How the Nuclear Regulatory Commission collects information in the licensing of spent nuclear fuel can be improved by a better understanding of the concept of risk-informed decision making, according to a report, Audit of the NRC’s Use of Requests for Additional Information in Licensing Processes for Spent Nuclear Fuel (OIG-21-A-08), by the agency’s Office of Inspector General (OIG).
The report assesses the efficiency and effectiveness of the agency’s use of requests for additional information (RAIs) in reviewing applications to store spent nuclear fuel, either at commercial nuclear power plants or at separate storage facilities. RAIs are the method by which NRC staff collects needed information from license applicants before making a regulatory decision.
According to the OIG, while the use of RAIs by staff is effective and efficient, there is an inconsistent understanding of how the risk-informed concept is applied to such requests.
“Agency positions should be readily understood; however, the expectations regarding how to risk-inform RAIs are unclear. As a result, there can be tension between licensing and technical staff during the RAI process,” the OIG said in its audit.
Risk-informed concept: To enhance its regulatory framework, the NRC has adopted a more risk-informed, performance-based approach to its licensing process. In May 2018, the NRC issued SECY-18-0060, “Achieving Modern Risk-Informed Regulation,” which discussed the need for systematic and expanded use of risk and safety insights in making decisions.
The OIG found, however, that there is no agreed-upon definition or clear expectation regarding what risk-informed means in the context of RAIs among NRC staff and program managers. As a result, the OIG said, “Some staff have difficulty balancing the push to be risk-informed with ensuring the applicant is meeting the regulations.”
The recommendations: To enhance the agency’s use of RAIs during the spent fuel licensing process, the OIG report makes the following recommendations:
- Update guidance to document strategies or tools to be used for risk-informing requests for additional information.
- Conduct training on how to risk-inform relative to the RAI process, and conduct refresher training on an as-needed, periodic basis.
- Create and implement a formalized process to facilitate effective management transitions in the NRC’s Division of Fuel Management.