ML19163A273

Enclosure 3 - Smarter NRC Programs - NEI Presentation Slides - Industry Input May 2019

ML19163A273
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/31/2019
From:	Nuclear Energy Institute
To:	Mark King, Ladonna Suggs Office of Nuclear Material Safety and Safeguards, NRC/RGN-II
Marcano J
References
Download: ML19163A273 (10)

Text

Building Smarter NRC Inspection and Licensing Programs - Industrys Input and Perspectives NEI and its Fuel Cycle Facility Members NRC Public Meeting May 2019

© 2019 Nuclear Energy Institute

GUIDING PRINCIPLES Atomic Energy Act Reasonable Assurance of Adequate Protection NRC Principles of Good Regulation SECY-18-0060 Achieving Modern Risk-Informed Regulation NMSS Dapas Memo 2

CURRENT REGULATORY PROGRAM IS NOT BROKEN Strong and Efficiencies Can Be Gained Improving Industry

• Benchmark with Others Performance

• Strong Project Management to Over Decades help Ensure Timely and Mature ISAs Effective Resolution of Issues

• Staff and Management Turnover Pose Challenges Robust Licensing Basis Success of Our Efforts Must Continuous be Measurable Learning 3

END-STATE Optimized Programs Lead to Reduced Resource Expenditures 4

3 CURRENT FOCUS AREAS - INSPECTION PROGRAM Area 1: Acknowledgement of Good Performance

- What does that mean?

- What criteria should be used to define it?

• e.g., sustained plant performance with no violations; self-identification

- How can License Performance Review process and findings be utilized in decision making?

- How does credit manifest itself? e.g.,

• Reduced scope or frequency of inspection or both? (NMSS procedures allow a 50% reduction in frequency for certain materials licensees)

• Reduced total number of hours

© 2019 Nuclear Energy Institute 5

INSPECTION PROGRAM Area 2: Optimizing Inspection Procedures

- In-depth review of baseline/core hours; re-assess regulatory basis for each

- Re-scope content, focus, priorities based on historical inspection findings, operational events & conditions, expert judgment, ensure inspection activities have a safety benefit, etc.

- Bundle more Inspection Procedures

- Conduct biennial EP inspection and biennial EP observed drill in alternating years

- Transfer additional IPs to Resident Inspectors at Category I facilities, e.g.,

Waste Management, Transportation, Maintenance/Surveillance

- Remove PI&R inspection for those with accepted CAP

- Credit for robust self-assessments or internal/external independent audits, e.g., DOE-Navy, NUPIC, corporate cyber

© 2019 Nuclear Energy Institute 6

INSPECTION PROGRAM Area 3: Managing Inspection Resources

- Preparation and Post Inspection Time: review of current practices; determine whether ratios are consistent among inspectors and appropriate for IP; establish maximum allowed; ensure appropriate scope for document requests

- Time on site: review of current IP hours; determine whether appropriate based on risk; establish maximum hours and allow for inspectors to reduce hours while on site if appropriate

- Travel Time and Related Costs -review of current practices; ensure travel time and related costs are efficient and cost effective e.g., inspection team members share rental cars

© 2019 Nuclear Energy Institute 7

3 CURRENT FOCUS AREAS - LICENSING PROGRAM

• Area 1: Requests for Additional Information

- Clear regulatory basis for each RAI documented

- Decision re: whether RAI issued in draft or final - pros/cons

- Limited number of rounds of RAIs

• Area 2: Licensing Milestones

- Solicit input from licensee and establish overall timeline that is documented on all licensing actions

- Solicit input from licensee re: milestones from when licensing action is accepted until a final licensing decision/amendment or license is issued which are provided to licensee/applicant

© 2019 Nuclear Energy Institute 8

LICENSING PROGRAM

• Area 3: Licensing Process

- Benchmark with other NRC regulatory programs could identify efficiencies and management tools to ensure continuity

- Renewals should focus only on areas of program change since licensees have living programs; diagnostic on past renewals

- Continuity of quality and efficiency of licensing process is maintained despite staff and/or management turnover

- Particularly challenging with protracted and more complex licensing actions - even more reason for established licensing milestones

© 2019 Nuclear Energy Institute 9

ENFORCEMENT PROGRAM EFFICIENCIES

• Does industry have suggestions for improvements to NRCs Enforcement Program or how it is implemented?

- Alternate Dispute Resolution

• All stakeholders must participate to avoid surprises

- Current Severity Level enforcement examples 10