ML20220A291
| 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 | |
| Shared Package | |
| ML20220A290 | List: |
| References | |
| Download: ML20220A291 (13) | |
Text
Risk-informed Process for Evaluations 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
- Backfittting
- 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 Different?
Integrated Decision-Making TSTF-505 and 50.69 TSTF-505 and 50.69 or equivalent Scope Only for Exemptions Both Exemptions and License Amendment Requests Risk-Informed Process for Exemptions Risk-Informed Process for Evaluations Before After
4 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
5 How does RIPE work?
Leverage work done in previous risk-informed initiatives 50.69 TSTF-505 RIPE (using existing regulations)
Integrated Decision-making Panel (IDP) - Key Engineering Principles Demonstrated Probabilistic Risk Assessment Acceptability
6 RIPE Structure Request via streamlined licensing 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
- Guidance in ADAMS ML# ML20118C231
NRC issues guidance supporting RIPE (Safety Impact Guidance and Streamlined Review Guidance)
Licensee or NRC identifies non-compliance issues that may have minimal safety impact Licensee documents that the non-compliance has minimal safety impact in accordance with guidance Licensee requests licensing action per streamlined review process 7
NRC reviews licensing action using streamlined review process and issues approval letter Approval Process Safety Impact Characterization Submittal to NRC Implementation of RIPE NRC Actions Licensee Actions
8 Streamlined NRC Review Process T < 13 Weeks DORL Issues Exemption to Licensee T < 11 Weeks OGC NLO to DORL T < 9 Weeks DORL SE to OGC T < 7 Weeks SE Input to DORL T < 3 Weeks Acceptance Review Issued T=0 Licensee Submits RIPE Exemption T < 20 Weeks DORL Issues LAR to Licensee T < 17 weeks OGC NLO to DORL T < 15 Weeks DORL SE to OGC T < 10 Weeks SE Input to DORL T < 6 Weeks DORL PM Submits Bi-Weekly FRN T < 3 Weeks Acceptance Review Issued T=0 Licensee Submits RIPE LAR
9 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
10 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
- Incentivize the further development and use of probabilistic risk assessment models and applications
11 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.
12 Potential Graded Approach 50.69 & TSTF-505 TSTF-425 and TSTF-505 TSTF-425 Other risk information Streamlined Review - No review of PRA or deterministic review Streamlined Review / Type 2 Deterministic Review Risk-informed review
13 Questions?
Send additional feedback or questions to:
Antonios.Zoulis@nrc.gov Timothy.Reed@nrc.gov