NRC: SECY-07-0110 - Summary of Activities Related to Generic Issues Program


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POLICY ISSUE
INFORMATION

SECY-07-0110

July 6, 2007

For:	The Commissioners
From:	Luis A. Reyes, Executive Director for Operations
Subject:	SUMMARY OF ACTIVITIES RELATED TO GENERIC ISSUES PROGRAM

PURPOSE
BACKGROUND
DISCUSSION
RESOURCES
COORDINATION

PURPOSE:

This paper provides the annual summary of the Generic Issues Program (GIP) activities including improvements to ensure timely and effective resolution of generic issues (GI). This paper does not address any new commitments.

BACKGROUND:

In the staff requirements memorandum (SRM) related to SECY-05-0126, "Summary of Activities Related to Generic Safety Issues," dated August 31, 2005 (ML052430101), the Commission directed the staff to develop a plan to focus renewed attention to the GIP to resolve the older GI, and ensure that future GIs are resolved in a timely manner. In its response to that SRM, "Response to Staff Requirements Memorandum on SECY-05-0126, 'Summary of Activities Related to Generic Safety Issues'," dated March 29, 2006 (ML053570259), the staff provided a plan to ensure timely resolution of GIs. The staff subsequently prepared its latest annual report (SECY-06-0161, "Summary of Activities Related to Generic Safety Issues," dated July 20, 2006 (ML061860078)), to give the Commission an update and progress report on this plan. Then, the staff informed the Commission of GIP improvement elements to be implemented through a revision of Management Directive (MD) 6.4, "Generic Issues Program," in SECY-07-0022, "Status Report on Proposed Improvements to the Generic Issues Program," dated January 30, 2007 (ML063460239).

DISCUSSION:

Status of Open Generic Issues

Since the latest annual report to the Commission (SECY-06-0161), the staff has removed ten reactor GIs and one non-reactor GI from active status, leaving five GIs that remain active as of June 30, 2007, as described below.

Reactor Generic Issues

During this reporting period, the staff identified and closed three new GI and screened and closed two previously identified GI as follows:

(1)     GI-201, "Small-Break LOCA and Loss of Offsite Power"
(2)     GI-202, "Spent Fuel Pool Leakage Impacts"
(3)     GI-203, "Potential Safety Issues with Cranes That Lift Spent Fuel Casks"
(4)     GI-200, "Tin Whiskers"
(5)     GI-198, "Hydrogen Combustion in PWR Piping"

The staff also closed GI-196, "Boral Degradation," after completing the technical assessment. In addition, the staff changed the status of the following three GIs to "Regulatory Office Implementation," consistent with SECY-07-0022:

(1)     GI-163, "Multiple Steam Generator Tube Leakage"
(2)     GI-189, "Susceptibility of Ice Condenser and Mark III Containments to Early Failure from Hydrogen Combustion           During a Severe Accident"
(3)     GI-191, "Assessment of Debris Accumulation on PWR Sump"

As a result, four reactor GIs remain "active" as of June 30, 2007. The enclosure to this paper provides the status of the four open reactor GIs, which are currently in the screening, safety and risk assessment, or regulatory assessment stages, as well as three GIs that are currently in other regulatory program office's processes.

Non-Reactor Generic Issues

The staff did not identify any new non-reactor GIs during this reporting period. Rather, the staff closed the following two non-reactor GIs:

(1) GI-NMSS-0014, "Surety Estimates for Groundwater Restoration at In-Situ Leach Facilities"
(2) GI-NMSS-0016, "Adequacy of 0.05 Weight Percent Limit in 10 CFR 40"

The one remaining non-reactor GI is GI-NMSS-0007, "Criticality Benchmarks Greater Than 5% Enrichment." The enclosure to this paper provides the status for this non-reactor GI, which is currently in the final stage of closure as a formal GI.

Update on GIP Improvements

In the recent notification of GIP improvements (SECY-07-0022), the staff discussed the overall objective of timely and effective assessment of GIs addressed under the GIP. In support of this objective, the new GIP addresses only those issues that have significant risk- or security-related generic implications that cannot be more effectively handled by other regulatory programs and processes. The staff has implemented several GIP enhancements consistent with the improvement elements identified in SECY-07-0022. These enhancements have significantly reduced the number of active GIs and supported more timely screening of recently submitted GIs.

As previously stated in SECY-07-0022, the staff is currently revising MD 6.4 and plans to submit the revision to the Office of Administration by mid 2008. This revision will reflect GIP improvements (consistent with SECY-07-0022) and recent process enhancement experiences and plans, including those listed below, as appropriate. Consistent with GIP improvements identified in SECY-07-0022, the staff plans to contact key nuclear industry stakeholders and to hold an open public meeting with stakeholders in September or October 2007. The staff will consider and incorporate feedback from these meetings, as appropriate, in revising MD 6.4. The GIP staff work load is expected to increase for FY 2008 to complete developing and implementing these GIP improvements for timely and effective GI resolution.

Specific GIP Enhancements

(1)	The GIP staff works closely with office contacts and responsible staff to obtain complete and accurate update information on active GIs for routine reports to Congress and the Commission and for updates to NUREG-0933, "A Prioritization of Generic Safety Issues." This includes discussions with responsible individuals, assuring continued administrative tracking by responsible offices, and management confirmation. Results of this improved coordination include improved quality of information reported in the Generic Issue Management Control System (GIMCS) as well as increased management attention to timely completion of major milestones.
(2)	Regulatory program office contacts are involved in reviewing proposed GIs and, together with responsible staff and management, in contributing to preliminary screening and subsequent steps of the GIP, as appropriate.
(3)	The GIP staff is developing a Web page interface and form for use in proposing GIs and submitting them to the GIP. The form will solicit information to help the originator (and responsible program office) determine whether the issue is suitable for the GIP. Using this form will (1) support process consistency, (2) facilitate interoffice coordination, and (3) streamline formal screening of proposed GIs by the Office of Nuclear Regulatory Research (RES). The information obtained from this form will also facilitate the application of criteria for a graded approach to processing proposed GIs through the GIP stages.
(4)	The GIP staff, working with the regulatory program office contacts and appropriate staff, will evaluate the GI proposal, together with appropriate criteria, to help determine whether the issue should be addressed by the GIP, screened out, or resolved by another regulatory program or process (e.g., regulatory compliance, differing professional opinion, allegation, reactor oversight process). The staff will also determine when an issue involves an adequate protection concern that might warrant prompt regulatory action, when a proposed GI requires research to support proper assessment, and when industry stakeholder involvement might be appropriate.
(5)	The staff is using risk-informed techniques to screen issues and focus assessment resources on issues that are considered most risk-significant. Beginning with information obtained from the GI proposal form (described above), the staff uses existing proven risk-informed techniques, models, and data to facilitate timely and effective screening and assessment. For example, the staff has successfully assessed and closed recent GIs with Accident Sequence Precursor Program analysts using the Standardized Plant Analysis Risk models. The staff uses these techniques in GI screening to leverage existing capabilities and improve efficiency in determining which GIs warrant formal risk and regulatory assessment.
(6)	The appropriate offices have established a point-of-contact to coordinate their interfaces for GIP activities. Similarly, for GIP activities that involve or impact one or more program offices, RES and regulatory offices are coordinating those activities through the designated office contacts. This enhanced interoffice coordination has improved staff awareness, involvement, and participation of responsible staff and regulatory solutions for recent GIs. In addition, this coordination streamlines the flow of information to support timely actions and decision-making by responsible program office staff and management.
(7)	Enhanced screening ensures that only issues suitable to the GIP will become formal GIs subject to tracking. Implementation and verification will be performed using existing regulatory office programs, outside the GIP, to limit processing requirements (i.e., avoid parallel processing under the GIP) and to reduce the time that many GIs remain active. The GIP will continue to track, update, and report GIs within GIMCS for recordkeeping purposes consistent with current practices.

RESOURCES:

For Fiscal Year (FY) 2007, the staff estimates that the resources needed for these activities will total $1,600K and 7.0 full-time equivalents (FTE). These resources are included in the FY 2007 budget as follows:

RES: $1,600K and 6.0 FTE
NRR: 0.4 FTE
NMSS, FSME, and NSIR: 0.2 FTE each

For FY 2008, the staff estimates that the resources needed for these activities will total $1,150K and 7.8 FTE. The following resources have been requested for FY 2008:

RES: $1,150K and 6.8 FTE
NRR: 0.4 FTE
NMSS, FSME, and NRO: 0.2 FTE each

COORDINATION:

The Office of the General Counsel reviewed this package and has no legal objection. The Office of the Chief Financial Officer has also reviewed this package and has concurred.

/RA William F. Kane Acting for/

Luis A. Reyes
Executive Director for Operations

Enclosure:

Generic Issue Management Control System, June 30, 2007

CONTACTS:	Jack W. Foster, RES/DRASP (301) 415-6250
	Timothy M. Mitts, RES/DRASP (301) 415-4067