Industry Says NRC Revised Fuel Cycle Oversight Process Is a Low Priority
April 24, 2014—The Nuclear Regulatory Commission’s efforts to revise its fuel cycle oversight process (RFCOP) should continue to be a low priority because the current process is adequate for identifying and addressing safety and security issues, the Nuclear Energy Institute told the agency recently. Further, NEI says, no issue has been identified at any nuclear fuel-cycle facility to warrant fast tracking the revision.
NEI’s April 10 letter also suggests that NRC and industry resources would be better used on higher priority matters, such as facility-initiated operational improvements.
The letter reaffirms that NEI and the industry continue to support the NRC’s revision initiative, as outlined in SECY-10-0031, “to develop a fuel cycle oversight process that is more risk-informed and performance-based, and provides a more objective, predictable, repeatable, and transparent assessment of licensee or certificate holder performance.” Industry has expressed its interest in and willingness to work with NRC on this issue since 2009.
The letter makes the industry’s case that fuel-cycle facilities should not be handled in the same way as nuclear power plants. Rather than adopting an oversight methodology similar to that used for commercial plants, as the NRC has proposed, the industry suggests elements to model the process that are more applicable to the diverse nature of fuel-cycle facilities, which include fuel fabricators, conversion facilities and enrichment facilities.
Specifically, the industry says that “the desired outcome of a RFCOP is a more performance-based inspection process with enhanced consideration of risk insights to enable flexibility in the level and degree of inspection to be applied at each facility.”
To help achieve this goal, the letter proposes incorporating insights from facility-specific integrated safety analyses (ISAs) into the RFCOP. The ISA process has been utilized since 2004 and could add site-specific risk insights to the oversight process, allowing the industry and the NRC to focus “resources on the areas with the highest risks,” the letter says.
The letter also offers the industry’s appreciation for NRC efforts to promptly review the annual facility change reports and apply risk insights toward annual inspections. It also says the industry welcomed the NRC staff’s recent efforts to develop a RFCOP project plan that will describe the project’s scope, milestones and timeline.
The letter also requests that the NRC look for opportunities to increase the overall transparency of the RFCOP process and engage with facility operators and other stakeholders on further process enhancements. It also requests that the NRC discuss the project’s plan status during the quarterly public meetings on the cumulative impact initiative because, the industry believes, the project’s priority, scope and milestones should be decided within the broader context of the cumulative impact of regulation.