NRC Inspection Manual 0609/Appendix M, Significance Determination Process Using Qualitative Criteria

From kanterella
Jump to navigation Jump to search

text

Issue Date: 01/10/19 1 0609 App M

NRC INSPECTION MANUAL APOB

INSPECTION MANUAL CHAPTER 0609 APPENDIX M

SIGNIFICANCE DETERMINATION PROCESS

USING QUALITATIVE CRITERIA

0609M-01 PURPOSE

This appendix provides guidance for assessing the significance of inspection findings in all

cornerstones of the Reactor Oversight Process (ROP) to allow the NRC to apply a consistent

process of using qualitative and quantitative attributes for risk-informed decision making.

Appendix M should not be used by decision makers when the results of another Significance

Determination Process (SDP) appendix do not appear to be appropriate (i.e., the significance is

perceived as too high or too low). In these cases, the appropriate SDP appendix should be

used and a deviation from the ROP Action Matrix should be pursued in accordance with

Inspection Manual Chapter (IMC) 0305, “Operating Reactor Assessment Program.”

0609M-02 ENTRY CONDITIONS

a. As specifically directed by other IMC 0609 appendices, or

b. When the cognizant NRC staff determine that no other SDP appendix is compatible for

use with the specific circumstances associated with the inspection finding and the

associated degraded condition (e.g., readily-available information is insufficient to

support a reliable and efficient evaluation), subject to confirmation by a planning

Significance and Enforcement Review Panel (SERP).

0609M-03 BACKGROUND

Occasionally, the staff may identify challenges in conducting an efficient assessment for an

inspection finding using readily-available methods. For example, there may be cases where an

appropriate SDP tool does not exist to determine the risk impact of a finding. In that case, the

safety significance of a finding must ultimately be determined using qualitative engineering

judgment and regulatory oversight experience, which is an acceptable approach in a

risk-informed process. In other cases, existing quantitative tools may not be well suited for the

specific application because the finding either (a) is particularly complex or (b) involves cause

and effect relationships, phenomena, or plant operations where the accident sequence

modeling state-of-practice is undeveloped. All probabilistic evaluations have an inherent level of

uncertainty associated with their quantitative outcomes. However, the amount of uncertainty

can vary depending on how well the risk impact of the finding can be modeled using available

state-of-the-art tools and other sources of information (e.g., Standardized Plant Analysis Risk

(SPAR) models, SDP appendices, licensee input). In cases of high uncertainty, the risk

evaluation process can take significantly more time than is necessary or reasonable for most

ROP applications. In all cases, a clear and well understood inspection finding must be

established in accordance with the guidance in IMC 0612, “Issue Screening.”

Issue Date: 01/10/19 2 0609 App M

Unless explicitly directed to use Appendix M by SDP guidance, the staff should conduct a

planning SERP to determine if Appendix M is an appropriate tool for characterizing the

significance of a finding. Careful consideration is warranted in considering this tool, especially if

another SDP tool or method provides a suitable approach (e.g., a degraded condition may be

readily modeled, uncertainties associated with an initiating event frequency or failure rate

probability may be sufficiently understood). In these cases, an existing SDP tool may provide a

suitable characterization of significance within the established SDP timeliness goals.

0609M-04 EVALUATION PROCESS

Findings should be assessed using risk insights along with deterministic engineering judgment

relying upon in-house engineering knowledge and expertise, regulatory oversight experience,

and best available information.

SECY-98-144 describes a “risk-informed” approach to regulatory decision making as one that

represents a philosophy whereby risk insights are considered together with other factors to

establish requirements that better focus licensee and regulatory attention on design and

operational issues commensurate with their importance to public health and safety. This

philosophy was elaborated on in Regulatory Guide (RG) 1.174 to develop a risk-informed

decision-making process for licensing changes. This philosophy has since been implemented in

other NRC risk-informed activities. In developing the risk-informed decision-making process,

the NRC defined a set of key principles in RG 1.174 to be followed for risk-informed decisions

regarding plant-specific changes to the licensing basis; however, the principles are global in

nature and can be generalized to all activities that are the subject of risk-informed decisionmaking.

  • Principle 1: Current Regulations Met
  • Principle 2: Consistency with Defense-in-Depth Philosophy
  • Principle 3: Maintenance of Safety Margins
  • Principle 4: Acceptable Risk Impact
  • Principle 5: Monitor Performance

The generalized approach integrates all the insights and requirements that relate to the safety

or regulatory issue of concern. These insights include any deterministic and/or probabilistic

analyses performed to support decision-making. The generalized approach ensures that

defense-in-depth measures and safety margins are maintained. The impact of the inspection

finding on Principles 2 and 3 have been evaluated using the guidance in Exhibit 2. Elements of

Principle 4, to the extent information is readily available, have been considered while performing

the evaluation described in Step 4.1. Aspects of Principles 1 and 5, while potentially not directly

applicable, can manifest themselves via the attributes that have already been evaluated (e.g., if

an inspection finding causes the plant to enter into an unanalyzed condition, the elevated risk

associated with that unanalyzed condition can often be correlated to an associated degradation

of safety margin or defense-in-depth).

Step 4.1 - Initial Evaluation

4.1.1 The purpose of this step is to determine if there are any significance colors (Green,

White, Yellow, or Red) that can be reasonably excluded from further consideration via

an initial evaluation using available quantitative and/or qualitative methods and best

available information. These methods should be consistent with traditional assessment

Issue Date: 01/10/19 3 0609 App M

approaches using reasonably conservative assumptions (e.g., minimal to no recovery

actions, use of screening values for human error probabilities). The evaluation should

not involve a detailed risk evaluation (although it may involve a simpler use of the same

tools) and need not be quantitative (e.g., in the case of findings associated with the

Emergency Preparedness and Radiation Protection cornerstones)1

. If the evaluation

shows that the finding is of very low safety significance (i.e., Green), the finding can be

documented in accordance with IMC 0611, “Power Reactor Inspection Reports,” and

the guidance provided in Step 4.4.2 of this appendix.

4.1.2 If the initial evaluation indicates that the risk significance of the finding is potentially

greater than Green, document the results using Exhibit 1, “Results of Initial Evaluation,”

of this appendix and then proceed to Step 4.2.

Step 4.2 - Attributes

4.2.1 For findings in which the risk significance is potentially greater than Green, evaluate the

following attributes to determine the significance of the finding, then proceed to

Step 4.3. Guidance on evaluating each attribute is contained in Exhibit 2,

“Considerations for Evaluation of Decision Attributes,” of this appendix.

4.2.1.1 Defense-in-Depth

4.2.1.2 Safety Margin

4.2.1.3 Extent of condition

4.2.1.4 Degree of Degradation

4.2.1.5 Exposure Time

4.2.1.6 Recovery Actions

4.2.1.7 Additional Qualitative Attributes

Step 4.3 - Integrated Risk-Informed Decision-Making

4.3.1 Integration of the results requires that the individual insights obtained from each

element of the decision-making process be weighed and combined to reach a

conclusion, in this case a decision on the significance of the finding. The staff involved

with analysis of the finding (e.g., inspectors, probabilistic risk assessment (PRA)

experts, engineering staff) should participate in the integration process. An example

approach to integrating multiple diverse sources of information as part of decisionmaking can be found in LIC- 504, “Integrated Risk-Informed Decision-Making Process

for Emergent Issues,” Appendix E, but use of those concepts should be in concert with

SDP-specific decision-making guidance contained in IMC 0609 Attachment 1.

Step 4.4 - Process and Documentation

4.4.1 If the results of the Appendix M evaluation indicate a greater than Green finding, the

decision-making logic should be documented using Table 1, ”Qualitative DecisionMaking Attributes for NRC Management Review,” and should be included in the SERP

package as described in IMC 0609, Attachment 1, “Significance and Enforcement

Review Panel.”

1

In cases where a qualitative approach is necessitated or appropriate, analogues can be drawn to existing

relationships between a performance deficiency and significance (from the IMC 0609 appendix relevant to the

performance deficiency) in order to establish a conservative estimate of the finding’s significance.

Issue Date: 01/10/19 4 0609 App M

4.4.2 If the results of the Appendix M evaluation indicate a Green finding, document the

quantitative and/or qualitative methods used, including the results, in the inspection

report.

0609M-05 REFERENCES

IMC 0609, Attachment 1, “Significance and Enforcement Review Panel Process”

IMC 0611, “Power Reactor Inspection Reports”

IMC 0612, “Issue Screening”

NRC Regulatory Guide 1.174, “An Approach for Using Probabilistic Risk Assessment in RiskInformed Decisions on Plant-Specific Changes to the Licensing Basis”

NRR Office Instruction LIC-504, “Integrated Risk-Informed Decision-Making Process for

Emergent Issues”

NRC, “Staff Requirements Memorandum - SECY-98-144 - White Paper on Risk-Informed and

Performance-Based Regulation,” SRM-SECY-98-144, March 1, 1999.

NUREG-1855, “Guidance on the Treatment of Uncertainties Associated with PRAs in RiskInformed Decisionmaking”

END

Issue Date: 01/10/19 E1-1 0609 App M

EXHIBIT 1 Results of the Initial Evaluation

1. Describe the influential assumptions used in the initial evaluation.

2. Provide sensitivity results on the key influential assumptions. Given that a detailed risk

evaluation is not tractable, these sensitivities might be qualitative or semi-quantitative,

and should only be performed when practical to do so. These might include changes to

the initiating event frequency, equipment failure rates, common cause failure

probabilities, and human error probabilities. In the case of purely qualitative initial

evaluations, these might include subjective evaluations of whether the significance

would differ for alternative assumptions.

3. Identify any information gaps in defining the influential assumptions used in the initial

evaluation.

Initial Evaluation Result: ____________________________

Issue Date: 01/10/19 E2-1 0609 App M

EXHIBIT 2 Considerations for Evaluation of Decision Attributes

A. Defense-in-Depth

Revision 3 of RG 1.174, “An Approach for Using Probabilistic Risk Assessment in RiskInformed Decisions on Plant-Specific Changes to the Licensing Basis,” identifies and

provides a discussion of seven considerations that should be used to evaluate impacts

on defense in depth. While RG 1.174 provides general guidance concerning analysis of

the risk associated with proposed changes in plant design and operation, the

considerations and discussion of defense in depth can be applied to the evaluation of

findings under the Reactor Oversight Process and in the use of this appendix. It is

important to note that the focus here is on the effect of the finding on defense in depth.

The seven defense-in-depth considerations presented are not intended to define how

defense in depth is implemented in a plant’s design, but rather to help the analyst

assess the impact of the finding on defense in depth.

1. Preserve a reasonable balance among the layers of defense.

A reasonable balance of the layers of defense (i.e., minimizing challenges to the

plant, preventing any events from progressing to core damage, containing the

radioactive source term, and emergency preparedness) helps to ensure an

apportionment of the plant’s capabilities between limiting disturbances to the

plant and mitigating their consequences. The term “reasonable balance” is not

meant to imply an equal apportionment of capabilities. The NRC recognizes that

aspects of a plant’s design or operation might cause one or more of the layers of

defense to be adversely affected. For these situations, the balance between the

other layers of defense becomes especially important when evaluating the

impact of a finding and its effect on defense in depth.

2. Preserve adequate capability of design features without an overreliance on

programmatic activities as compensatory measures2

.

Nuclear power plant licensees implement a number of programmatic activities,

including programs for quality assurance, testing and inspection, maintenance,

control of transient combustible material, foreign material exclusion, containment

cleanliness, and training. In some cases, activities that are part of these

programs are used as compensatory measures; that is, they are measures taken

to compensate for some reduced functionality, availability, reliability, redundancy,

or other feature of the plant’s design to ensure safety functions (e.g., reactor

vessel inspections that provide assurance that reactor vessel failure is unlikely).

Other examples include hardware (e.g., skid-mounted temporary power

supplies); human actions (e.g., manual system actuation); or some combination

of these measures. Such compensatory measures are often associated with

temporary plant configurations. The preferred approach for accomplishing safety

functions is through engineered systems. Therefore, when the finding

necessitates reliance on programmatic activities as compensatory measures,

analysis should indicate that this reliance is not excessive (i.e., not overly reliant).

2 The term “compensatory measures” is used here to refer to additional measures in place during the time of the

degraded condition.

Issue Date: 01/10/19 E2-2 0609 App M

The intent of this consideration is not to preclude the use of such programs as

compensatory measures but to ensure that the use of such measures does not

significantly reduce the capability of the design features.

3. Preserve system redundancy, independence, and diversity commensurate

with the expected frequency and consequences of challenges to the system,

including consideration of uncertainty.

The defense-in-depth philosophy has traditionally been applied in plant design

and operation to provide multiple means to accomplish safety functions. System

redundancy, independence, and diversity result in high availability and reliability

of the function and also help ensure that system functions are not reliant on any

single feature of the design. Redundancy provides for duplicate equipment that

enables the failure or unavailability of at least one set of equipment to be

tolerated without loss of function. Independence of equipment implies that the

redundant equipment is separate, such that it does not rely on the same supports

to function. This independence can sometimes be achieved by the use of

physical separation or physical protection. Diversity is accomplished by having

equipment that, while it performs the same function, relies on different attributes,

such as different principles of operation, different physical variables, different

conditions of operation, or production by different manufacturers, which helps

reduce common-cause failure (CCF). A degraded condition might reduce the

redundancy, independence, or diversity of systems. The intent of this

consideration is to ensure that the ability to provide the system function is

commensurate with the risk of scenarios that could be mitigated by that function.

The consideration of uncertainty, including the uncertainty inherent in the PRA,

implies that the use of redundancy, independence, or diversity provides high

reliability and availability and also results in the ability to tolerate failures or

unanticipated events.

4. Preserve adequate defense against potential CCFs.

An important aspect of ensuring defense in depth is to guard against CCF.

Multiple components may fail to function because of a single specific cause or

event that could simultaneously affect several components important to risk. The

cause or event may include an installation or construction deficiency, accidental

human action, extreme external environment, or an unintended cascading effect

from any other operation or failure within the plant. CCFs can also result from

poor design, manufacturing, or maintenance practices. Defenses can prevent

the occurrence of failures from the causes and events that could allow

simultaneous multiple component failures. Another aspect of guarding against

CCF is to ensure that an existing defense put in place to minimize the impact of

CCF is not significantly reduced; however, a reduction in one defense can be

compensated for by adding another.

5. Maintain multiple fission product barriers.

Fission product barriers include the physical barriers themselves (e.g., the fuel

cladding, reactor coolant system pressure boundary, and containment) and any

equipment relied on to protect the barriers (e.g., containment spray). In general,

these barriers are designed to perform independently so that a complete failure

Issue Date: 01/10/19 E2-3 0609 App M

of one barrier does not disable the next subsequent barrier. For example, one

barrier, the containment, is designed to withstand a double-ended guillotine

break of the largest pipe in the reactor coolant system, another barrier. A plant’s

licensing basis might contain events that, by their very nature, challenge multiple

barriers simultaneously. Examples include interfacing-system loss-of-coolant

accidents or steam generator tube rupture. Therefore, complete independence

of barriers, while a goal, might not be achievable for all possible scenarios.

6. Preserve sufficient defense against human errors.

Human errors include the failure of operators to correctly and promptly perform

the actions necessary to operate the plant or respond to off-normal conditions

and accidents, errors committed during test and maintenance, and incorrect

actions by other plant staff. Human errors can result in the degradation or failure

of a system to perform its function, thereby significantly reducing the

effectiveness of one of the layers of defense or one of the fission product

barriers. The plant design and operation include defenses to prevent the

occurrence of such errors and events. These defenses generally involve the use

of procedures, training, and human engineering; however, other considerations

(e.g., communication protocols) might also be important.

7. Continue to meet the intent of the plant’s design criteria.

For plants licensed under Title 10 of the Code of Federal Regulations Parts 50

or 52, the plant’s design criteria are set forth in the current licensing basis of the

plant. The plant’s design criteria define minimum requirements that achieve

aspects of the defense-in-depth philosophy. When evaluating a finding, the

analysis should identify the design criteria that is challenged and how the finding

impacts the design criteria.

B. Safety Margin

Safety margin is the extra capacity factored into the design of a structure, system, or

component (SSC) so that it can cope with conditions beyond the expected to

compensate for uncertainty. The evaluation should assess whether the impact of the

finding is consistent with the principle that sufficient safety margins are maintained. In

evaluating this factor, the staff should use engineering analysis or engineering judgment

appropriate for evaluating whether sufficient safety margins would be maintained given

the finding. The evaluation should consider if the inspection finding identifies an issue

which affects the licensees ability to meet the codes and standards or their alternatives

approved for use by the NRC. Additionally, consider if the finding identifies an issue

which affects meeting safety analysis acceptance criteria in the licensing basis (e.g.,

Update Final Safety Analysis Report, supporting analyses) or proposed revisions that

provide sufficient margin to account for analysis and data uncertainty.

Issue Date: 01/10/19 E2-4 0609 App M

C. Extent of Condition

If a finding is not isolated to a specific occurrence, condition, or event, its safety

significance is typically greater. When a finding is capable of affecting multiple SSCs,

the number of degraded conditions has the potential to be greater than a case in which a

finding is isolated to a specific SSC. The identified extent of condition should have a

reasonable and sound technical basis to justify the scope.

D. Degree of Degradation

The magnitude and detailed circumstances of the degraded condition (or programmatic

weakness) have a direct effect on the safety significance of the finding. As stated in IMC 0308, Attachment 3, “Technical Basis for the SDP,” the finding (i.e., more-than-minor

performance deficiency) is the proximate cause of the degraded condition or

programmatic weakness. Logically, the more a condition is degraded or program is

weakened, the more safety significant the finding.

E. Exposure Time

Generally, the longer a finding is left uncorrected the more opportunities the finding has

to manifest itself (i.e., act as the proximate cause of a degraded condition or

programmatic weakness). As such, the longer the exposure time the more safety

significant the finding.

F. Recovery Actions

Even if the extent of condition, degree of the degraded condition (or programmatic

weakness), and exposure time increased the safety significance of a finding, crediting

established recovery actions or mitigation strategies should be appropriately considered

to determine the overall significance of the finding.

G. Additional Qualitative Attributes

Depending on the situation, the previous six attributes may not capture all of the

qualitative attributes that may apply to the finding. Therefore, additional qualitative

circumstances, as appropriate, may be considered in the decision making process. Any

additional qualitative circumstances for management consideration should have a clear

and reasonable nexus to the safety significance of the finding. If additional qualitative

attributes are considered, one should be particularly aware of the goal of having a

scrutable and repeatable outcome, and should consider whether other decision makers

would reasonably be expected to invoke the same qualitative attributes.

Issue Date: 01/10/19 T-1 0609 App M

TABLE 1

Qualitative Decision-Making Attributes for NRC Management Review

Decision Attribute Basis for Input to Decision - Provide

qualitative and/or quantitative information for

management review and decision making.

Defense-in-Depth

Safety Margin

Extent of Condition

Degree of Degradation

Exposure Time

Recovery Actions

Additional Qualitative

Considerations

Result of management review (COLOR):

Issue Date: 01/10/19 Att1-1 0609 App M

Attachment 1

Revision History IMC 0609 Appendix M

Commitment

Tracking

Number

Accession Number

Issue Date

Change Notice

Description of Change Description of Training

Required and

Completion Date

Comment Resolution

and Closed Feedback

Form Accession Number

(Pre-Decisional, NonPublic Information)

N/A ML062510080

12/22/06

CN 06-036

This new document has been issued to

provide guidance to NRC management and

inspection staff for assessing significance of

inspection findings.

This procedure was

developed by involved

stakeholders. No

training on the

procedure

recommended at this

time. However,

additional guidance

may be developed

based on experience

gained.

ML063050646

N/A ML101550365

04/04/12

CN 12-005

Provided clarification in the Scope and

Applicability sections to articulate the Appendix

M entry conditions and that Appendix M is not

intended to be used to develop new models or

acquire in-depth expert elicitation. In addition,

ROPFF 0609M-1412 was incorporated to

clarify that Appendix M applies to all the safety

cornerstones of the ROP.

None N/A

ML18257A025

DRAFT

Made public to solicit industry comment at the

October 18, 2018, ROP Public meeting.

None N/A

Issue Date: 01/10/19 Att1-2 0609 App M

Commitment

Tracking

Number

Accession Number

Issue Date

Change Notice

Description of Change Description of Training

Required and

Completion Date

Comment Resolution

and Closed Feedback

Form Accession Number

(Pre-Decisional, NonPublic Information)

N/A ML18183A043

01/10/19

Cn 19-002

Provided clarification of the existing entry

conditions to more clearly illustrate when

Appendix M should be used. In addition,

provided clarification of the existing decisionmaking attributes to align with the enhanced

guidance in Revision 3 of Regulatory Guide 1.174, “An Approach for Using Probabilistic

Risk Assessment in Risk-Informed Decisions

on Plant-Specific Changes to the Licensing

Basis,” which was issued in January 2018.

Also, the description of the initial evaluation

was clarified to better align with intent/practice,

since the previous description inferred that (in

the case of a quantitative estimate) one would

use enveloping input assumptions across-theboard. Finally, ROPFF 0609M-2272 was

addressed to make the guidance more useful

for RP and EP findings. A Commissioners’

Assistant note was issued (ML18311A027) to

notify the Commission of the described

changes in accordance with Management

Directive 8.13 and COMSECY-16-0022.

None ML18184A428

0609M-2272

ML18226A054