ML18177A255
| ML18177A255 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/2018 |
| From: | Russell Gibbs NRC/NRR/DIRS/IRAB |
| To: | |
| Gibbs R, NRR/DIRS, 415-8578 | |
| References | |
| Download: ML18177A255 (24) | |
Text
NEA Learning Workshop for the Introduction of the Reactor Oversight Process Presented by Russell Gibbs - U.S.
Nuclear Regulatory Commission 21-22 June 2018 Tokyo, Japan
NRCs Oversight History
- Prior program (SALP) was too subjective, not predictive and caused unnecessary regulatory burden
- Numerous attempts made to improve SALP
- External stakeholder feedback was highly critical
- Decision made to develop a more risk-informed and performance based program 2
Phases of ROP Introduction
- Six-month pilot (1999)
- One year initial implementation (2000)
- Evaluations performed after each phase
- Significant stakeholder involvement 3
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Change Management (1)
- Introduction of risk-informed and performance based philosophy
- Enforcement de-emphasized
- Baseline inspection program highly prescriptive
- Inspectors were accustomed to having more flexibility
- Requires more effective time management skills to complete 5
Change Management (2)
- PRA skills/tools needed to be developed
- Negative perception by inspectors on their added value
- More concise inspection reports 6
Risk-informed Decision-Making (1)
- Consider use of the risk triplet
- Decisions should include both quantitative and qualitative information
- What are appropriate qualitative inputs?
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Risk-informed Decision-Making (2)
Use caution in over reliance on PRA point estimates for the SDP and misapplication of PRA 8
Relationship Between NRC and Licensees Principles of Good Regulation Independence Clarity Openness Reliability Efficiency 9
NRC is a trust but verify regulator
Interactions with Stakeholders (1)
Main reason for ROP success is intensive and frequent engagement with industry and other external stakeholders 10
Interactions with Stakeholders (2)
- Intensive discussions on program elements and more significant inspection findings
- Most meetings open to public
- Oversight program and results available on public web page 11
Performance Indicator Program Management (1)
- PI Program was industry suggestion
- PIs and inspections designed to overlap
- Industry developed guidance that NRC endorsed (recommended) - NEI 99-02
- Licensees voluntarily report PIs quarterly 12
Performance Indicator Program Management (2)
- All PIs inspected on an annual basis
- FAQ Program continues to require much attention
- MSPI calculation is complex and verification challenging 13
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ROP Challenges (1)
- Making consistent distinctions between minor/more than minor issues
- Designing/implementing a meaningful Cross-Cutting Issues Program
- Maintaining ROP is resource intensive.
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ROP Challenges (2)
- Re-aligning baseline inspections
- Conducting Design Basis Assurance inspections
- Achieving safety/security significance equality among cornerstones
- Resources for supplemental inspections 16
ROP Challenges (3)
- Balancing reliability and efficiency of decisions
- Efficient use of resources for findings of greater safety significance 17
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Best Practices (1)
- ROP Feedback/Procedure Change Processes
- ROP monthly public meetings with industry
- Senior Reactor Analysts 19
Best Practices (2)
- SDP Phase 1 Screening Process
- SERP Process/Regulatory Conferences
- Use of graded approach for assessment (i.e. Action Matrix) 20
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Human Resources (1) 22
- NRC attracts highly educated and motivated individuals
- NRC salary and benefits package is highly competitive
- Qualification programs are extensive requiring 2 years to complete
Human Resources (2) 23
- Many staff have nuclear experience prior to NRC
- NRC encourages a broad experience base giving staff career flexibility
- Staff experience and attrition becoming more challenging
Conclusion Introduction of an oversight program similar to NRCs is a significant decision requiring a large degree of commitment, time, resources and stakeholder involvement!
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