POLICY ISSUE 

INFORMATION 

June 27, 2011 SECY-11-0084

FOR: The Commissioners 

FROM: R. W. Borchardt 

 Executive Director for Operations 

SUBJECT: STAFF ACTION PLAN TO ADDRESS THE INTEGRATED 

REGULATORY REVIEW SERVICE MISSION 

PURPOSE: 

The purpose of this paper is to inform the Commission of the actions planned by the staff to 

address the recommendations and suggestions of the International Atomic Energy Agency 

(IAEA) Integrated Regulatory Review Service (IRRS) mission conducted October 17–29, 2010. 

In addition, this paper discusses the third IAEA IRRS lessons-learned workshop scheduled for 

October 26–28, 2011. 

BACKGROUND: 

The IRRS mission focused on the U.S. operating power reactor program. The mission report 

was issued on March 1, 2011, and is publically available under Agencywide Documents Access 

and Management System Accession No. ML110630400. The report contains 

2 recommendations, 20 suggestions, and 25 good practices. 

DISCUSSION: 

The following discussion provides information about the mission report and the staff’s action 

plan to address the recommendations and suggestions. 

CONTACT: Jon B. Hopkins, NRR/DPR 

 301-415-3027
The Commissioners 2

IRRS Report Format 

The IRRS report is formatted to address the 10 core IRRS modules and the optional module 

discussed during the mission. The two thematic modules, Periodic Safety Review and 

Feedback of Operating Experience, do not have their own report sections; rather, they are 

discussed within the other modules. 

IRRS Report Findings

An IRRS mission has three types of findings: recommendations, suggestions, and good 

practices. The IAEA guidance for IRRS missions defines these findings as follows: 

Recommendations are proposed where key aspects relative to the IAEA Safety 

Requirements are missing, incomplete, or inadequately implemented. 

Recommendations should be specific, realistic and designed to result in tangible 

improvements to regulatory effectiveness. 

Suggestions are used to identify opportunities for improvement unrelated to a 

non-compliance with IAEA Safety Requirements. Suggestions may indirectly 

contribute to improvements in national regulatory arrangements but are primarily 

intended to address regulatory technical and policy issues, to make the 

regulatory body’s performance more effective or efficient, to indicate useful 

expansions of existing programs and to point out possibly superior alternatives to 

current work. In general, suggestions should stimulate the regulatory body’s 

management and staff to consider new or different approaches to regulatory 

technical and policy issues and enhance performance. A suggestion is either a 

proposal in conjunction with a recommendation or may stand on its own. Each 

suggestion shall have a basis either in IAEA Safety Requirements, Safety Guides 

or other relevant IAEA documents or regulatory body commitments 

(e.g., Conventions). 

A good practice is identified in recognition of an outstanding organization, 

arrangement, program or performance superior to those generally observed 

elsewhere. It has to be worthy of the attention of other regulatory bodies. Good 

practices shall also reference a basis similar to suggestions. 

The report’s recommendations concern documenting and confirming that the Nuclear 

Regulatory Commission (NRC) has a fully integrated management system. 

The report’s suggestions include safety margin improvements by licensees; harmonization of 

codes and standards with international standards, operator training and Reactor Oversight 

Process (ROP) coverage of severe accidents, additional inputs to operating experience 

assessments, emergency preparedness and response, and the safety/security interface. 

The report’s good practices primarily address communication, transparency, human capital 

planning, vendor oversight, the operating experience program, the inspection program, the 
The Commissioners 3 

rulemaking process, regulatory guides, the emergency exercise program, and the 

safety/security interface program. 

Staff Action Plan 

The staff has developed an action plan (Enclosure 1) to address the recommendations and 

suggestions contained in the IRRS mission report. The staff incorporated the need to assess 

lessons learned from the Fukushima accident into several of the suggestions. Currently, the 

staff has identified four potential policy issues stemming from the plan (see Suggestions S4, S7, 

S8, and S10 in Enclosure 1). Implementation of the action plan has commenced for several of 

the actions. The staff will seek appropriate Commission guidance on all policy issues identified 

when sufficient details have been developed to either recommend action or options for 

Commission consideration. 

IRRS Followup Mission 

As part of the IRRS mission process, a followup mission is conducted approximately 

18–24 months after the original mission. The followup mission reviews the host country’s 

activities to address the mission’s recommendations and suggestions. In addition, the followup 

mission can review new areas, if agreed to by the host country. 

The followup IRRS mission for the United States has not been scheduled. The NRC staff 

believes that the followup mission will likely take place more than 24 months after the original 

mission because of the number of missions scheduled to be conducted by IAEA. 

IRRS Lessons Learned Workshop 

The NRC has agreed to host an IAEA IRRS mission lessons-learned workshop, scheduled for 

October 26–28, 2011. This will be the third IAEA IRRS lessons-learned workshop. Spain 

hosted an IRRS lessons-learned workshop in 2008 following its IRRS mission, and France 

hosted a workshop in 2007 following its mission. The IAEA will invite countries that have 

recently hosted an IRRS mission to present lessons learned and any suggestions they may 

have for IAEA or future host countries. Countries that expect to host a future IRRS mission will 

also attend. The IAEA Deputy Director General for the Department of Nuclear Safety and 

Security typically attends this meeting. 

Enclosure 2 provides several examples of the types of suggestions that the staff anticipates 

providing at the workshop. 

Resources 

1.7 FTE is included in the FY 2012 budget request for the IRRS mission. The planned staff 

actions discussed can be performed within these resources. 
The Commissioners 4 

CONCLUSIONS: 

The staff’s planned actions include the following: 

• Seek Commission guidance on policy issues involved in addressing the IRRS report 

recommendations and suggestions, if they arise. 

• Coordinate planning with IAEA for hosting the IRRS lessons-learned workshop. 

• Communicate with IAEA on the schedule for the followup IRRS mission. 

COORDINATION: 

The Office of the General Counsel has reviewed this paper and has no legal objection. The 

Office of International Programs has reviewed this paper and concurs. The Office of the Chief 

Financial Officer has reviewed this paper and concurs. 

 /RA by Martin J. Virgilio for/ 

R. W. Borchardt

 Executive Director 

 for Operations 

Enclosures: 

1. NRC Action Plan 

2. Lessons Learned Examples 
The Commissioners 4 

CONCLUSIONS: 

The staff’s planned actions include the following: 

• Seek Commission guidance on policy issues involved in addressing the IRRS report 

recommendations and suggestions, if they arise. 

• Coordinate planning with IAEA for hosting the IRRS lessons-learned workshop. 

• Communicate with IAEA on the schedule for the followup IRRS mission. 

COORDINATION: 

The Office of the General Counsel has reviewed this paper and has no legal objection. The 

Office of International Programs has reviewed this paper and concurs. The Office of the Chief 

Financial Officer has reviewed this paper and concurs. 

 /RA by Martin J. Virgilio for/ 

R. W. Borchardt

 Executive Director 

 for Operations 

Enclosures: 

1. NRC Action Plan 

2. Lessons Learned Examples 

EDATS: NRR-2011-0033 

ADAMS Accession No: ML111570141 *via email 

OFFICE DPR/PFAB TECH ED* DPR/PFAB DPR/NRR OIP 

NAME JHopkins JDougherty ASimmons TMcGinty JSchwartzman 

DATE 6/7/11 6/2/11 6/10/11 6/13/11 6/9/11 

OFFICE OGC CFO* NRR EDO 

NAME SBurns JDyer 

(GPeterson for) 

ELeeds 

(BBoger for) 

RBorchardt 

(MVirgilio for) 

DATE 6/8/11 6/16/11 6/23/11 6/27/11 

OFFICIAL RECORD COPY 
 ENCLOSURE 1 

Integrated Regulatory Review Service (IRRS)

Recommendations and Suggestions

NRC Action Plan

June 2011

Recommendation R1: 

The Nuclear Regulatory Commission (NRC) should identify/confirm and describe its 

organizational-wide core processes and support processes and include process inputs, flows, 

and outputs (e.g., develop a process map) in order to confirm and document a fully integrated 

management system. 

R1 Action: 

From its self-assessment, the staff commenced development of a comprehensive document 

describing the many complex components of the agency’s management system (also, see S3). 

The staff will complete the management systems document with the intent that it will confirm the 

comprehensiveness of the existing NRC management systems for the operating reactor 

program, to serve as a knowledge management tool, and to serve as a tool to support periodic 

management system reviews. (Also, see R2.) 

Next Step: Develop a process map for inclusion in the management systems document by 

June 30, 2012. 

Lead: J. Lubinski, NRR Coordination: J. Golder, CFO 

 J. Corbett, OIS 

Recommendation R2: 

The NRC should develop a methodology and implement a holistic management system review 

at planned intervals to ensure the continuing effectiveness of the management system. 

R2 Action: 

Following the completion of the management systems document developed to support the staff 

self-assessment and IRRS Recommendation R1 and Suggestion S3, staff will evaluate existing 

performance measurement and audit activities to determine whether additional reviews of 

NRC’s management system are necessary to periodically assess the effectiveness of the 

system. 

Next Step: Following completion of R1 and S3, evaluate the need for additional periodic 

reviews to close any gaps from a holistic review perspective. 

Lead: J. Lubinski, NRR Coordination: J. Golder, CFO 

 N. Mamish, OEDO 
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Suggestion S1: 

In the absence of a direct legal statement about the prime responsibility for safety, the NRC 

should provide a consistent, clear message to the licensees that they have responsibility to take 

their own initiatives to improve safety whenever reasonably practicable. 

S1 Action: 

Develop a consistent message on safety responsibility that can be conveyed to licensees during 

management meetings, such as drop-in meetings, Nuclear Strategic Issues Advisory Committee 

(NSIAC) meetings, and Utility Working Conferences. Work through the Office of the Executive 

Director for Operations to endorse and implement the message across offices and regions. In 

addition, the staff included a statement in the Safety Culture Policy Statement, which was 

approved by the Commission and published in the Federal Register on June 14, 2011, to reflect 

the expectation that licensees have the prime responsibility for safety and security. (Also, see 

S14.) 

Next Step: Develop a communication plan by September 30, 2011. 

Lead: B. Boger, NRR Coordination: C. Miller, Region I 

 R. Croteau, Region II 

 J. Lara, Region III 

 T. Pruett, Region IV 

 J. Cai, OE 

Suggestion S2: 

The NRC should evaluate the added value to safety of harmonizing its regulations and guides 

with the International Atomic Energy Agency (IAEA) safety standards and consider the possible 

means to take into account the IAEA safety standards in the regulations and regulatory guides. 

S2 Action: 

The NRC staff identified this issue from its self-assessment. The staff plans to: 

(1) Update staff guidance to include consideration of IAEA safety standards as additional points 

of reference when developing new or revised regulations and guidance (or endorsing voluntary 

industry initiatives). 

(2) Improve the effectiveness of the Knowledge Management Center’s “IAEA Safety Standards 

Gap Analysis” by piloting a reference document that summarizes the differences between a set 

of NRC regulations and key IAEA safety standards (for example, the General Design Criteria 

and IAEA Safety Standard NS-R-1). 

(3) Continue to support participation of agency experts in the development and revision process 

of IAEA safety standards in order to help ensure harmonization with U.S. practices and enhance 

the adaptability for reference in U.S. standards. 

(Also, see S5, S12, and S13). 
- 3 - 

Next Step: Management Directive (MD) 6.6, “Regulatory Guides,” for the development of 

regulatory guides, was approved and issued on April 12, 2011. As a result of the NRC’s selfassessment in preparation for the IRRS mission, MD 6.6 was revised to include a section on 

harmonization with international standards. Staff will continue the current practice of developing 

a “gap analysis” to support NRC interactions with IAEA on proposed standards. Staff will draft 

an update to staff guidance for regulations to include consideration of IAEA safety standards by 

March 31, 2012. 

Lead: D. Skeen, NRR Coordination: Mike Case, RES 

Suggestion S3: 

The NRC should continue to develop its draft management system description document and 

accommodate in this document the results of the recommendations given above (R1 and R2). 

S3 Action: 

From its self-assessment, the staff commenced development of a comprehensive document 

describing the many complex components of the agency’s management system. The staff will 

consider Recommendations R1 and R2, and the staff’s response to those recommendations, in 

its development of this document. (Also see R1 and R2.) 

Next Step: Develop a process map for inclusion in the management systems document by 

June 30, 2012. 

Lead: J. Lubinski, NRR Coordination: J. Golder, CFO 

 J. Corbett, OIS 

Suggestion S4: 

The NRC should develop means to verify that newly licensed operators have received adequate 

training on management of severe accidents. 

S4 Action: 

The staff will consider the adequacy of NRC’s current approach to the oversight of severe 

accident management guidelines (SAMGs). This will include development and maintenance of 

the procedures, as well as training and drills conducted by licensees. This will also include an 

assessment of how the NRC reviews SAMGs under the Reactor Oversight Process. (Also, see 

S10). 

Next Step: Staff will develop a more detailed plan following the NRC staff’s report on near-term 

lessons learned from Fukushima, which will include consideration of the recently completed 

Temporary Instruction (TI) –183 and TI-184. Staff recognizes that changes to address this 

suggestion will likely involve changes to agency policy and will require Commission review and 

approval. 
- 4 - 

Lead: F. Brown, NRR Coordination: C. Miller, Region I 

 J. Munday, Region II 

 J. Lara, Region III 

 T. Vegel, Region IV 

Suggestion S5: 

Future updates of the NRC’s standard review plans should take into account scientific and 

technological developments in the area of safety assessment as reflected in the relevant IAEA 

safety standards. 

S5 Action: 

Staff will update the Office of New Reactors (NRO) Office Instruction NRO-REG-300 

(ML073230703) and the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-200 

(ML060300069) to incorporate guidance on the use of IAEA safety standards as additional 

points of reference when updating review guidance, as is currently recommended in MD 6.6 

“Regulatory Guides.” (Also, see S2, S12, and S13) 

Next Step: Complete review of NRO and NRR office instructions by December 31, 2011. 

Lead: D. Skeen, NRR Coordination: P. Madden, NRO 

Suggestion S6: 

NRC should consider limiting its approval of codes submitted by vendors to a specific period of 

time to ensure the codes are periodically evaluated and updated, as necessary, to reflect 

lessons learned and the latest knowledge. 

S6 Action: 

The staff will review its current requirements and expectations for code use. The results will be 

assessed to determine the benefit and practicality of establishing time limits on the use of NRC 

approved codes. 

Next Step: NRR, NRO, and Office of Nuclear Regulatory Research (RES) to meet and draft a 

proposal by December 31, 2011. 

Lead: B. Boger, NRR Coordination: S. Elkins, RES 

 M. Lombard, NRO 

Suggestion S7: 

NRC should consider proper ways aimed at more direct implementation of the as low as 

reasonable achievable (ALARA) principle in setting up the radiological acceptance criteria for 

design basis accidents as well as in assessment of acceptability of the results of relevant safety 

analysis. 
- 5 - 

S7 Action:

The staff will explore this issue to better understand how international nuclear regulatory bodies 

have used the ALARA principle in this manner. The results will be assessed to determine the 

benefit and practicality of the use of the ALARA principle in establishing acceptance criteria in 

safety analyses. 

Next Step: NRR will survey its international counterparts on their approach to this issue. 

Survey to be completed by June 30, 2012. Staff recognizes that changes to address this 

suggestion will likely involve changes to agency policy and will require Commission review and 

approval. 

Lead: T. McGinty, NRR Coordination: K. Henderson, OIP 

Suggestion S8: 

NRC should assess whether the current regulations adequately provide for an independent 

verification of the safety assessment under the responsibility of the licensee before its use or 

submittal to the regulatory body and whether this verification is adequately confirmed by the 

NRC. 

S8 Action: 

The staff will assess regulatory requirements on design control (Title 10 of the Code of Federal 

Regulations Part 50, Appendix B), the quality of licensing submittals, and inspection program 

results (e.g., component design bases inspections) to determine whether confidence exists that 

licensees are performing acceptable safety analyses. If a gap is identified, the staff will explore 

the potential benefit of independent verifications. 

Next Step: NRR and NRO to meet and develop a proposal, if needed, by March 31, 2012. Staff 

recognizes that changes to address this suggestion will likely involve changes to agency policy 

and will require Commission review and approval. 

Lead: B. Boger, NRR Coordination: J. Tappert, NRO 

Suggestion S9: 

Although the NRC utilizes an alternate approach to meet the Periodic Safety Review (PSR) 

safety factors, NRC should incorporate lessons learned from PSRs performed in other countries 

as an input to the NRC’s assessment processes. 

S9 Action: 

The staff identified this issue from its self-assessment. The NRC will conduct a limited scope 

pilot effort to obtain some example PSRs performed in other countries where an English version 

of the PSR results is available (or as a minimum, the regulator’s review of the PSR). These will 

be reviewed for potential insights regarding nuclear power plant operating experience topics 

similar to the review performed prior to the IRRS mission. The pilot effort will review example 
- 6 - 

PSRs for potential insights to be assessed by the NRC’s regulatory processes, which could 

include, for example, issuing a nuclear power plant generic communication or future revisions to 

NRC license renewal guidance documents. The pilot effort will seek to establish the value 

added from the review of the example PSRs. 

In addition, the NRC will use bilateral meetings with other international regulatory bodies as a 

forum to obtain significant PSR findings from those countries for further evaluation by the NRC. 

Next Steps: Finalize standard set of questions for bilateral meetings on PSR findings by 

July 15, 2011, and obtain PSRs for the pilot effort by September 30, 2011. 

Lead: B. Holian, NRR Coordination: K. Henderson, OIP 

Suggestion S10: 

NRC should ensure that Severe Accident Management (SAM) is properly addressed in the 

Reactor Oversight Process. 

S10 Action: 

The staff will consider the adequacy of NRC’s current approach to the oversight of SAM. This 

will include operator training, emergency exercises, B.5.b follow-up, and inspection procedures. 

This will also include an assessment of how the NRC reviews SAM under the Reactor Oversight 

Process. (Also, see S4). 

Next Step: Following the staff’s report on near-term lessons learned from Fukushima, which will 

include consideration of the recently completed TI-183 and TI-184, the staff will assess NRC 

SAM oversight activities. Staff recognizes that changes to address this suggestion will likely 

involve changes to agency policy and will require Commission review and approval. 

Lead: F. Brown, NRR Coordination: C. Miller, Region I 

 R. Croteau, Region II 

 J. Lara, Region III 

 T. Vegel, Region IV 

 M. Thaggard, NSIR 

Suggestion S11:

NRC should review its inspection event response guidance and interact with licensees with an 

objective of reconfirming that the role of the NRC is understood and does not unduly influence 

the actions taken by the licensee.

S11 Action: 

The staff will assess agency guidance and expectations on event response to ensure the NRC 

doesn’t unduly impact licensee incident response. An appropriate interaction with licensees to 

confirm a common understanding of NRC and licensee roles during incident response will be 

conducted. 
- 7 - 

Next Step: Staff will assess NRC guidance and expectations on event response and develop a 

proposal, if needed, by December 31, 2011. Lessons learned from the Office of Nuclear 

Security and Incident Response’s assessment of the NRC’s response to the Fukushima Diiachi 

event will be considered and incorporated, as appropriate. 

Lead: F. Brown, NRR Coordination: C. Miller, Region I 

 J. Munday, Region II 

 J. Lara, Region III 

 K. Kennedy, Region IV 

Suggestion S12: 

The NRC should prioritize the development of a formal procedure for development and revision 

of regulatory guides. 

S12 Action: 

Management Directive 6.6, “Regulatory Guides,” for the development of regulatory guides, was 

under development prior to the IRRS mission. As a result of the NRC’s self-assessment in 

preparation for the mission, the MD was revised to include a section on harmonization with 

international standards. Issuance of the final MD will address the IRRS suggestion. (Also, see 

S13.) 

Next Step: MD 6.6 was approved and issued on April 12, 2011. This action is complete. 

Lead: D. Skeen, NRR Coordination: M. Orr, RES 

Suggestion S13: 

The NRC should consider making an implementing procedure to guide the periodic systematic 

review for its regulations and guides based on operating experience feedback and the 

development of international safety standards. 

S13 Action: 

The staff will assess the pros and cons of performing a periodic review of NRC regulations and 

guidance documents. In addition, similar to the effort to consider using international standards 

as points of reference in regulatory guides (also, see S12), the staff will consider developing an 

internal policy or MD that would direct NRC staff to consider IAEA safety standards as points of 

reference, when developing new or revised regulations (or when endorsing voluntary industry 

initiatives. 

Next Step: NRR, NRO, and RES develop a proposal, if needed, by March 31, 2012. 

Lead: D. Skeen, NRR Coordination: M. Case, RES 

 P. Madden, NRO 
- 8 - 

Suggestion S14: 

The NRC should consider possible measures to ensure that all licensees are more proactive in 

upgrading the systems, structures, and components of their facilities with the objective to 

improve safety margins. 

S14 Action: 

In conjunction with the development of a clear, consistent message to licensees identified in 

Suggestion 1, the staff will develop discussion points to address maintenance of safety margins 

and planned facility safety improvements for use in routine meetings with licensees. 

Next Step: Develop a communication plan by September 30, 2011. 

Lead: B. Boger, NRR Coordination: C. Miller, Region I 

 R. Croteau, Region II 

 J. Lara, Region III 

 T. Pruett, Region IV 

Suggestion S15: 

The NRC procedure for the IAEA emergency notification system (ENAC) should be improved 

and the emergency exercise program should include routine testing of ENAC reporting to the 

IAEA.

S15 Action: 

The staff will contact IAEA and the Department of State to (a) develop protocol for ENAC 

notifications of events, and (b) establish a method for routine testing of ENAC with IAEA, 

including during exercises. 

Next Step: Develop protocol for ENAC notifications by March 31, 2012. 

Lead: M. Thaggard, NSIR Coordination: K. Henderson, OIP 

Suggestion S16: 

The NRC should discuss with its Federal partners the consideration of a proposal for the 

development of initial operational intervention levels in line with the IAEA Safety Standard 

GS-R-2 provisions. 

S16 Action: 

The staff will present this suggestion at a Federal Radiological Preparedness Coordinating 

Committee (FRPCC) meeting. The outcome will depend upon the direction provided by FRPCC 

members. Staff will review this issue to determine the acceptability of the interagency 

approach, and provide feedback to NRC leadership and FRPCC for any possible future actions. 
- 9 - 

Next Step: The initial action has been completed. Staff presented the suggestion at the 

January 20, 2011, FRPCC meeting. Initial feedback at the FRPCC was positive; however, no 

definitive commitment was made on where FRPCC will go with this suggestion. Staff will raise 

this issue again at future FRPCC meetings. 

Lead: M. Thaggard, NSIR Coordination: NRC Leadership 

Suggestion S17: 

The NRC should discuss with its Federal partners, the consideration of a proposal for merging 

all field measurements performed during an emergency by different stakeholders into a single 

database. This database should be made available online for decision-making purposes. 

S17 Action: 

The staff will present this suggestion at a Federal FRPCC meeting. The outcome will depend 

upon the direction provided by FRPCC members. Staff will review this issue to determine the 

acceptability of the interagency approach, and provide feedback to NRC leadership and FRPCC 

for any possible future actions. 

Next Step: The initial action has been completed. Staff presented the suggestion at the 

January 20, 2011, FRPCC meeting. Initial feedback at the FRPCC was positive; however, no 

definitive commitment was made on where FRPCC will go with this suggestion. Staff will raise 

this issue again at future FRPCC meetings. 

Lead: M. Thaggard, NSIR Coordination: NRC Leadership 

Suggestion S18: 

The NRC should continue to explore options with the Federal and State partners in order to 

expand the scope of the emergency exercise program by adding elements to demonstrate the 

capability to respond to unpredictable courses of events and to make the exercise programme 

more challenging to all the participants. 

S18 Action: 

NRC staff and Federal Emergency Management Agency (FEMA) are participating in rulemaking 

and guidance development that, among other things, will help to ensure drills and exercises at 

nuclear plants are more challenging and less predictable. The draft final rule has been provided 

to the Commission for approval. Staff will review implementation to determine if this item has 

been fulfilled. 

Next Step: Staff will review implementation of final rule for adequacy to address S18 by June 

30, 2013. 
- 10 - 

Lead: M. Thaggard, NSIR Coordination: C. Miller, Region I 

 J. Munday, Region II 

 J. Lara, Region III 

 T. Vegel, Region IV 

 R. Virgilio, FSME 

Suggestion S19: 

NRC’s Operating Experience Branch procedures should be updated to include non-nuclear 

information which should be collected to evaluate understanding to any impact to safety or 

security that may inform the safety/security interface.

S19 Action: 

Staff will assess current processes for collecting information that is used to identify potential 

impacts on safety, security, and the safety/security interface, with consideration of non-nuclear 

sources. Processes will be updated, as appropriate, to address gaps. 

Next Step: Staff will complete its assessment by March 31, 2012, and propose changes, if 

appropriate. 

Lead: F. Brown, NRR Coordination: R. Correia, NSIR 

Suggestion S20: 

NRC should take further action to encourage industry to take actions to ensure the effective 

co-ordination of the safety/security interface issues. 

S20 Action: 

NRC staff has increased its attention to the safety/security interface, including the June 2009 

issuance of Regulatory Guide 5.74, “Managing the Safety/Security Interface,” which was issued 

to provide guidance on implementation of 10 CFR 73.58, “Safety/Security Interface 

Requirements for Nuclear Power Reactors.” In addition, NRC met with industry at the Nuclear 

Energy Institute (NEI) organized Nuclear Security Working Group, discussed the IRRS mission 

Suggestion 20, and encouraged industry to take actions to ensure the effective coordination of 

the safety/security interface. 

Next Step: Document that NRC action to address Suggestion 20 is complete. 

Lead: M. Galloway, NRR Coordination: R. Correia, NSIR 
ENCLOSURE 2 

U.S. Integrated Regulatory Review Service (IRRS)

Mission Lessons Learned Examples

1. Even partial-scope IRRS missions require an agencywide commitment. Member states 

who agree to host an IRRS mission must commit the resources needed to develop a 

thorough and credible assessment. Pre-mission planning should draw on several recent 

IRRS missions to other member states. Multiple member state points of contact (POCs) 

should be established for each module and POC roles and responsibilities should be 

clear. POCs should have no higher priority responsibilities during the 2 week mission. 

2. The partial-scope mission focused on the U.S. Nuclear Regulatory Commission’s 

operating power reactor program was the correct size for the United States. A mission 

with a larger scope and a larger IRRS review team would likely have been too unwieldy. 

3. Including a module overview along with the self-assessment within the advance 

reference material was helpful. 

4. If possible, IRRS mission teams should observe an agency’s response during an 

emergency preparedness exercise. If no such exercise is scheduled, consider 

conducting an agency tabletop exercise. 

5. The agency provided two conference rooms with computer capability for the IRRS team. 

One room was outside the security area and the other was inside the security area. This 

arrangement provided flexibility and convenience for the IRRS team. One of the rooms 

should be large enough for the entire team to review the draft report on a projection 

screen. 
- 2 -