EVALUATING INTERNAL STAKEHOLDER PERSPECTIVES ON RISK-INFORMED REGULATORY PRACTICES FOR THE NUCLEAR REGULATORY COMMISSION Page: 4 of 7
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WM'03 Conference, February 23-27, 2003, Tucson, AZ
providing a holistic view of system impacts and safety concerns, and reducing unnecessary
Though preferred paths forward differed, staff and managers were remarkably consistent in
identifying specific challenges that the reactor program faces in moving to a risk-informed
Clear and Common Understanding of Risk-Informed Practices
Every focus group and many individual interviews revealed concern over the lack of a common
understanding of what "risk-informed" means. Respondents felt that a clear, consistently agreed-
upon definition either did not yet exist or had not been adequately communicated. Respondents
believed that risk-informed approaches are intended to draw from the strengths of both
deterministic and PRA techniques, but didn't know what this ideal means in a practical sense for
individual jobs and tasks. Both staff and lower-level managers indicated they were looking for
increased leadership in this area, asking questions like, "How do we do it? What are the
objectives? What is the proper balance between risk and deterministic approaches? How do we
retain the concept of defense-in-depth?" These kinds of questions were raised many respondents
with both minimal and extensive experience with and acceptance of PRA technology.
In The Structure of Scientific Revolutions, Thomas Kuhn says a paradigm provides both model
problems and model solutions and discusses the problems this fact can cause when a group is
shifting to a new paradigm. Although PRA is often referred to as a tool or a technology, some
respondents perceived that its use requires a different set of underlying assumptions than the
deterministic design-basis approach. As NRC shifts from using risk insights to adjust the amount
of testing required for different components to applying the technology more rigorously, the
organization faces a set of challenges broader than simply encouraging the use of a new tool.
The profundity of this shift may account, in part, for the widely shared lack of clarity about the
term "risk-informed." Some respondents recognized that PRA is being applied more as a change
in philosophy than simply as a new tool. For example, in the case of the South Texas request for
exemptions regarding treatment of structures, systems, and components (SSCs), underlying
changes in assumptions were not clarified to staff in the presentation of the project. It was not
clear what the current regulations allowed or who bore the responsibility for ensuring that
functionality of SSCs was being maintained. Many respondents thought this example made it
clear that PRA is not simply another tool, but a change in philosophy requiring careful attention
to the way new tasks are framed and how risk-informed approaches might conflict with current
regulations. Thus, use of PRA introduces not just a new tool for finding an answer, but also a
new type of answer.
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Peterson, L. K.; Wight, E. H. & Caruso, M. A. EVALUATING INTERNAL STAKEHOLDER PERSPECTIVES ON RISK-INFORMED REGULATORY PRACTICES FOR THE NUCLEAR REGULATORY COMMISSION, article, February 27, 2003; Tucson, Arizona. (digital.library.unt.edu/ark:/67531/metadc788345/m1/4/: accessed February 22, 2019), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.