advanced technologies, including digital technologies; (5) identify recommendations resulting from the assessments described in paragraphs (1) through (4);

(6) identify specific actions that the Commission may take to incorporate into the training, inspection, oversight, and licensing activities, and regulations, of the Commission, without compromising the mission of the Commission, the recommendations identified under paragraph (5); and (7) describe when the actions identified under paragraph (6) may be implemented.

Schedule

  • Public meeting (December 10, 2024)

(Observation)

  • Public meeting for comments and feedback (January 15, 2025) (Comment Gathering)
  • ROP Bi-monthly meeting (January 29, 2025)

(Observation)

  • SECY to Commission (TBD 2025)
  • Report to Congress (July 9, 2025)
  • Implementation (ongoing)

HQ Regional Assistance on Inspections Issues:

- Clarify limit for effort expended on very low safety significant issues before management engagement and evaluation of VLSSIR criteria Engineering inspections

- Scheduled effectiveness review to begin 4th quarter 2025 to identify any changes Emergency preparedness

- Emergency Response Facility (ERF) Performance Indicator

- Significance Determination Process (SDP) Revision Security

- Working group to revise SDP Cyber Security

- Working group to evaluate the structure, staffing, and frequency of the inspection procedure (IP) 71130.10, Cybersecurity.

Current Implementation Activities

Topics Under Consideration

  • Reactor Oversight Process (ROP) Re-baseline

- New Performance Indictors (PIs)*

- Holistic review of all baseline inspection procedures based on new PIs*

- PI&R Inspection review*

- Complete effectiveness review of current quadrennial Engineering Inspection cycle*

  • Management Directive (MD) 8.13 governs Commission notification and approval of ROP revisions.
  • Credit sustained Column 1 performance in Action Matrix*

- Adjust PI&R team inspection frequency and number of members*

- Reduce baseline samples*

Topic Under Consideration

  • Management Directive (MD) 8.13 governs Commission notification and approval of ROP revisions.
  • Items that could be done in current inspection year:
  • Comprehensive Engineering Team Inspection (CETI) reduced by one inspector (7 down to 6 persons).
  • Revise guidance on when going to minimum samples may be appropriate based on equipment risk.
  • Revise team inspection IPs so that there is one week on site and one-week remote inspection effort with a provision for one team member to return to the site to complete any required inspection effort after the remote week.

Topic Under Consideration

  • Cross-cutting Issues Program Revision*
  • Evaluate current practice of dual-path findings (Reactor Oversight Process and Traditional Enforcement)
  • Reduce scope of documentation for Green/SL-IV findings/Non-Cited Violations

- Similar to Licensee-Identified Violations with more description of the issue.

Inspection Finding Screening and Documentation Ideas

  • Management Directive (MD) 8.13 governs Commission notification and approval of ROP revisions.
  • Licensee-identified White findings/violations would not result in Action Matrix movement

- Targeted follow-up (IP 71152) or supplemental (IP 95001) inspection would still occur

  • White findings would no longer aggregate to a Degraded Cornerstone*

Assessment Ideas

  • Management Directive (MD) 8.13 governs Commission notification and approval of ROP revisions.
  • Entrance meeting would by exception
  • Virtual exit meetings unless otherwise indicated
  • NRC Requests for Licensee Documentation:

Upgraded NRC Library to simplify access to documentation already in NRC possession

  • Reduce onsite time to one week and make other week remote (for two-week inspections)

Team Inspection Ideas

  • Re-evaluation of Performance Indicators (PIs)

- Potential to shift more oversight from inspection to PIs

- Simplify submission process

  • Engineering inspection changes

- Proposed for start of new cycle January 2027

  • Organizational Structures Longer-Term Ideas
  • Management Directive (MD) 8.13 governs Commission notification and approval of ROP revisions.

- Options for major ROP revisions will be in SECY to Commission in 2025. This will include Commission notification items.

- Some items may be implemented before report to Congress Implementation

Is the proposed option within the scope of the ADVANCE Act?

If the proposed option is not in the scope of the ADVANCE Act, does it meet the intent of the ADVANCE Act Section 507 discussion to improve NRC efficiency through optimization of risk-informed, performance-based oversight?

Would the proposed option result in a reduction of reasonable assurance of adequate protection because of a gap in oversight.

(consider using the Be riskSMART framework)?

Could the Agency continue to achieve its oversight mission if the proposed change is enacted?

If the proposed option does not result in an unacceptable gap in NRC oversight, then does the proposed option improve efficiency for the Agency and also not inappropriately shift burden to external stakeholders?

Evaluation Criteria

Does the proposed option also meet the remaining POGR goals (i.e.,

openness, independence, clarity, reliability)?

Was the proposed option considered before and not approved by the Commission? If yes, does it meet the intent of the Advance Act and should it be considered in the Section 507 effort?

Other guidance the project team used:

The revision should not interject subjectivity into the ROP.

Maintaining the Action Matrix structure would ease the ROP revision and retain how the Agency responds to declining licensee performance.

Retain current resident inspector site manning structure.

Evaluation Criteria (Cont)

Industry Comments

Public Comments

Closing Remarks