ML20097F786
| ML20097F786 | |
| Person / Time | |
|---|---|
| Issue date: | 04/06/2020 |
| From: | William Burton NRC/NRR/DNRL/NLRP |
| To: | |
| William Burton, NRR/DNRL 301-415-6332 | |
| References | |
| Download: ML20097F786 (28) | |
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1 VISION Giving staff the courage to make realchange MISSION We are creative catalysts who remove barriers to innovation and launch initiatives that improvethe way we work to make SAFE use of nuclear technology POSSIBLE 2
BREAKING DOWN BARRIERS Challenge invisible orthodoxies Harness "If you look at history, innovation doesnt come just from giving underappreciated people incentives; it comes from trends creating environments where their ideas canconnect..
Leverage embedded Steven Johnson competencies and assets Address unarticulated needs 3
OPERATING MODEL No two EMBARK projects are alike - so how we engage varies.
We We We We We ENABLE ADVISE PARTNER CREATE TEACH We INSPIRE.
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THE GARAGE NEUROLOGY The Garage is our process DEPARTMENTS Neurology is about understanding improvement effort. It is theplace risk, overcoming fear of failure, where we tune up our processes challenging the status quo, and and upgrade our procedures to breaking down barriers. We transform the way we regulatefor envision an Agency thatproactively the nuclear future. Weare looking and creatively adapts to our at our approach and prototyping environment while staying true to new ideas. our mission.
NEXTGEN DATA #HASHtagChange NextGen Data is focusedon taking HASHtagChange is all about data to the masses, leveraging the improving the experience for our data we have in innovative waysto internal and external bring transparency and greater stakeholders and providing more understanding for better regulatory effective tools that enhance the decisionmaking. way we interact with eachother.
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ASME Code Request for Confirmatory Topical Reports Rulemaking Information Process ELEVATING THE "BUSINESS AS USUAL" Mission Analytics Risk Informed Process Subsequent License Portal for Exemptions Renewal Enhancements 6
ASME Code Request for Confirmatory Topical Reports Rulemaking Information Process ELEVATING THE "BUSINESS AS USUAL" Mission Analytics Risk Informed Process Subsequent License Portal for Exemptions Renewal Enhancements 7
Rethinking Standard OpE Keyword List Goal: Reduce unnecessary burden on the licensee and staff while maintaining the ability to do an appropriate and effective OpE review.
Why?
- The standardized list of 179 keywords approved in Nov. 2017 keeps changing and growing. The keywords are of varying usefulness to the staff Picture of key word list forthcoming How?
- Surveying Staff to find out which words are most essential to have in the licensee-prepared spreadsheet and analyzing the results.
- Discussing ways of doing things differently with industry in order to understand the impact.
Draft keyword list as of 4/1.
Subject to change!
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Could we.
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Could we.
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Could we.
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Could we.
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Could we.
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Could we.
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Could we.
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Thank you!
We will go back and refine the list based on what weve heard here today.
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Use of Formal Risk But what about PRA Information and other formal risk information? Generally, yes, Can it be used in a although some SLRA? approaches are more achievable in the short term.
Ready to Explore AMPs 17
Working Groups Next Steps Engage industry, through public meetings, to determine the level of interest in using PRA or other risk insights in the various parts of the license renewal application.
Develop conceptual guidance for NRC staff to use when reviewing PRA or risk insights as part of the license renew review, including how and when to engage risk experts.
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EMBARK Venture Studio - Risk Informing Subsequent License Renewal (RISLR) Project Potential Subsequent License Renewal Process Enhancements 19
Pre-Submittal Meetings Determine what process risk entails for pre-submittal meetings.
Encourage wider use of the pre-submittal meeting process to include early communication on areas such as risk information, deviations from guidance, operating experience, to allow for more efficient and effective allocation of staff resources.
Request the applicant to provide additional information during pre-submittal meetings including the use of corporate or fleet procedures that have been reviewed by the staff for previous applications for aging management activities.
Identify incomplete SLRA areas during the pre-submittal meetings, which can be addressed prior to submittal.
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Acceptance Review Determine what process risk entails for the acceptance review.
Consider the use of a representative team to perform the acceptance review of the SLRA.
Leverage the acceptance review phase to communicate new or complex technical issues early in the review.
Identify missing SLRA information that is low risk (low safety risk or low process risk) -
accept the application contingent on receiving the additional, low risk information within x number of days (during which the staff might audit or have a public meeting on these areas).
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SLRA Section 2 - Scoping and Screening Review As identified in the pre-submittal meetings focus staff resources on:
- New or modified plant systems and risk significant systems.
- For the remaining systemsexisting systems, that have not been modified, not of high risk significance, and which were reviewed and approved for the initial license renewal applicationconsider a sampling review of SLRA information and the license renewal drawings.
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SLRA Section 3 - Aging Management Review Streamline and enhance the TRP Tool development to align with project managers workload processing tools to avoid complex/overly burdensome/duplicative process interconnections.
Staff to perform a sample review of not applicable (N/A) line items very few errors (typically none) have been identified during previous reviews.
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- Review all TLAAs but focus staff resources on TLAAs that have not been previously evaluated (if any are identified).
- Reduce staff focus on non-time dependent TLAA attributes that were reviewed and approved during the initial license renewal application review.
Request applicants to specifically identify any changes in the non-time-dependent attributes of TLAAs.
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Operating Experience (OE) Audit Reevaluate the current practice of requesting the applicant to develop an excel file of the results of a query of the CAP data base, based on staff supplied keywords, for the preceding 10 years.
Determine whether a common time period (e.g. 10 year) is appropriate for various AMPs.
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Operating Experience (OE) Audit Consider relocating the audit to the applicants facility, with direct access to the CAP database.
Perform the OE audit using a representative team of approximately eight technical reviewers, where each reviewer would support the reviews of additional staff members.
Expand the scope of the OE Audit to address any to discuss the pre-developed RAIs, RCIs, complex technical issues, and perform necessary visual observations of equipment conditions and configurations.
The audit might be referred to as the OE and Aging Management Audit with an anticipated audit length of one week.
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In-Office Audit Increase the use of Request for Confirmation of Information (RCIs) - note this is the new term for the 4d, process.
Initial portal documentation to include SLRA development implementing procedures, AMP/TLAA basis documents, and information providing a basis for AMPs taking an exception/enhancement to GALL. Additional portal requests tohave a regulatory and technical basis related to an RAI, RCI, or complex technical issue.
Continue to use additional on-site audits and public meetings, as necessary to resolve complex technical issues as early as possible during the review period.
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Thank You Additional questions?
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