ML19260E683
| ML19260E683 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/2019 |
| From: | Ho Nieh Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| Betancourt L., NRR, 301-415-6146 | |
| References | |
| Download: ML19260E683 (3) | |
Text
October 15, 2019 MEMORANDUM TO: All Staff who Support the Nuclear Reactor Safety Program FROM: Ho K. Nieh, Director /RA/
Office of Nuclear Reactor Regulation
SUBJECT:
APPLYING THE PRINCIPLES OF GOOD REGULATION AS A RISK-INFORMED REGULATOR The U.S. Nuclear Regulatory Commission (NRC) is transforming to become a modern, risk-informed regulator and this is an exciting time of change at our agency. Our workload and workforce continue to evolve. For example, electricity market forces are reshaping the operating reactor fleet, new technologies are seeking regulatory reviews and the next generation of nuclear safety professionals is emerging. As such, we must continuously be ready to embrace change in meeting our mission in new and innovative ways. Going forward, the vision for the Nuclear Reactor Safety Program is that:
We make SAFE use of nuclear technology POSSIBLE.
Today marks a new beginning with the major reorganization of the Office of Nuclear Reactor Regulation taking effect. We should appreciate the many things and strengths that have served us well up to this point. At the same time, we must stand ready to embrace new and innovative ways to better meet our mission, such as by using modern technology, working smarter and focusing our attention on the things that matter the most.
Our success in this dynamic environment depends on our ability as individuals and as a team to adapt our behaviors and practices to achieve our mission of reasonable assurance1 of adequate protection of public health and safety, perhaps in ways that are substantially different than before. To help us confidently do our jobs even better, the NRCs Principles of Good Regulation will continue to be our guide for agency decision-making and individual behavior, exactly as the Commission intended2. Familiarize yourself with these Principles and make them your instincts.
The attachment to this memo is intended to be a desktop guide to help align our decision-making and behaviors with the Principles of Good Regulation and with being risk-informed3.
The desktop guide is not all-inclusive, but it is a good place to start when you apply the Principles of Good Regulation in your work. I look forward to working together with all of you to become the modern, risk-informed regulator we are striving to be.
1 Discussions on reasonable assurance can be found in memoranda available at ML18240A410 and ML19015A290 2 https://nrcpublicblog.files.wordpress.com/2017/01/principles-of-good-regulation-announcement-january-17-1991.pdf 3 SRM-SECY-98-144, White Paper on Risk-Informed and Performance-Based Regulation (ML003753601)
NRSP Staff 2
SUBJECT:
APPLYING THE PRINCIPLES OF GOOD REGULATION AS A RISK INFORMED REGULATOR DATE: October 15, 2019 DISTRIBUTION:
RidsEdoMailCenter RidsResOd RidsNmssOd RidsRgn1MailCenter RidsRgn2MailCenter RidsRgn3MailCenter RidsRgn4MailCenter RidsOeMailCenter RidsOiMailCenter RidsOgcMailCenter RidsNsirMailCenter RidsOpaMail RidsOcaMailCenter ADAMS Accession Number: ML19260E683 *via email OFFICE NRR NRR/DMLR NRO/DLSE RES/D NAME LBetancourt JDonogue* ABradford* RFurstenau*
DATE 09/18/19 09/19/19 09/19/19 09/25/19 OFFICE RI/RA RII/RA RIII/RA RIV/RA NAME DLew* JMunday* DRoberts* SMorris*
(for LDudes)
DATE 09/27/19 09/27/19 09/30/19 09/25/19 OFFICE NMSS/D NSIR/D OE/D OGC NAME JLubinski* MLombard* GWilson* BClark*
(for BHolian) (for MZobler)
DATE 10/02/19 09/26/19 09/30/19* 10/11/19 OFFICE NRR/D NAME HNieh DATE 10/15/19 OFFICIAL RECORD COPY
Some Key Questions for Practical Application of the Principles of Good Regulation Does my decision create trust in the NRC to be an objective, competent regulator?
Did I apply enough of my own expertise, experience and analytical tools beyond what the licensee or applicant provided?
Is my decision free from undue or unreasonable pressure from interested parties?
Independence Am I confident that my decision was not made in isolation?
Have I considered viewpoints of all those who may be affected by this decision?
Is this a high interest decision or issue that warrants additional measures for early engagement, public transparency and/or participation?
Have I considered whether additional communications are needed with the licensee or applicant, Congress, other federal and state government agencies, Openness non-governmental organizations, local citizens or the international community?
Have I taken steps such that those affected will not be surprised by this decision?
Does my decision achieve the desired result in the most cost-effective way?
Is my level of effort commensurate with the safety or security significance?
Have I met the standard of reasonable assurance, not more and not less? If I am not sure, have I sought advice or elevated the matter so that I will not expend Efficiency unnecessary effort or expense?
Have I considered process improvements to be more effective and efficient?
Am I clear on the regulatory bases for my decision? Is my work tied directly to NRC requirements?
Have I clearly and concisely explained the regulatory decision or position?
Have I developed key messages that are safety-focused and appropriate for the Clarity audience?
Am I prepared to deliver my key messages in a succinct way that is not dull? Have I practiced and rehearsed my delivery?
Did I consider the risk triplet: What can go wrong? How likely is it? What are the consequences? The risk triplet can be considered for all decisions, technical and corporate.
Have I applied a risk-informed approach that considered risk insights along with other factors (e.g., defense-in-depth, safety margins and risk mitigation actions) to focus regulatory attention commensurate with the safety and security significance?
Reliability Is my decision supported by reliable data and/or the best available information (e.g., domestic or international research and operating experience)?
Have I considered the relevant uncertainties in my evaluation?
Have the appropriate backfitting or forward fitting standards been considered in my decision-making?
Is my decision fair and is it timely?
Attachment