ML20220A291

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
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Klett A
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ML20220A290	List: ML20220A291 ML20220A292
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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.

• Incorporate TSG into formal NRC NRR Office Instructions.

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