ML20118C188
| ML20118C188 | |
| Person / Time | |
|---|---|
| Issue date: | 05/04/2027 |
| From: | Tim Reed, Antonios Zoulis NRC/NRR/DORL/LPL2-1 |
| To: | |
| Audrey K | |
| References | |
| Download: ML20118C188 (15) | |
Text
Risk-informed Process for Exemptions Tim Reed, NRR/DORL Antonios M. Zoulis, NRR/DRA
2 A Map of the Universe of Findings High safety Low safety Clearly within the licensing basis Address issue with appropriate tools such as:
- Enforcement
- Order
- Inspect licensee corrective actions Clearly within the licensing basis Address finding/violation with appropriate tools (i.e., either the licensee comes into compliance or proposes changes to the licensing basis):
- Inspect licensee corrective actions (e.g., 50.59, PI&R)
- Change the licensing basis (LAR, relief, exemptions, etc.)
- Assess adequacy of the requirement (i.e., rulemaking)
Not clearly within the licensing basis Evaluate issue to determine regulatory actions with tools suchas:
- 50.54(f) or generic communication
- Backfitting
- Generic issue process
- Use LIC-504 and TIA as applicable Not clearly within the licensing basis but clearly low safety significance EXIT:
- Document decision
- Make public record Address issues in this quadrant
3 What is Risk-informed Process for Exemptions (RIPE)?
- RIPE could be used to address non-compliance issues that have a minimal safety impact using existing regulations, such as:
- 10 CFR 50.12(a)(2)(iii), Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated
- 10 CFR 50.12(a)(2)(iv), the exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption
- By leveraging current regulation and using risk information, licensees could justify plant-specific exemptions where the compensatory actions eliminate most of the risk without imposing undue burden.
4 What is RIPE? (Cont.)
Regulations Does not displace rulemaking.
Does address unique plant non-compliance issues that would be specific to a narrow portion of the regulation for that licensee.
Exemption Does not change how licensee makes the determination concerning validity of exemption request.
Does inform the level-of-effort NRC staff will expend to conduct review and approval/denial of exemption request.
Inspection/Enforcement Does not involve inspection and enforcement of findings and violations.
Does support how those violations and findings are corrected.
5 What is (RIPE)? (Cont.)
Leverage work done in previous risk-informed initiatives 50.69 TSTF-505 RIPE (using existing 50.12 regulations)
Integrated Decision-making Panel (IDP) - Key Engineering Principles Demonstrated Probabilistic Risk Assessment Acceptability
6 What is RIPE? (Cont.)
Request via streamlined exemption process Review and Approval Define non-compliance issue Evaluate using IDP and assess plant-specific risk Identify risk management actions as necessary Assess cumulative risk
NRC issues guidance endorsing RIPE Licensee or NRC identifies noncompliance issues that may have minimal safety impact Licensee prepares documentation per guidance Licensee requests exemption using §50.12 per RIPE process 7
NRC evaluates exemption via streamlined review Approval Process Safety Significance Characterization Submittal to NRC Implementation of RIPE NRC Actions Licensee Actions
8 Safety Impact Characterization Overview
9 Safety Impact Characterization Identify issue that requires NRC review for resolution and potentially has a minimal risk impact EP SECURITY Current phase will focus on Reactor Safety NRC-identified or licensee-identified
10 Safety Impact Characterization Define the issue Explore the issue in detail using a Generic Assessment Expert Team (GAET) and/or plant-specific integrated decision-making panel (Plant IDP)
Finalize responses to the screening questions Generic or Plant-specific
11 Safety Impact Characterization Finalize responses to the screening questions Consider risk management actions Assess the cumulative risk Is the risk impact minimal?
Submit the licensing action to the NRC for a streamlined review Bring the plant into compliance or submit the change to the NRC using another process CDF < 1E-07, LERF < 1E-08, and less than 1% of the overall CDF & LERF
12 RIPE Streamlined Review Staff Role Typical Work Scope for Exemptions Streamlined Scope for RIPE DORL Project Manager Correspondence NEPA Review Process/regulatory conformance Section I (Background)
Section II (Request/Action)
Section III.A (Authorized by Law)
Section III.C (Common Defense)
Special Circumstances
CatEx or EA development Section IV (Conclusions)
Final Package Assembly - FRN Regulatory review Same DRA Risk Analyst SE Input Section III.B (No Undue Risk )
PRA Acceptability As Built/As-Operated Plant Peer Review Documentation consistent with the Standard Key Assumptions/Sources of Uncertainty F&Os Baseline Risk/Delta Risk Quantification
RG 1.174s 5 key principlesSection III.B (No Undue Risk )
Confirm TSTF 505 and 50.69 approved and all license conditions completed.
Confirm issue is within the scope of the licensees PRA and risk impact can be modeled using PRA.
Technical Reviewer(s)
SE Input Defense in Depth (DID)
Safety Margins (SM)
Section III.C (Special circumstances)
Section III.C, Verify special circumstances exist (DID & SM used in IDP evaluation and was reviewed via TSTF-505 & 50.69 approval)
Environmental Reviewer NEPA Review Verifies CatEx applies if requested by PM; Concurs on EA developed by PM or Develops EA Same Most applications will likely qualify for CatEx Env CoE developing checklist OGC Legal review
~10 business days TBD/Same
13 Why RIPE?
- Focus NRC and licensee resources on the most safety significant issues.
- Address low safety compliance issues in an efficient and predictable manner consistent with NRC's Principles of Good Regulation.
- Leverage existing regulations and risk insights.
- Incentivize the further development and use of probabilistic risk assessment models and risk-informed applications.
14 Whats Next?
- Obtain feedback from industry and the public on interest in applying the process.
- Conduct a pilot of the process.
- Finalize RIPE guidance.
15 Questions?
Send additional feedback or questions to:
RIPE_EMBARK@usnrc.onmicrosoft.com