ML20220A291

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Risk-Informed Process for Evaluations Process Public Meeting August 2020
ML20220A291
Person / Time
Issue date: 08/06/2020
From: Audrey Klett, Tim Reed, Antonios Zoulis
NRC/NRR/DORL/LPL4, NRC/NRR/DRA
To:
Klett A
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ML20220A290 List:
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Download: ML20220A291 (13)


Text

Risk-informed Process for Evaluations Tim Reed, NRR/DORL Antonios M. Zoulis, NRR/DRA

A Map of the Universe of Findings Address High safety Not clearly within the Clearly within the issues in this licensing basis licensing basis quadrant Evaluate issue to determine Address issue with appropriate tools such as:

regulatory actions with tools such as:

  • Enforcement
  • 50.54(f) or generic communication
  • Order
  • Backfittting
  • Inspect licensee corrective actions
  • Generic issue process
  • Use LIC-504 and TIA as applicable Not clearly within the licensing basis Clearly within the licensing basis but clearly low safety significance Address finding/violation with appropriate tools EXIT: (i.e., either the licensee comes into compliance
  • Document decision or proposes changes to the licensing basis):
  • Make public record
  • 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) 2 Low safety

What is Different?

Before After Risk-Informed Process for Exemptions Risk-Informed Process for Evaluations Scope Both Exemptions and License Amendment Only for Exemptions Requests Integrated Decision-Making TSTF-505 and 50.69 TSTF-505 and 50.69 or equivalent 3

Risk-informed Process for Evaluations (RIPE)

  • RIPE can be used to address low risk significant non-compliance issues using existing regulations under 10 Code of Federal Regulations (CFR) 50.12 or 50.90.
  • By leveraging current regulation and using risk information, licensees can justify plant-specific licensing changes for low safety significant issues
  • Consistent with our RG 1.174 risk-informed integrated decision-making principles 4

How does RIPE work?

Leverage work done in previous risk-informed initiatives Integrated Decision-making Panel (IDP) - Key Engineering 50.69 Principles RIPE (using existing regulations)

Demonstrated Probabilistic TSTF-Risk Assessment 505 Acceptability 5

RIPE Structure Request via streamlined Assess licensing process Identify risk cumulative management risk Evaluate using IDP actions as Review and and assess necessary Approval plant-Define Non- specific risk compliance issue

Implementation of RIPE Safety Impact Approval Submittal to NRC Characterization Process NRC issues guidance supporting Licensee NRC reviews RIPE Licensee or documents licensing action (Safety NRC identifies Licensee that the non- using Impact non- requests compliance has streamlined Guidance and compliance licensing action minimal safety review process Streamlined issues that may per streamlined impact in and issues Review have minimal review process accordance approval letter Guidance) safety impact with guidance NRC Actions 7

Licensee Actions

Streamlined NRC Review Process T=0 T < 3 Weeks T < 7 Weeks T < 13 Weeks T < 9 Weeks T < 11 Weeks Licensee Acceptance SE Input to DORL Issues Review Issued DORL DORL SE to OGC NLO to Submits RIPE Exemption to OGC DORL Exemption Licensee T=0 T < 3 Weeks T < 6 Weeks T < 10 Weeks T < 20 Weeks T < 15 Weeks T < 17 weeks Licensee Acceptance DORL PM SE Input to DORL Issues Review Issued DORL DORL SE to OGC NLO to Submits RIPE Submits Bi- LAR to OGC DORL LAR Weekly FRN Licensee 8

Example Submittal

  • REGULATORY REQUEST
  • DETAILED DESCRIPTION OF THE REGULATORY ISSUE
  • REFERENCES
  • SUPPORTING INFORMATION FOR CONCLUSIONS REGARDING SAFETY IMPACT:

- If a generic assessment was performed, provide the generic preliminary screening question results, including explanations

- Steps 1 and 2: Site-specific screening question results, including explanations

  • STEP 3 - PRA RESULTS AND ASSOCIATED DISCUSSIONS, INCLUDING SENSITIVITY ANALYSES
  • STEP 4 - ASSESS NEED FOR RISK MANAGEMENT ACTIONS
  • CUMULATIVE RISK RESULTS
  • SAFETY IMPACT CHARACTERIZATION CONCLUSION
  • SIGNIFICANT HAZARDS CONSIDERATIONS
  • ENVIRONMENTAL CONSIDERATIONS 9

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 our Principles of Good Regulation
  • Leverage existing regulations and risk insights

Whats Next?

  • Finalize NRC Temporary Staff Guidance (TSG).
  • Continue working on graded approach to support other levels of risk-informed integrated decision-making.
  • Continue outreach to interested parties and the public.
  • Incorporate TSG into formal NRC NRR Office Instructions.

11

Potential Graded Approach Streamlined Review - No review 50.69 & TSTF-505 of PRA or deterministic review TSTF-425 and TSTF-505 Streamlined Review / Type 2 Deterministic Review TSTF-425 Risk-informed review Other risk information 12

Questions?

Send additional feedback or questions to:

Antonios.Zoulis@nrc.gov Timothy.Reed@nrc.gov 13