SECY-18-0070, Evaluation of the Implementation Status of Certain Voluntary Industry Initiatives
| ML18141A033 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/2018 |
| From: | Mccree V NRC/EDO |
| To: | Commissioners NRC/OCM/JMB, NRC/OCM/KLS, NRC/OCM/SGB |
| Bowman E, NRR/DLP, 301-415-2963 | |
| Shared Package | |
| ML18141A133 | List: |
| References | |
| SECY-18-0070 | |
| Download: ML18141A033 (3) | |
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POLICY ISSUE (Information)
June 28, 2018 SECY-18-0070 FOR:
The Commissioners FROM:
Victor M. McCree Executive Director for Operations
SUBJECT:
EVALUATION OF THE IMPLEMENTATION STATUS OF CERTAIN VOLUNTARY INDUSTRY INITIATIVES PURPOSE:
This paper informs the Commission of the results of the U.S. Nuclear Regulatory Commission (NRC) staffs evaluation of the implementation status of the most risk-or safety-significant Type 2 voluntary industry initiatives.1 This paper does not address any new commitments or resource implications.
BACKGROUND:
In SECY-13-0132, U.S. Nuclear Regulatory Commission Staff Recommendation for the Disposition of Recommendation 1 of the Near-Term Task Force Report, dated December 6, 2013, the NRC staff recommended that the Commission approve three regulatory improvement activities. In its related staff requirements memorandum (SRM), dated May 19, 2014, the Commission directed the staff to reevaluate the first two regulatory improvement activities in the context of Commission direction on a long-term Risk Management Regulatory Framework. The first two regulatory improvement activities were ultimately resolved in CONTACT: Eric E. Bowman, NRR/DLP 301-415-2963 1
As defined in SECY-01-0121, Industry Initiatives in the Regulatory Process, a Type 2 voluntary industry initiative is one that is developed in response to a potential safety concern that is a potential cost-beneficial safety enhancement outside existing regulatory requirements. Such industry initiatives may be used to provide safety enhancements without the need for regulatory action. However, where it is determined that the proposed industry initiative is not effective in addressing the safety concern, the NRC may pursue rulemaking in accordance with the criteria described in 10 CFR 50.109.
The Commissioners 2
SECY-15-0168, Recommendations on Issues Related to Implementation of Risk Management Regulatory Framework, dated December 18, 2015, and the associated SRM, dated March 9, 2016.
The third of these activities, and the subject of this paper, was to [c]larify the role of voluntary industry initiatives in the NRC regulatory process by specifying when these initiatives may be credited and providing guidance regarding what type and level of licensee documentation and NRC oversight is appropriate for future industry initiatives. With respect to this regulatory improvement activity, the Commission directed the staff to evaluate the current status of implementation on the most risk-or safety-significant Type 2 initiatives and verify that these voluntary initiatives are being adequately implemented. The Commission also directed the staff to provide the results of this verification process and any recommended improvements, if warranted, for its review and approval.
DISCUSSION:
Upon issuance of SRM-SECY-13-0132, the NRC staff performed a screening analysis to identify those initiatives needing further evaluation of their effectiveness. The focus of the staffs evaluation was on the most risk or safety significant Type 2 voluntary industry initiatives. The staff provided the results of this screening analysis in a Note to Commissioners Assistants dated August 27, 2014 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML14239A346). The staff determined that some of these initiatives were being effectively implemented by licensees, while others were being addressed through existing regulatory activities. The NRC staff did, however, identify two initiatives needing further evaluation and committed to providing this paper by June 30, 2018.
The first initiative needing further evaluation addresses safety culture. The staff documented its evaluation of the safety culture initiative in a memorandum dated March 22, 2018 (ADAMS Accession No. ML18078A156) and based on the results of its evaluation, the staff determined that the current process for monitoring and assessing safety culture at nuclear power plants, including the industrys implementation of Nuclear Energy Institute (NEI) 09-07, Fostering a Strong Nuclear Safety Culture, was effective.
The second initiative, which addresses low-power/shutdown risk (shutdown issues), required further evaluation because of its interaction with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ADAMS Accession No. ML12054A736). That order requires mitigating strategies for extreme natural phenomena hazards in low-power and shutdown modes of plant operation. The staff completed its evaluation of this initiative and concluded that no improvements to the industry initiative itself are warranted. However, the staff identified opportunities for improvements in the clarity and efficiency of NRC oversight of this initiative in the Reactor Oversight Process. These improvements include potential updates to inspection procedures, enhanced awareness of the industry initiative, and further monitoring of operational experience on shutdown events. The staff is making these improvements within currently budgeted resources. The staff documented the results of this evaluation in a memorandum dated April 20, 2018 (ADAMS Accession No. ML18113A300).
The Commissioners 3
CONCLUSION:
The NRC staff has completed its evaluation of the current status of implementation of the most risk-or safety-significant Type 2 initiatives and concluded that such initiatives are being adequately implemented and that the Reactor Oversight Process allows for appropriate monitoring of the initiatives. No improvements to the initiatives are warranted at this time.
COORDINATION:
This paper has been coordinated with the Office of the General Counsel, which has no legal objection.
/RA/
Victor M. McCree Executive Director for Operations
ML18141A033 SRM-S13-0132-3
- via email OFFICE NRR/DLP/PBMB NRR/DLP/PBMB/BC QTE*
NAME EBowman MShams JDougherty DATE 5/11/2018 5/16/2018 5/21/2018 OFFICE NRR/DLP/D OGC(NLO)*
NRR/D NAME LLund SClark BHolian DATE 5/24/2018 6/14/2018 6/22/2018 OFFICE EDO NAME VMcCree DATE 06/28/2018