ML18263A145
| ML18263A145 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/2018 |
| From: | Ed Miller Special Projects and Process Branch |
| To: | Wetzel B Nuclear Energy Institute |
| References | |
| Download: ML18263A145 (15) | |
Text
1 NRR-DMPSPEm Resource From:
Miller, Ed Sent:
Thursday, September 13, 2018 8:13 AM To:
baw@nei.org
Subject:
Slides for NOED Public Meeting Attachments:
NOED revision_Public Meeting Slides.pdf
- Beth, Attached are the slides I plan to present at the 9/26/18 public meeting on revisions to the NOED process. Please let me know if you have any questions in advance of the meeting. Thanks.
Ed Miller 301-415-2481
Hearing Identifier:
NRR_DMPS Email Number:
561 Mail Envelope Properties (Ed.Miller@nrc.gov20180913081200)
Subject:
Slides for NOED Public Meeting Sent Date:
9/13/2018 8:12:45 AM Received Date:
9/13/2018 8:12:00 AM From:
Miller, Ed Created By:
Ed.Miller@nrc.gov Recipients:
"baw@nei.org" <baw@nei.org>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 234 9/13/2018 8:12:00 AM NOED revision_Public Meeting Slides.pdf 243612 Options Priority:
Standard Return Notification:
No Reply Requested:
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Recipients Received:
NOED Process Revision Ed Miller - (301) 415-2481 - ed.miller@nrc.gov
Overview Why we are revising the process What works Clarifications Criteria Relocation of the guidance NOED Duration Limit Simplified Criteria Next Steps
Guidance Revision
NOED process is generally successful today and we should preserve what works -
Fundamental concept and elements are not changing
Core of process is solid
Current required and optional participants provide adequate support
Basic criteria remain valid
Clarifications
How far from end of LCO can we NOED and is there an upper limit on NOED
Relationship between NOEDs and RICT programs
Simplify Natural Phenomena portion and remove pandemic language
Follow-up LAR
Improve flow and user friendliness of the document
Criteria
Clarify and reorganize questions that are potentially duplicative or ambiguous
Improve logical flow of the criteria
Reinforce role of Amendment Process
Relocation of Guidance Currently in IMC-0410 Options considered Enforcement Manual NRR Office Instruction Regulatory Guide Stand Alone Guidance
Enforcement Manual Appendix F PROs
Appendices provide specific implementing details for portions of our enforcement function
Aligns with the policy that this process implements
Has formal change control process
Enforcement discretion is already in the enforcement policy CONs
Misaligns procedural program with process owner since NRR owns the process, but OE owns the manual.
Necessitates good communication and coordination.
NOED Duration Limit
NOED process is meant to be flexible
Setting a specific quantitative upper limit not appropriate
Amendment (or relief request) process should be used whenever possible
All NOEDS must justify why licensing process is not appropriate
NOEDs with requested duration longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> require compelling justification for why an emergency LAR isnt processed during a shorter period of enforcement discretion
Relationship with RICT programs
Implementation of a RICT program is expected to reduce the need for enforcement discretion
Completion times up to 30 day backstop allows increased time for licensing solution
NOED not prohibited, but scenario where NOED is appropriate expected to be exceedingly rare
Revised Criteria Explain why a licensing process is not appropriate to address the issue. If applicable, this explanation shall address previous instances of the issue and decisions to pursue licensing solutions in the past.
Provide a description of the TSs or other license conditions that will be violated. This description shall include the time the condition was entered and when the completion time will expire.
Provide sufficient information to demonstrate that the cause of the situation is well understood including extent of condition on other related SSCs (e.g., common cause).
Revised Criteria (cont)
Provide an evaluation of all safety and security concerns associated with operating outside of the TS or license conditions that demonstrates that the noncompliance will not create undue risk to the public health and safety or involve adverse consequences to the environment. This should include, as appropriate, a description of the condition and operational status of the plant, equipment that is out of service, inoperable, or degraded that may have risk significance, may increase the probability of a plant transient, may complicate the recovery from a transient, or may be used to mitigate the condition. This evaluation shall include potential challenges to offsite and onsite power sources and forecasted weather conditions.
Revised Criteria (cont)
Provide a description of the proposed course of action to resolve the situation (e.g., likely success of the repairs) and explain how the resolution will not result in a different or unnecessary transient. This shall include the time period for the requested discretion and demonstrate a high likelihood of completion within the requested period of enforcement discretion. If the proposed course of action necessitates enforcement discretion greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the licensee shall justify why a longer-term solution (e.g., emergency amendment) should not be processed within the duration of a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> NOED.
Revised Criteria (cont)
Detail and explain compensatory actions the plant has both taken and will take to reduce risk(s), focusing on both event mitigation and initiating event likelihood. Describe how each compensatory measure achieves one or more of the following:
Reduces the likelihood of initiating events, and
Reduces the likelihood of the unavailability of redundant trains, during the period of enforcement discretion, and
Increases the likelihood of successful operator actions in response to initiating events.
Demonstrate that the NOED condition, including compensatory measures will not result in more than a minimal increase in radiological risk, either in quantitative assessment that the risk will be within the normal work control levels (ICCFP less than or equal to 5E-7 and/or ICLERP less than or equal to 5E-8) or in a defensible qualitative manner.
Revised Criteria (cont)
Confirm that the facility organization that normally reviews safety issues has reviewed and approved this request and that a written NOED request will be submitted within 2 days of the NRC staffs decision regarding the NOED.
Next Steps Finalize guidance Internal concurrence Paperwork Reduction Act Clearance Final Issuance
Schedule Public Meeting - Sept 2018 Begin Internal Concurrence - Oct 2018 Final Issuance - Dec 2018