ML17313A819

Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process

ML17313A819
Person / Time
Site:	Palo Verde
Issue date:	02/24/1999
From:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-64FR3576 64FR3576-00020, 64FR3576-20, SECY-99-007-C, SECY-99-7-C, NUDOCS 9903020325
Download: ML17313A819 (14)

Text

ACCESSION NBR:9903020325 t CATEGORY 2 DOC.DATE: 99/02/24 t

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

NOTARIZED: NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION LEVINE,J. ,

Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION MEYER,D.L. Rules 5: Directives Review Branch (Post 920323)

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SUBJECT:

Comment supporting SECY 99-007, "Recommendation for Reactor A Oversight Process Improvements," 8 comments provided by NEI 6 Regional Utility Group IV.Offers comments on NRC approach to using performance indicators in assessment process. T DISTRIBUT10N CODE, DS09D TITLE SECY/DSB Dist:

COPIES RECEIVED,LTR Public C4mment on Proposed j ENCL Rule I SIZE.~

(PR)-Misc Notice;Reg G E

G NOTES:STANDARDIZED PLANT 05000528 Standardized plant. 050005290 Standardized plant. 05000530 RECIPIENT COPIES COPIES ID CODE/NAME 1'ECIPIENT LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL: CENTER OGC/DR 15-B-18

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NOTE TO ALL "RZDS" RECIPIENTS:

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~r=yr ~n aa, I'" 9 James M. Levine TEL (602)393.5300 Ma) Station /tt02 Q, 0 Sohbr Vice Pn stdr ht FAX {602)393.6077 'P.o. Box 5203<

Po!o Verde Nuoloo~

NUcteaf Phoen x, AZ 85072.2P34 Generating Sta'tan 102-04249-JML/AKK/DLK February 24, 1999 Chief, Rules and Directives Branch Division of Administrative Services D3 Office of Administration U. S. Nuclear Regulatory Commission rn Mail Station: T D59 NIashington, OC 20555-0001 B~

Xl'IW PI Dear David L. Meyer

Subject:

Palo Verde Nuclear Generating Station (PVNGS)'nits 1, 2, and 3 Docket Nos. STN 60-528I829I530 Comments on 8ECY S9-00?, "Recommendation for Reactor Oversight Process Irnprovemerlts" I

Arizona Public Service Company (APG) has reviewed SECY 80-007, "Recommendation for Reactor Oversight Process Improvements," dated January 8, 1999, and would like to take this opportunity to submit comments for conslderatlon. APs also fviwards an endorsement nf the comments provided by the Nuclear Energy Institute (NEI) and Regional Utility Group (RUG) IV.

APS COMME TS APS agrees with the NRG's approach to using performance indicators (Pls) in the assessment process. However, some of the proposed performance Indicators are not readily available or suitable for use in a risk-informed assessment. There is a good understanding of performance indicators used for assessing the Initiating Events, Mitigating Systems, Barriers, Occupational Radiation Safety, and Public Radiation Safety Carnerstones. The Physical Security performance indicators and some of the Emergency Preparedness performance indicators have not been well developed, are not risk-informed and their usefulness is still unknown. Therefore, APS recommends that performance in the Physical Protection Cornerstone continue to be assessed using complimentary inspections only and porforrnence indicators in the Emergency Plan be reviewed for their ability to Indicate safety-significance, riskinformed performance.

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i eb po-99 11 4 pvN P ~ OD Chief, Rules and Directives Branch Division of Administrative Services Offico of Administration U. S. Nuclear Regulatory Commission Page 2 The concept of using a combination of performance indicators and inspection results as prirrrary inputs into the performance assessment process ls sound and workable. APS believes some additional evaluation and refinement of the proposed Pls and inspections is needed to establish more equitable evaluation criteria and threshold triggoro in order to concentrate focus on risk-significant areas, eliminate duplicate inputs, and define the process of integrating the two inputs into an overall conclusion. Listed below are some examplo0:

o Equitable Evaluativrr Criteria and Threshold Triggors Attachment 2, page 19 contains a discussion about the possible use of plant specific information to establish some threshold triggers. N/hlle this approach may effect consistency ~cross the industry, the fact remains that age, design, size, and siting have a direct effect on the risk characteristics on an individual facility. For example, a facility that divas built or modified to include state-of-the-art technology should not be penalized for their ability to determine system unavailability with a higher degree of accuracy. Another example of risk characteristic differences'ould be failure of a number of emergency plan sirens at site located in a sparsely populated area that does not carry the same risk significance as the same number of failed sirens at a facility located in a heavily popuiat& area. APS recommends incorporating a mechanism into the assessment process that allows for threshold adjustments on a case by case basis wlien Justifiable from a risk perspective.

u Focus on Risk-Significant Areas Attachment 9, Appendix B. page B.B contains a discussion on Safety System Failures and makes reference to 26 safety-related systems. While not specTiically defined in Gi GY 99-007, it is highly unlikely that all 28 systems are risk-significant in.

terms of major contributors to Core Damage Frequency. The Pl should focus on "High Risk Significant Systems" as defined by the Maiirtvr~ance Rule, The term "failure." as used for the Pl, should be clearly defined to remove some of the subjectivity over what constitutes a failure. APS recommends the following definition: "A failure is the inability of a system, structure, or component {SSC) to meet a current design basis performance requirement that results in the inability of the SSC to perform a safely function under design basis conditions,"

a Eliminate Duplicate Inputs Attachment 3. pages l.1 through I.45 references several proposed inspection areas that are duplicated as existing Pls or by other inspections. Risk-significant problems that might bo found during the course of an inspection will also manifest themselves in the form of inspection findings or degraded performance indicators elsewhere.

For example, emergent work or rnairiterrarrr;r" work prioritization risk-significant problems would manifest themselves as findings in the Maintenance Rule inspection, or degraded system availability, safety system failure, or initiating event Pls. APS recommends eliminating duplicate inputs.

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i eb ao-ss xl ae r vN Chief, Rules and Directives Branch Division of Administrative Services Office of Administration U. S, Nuclear Regulatory Commission Page 3 o Pl and Inspection Integration Attachment 4, "Assessment Process," runes not provide clear guidance on how to combine the NRG inspection results with the licensee measured Pls nor does it provide guidance on equating inspection findings to Pls from a risk-significant perspective so the two can be combined and overall plant safety performance assessed. Also, the Action Matrix (attachment 1, page 8) introduces confusion in the results row by using colored "windows" as. the decision triggers. Colored "windows" are products of Pls not products of conclusions drawn from the combination of Pls and inspection results. APS recommends developing a clearly defined method to integrate NRC inspection results with Pls to assess overall plant safety performance, Because Pts are based on factual data, and inspections can Introduce subjectivity, APS recommends Pls be given more influence in the overall conclusion.

SEGY S9-007 does not specifically include licensee-performed self-assessments as potential alternatives to NRC iiispections. APS believes that properly documented or NRC monitored self-assessments provide valuable insight into evaluating performance and should be a factor in the inspection planning process.

Attachment 3, page 7 contains a discussion on the process for evaluating problem resolution, As part of the process, tho NRC will review licensee activities to "verify root causes of problems and issues have been properly determined and corrective actions are timely and ettectwe." APS ls concerned that this could have the effect of Introducing regulation beyond the scope of 40 CFR 50 Appendix B Criterion 16 if the reviews apply to anything less severe that "significant conditions adverse to quality." Many station problems identified are conditions adverse to quality, but not "significant conditions adverse to quality," therefore no root cause evaluations are required by current regulaliuiis. APS recommends that the review of root cause evaluations be timited to "significant conditions adverse to quality."

Attachment 5, page 2 refers to "regulatory significance" as an influencing factor in determining enforcement severity levels, "Regulatory significance" is not always driven by risk significance and should not bc a factor when making risk-inforrnod docision0.

APS recommends eliminating references to "regulatory significance" as it applies to determining enforcement or categorlzlng'inspection findings.

SECY 99-007 has prompted many comments from individual plants and the nuclear utility industry as a whole. Most of the comments either seek clarification or express concern that specific parts of the proposal may not yield the intended results.

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~ i eb-25-99 11-PG PVN Chief. Rules and Directives Branch Division of Administrative Services Offioo of Administration U. S. Nuclear Regulatory Commission Page 4 APS recommends that a process be established during the fmplementation phase where questions sooking clarification can be submitted, reviewed, answered, and published on a web site. Questions should be reviewed by both the NRC and a nuclear industry group such as NEI on a frequent basis (l.e, weekly), and both organizations should come to agreement on the answer. The web site could also be used as a forum for sharing any lessons learned during the Implementation phase. Had a similar proooso been used during the implementation of the Maintenance Rute, many of the initial problems and misunderstandings would have been avoided.

APS appreciates the NRG's willingness to consider industry comments on the proposed Reactor Oversight Process and commends the NRG for their work ln aggressively pursuing this effort.

Shoufd you have any questions, please contact Ms. Angefa K. Krainik at (602) 393-5421.

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