ML18177A448

Licensee Japan Industry Workshop for Understanding NRCs Reactor Oversight Process June 2018

ML18177A448
Person / Time
Issue date:	06/26/2018
From:	Russell Gibbs NRC/NRR/DIRS/IRAB
To:
Gibbs R, NRR/DIRS, 415-8578
References
Download: ML18177A448 (31)

Text

Licensee Workshop for Understanding NRCs Reactor Oversight Process Perspectives on the SDP, PRA and PI&R Presented by Russell Gibbs - U.S. Nuclear Regulatory Commission 8 June, 2018 Tokyo, Japan

Oversight Framework Initiating Events Mitigating Systems Barrier Integrity Emergency Preparedness Occupational Radiation Safety Public Radiation Safety Physical Protection NRCs Overall Safety Mission Strategic Performance Areas Protect Public Health and Safety as a Result of Civilian Nuclear Power Operation Reactor Safety Radiation Safety Safeguards 2

Reactor Oversight Process 3

ROP Simplified Cornerstone Baseline Inspection Results Significance Threshold Action Matrix Significance Threshold Performance Indicator Results Regulatory Response 4

ROP Goals

• Maintain safety

• Improve efficiency and effectiveness

• Increase public confidence

• Reduce unnecessary regulatory burden 5

SDP Objectives (1) 6

• Characterize significance of inspection findings, using best available information

• Provide stakeholders an objective and common framework for communicating the potential safety significance of inspection findings.

SDP Objectives (2) 7

• Provide basis for timely assessment and/or enforcement actions

• Provide inspectors with plant-specific risk information for use in risk-informing the inspection program

8 The Reactor Oversight Process is designed to be risk-informed and performance based.

Risk-informed = using both relevant quantitative and qualitative information for decisions Risk-informed PRA 9

What is a risk-based decision?

Possible Answer - when the decision-maker overly relies upon risk information that may not be relevant and/or involves high levels of uncertainty.

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How can a risk-informed decision be made for reactor power oversight?

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What are appropriate and relevant risk-informed decision-making inputs?

(Regulatory Guide 1.174) 12 12

Inappropriate Inputs to Decision 13 Media interest Personal prejudices Political implications Financial impacts on licensees Gut feel (i.e., judgement with no technical basis)

When PRA not available or not productive for decision-making consider such factors as

• Extent of degraded condition

• Exposure time

• Recovery actions

• Defense-in-depth

• Safety Margin 14

NRC Confidence in PRA

• PRA is an essential tool for evaluating risk increase in licensee performance deficiencies.

• PRA has matured since 1980s

• SPAR models are used to verify licensee results.

• PRA models have been peer reviewed

• NRC trains staff on PRA and its applications.

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Balancing Qualitative and Quantitative Information

• NRC uses risk-informed qualitative information to screen inspection findings.

• Detailed risk evaluations require use of influential assumptions.

• Limitations of PRA must be considered Biasing inputs and integrating results objectively is main challenge.

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Use caution on over reliance on PRA point estimates for the SDP and possible misapplication of PRA 17 17

Key SDP Program Documents (1)

• Overall Program Document (IMC 0609)

• Significance and Enforcement Review Panel Process (IMC 0609 Att. 1)

• Appeal Process (IMC 0609 Att. 2) 18

Key SDP Program Documents (2)

• SRA Expectations (IMC 0609, Att. 3)

• Initial Characterization Procedure (IMC 0609 Att. 4)

• Bases Documents (IMC 0308, Att. 2)

• Risk Assessment Standardization Project (RASP) Handbook 19

Specific SDP Documents

• Numerous cornerstone/inspection finding specific SDP procedures developed (i.e., IMC 0609 Apps A - O and their basis documents)

- promotes objectivity, reliability and efficiency!

• Deterministic SDP procedures used for EP, RP and Security

• Probabilistic SDP procedure used for IE, MS and BI cornerstones 20

21 SDP Program management mainly includes annual assessment and associated metrics and stakeholder feedback for continuous improvement

Interactions with Stakeholders Main reason for ROP success is intensive and frequent engagement with industry and other external stakeholders 22

Communications with Licensees (1)

• An open and transparent dialogue is essential

• Access to licensee models is preferred

• Must consider licensee perspectives

• Routine meetings conducted on PRA modelling/data issues 23

Communications with Licensees (2) 24

• For significant inspection findings there is significant dialogue with Senior Reactor Analysts, NRC managers and licensees

• New process developed to further improve communications

• Publicly available RASP Handbook is helpful

Problem Identification & Resolution 25

Perspectives on PI&R Oversight (1) 26

• Identifying and correcting plant problems is a foundation of the Reactor Oversight Process

• Baseline inspections performed on a routine basis and as needed for significant inspection findings

Perspectives on PI&R Oversight (2) 27

• NRC offers oversight credit for good licensee performance

• More significant problems = more PI&R inspection Viewpoint - NRA and industry reaching a common understanding on licensee Corrective Action Programs is a significant challenge for NRAs revised oversight program.

PI&R Methods (1) 28

• Are plant issues being appropriately added to the licensees Corrective Action Program?

• Are the cause(s) of problems being evaluated in an acceptable manner?

• Are problems evaluated and corrected to prevent recurrence in a timely manner?

PI&R Methods (2) 29

• Is operating experience being properly evaluated?

• Are self-assessments effective?

• Are effective trending analyses being conducted?

• Is there a healthy safety conscious work environment?

Final Thoughts 30 Will Japans nuclear industry be ready for NRAs pilot of its revised oversight program beginning in October 2018?

What are the key areas of needed attention and focus?

Suggest intensive and frequent dialogue with NRA going forward on key revised oversight program elements!

Questions and Answers 31