ML003701452
| ML003701452 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/2000 |
| From: | Collins S Office of Nuclear Reactor Regulation |
| To: | Ralph Beedle Nuclear Energy Institute |
| Allsopp D | |
| References | |
| Download: ML003701452 (4) | |
Text
April 20, 2000 Ralph E. Beedle Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute 1776 I Street, NW Suite 400 Washington, DC 20006-3708
Dear Mr. Beedle:
In my March 20, 2000, response to your recent letter, dated March 13, 2000, I indicated that the NRC scheduled a public meeting to discuss your concerns regarding the potential unintended consequences of tracking manual scrams as a performance indicator (PI). We were particularly interested in any new information you may have had on this issue. This public meeting was conducted on March 29, 2000. Attachment 1 provides a meeting summary while lists the meeting attendees.
As you know, the value of tracking manual scrams as an indicator has been discussed extensively throughout the development and implementation of the revised reactor oversight process and NEI has been fully involved in determining the state of the current PI which includes tracking manual scrams. While we received no new information during the March 29 meeting, we expressed our interest in working with NEI and other stakeholders to consider an alternate PI that tracks initiating events in a way that minimizes potential unintended consequences. It is our understanding from this meeting that NEI will (1) propose an alternative PI in the near future and (2) take the lead to reemphasize the role of the operator in maintaining plant safety.
Sincerely,
/RA/
Samuel J. Collins, Director Office of Nuclear Reactor Regulation Project No. 689 cc: See next page Attachments: As stated
April 20, 2000 Ralph E. Beedle Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute 1776 I Street, NW Suite 400 Washington, DC 20006-3708
Dear Mr. Beedle:
In my March 20, 2000, response to your recent letter, dated March 13, 2000, I indicated that the NRC scheduled a public meeting to discuss your concerns regarding the potential unintended consequences of tracking manual scrams as a performance indicator (PI). We were particularly interested in any new information you may have had on this issue. This public meeting was conducted on March 29, 2000. Attachment 1 provides a meeting summary while lists the meeting attendees.
As you know, the value of tracking manual scrams as an indicator has been discussed extensively throughout the development and implementation of the revised reactor oversight process and NEI has been fully involved in determining the state of the current PI which includes tracking manual scrams. While we received no new information during the March 29 meeting, we expressed our interest in working with NEI and other stakeholders to consider an alternate PI that tracks initiating events in a way that minimizes potential unintended consequences. It is our understanding from this meeting that NEI will (1) propose an alternative PI in the near future and (2) take the lead to reemphasize the role of the operator in maintaining plant safety.
Sincerely,
/RA/
Samuel J. Collins, Director Office of Nuclear Reactor Regulation Project No. 689 cc: See next page Attachments: As stated DISTRIBUTION: (GT20000132)
NRC File Center PUBLIC IIPB r/f DIPM r/f MTschiltz, EDO HMiller, RI LReyes, RII JDyer, RIII EMerschoff, RIV ACCESSION #: ML003701452 TEMPLATE #: NRR-056
- see previous concurrence To receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE NRR:IIPB NRR:IIPB NRR:IIPB NRR:DIPM NRR:ADIP NAME DKAllsopp*
MRJohnson*
WMDean*
BABoger JRJohnson*
DATE 4/11/00 4/12/00 4/13/00 4/13/00 4/14/00 OFFICE D:NRR NAME SJCollins DATE 4/20/00 OFFICIAL RECORD COPY
Summary of Public Meeting on Manual Scrams A public meeting was held on March 29, 2000, at the Capital Hilton following the Regulatory Information Conference to discuss NEIs concern related to tracking manual scrams as a performance indicator (PI). The meeting began with introductions by selected stakeholders (as indicated by an asterisk on the Attendance List (Attachment 2)) seated at the main table. After introductions, the selected stakeholders discussed the role of the PI associated with the initiating events cornerstone of safety, the basis for the Unplanned Scrams per 7000 Critical Hours PI (that includes both automatic and manual scrams), and the results of stakeholder feedback provided to-date. The meeting concluded after other stakeholders were given an opportunity to voice their views and the agreed upon action items were reviewed.
While participants expressed support for the initial implementation of the revised reactor oversight process (RROP), NEI and several industry participants voiced concerns regarding the potential unintended consequences that could result, namely that operators could be influenced to make a non-conservative decision to not initiate a manual scram in order to prevent crossing the PI threshold. The Professional Reactor Operator Society representative expressed his strong belief that operators would take appropriate conservative actions, as this is what they were trained to do, and that manual and automatic scrams should be treated equally since they present the same challenge to the plant. The State of Illinois representative was concerned that if this last-minute issue was handled outside the process, it would give the appearance of circumventing the open, public process used to develop the PIs. The Union of Concerned Scientist representative raised the issue that there are other PIs that could potentially cause unintended consequences and that other plant personnel besides operators could thus be influenced to make non-conservative decisions.
As a result of the meeting, NRR committed to use a formal PI change process to consider, on a priority basis, an alternate PI(s) that tracks initiating events in a way that minimizes potential unintended consequences. NEI agreed to submit a proposal for an alternate PI for initiating events for the staff to consider. NEI also agreed to take the lead in working with industry senior managers to reemphasize the role of the operator in maintaining plant safety and that PIs and other potential issues should not unduly influence conservative decision making.
ATTENDANCE LIST FOR MEETING ON MARCH 29, 2000 NAME ORGANIZATION Michael Johnson NRC/NRR Frank Gillespie NRC/NRR Alan Madison NRC/NRR W. T. Cottle STP NOC Marvin Fertel NEI Phylus Rich NEI Stan Maingi PA-BRP Richard Sweigart Duke Energy Faridch Saba NUSIS Lynne Neal NEI Gareth Parry NRC/NRR Don Hickman NRC/NRR Dave Allsopp NRC/NRR Eric Dixon NII Herb Fontecilla VA Power Deann Raleigh Serch, Bechtel Power Mike Callahan GSI Roger Huston LSS Mark Satorius NRC/OEDO Glenn Tracy NRC/OCM/RAM Nathan L. Haskell Consumers Energy Cornelius Holden NRC/NRR R. M. Krick ComEd Jon Johnson NRC/NRR Ralph Beedle NEI C.S. Hinnant CP&L S. Unglesbee NEI Mark Peifer INPO Ron Eaton H&P, Inc.
Tom Houghton NEI/HTP Steve Floyd NEI Paul Blanch Self Mahfred Petroll Self Serita Sanders NRC/NRR Sidney Crawford Consultant David Stellfox McGraw-Hill Leslie Collins ABB CENP Paige Negis GE Nuclear Joel Sorensen NSP Samuel Collins*
NRC/NRR William Dean*
NRC/NRR David Lochbaum*
UCS Cecil Settles*
Illinois Dept of Nuclear Safety David Flower*
PROS Joe Colvin*
NEI Oliver Kingsley*
Commonwealth Edison Co.
- indicates meeting attendees who formed the topic discussion group
Nuclear Energy Institute Project No. 689 cc:
Mr. David Lochbaum Ms. Lynnette Hendricks, Director Nuclear Safety Engineer Plant Support Union of Concerned Scientists Nuclear Energy Institute 1616 P Street NW, Suite 300 Suite 400 Washington, DC 20036 1776 I Street, NW Washington, DC 20006-3708 Mr. James Ricco Mr. Cecil Settles Staff Attorney Illinois Department of Nuclear Safety Public Citizens Critical Mass Energy Office of Nuclear Facility Safety Project 1035 Outer Park Drive 215 Pennsylvania Ave SE Springfield, IL 62704 Washington, DC 20003 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.
Suite 400 12300 Twinbrook Parkway, Suite 330 1776 I Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. David Modeen, Director Dr. Jill Lipoti, Assistant Director Engineering State of New Jersey Nuclear Energy Institute Department of Environmental Protection Suite 400 Radiation Protection Programs 1776 I Street, NW P.O. Box 415 Washington, DC 20006-3708 Trenton, NJ 08625-0415 Mr. Anthony Pietrangelo, Director David Flowers, Vice President Licensing Professional Reactor Operator Society Nuclear Energy Institute 150 South Fox Run Lane Suite 400 Byron, IL 61010 1776 I Street, NW Washington, DC 20006-3708 Mr. H. A. Sepp, Manager Regulatory and Licensing Engineering Westinghouse Electric Company P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708