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Revisions to the Fuel Cycle Revisions to the Fuel Cycle Oversight Process Oversight Process Presentation to the Commission April 29, 2010 Agenda Agenda Current Process Joe Shea Director DFFI, Region II Proposed Revisions


  1. Revisions to the Fuel Cycle Revisions to the Fuel Cycle Oversight Process Oversight Process Presentation to the Commission April 29, 2010

  2. Agenda Agenda • Current Process– Joe Shea Director DFFI, Region II • Proposed Revisions – Dan Dorman Director FCSS, NMSS 2

  3. Overview of the Current Fuel Overview of the Current Fuel Cycle Oversight Process Cycle Oversight Process • Oversight Process Elements – Inspection – Enforcement – Assessment • Implementation 3

  4. Overview of the Current Fuel Overview of the Current Fuel Cycle Oversight Process Cycle Oversight Process (Cont.) (Cont.) • Current program is adequate to ensure safety and security • Current program is evolving, slow ly, w ithin existing framew ork • Approach to improvements can be better focused, more effective and efficient 4

  5. Purpose of Oversight Revision Purpose of Oversight Revision Project Project • To improve program effectiveness and efficiency • To make the process more – Risk-Informed – Performance-Based – Predictable – Transparent 5

  6. Risk Informed & Performance Risk Informed & Performance Based– Current Program Based– Current Program • Inspection – Use of Integrated Safety Analyses (ISA) during inspection planning improves risk focus – Programmatic approach still used in some areas • Enforcement – Proposed policy is more ISA-informed 6

  7. Risk Informed & Performance Risk Informed & Performance Based– Current Program Based– Current Program • Assessment – Process allow s for integration of enforcement actions – Some consideration of risk 7

  8. Predictability – Current Predictability – Current Program Program • Inspection – Reactive and initiative inspection decisions lack clear thresholds • Enforcement – Variability in ISA methods presents a challenge 8

  9. Predictability – Current Predictability – Current Program Program • Assessment – Relationship betw een NRC inspection effort, assessment periodicity, and enforcement history is not w ell defined – Assessment process lacks thresholds for specific licensee and NRC actions 9

  10. Transparency – Current Transparency – Current Program Program • Inspection – Inspection and enforcement results are generally publicly available – Use of w ebpage to present process and outcomes can be improved • Enforcement – Consideration of risk escalators and mitigators not transparent 10

  11. Proposed Plan Proposed Plan • Oversight Framew ork • Risk–Informed Baseline • Significance Determination • Performance Assessment • Enforcement 11

  12. Schedule of Activities Schedule of Activities • Technical Basis Development • Process Development • Transition • Stakeholder Engagement 12

  13. Technical Basis for Risk- Technical Basis for Risk- Informing Informing • Use existing ISA’s • Screening tool for items of very low safety significance • Significance determination flow -charts • Validation • Facilities w ithout ISA’s 13

  14. Definition of Risk Thresholds Definition of Risk Thresholds • Tw o Options Evaluated – Qualitative – Quantitative • Recommendation is for the qualitative 14

  15. Risk-Informing Risk-Informing • Baseline Inspections • Significance Determination Process • Enforcement Policy • Action Matrix 15

  16. Challenges Challenges • Diversity of operation and activities among licensees and certificate holders • Cumulative impacts • Performance Deficiency definition • Corrective Action Program inspection 16

  17. Potential Policy Issues Potential Policy Issues • Deferral of Performance Indicator development • Risk Surrogates and Thresholds • Incorporation of Safety Culture • Performance Deficiency • Security/Safety program interface 17

  18. Alternative Approaches Alternative Approaches • Proposal aligned to ROP principles • Other options include: – Maintain current approach w ith evolving processes – Modest enhancements to current process – Phased revision over longer period 18

  19. Conclusion Conclusion • Current process is adequate but needs to be improved • Proposed improvements w ould use existing ISA’s • Proposed implementation in 2014 • Staff aw aits Commission direction 19

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