ML20034F884
| ML20034F884 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/03/1992 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Selin I, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20034F863 | List: |
| References | |
| FOIA-92-539 NUDOCS 9303050144 | |
| Download: ML20034F884 (5) | |
Text
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August 3, 1992 l
MEMORANDUM FOR:
The Chairman FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
INSIDE N.R.C. ARTICLE REGARDING INDIVIDUAL PLANT EXAMINATION PROGRAM i
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I am responding to your concerns regarding the INSIDE N.R.C. article "As IPE i
Program Moves into High Gear, Agency Uses of Submittals Uncertain," dated July 25,1992.
i This article cites several comments or examples to support the contention that the IPE program was not well thought through. However, it appears that the reporter does not understand fully the IPE review process. The staff has addressed those issues raised by this article in the enclosure to this memorandum.
I trust this responds to your concerns.
Original Signed By hmes M. Taylor James M. Taylor Executive Director for Operations
Enclosure:
As stated cc:
Commissioner Rogers Commissioner Curtiss Commissioner Remick Commissioner de Planque SECY OPA
- See previous concurrence OFFICE: DSIR/SAIB*: DD/DSIR*: D/DSIR*
- DREP/NRR*: DD/RES*: D/RES:
j NAME : CAder
- TKing
- WMinners : FCongel
- TSpeis :
EBeckjord DATE :
7/30/92
- 7/30/92 : 7/30/92 : 7/30/92 : 7/31/92: 7/ /92 OFFICE:
JqTaylor E
/
NAME:
DATE:
t&/13/92 DOC NAME:g:inside.NRC 9303050144 921218 PDR FOIA
/
WILLIAM 92-359 PDR s ( /-
g' ENCLOSURE In the July 27, 1992 issue of INSIDE N.R.C, an article entitled "As IPE Program Moves into High Gear, Agency Uses of Submittals Uncertain," raised several concerns with regard to the IPE program.
In sumary, the article appears to characterize the IPE program as not well thought through, with unpredictable results, and with " apparent schizophrenia inside the agency about how to treat IPEs - about mandating information without really resolving how it would be treated." Each of these concerns is addressed below.
1.
The author apparently has reached the cor,clusion, based both on NRC staff communications and comments and induatry comments, that the agency does not have a well thought through approach to reviewing IPE submittals.
From the beginning, it was believed that the prime beneficiaries of the IPE process would be the licensees. Partly as a result of this belief and as a result of resource considerations, the staff review of the IPE always was intended to be a limited or high-level review of the licensee's program. A discussion of the staff's review process (Attachment A) was included as an appendix to NUREG-1335, " Individual Plant Examination Submittal Guidance,"
dated August 1989.
Similar discussions of the review process were included in SECY-90-180, " Status of Implementation Plan for Closure of Severe Accident Issues and Status of the Individual Plant Examinations (IPE)," dated May 18, 1990 and, more recently, in SECY-92-151, " Issuance of the Staff's Evaluation Report on the Seabrook Individual Plant Examination Submittal," dated April 24, 1992 (Attachment B). Although the review process has undergone minor adjustments based on staff experience with the initial reviews, fundamentally it has not changed from that discussed in NUREG-1335.
2.
The " treatment" of New York Power Authority is presented as an example of the unpredictable results of the IPE program.
The statement of the unpredictability of the IPE process appears to be based on a misunderstanding of the roles of NRR and RES in the reviews of the IPE.
The article seems to question why NRR asked NYPA to re-evaluate its IPE results when RES has the lead responsibility for the IPE review.
Although RES does have the lead role for review of the IPE submittals, all correspondence with licensees is transmitted by NRR. Therefore, any questions transmitted to a licensee concerning IPE results will be sent by NRR.
Furthermore, the author is confusing a request for information sent to NYPA on February 6, 1992 with a subsequent request sent on May 20, 1992.
In February, the staff requested NYPA to re-evaluate its IPE results in light of the recent diagnostic evaluation team (DET) report.
There was some discussion at the time whether this request should have been delayed until the IPE review team had developed the remainder of its questions regarding the IPE submittal.
However, in view of the concerns raised by the DET, it was believed that an early request was appropriate.
In May, the staff sent NYPA additional questions which were the result of the ongoing review of the FitzPatrick IPE submittal.
The staff considers the FitzPatrick IPE/DET situation unique and is committed to minimizing the number of separate requests made to licensees regarding
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their IPEs. However, staff does not believe it is an example of an unpredictable process.
3.
The article mentions " apparent schizophrenia inside the agency about how to treat IPEs," citing questions raised about the meaning of NRC's staff evaluation report (SER) and AE00 involvement in the IPE program.
First, with regard to the meaning of the SER, the focus of the review of a licensee's IPE submittal is on assessing the quality of the licensee's IPE process with respect to the potential for meeting the objectives of the IPE.
Upon completion of its review, RES documents its conclusions in a draft SER, which it forwards to NRR for transmittal to the licensee. Accordingly, the primary conclusion of the SER is whether the licensee's process appears acceptable and is, therefore, capable of meeting the objectives of Generic 1
Letter 88-20. This intent was discussed in NUREG-1335 in 1989 and has not changed.
Because the IPE review is not an in-depth review, the SER does not conclude that the detailed findings are correct. However, if weaknesses in the IPE are noted or there is disagreement with certain of the licensee's assumptions, these areas are noted in the SER.
In addition, if the staff determines that additional modifications appear to be warranted, it will follow the procedure required by the backfit rule,10 CFR 50.109. The staff i
does believe that a licensee with an acceptable IPE can use it in support of future actions. However, such actions are likely to require a more in depth review. The need for such a review will be determined on a case-by-case basis.
1 Secondly, the author of the article misunderstands the involvement of AE00 in the IPE program. AEOD is in the process of updating and improving the Accident Sequence Precursor (ASP) models and methods.
In support of this effort, AEOD has requested RES assistance in obtaining information available from the IPE submittals.
RES is currently working with AEOD in response to j
this request. However, due to different approaches to performing an IPE and different levels of detail contained in IPE submittals, not all information 4
desired by AE00 will be available.
This is not a result of the lack of detailed review by the staff, as implied by the article, but is a result of the NRC's actions to minimize the regulatory impact on licensees.
Because the purpose of the IPE program is to identify severe accident vulnerabilities that might be missed absent a plant j
specific examination, the information requested from licensees was limited to that needed for the staff to determine if this intent was met.
The AE00 request is an example of an additional benefit of the IPE program and is not an example of " schizophrenia" about how to treat IPEs. Another example of the benefit of the IPE program is the use of the insights gained to assess the effectiveness of various regulatory requirements.
It is expected that the IPEs will have a number of additional benefits beyond that of their original purpose.
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Attachment A o
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i, (Staff Review Guidance, Appendix D to NUREG-1335)
In this appendix,.the procedure by which the staff will review the IPE submittals is discussed.
The purpose of the staff review is to determine whether or not the IPE process was adequate to meet the four specific objectives listed in Section 1.1.
If it l
has been determined that the process has met the objectives, the presumption will be that the examination of the plant has met the expectations of the l
Severe Accident Policy Statement.
In general, the staff is expected to perform an audit review of each submittal.
The staff plans to review IPE submittals on a team rather than an individual basis and expects to use contractor personnel as part of each team.
- However, the staff will not in general make an independent assessment to the depth required for agreement with the detailed findings.
The review process will fall roughly into two phases.
First, the staff will determine the completeness and adequacy of the documentation as submitted by the utility.
This should be examination of the documentation to see that the requested level of detail has been provided for all subjects listed in Table 2.1.
Second, the staff will conduct a review of the content of the submittal, concentrating on event trees, system interactions and dependencies, failure modes, and treatment of containment function failure.and radioactive material releases.
This review constitutes a high-level sampling of the IPE.
It is expected that specific fault trees will be requested by the staff during the review, the specific fault trees to be determined on a case-by-case basis.
Questions directed to and meetings with individual licensees in order to clarify details of and discuss the examination process are to be expected.
The staff will review the options considered by the utility for plant imorovements, including whether there are less costly alternatives if a utility found that there were no cost-effective options and whether there are any attendant risks associated with the proposed modifications.
Further, the staff will review the list of vulnerabilities and the functional or' systemic sequences selected under the screening criteria to obtain reasonable assurance that the licensee has made valid use of the insights concerning the plant.
An IPE Evaluation Report will be prepared documenting, in the same format as given in Table 2.1 for the utility's submittal, the staff review process and conclusions relative to the objectives in Section 1.1.
From time to time, the staff may find it necessary to perform a more detailed review or audit.
The staff will determine the level of depth to which the detailed review should proceed, including independent assessment of parts of the IPE.
It is likely that at least part of the documentation retained by the
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utility would have to be reviewed by the staf f to accoumodate the in-depth review.
Attachment B 5,
(Enclosure 2 to SECY-92-151)
THE STAFF'S REVIEV PROCESS FOR INDIVIDUAL PLANT EXAMINATION REPORTS The staff established a two-step review process in February 1990 to review the Individual Plant Examination (IPE) reports submitted to the NRC in response to Generic Letter 88-20, Supplement 1.
Using this approach, the staff will perform a relatively short Step 1 review of each IPE submitted to (1) determine whether or not the licensee's IPE process met the intent of Generic Letter 88-20, and (2) store important IPE insights and findings in a database for future use. The staff will perform a more detailed Step 2 review on only selected IPE submittals. The IPEs selected for a Step 2 review are normally those for (1) plants with Step 1 review findings that appear inconsistent with the staff's Probabilistic Risk Assessment (PRA) experiences or expectations suggesting weaknesses in the applied methodology or the plant's operational characteristics, or (2) plants with unique characteristics that are not well understood.
The staff will perform a "scrutability check" on each IPE submittal from licensees that have a PRA and submitted it for NRC review. This check would include the formulation of written questions (or requests for additional information) to be sent to and answered by the licensee. The staff normally meets at least once with'these licensees to discuss the responses to the l
questions, their approach to the IPE process, and. any actual or potential outliers identified in the process. The Step 1 review, because it is short and does not delve into many details, is intended tar determine whether or not the licensee's IPE process was capable of identifying significant core damage vulnerabilities. The staff will conduct the medium scop.e Step 2 review, when warranted, to examine the methodology, assumptions, and database used by the l
licensee and to reach a more substantive conclusion about the licensee's IPE A Step 2 review includes a site visit by the team to discuss the IPE process.
with the licensee, review tier 2 documents, and conduct walkdown inspections as appropriate.
In cases where licensees choose to use their IPE in support of proposed future actions or changes to their licensing basis (e.g., in connection with Technical Specification changes, integrated safety assessment, license renewal programs, etc.), the staff may find it necessary to reach beyond the depth of the Step 2 level of review. However, this is a case-by-case judgement that would need to be determined at the time such licensee proposals are made.
To date, the only plant selected for a Step 2 review has been the Turkey Point Station. The staff performed a more detailed review of Turkey Point because the licensee had not previously performed a PRA for the plant.
In November 1991, five NRC personnel and three consultants conducted a site visit. The
,taff expects to complete the review of Turkey Point in April 1992.
The staff is also reviewing IPEs for Hillstone 3, Oconee, FitzPatrick, Surry, McGuire, and Susquehanna and expects to receive a majority of the IPE submittals in FY 1992 (See Enclosure 3 projections).
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