ML19274C659
| ML19274C659 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/2019 |
| From: | Don Helton NRC/NRR/DRA/APOB |
| To: | |
| RAKOVAN L/NMSS/MSST | |
| Shared Package | |
| ML19274C654 | List: |
| References | |
| Download: ML19274C659 (6) | |
Text
Low Safety Significance Issue Resolution Don Helton Senior Reliability & Risk Analyst Division of Risk Assessment Office of Nuclear Reactor Regulation National State Liaison Officer Conference September 4, 2019
2 Risk-informing isnt new, but it can be improved.
- Long-standing commitment to risk-informing:
- Successful in a lot of areas
- Existing processes that cover many contexts
- Working group stood up in November 2018:
- Identify means to enhance NRC internal processes to mitigate situations where an inappropriate expenditure of resources and attention is applied to issues of low safety significance
- Initial focus is on operating nuclear reactors; concepts are broader
- Common culprits: dispute on licensing basis standing, safety significance Risk-informed approach:a philosophy whereby risk insights are considered together with other factors SRM-SECY-98-144
3 The exception, not the rule Most issues High resources, little gain?
Help available
4 To find your way home, you must know where you are on the map.
Clearly within the existing licensing basis NOT clearly within the existing licensing basis High safety significance Low safety significance Issue must be resolved per governing statute (compliance) -
only the means and timeline are negotiable NRC has the discretion (and responsibility) to manage its resources in the best interest of public health and safety E.g., Backfit E.g., Generic communication E.g., No action E.g., Order E.g.,
Enforcement Discretion E.g., Change requirement (rulemaking)
5 We are recommending specific changes, and further exploration.
[Preliminary, and subject to change]
- Enhance existing processes to make licensing basis standing and safety significance more integral to resource management during issue exploration
- Earlier litmus test in inspection issue handling
- Explicit screening and evaluation in Technical Assistance Requests
- Training for enhanced processes
- Exploring longer-term activities for more efficiently resolving low-safety compliance issues
6 Next steps
- Recommendations to NRR Office Director - Forthcoming
- Guidance document updates and review/issuance - Ongoing
- Staff training - Planned
- Will need to sync with other ongoing changes (e.g., Commission direction on backfitting and forward-fitting)
- Exploration of longer-term initiatives - TBD
- Will also need to sync with other activities (e.g., SECY-18-0060 recommendation on risk-informing 10 CFR 50.59)