ML20296A555

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October 28-29 Cer Public Meeting Slides - Final
ML20296A555
Person / Time
Issue date: 10/22/2020
From: Osiris Siurano-Perez
Division of Fuel Management
To:
Siurano-Perez O
References
Download: ML20296A555 (107)
v • d • e


Text

Cumulative Effects of Regulation October 28-29, 2020 Public Meeting With Nuclear Energy Institute and Members of the Nuclear Fuel Cycle Industry Osiris Siurano-Perez, Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards Osiris.Siurano-Perez@nrc.gov Tel. 301-415-7827 1

Meeting Category and Public Participation This is a Category 2 meeting. The public is invited to participate in this meeting by discussing regulatory issues with the Nuclear Regulatory Commission (NRC) staff at designated points.

2

Agenda - October 28, 2020 Topic Time Speakers Andrea Kock, Director Division of Fuel Management (DFM)

Office of Nuclear Material Safety and Safeguards (NMSS)

Opening Remarks 12:00 PM U.S. Nuclear Regulatory Commission (NRC)

Janet Schlueter Nuclear Energy Institute (NEI)

Discussion Topics October 28, 2020

  • Integrated Schedule Updates Presenters:
  • Fall Exemptions and Feedback on Exemption Process Leira Cuadrado, Branch Chief, DFM
  • Industry-Generated Inspection Program Topics NEI Letter 689, IMC 0616 Examples Karl Sturzebecher, Project Manager, DFM Credit/Flexibility for Good Performance
  • BREAK
  • Status of Smarter Licensing Program Teams Work Andrea Kock, DFM Summary of Day 1 Proceedings and Discussions 5:15 PM Janet Schlueter, NEI Osiris Siurano-Perez Adjourn 5:30 PM Project Manager, DFM 3

Opening Remarks Andrea Kock, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards Janet Schlueter Nuclear Energy Institute 4

Integrated Schedule Chart and Supplement Updates Osiris Siurano-Perez Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 5

Integrated Schedule Chart and Supplement Updates

  • Updated October 21, 2020

- List of regulatory activities remains unchanged

- Four areas with minor changes/updates on both documents

Contact:

Osiris Siurano-Perez NMSS/DFM/FFLB 301-415-7827 6

Integrated Schedule Chart Updates

  • Part 61 - Low-level Waste Disposal

- New contact: George Tartal, 301-415-0016

  • Part 73 - Enhanced Security for SNM

- Reflect status as of October 2020

- Reflect status as of October 2020

  • Enhanced Weapons

- New contact: Martha Barillas, 301-415-2460

Contact:

Osiris Siurano-Perez NMSS/DFM/FFLB 301-415-7827 7

Integrated Schedule Chart Updates 2019 2020 2021 2022 Comments De c

No vOct Sep tAu g

Jul y

Jun eMa y

Apri l

Mar cFeb Regulatory Activity Revised crJan lDe c

No vOct Sep tAu g

Jul y

Jun eMa y

Apri Mar Feb rJan De c

No vOct Sep tAu g

Jul y

Jun eMa ly Apri Mar cFeb rJan De c

No vOct Sep tAu g

Jul y

Jun eMa ly Apri Mar cFeb rJa n

The staff is currently considering Part 61 - LLW Disposal options for moving forward with 10/21/2020 this and the GTCC rulemaking POC: George Tartal and make its recommendations to the Commission.

Part 73-Enhanced Security for SNM POC: Ed Lohr/Kevin Ramsey l 10/21/2020 Awaiting Commission direction.

Enhanced Weapons Rulemaking POC: Martha Barillasl/Kevin Ramsey 10/21/2020 l Awaiting Commission direction.

Part 73-Cyber Security Rulemaking Draft rule has been completed.

POC: Ed Lohr/James Downs 10/21/2020 Awaiting Commission direction -

SECY-17-0099.

ANS 57.11 (ISA)

POC: April Smith 10/21/2020 No changes identified.

Regulatory Information Conference Presentations prepared for POC: Haile Lindsay 10/21/2020 sessions of fuel cycle interest RIC Session are available online.

Working Group Recommendations Smarter Licensing Charter Final Report - April 30, 2020; Public 10/21/2020 *

  • I POC: Donnie Harrison/Karl Sturzebecher Version of Smarter Licensing Action Plan and Project Status - July 10, 2020 Working Group Final Report -

Smarter Inspection Charter

  • I issued March 18, 2020; 10/21/2020 POC: Alayna Pearson Implementation plan -

issued July 8, 2020.

= Reg. Basis/Draft Guidance = Proposed Rule/Draft Guidance = Final Rule/Final = Public Interaction Guidance

= Implementation = Non-rulemaking/NRC = Pending Commission Action Activities = Final Report Issued

= Site Visit A = ACRS Meeting

Contact:

Osiris Siurano-Perez NMSS/DFM/FFLB 301-415-7827 8

8

Integrated Schedule Supplement Updates

  • Part 61, Low-level Waste Disposal

- Key contact George Tartal replaces Martha Barillas

  • Enhanced Weapons Rulemaking

- Key contact Martha Barillas replaces Robert Beall

Contact:

Osiris Siurano-Perez NMSS/DFM/FFLB 301-415-7827 9

Integrated Schedule Supplement Updates (continued)

  • American Nuclear Society Standard 57.11

- Key information Proposal to issue the standard for trial use only

  • Regulatory Information Conference

- Key contact Haile Lindsay replaces Richard Jervey

- Key information Potential topics for the 2021 RIC listed

Contact:

Osiris Siurano-Perez NMSS/DFM/FFLB 301-415-7827 10

Integrated Schedule Supplement Updates (continued)

  • Smarter Inspection Program

- Related documents Reference NEI letter 689 dated July 24, 2020

Contact:

Osiris Siurano-Perez NMSS/DFM/FFLB 301-415-7827 11

Updates to Integrated Schedule Chart and Supplement

  • Updated information

- Cumulative Effects of Regulation https://www.nrc.gov/materials/fuel-cycle-fac/regs-guides-comm.html#cumeffects

- Integrated Schedule (Chart) https://www.nrc.gov/docs/ML2029/ML20293A421.pdf Summary of the changes July - October 2020 o ADAMS Accession Number ML20294A059

- Integrated Schedule Supplement https://www.nrc.gov/docs/ML2029/ML20293A422.pdf Markup with updates July - October 2020 o ADAMS Accession Number ML20293A423

Contact:

Osiris Siurano-Perez NMSS/DFM/FFLB 301-415-7827 12

Updates to Integrated Schedule Chart and Supplement QUESTIONS/COMMENTS 13

NRC COVID-19 Response Remote & Follow Up On-Site Inspection Feedback & Lessons-Learned Roundtable Discussion NRC Staff/Nuclear Energy Institute/Industry 14

NRC COVID-19 Response Path Forward Kevin Ramsey Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 15

COVID Relief Path Forward NRC staff will continue to process requests for relief as they are received. Requests for relief extensions must explain why licensee cannot comply with a requirement, explain how safety will be ensured, demonstrate good faith effort to return to compliance, and address degradation of conditions over time.

  • Letter re: Methods for Providing Regulatory Relief During the 2019 Public Health Emergency, ML20094G166.
  • Temporary Staff Guidance - Fuel Facility Regulatory Relief Requests Related to COVID-19, ML20108E911.
  • Several letters on acceptable bases for granting relief from various regulations.

Contact:

Kevin Ramsey NMSS/DFM/FFLB 301-415-7506 16

COVID Relief Path Forward QUESTIONS/COMMENTS 17

Fall Exemptions and Feedback on Exemption Process Nuclear Energy Institute 18

Fall Exemptions and Feedback on Exemption Process QUESTIONS/COMMENTS 19

Guidance for Material Control and Accounting Plan Required for Special Nuclear Material of Moderate Strategic Significance James Rubenstone Branch Chief Material Control and Accounting Branch Chief Division of Fuel Management Office of Nuclear Material Safety and Safeguards 20

Guidance for Material Control and Accounting Plan Required for Special Nuclear Material of Moderate Strategic Significance - NUREG-2159

  • Issue for public comment - 60 days

- January 2021

  • Incorporate/address public comments

- Completed by April 2021

  • Issue final document

- May 2021

Contact:

James Rubenstone NMSS/DFM/MCAB 301-415-7231 21

Guidance for Material Control and Accounting Plan Required for Special Nuclear Material of Moderate Strategic Significance - NUREG-2159 QUESTIONS/COMMENTS 22

Industry-Generated Inspection Program Topics Leira Cuadrado Branch Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Eric Michel Branch Chief Division of Fuel Facility Inspection Projects Branch 2 Chief U.S. Nuclear Regulatory Commission Region II 23

Main Discussion Topics

  • Regulatory Requirements

- Fuel Facility Program Violations Performance Requirements Management Measures

  • Inspection Guidance

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 24

Regulatory Requirements

  • 10 CFR 70.61(e) - Each engineered or administrative control or control system necessary to comply with paragraphs (b), (c), or (d) of this section shall be designated as an item relied on for safety. The safety program, established and maintained pursuant to § 70.62 of this subpart, shall ensure that each item relied on for safety will be available and reliable to perform its intended function when needed and in the context of the performance requirements of this section

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 25

Regulatory Requirements

  • 10 CFR 70.62(d) - Management measures. Each applicant or licensee shall establish management measures to ensure compliance with the performance requirements of § 70.61. The measures applied to a particular engineered or administrative control or control system may be graded commensurate with the reduction of the risk attributable to that control or control system.

The management measures shall ensure that engineered and administrative controls and control systems that are identified as items relied on for safety pursuant to § 70.61(e) of this subpart are designed, implemented, and maintained, as necessary, to ensure they are available and reliable to perform their function when needed, to comply with the performance requirements of § 70.61 of this subpart.

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 26

Fuel Facility Program Violations Performance Requirements and Management Measures

  • A noncompliance such as the failure to meet 70.61(e) and 70.62(d) with respect to management measures can exist even when the performance requirements 70.61(b) & (c) are satisfied.
  • Additional margin afforded by additional IROFS to what is needed to meet performance requirements 70.61(b) & (c) is already considered in determining the significance of a violation

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 27

Fuel Facility Program Violations Performance Requirements and Management Measures

  • A failure to meet the requirements of 10 CFR 70.61 (b) and (c) results in escalated enforcement
  • A failure to meet the requirements of 10 CFR 70.61 (e) and 70.62 (d) will likely result in a SL IV or minor violation if the requirements of 70.61 (b) and (c) are met

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 28

The NRC Enforcement Policy

- Escalated enforcement when performance requirements are not met

- Severity Level IV or minor: if safety margin exists, (IMC 0616 assist in this screening)

- Enforcement Policy Section 2.3.1 Minor Violation Provisions for documenting minor violations can be found in the NRC Enforcement Manual, ... IMC 0616

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 29

Inspection Manual Chapter 0616

  • The 2017 changes to this IMC provided additional guidance and examples for screening minor/more than minor (SL-IV) to increase consistency and transparency in documenting and dispositioning of violations

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 30

Fuel Facility Inspection Program Guidance

  • IMC 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program
  • IMC 0616, Fuel Cycle Safety and Safeguards Inspection Reports
  • IMC 2606, Assessment of the Risk Resulting from a Potential Safety Noncompliance at a Fuel Cycle Facility
  • IMC 2650, Fuel Cycle Inspection Assessment Program

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 31

Inspection Manual Chapters/Inspection Procedures Revision Process

  • Significant public involvement in staff's assessment of the fuel cycle inspection oversight program
  • Currently, revising all the fuel cycle inspection program procedures to implement smarter inspection program working group recommendations
  • Staff continues to provide implementation updates

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 32

Discussion Topics

- IMC 0616 examples

  • Credit for good performance presentation

- Examples of criteria

- What constitutes good performance?

Contact:

Contact:

Leira Cuadrado Eric Michel NMSS/DFM/IOB RII/DFFI 301-415-0324 404-997-4555 33

Industry-Generated Inspection Program Topics QUESTIONS/COMMENTS 34

Flexibility to Smarter Core Inspection Program for Good Performance Nuclear Energy Institute 35

Flexibility to Smarter Core Inspection Program for Good Performance October 28, 2020

©2020 Nuclear Energy Institute

Background

April 2019 - NRC Formed WG to Perform Holistic Assessment of Fuel Cycle Oversight Program April-December 2019 - Multiple Public Meetings March 2020 - WG Implementation Plan with Recommendations for Notable Adjustments to IMC 2600 & Appendix B April & July 2020 - Public Meetings on Project & Status October 2020 - Await NRC Proposed Revisions to IMCs and Related IPs

©2020 Nuclear Energy Institute 37

Inspection Program Principles Comprehensive NRC Oversight Program is Key Attribute of NRCs Principles of Good Regulation Risk and Performance-Based Insights Justify Efficiencies to Smarter Core Inspection Program Continued Use of Special or Reactive Inspections Industry Respectfully Submits there Remains Potential Improvements with Regard to Flexibility of the Smarter Core Based on Licensee Performance

©2020 Nuclear Energy Institute 38

Fuel Cycle Fleet Risk Profile Low Risk Profile in Many Program or Functional Areas, e.g.,

Radiation & Environmental Protection - Low and Decreasing Doses to Worker and Public; Effective ALARA Programs Material, Control & Accounting - Low Strategic Significance of Category III Facilities Material Waste Management - Facilities Continue Reducing Production and Volume of LLRW Transportation - Industrys Excellent Safety Record on Thousands of Shipments, e.g., LLRW, Nuclear Fuel, Radiation Sources

©2020 Nuclear Energy Institute 39

Concept of Flexible Adjustments Use Existing LPR Process to Assess and Evaluate Each Licensee in its Normal Review Cycle:

  • Determine Whether Flexible Adjustments Can be Applied to Reduce Frequency and/or Duration of Smarter Core Inspection Program During Each LPR, Staff Collects Performance Data to Include But Not Limited to:
  • Number of Violations, Reportable Events, and Both Self-Identified and Self-Revealing Safety or Security Events Review to Include Inspection Results and Consider NRC Observations as Recorded

©2020 Nuclear Energy Institute 40

Examples of Criteria* for Determining Potential Flexible Performance Based Adjustments

  • No Escalated Violations (i.e., > SL III)
  • Low Worker and Public Doses
  • If Licensee has Comprehensive CAP,
  • ISAs Rely on Defense-in-Depth (e.g.,

Minor, Non-Cited and SL IV Violations > 2 IROFS) or Performance Criteria Would Not Negatively Impact Margin Consideration of Adjustments

  • Robust Management Measures
  • Reportable Events that Do Not Result Result in Available and Effective in Significant Violations Would Not IROFS Negatively Impact Consideration of
  • Effective Self or Independent Adjustments Assessments Would be Additional
  • Low Number of Contamination, Basis for Consideration of Adjustment Waste Management or Transportation
  • Continued or Repetitive Periods of Events Performance under LPR Resulting in an Area not Needing Improvement
  • Single, Stand-Alone Criteria

©2020 Nuclear Energy Institute 41

Suggested Flexible Adjustments to Smarter Core Inspection Program Frequency or Duration of IP Would Be Reduced by 50% in a Given Area if:

  • 2 or More Sequential LPRs With No Improvement Needed
  • Zero Significant Violations Flexibility in a Given Area Can Be Waived (i.e., Not Granted) if There is a Formally NRC-Identified Generic Safety or Security Concern Across the Industry Adjustments Are Not Cumulative, i.e., Flexibility Must Be Earned Each LPR Period Special and Reactive Inspections Are Independent of Any Flexible Adjustments and Can Be Basis of Revocation of Any Flexibility

©2020 Nuclear Energy Institute 42

Future Actions Continue Public Dialogue to Reach Common Ground on Principles of Performance Based Adjustments Solicit Stakeholder Input for Assessment of Potential Changes Consider Whether Piloting Flexible Adjustments is Worthwhile Determine Timeline and Decision Points for Project Thank You!!

©2020 Nuclear Energy Institute 43

Acronyms ALARA - As Low As Reasonably Achievable CAP - Corrective Action Program IMC - Inspection Manual Chapter IP - Inspection Procedure IROFS - Items Relied on For Safety ISA - Integrated Safety Analysis LLRW - Low-Level Radioactive Waste LPR - License Performance Review SL - Severity Level WG - Working Group

©2020 Nuclear Energy Institute 44

Industry-Generated Inspection Program Topics QUESTIONS/COMMENTS 45

Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments on the following topics:

- Integrated Schedule Updates

- NRC COVID-19 Response

- Fall Exemptions/Feedback on Exemption Process

- Status of Draft NUREG-2159 on Cat II MC&A

- Industry-Generated Inspection Program Topics 46

Status of Smarter Licensing Program Teams Work Karl Sturzebecher Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 47

Smarter Licensing Program Objective: Implement recommendations with the best cost-benefit perspective

  • Status

- Near Term recommendations are nearing completion

- Mid and Long Term action teams continue working on assigned recommendations

- The recommendation improvements apply to each step of the licensing process

  • Licensing Process demonstration (Next slide)
  • Smarter Licensing Improvements to NRC guidance (Final slide)
  • Schedule - Close Out: schedule, impact, benefits achieved & lessons learned

- Near-Term by December 2020

- Mid-Term by March 2021

- Long-Term by January 2022

Contact:

Karl Sturzebecher Organization NMSS/DFM/FFLB 301-415-8534 48

Licensing Process Public Access Pre- Application Reviewed SER RAIs Finalize Draft Action Send Start Application & Acceptance Outline Needed in Approval Close Out Submitted SER Assigned Letter Drafted  ? Concurrence Letter YES RAI Path is Technical or Environmental Public Access YES YES Develop Call to 1st Issue of RAIs 2nd Round Resolved of RAIs Resolve RAIs Response

? RAIs Staggered Review Public Access

Contact:

Karl Sturzebecher Organization NMSS/DFM/FFLB 301-415-8534 49

Licensing Process NT1_3 *Enhance communication practices with the licensee NT1_29 *Improve early processing alignment & communicate scope, focus & level of detail NT1_6a -(NEI) *Involve COEs & Office input for milestones NT1_1 -(NEI) *Communicate input & milestones with licensee NT1_2 *Communicate estimated hours with licensee NT2_4 *Support pre-application review meeting NT2_27 *Lead risk-informed & holistic NRC team meeting before pre-application meeting NT2_7b *Conduct pre-application meeting @ site

Contact:

Karl Sturzebecher Organization NMSS/DFM/FFLB 301-415-8534 50

Licensing Process NT4_8 -(NEI)*Clear basis NT4_12 - (NEI) *Division management concurs on 2nd NT4_9a -(NEI) round RAIs

  • Share RAIs NT4_7a *Site visit for RAIs NT4_11 NT4_9b - (NEI)
  • Clarifying call
  • Review draft response NT4_10(P1) *Add guidance on RAIs on review timing NT3_10(P2) *RAI staggered review tool in WBL

Contact:

NT4_13a -(NEI) NT4_22 *Scope RAI dashboard needs Karl Sturzebecher *Staff Turnover for future work group Organization NMSS/DFM/FFLB 301-415-8534 51

Licensing Process NT3_5&28 *Add guidance on combining acceptance with approval NT3_17 *Ensure WBL planning & tracking tool can address metrics requirements

Contact:

Karl Sturzebecher Organization NMSS/DFM/FFLB 301-415-8534 52

Licensing Process MT1_29 *Develop job aids types for early MT1_31 *Develop job aids for risk-alignment, focus, documenting, & informing with support questions communicate with licensee MT1_30 *Develop job aids types for MT1_27 *Improve review guidance risk-informing reviewers and decision makers for an early holistic approach MT1_15 *Develop job aids considering per review level applicability MT1_18 *Develop guidance for best job aid/instructions that apply to a review MT1_25 *Incorporate into guidance to include Inspectors involvement MT1_21 *Augment guidance so review approach is cited in the SER

Contact:

Karl Sturzebecher Organization NMSS/DFM/FFLB 301-415-8534 53

Smarter Licensing Improvements Early communications Metric tracking improvements Accurate assessment of the request WBL scheduling improvements Transparent milestone and charges Fast track acceptance to close out Pre- Application Reviewed SER RAIs Finalize Draft Action Send Start Application & Acceptance Outline Needed in Approval Close Out Submitted SER Assigned Letter Drafted  ? Concurrence Letter YES RAI Path is Technical or Environmental Step up early communications NRC pre-application teaming YES YES Alignment and Assignment 2nd Round Accomplish in a holistic manner Develop RAIs Call to Resolve 1st Issue of RAIs RAIs

Response

Resolved of

?

Site visits RAIs Staggered Review Early RAI discussion Discussion on RAI response Transparency to inform and resolve Management addresses 2nd round RAI

Contact:

Karl Sturzebecher Organization Support job aids & guidance NMSS/DFM/FFLB Focus is NT1 and NT2 301-415-8534 54 54

Status of Smarter Licensing Program Teams Work QUESTIONS/COMMENTS 55

Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments on the following topic:

- Status of Smarter Licensing Program Teams Work 56

Cumulative Effects of Regulation Summary of Proceedings October 28, 2020, Session Osiris Siurano-Perez Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 57

Meeting Category and Public Participation This is a Category 2 meeting. The public is invited to participate in this meeting by discussing regulatory issues with the Nuclear Regulatory Commission (NRC) staff at designated points.

58

Agenda - October 29, 2020 Topic Time Speakers Andrea Kock, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards (NMSS)

Opening Remarks 10:00 AM U.S. Nuclear Regulatory Commission (NRC)

Janet Schlueter Nuclear Energy Institute (NEI)

Discussion Topics October 29, 2020 Presenters:

Leira Cuadrado, Branch Chief, DFM

  • Status of Inspection Modifications Kevin Ramsey, Project Manager, DFM
  • Operating Experience Program 10:10 AM Donnie Harrison, Sr. Level Advisor for Risk Assessment, DFM
  • Status of Non-Fee Billable Work
  • Status of Efforts on Low Safety Significance Issues

Cumulative Effects of Regulation Public Meeting With Nuclear Energy Institute and Members of the Nuclear Fuel Cycle Industry October 29, 2020 Opening Remarks Andrea Kock, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards Janet Schlueter Nuclear Energy Institute 60

Smarter Inspection Program Status of Inspection Modifications Leira Cuadrado Branch Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 61

Smarter Inspection Program Status of Inspection Modifications

  • Working Group (WG) conducted a holistic assessment of the fuel cycle oversight program to:

- Improve effectiveness and efficiency

- Further integrate risk-informed insights to ensure that the appropriate focus is applied to the areas most important to safety

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 62 62

Smarter Inspection Program Enhancement Effort

  • Revise fuel cycle inspection guidance documents

- Adjust the frequency of inspections + number of hours, according to the risk of the activity

- Reduce inspection frequency for facilities with an approved corrective action program

  • Train inspectors with revised guidance documents, with full implementation starting January 2021
  • Complete assessment of the scope of the resident inspector program

- Formalize process to incorporate operating experience into inspection program after revision of inspection guidance documents

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 63 63

Smarter Inspection Program Revision Process HQ resolves Revise Guidance Technical Staff Technical Staff Technical Staff Document Review Concurrence Comments HQ resolves Branch Chief Branch Chief Branch Chief Concurrence Review Comments (HQ + Regions)

HQ resolves Issuance of DFM Director DFM Director DFM Director Guidance Review Concurrence Comments Document

Contact:

Leira Cuadrado  : May involve multiple iterations back and forth NMSS/DFM/IOB 301-415-0324 64 64

Smarter Inspection Program Status of Revisions

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 65 65

Smarter Inspection Program Proposed Changes

  • IP 88135: Resident Inspector Program

- Adjust inspections to focus on areas of higher risk-significance Utilizing the Integrated Safety Analysis Emergent plant issues Current equipment problems

- Approximately 752 hours0.0087 days <br />0.209 hours <br />0.00124 weeks <br />2.86136e-4 months <br /> of direct inspection, with variance of + 10%

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 66 66

Smarter Inspection Program Proposed Changes

  • IP 88135: Resident Inspector Program (continued)

- Rewrites to IP 88135 Attachments to align with recommendations

- Consolidation of the Identification and Resolution of Problems guidance to IP 88135.02, Plant Status, only, to eliminate duplication in remaining IP 88135 Attachments

- NRC staff will pilot incorporating issues of low safety significance as part of the IP revisions

  • Formal assessment of the resident program to be completed in 2021

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 67 67

Smarter Inspection Program Proposed Changes (continued)

  • IP 88045: Environmental Protection

- Inclusion of aspects from IP 88030, Radiation Protection

- Additional scope related to decommissioning planning during operations

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 68 68

Smarter Inspection Program Proposed Changes (continued)

  • IMC 2600: Fuel Cycle Facility Operational Safety and Safeguards Inspection Program

- Flexibility for remote oversight activities

- New Appendix E to IMC 2600 Guidance for inspections during pandemics and other wide-spread illnesses Incorporates guidance issued for COVID-19

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 69 69

Smarter Inspection Program Proposed Changes (continued)

  • Retirement of Guidance Documents Retiring Guidance Documents Information to Be Incorporated Into IP 88025, Maintenance and Surveillance
  • IP 88020, Operational Safety of Safety Controls
  • IP 88030, Radiation Protection Handling, Storage, and Transportation
  • IP 88045, Effluent Control and Environmental Protection

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 70 70

Smarter Inspection Program QUESTIONS/COMMENTS 71

Fuel Cycle Operating Experience Program Leira Cuadrado Branch Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards 72

Fuel Cycle Operating Experience Program

  • Overview

- Background

- Fuel Cycle (FC) Operating Experience (OpE)

Program Purpose

- FC OpE Program Description

- FC OpE Data Evaluation Process

- OpE Program Products

- Future OpE

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 73

Fuel Cycle Operating Experience Program

  • OpE Program Purpose

- Collect, evaluate, and trend OpE for continuous improvement of regulatory processes

  • OpE Components

- Implementing procedures and guidance for the data screening process using NMSS P&P 6-14, Fuel Cycle Operating Experience Program

- Database

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 74

Fuel Cycle Operating Experience Program Event Notification Domestic OpE OpE Data International OpE

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 75

Fuel Cycle Operating Experience Program Step 2 Step 1 OpE Data Event Sub-Performance Area categorization Step 5 Step 4 Step 3 Reporting Contributing Level of Safety Requirements Factors Significance

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 76

Fuel Cycle Operating Experience Program Screening Step 1: Performance Area

  • Criticality Safety
  • Operational Safety

- Chemical Hazard

- Fire Hazard

  • Radiation Protection Program

- Occupational

- Public

  • Material Control and Accounting (MC&A)

- Shipping

- Onsite

  • Natural Phenomena Hazard (NPH)
  • Construction

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 77

Fuel Cycle Operating Experience Program Screening Step 2: Sub-Categories

  • The sub-categories provide additional screening criteria to describe specific traits of the event and are available as searchable terms in the FC OpE database.

Failure (Initiating Event)

Structure System or Unplanned Other - This could be Components (SSC) Medical modified as we Treatment received information Yes No Chemical Injury (

e.g., ocular or dermal exposure to Procedural chemicals)

IROFS Control IROFS Control Operational ( e.g.,

thermal burn, (Criticality) Administrative Radiologi injury while Passive Active Double cal operating)

Contingency Control Personal ( e.g.,

Chemical heart attacks, Criticality Control low sugar, Control fainting)

Over Chemical Exposure to a Radiological Control Control Worker

Contact:

Fire Leira Cuadrado Fire Control NMSS/DFM/IOB Control 301-415-0324 78

Fuel Cycle Operating Experience Program Screening Step 3: Level of Safety Significance

  • Level A: An event that resulted in or could have resulted in consequences commensurate with a high consequence event as defined by 10 CFR 70.61, Performance Requirements, as a result of licensed materials or hazardous chemicals produced from licensed materials.
  • Level B: An event that resulted in or could have resulted in consequences commensurate with an intermediate-consequence event as defined by 10 CFR Part 70.61. These events usually include escalated enforcement actions, such as Severity Level III violations and may include multiple Level C events of a similar nature.
  • Level C: An event that is less serious than a Level B event and resulted in a low safety consequence. These events can include Severity Level IV violations, Non-Cited Violations, Minor Violations and events with no associated violations.

Safety significance Level C should not include escalated violations.

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 79

Fuel Cycle Operating Experience Program Screening Step 4: Contributing Factors

  • Maintenance
  • Procedures and Work Packages
  • Configuration Management (CM)
  • Design
  • Training and Qualifications
  • Human Factors
  • Integrated Safety Analysis (ISA)
  • Not Applicable (N/A)

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 80

Fuel Cycle Operating Experience Program Screening Step 5: Reporting Requirements

  • The FC OpE Program applies procedures for event reporting to determine if an event is reportable by the NRC
  • Reporting Material Events to the International Nuclear Event Scale
  • Abnormal Occurrences Reporting

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 81

Fuel Cycle Operating Experience Program Trending Analysis Performance Areas Level of Safety Significance Contributing Factors RESULTS

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 82

Fuel Cycle Operating Experience Program Program products

  • Primary

- Generates the annual FC OpE report.

- Supports international event reporting activities (e.g., FINAS, INES)

  • Secondary

- Provides a source of information to support continuous improvement of the regulatory processes and oversight program

- Supports the development of generic communication for internal and external stakeholders

- Assists the process for generating or reviewing guidance documents

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 83

Fuel Cycle Operating Experience Program 2019 Fuel Cycle OpE Report - ML20010E782

  • A total of 21 events were reported

- 4 events were retracted

- 8 events were reported under 10 CFR 70 Appendix A (c)

Concurrent Report

- 9 events to analyze Criticality safety (3)

Chemical processes (2)

Fire safety (2)

MC&A (2)

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 84

Fuel Cycle Operating Experience Program Future of OpE

  • The WG recommends formalizing into the inspection program the results of the Operating Experience Program and the Fuel Cycle Inspection Assessment Program to determine, on a frequent basis, if changes to core inspection program are needed.

Smarter Inspection Program Report - ML20073G659

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 85

Fuel Cycle Operating Experience Program Future of OpE (continued)

  • Benchmark other programs, including ROP and materials

- Scope and data sources

- How feedback is incorporated into inspection program

  • Obtain stakeholder feedback

- How does industry use operating experience?

What sources of data are considered?

How are the insights or results of your operating experience program leveraged?

Contact:

Leira Cuadrado NMSS/DFM/IOB 301-415-0324 86

Fuel Cycle Operating Experience Program QUESTIONS/COMMENTS 87

Status of Non-Billable Work Kevin Ramsey Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards 88

Self-Assessment of Non-Billable Work in the Fuel Facilities Business Line

  • Self-Assessment Report issued April 15, 2019
  • Closure Report for Corrective Actions issued December 23, 2019
  • Effectiveness Review Report issued August 4, 2020
  • Charges without Enterprise Project Identifier

- Licensing declined from 97% to 50%

- Oversight declined from 99% to 36%

- Rulemaking declined from 64% to 54%

Contact:

Kevin Ramsey NMSS/DFM/FFLB 301-415-7506 89

New Billable Cost Accounting Code for Routine Inspection Related Communications

  • Self-Assessment identified inconsistent billing between Project Managers (PMs) and Project Inspectors (PIs)
  • Both perform similar duties (schedule management, routine communications, briefing packages, etc.)
  • PM time billed, but PI time not billed
  • Operating Reactor business line uses billable code for routine inspection related communications
  • We have defined a new CAC 001710 (FB-FF-Routine Inspection Related Communications)

Contact:

Kevin Ramsey NMSS/DFM/FFLB 301-415-7506 90

Status of Non-Billable Work in the Fuel Facilities Business Line

  • Product Line 1 - Event Response (1786 hours0.0207 days <br />0.496 hours <br />0.00295 weeks <br />6.79573e-4 months <br />)

- Event Response Operations

- Incident Response Exercises

  • Product Line 2 - Generic Homeland Security (Off Fee Base)
  • Product Line 3 - International Activities (9475 hours0.11 days <br />2.632 hours <br />0.0157 weeks <br />0.00361 months <br />)

- Conventions & Treaties

- Import/Export Licensing

- International Cooperation

- International Liaison

Contact:

Kevin Ramsey NMSS/DFM/FFLB 301-415-7506 91

Status of Non-Billable Work in the Fuel Facilities Business Line

  • Product Line 4 - Licensing (16,950 hours0.011 days <br />0.264 hours <br />0.00157 weeks <br />3.61475e-4 months <br />)

- Emergency Preparedness (EMP Activities, etc.)

- Codes and Standards Meetings

- Develop and Maintain Licensing Guidance (Cat II MC&A, Smarter Licensing, Critical Mass SRP, etc.)

- Environmental Reviews (Environmental Center of Expertise, Licensing Assistant Support, etc.)

- Non-Billable Licensing Actions (Licensing Assistant Support, Technical Assistant Duties, CER Program, Fee Exempt Universities, etc.)

- Policy Outreach (Evidence Act Working Group, etc.)

- Security (MOU with DHS and DOT, Advance Notice of Shipments, etc.)

Contact:

Kevin Ramsey NMSS/DFM/FFLB 301-415-7506 92

Status of Non-Billable Work in the Fuel Facilities Business Line

  • Product Line 5 - Oversight (23,247 hours0.00286 days <br />0.0686 hours <br />4.083995e-4 weeks <br />9.39835e-5 months <br />)

- Allegations & Investigations

- Enforcement (Enforcement Policy Revision, etc.)

- Codes and Standards Document Review

- Develop & Maintain Inspection Guidance (Risk-Informed Inspection Program, Low Safety Significance Issue Resolution, etc.)

- Enforcement Related Order Follow-up (GNFA, BWXT, etc.)

- Inspection (Project Inspector Duties, Smarter Inspection Program, DFFI Office Tasks, Technical Assistant Duties, etc.)

- Security (Project Inspector Duties, Accepting Risk in Decision-making, DFFI Office Tasks, etc.)

Contact:

Kevin Ramsey NMSS/DFM/FFLB 301-415-7506 93

Status of Non-Billable Work in the Fuel Facilities Business Line

  • Product Line 7 - Rulemaking

- Pre-Rulemaking (COVID-19 response, FY 2021 Fee Rule, etc.)

- Proposed Rules (Cyber Security for Fuel Facilities, etc.)

- Final Rules (Enhanced Weapons, FY 2020 Fee Rule, etc.)

- Rulemaking Support (Post rulemaking for Part 74, Administrative Support, etc.)

  • Product Line M - Support Staff (25,282 hours0.00326 days <br />0.0783 hours <br />4.662698e-4 weeks <br />1.07301e-4 months <br />)

- Non-Supervisory Staff (NextGen Activities, Fee Billing Support, Staff Meetings, etc.)

- Supervisory Staff

- Administrative Assistants

Contact:

Kevin Ramsey NMSS/DFM/FFLB 301-415-7506 94

Status of Non-Billable Work in the Fuel Facilities Business Line QUESTIONS/COMMENTS 95

Status of Efforts on Low Safety Significance Issues Donnie Harrison Senior Level Advisor Division of Fuel Management Office of Nuclear Material Safety and Safeguards 96

Status of Efforts on Low Safety Significance Issues What is being addressed?

  • Low safety significant issues that, in some Low Safety cases, result in an excessive effort Significant (resources and time) to resolve Issue Resolution What is the objective?

(LSSIR)

  • Put in place process enhancements to mitigate (risk-inform) these situations

Contact:

Donnie Harrison NMSS/DFM 301-415-2470 97

Status of Efforts on Low Safety Significance Issues

Background

  • Through 2019/2020 NRR led an effort on LSSIR

- Provided approach and recommendations (subsequently approved by NRR Office director) on approach to address these issues

- Implemented concept and used a handful of times

- Concept could also apply in NMSS; with some modifications

- Identified activities pursuing similar intent over multiple business lines

Contact:

Donnie Harrison NMSS/DFM 301-415-2470 98

Status of Efforts on Low Safety Significance Issues Background (continued)

  • NMSS working team formed with staff across business lines to share insights on implementing a consistent approach while recognizing differences in business lines

- Andrea Kock (NMSS Leadership Champion)

- Alayna Pearson (DFM)

Contact:

Donnie Harrison NMSS/DFM 301-415-2470 99

Status of Efforts on Low Safety Significance Issues Concept of the Universe of Issues Evaluate issue to determine regulatory Address issue with appropriate Safety Safety Significant Significant actions: regulatory tools:

  • Generic Issue Screening
  • Enforcement Existing Processes;
  • Order
  • Order Continual Improvement
  • Consider Prompt Corrective
  • TAR Action Clearly NOT in Licensing Basis Clearly in Licensing Basis Limited effort that issue is likely Address issue with appropriate tools (achieve outside licensing basis & is of low compliance or change licensing basis) such as:

safety significance:

  • Corrective Action
  • Stop Pursuing to Full Resolution
  • Document Decision with Bases
  • Change Licensing Basis (72.7 Exemption, 72.56
  • Re-focus Resources Amendment, etc.) Longer-Term Low Safety
  • Change Requirement (Rulemaking)

Solutions Ripe for Near-Term Gains Significant

Contact:

Donnie Harrison NMSS/DFM 301-415-2470 100

Status of Efforts on Low Safety Significance Issues

  • The licensee argues Inspector Not clear if its it is not required Identifies required per per licensing bases Issue licensing bases and provides Continue Normal justification Inspection Processes Inspector evaluates licensee argument (nominal
  • Inspector can invalidate effort) licensees position
  • Inspector cannot invalidate licensees Determine position; not clear if its Safety required per licensing Significance bases Follow Normal Document Very Inspection Low Safety Very Not (& URI/TAR)

Significance Low Very Processes & Include Without Pursuing Issue Documentation

Contact:

Low Full Resolution Donnie Harrison NMSS/DFM 301-415-2470 101

Status of Efforts on Low Safety Significance Issues QUESTIONS/COMMENTS 102

Regulatory Information Conference 2021 Haile Lindsay Thermal Engineer Division of Fuel Management Office of Nuclear Material Safety and Safeguards 103

Regulatory Information Conference 2021 March 8 - 11, 2021 Potential Panel Panel DFM Point Panel Panel Topics Panelists Type Chair of Contact Sessions Front and NRC (NMSS Discussion Marilyn Ricardo Back End Preparations and RES), Diaz Torres ATF (joint for licensing EPRI, NEI, with NRR ATF DOE lead)

Preparing Preparations NRC, DOE, Jonathan for for advanced Fuel Vendor, Discussion Tom Boyce Marcano Advanced reactor fuels DOT Reactor (front and Fuels back end)

Contact:

Haile Lindsay NMSS/DFM/CTCFP 301-415-0616 104

Regulatory Information Conference 2021 QUESTIONS/COMMENTS 105

Public Participation At this time, the public is afforded an opportunity to ask questions and/or provide comments on the following topics:

- Status of Inspection Modifications

- Operational Experience

- Status of Non-Fee Billable Work

- Status of Efforts on Low Safety Significance Issues

- Regulatory Information Conference 2021 and Fuel Cycle Topics 106

Closing Remarks Andrea Kock, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards Janet Schlueter Nuclear Energy Institute 107

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