ML15167A320
| ML15167A320 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/15/2015 |
| From: | David Pelton Plant Licensing Branch III |
| To: | Bettis A Plant Licensing Branch III |
| Snodderly M | |
| References | |
| Download: ML15167A320 (182) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 June 15, 2015 MEMORANDUM TO: ACRS Members FROM: Michael R. Snodderly, Senior Staff Engineer /RA/
Technical Support Branch, ACRS
SUBJECT:
CERTIFIED MINUTES OF THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS RELIABILITY AND PRA SUBCOMMITTEE MEETING ON FEBRUARY 20, 2015 The minutes for the subject meeting were certified on June 7, 2015, as the official record of the proceedings of that meeting. Copies of the certification letter and minutes are attached.
Attachment:
As stated cc w/o
Attachment:
M. Banks cc w/
Attachment:
ACRS Members
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 MEMORANDUM TO: Michael Snodderly, Senior Staff Engineer Technical Support Branch, ACRS FROM: John W. Stetkar, Chairman Reliability and PRA Subcommittee
SUBJECT:
CERTIFICATION OF THE MINUTES OF THE ACRS RELIABILITY AND PRA SUBCOMMITTEE MEETING ON FEBRUARY 20, 2015, IN ROCKVILLE, MARYLAND I hereby certify, to the best of my knowledge and belief, that the minutes of the subject meeting are an accurate record of the proceedings for that meeting.
___________R/A___________________6/ 7 /15 John W. Stetkar, Chairman Date Reliability and PRA Subcommittee
Certified on: June 7, 2015 Certified by: John Stetkar ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MINUTES OF THE ACRS RELIABILITY AND PRA SUBCOMMITTEE MEETING FEBRUARY 20, 2015 The ACRS Reliability and PRA Subcommittee held a meeting on February 20, 2015 in TWFN 2B1, 11545 Rockville Pike, Rockville, Maryland. The meeting convened at 8:33 a.m. and adjourned at 11:30 a.m.
The entire meeting was open to the public.
Ed Lyman of the Union of Concerned Scientists requested time to make oral statements. No written comments were received from members of the public related to this meeting.
ATTENDEES ACRS Members John Stetkar, Chairman Ronald Ballinger, Member Dennis Bley, Member Charles Brown, Member Joy Rempe, Member Michael Ryan, Member Stephen P. Schultz, Member Gordon R. Skillman, Member NRC Staff Michael Snodderly, Designated Federal Official Ed Hackett, ACRS Michel Call, NMSS Mary Drouin, RES Rich Correia, RES John Nakoski, RES Richard Dudley, NRR Joseph Giitter, NRR Lawrence Kokajko, NRR Aby Mohseni, NRR Natreune Jordan, NRR Donald Harrison, NRO Mark Lombard, NMSS Meraj Rahimi, NMSS Joseph Rivers, NSIR Randy Sullivan, NSIR Other Attendees Michael Tschiltz, NEI John Butler, NEI Jana Bergman, Curtiss-Wright/Scientech Stanley Levenson, AREVA Tom Hiltz, DOE 1
Other Attendees (Continued)
Jim OBrien, DOE Ed Lyman, UCS
SUMMARY
The purpose of the meeting was to discuss the status of the staffs plans for responding to direction from former-Chairman Jaczko to review NUREG-2150, "A Proposed Risk Management Regulatory Framework," and provide a paper that would identify options and make recommendations, including the possible development of a Commission policy statement. The meeting transcripts are attached and contain an accurate description of each matter discussed during the meeting. The presentation slides and handouts used during the meeting are attached to these transcripts.
SIGNIFICANT ISSUES Reference Pages Issue in Transcript
- 1. J. Giitter, Director of Division of Risk Assessment, provided an opening statement for the staff where he outlined the presentation, provided introductions and mentioned the key objective to inform the Subcommittee 6-9 on the staffs efforts in evaluating a possible Risk Management Regulatory Framework.
- 2. R. Dudley discussed background and implementation options the staff is considering for a possible Risk Management Regulatory Framework for 10-69 power reactors. He also discussed plans for moving forward.
- 3. Member Bley asked the staff to confirm that the Commissions direction 11 was to perform an agency-wide evaluation.
- 4. Member Skillman asserted that security is a subset of safety. 13
- 5. Member Schultz asked about establishing goals and objectives to allow 20 for evaluation of comparative risks.
- 6. Chairman Stetkar asked about a previous draft policy statement. R.
Dudley confirmed that one was published and a public meeting was held to 23 solicit feedback but the staff has moved on from that version.
- 7. Member Brown asked what distinguishes Option 2 from the Risk Prioritization Initiative. Member Rempe asked about the PRA needed to 29 support Option 2 versus Option 3.
- 8. Member Skillman and the staff discussed the importance of plant 32-38 configuration control and how the plant is modeled in the PRA.
- 9. Chairman Stetkar questioned the staff about the specified criteria used to 39 support Option 2 versus Option 3.
- 10. R. Dudley begins discussion of Option 3. 44 2
- 11. Member Skillman asked what a hypothetical Option 3 plant would look like 47 compared to a currently operating 10 CFR 50 Appendix A plant.
- 12. Member Brown, the staff and various ACRS Members discussed the ability of the PRA to model potential self-approved changes to digital I&C 52-59 systems that may appear to be less than the 10-7 CDF acceptance criteria but may not be because they violate certain firewall design criteria.
- 13. Member Rempe asked if the staff considered additional specified criteria that potential changes not exceed 5 percent or 10 percent of overall plant risk 60 to address advanced plants like the AP-1000 with relatively lower core damage and large early release frequencies.
- 14. D. Harrison reminded the Subcommittee that at some point the staff's going to have to address the ideas of defense-in-depth, safety margins and that type of thing when developing specified criteria. R. Dudley mentioned that the Commission Paper to address NTTF Recommendation One had some 68 substantial recommendations for improving the definition and criteria for adequacy of defense-in-depth. He suggested that the staff would likely include that effort into one or more of the proposed options.
- 16. In response to a question from Chairman Stetkar on uncertainty, J. Rivers described the activities of the Intelligence Liaison and Threat Assessment Branch. He described how this branch assesses terrorist activities worldwide and informs the Commission on whether the design basis threat needs to be 76 revised. These activities include estimating likelihood and relative risk rankings. Member Bley extolled the benefits of relative risk rankings in this area.
- 17. Chairman Stetkar asked about a cyber security risk model being developed at Pacific Northwest National Laboratory. This model also 81 includes the physical plant.
- 18. J. Rivers stated that ARES Corporation has developed simulation models of two or three nuclear sites. He mentioned that the staff is trying to 84 determine what role these models could play in supporting a risk-informed regulatory framework.
- 19. Member Rempe asked if the material attractiveness model considered 87 adversaries who may just want to wreak havoc.
- 20. Member Brown asked about the application of Regulatory Guide 5.71. 91
- 21. J. Rivers mentioned the three-day workshop on vulnerability assessment tools scheduled for September 2015. Member Bley asked about Department 98 of Energy involvement.
- 22. Member Brown and Member Schultz asked about access points and 100 barrier evaluation.
- 23. M. Call provided insights into NMSS activities to risk-inform spent fuel storage and transportation. These activities include investigating adequate 103-113 defense-in-depth.
- 24. Member Ballinger asked if NMSS was interfacing with NRR license renewal staff to evaluate cask performance during extended periods and long 107 term dry storage.
3
- 25. M. Tschiltz of NEI provided his perspective on the staffs RMRF efforts and his concern about limited public and industry involvement in the 114-118 development of the potential options.
- 26. M. Tschiltz suggested that RMRF should be considered and prioritized through the joint Risk-Informed Steering Committee along with issues such 117 as: treatment of uncertainty in decision making, aggregation of risk and development of external event PRAs.
- 27. E. Lyman of the Union of Concerned Scientists provided his perspective on the staffs RMRF efforts including the concept of risk minimization versus 119-123 risk management.
- 28. Chairman Stetkar asked for public comments. There were none. 124
- 44. Chairman Stetkar asked the subcommittee for final comments. 125-127
- 45. Chairman Stetkar adjourned the meeting. 127 ACTION ITEMS Reference Pages Action Item in Transcript
- 1. The Subcommittee suggested that the next meeting on this matter would be after the NRC staffs white paper has been issued and they have held 127 the proposed public meeting.
Documents provided to the Subcommittee
- 1. NUREG-2150, A Proposed Risk Management Regulatory Framework, April 2012 (ML12109A277)
- 2. Memorandum from Gregory B. Jaczko, Evaluating Options Proposed for a More Holistic Risk-Informed, Performance-Based Regulatory Approach, June 14, 2012 (ML121660102)
- 3. SECY-13-0132, NRC Staff Recommendation for the Disposition of Recommendation 1 of the Near-Term Task Force Report, December 6, 2013 (ML13329A336)
- 4. SRM-SECY-13-0132, NRC Staff Recommendation for the Disposition of Recommendation 1 of the Near-Term Task Force Report, May 19, 2014 (ML14139A104)
- 5. Memorandum from Michael Snodderly, Certified Minutes of the Meeting of the Reliability and PRA Subcommittee on October 17, 2014, dated January 20, 2015, Closed Meeting Not Publically Available
- 6. Federal Register 78 FR 70354, Conceptual Example of a Proposed Risk Management Regulatory Framework Policy Statement, dated November 25, 2013 (ML13273A493) 4
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Reliability and PRA Subcommittee Meeting Docket Number: (n/a)
Location: Rockville, Maryland Date: Friday, February 20, 2015 Work Order No.: NRC-1400 Pages 1-129 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 RELIABILITY AND PRA SUBCOMMITTEE 8 + + + + +
9 FRIDAY, FEBRUARY 20, 2015 10 + + + + +
11 ROCKVILLE, MARYLAND 12 + + + + +
13 The Subcommittee met at the Nuclear 14 Regulatory Commission, Two White Flint North, Room 15 T2B1, 11545 Rockville Pike, at 8:30 a.m., John W.
16 Stetkar, Chairman, presiding.
17 COMMITTEE MEMBERS:
18 JOHN W. STETKAR, Subcommittee Chairman 19 RONALD G. BALLINGER, Member 20 DENNIS C. BLEY, Member 21 CHARLES H. BROWN, JR. Member 22 JOY REMPE, Member 23 MICHAEL T. RYAN, Member 24 STEPHEN P. SCHULTZ, Member 25 GORDON R. SKILLMAN, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 DESIGNATED FEDERAL OFFICIAL:
4 ALSO PRESENT:
5 EDWIN M. HACKETT, Executive Director, ACRS 6 MICHEL CALL, NMSS 7 MARY T. DROUIN, RES 8 RICHARD DUDLEY, NRR 9 JOSEPH G. GIITTER, NRR 10 DONALD G. HARRISON, NRO*
11 MARK D. LOMBARD, NMSS 12 ED LYMAN, UCS*
13 JOSEPH RIVERS, NSIR 14 MICHAEL TSCHILTZ, NEI 15 16 *Present via telephone 17 18 19 20 21 22 23 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 C O N T E N T S 2 Page 3 Opening Remarks and Objectives.....................4 4 Presentation on Status of White Paper on 5 Responding to Risk Management Regulatory 6 Framework Recommendations..........................8 7 Status of Risk-Informed Activities Regarding 8 Common Defense and Security.......................71 9 Status of Risk-Informed Activities Regarding 10 Spent Fuel Dry Storage...........................104 11 Status of Risk-informed Activities Regarding 12 Nuclear Materials Licensing......................110 13 Industry Comments................................115 14 Union of Concerned Scientists Comments...........121 15 Public Comment...................................126 16 Discussion.......................................127 17 Adjourn..........................................129 18 19 20 21 22 23 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P R O C E E D I N G S 2 8:33 a.m.
3 CHAIRMAN STETKAR: The meeting will now 4 come to order. This is a meeting of the Advisory 5 Committee on the Reactor Safeguards Subcommittee on 6 Reliability and Probabilistic Risk Assessment. I'm 7 John Check -- John Stetkar, Chairman of the 8 Subcommittee.
9 (Laughter) 10 CHAIRMAN STETKAR: It's cold and the mouth 11 doesn't work well under optimum circumstances.
12 Members in attendance today are Steve Schultz, Dick 13 Skillman, Dennis Bley, Mike Ryan, Ron Ballinger and Joy 14 Rempe. And I've been told we will be joined by Charlie 15 Brown.
16 The purpose of today's meeting is to 17 continue discussions on the status of the staff's plans 18 for responding to direction from Chairman Jaczko to 19 review NUREG-2150, a proposed Risk Management 20 Regulatory Framework. And provide a paper that would 21 identify options and make recommendations, including 22 the development of a Commission Policy Statement.
23 The meetings are open to the public. This 24 meeting is being conducted in accordance with the 25 provisions of the Federal Advisory Committee Act.
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5 1 Rules for the conduct of and participation in the 2 meeting have been published in the Federal Register as 3 part of the notice for this meeting.
4 The Subcommittee intends to gather 5 information, analyze relevant issues and facts and 6 formulate proposed positions and actions as 7 appropriate for deliberation by the full Committee.
8 Mr. Michael Snodderly is the designated Federal 9 Official for this meeting.
10 A transcript of the meeting is being kept 11 and will be made available as stated in the Federal 12 Register notice. Therefore, it is requested that all 13 speakers first identify themselves and speak with 14 sufficient clarity and volume so that they can be 15 readily heard. And I'll remind all of you to please 16 silence all of your little beeping devices.
17 We have received a request to make oral 18 statements from Michael Tschiltz of the Nuclear Energy 19 Institute and Ed Lyman of the Union of Concerned 20 Scientists. I understand that there may be 21 individuals on the bridge line today who are listening 22 in on the proceedings.
23 The bridge line will be closed and placed 24 on mute so that those individuals may be listen in --
25 may listen in. At the appropriate time later in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 meeting, we'll have an opportunity for public comments 2 from the bridge line and from members of the public in 3 attendance. And also, we'll open the bridge line 4 periodically.
5 I understand that there are members of the 6 NRC staff also on a separate line that we'll make sure 7 that we open that to have comments from you. Also, if 8 any of the presenters want help from any of the staff, 9 just let me know and we'll get that line open.
10 We'll now proceed with the meeting and I'll 11 call upon Joe Giitter of the Office of Nuclear 12 Regulation -- Reactor Regulation, to open the 13 presentation. Joe?
14 MR. GIITTER: Thank you John. I 15 appreciate the opportunity for the staff to come here 16 and discuss their efforts in evaluating a possible Risk 17 Management Regulatory Framework.
18 Since the NRC Commission issued PRA Policy 19 Statement nearly 20 years ago, the staff has been slowly 20 moving towards a more risk-informed approach to 21 decision making. In the oversight area we rely on the 22 significance determination process to determine the 23 appropriate level of inspection.
24 In the licensing area we have made strides 25 in risk-informing fire protection requirements and in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 improving change to allow outage times and surveillance 2 frequencies. However, many of our regulations are 3 still based on deterministic criteria that do not 4 consider risk insights.
5 One of the main recommendations of the 6 National Academy's report on the Fukushima accident is 7 that the NRC should incorporate modern risk concepts 8 into the regulations. And that the NRC and industry 9 should strengthen their capabilities for identifying, 10 evaluating and managing risks from beyond the found 11 basis of that.
12 There may be no better time for the Agency 13 to move toward an approach that would allow us to 14 consistently consider risk in our decisions. We last 15 discussed the Risk Management Regulatory Framework in 16 the Subcommittee on October 17, 2014. At that meeting 17 we described a two-phase effort focusing first on power 18 reactors.
19 Then after obtaining Commission feedback 20 on RMRF Options for power reactors, we planned to 21 evaluate the merits of an Agency wide RMRF Policy 22 Statement. And my understanding is that the 23 Subcommittee was concerned that addressing power 24 reactors first, might ultimately limit or constrain 25 potential options for an Agency wide Policy Statement NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 addressing all NRC regulated program areas.
2 Since last October, we've had a number of 3 senior management meetings on this topic and are now 4 pursuing a slightly different approach. We still plan 5 to propose several RMRF power reaction implementation 6 options to the Commission in the initial RMRF SECY 7 paper. But we've also decided to ask for a Commission 8 decision on whether we should also pursue an 9 overarching Agency wide Risk Management Policy 10 Statement. And you'll hear more about that from the 11 staff today.
12 So, today we plan to present a brief 13 overview of what an Agency wide Risk Management Policy 14 Statement might contain. And an update on our power 15 reactor implementation options. And then finally a 16 summary of our plans to move forward.
17 And also, because we're now considering an 18 Agency wide Policy Statement, we're also providing 19 presentations on the status of risk-informing the 20 program areas of security, spent dry fuel storage and 21 other areas within our regulatory purview.
22 With that I'm going to ask Dick to go ahead 23 and start the staff's presentation.
24 MR. DUDLEY: Thank you Joe. Starting 25 with slide two. What I'm going to talk about is just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 the background and the current approach. First I'll 2 describe a little bit of what we're thinking on the 3 Agency wide policy statement. Then I'll discuss the 4 implementation options for Risk Management Regulatory 5 Framework for Power Reactors that we're currently 6 considering. And Then I'll briefly touch on our plans 7 to move forward.
8 After I speak, Joe Rivers will talk about 9 the status of risk-informed activities regarding 10 common defense and security. Following him Michel 11 Call will talk about the status of risk-informed 12 activities regarding dry spent fuel -- spent fuel dry 13 storage. And also Michel Call will speak about the 14 status of risk-informed activities regarding nuclear 15 materials licensing.
16 Michael is sitting in for Dennis Damon who 17 was on official travel. So detailed questions might 18 not be -- if you have a detailed question and we can't 19 answer it, we'll take it down and we'll get the answer 20 back to Mike Snodderly to distribute to the 21 Subcommittee.
22 On slide three, as Chairman Stetkar said, 23 the Chairman's Tasking Memo of June 2012 directed the 24 staff to review NUREG-2150 and provide a paper to the 25 Commission that would identify options and make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 recommendations, including the potential development 2 of a Commission Policy Statement.
3 Furthermore, the Commission's May 2004 SRM 4 on Near Term Task Force Recommendation One, directed 5 the staff to reevaluate our proposed Improvement 6 Activities -- Improvement Activity One to establish a 7 new design basis extension category of regulations.
8 And Improvement Activity Two to define and establish 9 criteria for adequacy of defense-in-depth to 10 reevaluate those Improvement Activities within the 11 context of the Commission's direction on a long term 12 risk management regulatory framework.
13 The Commission's SRM also closed Near Term 14 Task Force Recommendation One and it increased the 15 scope of the RMRF SECY paper by adding a requirement 16 that we describe the relationships between the ongoing 17 risk-informed activities. As a result in the change 18 of scope, the staff requested an extension of the due 19 date for the RMRF SECY paper until December 2015.
20 And as Joe said, since we talked to you last 21 in October, management has reevaluated our approach to 22 evaluating an Agency wide risk management regulatory 23 framework. And now we're currently considering three 24 power reactor specific implementation options for a 25 risk management regulatory framework. But we will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 also in parallel with that, this paper will ask the 2 Commission to consider an overarching Agency wide risk 3 management policy statement.
4 The next few slides are sort of an overview 5 of what this policy statement might look like.
6 MEMBER BLEY: Dick, excuse me. Wasn't 7 that part of your original charter?
8 MR. DUDLEY: To?
9 MEMBER BLEY: The Agency wide aspect of 10 this.
11 MR. DUDLEY: I mean, that was -- that was 12 the Chairman's Tasking Memo.
13 MEMBER BLEY: Yes.
14 MR. DUDLEY: Said to make recommendations 15 regarding an Agency wide policy statement. That's 16 correct. Or to consider that.
17 MEMBER BLEY: Okay. But now you're going 18 back to the Commission to say there's a way we could 19 do that or something?
20 MR. DUDLEY: Yes.
21 MEMBER BLEY: Okay.
22 MR. DUDLEY: And so what I'm going to 23 describe in the next few slides are just of -- it's sort 24 of a bulletized summary of what this might look like.
25 We didn't want to spend too many resources developing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 a detailed policy statement and find out that the 2 Commission didn't want us to spend all the resources 3 to do that.
4 So, we're sort of walking a fine line 5 between trying to get enough detail to describe to the 6 Commission what such a policy statement might look like 7 to allow them to make an informed decision. But yet 8 not use up all -- expend a lot of resources on something 9 and have them say well no, that's really not what --
10 we didn't want you to do that. So, that's the balance 11 we're trying to strike in evaluating the policy 12 statement.
13 So, what we have is we believe that this 14 policy statement of course would be applicable to all 15 NRC regulated program areas, applying both to 16 radiological safety and to security. We believe that 17 -- a risk management approach would be used to ensure 18 adequate protection of public health and safety and to 19 promote the common defense and security for all Nuclear 20 Regulatory activities.
21 In a risk management approach, safety and 22 security are ensured by understanding the risks and the 23 hazards associated with NRC regulated activities. And 24 using that information to make regulatory decisions.
25 Onto slide five.
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13 1 The risk management approach would use a 2 structured process to identify issues, develop and 3 analyze options and make decisions and monitor the 4 effectiveness of Regulatory programs to -- and make 5 appro -- go back and make improvements to them if we 6 found that to be necessary. It would ensure 7 appropriate Regulatory controls and oversight are in 8 place that recognize the variety of risks associated 9 with the different uses of radioactive materials.
10 And it would employ risk-informed decision 11 making in which risk insights of both qualitative risk 12 insights and quantitative risk insights would be 13 considered together with other non-risk factors 14 commiserate with their importance to public health and 15 safety and common defense and security.
16 MEMBER SKILLMAN: Dick, may I ask you to 17 go back to slide four please.
18 MR. DUDLEY: Yes.
19 MEMBER SKILLMAN: In your second bullet, 20 you've identified safety independently from security.
21 Isn't security a subset of safety?
22 MR. DUDLEY: There is a safety/security 23 interface where actions that you take to ensure 24 security of a facility from external attacks or that 25 sort of thing, there is a relationship between the two.
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14 1 Ultimately, a security event, the consequences would 2 perhaps be radiological. Joe, do you want to --
3 MEMBER SKILLMAN: I'm well aware of that.
4 What I'm trying to do is get clear in my mind what I 5 think is a distinction that you're drawing here between 6 safety, in terms of nuclear safety, SSCs, CDF, LERF, 7 that type of thing. Contrasted against force on force, 8 bad guys, terroristic threat to the facility or to fuel 9 facilities. Is that the distinction you're making 10 here?
11 MR. DUDLEY: It would -- well, we would --
12 this policy would apply to both.
13 MEMBER SKILLMAN: But are you trying to 14 have two policies or one policy?
15 MR. GIITTER: Dick, maybe I can take a stab 16 at that. You know, the Agency's traditionally talked 17 about safety and security separately. But of course 18 we understand that security can be a subset of safety 19 especially when you're looking to design basis threats.
20 For some facilities, Cat 1 facilities for 21 example, for reactors it's radiological sabotage. But 22 for Cat 1 facilities, you're concerned about theft and 23 diversion of special nuclear material.
24 So, we do understand the nexus, the point 25 you're raising. But traditionally, the Agency has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 discussed security, although it can be a subset of 2 safety as you indicated, as something separate and 3 distinct from security -- safety and security is two 4 separate and distinct things. Although we understand 5 the interrelationship.
6 MEMBER BLEY: Mr. Giitter though, it is 7 traditional, I agree with you. But on at least three 8 occasions over the last six, seven years, the 9 Commission has issued SRMs urging the staff to 10 integrate their concerns with safety and security.
11 MR. GIITTER: Yes, we agree.
12 MEMBER BLEY: Okay.
13 MEMBER SKILLMAN: Joe thank you.
14 Understand. Dick, thank you.
15 MR. DUDLEY: Okay. On slide six now, 16 under an Agency wide policy statement, the technical 17 analysis supporting the risk management approach 18 should be based on sound data, information and 19 methodologies, including the consideration of 20 uncertainties. It should use techniques or 21 combinations of techniques that are appropriate for the 22 hazards and the complexity of the issue.
23 It should be as realistic as practicable 24 considering the specific application. And it should 25 promote and utilize advances in science and technology NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 as practicable.
2 MEMBER SKILLMAN: Dick, back to six 3 please. Items one and two, at least in my view, have 4 the attribute of metrics. You can measure them. You 5 can figure out what you're talking about. You can put 6 numbers, percentages, some form of measurable scale for 7 one and two. Both three and four have the word 8 practicable.
9 And what I see as practicable and what you 10 see and what the other members of the public might see 11 as practicable, might be vastly different. What can 12 be done to make sure that there's a metrification there 13 so that the measurement standard is understood and is 14 defendable?
15 MR. DUDLEY: I think you've hit on the 16 challenge. An Agency wide policy statement, we have 17 certain programs where we have quantitative tools and 18 safety goals. And we have other programs which rely 19 more on qualitative risk assessments. I can't really 20 tell you how we're going to bring them or even if we 21 can bring them all into a quantitative arena.
22 I don't believe that is likely possible.
23 But what you hit on I think, is the major challenge of 24 an Agency wide policy statement.
25 MEMBER SKILLMAN: Are we pumping against NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 the tide? Is this a go nowhere riddle that we're going 2 to be involved in?
3 MR. DUDLEY: No, I don't think so. I mean 4 we can certainly address activities in a quantitative 5 fashion if that's appropriate. In a qualitative 6 fashion if quantitative tools are not yet available.
7 MEMBER SKILLMAN: Okay. Thank you.
8 MS. DROUIN: This is Mary Drouin.
9 Another way to look at that third bullet and 10 interpreting the work practical, is that not every 11 analysis that we do needs to be completely realistic.
12 You know, there will be some analysis because of how 13 you're applying it, you don't need to be as realistic.
14 So this is you know, be as realistic as it's 15 commiserate with the application or the decision that 16 you're trying to support.
17 MEMBER BLEY: That makes sense to me Mary.
18 And if I look up the work practicable, it just means 19 is it possible to do it, right. What you're saying is, 20 does it make sense? Which is a different concept. And 21 if that's where you folks are headed, maybe you ought 22 to polish up the language a little.
23 MR. DUDLEY: I haven't looked up 24 practicable in the dictionary. I need to do that and 25 maybe we want a different word.
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18 1 MS. DROUIN: Yes. And recognize that you 2 know, all these bullets that Dick has put up there, we 3 will envision that over time you know, as we have more 4 dialog, among the staff, as we go out for public review 5 and comment. You know, these words are going to be 6 massaged and worked through. This is not the end 7 product that you're seeing here.
8 MEMBER RYAN: One thing that might be 9 helpful, and I'm sure others will have, you know enjoy 10 seeing a glossary that takes all these terms, 11 practicable, practical, you know, any one of two or more 12 dozen words you want to define to help give people at 13 least some idea of what your intention for the meeting 14 is and the document. I think that would be a useful 15 addition.
16 MR. DUDLEY: Again, I want to emphasize, 17 this is our very first draft.
18 MEMBER RYAN: Sure.
19 MR. DUDLEY: It's very early on. There 20 will be multiple levels of management review. Clearly 21 if the Commission supports such an approach, just what 22 you said, we'll have to dissect these words very 23 carefully. We'll have to have them clearly defined.
24 But at this point, we're just not there.
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19 1 of what this policy might look like so that they can 2 make an informed decision as to whether or not they want 3 the staff to pursue it. But yet, not use too many 4 resources to develop a policy statement that perhaps 5 the Commission chooses not to have us do.
6 MEMBER RYAN: Well, that's a fair way to 7 look at it. Yes. And to proceed.
8 MR. DUDLEY: Right.
9 MEMBER RYAN: Thank you.
10 MR. DUDLEY: Great.
11 MS. DROUIN: This is Mary Drouin again.
12 Your point is very well taken. And the working group 13 has started a glossary you know, on this. So, we have 14 anticipated that and there's already some terms that 15 we have defined and we are actually starting a glossary.
16 MEMBER RYAN: Okay, great.
17 MS. DROUIN: And I think Dick has that as 18 a backup slide.
19 MR. DUDLEY: Yes, we have defined a number 20 of terms.
21 MEMBER RYAN: Excellent.
22 MR. DUDLEY: And practicable or perhaps 23 some other adjective would be added to that if that's 24 not the right word.
25 On slide --
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20 1 MEMBER SCHULTZ: Dick, before we go 2 forward.
3 MR. DUDLEY: Yes?
4 MEMBER SCHULTZ: In the last -- in these 5 three slide where you've talked about the statement and 6 then the approach and technical analysis, in order to 7 get to the point where this is being utilized beyond 8 the evaluation and then getting into decision making, 9 are we also promoting an approach that would be 10 evaluating comparative risks associated with the 11 technology and the decisions and so forth? In order 12 to make good decisions related to this technology, the 13 nuclear technology versus other technology?
14 MR. DUDLEY: You mean comparing nuclear to 15 this?
16 MEMBER SCHULTZ: Well, establishing the 17 metrics that would allow decision making to happen. We 18 haven't talked about that. It's not talked about here, 19 establishing the goals and objectives.
20 MR. DUDLEY: That's correct. That will 21 be easier to do for some programs then for others. And 22 again, that was Member Skillman's point I think. We 23 clearly have quantitative tools and safety goals for 24 certain regulated areas. We have qualitative tools 25 and goals in other regulated areas.
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21 1 I am not sure if all regulated areas will 2 ever make it to qualitative tools and acceptable levels 3 of risk.
4 MEMBER SCHULTZ: You mean quantitative?
5 MR. DUDLEY: Quantitative, um-hum.
6 MEMBER SCHULTZ: Quantitative then.
7 MR. DUDLEY: Quantitative, I apologize, 8 yes. I'm not sure that those who have qualitative 9 tools and measures will make it into quantitative. So 10 I can't necessarily -- perhaps your question was can 11 you compare risk from one regulated area to another 12 regulated area using the same scale? Was that where 13 you were coming from?
14 MEMBER SCHULTZ: Well, I'm focusing on the 15 attribute of decision making. And you can do 16 comparative evaluations and analysis. But all of this 17 appears to be in internal focus associated with what 18 is being done within this Agency. And I'm also looking 19 for an understanding of what is done outside the Agency 20 in terms of the same types of decision making. I'm not 21 seeing it here.
22 MR. DUDLEY: I mean, if one -- if you're 23 postulating tools that would allow one to compare the 24 risk to the public from electrical power generated by 25 nuclear versus risk to the public of electrical power NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 generated by burning coal, we're not going to be doing 2 that. I personally think that would be very 3 interesting. I have seen some studies on that.
4 But, that's not I think within -- I don't 5 have an OGC representative here. But I don't know that 6 that's within our charter.
7 MR. GIITTER: Yes Dick, just let me try to 8 clarify a little bit. For the harm part of Agency wide 9 policy statement, that was not envisioned. We do that 10 as you know of course, to a certain extent with the 11 safety poll policy. But whether we would do that would 12 certainly -- would be a Commission decision, a policy 13 decision.
14 But it's currently not something that's 15 envisioned for RMRF at this point.
16 MEMBER SCHULTZ: Thank you.
17 MR. DUDLEY: That concludes the very --
18 the preliminary work that we've done regarding an 19 Agency wide policy statement. We -- the management 20 decision to pursue that was made in January.
21 So we haven't been looking at this very 22 long. So it is --
23 MEMBER BLEY: Just last month? January?
24 MR. DUDLEY: Yes. That's correct. So 25 and it is very preliminary.
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23 1 CHAIRMAN STETKAR: You have circulated a 2 draft policy statement back last year, didn't you? For 3 comments? Or did the -- I guess I never -- no, it was 4 released.
5 MR. DUDLEY: There was one published, a 6 risk management. Yes, that's correct.
7 CHAIRMAN STETKAR: Did you get public 8 feedback on that?
9 MR. DUDLEY: Yes, we did.
10 CHAIRMAN STETKAR: Okay.
11 UNKNOWN: And?
12 MR. DUDLEY: I answered the question.
13 CHAIRMAN STETKAR: And I didn't follow up 14 and silence is interpreted as move on quickly.
15 (Laughter) 16 MR. DUDLEY: No, seriously I -- I'm 17 assuming we -- I think this Committee, this 18 Subcommittee was very pleased with the work.
19 CHAIRMAN STETKAR: Yes. We were briefed 20 on it in that October meeting.
21 MR. DUDLEY: Right. So yes, this 22 Committee was pleased with that. There were other 23 members of the public that perhaps were not so 24 supportive. But -- so feedback was mixed. But yet as 25 you say, this Subcommittee was very positive with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 respect to that policy statement.
2 CHAIRMAN STETKAR: Okay. Thank you.
3 MR. DUDLEY: Okay. The slide seven 4 starts the three power reactor risk management 5 regulatory framework implementation options that we 6 are currently considering. Option One is to maintain 7 our existing current regulatory framework.
8 Option Two would be to institute a 9 voluntary, alternative, risk-informed licensing 10 basis. And Option Three would be a plant specific risk 11 management regulatory framework, essentially the 12 framework recommended in NUREG-2150 for power 13 reactors.
14 These three Options were also described to 15 you essentially in the same form when we came here in 16 October. But when we were here in October, we had a 17 fourth option that we have dropped. The option that 18 we had, that we dropped, was to continue to risk-inform 19 our regulations on a generic basis.
20 That activity includes things like 21 finishing up 5046(a), the risk-informed ECCS rule.
22 Maybe looking at the coupling LOOP from LOCA. And 23 under that Option we were going to more aggressively 24 and more thoroughly go through our regulations and see 25 if there are others that could be risk-informed on a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 generic basis.
2 I don't know that that would have been 3 successful. Ultimately management decided we would 4 drop that Option to simplify the paper.
5 CHAIRMAN STETKAR: In a sense, one could 6 argue that's part of Option One anyway, right?
7 MR. DUDLEY: You could argue that under 8 Option One, we've gone about as far as we can go.
9 CHAIRMAN STETKAR: Okay.
10 MR. DUDLEY: And I think that probably is.
11 At least that's my view. By the time we complete 12 5046(a), and then perhaps look again at LOOP --
14 Any other questions?
15 (No response) 16 MR. DUDLEY: Okay. So those are the three 17 Options. Our description of these three Options 18 should essentially be similar to the description that 19 we gave you back in October.
20 Under maintain the current regulatory 21 framework, we would not revise our framework. We 22 believe and even NUREG-2150 states, in Chapter 4, 23 Option A, that the current power reactor regulatory 24 framework meets the criteria for a risk management 25 regulatory framework.
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26 1 We have the Commission Safety Goal Policy 2 statement which sets forth a risk management objective.
3 Our current regulations implement sufficient 4 protection, defense-in-depth and safety margins that 5 they would provide, that would correspond to meeting 6 the 2150 risk management goal.
7 NRR has a licensing instruction, LIC-504, 8 which has a risk-informed decision making process in 9 it very similar to the one recommended in NUREG-2150.
10 And in addition, the NRC has numerous monitoring and 11 feedback mechanisms that we use to gauge the efficacy 12 of our regulatory decisions and to identify new 13 information that should be considered within the 14 regulatory framework.
15 And I believe when I met with this 16 Subcommittee once before to talk about Near Term Task 17 Force Recommendation 1, we had a little over an hour 18 presentation where we talked to you about our existing 19 programs that do this. The Operating Experience 20 Program, the Generic Issues Programs, the Agency Action 21 Review Meeting. So, we have discussed these programs 22 with this Committee before.
23 And finally, we like to always emphasize 24 that maintaining our current regulatory framework is 25 not a do nothing option. Under our current framework, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 we have complete freedom to make safety improvements 2 based on risk insights or whatever considerations we 3 would choose whenever it's deemed necessary. And we 4 can make changes using our existing regulatory 5 processes.
6 CHAIRMAN STETKAR: But I think that just 7 for the record that does tend to be more of an ad hoc 8 process, issue specific, rather then a comprehensive 9 integrated Agency wide approach.
10 MR. DUDLEY: It is --
11 CHAIRMAN STETKAR: Even within the narrow 12 focus that you've emphasized here, even within the 13 power reactors area.
14 MR. DUDLEY: I would say that's correct.
15 CHAIRMAN STETKAR: Okay.
16 MR. DUDLEY: I would not disagree.
17 Power Reactor Option Two. Under Option 18 Two, the Voluntary Alternative Risk-Informed Licensing 19 Basis, we would maintain our existing generic 20 regulatory structure as it is, but we'd issue a rule 21 allowing licensees who volunteer or choose to upgrade 22 their PRAs. They could apply for approval of a 23 licensing basis that would support a performance based, 24 risk-informed alternative to certain deterministic 25 regulations that their PRA would show might have low NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 safety benefit at their specific facilities.
2 So these licensees would be allowed to 3 select a plant specific set of design changes or 4 compliance issues, shown to be of low risk, from which 5 they could deviate from our current deterministic 6 requirements. Some of these would require NRC 7 approval. Some of this might allow -- in some cases 8 we might allow licensees to approve low risk changes 9 themselves without our approval, as long as they also 10 search for and mitigate all plant specific risk 11 vulnerabilities that would meet NRC specified 12 criteria.
13 So, if you want to take this approach and 14 do your PRA and try to reduce or eliminate some low risk, 15 significant requirements, you will have had to look for 16 risk outliers and other things that maybe have specific 17 risk at your facilities, even though they're in 18 compliance with the current regulations. You would 19 then have to under this alternative, mitigate that risk 20 before you could then take the benefit of making the 21 facility changes to change the existing deterministic 22 requirements that were not risk significant at your 23 facility.
24 MEMBER BROWN: Isn't this -- the first --
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29 1 like part of the prioritization type stuff where you 2 have -- I mean that's -- I'm just connect -- trying to 3 connect the dots with these. They sound very similar 4 where you can avoid safety benefit, you can then 5 prioritize and do some stuff on a lower level basis then 6 you did as a --
7 MR. DUDLEY: They are. There is a 8 similarity.
9 MEMBER BROWN: Okay. I mean, is that --
10 why is the prioritization separated out? I know we're 11 going to do that this afternoon, but --
12 MR. DUDLEY: These activities are 13 related. Prioritization is the first step.
14 MR. GIITTER: Yes, let me try to address 15 that. What you're going to hear this afternoon is 16 focused primarily on -- at least initially, on 17 scheduling. So if licensing has a modification in 18 front of them, whether it's something they're required 19 to do or something that they are taking it upon 20 themselves to do because they think it's going to 21 improve their reliability at the plant, they will --
22 it provides a methodology for them to make decisions 23 on what should come first. And what can be deferred 24 to later.
25 What we're talking about here, similar in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 concept because you're using risk insights to determine 2 what's more important, but fundamentally it's 3 different in that we're looking at actual changes to 4 the license and the licensing basis for the plant. So 5 it's a more permanent and substantial change then the 6 risk prioritization effort that you'll hear about this 7 afternoon.
8 MEMBER BROWN: Okay. Thanks.
9 MEMBER REMPE: If I compare Option Two and 10 Option Three, and I know you've not fleshed out all the 11 details, but in your mind, it would the same amount of 12 upgrades to the PRA be needed for Option Two and Option 13 Three?
14 MR. DUDLEY: Let's see, I'm -- I'm not 15 sure.
16 MR. GIITTER: That's -- yes, I can talk a 17 little bit about that We envision that there's going 18 to be upgrades to the PRA required for both Option Two 19 and Three. It may be a matter of degree.
20 For Option Two, certainly you're going to 21 have to upgrade your PRA to a level that is necessary 22 in order to make the right decisions. In other words, 23 if you're looking at what all of the hazards are for 24 the facility, you're going to need to have external 25 event models for example. You'd need to understand how NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 they play in.
2 Now whether you actually have to do for 3 example, a flooding PRA or something like that, there 4 may be some flexibility in how you do that. You may 5 be able to because right now the state of the art doesn't 6 really support flooding PRA. You may be able to use 7 qualitative insights or some other methods similar to 8 what we did for the IPEEE to make those kind of 9 decisions.
10 But you are going to have to have 11 information necessary in order to make the right 12 decision. Whatever that decision might be.
13 MEMBER REMPE: Okay. Thank you.
14 MS. DROUIN: Let me just also add to that.
15 It's also going to be dependent on what your acceptance 16 criteria is. I mean in Option Two, you may keep your 17 acceptance criteria for example to reactors CDF and 18 LERF. Or maybe you know, just to release those. So 19 then you'd only require you know, a level two.
20 Now the level of detail in the scope that 21 goes with it would probably increase. But when you go 22 to Option Three, you know, if you're starting to talk 23 about using for example a frequency consequence curve, 24 then you're talking about having to do a level three 25 PRA. Versus just keeping your PRA the CDF and LERF.
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32 1 MEMBER SKILLMAN: Dick, let me make an 2 observation and then ask a question. Option Two 3 provides what I view as a very great benefit to 4 licensees. But, I spent about ten years consulting.
5 And most of my consulting was engineering effectiveness 6 in relationship of engineering for the plant culture.
7 Whether it's the work management program or operations.
8 And what I observed in those ten years is 9 some plants that were very well run, there was a very 10 strong relationship between the corrective action 11 program, their work management program and just an 12 honest to goodness understanding of Appendix B to 10 13 CFR 50. All 18 points, including record keeping and 14 configuration control.
15 And unless a licensee is firmly set on a 16 configuration control program that ensures the plant's 17 configured the way it's supposed to be and its 18 documentation shows that configuration, unless the PRA 19 model reflects the current configuration, this can be 20 a red herring. Because they can be asking for change 21 under what they believe to be an appropriate PRA model 22 when the plant isn't reflective at all of that model.
23 So my question is, what is the discipline 24 that ensures that before an option like this is granted 25 to a licensee, they are really where they are supposed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 to be in configuration control, commitment to 10 CFR 2 50, Appendix B? They are really doing it?
3 MR. DUDLEY: Well, we have a very active 4 reactor oversight program and onsite inspectors. And 5 I think that's the tool that we would use. And that 6 we are using right now.
7 MEMBER SKILLMAN: Do you believe that's 8 effective?
9 MR. DUDLEY: I'm not an expert on the 10 oversight program. I can't speak to that. I assume 11 it's effective or we would be improving it. But I think 12 our existing oversight program is likely adequate for 13 that. If you would like us to get some additional 14 information or if you're at a future meeting, something 15 about that, we can put that together for your. But --
16 MEMBER SKILLMAN: That is not really what 17 I'm driving towards. What I'm driving towards is the 18 notion that if Option Two were to become a viable option 19 that there needs to be part of that Option Two a 20 recognition of the importance of compliance with the 21 other regulations that ensure that the plant 22 configuration and the PRA model are in alignment.
23 MR. DUDLEY: So perhaps what you're 24 suggesting is, if the plant implemented Option Two, one 25 of the conditions of that might be a special inspection NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 prior to that approval to make sure that their actual 2 configuration was consistent with the configuration 3 that was modeled in the PRA. Maybe that's something 4 we should consider.
5 MR. GIITTER: Well, yes, Dick let me just 6 -- I agree with your comment. And with any model or 7 PRA model, it's only as good as the understanding of 8 how the systems operate, your ability to model systems, 9 failure modes of course. So, that is critical.
10 And how that's done, it's a very good 11 point. I don't know that we would necessarily want to 12 do a detailed PRA inspection. I mean, that's certainly 13 a possibility we could look at. But there are -- it 14 is something that we would have to have a high degree 15 of assurance that the PRA model is -- represents the 16 plant condition.
17 And there are -- and then Mary can talk 18 about this more. You know, there are peer reviews that 19 are done of course anytime you upgrade your PRA. That 20 doesn't go into the level of detail that you're talking 21 about. But -- so this is a very good point and it's 22 something we'll take into consideration.
23 MEMBER SKILLMAN: Can I just -- let me make 24 one more point. The real concern I have is that the 25 more clever your team is at the site -- the more clever NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 the operating team and the engineering team is at the 2 site, the potential for gaming the system increases.
3 And it's that that I'm really both aware of and 4 concerned about.
5 I think it's great to give the licensees 6 freedom to use a PRA tool to reduce perhaps the burden 7 where the value of some of the issues that they are 8 protecting against is very low. I understand that 9 concept. But I also am aware of organizations that 10 have the potential to game the system.
11 And hence there needs to be at least in my 12 mind, the ability to make sure that the rigor and 13 discipline are there. So that a freedom is given on 14 Option Two, we are confident that the licensees are 15 where they're supposed to be. That's what I'm saying.
16 MR. DROUIN: One thing to note is that you 17 know, there is the PRA standard now. You know, we have 18 reviewed that standard and endorsed it in one point or 19 another. If the Commission decided to go forward with 20 Option Two, we would have to relook at that standard 21 you know, in the light of does it provide us enough that 22 we're going to have the right technical acceptability 23 in that PRA to support an Option Two.
24 Now one part of the standard is not just 25 the technical requirement for doing the PRA. A big NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 piece of that standard is the configuration control of 2 that PRA. So the standard does get into requirements 3 you know, of how to you know, maintain the configuration 4 of the PRA such that it appropriately reflects you know, 5 the design and operation of the plant.
6 So we would have to -- we would go back and 7 look at those requirements and make sure that those are 8 strong enough, you know, to support this kind of 9 application.
10 MEMBER SKILLMAN: Thank you Mary, Joe, 11 Dick.
12 MEMBER SCHULTZ: So, again, that gets to 13 the PRA and the analysis portion of the discussion that 14 Dick was raising. And I think what you're saying Dick, 15 is that the other important parts of this are the 16 relationship of that particular analysis to the 17 configuration control, the maintenance, the plant 18 programs, including operations and training and all of 19 those elements that result at the analysis for the PRA 20 for that facility.
21 But also maintain it over the lifetime of 22 the plant, which is what we're asking the licensee to 23 do here.
24 MEMBER SKILLMAN: Yes, let me give you a 25 word picture that might even be more clear. I worked NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 at a plant where the plant changed from their old 2 electrical load model, I think it was ohms to ETAP.
3 ETAP is the we're told and is a very, very complicated, 4 very detailed program. It's probably on a par with 5 BRA. ETAP is a very complicated program.
6 In this particular plant, ETAP, this 7 Electrical Transient Assessment Program, was being 8 maintained by a college coop three months of the year.
9 And it was the flagship program for protecting the load 10 configuration at this particular nuclear power plant.
11 And so the leadership of that plant had 12 determined that it was acceptable for a part time 13 college student to maintain the database. And that's 14 the program upon which ECCS loading, current flows, 15 breaker protection, breaker relay alignment was 16 established. And that was an alarming finding.
17 But it was so deep in the culture, one had 18 to really dig for it.
19 MS. DROUIN: I think you raise excellent 20 issues. And these are you know, some of the challenges 21 that are going to be faced. I'm not trying to harp on 22 this standard. It does require the licensee to develop 23 a PRA configuration control program. It doesn't get 24 into details.
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38 1 that we as the NRC may need to come back and write a 2 perhaps a Regulatory Guide to give accept -- you know, 3 our acceptable staff position of what constitutes an 4 acceptable PRA configuration control program.
5 So these are all you know, questions that 6 you know, we're going to have to explore and answer.
7 MEMBER SKILLMAN: Okay. Thank you Mary.
8 Thank you Dick.
9 MR. DUDLEY: Back to slide nine. So, 10 licensees who would choose this alternative would have 11 to go out and look for risk outliers or plant specific 12 vulnerabilities. And meeting NRC specified criteria 13 and mitigate them even if they were in compliance with 14 our existing deterministic regulations.
15 And so things that those licensees find, 16 new information on the mitigation of these events or 17 sequences would have to be documented. And they would 18 become part of their FSAR in accordance with the 19 50.71(2) FSAR update requirements.
20 And we also, licensees taking this option 21 would have to implement mandatory, monitoring and 22 feedback as described in Reg Guide 1.174 to ensure that 23 the changes and risks which were deemed acceptable at 24 the time that they were made, to ensure that they remain 25 acceptable over the lifetime of the facility.
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39 1 Now monitoring and feedback would perhaps 2 catch issues with maintenance. In other words if there 3 are maintenance inadequacies at the plant, licensees 4 would have to track the reliability of certain 5 equipment. And if the reliability of that equipment 6 was different then what was assumed in their PRA, they 7 would have to go back and recalculate and make sure that 8 the change in risk was acceptable associated with this 9 change throughout the life of the plant.
10 And so, that might require them to increase 11 the reliability of certain equipment and change the 12 maintenance. Or make some other corresponding change 13 in the facility to reduce risk to an acceptable level.
14 CHAIRMAN STETKAR: And I realize these are 15 basically pretty high level talking points at the 16 moment. But the -- when I look at Option Two and I think 17 about Option Two that and, which you have appropriately 18 highlighted in red there, meeting NRC specified 19 criteria, that to me sounds an awful lot like the --
20 if you ever get to it, Option Three, the RMRF framework 21 that says well, below some area we feel the risk is 22 acceptable.
23 So therefore, that -- is that the notion 24 of these NRC specified criteria? Or is this left up 25 to the NRC saying well, despite the fact that we know NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 that large LOCAs aren't important to risk, we still 2 think you need to have certain criteria for large LOCAs?
3 MR. DUDLEY: Well, no, I mean --
4 CHAIRMAN STETKAR: Because that -- so I'm 5 trying to understand what the notion of these NRC 6 specified criteria are. Are you setting the 7 acceptable risk thresholds?
8 MR. DUDLEY: Well I mean -- Joe, can you 9 give your example about the fire protection inspections 10 and the vulnerability that was uncovered under 11 NFPA-805?
12 MR GIITTER: Oh okay. Well, there's --
13 CHAIRMAN STETKAR: I'm not talking about 14 the second point of identifying vulnerabilities. I'm 15 talking about the notion that the NRC is going to 16 specify some sort of threshold criteria.
17 MR. DUDLEY: We would have to -- it 18 actually probably would be two thresholds. We'd have 19 to figure out what's the threshold that you have to take 20 action? And then what is the -- then it might be a 21 different threshold that you have to reduce the risk 22 to.
23 So, that's an implementation detail that 24 we don't have at this point.
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41 1 notion of if I look at 2150, that to me starts to sound 2 like the three kind of bands in 2150, isn't it?
3 MR. GIITTER: There are similarities to 4 2150.
5 CHAIRMAN STETKAR: Okay.
6 MR. GIITTER: The biggest difference 7 John, is that we're looking at Option Two as an option 8 in between the do nothing option and full 9 implementation of RMRF.
10 CHAIRMAN STETKAR: Sure. Sure.
11 MR. GIITTER: And so Option Two does 12 include an incentive if you will for licensees to move 13 towards a more risk-informed framework where I'm not 14 sure that Option Three does that as well. Especially 15 if it requires development of a level three PRA.
16 But there are similarities. And the point 17 there, without getting into a lot of detail, is if 18 licensees are going to identify deterministic 19 requirements of low risk significance, whatever it 20 might be, tornado, missiles, or you know, who knows.
21 Then they should also seek out and look for risk 22 outliers.
23 So we don't -- what we're saying is we 24 shouldn't allow licensees to -- it's an untoward. You 25 don't want them to just take advantage without looking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 holistically at okay, with the clearer picture of risks 2 that I now have, are there things that are treated in 3 a deterministic world in my -- that we might do 4 differently based on some risk insights.
5 CHAIRMAN STETKAR: I understand that 6 completely. And I'm obviously running the NFPA-805 7 stuff in the back of my head. And people who went 8 through that exercise indeed did find vulnerabilities 9 that their deterministic 10 CFR 50, Appendix B stuff, 10 nobody even thought about.
11 MR. GIITTER: Right.
12 CHAIRMAN STETKAR: What I'm curious about 13 though is, if I use that analogy, when you say that they 14 must mitigate all plant specific risk vulnerabilities, 15 meeting NRC specified criteria, do you have an example 16 of what that means in the context of NFPA-805? Because 17 NFPA-805 just looked at Reg Guide 1174.
18 MR. GIITTER: Right.
19 CHAIRMAN STETKAR: It said you know, if 20 you --
21 MR. GIITTER: Right.
22 CHAIRMAN STETKAR: In that context, you 23 use that basically as your metric for determining 24 whether or not the change was acceptable to the state.
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43 1 envisioning here is something very similar to what we 2 did for NFPA-805.
3 CHAIRMAN STETKAR: Okay. Okay. That's 4 -- I was hoping that's what those words meant.
5 MR. GIITTER: Yes, I --
6 CHAIRMAN STETKAR: And their capability.
7 MR. GIITTER: Right.
8 CHAIRMAN STETKAR: Okay. Because you got 9 into the 1174 in terms of the monitoring and feedback 10 and all of that part of the process. I was just kind 11 of hanging up on those criteria. Thanks.
12 MR. DUDLEY: On slide ten now. This is 13 still Option Two. And this is kind of what you wanted 14 to hear. The regulatory processes under Option Two for 15 self approval of certain plant specific changes would 16 be similar to NFPA-805 approval process.
17 Which I believe risk-informed changes are 18 allowed to license requirements without prior NRC 19 approval if the change in risk -- the increase in risk 20 where changing CDF is no more then minimal, less then 21 ten to the minus seven per year. And changes with risk 22 increases more then minimal would require NRC approval.
23 Plant licensees are expected to have an 24 upgraded, high quality PRAs to support this 25 risk-informed alternative licensing basis approach.
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44 1 We haven't defined exactly what that is. And we would 2 submit --
3 CHAIRMAN STETKAR: Well, but you have in 4 the sense of Reg Guide or in the sense of NFPA-805. I 5 mean they're basically supposed to comply with Reg 6 Guide 1.200, which you know, endorses the ASME NS 7 standard.
8 So, there is precedent to -- for 9 understanding of what that upgraded, high quality PRA 10 means. In current regulatory space. I mean, this 11 isn't something that needs to be -- you might -- as Mary 12 said, you might want to elaborate on some particular 13 issues. But this isn't something that needs to be 14 crafted out of nothing.
15 MR. DUDLEY: Are there any more questions 16 on Power Reactor Option Two?
17 (No response) 18 MR. DUDLEY: Okay. Option Three is the 19 recommended compliant specific, risk management 20 regulatory framework implementation option from 21 NUREG-2150. Under Option Three we would require 22 operating licen -- all operating plants to have PRAs 23 and upgrade them periodically. And establish -- and 24 use them to establish a plant specific licensing base 25 basis, which would be based on their plant specific risk NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 profiles and NRC specified risk management -- an NRC 2 specified risk management objective.
3 We would require licensees to use a 4 structured risk-informed decision making process. We 5 would require that both for licensees and for the NRC 6 under Option Three. And based on the plant specific 7 risk profile, licensees could implement the plant 8 specific licensing basis by determining how they want 9 to meet the risk objective.
10 Then they would have to ensure that the 11 necessary protections are in place to meet the risk 12 management goal. They'd have to establish the 13 risk-informed decision making process. And they'd 14 have to establish the monitoring and feedback process.
15 And there would also have to be a reporting process 16 associated with this plant specific approach.
17 Let me go to the next slide before the 18 questions start. Because I might answer some of them.
19 (Laughter) 20 MR. DUDLEY: So each plant's licensing 21 basis would consist of technical requirements that 22 would be based upon this plant specific attributes.
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46 1 and defense-in-depth in light of the plant specific 2 attributes and design elements.
3 And FSAR level description of the plant 4 specific attributes and the applicant selected design 5 elements would -- and the input assumptions for the 6 above rationales would also have to be maintained. And 7 the process for maintaining the validity of the 8 rationales, the technical basis through the lifetime 9 of the plant would also have to be included in this 10 plant's licensing basis.
11 So licensees would be required to use the 12 structured process with monitoring and feedback to 13 ensure that the plant specific licensing basis remained 14 consistent with the risk profile of the plant, which 15 could change over time.
16 MEMBER SKILLMAN: Dick, let me ask. Just 17 conceptually, how would this be implemented? There 18 are what about 67 sites, 104 plants, 100 plants? All 19 part 50 plants are designed to Appendix A. Part 50 20 plants are designed to Appendix A at 10 CFR 50.
21 Does the first bullet imply some form of 22 change to that?
23 MR. DUDLEY: This implementation approach 24 could result in I could think significant differences 25 between the design of one plant to another plant.
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47 1 Plants that were initially identical might end up with 2 designs that are significantly different.
3 CHAIRMAN STETKAR: Plants have designs 4 that are different. They might have different 5 licensing basis. But because of the differences in 6 those designs --
7 MR. DUDLEY: Their licensing basis could 8 change and they -- that might include changes in the 9 design. In certain aspects of the design.
10 MEMBER SKILLMAN: I'm confused. I don't 11 understand those words. I understand what John said.
12 MR. GIITTER: Yes, let me try to clarify 13 it a little bit. Every plant now pretty much has a 14 unique licensing basis even though we you know.
15 MEMBER SKILLMAN: Right. Sure.
16 MR. GIITTER: So, it isn't as radical as 17 it may sound. But this approach would allow some sites 18 to have a more risk-informed licensing basis then other 19 sites. And so you would have some variability if you 20 take for example two standardized plants, which we 21 really don't have any in the United States, but 22 theoretically if we did, one could have a risk-informed 23 licensing basis, the other one might have a licensing 24 basis that's largely deterministic.
25 And so I -- and we have that today, okay.
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48 1 We have plants that have transitioned to NFPA-805 that 2 have made modifications to the plant. They've added 3 additional auxiliary feed water trains, non-safety 4 grade. And then you have plants that are 5 deterministic.
6 Well, so you might have a four-loop 7 Westinghouse plant with -- I'm getting into too much 8 detail here, but with two motor-drive aux feed pumps 9 and a turbine driven aux feed pump. And you might have 10 another plant that because of the vulnerability of fire 11 in a particular area of the plant, they might have an 12 additional non-safety grade aux feed water pump that 13 the other plant doesn't have.
14 So there will -- Dick's right, there will 15 be design differences. But you know, fundamentally 16 you're looking a different licensing basis for a 17 risk-informed plant versus a deterministic plant 18 because you determined based on risk insights that you 19 may need some additional systems or modifications that 20 you didn't have in the deterministic plant.
21 You may also determine that there are some 22 particular design features in the risk-informed plant 23 that aren't as necessary because they're not safety 24 significant.
25 MEMBER SKILLMAN: Okay, let me ask this.
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49 1 To what extent would Option Three require a rewrite of 2 the FSAR or rewrite of the Tech Specs?
3 MR. GIITTER: Well, we definitely require 4 a rewrite of the FSAR.
5 MEMBER SKILLMAN: Okay.
6 MR. GIITTER: The Tech Specs at a lot of 7 plants are going to be changed anyway because of 8 risk-informed Tech Specs.
9 MEMBER SKILLMAN: Okay, so let's talk 10 about rewrite of the FSAR. Isn't that a swamp that is 11 just -- that is just endless opportunity for error?
12 MR. GIITTER: Well, FSARs are rewritten 13 all the time based on --
14 MEMBER SKILLMAN: In piecemeal based on 15 amendments that are --
16 CHAIRMAN STETKAR: But isn't that a swamp 17 that the piecemeal cannot be tracked correctly so that 18 you get inconsistencies in your FSAR?
19 MEMBER SKILLMAN: If your configuration 20 control program is poor, yes. Exactly.
21 CHAIRMAN STETKAR: Okay but that's --
22 that's the current situation.
23 MEMBER BLEY: I mean I agree with a lot of 24 your points Dick. But I also note as you did with your 25 ETAP plant, this isn't a problem with Option Three or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 1 with the PRA, it's a problem that applies to essentially 2 everything in the plant. All the analysis, all the 3 equipment. And if you don't have a good program, it 4 isn't going to be what you thought it was.
5 MEMBER SKILLMAN: I agree.
6 CHAIRMAN STETKAR: If you have a good 7 program, you have a good program. If you don't have 8 a good program, --
9 MEMBER SKILLMAN: That isn't Option 10 Three's fault, that's the plant's fault. And nobody's 11 going to fix that.
12 CHAIRMAN STETKAR: Will Option Three fix 13 it?
14 MEMBER SKILLMAN: Option Three would at 15 least require you to take a comprehensive look at your 16 plant and the licensing basis for your plant. Which 17 currently isn't required. It's done piecemeal.
18 So in some sense it would at least provide 19 that catalyst in my mind that would prompt perhaps you 20 know, comprehensive reexamination of your licensing 21 basis. And given the fact that it's at one time, you 22 know, you wouldn't have this necessarily piecemeal 23 changes over the course of you know, several years.
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51 1 as marginal performers in terms of comprehensive look 2 at their facilities and give them a shock in a sense 3 to look at things.
4 MEMBER SCHULTZ: It's hard to believe that 5 would not happen given at least this description.
6 MEMBER RYAN: It would seem to me that 7 there'd be some kind of a feedback mechanism too if the 8 staff isn't you know, not just doing this in a vacuum.
9 There's going to be some feedback, the reactor would 10 feedback, they adjust. And that's a cycle that goes 11 on you know, really robust program that's healthy.
12 So I'm just trying to -- so how do you 13 describe a healthy program? And if a program is 14 healthy by whatever measure or structure you send up 15 to make that -- or set up to make that evaluation, you 16 know, you can demonstrate what you're trying to 17 demonstrate.
18 I mean, I take your point that if it's not 19 exercised properly it's probably not worth much. That 20 it could be worth less. So I think it's -- it really 21 gets down to how do you judge the program? How do you 22 decide it's a good program or needs its work? I don't 23 know.
24 Does that make sense Dick?
25 MEMBER SKILLMAN: Yes.
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52 1 MR. DUDLEY: Yes. Are there any more 2 questions on Power Reactor Option Three?
3 MEMBER BROWN: Your next is just a path 4 forward, right?
5 MR. DUDLEY: Yes. Right.
6 MEMBER BROWN: Can I go back to Option Two?
7 MR. DUDLEY: Sure.
8 MEMBER BROWN: The -- I guess the page ten, 9 slide ten is the one of interest. The self-approved 10 certain plant changes list conformed to add to the 11 license requirements without prior NRC approval of the 12 CDF -- Delta CDF is no more then -- is less then one 13 times ten to the minus seven.
14 Which always gives me a little bit of pause 15 for thought. Because somebody's got to model ten to 16 the minus seven to get there. And I guess I was trying 17 to come up with an example that I could phrase my 18 question to make it clear.
19 Right now in my world, the I&C world, we're 20 dealing with the issue of how you transmit data out of 21 a plant and whether it's a unidirectional hardware 22 based or whether it's a firewall which has software 23 involved in it.
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53 1 about these five years ago, six years ago, the comment 2 was that oh, well because we've got a firewall there 3 and we've got anti-virus software, we've got malware 4 detection, Trojan horse, and everybody thinks this 5 stuff is the hot -- theirs is the hottest stuff that 6 ever walked the face of the earth.
7 So, we've been trying -- there's been a 8 forcing function to try to get people to more consider 9 you know, strictly hardware based transmissions. So 10 there is no external capability to get in.
11 And I'm looking downstream, you get a plant 12 configured like that and now you come along later, five 13 years later and management or somebody in the plant 14 decides gee, we're spending a lot of effort because we 15 have to have people come into the plant, bring hardware 16 down, go down to the cabinets. You know open them up, 17 put you know, a lap top in connection with it.
18 It would be far more efficient to be able 19 to send this from the vendor directly via the internet 20 into the plant, into the server, the network system and 21 then down to the maintenance cabinet. And then into 22 cabinets you know, to change whatever you want to 23 change.
24 So that would require a firewall to 25 software as opposed to a hardware based one way. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 I can easily envision the computer weenies that think 2 their virus software and protection software is so 3 perfect that they will easily meet the one times -- it 4 will be easily be one times ten to the minus 12, the 5 way they'll advertise this.
6 They'll change that fire -- that barrier 7 to a software based barrier and nobody will ever see 8 it. And I don't know how as a regulator there are 9 certain boundary conditions I would have a hard spot 10 with allowing free you know, self approval. On the 11 program I came from nobody changed it without 12 headquarters while were the designers as well as the 13 regulator. But we had to be careful of that.
14 So, I just you know, that one just -- there 15 are some things that it would probably work just fine 16 for. But there are others that are fraught with peril 17 in my own mind. So I don't know how you balance that.
18 I'm not saying you don't go forward. But 19 it seems to me there have got to be some look at what 20 somebody's doing. As it chose to without prior NRC 21 approval are very strong words. And self approval 22 means nobody -- effectively nobody looks at it or has 23 to look at it.
24 MR. GIITTER: I can address that Dick.
25 Currently what the process laid out here is exactly what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 1 we do for NFPA-805.
2 CHAIRMAN STETKAR: And other things.
3 MR. GIITTER: And other things, thank you.
4 Yes. I agree with your comment on the degree of 5 precision sometimes when you come up with a 6 quantitative value for core damage frequency. That 7 people who practice PRA understand there are 8 limitations and that you can't you know, when you get 9 really small numbers like that you have to be careful.
10 But the point is that we have to ensure that 11 there would be only minimal increases in risk or even 12 preferably decreases in risk in the modifications that 13 are being made. So it's -- what you're really looking 14 at is the relative order of magnitude. You want to make 15 sure that the risk increase if there is one is actually 16 very small to allow licensees to self approve.
17 And we do audit that. It's not like we're 18 not taking a look at it. We do you know, that is 19 something we will look at. And through the audit 20 process or through our regular oversight process. But 21 at some point you know, we have to kind of let go of 22 things that are of very low risk significance because 23 --
24 MEMBER BROWN: Well, I don't think that --
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56 1 assessment.
2 MR. GIITTER: No, but what we're talking 3 about is.
4 MEMBER BROWN: Not even close.
5 MR. GIITTER: No and I understand that. I 6 understand that. But what we're talking about is, is 7 items that are clearly of low risk significance. Or 8 preferably if you're even looking at modifications that 9 improve safety and decrease risk. That wouldn't 10 require NRC approval unless it changes the licensee 11 basis of the plant.
12 So, there is precedent here. We're not 13 just making this stuff up. It's based on the you know, 14 the regulatory infrastructure we have in place. And 15 we've implemented it and NFPA-805 in other areas as 16 well.
17 MEMBER SCHULTZ: So would the example that 18 Charlie has brought up, would that be caught in the 19 first bullet where we're talking about maintaining 20 compliance and insuring that NRC's specific specified 21 criteria are met? In other words, what Charlie is 22 saying is there's certain things that you would not want 23 to fall out of the control process because someone's 24 come up with a great idea that reduces a particular 25 system vulnerability they think to a low, low level and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 they're wrong.
2 So, he's looking for a backstop that will 3 catch that and prevent it from happening.
4 MEMBER BROWN: And I don't think an audit, 5 I mean, audits or spot checks. And I am just not sure 6 that an audit would catch them. And obviously I have 7 strong feelings on this particular incident.
8 CHAIRMAN STETKAR: That's a bit of the 9 problem is that you have strong feelings about one 10 particular aspect of the digital I&C design. A 11 materials guy has one -- has his own strong feelings 12 about one particular materials issue. A pump guy --
13 everybody has their own strong feelings about 14 individual issues.
15 And everybody is not equally got. Now the 16 nice thing about risk assessment is you look at 17 everything under the same umbrella.
18 MEMBER BROWN: Well, and all I'm saying is 19 I got the risk --
20 CHAIRMAN STETKAR: And you see that the 21 risk models may be less, the current risk models may 22 be less capable of evaluating with six significant 23 figure in numerical precision, elements of software in 24 digital I&C programs. And that's true.
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58 1 uncertainties. And in many cases the differences 2 don't make any difference.
3 MEMBER BROWN: I guess I would think that 4 -- I understand you point.
5 CHAIRMAN STETKAR: But part of this --
6 MEMBER BROWN: But I think --
7 CHAIRMAN STETKAR: Part of this notion 8 without pointing fingers, is to remove I think in my 9 opinion, a bit of that issue specific focus among 10 designers, you know, maintainers, regulators, 11 everybody and say let's at least use the risk assessment 12 process to look at all the contributors to risk.
13 MEMBER BROWN: My only point is and my --
14 and this again, like you say, I have a very parochial 15 thought process and very focused on the areas for which 16 I have -- my greatest interest. But software is very 17 amorphous. It is not predictable.
18 The way people program it varies from 19 individual to individual. What one guy thinks is 20 satisfactory in terms of how he structures his software 21 is fine. Another guy has a different way of doing that 22 because he thinks the other guy is not doing it the right 23 way.
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59 1 I call the blacksmith tech -- I know, I'm not being 2 facetious, I mean the blacksmith you know, materials, 3 et cetera, et cetera. It's a little bit more amenable 4 to looking at small variations because they're just not 5 as intractable as the variability of software is.
6 CHAIRMAN STETKAR: You talk to sump pump 7 designers and they say they'd like to have a factor of 8 three margin or net positive suction head available 9 divided by net positive suction head required. Other 10 people say no, maybe one and a half, maybe you could 11 get down to one. Maybe a little bit of cavitation is 12 okay. What's the difference?
13 MEMBER BROWN: That is not the same. I 14 don't think those --
15 CHAIRMAN STETKAR: That's a -- okay.
16 Okay.
17 MEMBER BROWN: That's like moral 18 equivalence. Okay, I don't think they're totally. I 19 understand your point but they are not equivalent, 20 okay. You can put your hand on that. You can't on the 21 software. It's buried in ones and zeros.
22 CHAIRMAN STETKAR: Okay.
23 MEMBER REMPE: Since you went back to this 24 one --
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60 1 ahead.
2 MEMBER REMPE: Well there's one point I 3 thought about mentioning and didn't. But more then 4 minimal, ten to the minus seven per year is different 5 for an AP1000 perhaps then an older plant. And so why 6 did you decide to go with something like that to 7 quantify more then minimal then saying like ten percent 8 or five percent or something like that of the frequency?
9 And have you thought about changing that type of 10 statement to have a percentage of the core damage 11 frequency for example?
12 MR. DUDLEY: Well, these are based on what 13 we do for NFPA-805. And Joe, do you want to apply that 14 to -- can you expand that to other new plant designs 15 or any?
16 MR. GIITTER: Well, yes, without getting 17 into new plant designs, it's a metric that's consistent 18 with how we measure risk. So, if you look at a 19 percentage, I mean, you could always do that. But the 20 way that the standards are written and the regulatory 21 guidance is written and the standard practice within 22 the PRA community is to look at core damage frequency 23 or other as measures.
24 So it's -- I understand your point, why 25 don't you look at it in relative terms because you have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 1 --
2 MEMBER REMPE: You may have a small 3 modular reactor coming in.
4 MR. GIITTER: You may have a small modular 5 reactor which has a much lower risk profile then an 6 operating -- currently operating reactor. You know, 7 it's something we will -- you know, we can consider.
8 I understand your point.
9 MEMBER REMPE: Okay. I just thought I'd 10 mention it.
11 MR. GIITTER: Quite frankly I don't think 12 we've given it any thought. But --
13 MEMBER REMPE: It's just something to 14 think about.
15 MR. GIITTER: Yes.
16 MEMBER REMPE: Okay.
17 MEMBER BROWN: Also, don't take my 18 comments that I'm not against some relaxation to allow 19 people to do stuff on their own. I mean that's -- we 20 can over complicate stuff and drive costs out of sight.
21 So I understand that.
22 I just, along with Steve's comment about 23 backstops. I just think that somewhere at the higher 24 level, but not down in the lower levels. I mean, I can 25 look at stuff going on in the I&C where some changes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 1 they make would be perfectly acceptable without going 2 through your thing.
3 But if there's certain boundary conditions 4 I think that ought to be put in place on some things.
5 I quit.
6 MEMBER REMPE: The Charlie Brown software 7 rule.
8 MR. DUDLEY: I had one more slide. And 9 maybe I can just do that before the break. Again, this 10 last slide is on our path forward.
11 We had written a draft white paper that we 12 had hoped we could have made public prior to this 13 meeting. And we were unable to do so.
14 CHAIRMAN STETKAR: We were pretty hopeful 15 that would have occurred too. I'll just put that on 16 the record.
17 MR. DUDLEY: Right.
18 CHAIRMAN STETKAR: And we're pretty 19 disappointed that we didn't get to see that.
20 MR. DUDLEY: Right. Right. That paper 21 is now under review by NRC Senior Management. We will 22 incorporate management comments into an updated draft 23 of that white paper as soon as we can. And we will 24 publically release it and the Committee will get it at 25 that time.
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63 1 We'll have a public meeting to discuss the 2 white paper probably in April, maybe late April to 3 discuss the white paper. At one point -- at some point 4 along the process we'll solicit written comments on a 5 version of the white paper. It probably won't be the 6 first version. We'll probably want to iterate on it 7 a little -- a time or two so that we have a little more 8 fully developed paper when we go out for public comment.
9 So, I can't tell you exactly when we'll ask 10 for public comments. The paper will be available as 11 it evolves over time on the Regulations.gov, the 12 Federal rule making website. And at some point we will 13 ask for written public comments.
14 We will then receive those comments, 15 summarize those comments and I think that that's 16 probably the best time for us to come back and meet with 17 you. But we're certainly open to discussions as to how 18 you would like the interactions to take place. But we 19 think that can happen sometime this summer.
20 And the due date for the SECY paper we're 21 tasked with providing is December 18, 2015. This date 22 was established before this op -- of this effort evolved 23 to include an Agency wide policy statement. So I am 24 not a hundred percent certain --
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64 1 to the original tasking memo, which required an Agency 2 wide policy statement?
3 MR. DUDLEY: Well the SRM 1 recommendation 4 would change the scope also and there were some -- there 5 were some redirections associated with that. But 6 you're right. I -- December 18 is the current date.
7 I will strive to try to meet that date. Depending upon 8 how much detail we get into on an Agency wide policy 9 statement and how long it takes to reach Management 10 agreement on that, will determine whether or not I think 11 we can meet that date.
12 And that completes my presentation on the 13 status of our activities on the risk management 14 regulatory framework.
15 MEMBER BLEY: We'd sure like to see the 16 white paper as soon as we can.
17 MR. DUDLEY: Yes. We understand that and 18 we're providing it as soon as possible.
19 MEMBER BLEY: Do you have a date set for 20 the public meeting?
21 MR. DUDLEY: No.
22 MEMBER BLEY: How far before the public 23 meeting do you have to have the paper?
24 MR. DUDLEY: We generally -- well, I think 25 we're going to have like a 60-day public comment period.
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65 1 So we usually like to have the public meeting right in 2 the middle of the public comment period.
3 MEMBER BLEY: Okay.
4 MR. DUDLEY: So that people have had time 5 to read the paper. And then they can come to the 6 meeting and we can have our discussions and then they 7 can produce -- then they still have time to produce 8 informed comments.
9 So the public meeting should be right about 10 in the middle of the public comment period, about 30 11 days after we've released the --
12 CHAIRMAN STETKAR: So you're looking 13 roughly a month from now at the latest if this late --
14 late April date for the public meeting is --
15 MR. DUDLEY: That is correct. Yes, I'm 16 one of the Senior Managers and I've asked Senior 17 Managers to provide their comments to me on this current 18 draft by next Tuesday. I'm not sure how many 19 iterations we'll go through.
20 That would depend some -- once I see the 21 first round of comments I'll have an idea of whether 22 we're converging or whether we're still -- have 23 differing views that we need to work out.
24 CHAIRMAN STETKAR: Anything else for --
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66 1 confused by these different versions that you intend 2 to create. Isn't one version going out for public 3 comment? Or are you going to iterate on the version 4 sometime during the public comment period?
5 MR. DUDLEY: As soon as we get a white 6 paper that is approved by Management, we'll release it 7 to the public, post it on Regulations.gov.
8 MEMBER SCHULTZ: Got you.
9 MR. DUDLEY: Over time, as we work with 10 that, we'll update that white paper so that the 11 publically available version will evolve. And when we 12 get to the point we think it's appropriate that we've 13 got enough detail in that particular version of the 14 white paper, then we will solicit formally written 15 public comments.
16 So the public can follow this entire 17 process on Regulations.gov by looking at -- each white 18 paper will be there. And as it evolves from time to 19 time, members of the public will be able to see that.
20 After --
21 MEMBER SCHULTZ: But they're not 22 providing comment?
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67 1 comments. But only one time. But the paper is out 2 there available hopefully, you know, in two or three 3 weeks. And as it evolves over time, we will continue 4 to make the updated versions available on 5 Regulations.gov.
6 MEMBER SCHULTZ: and then there'll be a 7 public comment period of some duration of --
8 MR. DUDLEY: And we will meet after 60 9 days.
10 MEMBER SCHULTZ: And then we'll meet again 11 after the public comments have been provided but not 12 resolved, most likely.
13 MR. DUDLEY: Right. We'll summarize for 14 you the public comment.
15 CHAIRMAN STETKAR: Well, I think the 16 Subcommittee probably would want to meet before that.
17 When you say we, the full ACRS certainly -- well, I can't 18 speak for the full ACRS. But the Subcommittee would 19 want to engage, you know, earlier rather then later.
20 MR. DUDLEY: That sounds good.
21 CHAIRMAN STETKAR: The full ACRS you know, 22 that's up to the Committee.
23 MR. DUDLEY: Yes, this next meeting will 24 be a Subcommittee meeting.
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68 1 Dick?
2 (No response) 3 CHAIRMAN STETKAR: Well, what I've done 4 is, I know we have some staff members out on -- we have 5 two bridge lines set up for this particular meeting.
6 And I know we have some staff members on one of them.
7 And I've asked that that line be opened up. We'll open 8 up the meeting for public comments closer to the end 9 of the meeting.
10 But because we're finishing this general 11 discussion on the RMRF and the different Options, I'll 12 just ask if anybody from the staff is out there, if you 13 want to add anything to the discussion, you've been on 14 mute. So this is your opportunity.
15 MR. HARRISON: This is Donnie Harrison.
16 CHAIRMAN STETKAR: Hi Donnie.
17 MR. HARRISON: Hi. As we were going 18 through the slides and the discussion on like backstop, 19 it dawned on me that we need to recognize in both Options 20 Two and Three, at some point the staff's going to have 21 to deal with or struggle with the ideas of 22 defense-in-depth, safety margins and that type of 23 thing.
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69 1 all geared towards risks and there's other factors we 2 need to include.
3 CHAIRMAN STETKAR: That's a good point.
4 I mean you know, 1174 addresses those issues. But 5 perhaps not as quantitatively as you might want.
6 MR. DUDLEY: And the paper on Near Term 7 Task Force Recommendation One had some substantial 8 recommendations for improving our definition and 9 criteria for adequacy of defense-in-depth. So we 10 would likely include that sort of an effort into one 11 of these options if we were to you know, if we were to 12 recommend it. Although so that it would be a 13 risk-informed and not risk-based approached.
14 CHAIRMAN STETKAR: Well, Donnie's right.
15 I mean, it applies both to Options Two and Three as 16 they're --
17 MR. DUDLEY: That's correct.
18 CHAIRMAN STETKAR: As they're cast now.
19 MR. DUDLEY: But we have to have better 20 handle on defense-in-depth, safety margins and other 21 related facets.
22 MR. HARRISON: Right. I didn't want to 23 leave the impression that just because someone could 24 say a large LOCA with one train of safety systems is 25 always going to be a low ten to the minus seven, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 1 therefore I can get rid of the second train.
2 MR. DUDLEY: Right.
3 MR. HARRISON: We would have a -- we'd have 4 to add defense-in-depth metrics as well to say what's 5 the minimum interpretation of defense-in-depth so 6 those things wouldn't happen.
7 MR. DUDLEY: Right. Right.
8 CHAIRMAN STETKAR: Good. Anybody else 9 from the staff out there?
10 (No response) 11 CHAIRMAN STETKAR: If not, we'll cut you 12 off again and put you on mute. And we'll take a recess 13 until 10:15.
14 (Whereupon, the above-entitled matter 15 went off the record at 10:01 a.m. and 16 resumed at 10:16 a.m.)
17 CHAIRMAN STETKAR: We are back in session.
18 I guess you're up Joe.
19 MR. RIVERS: Okay, we basically thought 20 that it would be a good opportunity to give you folks 21 on the ACRS some insights into some of our activities 22 on trying to risk-inform security. This dates back to 23 probably about 2009 where we started actively working 24 in this area when former Chairman Klein and that time 25 Commissioner Klein gave a talk at a November 2009 ANS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 meeting and one of his statements he made in that 2 presentation was that NSIR needs to better risk-inform 3 security.
4 And so the next day I was called into Jim 5 Wiggins' office and Jim said Joe, you have a new area 6 of responsibility. Get to work.
7 And so that sort of -- and we have been 8 doing things related to this before, but not formally 9 talking about it as risk-informed in security. So we 10 can go to the next slide.
11 But one of the first things we did is we 12 worked with the Office of Research to put together a 13 workshop. We had Sandia actually conduct the workshop 14 for us. It was actually held at a classified level.
15 That was held at Sandia in the fall of 2010.
16 And essentially what came out of that 17 workshop was six sort of areas of opportunities were 18 identified to potentially risk-informed security.
19 One was the uncertainty of initiating events. Always 20 the -- one of the bigger challenges in security.
21 Simulation tools, collaboration between 22 safety and security, cyber security, improving metrics 23 and also the possibility of a demonstration project 24 like WASH 1400. So, once that workshop was complete, 25 that was about the time that the Risk Task Force that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 1 was headed up by Commissioner Apostolakis began.
2 And so we decided to lay low a little bit 3 there to see what came of that Task Force before we 4 proceeded in any of these initiatives. Next slide 5 please.
6 One of the things we found from the 7 workshop that Sandia hosted was that it cost us a lot 8 of money. So I came up with the brilliant idea that 9 we ought to get a professional society to host one of 10 these. And essentially it would cost us travel costs 11 and registration fees.
12 And so we asked them to host a workshop 13 on risk-informing security. It was initially 14 scheduled for October 2013. The Government shutdown 15 sort of impacted us there. We rescheduled it for 16 February 2014. And these were the five general areas 17 that we worked on that workshop. Next slide please.
18 MEMBER SKILLMAN: Joe, what is INMM?
19 MR. RIVERS: It's the Institute of Nuclear 20 Materials Management.
21 MEMBER SKILLMAN: Thank you.
22 MR. RIVERS: So it's that along with the 23 American Nuclear Society are probably the two that 24 cover most of the activities, but that this Agency's 25 involved at.
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73 1 So, the area of safety and security risk 2 assessment is we had discussion at PRA and NRC. We had 3 some other presentations, one by Los Alamos on an 4 extensible risk-informed decisions work method.
5 Another lab person presented on implications of 6 security challenges for safety assessment tools.
7 And then DNDO presented on some of its risk 8 models that it actually develops under Executive Order 9 requirements. Next slide please.
10 Then I convened a panel on material 11 attractiveness, an effort that we've got to try to 12 understand what special nuclear material was -- how 13 attractive it is to potential adversaries. We made a 14 presentation on the NRC approach that was under 15 development.
16 DOE provided some technical support for 17 that NRC approach. We had Matt Bunn provided some 18 thoughts on where he thought that approach ought to go.
19 Industry gave some insights that they had.
20 The United Kingdom gave comments on their 21 concepts for dilution, which is the primary focus of 22 our approach. And the French provided a presentation 23 on security in civilian facilities.
24 One thing to make note of is that at the 25 2012 Nuclear Security Summit, the U.S., France and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 United Kingdom gave -- made the commitment to have a 2 workshop on material attractiveness and this workshop 3 and this specific panel actually met that commitment 4 that was made at that Nuclear Security Summit. Next 5 slide please.
6 The likelihood of event --
7 MEMBER BLEY: Before you do that.
8 MR. RIVERS: Yes?
9 MEMBER BLEY: There's a conference coming 10 up in March, is that -- that's associated with --
11 MR. RIVERS: I'm going to talk about it.
12 MEMBER BLEY: Oh, you've got that coming 13 up. I didn't see it when I -- I didn't flip far enough.
14 Okay, I'll wait.
15 MR. RIVERS: Okay. Very good. We've got 16 several conferences coming up.
17 MEMBER BLEY: Okay.
18 MR. RIVERS: So, after we've done that, of 19 course the real challenge we have here is that unlike 20 in the safety world where we tend to think that things 21 will happen randomly and security it's actually a --
22 when the aberrant started to think -- thinks it's a good 23 opportunity to do it and he has the best chance of 24 success. And so, that tends to be somewhat of a 25 challenge.
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75 1 So we had presentations on possible 2 approaches and options. Just how some of those 3 approaches might be used. And then DoD funds an effort 4 out of the University of Maryland on -- at the National 5 Consortium for the Study of Terrorism and Responses to 6 Terrorism Approach that has some insights on how they 7 might consider doing that type of a thing.
8 So there's no clear cut way of doing it.
9 There will be a lot of uncertainty if you try to do that.
10 And that's generally one of the reasons in the security 11 world we either do things based on a conditional risk 12 or focus on trying to look at the consequences that 13 might be associated with an event. Next slide.
14 CHAIRMAN STETKAR: Joe, is some of that 15 thought changing though?
16 MR. RIVERS: I don't think it's changing 17 that much. We're trying to introduce as many risk 18 insights as we can. But for example when DHS is doing 19 its integrated terrorism risk assessment models, 20 especially the Rad Nuc Terrorism Risk Assessment, they 21 go to the intel community and say what is the likelihood 22 that there is going to be an initiating event?
23 And when they do that, what they find --
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76 1 and it's probably plus or minus 100 or 200 percent.
2 CHAIRMAN STETKAR: Sure. But I mean, you 3 know, in the safety arena we deal with that also. And 4 in some senses, although the uncertainties may be very, 5 very large, you still may be able to rank order threats 6 if you will relative to one another.
7 MR. RIVERS: Yes. We -- you know, we used 8 the -- you know, NRC has the Intelligence Liaison and 9 Threat Assessment Branch and their job is to try to 10 understand, you know, we look at the terrorist 11 activities worldwide. And then we try to assess what 12 is the likelihood that they're going to show up on our 13 doorstep.
14 And so we do some of that and then we inform 15 the Commission. And the Commission makes some 16 determination as to whether or not we need to adjust 17 the design basis threat or not based on that.
18 So there are things that are happening in 19 other parts of the world that we don't assess will 20 happen here in the United States.
21 MEMBER BLEY: I kind of like what you're 22 doing there. Because I -- this guy's done a lot of 23 PRAs. I disagree with many of my colleagues on this 24 part. You can get some kind of comparative stuff that 25 would be useful by doing the whole thing at once. But NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 this is unusual from most of our other kinds of analysis 2 in that that initiating that first strike, is a time 3 varying thing.
4 And trying to keep -- I mean, taking 5 advantage of the government agencies that are tracking 6 that and trying to be up to date on that makes a lot 7 of sense to me.
8 MR. RIVERS: And we have a lot of 9 activities that we work and the interagency with the 10 White House that if certain things become evident in 11 the chatter and things like that and the intelligence 12 understanding of things that we have approaches that 13 we can use to immediately implement certain 14 requirements that we wouldn't normally consider as 15 being appropriate. So, we do work within the 16 interagency to try to be able to effect those types of 17 changes if something pops up.
18 CHAIRMAN STETKAR: My only -- the only 19 reason for my bringing up the topic is that a focus only 20 on consequences and protection against what are deemed 21 to be severe consequences can sometimes overlook I'll 22 call them scenarios that might have not as severe a 23 consequence as your worst possible focus, might have 24 a higher frequency. You know, opportunistic attacks 25 --
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78 1 MR. RIVERS: Well, and I think that --
2 CHAIRMAN STETKAR: And that's the notion 3 of trying to understand you know, the more integrated 4 some of that.
5 MR. RIVERS: I think we debated some about 6 of that at the Y12 incident --
7 CHAIRMAN STETKAR: Yes.
8 MR. RIVERS: Where it was the protesters.
9 You know, when I think back to the '80s, long before 10 9/11, before Oklahoma City, you know, I can recall that 11 the security -- DOE Security Manager Rafi Flasch used 12 to have all the Saint's Days, she had her little 13 church's calendar up on her door and she highlighted 14 the ones she thought the nuns would be showing up for.
15 And so that was fairly common back in those 16 days. And we really focused a lot back in the '80s on 17 these protests that would take place. At the Nevada 18 test site we had a you know, certain procedure that we 19 worked with the protesters that they would cross a line, 20 they'd get arrested. The next group would cross a 21 line, they'd get arrested.
22 But I think 9/11 and Oklahoma City and 23 other events caused us to put more of a focus on the 24 big major terrorist events. But I think the Oak Ridge 25 event, the Y12 event, caused us to relook that. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 I know that we as a government are working closely with 2 the British and the French to try to understand what 3 is the best way to actually prepare for those types of 4 civil disobedience type things and how do we address 5 those in an appropriate fashion.
6 So that's an ongoing challenge right now.
7 Okay, one of the things I know coming from the DOE world, 8 you know, DOE world is very heavily and actively 9 involved in using VA simulation tools. A lot of those 10 tools actually were developed by the same people that 11 developed the PRA tools that we use in the safety world.
12 What I also realized is that my likelihood 13 of getting a regulatory requirement to force them to 14 use these tools was probably slim to none. And so what 15 I did is I worked with the vendor communities who 16 encouraged them to approach the reactor utilities to 17 talk about how their tools might actually be useful.
18 Both ARES Corporation with AVERT and Rhino 19 Corporation with Simajin actually have done that. And 20 so that -- I'll talk about that in a few minutes. But 21 at this workshop we had both of them make presentations.
22 Also Sandia and DTRA on some of their modeling aspects.
23 And then also Pacific Northwest National Laboratories 24 developing a tool that sort of merges cyber and physical 25 type security within the tool. So it's a fairly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 interesting development there. Next slide please.
2 Cyber security of course is a new and 3 ever-changing environment. We had some discussion on 4 the pros and cons and challenges of risk-informing 5 cyber security. NRC talked about our regulatory 6 program. And PNNL talked a bit about their cyber 7 model. Next slide please.
8 Okay, basically post that workshop, what 9 we've done is we've you know, I wanted to highlight some 10 of the things that we're working on. Risk 11 prioritization initiative and of course I won't mention 12 that, talk about too much now as we're talking about 13 it this afternoon.
14 CHAIRMAN STETKAR: Joe, I have to 15 interrupt you in deference to Charlie who's not here.
16 If I go back to the cyber security, the previous slide, 17 and you don't have to go back to it. Is that -- that's 18 an ongoing --
19 MR. RIVERS: Essentially the --
20 CHAIRMAN STETKAR: You said PNNL and those 21 --
22 MR. RIVERS: Well, Jim and I talked about 23 cyber risk model, but if we're looking at the regulatory 24 program, of course we put requirements into place.
25 It's big -- it's not fully implemented now.
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81 1 CHAIRMAN STETKAR: But if I stay away from 2 the regulatory part of it and just put my sort of 3 engineer hat on, you said PNNL talked about a cyber risk 4 model or they actively --
5 MR. RIVERS: They're actively pursuing 6 this.
7 CHAIRMAN STETKAR: They are?
8 MR. RIVERS: Yes.
9 CHAIRMAN STETKAR: Okay. Thanks.
10 That's what I wanted to -- oh, thank you.
11 MR. RIVERS: So, I'll talk about each of 12 these individually. But this is sort of what's going 13 on right now and what I'm working on in risk-informing 14 security. So you can go to the next slide.
15 Risk prioritization initiative of course 16 we'll talk a bit more about it this afternoon. But one 17 of the things that we find is that they do a really 18 reasonable job on looking at the safety aspects of risk 19 prioritization.
20 But trying to get the industry to better 21 understand how to actually look at the security risk 22 is somewhat of a challenge. And then trying to -- how 23 to integrate that with the safety risk is also not the 24 easiest thing. But it's something that we've 25 committed to work with industry on. Next slide please.
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82 1 MEMBER SKILLMAN: Joe, before you change.
2 Would you comment on attempting to prioritize emergency 3 preparedness?
4 MR. RIVERS: Well, that also -- basically 5 if we look at the industry initiative, they are looking 6 at safety, security, emergency preparedness and 7 radiation protection, all of those. What you tend to 8 find is that the emergency preparedness and radiation 9 protection tend to be not as risk significant generally 10 as the security and the safety elements.
11 Emergency preparedness of course is trying 12 to mitigate if something does happen. So you've 13 already had an event. So, what --
14 CHAIRMAN STETKAR: We'll hear it -- we'll 15 hear a bit more about this this afternoon.
16 MEMBER SCHULTZ: But your point is that 17 security and emergency preparedness, they are 18 different --
19 MR. RIVERS: Yes, they are different.
20 MEMBER SCHULTZ: In terms of 21 characterization with regard to risk prioritization --
22 MR. RIVERS: Right.
23 MEMBER SCHULTZ: And with regard to the 24 way in which one can benefit from application of 25 risk-informed preparation.
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83 1 MR. RIVERS: Right. Generally the 2 emergency preparedness is how do we mitigate if 3 something actually does happen. Security, what you 4 find is that you can have security events that can cause 5 the same types of things that safety events might cause.
6 And so --
7 MEMBER SCHULTZ: Correct.
8 MR. RIVERS: Trying to figure out how to 9 actually integrate the safety and security things, it's 10 somewhat of a challenge because one of the things I 11 think we found was that the people that were generating 12 the -- initially generating the industry sort of model 13 for risk prioritization didn't actively involve a lot 14 of their security people. So they didn't have the 15 understanding of how security actually fit into the 16 process.
17 But you can ask more about that this 18 afternoon when it's probably a better venue to do that.
19 Next slide, okay.
20 Risk Management Regulatory Framework 21 Working Group, that's what we're here right now for.
22 We've been actively involved with that to make sure that 23 the security aspects of things are appropriately 24 addressed within the working group. Next slide 25 please.
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84 1 Okay, they used the simulation modeling.
2 Essentially through some of my efforts we have at least 3 two of the vendors, ARES Corporation and Rhino Corp that 4 are actively working with industry right now to look 5 at how simulation modeling can actually help in them 6 securing their facilities and also addressing 7 regulatory issues. ARES Corporation is actually 8 modeled two or three of the nuclear sites to date.
9 And we're trying to work with industry to 10 better understand what is -- what do we need to have 11 here at NRC in the way of oversight of that to allow 12 that to fit into the regulatory program? So, you know, 13 I think one of the concerns, we have to understand how 14 the facilities were modeled, how the data was generated 15 to do that.
16 And I heard earlier this morning about the 17 concern about gaming the PRA type models. The same 18 thing can be done on the security models. And so, we 19 want to make sure that we have an understanding of you 20 know, what's common and data elements drive the models 21 so that we can focus our attention on those elements 22 in our oversight process.
23 MEMBER BROWN: If this -- excuse me. Is 24 this the physical plant? This modeling?
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85 1 fact that at least one of the National Laboratories, 2 Pacific Northwest National Lab is actually trying to 3 develop a cyber risk model. And also one that 4 integrates cyber and physical.
5 MEMBER BROWN: Yes, I see you haven't 6 gotten to that slide yet. I just wanted to see if there 7 was a separate that this was being applied to.
8 MR. RIVERS: Okay, so next slide please.
9 Material attractiveness. This is something I actually 10 worked on when I was at the Department of Energy and 11 when I came here to NRC I was asked to continue working 12 in this area.
13 But it's essentially taking what we -- how 14 we categorize material and security for predominately 15 the fuel cycle facility, but it will also impact the 16 research and test reactor facilities. Where you know, 17 is all uranium and all plutonium the same? And the 18 answer is no.
19 One example would be that if I have five 20 kilograms of high enriched uranium metal in a button 21 versus five kilograms disbursed in soil on a railcar, 22 do they require the same protection? And the answer 23 is no. The adversary is going to focus on the metal 24 button more so then that five kilograms disbursed in 25 a railcar.
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86 1 And so that's what this approach is looking 2 at. Next slide please.
3 To support that we actually conducted a 4 study at Los Alamos National Laboratory. They 5 developed a logic module that sort of put things into 6 four phases. One is acquiring the special nuclear 7 material. Looking at a wide variety of facilities and 8 types of material that might be present in those 9 facilities. What type of processing is required to 10 take that material that's acquired at those facilities 11 to convert it into a weapons useful form.
12 Then weaponization goes from a design of 13 an improvised device to engineering that improvised 14 device. And then one of the questions that I've always 15 been asked over the years by the policy makers is, okay, 16 that's what Los Alamos and Livermore can do, but what 17 can a real adversary do? And so we actually have an 18 approach in that model to perform a yield reduction 19 based on some understanding that they aren't going to 20 be necessarily as skilled as one of our National 21 Laboratories.
22 And then in the end what it does is it 23 provides yield -- an estimate of the likelihood of an 24 actual nuclear detonation and also a yield associated 25 with that detonation.
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87 1 MEMBER REMPE: For a minute if you don't 2 mind going back to slide 13 with the material 3 attractiveness and your statement. That's assuming 4 that the adversary is going to do something with the 5 material for alternative uses when you make that 6 assumption about which -- whether they'll go for 7 disbursed materials or not disbursed materials. And 8 they may have other priorities.
9 MR. RIVERS: Well from a security 10 standpoint, when we're looking at this specific 11 approach, we're predominately focused on the theft of 12 that material to potentially be used in an improvised 13 nuclear device. Essentially a mock up of that.
14 MEMBER REMPE: Right. And so what -- are 15 you considering other types of adversaries who may just 16 want to reek havoc? That the disbursed material would 17 be just as attractive to them.
18 MR. RIVERS: Well we -- one of the things 19 we look at and that we're also looking at in this rule 20 making for material attractiveness standpoint is, of 21 course with the radioactive materials, we put in 22 certain requirements in 10 CFR Part 37 to address the 23 potential use of that material in a disbursal device 24 and exposure device or other things. And a lot of it's 25 based on the IAEA Code of Conduct concept of what's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 important.
2 Given that some of these special nuclear 3 materials could also be used in a disbursal device, we 4 as part of the study that we had conducted at Los Alamos 5 and also one conducted at Sandia National Laboratories, 6 we looked at what comparable quantities of special 7 nuclear material could produce similar effects to those 8 radioactive materials?
9 And so trying to align the protection 10 requirements for those smaller quantities of special 11 nuclear material, generally in the category three 12 realm, where if we were just protecting them from an 13 improvised nuclear device threat, we probably wouldn't 14 put a lot of requirements on because you wouldn't have 15 enough to do anything. But you might have enough to 16 actually disburse and cause problems.
17 And so in the rule making that's currently 18 under development, we would actually add some 19 requirements to some of those nuclear materials that 20 could have a radiological fence price. Okay, so the 21 next slide.
22 So essentially, what we've done is we've 23 developed this model and based on a lot of information 24 that we got from this model that Los Alamos developed 25 for us we identified you know, what are the appropriate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 protection mechanisms? It led us to determining that 2 probably the best property of material to be used in 3 an attractiveness concept is probably dilution.
4 And so that's essentially how we you know, 5 developed the material attractiveness approach for the 6 ongoing rule making. Next slide.
7 MEMBER BALLINGER: But you're limiting 8 now this to the special nuclear materials?
9 MR. RIVERS: This is special nuclear 10 material. Cyber security, this panel discussed a 11 number of things that we talked about. We're looking 12 at -- some of the things that we're looking at are 13 reactor cyber security implementation that's underway.
14 Highest consequence, critical visual assets are 15 addressed.
16 And we're trying to use a consequence based 17 approach to consider lesser requirements for critical 18 visual assets with lower consequences. So, in the 19 implementation to meet the NRC requirements, there are 20 eight milestones essentially that all of the plants 21 have implemented for seven milestones. The last 22 milestone is focusing on those lower consequence 23 critical digital assets.
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90 1 requirements on those final visual assets that we did 2 for all of the previous ones? And I think the general 3 direction is to try to do it in a more risk-informed 4 approach where you probably wouldn't expect all the 5 same security measures to go into place for these lesser 6 assets then you would in the previous ones.
7 MEMBER BROWN: How do I phrase this? When 8 you say implementation is underway at the plants, what 9 are the elements? What kind of elements of that 10 implementation are there?
11 I mean if -- I mean, we've had absolutely 12 no, I don't think we have, any discussion of that, of 13 how you're looking at implementing the you know, the 14 5.71, Reg Guide 5.71 where it talks about CDAs or 15 critical digital assets. But nobody's gone through 16 and okay, when we're looking at this from the top down 17 and looking at the plant, what are the elements? Where 18 -- is there a level of work through? You're talking 19 about reactor cyber security, what does that mean?
20 MR. RIVERS: Well, basically we right now 21 only our -- have an active requirement at nuclear power 22 plants. All of the other ones were in a process of 23 deciding how much cyber security is appropriate for 24 each of those.
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91 1 and things like that?
2 MR. RIVERS: Just for example there is --
3 MEMBER BROWN: I'm looking -- I'm only 4 asking about reactor -- nuclear power plants right now.
5 MR. RIVERS: Looking at nuclear power 6 plants, Reg Guide 5.71 is what we tend to be using. It 7 tends to focus on essentially the NIST process for 8 addressing cyber security which has several hundred 9 elements that they're supposed to look at for each of 10 these digital assets.
11 They put together a cyber security plan.
12 We evaluate that. We send inspection teams out to 13 assess whether or not they're implementing the plan 14 appropriately. This isn't my area of special 15 expertise.
16 MEMBER BROWN: Okay. So I shouldn't ask.
17 MR. RIVERS: So, I can't give you a lot of 18 detail on that. But I'm sure that if you'd like to talk 19 to our cyber security folks, Barry Westreich is the 20 Director of the directorate. He or his deputy would 21 be very happy to talk to you.
22 MEMBER BROWN: Okay, so we've got a 23 meeting coming up if I remember correctly in a month 24 or so?
25 CHAIRMAN STETKAR: Fuel cycle facilities.
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92 1 MR. RIVERS: It's for fuel cycle 2 facilities.
3 CHAIRMAN STETKAR: It's not nuclear power 4 plants.
5 MR. RIVERS: But I'm sure that because 6 you'll have the right people there that they can answer 7 your questions on reactors and such.
8 MEMBER BROWN: But we could -- we'll have 9 to talk more.
10 CHAIRMAN STETKAR: Well PNNL apparently 11 is developing some models for cyber security. At least 12 Oconee for example ought to have in place. Remember 13 there aren't too many operating plants in the country 14 that have the integrated safety and you know, 15 protection control systems. Oconee is one though. So 16 if we're interested to find out you know, what they've 17 actually done in terms of hardware and otherwise.
18 MEMBER BROWN: Well, I was interested also 19 not just -- you know, not just looking at the 20 plant/plant type stuff. But you know the other 21 activities that are conducted within you know, what I 22 call the overall governance and management of the plant 23 and how is that looked at if you're not --
24 MR. RIVERS: Right, but I'm not the expert 25 on that.
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93 1 MEMBER BROWN: That's fine. I 2 understand. I'm not going to go -- we're not going to 3 do that.
4 MR. RIVERS: Sorry. So --
5 MEMBER BROWN: We just -- I think we need 6 to.
7 MR. RIVERS: Well I think you can talk to 8 our folks that are involved in that because we have to 9 address all of the things including their business 10 systems and their access authorization systems. All 11 of those things get factored into.
12 MEMBER BROWN: Yes, my concern is how 13 those would integrate down into the configuration 14 control and other plant management to interact. You 15 know, how they interact because right now they're not 16 supposed to electronically interact but they --
17 MR. RIVERS: That's right. They're 18 supposed to be --
19 MEMBER BROWN: But we can pursue that 20 separately.
21 CHAIRMAN STETKAR: Yes. That's a good 22 idea.
23 MEMBER BROWN: All right. We might even 24 have to have a separate meeting on that.
25 CHAIRMAN STETKAR: Another Subcommittee.
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94 1 MEMBER BROWN: But I'm not sure we'll have 2 enough time if the other one's just a half day.
3 MR. RIVERS: So anyway, on the fuel cycle 4 essentially that's gone to the Commission. We've got 5 I think three of the four votes back on that. So we'll 6 be waiting an SRM on that.
7 We're also had -- there's a paper that was 8 developed on research and test reactors. Then we'll 9 also be looking at radioactive materials as well. So 10 we're trying to look at all of those. But the first 11 initial focus was on power plants because they have the 12 biggest potential consequence. Next slide please.
13 I chair an IAEA Coordinated Research 14 Project in Vienna that's been ongoing for a couple of 15 years right now on the development of essential 16 guidance on how to conduct security assessments. So 17 it fits right into this idea of risk-informing 18 security.
19 So the intent is to develop sort of two 20 levels of guidance. One that is a more complete type 21 guide that would sort of supporting nuclear power 22 plants or category one fuel cycle facilities. And a 23 lesser guide that would be a little bit more 24 straightforward to be able to be used by a wider variety 25 of facilities.
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95 1 A lot of times for example if I get to an 2 irradiator facility, the person doing the security is 3 a radiation safety officer. And so he's not going to 4 have either the interest or the knowledge to 5 necessarily understand a very complex guide that you 6 might use in a nuclear power plant.
7 To support this we're also doing case 8 studies that help people understand how to implement 9 it within their own type of facility. And the five that 10 we currently have ongoing are nuclear power plant case 11 study, an irradiator facility, radioactive material 12 transport, and LEU fuel fabrication facility and a 13 spent fuel storage facility.
14 To basically figuring that a general 15 guidance document generally a lot of times isn't 16 enough. That you need to have these case studies that 17 can be used to support those guidance documents and also 18 potentially support training activities. Next slide.
19 Also, we've got a number of workshops that 20 will be carried out this year. These are the three 21 workshops. Next slide please.
22 The INMM and Reducing Risk Workshop is 23 actually the seventh in a series of reducing risk 24 workshops that INMM has put on. This one will be put 25 on at GW University next month, the week after the RIC.
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96 1 It will have four panel discussions. One of them will 2 be on cyber security.
3 I've set the cyber security panel 4 discussion to focus on essentially risk associated with 5 security -- cyber security at a nuclear power plant.
6 It will have panel members from NRC Cyber Security 7 Directorate, three of the National Laboratories and 8 also industry.
9 There will be three other panels during the 10 workshop. One will be on insider mitigation. A third 11 one will be on perception of risk. And a fourth one, 12 because we're doing this in conjunction with the 13 Elliott School of International Affairs, will be on 14 essentially the changing relationship with the 15 Government of Russia.
16 Given with what's been happening in the 17 Ukraine and things like that. So it will be a fairly 18 diverse workshop. Next slide please.
19 MEMBER BLEY: Are you getting mostly the 20 people you interact with anyway? Or are you getting 21 some -- a bigger cross section? You've gotten some 22 good ideas coming out from these?
23 MR. RIVERS: We tend to get a bigger cross 24 section. We also get a lot of international fly in on 25 some of these workshops. I know that one of the names NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 1 I've seen that's registered is Philippe Galland from 2 Russia, not from Russia, from France, from CEA.
3 Usually we get representation from the UK, from Japan, 4 from other governments that will send people to these 5 workshops.
6 We also try to open them up so that we get 7 non-governmental organization participation. For 8 example, on the perception of risk work panel 9 discussion, Ed Lyman will be a participant on that.
10 We'll have a couple of folks from NRC that will 11 participate. And so that -- I think somebody from 12 Monterey will also be on that panel.
13 So, we try -- when I do these workshops I 14 try to do it in such a way that we get a very wide and 15 diverse group up in the panel so that we get a lot of 16 participation from the workshop participants as well.
17 One of the things to come out of both the 18 Sandia and the Stone Mountain workshop were that we 19 needed to really engage the risk, safety and security 20 people. So working with Nathan Su and John Nakoski in 21 research, we identified that an ANS meeting that was 22 being given at Sun Valley, Idaho in April as being a 23 targeted opportunity that will have a lot of the safety 24 risk analysts at that meeting.
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98 1 a one day workshop on the day prior to the ANS meeting 2 to have a day of engagement between the safety and 3 security risk professionals. Next slide please.
4 One of the things that has never really 5 taken place is actually a real workshop on 6 vulnerability assessment tools. And since I think 7 when I mentioned it to Chris Lui and my boss that we 8 had set up the ANS INMM one on safety and security, she 9 walked in the next day and said well, when are you going 10 to do one on vulnerability assessment tools.
11 So, we got the INMM to agree to put on this.
12 It will be a three-day workshop in Boston in September.
13 We'll have a discussion of VA tools that will talk about 14 the validation, verification and accreditation of 15 tools, of software tools. It will have a discussion 16 of modeling issues. A discussion of data.
17 We'll have a demonstration by vendors.
18 And this is one where I'm actually pulling in the NUSAM 19 project I mentioned before where there's a case study 20 on nuclear power plants where we'll actually give the 21 vendors that are participating the case study on 22 nuclear power plants. So each of them can demonstrate 23 how their tool assesses the security effectiveness at 24 that nuclear power plant.
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99 1 to actually interact directly with all of the workshop 2 participants. Then we'll have some panel discussions 3 at the end where we'll have users, regulators, industry 4 and vendors discuss these vulnerability assessment 5 tools.
6 MEMBER BLEY: Is DOE coming? Are they 7 part of this?
8 MR. RIVERS: DOE is actively working, 9 supporting me in setting this workshop up.
10 CHAIRMAN STETKAR: I haven't heard of this 11 one Joe, what are the dates in September? Do you have 12 them? That's all right, we can get them.
13 MR. RIVERS: It's mid-September time 14 frame. If you go to the INMM website, www.INMM.org, 15 it has a -- in the upcoming events, you can click on 16 this and get the dates for it.
17 CHAIRMAN STETKAR: Okay. Thank you.
18 MR. RIVERS: And probably in the next week 19 or so, we'll probably put up the draft agenda for the 20 workshop on the website as well.
21 Okay. And I think that's the last slide 22 other then the questions slide. If you have any 23 questions, I would be happy to answer them.
24 CHAIRMAN STETKAR: Anything more for Joe?
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100 1 sitting idle and you know, we have our initiatives 2 ongoing in the security world to try to better 3 risk-inform security.
4 CHAIRMAN STETKAR: Thank you.
5 MEMBER BROWN: Just one question. You 6 said this earlier and I just probably missed it. The 7 risk-informing security, there's some aspects of that 8 are a little tenuous. I mean how?
9 MR. RIVERS: Well I think it's you know, 10 my training is you know, as a statistician. So you 11 know, risk has certain consequences, expected loss 12 basically is what risk is.
13 But knowing that we can't necessarily do 14 all of that real well in the security world, it's trying 15 to look at those elements of risk that can help us do 16 a better job in security. You know, and I gave some 17 examples of some of the ongoing activities.
18 You know, some of them include trying to 19 get more use of simulation modeling at nuclear power 20 plants. Trying to better understand what can an 21 adversary really do. Trying to understand what 22 consequences can actually be achieved because that's 23 very important to understand. So, all of those types 24 of things.
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101 1 points are a big part of maintaining a secure 2 environment.
3 MR. RIVERS: Correct.
4 MEMBER BROWN: And I mean is -- at least 5 that's a high level.
6 MR. RIVERS: Yes.
7 MEMBER BROWN: Is a way to look at it. I 8 mean, is that part of the modeling in terms of trying 9 to look -- I mean, if you're a plant, how many access 10 points do you have?
11 MR. RIVERS: Well, when you look at -- one 12 of the issues that you have at a nuclear power plant 13 or a category one facility is, is you do control access.
14 Adversaries can use a number of approaches to getting 15 into the facility. Some of it can be through deception 16 where they actually fake credentials, steal 17 credentials or whatever to try to get in to get in 18 through certain levels. But you may also just use 19 brute force where you just basically crash through the 20 fences and use explosives to breach walls and things 21 like that.
22 So, all of those have to be considered when 23 you're looking at security risks.
24 MEMBER BROWN: Okay. Thank you.
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102 1 you look at the material attractiveness thing that 2 we're working on right now in the fuel cycle facilities, 3 one of the thoughts is that if we actually determine 4 that some materials that are currently put into the 5 material access areas in those secured areas don't 6 really credibly have to be there. Those activities 7 that are performed at those plants can be performed in 8 less secure areas which means that fewer people are 9 gaining access to the most secure parts of the facility.
10 So, we're looking at a lot of those types 11 of elements and risk-informing security.
12 MEMBER SCHULTZ: I think the most 13 important feature that -- well one of the most more 14 important features that you'd be looking at, I didn't 15 see it in a conference, but probably it's in the 16 discussions is barrier evaluation and development.
17 MR. RIVERS: Yes, if you look up -- yes.
18 MEMBER SCHULTZ: Because the consequences 19 are interesting. But in fact minor consequences could 20 have a major impact on industry. So, the important 21 features would be to assure that the event doesn't come 22 to fruition.
23 So, a varied evaluation and opportunities 24 to dissuade.
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103 1 very important part of this. It's a development of a 2 lot of the things that I talked about.
3 CHAIRMAN STETKAR: I need to keep us 4 moving here a bit because we have time slotted for a 5 presentation by the industry. Another turn by UCS.
6 And I need to get public comments and comments from the 7 Committee. And I need to leave Michael enough time so 8 that he doesn't have to speak too rapidly. So Michael?
9 MR. CALL: Thank you. Just wanted to give 10 you a brief overview of some efforts that we're doing 11 in the area of spent fuel storage in my division, which 12 is the Spent Fuel Management Division in NMSS. This 13 effort is relatively young. And so there hasn't been 14 too much that's gone forward in it yet. So it's just 15 we'll be bringing up to speed on the general outline 16 of what it's like, what we're doing and the significant 17 workshop that we had last month.
18 This effort we're looking to try to set up 19 as a goal, we have a framework -- aiming for a framework 20 to better enable risk-informed regulatory decisions in 21 the areas of us looking at both spent fuel storage and 22 transportation. But with the interest being mainly in 23 transportation right now, we felt it's important to 24 focus our efforts initially in spent fuel dry storage.
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104 1 relatively new. Some of the reasons for taking on this 2 effort is partly because of understanding the 3 NUREG-2150. Come out of the follow up efforts that 4 we're talking about here today as well as public 5 interactions where we present but we've received a 6 petition for rule making from NEI where they felt if 7 we made -- they proposed certain changes that they felt 8 would be useful to make Part 72 of the storage 9 regulations more risk-informed.
10 In our reports we're looking at trying to 11 set up this framework through a process -- in taking 12 seven major steps, looking to see what risk information 13 is out there already. For example, you may be familiar 14 with, there are a couple of PRAs that have been done.
15 NRC did their own pilot PRA, which is NUREG-1864 as well 16 as EPRI had done a PRA of their own.
17 So, just trying to identify what 18 information is available. And the next step which is 19 where our workshop from last month comes in, was to try 20 to see where a defense-in-depth, how we would go about 21 defining defense-in-depth for purposes of application 22 and spent fuel storage. I believe that's the next 23 slide. Yes, it's right there.
24 So, we had -- this workshop we had, held 25 it on the 15th. It was well attended by both we had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 1 NEI participation and a number of public participants 2 both in person as well as through the webinar that we 3 had. In fact we had so many trying to register in that 4 we -- assignment of a system telling people that we were 5 overloaded, we can't take anymore.
6 So, maybe next time we have a public 7 webinar we'll expand the number of lines that we make 8 available for that. The NRC and NEI, we asked NEI to 9 make a presentation on their views of what 10 defense-in-depth would look like as well as presenting 11 our own, and that is discussed a little bit more on the 12 next slide.
13 For NRC we are looking and thinking in 14 terms of threes. We're looking at three layers to 15 ensure performance of three safety functions. And 16 understanding how operations of spent fuel storage 17 occur. Breaking that out as far as how we looked at 18 it in terms of three different phases of operation.
19 NEI's is more a -- applying more succinct way of looking 20 at it in terms of identifying barriers, controls, 21 personnel and so forth to prevent and contain or 22 mitigate exposure to radioactive materials.
23 As I said, we had a number of public 24 comments ranging from you know, in favor of you know, 25 the NRC is looking at this as a good thing because it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1 can help enhance and make the framework we've got now 2 being more clear. And to help us identify what's 3 really needed to be looked at in terms of certifying 4 casks for storage.
5 There were some questions about the level 6 of detail and some questions about different things 7 such as well how are you going to determine if you have 8 adequate defense-in-depth. And so there were some 9 discussions on those points.
10 So that's where we are at this point. We're 11 looking at taking the comments that we had from that 12 meeting and putting together some kind of brief paper 13 to consolidate that thinking. And then move to the 14 next step which would be like I said, there are seven 15 steps that we're looking at. I think we're looking at 16 what are we going to use of making decisions, decision 17 metrics. And how those would play into a decision 18 process.
19 Eventually we're going to lay out a 20 preliminary framework and then use a pilot -- selected 21 a pilot to run that through and see where we need to 22 make changes to that and finalize our approach before 23 going forward with that.
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107 1 we are in terms of a significant activity in spent fuel 2 storage.
3 MEMBER BALLINGER: Are you interfacing 4 with the folks that are looking at license renewal for 5 these casks and long term dry storage and things like 6 that?
7 MR. CALL: License -- well, I realize --
8 MEMBER BALLINGER: You have a unique 9 opportunity here.
10 MR. CALL: Right. I think I -- when we've 11 been looking at these things as far as looking at what 12 elements might be in each of these layers, we're not 13 just looking at an initial storage period, but also 14 looking at what might be things in a renewal period 15 also. So there is some thinking toward that effort.
16 Like I said, we're relatively -- this is 17 a relatively young and so as we go forward, we can 18 definitely keep those things in mind to make sure that 19 we reach out to that adequately.
20 MEMBER BALLINGER: I would encourage you 21 to do that. Because there's a huge effort on defining 22 what kind of inspections are going to be needed. And 23 expensive. Very expensive inspections and technology 24 which need to be balanced against other types of 25 inspection which ensure that you don't get released NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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108 1 material.
2 MR. CALL: Okay. Yes, we will definitely 3 keep --
4 MR. LOMBARD: Actually if I may Ron, Bill 5 Demoross.
6 MEMBER BALLINGER: Demoross, who is that?
7 CHAIRMAN STETKAR: Identify yourself sir.
8 MR. LOMBARD: I need records for a 9 schedule of management. He can schedule management 10 within NMSS and the folks who are developing HMS 11 programs, managing regulatory framework are the same 12 division, same compliance.
13 CHAIRMAN STETKAR: I'm sorry, we need your 14 name on the record too.
15 MR. LOMBARD: Mark Lombard.
16 CHAIRMAN STETKAR: Thank you.
17 MR. LOMBARD: Yes, we deal very closely 18 with NEI, the same folks who interfaced with us on other 19 spent fuel storage issues almost on a weekly basis.
20 CHAIRMAN STETKAR: Any other questions?
21 (No response) 22 MR. CALL: And just moving on, as Dick 23 mentioned earlier, I'm filing in for Dennis Damon.
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109 1 again, a brief informational presentation about some 2 efforts that have gone on that are NMSS wide as well 3 as just point to some things that are active in the 4 different divisions within the NMSS.
5 Sometime ago there was a risk task group 6 that was organized and developed a guidance document 7 that's referred to as the Risk-Informed Decision Making 8 document or RIDM. The current revision is -- we have 9 one that was put out in February 2008.
10 But the activity started much earlier in 11 a response to the SRM on SECY-99-0100. In that SECY 12 just to give you a little bit of information, the 13 staff's proposal to implement a framework for using 14 risk assessment in regulating nuclear material uses and 15 disposal was approved along with the proposal for 16 addressing risk management issues in those areas 17 including development of risk metrics and goals. And 18 then there was a joint ACRS/ACNW subcommittee that was 19 established to peer review those staff efforts.
20 The document itself has four objectives.
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110 1 should say, not acceptable and negligible are the terms 2 that they were using. And then to discuss how the RIDM 3 method would be applied to nuclear material and waste 4 regulatory areas.
5 In the SRM on SECY-04-0182, the Commission 6 approved staff's plan to continue to apply 7 risk-informed methods to these activities, materials 8 and the waste repository activities and directed that 9 the staff should consider applying the guidance in the 10 document to planned and emergent activities. Next 11 slide please.
12 So as I mentioned, part of the guidance 13 that was developed and in the document itself there are 14 quantitative health guidelines. They developed six.
15 Two of which will look similar to the guideline -- to 16 the goals that are for the reactor safety goals.
17 They're all in terms of individual risk.
18 So that there are six. Three for the public, three for 19 workers. In addition to acute fatality and serious 20 injury or like in cancer fatality, the serious injury 21 guideline was also adopted or suggested.
22 I would note that these are not -- unlike 23 the safety goals for reactors, these are not endorsed 24 by any type of Commission policy statement. And what 25 they are, you'll notice that we've called them NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 1 guidelines instead of goals. Instead of conveying a 2 sense that these would be something that would need to 3 be met at some point in the future or at some day, these 4 are more of guidelines which would be anticipated 5 according to the guidance document levels below which 6 do you really need to consider doing much more to ensure 7 that the risks are any lower then this.
8 MEMBER SKILLMAN: So these are thresholds 9 for action?
10 MR. CALL: Kind of. Looking at -- yes.
11 And they're not really -- it's not a hard and fast.
12 It's kind of -- it's like I said, it's a guideline to 13 suggest considering whether any further effort is 14 needed. So whether you're in the negligible risk area 15 and need to do anymore or not. Of course there will 16 be other considerations that may weigh into that. But 17 from a risk values perspective, that's where this is 18 looking at.
19 MEMBER SKILLMAN: Thank you.
20 MR. CALL: On the next slide. To see if 21 you know, since that time we note that these guidelines 22 are not widely known or incorporated into 23 risk-informing applications within the NMSS programs.
24 However, there's various concepts have you know, the 25 different groups are aware of the various other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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112 1 concepts in the guidance and made use of those as they 2 felt was deemed appropriate. Just describing some of 3 that here with the different organizations. The 4 Economic Directorate, my division in terms of spent 5 fuel storage, the fuel cycle and the materials and 6 decommissioning.
7 And some of these are in terms of ongoing 8 efforts. For example, in fuel cycle they're looking 9 to revise their oversight program. And they feel that 10 some of the milestones that they've set up for 11 activities there would be well suited to employ 12 guidance from, or consider guidance from the RIDM 13 document.
14 On the next slide. In addition to that, 15 just wanted to also make you aware that there have been 16 various activities both past and ongoing within the 17 different divisions that are risk-informing in nature 18 or that support risk-informing efforts. Many of these 19 if not all I would imagine are or have been or are 20 currently listed on the NRC's public website. And it 21 describes the different risk-informing activities of 22 the Agency.
23 And then I've listed here some examples for 24 the different areas. You'll see that this covers the 25 range of what we regulate at NMSS.
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113 1 And then that's the last slide, so if there 2 are any questions?
3 MEMBER SCHULTZ: Michael, are you 4 familiar enough with the fuel cycle effort with regard 5 to the integrated safety -- the overall plan as to know 6 what the schedule is there?
7 MR. CALL: For the revised oversight 8 program?
9 MEMBER SCHULTZ: Yes, exactly.
10 MR. CALL: That I'm not aware of the 11 schedule, no. I just know that they are working 12 towards some. They have an effort engaged in that 13 area.
14 MEMBER SCHULTZ: I'll look it up.
15 Thanks.
16 CHAIRMAN STETKAR: Any other questions 17 for Michael or the staff?
18 (No response) 19 CHAIRMAN STETKAR: If not, thank you all.
20 It's good overview of not only the RMRF initiative, but 21 what's going on in the other areas that would be 22 affected by the integrated policy statement and 23 regulatory framework.
24 With that I'd like -- we have next on the 25 agenda a slot for NEI. If you have some comments to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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114 1 come up.
2 Mike, we haven't received any material 3 from the slide or whatever.
4 MR. TSCHILTZ: No. No.
5 CHAIRMAN STETKAR: Or is it just -- okay.
6 It will be on the record.
7 MR. TSCHILTZ: Certainly. I 8 contemplated developing slides for this discussion, 9 but when I was initially asked to come and speak before 10 the Committee, it was under the presumption that the 11 paper would be available and the industry would have 12 an opportunity to comment.
13 And so I think my comments won't be so much 14 aimed at the content or the presumed content of the 15 paper, but more at a higher level as to where we're going 16 with this initiative and where the industry may come 17 out as far as seeing the benefit or not seeing the 18 benefit. I guess just looking at the process for 19 moving forward, you know, Dick Dudley described the 20 white paper followed by a public comment period 21 followed by potentially a meeting to discuss a 22 resolution of comments.
23 One perspective I would offer is that these 24 initiatives seem to be voluntary initiatives. And 25 they're not something that would be imposed upon the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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115 1 licensee, it would be something that they would 2 voluntarily apply for and implement similar to NFPA-805 3 or Option Two was the example that was given there.
4 So, the observation that I would have is 5 that NUREG-2150 was developed and written by an NRC Task 6 Force with little public involvement. The development 7 of the white paper, the Options is being developed with 8 little public involvement. Just one opportunity it 9 appears for stakeholder feedback on the white paper.
10 So, my concern is that there's going to be 11 a lot of effort potentially put into the development 12 of Options that there's no clear identified person or 13 utility that would implement it. So to me, it seems 14 that it needs to be more closely linked to the people 15 -- the development of the Options need to be more 16 closely linked to the people who would ultimately 17 implement that.
18 So, in separation of those two activities, 19 I think is problematic. And the reason that I wouldn't 20 offer more detailed comments I think are the devil's 21 in the details. I think whether these Options are 22 looked upon favorable and then people decide to 23 implement them are largely based upon the details that 24 are going to be developed for the Options.
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116 1 important that you know, we allow sufficient time in 2 the development of these Options for meaningful 3 interactions. And I would say it would be beneficial 4 to look at a potential examples of applications for 5 Option Two.
6 Just looking at Option Three on the 7 surface, it would appear that it's what I would 8 characterize as a heavy lift. And with all of the other 9 activities going on in the post-Fukushima era here, 10 there's a lot to consider. So, someone's volunteering 11 to take that on, at this stage I think that would be 12 questionable. But I think that's something that we 13 need to explore as we move forward.
14 The other observation I would offer is that 15 the industry and the NRC have formed risk-informed 16 steering committees. And there's joint meetings where 17 the industry's steering committee meets with the NRC's 18 steering committee. And they identify the issues that 19 they think are most important to be addressed in the 20 near term as far as risk-informed regulation.
21 And I think if you look at what we focused 22 on in the past year and the things that we're focusing 23 on in the coming year, it's going to identify the things 24 that are really issues that people face right now that 25 they need answers to. For example, this year one of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 1 the issues was PRA realism. And to a large degree that 2 was as a result of some of the issues that arose during 3 the development of fire PRAs for NFPA-805.
4 And the industry has a sense of urgency in 5 the need to resolve those issues with fire PRAs because 6 of the consequences of having these conservatisms. So 7 -- and the potential negative consequences and 8 diversion of resources to things that don't have a true 9 safety benefit.
10 So, I would say the risk-informed steering 11 committee is a good place and this is -- this issue, 12 the RMRF is one of the topics that the staff steering 13 committee has raised as a potential, one to be 14 considered in 2015. But I think the industry is 15 looking at more practical application, things that can 16 be used in the near term. The treatment of uncertainty 17 in decision making. Aggregation of risk and 18 development of external vent PRAs.
19 The flooding PRAs being an issue. I know 20 you've heard of the challenges that the industry and 21 the staff has faced with evaluating flooding hazards 22 to the deterministic methods that are used per site in 23 new reactors and the challenges that are created by 24 that. And not having a risk-informed or accepted 25 risk-informed method for dealing with those hazards.
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118 1 So, I would say that being said, I mean, 2 we're ready. I have a small working group formed to 3 review the paper when it's issued. And we'll provide 4 our comments and engage the staff.
5 I think the general belief out there I 6 think from when NUREG-2150 was initially issued was 7 that the regulatory framework doesn't really need to 8 be revamped at this stage. That our efforts would be 9 better spent encouraging and sustaining the existing 10 policies that have been put in place with the PRA policy 11 statement that exists.
12 And there's still a lot of work to be done.
13 We heard comments today on defense-in-depth. It has 14 just been out there since the initial implementation 15 of misconformed regulation. And people still struggle 16 with how to apply those concepts. So I think we can 17 clearly make progress in those areas in an evolutionary 18 way as opposed to a revolutionary way of reframing the 19 regulations.
20 So I'll stop there and take any questions.
21 CHAIRMAN STETKAR: Any questions for 22 Mike?
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119 1 about not having something more substantive to actually 2 comment on. But, that's the way it is. We will have 3 that opportunity in the future. And I'm sure you'll 4 be back.
5 MR. TSCHILTZ: Thanks.
6 CHAIRMAN STETKAR: And we have a request 7 from Union of Concerned Scientists. So I believe Ed 8 Lyman is here. Is Ed here? Oh, is he on -- okay. Ed 9 is apparently out there screaming at his communication 10 device. Ed, we'll get the line open for you in a second 11 here.
12 MR. LYMAN: Hello?
13 CHAIRMAN STETKAR: Ed, are you there?
14 MR. LYMAN: Yes. Can you hear me?
15 CHAIRMAN STETKAR: Yes, we can.
16 MR. LYMAN: Yes. I apologize for not 17 being there in person today.
18 CHAIRMAN STETKAR: No. That's fine.
19 MR. LYMAN: So, as always we appreciate 20 the opportunity to provide comments. But I don't want 21 to pile on here. But again, we were also expecting to 22 get the white paper to comment on. And so without 23 having that, my remarks are just going to be reactions 24 to some of what I've heard this morning.
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120 1 regulatory framework, I guess there are two separate 2 aspects here. One is the -- is it appropriate to 3 implement this policy statement Agency wide for all 4 aspects, even those where there may not be a clear or 5 useful application of risk management concepts? And 6 I think the answer to that is no from our perspective.
7 One clear example being security. I am 8 glad to hear that there doesn't seem to be an effort 9 to try to quantify the unquantifiable with regard to 10 initiating events for security. But that's certainly 11 something we would not support.
12 The other aspect is are the -- is what we 13 heard with regard to the Power Reactor Options on 14 appropriate. And I think the answer to that is also 15 no. I think there is a great need for the Agency to 16 clarify the way risk is being used to clear up some of 17 the issues and inconsistencies. And it doesn't sound 18 like this particular vehicle is going to accomplish 19 that. And you may not hear this very often, but I 20 totally agree with the NEI speaker about I think the 21 --
22 CHAIRMAN STETKAR: There's laughing going 23 on in the room Ed, if you can't hear it.
24 MR. LYMAN: But I actually am going to say 25 the same thing. I don't see how what the elements of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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121 1 the policy statement that were presented are any 2 improvement over the PRA policy statement. In fact I 3 think it may be a step backward.
4 For instance, I'm concerned about the 5 first bullet which sounds to me would perhaps the plant 6 adequate protection or equate adequate protection with 7 the idea that that's really risk management. And I 8 don't think you can really justify and I think risk 9 management is the only aspect of adequate protection.
10 And I'm concerned about the implications, the legal 11 implications of a statement like that.
12 I would say adequate protection is 13 probably closer to risk-minimization. Or that would 14 be our hope then risk management. You could always 15 keep in mind that you know, the public is one of the 16 customers of this policy statement and I think the 17 Agency needs to focus on improving the priority with 18 how it applies in it's decision making. And I don't 19 see that happening here.
20 One aspect I think that highlights it, we 21 heard how NFPA-805 was actually it sounds like it's 22 leading to greater inconsistencies between those who 23 voluntarily choose to implement it and sign 24 vulnerabilities that require correction and those who 25 don't. And that seems to be going in the wrong NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 direction.
2 So until that problem is fixed, it doesn't 3 seem like it's a good model for going forward. And I 4 don't see how Option Two, clearly industry is not going 5 to want to go on a hunt for unrectified vulnerabilities 6 that they're going to have to pay to fix. So that --
7 to expect that that's going to be a reasoned outcome 8 of this process is not a reasonable expectation. So 9 if it were going to happen, I think it would have to 10 be a mandatory Option Three type.
11 We've made pitches in the past for a new 12 vulnerability, you know, systematic vulnerability 13 assessment across the whole fleet so that you can at 14 least get consistency. And it seems to increase 15 inconsistency by allowing this process to be voluntary 16 would make matters worse.
17 So I think that's all I have to say on that.
18 On risk-informing security, we have some views on the 19 material attractiveness rule making that Joe Rivers is 20 well familiar with. I won't rehash them here, but I 21 think Dr. Rempe's comment goes to one of our main 22 concerns, that material attractiveness is not an 23 intrinsic aspect of material properties.
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123 1 their contentions. And that has to be accounted for 2 better in the rule making process to make clear that 3 there is some target adversary in mind when you're 4 talking about what materials are attractive and what 5 are less attractive.
6 The last point I wanted to make has to do 7 with defense-in-depth for spent fuel. I think here is 8 this is an area where there might be some value in 9 considering risk. And we think that if you apply the 10 defense-in-depth, the metric for evaluating the 11 expedited fuel transfer issue as I said before, that 12 that would make expedited fuel transference dry casks 13 look more attractive then if you've done a cost benefit 14 analysis expected.
15 So I would hope that that program would 16 also be applied not just to spent fuel in dry storage 17 but also comparative of risks of densely packed spent 18 fuel pools compared to dry storage.
19 And I think that's all I have. Thank you.
20 CHAIRMAN STETKAR: Thank you very much.
21 I've lost track of what lines are open. Was Ed on the 22 general public line?
23 MR. SNODDERLY: No. Ed was on the staff 24 line.
25 CHAIRMAN STETKAR: Was on the staff line.
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124 1 Okay. Let me ask, as long as we have the staff line 2 open, are any other members of the staff out there that 3 wanted to make any comments on anything? As long as 4 we have your line open.
5 MR. HARRISON: No comments here.
6 CHAIRMAN STETKAR: Okay. Thank you.
7 What we'll do then is open up the other line, which is 8 the public line. And while we're doing that, let me 9 ask if is there anyone in the room that has any comments 10 that you'd like to make? Please come up and do so.
11 Now, if there's a member of the public out 12 there, because of our high tech system here, could you 13 just please say something, hello or anything so that 14 we can confirm that your line is open.
15 (No response) 16 CHAIRMAN STETKAR: It's always 17 troublesome.
18 MR. SNODDERLY: There wasn't anybody.
19 CHAIRMAN STETKAR: Okay. We have 20 indications that there isn't anyone on the public line.
21 And if that's the case, then thank you all for your 22 comments. And again, NEI and Ed Lyman, you're on the 23 record for the meeting. So, we have your comments.
24 What we always do at the end of one of these 25 Subcommittee meetings, I'll go around the table and ask NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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125 1 each Member if you have any final comments that you'd 2 like to make. And also, if -- ask whether you think 3 that at this stage in the game it merits bringing the 4 issue before the full Committee.
5 I always like to get a little feedback from 6 other Members on that topic in terms of timeliness.
7 And because Joy got a chance to go last a few days ago, 8 you can go first today.
9 MEMBER REMPE: Oh. I wanted to thank you 10 for the presentations and comments. I look forward to 11 the white paper when it's released. I would encourage 12 us to have another Subcommittee -- my viewpoint is we 13 should have another Subcommittee meeting after the 14 white paper is released. And then I would take it to 15 the full Committee. I think at this time that we're 16 going before the paper is released to the full 17 Committee.
18 CHAIRMAN STETKAR: Charlie?
19 MEMBER BROWN: Same comment on the 20 presentations. Got something out of it. And I agree 21 with Joy that we ought to get the white paper done first 22 before we go to the full Committee.
23 CHAIRMAN STETKAR: Ron?
24 MEMBER BALLINGER: Same.
25 CHAIRMAN STETKAR: It's going quick.
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126 1 Mike?
2 MEMBER RYAN: It's a work in progress.
3 And I agree with the comments from my colleagues.
4 CHAIRMAN STETKAR: Dennis?
5 MEMBER BLEY: I agree with them except we 6 might want to wait until the public comments are in on 7 the white paper before we take it to the full Committee.
8 CHAIRMAN STETKAR: Okay. Dick?
9 MEMBER SKILLMAN: Yes, I agree with Dr.
10 Rempe. I'd like to hear again after we see the white 11 paper, after the public comments, that would probably 12 be better. But I also want to thank Dick and Joe for 13 putting up with my focused questions. Thank you Dick 14 Dudley and Joe.
15 CHAIRMAN STETKAR: Steve?
16 MEMBER SCHULTZ: I appreciate the 17 presentations and also the -- got the involvement by 18 both the staff and the other organizations that have 19 provided input to us today. And would suggest that we 20 have the Subcommittee meeting as we get the additional 21 information and join in with the public comment period.
22 CHAIRMAN STETKAR: Yes. My inclination 23 -- thanks. You have -- well, my inclination is to do 24 that Dick. Is that you're path forward that identified 25 interactions with the Subcommittee I think during the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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127 1 summer period. I think we want to probably interact 2 with you earlier then that so that you have the benefit 3 of the Subcommittee feedback in parallel with the 4 public comments.
5 And then see where we go after all of the 6 public comments are in and you have a final version of 7 the paper you know, later in the year. So, I think 8 we'll probably be looking at scheduling a Subcommittee 9 meeting in the April/May time frame. Well have to 10 figure out a slot to put that in. But I think earlier 11 the better I think is what you're hearing from us.
12 MEMBER BLEY: You want to wait until after 13 they have that meeting I would think.
14 CHAIRMAN STETKAR: I think we want to wait 15 until after they have that meeting. But not 16 necessarily wait until they have all of the public 17 comments and are working on the you know, the final 18 draft.
19 And with that, if there are no other 20 comments, we are adjourned.
21 (Whereupon, the above-entitled matter 22 went off the record at 11:30 a.m.)
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Staff Recommendations Regarding a Risk Management Regulatory Framework Briefing for ACRS Subcommittee February 20, 2015
Outline of Staff Presentation on Risk Management Regulatory Framework (RMRF)
Background and Current Approach (R. Dudley)
Agency-wide Policy Statement Implementation Options for Power Reactors Path Forward Status of Risk-Informed Activities Regarding Common Defense and Security (Joe Rivers)
Status of Risk-Informed Activities Regarding Spent Fuel Dry Storage (Michel Call)
Status of Risk-Informed Activities Regarding Nuclear Materials Licensing (Dennis Damon/Michel Call) 2
Summary: Background and Current Approach to Evaluate Risk Management Regulatory Framework Chairmans Tasking Memorandum of June 14, 2012 directed staff to review NUREG-2150 and provide a paper to the Commission that would identify options and make recommendations, including the potential development of a Commission policy statement.
Commissions May 19, 2014 SRM on Near-Term Task Force Recommendation 1:
Directed staff to reevaluate objectives of Improvement Activity 1 (new design-basis extension category) and Improvement Activity 2 (adequacy of defense-in-depth) within context of Commission direction on long-term Risk Management Regulatory Framework Closed NTTF Recommendation 1 Increased scope of RMRF SECY paper (describe relationships between ongoing risk-informed activities)
Staff has requested extension of due date until December 2015 Management has re-evaluated the staffs approach to evaluating agency-wide RMRF Staff will consider 3 RMRF implementation options for power reactors Staff will also ask Commission to consider an overarching, agency-wide risk management policy statement 3
Overview of Agency-wide Policy Statement Applicable to all NRC-regulated program areas (radiological safety and security)
A risk management approach would be used to ensure adequate protection of public health and safety and promote the common defense and security for all NRC regulatory activities.
In a risk management approach, safety and security are ensured by (1) understanding the risk associated with NRC-regulated activities and (2) using that risk information to make regulatory decisions.
4
Overview of Agency-wide Policy Statement (continued)
The risk management approach would:
- 1. Use a structured process to identify issues, develop and analyze options, make decisions, and monitor the effectiveness of regulatory programs to make improvements as necessary,
- 2. Ensure appropriate regulatory controls and oversight are in place recognizing the variety of risks associated with different uses of radioactive materials, and
- 3. Employ risk-informed decision-making, in which risk insights are considered together with other factors commensurate with their importance to public health and safety and common defense and security.
5
Overview of Agency-wide Policy Statement (continued)
The technical analyses supporting the risk-management approach should:
- 1. Be based on sound data, information, and methodologies, including consideration of uncertainties,
- 2. Use techniques or combinations of techniques appropriate for the hazards and complexity of the issue,
- 3. Be as realistic as practicable, and
- 4. Promote and utilize advances in science and technology, as practicable.
6
Three Power Reactor Implementation Options Option 1 - Maintain Current Framework Option 2 - Voluntary Alternative Risk-Informed Licensing Basis Option 3 - Plant Specific Risk Management Regulatory Framework from NUREG-2150 7
Power Reactor Option 1 - Maintain Current Framework No overall revision of NRCs regulatory framework The current power reactor regulatory framework meets the RMRF criteria in NUREG-2150, Chapter 4 - Option A Commission Safety Goal Policy sets forth the risk management objective Current regulations implement sufficient protections (e.g., defense-in-depth and safety margins) corresponding to NUREG-2150 risk management goal NRRs LIC-504 sets forth a risk-informed decision process with steps consistent with those described in NUREG-2150 NRC has numerous monitoring and feedback mechanisms to (1) gage the efficacy of regulatory decisions and (2) identify new information that should be considered within the regulatory framework Not a do nothing option -- staff would still make safety improvements (based on risk insights or other considerations) whenever deemed necessary using existing regulatory processes 8
Power Reactor Option 2 - Voluntary Alternative Risk-Informed Licensing Basis Maintain existing generic regulatory structure Issue rule allowing licensees who upgrade PRAs to apply for approval of a licensing basis that would support a performance-based, risk-informed alternative to certain deterministic regulations of low safety benefit Licensees allowed to select a plant-specific set of design changes/compliance issues of low risk-significance that would deviate from current deterministic requirements (NRC or self-approval) and must search for and mitigate all plant-specific risk vulnerabilities meeting NRC-specified criteria New information on mitigation of risk-significant events and/or accident sequences (risk vulnerabilities) must be documented in an updated Final Safety Analysis Report (FSAR) in accordance with 10 CFR 50.71 (e) requirements Mandatory monitoring and feedback (as described in RG 1.174) to ensure changes in risk remain acceptable throughout the lifetime of the facility 9
Power Reactor Option 2 - Voluntary Alternative Risk Informed Licensing Basis (continued)
Regulatory process for licensees to self-approve certain plant-specific changes would be similar to NFPA-805 approval process, i.e., risk-informed changes allowed to license requirements without prior NRC approval if risk increase ( CDF) is no more than minimal (e.g., < 1E-7/year)
Changes with risk increases more than minimal (e.g., > 1E-7/year) require NRC approval Plant licensees are expected to have upgraded, high quality PRAs to support this risk-informed alternative licensing basis approach 10
Power Reactor Option 3 - Plant-Specific RMRF from NUREG-2150 Require PRAs and establish plant-specific licensing basis based on:
Plant-specific risk profiles NRC-specified risk management objective Structured, risk-informed decision-making process used by both NRC and licensees Based on the risk profile, licensees would implement the plant-specific licensing basis by:
Determining how the risk objective is met Ensuring that the necessary protections are in place to meet the risk management goal Establishing the risk-informed decision-making process Establishing the monitoring/feedback and reporting process 11
Power Reactor Option 3 - Plant-Specific RMRF from NUREG-2150 (continued)
Each plants licensing basis would consist of:
Technical requirements based upon plant-specific attributes and applicant-selected design specific elements/constraints Rationales (technical bases) why the technical requirements adequately address risk and defense-in-depth in light of the plant-specific attributes and design specific elements/constraints FSAR-level description of the plant-specific attributes and applicant-selected design specific elements/constraints that are the inputs/assumptions for the above rationales (technical bases) which must be maintained Process for maintaining the validity of the rationales (technical bases) throughout the operating lifetime of the facility.
Licensees would be required to use the structured process with monitoring and feedback to ensure that the plant-specific licensing basis remained consistent with the risk profile of the plant, which could change over time.
12
Path Forward on RMRF Draft white paper and outline of policy statement now being reviewed by NRC Senior management Incorporate management comments into updated draft white paper and release to public Public meeting (late April) to discuss draft white paper Solicit written public comments on later version of white paper via www.regulations.gov Summarize public comments and meet again with ACRS (summer)
RMRF SECY paper currently due to Commission on December 18, 2015 13
Backup Slides 14
Definitions To ensure a common understanding of this example policy statement, it is important to know the differences between the terms risk management, risk assessment, and risk-informed approach.
Risk management is the recognition of the threat or danger involved with the use of nuclear materials and establishing controls and oversight to manage the potential threat or danger. That is, it is coordinated activities to direct and control an organization with regard to risk. [From ISO 31000, Risk Management - Principles and Guidelines]
Risk assessment is the evaluation of what can go wrong, how likely is it, and what would be the consequences? This consideration may be addressed either qualitatively or quantitatively. [From SRM-SECY 144, White Paper on Risk-Informed and Performance-Based Regulation, March 1999]
15
Definitions (continued)
Risk-informed approach to regulatory decision-making represents a philosophy whereby [quantitative and qualitative] risk insights are considered together with other factors to establish requirements that better focus licensee and regulatory attention on design and operational issues commensurate with their importance to public health and safety. A risk-informed approach enhances the deterministic approach which is used to define many of the design and operational requirements for NRC licensees. Risk-informed approaches lie between the risk-based and purely deterministic approaches.
[From SRM-SECY-98-144, White Paper on Risk-Informed and Performance-Based Regulation, March 1999]
16
NUREG-2150 Hierarchy and Structured Decision-making Process 17
Joe Rivers, NSIR February 20, 2015 ACRS Subcommittee Meeting
NRC Sandia Workshop 2010
- Six Areas of Opportunity Identified
- Uncertainty of initiating events
- Simulation tools
- Collaboration between safety/security
- Improved metrics
- Demonstration project like WASH 1400 2
February 2014 INMM Workshop
- Safety/Security Risk Approaches
- Material Attractiveness
- Likelihood of Event
- VA Simulation Tools
Safety/Security Risk Approaches
- Discussion of PRA at NRC
- Presentation of an extensible risk informed decision support method
- Implications of security challenges for safety assessment tools
- DNDO risk models 4
Material Attractiveness
- NRC approach under development
- DOE support for NRC approach
- NGO thoughts on approach
- Industry thoughts
- UK comments on concept of dilution
- French presentation on security at civilian facilities 5
Likelihood of Event
- Surveys of possible approaches and options
- Discussions of how approaches might be used
- National Consortium for the Study of Terrorism and Responses to Terrorism approach 6
VA Simulation Tools
- ARES Corporation - AVERT
- Rhino Corp - Simajin
- Sandia modelling
- DTRA modelling
- PNNL tool to address physical and cyber attacks 7
- Discussion of pros, cons and challenges of risk informing cyber security
- NRC regulatory program
- PNNL cyber risk model 8
Current Activities
- Risk Prioritization Initiative
- Risk Management Regulatory Framework Working Group
- Use of Simulation Modelling
- Material Attractiveness
- NUSAM 9
Risk Prioritization Initiative
- Attempt to prioritize plant projects informed by risk associated with safety, security, emergency preparedness, and radiation protection
- Industry Pilots conducted 10
Risk Management Regulatory Framework Working Group
- Addressing recommendations of RMRF Task Force
- First, focus on reactor safety
- Expand to other disciplines
- Include concept of defense in depth
- Look at beyond design basis accidents 11
Use of Simulation Modelling
- Industry initiative to incorporate vulnerability assessment modelling tools into regulatory process
- Industry pilot to model a number of NPPs
- NRC staff assessing process to determine requirements for use in regulatory process 12
Material Attractiveness
- Development of an approach to grade security based on the attractiveness of the nuclear material to the adversary
- Approach allows alternative measures to be applied for varying levels of dilution
- Will apply to fuel cycle facilities and RTRs 13
Los Alamos Model
- Logic model developed
- Four modules
- Acquisition
- Processing
- Weaponization
- Yield reduction
- Provides an estimate of likelihood 14
- Reactor cyber security implemantation under way
- Highest consequence critical digital assets (CDAs) adressed
- using a consequence based approach to consider lesser requirements for CDAs with lower consequences 15
NUSAM
- IAEA Coordinated Research Project
- Develop guidance on the conduct of security assessments
- Case Studies
- NPP
- Irradiator Facility
- Rad Material Transport
- LEU Fuel Fabrication Facility
- Spent Fuel Storage Facility 16
Upcoming Workshops
- INMM Reducing Risk Workshop
- INMM/ANS Workshop on Safety/Security Risk
- INMMWorkshop on VA Tools 17
INMM Reducing Risk Workshop
- March 2015 in Washington, DC
- Session on Cyber Security
- Focus on risk approaches that might apply to cyber security 18
ANS/INMM Workshop on Safety/Security Risk
- April 2015 in Sun Valley, Idaho
- Engage safety and security risk professionals in a discussion of risk applied to their discipline 19
INMM Workshop on VA Tools
- September 2015 in Boston
- Discussion of VA Tools
- Discussion of VV&A
- Discussion of modelling issues
- Discussion of data
- Demonstration by Vendors
- Discussion by users
- Panel Discussion 20
Questions ?
21
Risk Informing Spent Fuel Dry Storage Michel Call Division of Spent Fuel Management Office of Nuclear Materials Safety and Safeguards
Risk-Informing Effort Prompted by agency activities and stakeholder interactions Goal - framework to better enable risk-informed regulatory decisions Focus - initially on spent fuel dry storage Approach - 7 major steps
Defense-in-Depth Public Workshop Definition and application in dry storage, one major step Held public workshop Jan 15, 2015 Well attended with good public and industry participation NRC and NEI presentations
Defense-in-Depth Approaches NRC 3 layers (engineered, programmatic, and mitigating controls) 3 safety functions (sub-criticality, radiation exposure, radioactive materials release) 3 operations phases (loading/transfer, storage, unloading)
NEI Barriers, controls, etc. to prevent, contain, mitigate exposure to radioactive materials
Risk Informing in NMSS Michel Call Division of Spent Fuel Management Office of Nuclear Materials Safety and Safeguards
Risk-Informed Decisionmaking (RIDM)
Guidance document developed by NMSS Risk Task Group Current Revision (Rev 1) from February 2008 (ML080720238)
Response to SRM-SECY-99-0100 4 objectives of the RIDM document Commission Approval in SRM-SECY-04-0182
Quantitative Health Guidelines (QHGs) 6 Guidelines Public Worker Acute fatality 5x10-7/yr 1x10-6/yr Latent cancer 2x10-6/yr or 1x10-5/yr or fatality 4 mrem/yr 25 mrem/yr Serious injury 1x10-6/yr 5x10-6/yr Not endorsed by Commission policy statement Guidelines vs. Goals
Use of RIDM & QHGs QHGs are not widely known or incorporated into risk-informing applications NMSS programs Yucca Mountain - risk-informed regulation and guidance in place, pre-dates RIDM and QHGs Dry Spent Fuel Storage - consideration in effort to risk-inform dry storage Fuel Cycle - consideration/application in revised oversight program development Materials and Decommissioning - have made use of various concepts from RIDM
Other NMSS Risk-Informing Efforts Variety of Activities past and present Current activities described on NRCs website Examples of Activities (past and present)
NUREG-1556 Series - Guidance about Materials Licenses Part 61 rulemaking - Land disposal of radioactive waste Fuel Cycle - Integrated Safety Assessment, Part 70 Subpart H Yucca Mountain - Part 63, Performance Assessment Spent Fuel Transportation - Fire Studies