ML19289A189

NRC SEP, Speech for Presentation at Oct 1978 Meeting of Ens/Ans in Brussels,Belgium

ML19289A189
Person / Time
Issue date:	10/31/1978
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:
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ML19256F916	List: ML19289A189 NUREG-0510, Responds to 790614 Questions Re Status & Future of Nuclear Power in Mi.Nrc Has Summarized Historical & Economic Data Requested.Forwards NUREG-0510.Cover Sheet Only Encl
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NUDOCS 7912270077
Download: ML19289A189 (30)

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THE UNITED STATES NUCLEAR P.EGULATORY COMISSION SYSTEMATIC EVALUATION PP03RA'1 BY DARRELL G. EISEt; HUT

• TO BE PRESENTED AT THE ENS /ANS MEETIf.tG, OCTOBER 1978 c

BRUSSELS, BELGIdM ABSTP.ACT

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The United States l'u: lear Regulatory Commission has begun a program to retvaluate the safety mergins of the design and operetion of eleven of the oldu.t operating fetilities in the United States.

These facilitiu, which wers licensed as early es 1959, will be compred against preser.t NRC require ents and guidelines for new plants.

The ef fort nli.1 evolutte six boiling t.ater reactors cod five pressurized water reactors and will be completed by ebout curly 1981.

Mr. Eisenhut is Deeuty Director, Division of Opercting Reactors U.S. !;uclear Regulatory Cor.-ission, Washington, D.C. 20E55 (301-492-7221)

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2 1.0it,Cm0VND In the United States, it hSs long been recognized that a need exists to document more thoroughly the bases for the safety of cider operating rea c to rs.

This need is prompted by the differences between current technical positions on safety issues and those that existtd in the past when older operating nuclear plants were licensed to operate.

Therefore, to effectively end convincingly confirm the level of safety provided in older operating plants, and to document the acceptability of that 1 vel of safety, the United States h'uclear Regulatory Commission has begun a program called the Systematic Evaluation Program (SEP).

The SEP will reeveluate eleven of the oldest operating plants in the United States.

It includes plants licensed for operction as early as 1959 and includes six boiling water reactors (BWRs) and five pressuri:ed water reactors (PWRs).

These plants, as a group, genere11y tend to precede what one might call the modern generation of light water r: actors; that is, those in which a large pipe breek was evalveted as a desian basis and for which large emeroency core cooling systems were rtquired to tinimize the effects and consequences of such a design basis accident.

Fc110..ir.g ctmletion of the SEP review for these eleven facilities, a dtc'.? ion will be made regarding whether to cor. duct this type, or erothtr type, of review for the remainder of the seventy (70) nuclear pract plar.tt presently licensed to optrate in the Unittd States.

For reacters whic, receive en cperating license in the future, it is expected ifat such c re-review program will not be needed.

This is due to at least two majcr reasons:

first, it is not expected that requirements end guidelines for nuclear plants will undergo an evolution process Limilar to that undergone in the 1950s and early 1970s, and second, the h'R; has instituted new procedures for each new operating license e

review which will require the documentation of deviations from all license rtquirements then current and the basis for accentence.

2.0 PR33 W OBJECTIVES If The major objectives of the Systematic Evaluation Program are:

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1 Assess the margins of safety of the design and operation of the eleven selected plants with respect to current licensing F

requirerents,

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Establish documentation which shows how these operating plants compere with current acceptance criteria and guidelines on significant safety issues, and provide a technical rationale for acceptable departures from these criteria and guidelines, 3.

provide the capability for making integrated and balanced decisions with respect to any required backfitting, and 4

Provide for the ea'ly identification and resolution of any

,1 potential safety deficiency.

It is expected that the NRC's review of these eleven facilities will require approximately three years to complete.

3.0 FIOGRUi DESCRIPTION The Systematic Evaluation Prograr will evaluate specific safety topics (called the Topic List) and is based on en integrated review of the overall ability of a plant to respond to certain design basis events (challenges), including normal operation, transients and postulated accidints. The evaluation will result in a reassessment of the overall safety msrgins for each feilMy and documentation of the reassessment on the basis of current criteria.

The Tcpic List consis ts of about 130 technical issues that will be evalueted for each of the eleven nuclear plants.

The Topic List can be considered to consist of two types of items.

The first type is brcadly termed the design basis events, i.e., transients, accidents and natural phenomena, which the plant should be able to accommodate I

without exceeding specified acceptance criteria.

Examples of such

lii design basis events are internal plant events such as i roine trip, a failure of a high energy piping line, or a fire and en 31 phenomena F

such as seismic events and floods.

The second type consis.

'f identified potential equipment failure ecchanisms within saf s y-rel at ed syste.s (for example, equipment to monitor the condition of d... power system supplies) or in general, degradations in structures, systens, or components that are designed to mitigate the consequences of accidents.

Some topics on the topic list are generic and are the subject of other ongoing NRC programs.

They will be resolved and implemented independently of SEP activities; however, for the plants which are part of the SEP effort, the ultimate conclusions of a facility review for ongoing generic concerns and of the SEP will be closely integrated, where practicable, into an overall NRC position to improve the effectiveness and efficiency of these efforts and to minimize impacts on licensees.

In addition, the status and conclusions of all generic issues will be molded into the final safety assessment for each plant, ntMA1A,....,b

4 Each design basis event will be evaluated and potential corrective measures will be documented for consideration when the overall plant safety assessment is made.

The effect of corrective neasures identified for each event evaluated will be examined to determine the integrated effect of the preliminary assessment from all other design basis events.

This will provide assurance that measures taken to assure an acceptable response to one event will not adversely effect the plant's response to some other event, that backfitting decisions are balanced, and that the most efficient approach to any necessary plant upgrading

r is taken.

After potenti.01 conflicts in system functions have becn identified and resolved, alternatives will be considered end overall integrated decisions on the plant as a whole can be made on the appropriate corrective action, t,. 0 DE ISION CRITERIA The review of each of the items on the Topic List will include a comparison of each individual plant with current f;RC licensing criteria and guidelines - - such as the Standard Review plan, Regulatory Guides,and established steff positions on certein topics.

Deviations from these criterie will be deemed ecceptabic if the staff evaluation shows that the plant will resp;nd satisfactorily to all design basis events.

The capability of a plant to respone' to selected design basis events will be the basis for assessing the safety significance of deviations from current criteria for individual topics.

The selected design basis events consist of identified single events which can potentially result in greater than routine releases of radioactive material from the site.

This set of design basis events include for example:

(1) natural phenomena such as earthquakes and floods and (2) events resulting from postulated plant transients, accidents and failures such as turbine missiles, pipe breaks, or fires.

Certain of the topics on the Topic List effect the likelihood of occurrence of an event and others' affect the response of the plant to the event ( some topics affect both).

Both the likelihood of the event and the plant response to the event will be considered in making safety assessments.

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. SP.P criteria will be used as a gauge to determine the extent of confomance with current licensing criteria.

Where current licensing criteria and guidelines are met for individual plants, the staff will document this acceptability. Where the criteria and g;idelines are not met, the following alternatives (or combinations of alternatives) will be considered as a basis for establishing acceptability:

1.

The deviation can be justified as not significently decreasing the level of safety, i.e., the probability and/or consequences of events are suf ficiently low, 2.

The use of non-safety systems to perform the required safety functions, 3.

Possible administrative or procedural changes to enhance system rel iabili ty, 4.

Augter.ted inspection and testing of safety systems, and 5.

Selected backfitting to improve safety rargins.

An evaluetien of relevant operating experience will also be included in each step of this process, as appropriate.

This evaluation will include a review of licensee operating and event reports for indications of any needed changes to reduce the likelihood of system or component fa il u res.

Favorable operating experience will also be considered in assessing deviations from current criteria where appropriate.

5.0 ACTIONS TO DATE Although active evaluation is proceeding on a number of technien1 subjects, developments on a couple of issues are worth noting.

First, at the onset of the Systematic Evaluation Program it was recognized that any significant safety issue that was identified during this program must be resolved expeditiously and outside of the schedule of the SEP, at letst on an interim basis. Thus far, one such item, the " environmental qualification of safety-related equipment", has been identified.

All eleven SEP facilities were visited and equipment such as electrical connectors, penetrations and terminal blocks wers rwiewed, htailed information from each facility which indicates the degree of e;vironmental qualification of all electrical equipment, is presently under evaluation.

As a result, environmental testing has been performed by several utilities on certain pieces of electrical equipment under postulated LO:A-type environments.

The results of these qualification testing programs t. ave occasionally led to the r. placement of selected electrical components, t

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A second major evaluation is the area of seismic design.

This is probably one of the most difficult tasks and will require the longest period of time to complete.

To date, the staff has initiated its evaluation to detemine the appropriate seismic inputs (acceleration, spectra) for the SEP plants as compared with those used for new plants.

The SEP plants fall basically in three different groups as to the vintege of their seismic design.

The oldest plants typically were conservatively designed to building codes in existance in the lete 1950s, and early 1960s, but without specific dynamic analyses of structures and systems.

Those plants designed in the mid 1960s were designed with a specified ground accelerationmd e variety of response spectra.

The third group of plants, those designed in the late 1960s, used tethods which yeild results generally equivalent to'those in use today.

The staff's evaluation efforts to determine the seismic capability of these plants, is expected to vary from a minimal effort for the latter group to a significant re-analysis, and possible upgrading for the Oldsst plants, t

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N IDENTIFICATION OF iir UNRESOLVED SAFETY ISSUES RELATING TO

!F NUCLEAR POWER PLANTS _

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OUEST10's 3.

I am told that the fiuclear Reculatory Comission has cited 14ichigan as being tmong the worst states in terms of regulatory

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compliance and that within the past thrce years, 217 citiations have been issued for safety violations, infractions and deficiencies.

Is this an accurate portrayal of the situation in liichigan? Can you confirm these statistics?

ANSWER An NRC document entitled " Licensee Regulatory Performance Evaluation," dated October 25,1978, (Attachment 1), doscribes three studies conducted in 1976 and 1977 to assess the development, status and future plans for. work in the field of licensee perfor: nance evaluation.

All three studies were developmental in nature.

Each evaluatien methodology studied showed both strengths and weaknesses, and none was adopted by the Co raission as an acceptcble measure of licensee perfor-mance.

The infomation in the studies, in f act,.was not endorsed by the Comission, although the Comission did tuthorize further development of the evaluation metholdogy.

In November,1978, reports of each study and related documents were placed in the public domain in response to a request under the Freedom of Information Act. The studies were not released earlier because they were considered predecisional material, and the results, including the ranking of plants, were carefully qualified to point up the need for further.refincments in the evaluation methodology.

Those qualifications apparently were overlooked in some media accounts, in this connection, it is important to note that the standards and criteria for saf ety (in the "go/no go" or " pass /f ail" sense) commonly applied in.NRC!s licensing, inspection and. enforcement processes were not used in the comparative evaluations, Instead, the evaluations were based on a series of measures -- some quantifiable (such as.the numbers of items of noncompliance with NRC regulations), and some subjective (such as inspector opinions in the inspector survey) -- from which an attempt was made to find a numerical rank or level for each licensee.

" Items of noncomplian:e" are. citations issued by NRC to indicate f ailure to comply with regulatory requirements. They are classified in three categories of decreasing severity:

Violations, Infractions and Deficiences, each of which is a violation in the statutory sense. is a description of these categories.

Attach-ment 3 is a list of items of noncompliance, by category, for reactors in the State of Michigan for the years 1975, 1977 and 197S.

For the operating reactors (Big Rock Point, Cook 1, Cook 2 end Palisades) the total of the items shown is 270.

The discrepancy from the 217 figure cited in your question may be due to duplicate citations against Cook 1 and Cook 2 where.an item of noncompliance was common to both ur.its but cited against each of them, m.m rb

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The enclosed Nuclear Regulatory Commission Staff Paper, p0LICY SESSION i

ITEM (EECY-78-554, dated October 25,1978) with subject " Licensee i

Regulatory Performance Evaluation" describes three approaches tried by the NRC staff for evaluating the regulatory performance of operating nuclear power plants.

These approaches were preliminary efforts toward developing a technique for evaluatin) the regulatory performance of NRC l

licensees on a nationwide basis.

The staff has requested Commission approval of a two-year trial program to further develop and test an i

evaluation technique.

If successful, licensee regulatory performance evaluation should give NRC staff the ability, on a nationwide basis, to distinguish between icvels of licensee regulatory performance.

This could lead to more effective use of the agency's inspection and enforcement resources and to identification of plants that need further examination by the agency.

The NRC staff emphasizes that, while an evaluation program may be useful in focusing staff attention of the plants that depart from the performance of the majority of plants, the means of assuring adequacy of plant safety will not be changed. This assurance will continue to rest on detailed reviews of plant operations by the Office of Muclear Reactor Regulation and plant-by-plant judgments made as a result of inspections by the Office of Inspection and Enforcement.

The three evaluation approaches which have been tried are:

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The " statistical method," based on evaluating two measures of performance: the number of noncompliance findings and the number of events, considered directly controllable by the licerQ4fb9 A 1 C1 the total events required to be reported to the NRC.

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facters then were weighed by taking into cecount such things ts the severity of the items of noncompliance and the amount of staff inspection time required to identify individual items of nonccmpliance.

Under the statistictl method, reactors or sites were icentified as being in one of three troups - A, B,,

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2.

The " trend c.Islysis method," based on a detailed review of ' vents e

which licensees are required to report to the NRC.

An effort then was made to identify trends, repetit.ive problems, or those linked to si:ilar causes.

3.

The " regional survey method," which collected expressions of opinion of facilities by NP.C inspectors and regionel management.

For the trial effort, NRC ficld inspector personnel were esked to express themselves on c scale, from ecccptable to exceptional, about fcctors concerning operating reactors, i

The Sttff ? aper, SE;Y-70-554 and its. enclosure including the reports describing the appretches tried by the NRC staff, are enclosed.

inese cocum:nts tre being sent to each licensee whose fccility is mentioned in the p;pr or repcrts and to other individuais expressing an interest in th o -u.;t e r.

Copier, also, have been p1Leed in the URC's Public Documsn't F.:cr.,1717 H Street, N.W., Washington, D.C., end the Commission's Regional CMices--031 Park /. venue, King o f Prussia, Pennsyivania; Suite 3100, 101 l'.t :etta Street, Atlanta, Georgia; 799 Roosevelt Rotd, G'.cn Eilyn, 'llir.;is ; Suite 1000, Gli Ryan Plaza Drive, Arlington, Texas; and Suitt 102,1W 0 North California Bouleverd, Walnut Creek, California.

I Sincerely, Enclosur. :

USMRC Pniity Sestica ? tem, SECY-70-CE', dtd ' 0/:.6/78, v/encls.

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October 25, 1978 SECY-78-554 UNITED ST ATFS NUCLEAR REGULATORY Co r.*.Mf S$loN POLICY SESSION ITEM For:

The Comiissioners D.EJ

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From:

John G. Davis, Acting Director y.

Office of Inspection and Enforcement 4Q,v ;[

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Thru:

Executive Director for Operations /^ p.d4' LICENSEE REGULATORY PERF0k!lMCE EVALUATION

Subject:

cc Purcose:

The purpose of this paper is to infom the Commission regarding the status of efforts by the Office of Inspec-tion and Enforcement in licensee regulatory performann t

evaluation and to obtain Commission approval of a two year trial program, p'

Discussien:

IE has beec, working to develop techttiques for evaluating

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the regulatory perfomance of NRC licensees for several years, with intensified effort over the last two years.

" Regulatory perfomance," is meant to convey the ability of the licensee to meet regulatory requirements and to avoid reportable events that appear to be directly under the control of the liceri:ee.

" Regulatory perfomance" does not involve reliability, availability, earnings, or Other measures which may be used to wasure perfomance.

Licensee Regulatory Perfomance Evaluation (LRPE) is the effort to evaluate the regulatory performance of licensees or. a national basis.

It has as its objectives:

Identification of factors that lead to different levels of regulatory perfomance.

,, Effective and efficient use of NRC inspection resources.

Information from the evaluation process also can be used to evaluate aspects of the NRC inspection program.

Contact:

DUPLICATE DOCUMENT H. D. Thornburg, RCI 49-28484 Entire document previously entered into system under:

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CNNACDw RIEGLE, JR.

,6u e m o u 3 TnifcD M la{cs M en G[0 I J WAbHINGTON, D.C. 20510 June 14, 1979

: s Chairman Joseph M.

Hendrie Nuclear Regulatory Commission 1717 H Street h'W Washington, D.C.

20555

Dear Mr. Chairman:

As you know, there are currently three operating nuclear power plants in Michigan.

In addition five other units are under construction and planned for operation between 1980 and 1991.

Operating plants include Big Rock Point I, Cook I and II and Palisades.

Plants under construction include Enrico Fermi II and Midland I and II.

Greenwood II and III are planned.

The future use of nuclear power in Michigan has become an extremely sensitive and controversial issue.

To become better informed on the issue I would appreciate your having your staff prepare for me a summary of the ihinterv of nuclear de"elopment in Michiaan -- including cost information, feculatorv vi ol at i qns, and d_ata concernina electricity cenerated compared to plant capacitr.

More particularly, I am concerned with obtaining specific responses to the following questions:

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1. What are the _ current problem areas with respect to nuclear energy in Michigan?

Please, at a minimum, identify problems with plants, 2.

What additional problems do you foresee in the immediate q

future (1-10 years) in Michigan?

3.

I am told that the Nuclear Pegulatory Commission has IE cited Michigan as being among the ubrst states in terms of regulatory compliance and that within the past three years, 217 citations have been issued for safety violations, infractions and deficiencies.

Is this an accurate portraval of the situation in Michigan?

Can you conrirra Tnese statistics?

l TE 4.

To what extent is Michigan's experience different from that of other states?

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5.

With escalating nuclear construction costs and the need

" ' ;N'gg to include the costs of waste disposal and plantdecommissioning,

..o is nuclear power currently cost effective in Michigan?

What are your g gtions for the fut,ure?

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f Chairmn Jost ph M. HEWrie June 14, 1975 Page two 6.

What plac 2ny, presently exist for the long term ilyd5 storage of nuclear wastes?

When will a system be available for E

commercial use?

Have adequate measures been taken to insure against the release of radioactive materials during their storage or t.'4sportation?

p NRR 7.

Do current Conmission regulations adequately insure O

that radioactive mate-4 n1 rnn*ained in a nuclear _ reactor will E

n.ot enter the outside environment?

lYSA/tfR 8.

Do you believe that e_lectricity demand will grow fast enough to justify large-scale commitments to nuclear power --

first, in the State of Michigan?

Second, in the country 33 at large?

(A9A 9.

Do you personally believe that tne benefits of nuclear power outweigh the doub's abcut its safety and community fears?

My staff is presently looking into each of these questions.

Obviously, we have neither the requisite expertise nor the time to sif t through the stacks of technical materials which I am sure are available Lith respect to the specific nuclear plants in Michigan.

Therefore, I would appreciate your supplying me with information that is at the same time concise, accurate, readily understandable and responsive to my concerns and questions.

j L

,m. _

I appreciate your expeditious attention to this matter.

"=

Sincer ly, l

b w D,.ald W.

Riegle, J.

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