A full ALARP framework relies on explicit estimation of the value of statistical live (VSL). It relies on explicit statements of risk tolerance. Barriers to Implementation (some overlap with above) “cons” 1. Need to place a value on a statistical life. 2. Regulator and stakeholder unfamiliarity with models that requires some understanding of probability and statistical concepts. 3. Lack of data and deficiencies in quantitative models. 4. ALARP requires an explicit statement of risk tolerance, stated in the form of the upper and lower risk tolerability limits in the ALARP diagrams. 5. Absent more robust quantitative risk models, it would be difficult to attribute an incremental benefit to any particular threat and any particular mitigation control measure associated with that threat. (For example, leak survey is one type of risk mitigation but the total benefit must somehow be apportioned to all threats that have benefited from the leak survey, including for example, internal corrosion, external corrosion, stress corrosion cracking, earth movement, etc. 6. Regulators’ accidents” expectation does not conform with “no reality. SED Comments SED Staff asserts that the As Low As Reasonably Practical (ALARP) framework is a valuable alternative for consideration by the Commission. ALARP is an overarching framework meant to be used in conjunction with whatever risk evaluation tool that a utility may use (including the Joint Intervenors’ proposed approach). ALARP tends to be more useful in the longer horizon as the models mature and can incorporate more fully probabilistic
A full ALARP framework relies on explicit estimation of the value of statistical live (VSL). It relies on explicit statements of risk tolerance. Barriers to Implementation (some overlap with “cons” above) 1. Need to place a value on a statistical life. 2. Regulator and stakeholder unfamiliarity with models that requires some understanding of probability and statistical concepts. 3. Lack of data and deficiencies in quantitative models. 4. ALARP requires an explicit statement of risk tolerance, stated in the form of the upper and lower risk tolerability limits in the ALARP diagrams. 5. Absent more robust quantitative risk models, it would be difficult to attribute an incremental benefit to any particular threat and any particular mitigation control measure associated with that threat. (For example, leak survey is one type of risk mitigation but the total benefit must somehow be apportioned to all threats that have benefited from the leak survey, including for example, internal corrosion, external corrosion, stress corrosion cracking, earth movement, etc. 6. Regulators’ “no accidents” expectation does not conform with reality. SED Comments SED Staff asserts that the As Low As Reasonably Practical (ALARP) framework is a valuable alternative for consideration by the Commission. ALARP is an overarching framework meant to be used in conjunction with whatever risk evaluation tool that a utility may use (including the Joint Intervenors’ proposed approach). ALARP tends to be more useful in the longer horizon as the models mature and can incorporate more fully probabilistic
165087191.docx