ML20134Q052
| ML20134Q052 | |
| Person / Time | |
|---|---|
| Issue date: | 02/21/1997 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-2093, NUDOCS 9702260228 | |
| Download: ML20134Q052 (401) | |
Text
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Officirl Trcnscript cf Praccedings O NUCLEAR REGULATORY COMMISSION FGRs7~ 2693
Title:
Advisory Committee on Reactor Safeguards Probabilistic Risk Assessment Subcommittee
'l 3 TRO4 (ACRS)
RETURN ORIGINAL Docket Number: (not applicable). TO sawaITE ,
M/S T-2E26 '
415-7130 THANKS!
Location: Rockville, Maryland U oate: Friday, February 21,1997 A1RStie00py. ass- l
~0r':'e fe Oh6 30~f'It:0E Work Order No.: NRC-1018 Pages 356-707 l
NEAL R. GROSS AND CO., INC. !
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i DISCLAIMER PUBLIC NOTICE I BY THE l UNITED STATES NUCLEAR REGULATORY COMMISSION'S !
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS !
FEBRUARY 21, 1996 l
The contents of this transcript of the i
proceedings of the United States Nuclear Regulatory f Commission's Advisory Committee on Reactor Safeguards on FEBRUARY 21, 1996,.as reported herein, is a record of the f t
discussions recorded at the meeting held on the above date. ;
\ This transcript has not been reviewed, corrected i
and edited and it may contain inaccuracies.
l 1
e a
hTAL R. GROSS COURTREPORTERS ANDTRANSCRIBERS I323 R1IODEISLAND A\T.NUE,NW (202)234 443' WASl[ING1DN,D.C. 20005 (202)234-4433 i
356 i
1 UNITED STATES OF AMERICA l
,q
, 2 NUCLEAR REGULATORY COMMISSION O 3 +++++
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 PROBABILISTIC RISK ASSESSMENT SUBCOMMITTEE 6 +++++
7 FRIDAY 8 FEBRUARY 21, 1997 9 +++++
10 ROCKVILLE, MARYLAND 11 +++++
12 The Subcommittee met at the Nuclear Regulatory 13 Commission, Two White Flint North, Room T2B3, 11545 14 Rockville Pike, at 8:30 a.m., George Apostolakis, 15 Chairman, presiding.
16 MEMBERS PRESENT:
17 GEORGE E. APOSTOLAKIS, CHAIRMAN 18 JOHN J. BARTON, MEMBER 19 IVAN CATTON, MEMBER 20 MARIO H. FONTANA, MEMBER 21 THOMAS S. KRESS, MEMBER 22 DANA A. POWERS, MEMBER 23 ROBERT L. SEALE, MEMBER 24 WILLIAM J. SHACK, MEMBER O DON MILLER, MEMBER N.j 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 2344433 WASHINGTON, D C. 20005-3701 (202) 234-4433
I 357 1 ACRS STAFF PRESENT:
,r w 2 JOHN T. LARKINS, EXECUTIVE DIRECTOR J
3 MICHAEL T. MARKLEY 4 SAM DURAISWAMY 5 AMARJIT SINGH 6
7 ACRS FELLOW PRESENT:
8 RICK SHERRY
, 9 10 ACRS CONSULTANTS PRESENT:
11 EDWARD ABBOTT 12 JAMES CARROLL 13 ALSO PRESENT:
A 14 ROY WOODS 15 GARY HOLAHAN 16 STEPHEN DINSMORE 17 BOB JONES 18 TOM KING 19 ROBERT GRAMM 20 RICK GRANTOM 21 LAWRENCE MARTIN 22 GARETH PARRY 23 SUZY BLACK 24 BIFF BRADLEY 25 ADRIAN HEYMER NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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358 1 A-G-E-N-D-A
,S 2 Acenda Item Pace 3 Reconvene Subcommittee - review past 4 deliberations & objectives for this 5 meeting 359 6 Discussion of RG & Pilot for GQA 361 7 Pilot plant perspectives - GQA (South Texas 8 Project) 452 9 General discussion of issues; items to resolve 514 10 LERF & CDF 11 Defense-in-depth 12 Safety margins 13 Temporary changes
< s i i V 14 Expert panels / peer reviews i 15 Follow-uo and discussion of issues for full 16 ACRS review 605 17 18 19 20 21 22 23 24
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359 1 P-R-O-C-E-E-D-I-N-G-S 2 (8:34 a.m.)
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3 CHAIRMAN APOSTOLAKIS: The meeting will now 1 I
4 come to order. This is the second day of the meeting of 5 the ACRS Subcommittee on Probabilistic Risk Assessment.
6 I am George Apostolakis, Chairman of the 7 Subcommittee.
8 ACRS Members in attendance are John Barton, l 9 Ivan Catton, Mario Fontana, Thomas Kress, Don Miller, Dana 10 Powers, Robert Seale and William Shack. :
11 We also have in attendance Jay Carroll and Ed 12 Abbott who are here as consultants to the Subcommittee.
13 ACRS senior fellow in attendance is Richard eb'i
\- / 14 Sherry.
15 The purpose of this meeting is to continue our 16 discussion of the NRC staff's approach to codify risk-17 informed and perfc: ince-based regulation through 18 development of the Standard Review Plan Sections and 19 associated Regulatory Guides.
20 As a subcommittee, we'll gather information, 21 analyze relevant issues and facts and formulate proposed 22 positions and actions, as appropriate, for deliberation by 23 the full Committee.
24 Michael T. Markley is the cognizant ACRS staff n
k ,) 25 engineer for this meeting.
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360 1 The rules for participation in today's meeting 2 have been announced as part of the notice of this meeting, f-'S O 3 previously published in the Federal Reaister on February 4 5, 1997.
5 A transcript of the meeting is being kept and 6 will be made available as stated in the Federal Reaister 7 notice.
8 It is requested that the speakers first 9 identify themselves and speak with sufficient clarity and 10 volume so that they can be readily heard.
11 We have received no written comments or 12 requests for time to make oral statements from members of 13 the public.
k' '} 14 We have Mr. Rick Grantom and Lawrence Martin 15 of Houston Lighting and Power Company, South Texas Project 16 to make a presentation on pilot plant perspectives 17 regarding graded quality assurance.
18 Mr. Biff Bradley of the Nuclear Energy l
19 Institute and Doug True of ERIN Engineering will not, i 20 however, be making a presentation today regarding large 21 early release frequency.
22 We will proceed with the meeting and I call 23 upon Mr. Roy Woods from the Office of Research and Mr.
l 24 Robert Gramm from the Office of Nuclear Regulation to l
' j gx)
\ 25 begin. Why did we leave Mr. Dinsmore out? I call upon NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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361 1 him too.
2 (Laughter.)
U Could I interrupt for just a 3 MEMBER SEALE:
4 moment?
5 CHAIRMAN APOSTOLAKIS: Yes.
6 MEMBER SEALE: I'd like to remind the Members 7 of the Committee that you all have an obligation today at 8 lunch time to interview people as you did yesterday.
9 You've got a schedule and a resume, I believe.
10 CHAIRMAN APOSTOLAKIS: Okay.
11 MR. GRAMM: Good morning. My name is Bob 12 Gramm. I'm the team leader from NRR for GCA and with me
,_ 13 here today is Stephen Dinsmore from the PRA branch in NRR
( )
14 as well as Roy Woods, who is the co-team leader from 15 Research.
16 We've had the opportunity to brief you on 17 three prior occasions on graded QA in the fall of 1995, 18 April of 1996 and most recently, in November of 1996. And 19 again, for background purposes, the genesis of this 20 program is identified and encapsulated to a great degree 21 in a SECY paper we provided you before which had four 22 essential ingredients and we're trying to capture those 23 thoughts in the Regulatory Guide that's been developed by 24 the staff over the previous months.
O V 25 The Regulatory Guide for GQA follows the four NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 1
362 1 essential elements that are laid out in the master
,, ~s 2 document. The reg. guide has not changed appreciably from t i
\/
3 the version we showed you in November, so we would like to 4 move quickly through the four essential elements and then 5 focus on the differences as well as the pilot program, if 6 that's acceptable to you folks.
7 MR. DINSMORE: Yes, this is Stephen Dinsmore.
8 I got here faster than I thought. This is the element 2.
9 This is very similar to what we presented last time and it 10 gives an overview of how the staff currently thinks that 11 the process should proceed, to develop the high and low 12 safety significant categories. Just real quick, you 13 identify system functions. You categorize the safety
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\/ ~ 14 significance of these functions. You identify the SSCs 15 that support, in particular, the high safety significant )
16 functions and then you categorize the SSCs that support 17 those functions.
18 The only change to this is we used to call at 19 this level, at the working group level we used to call 20 this risk importance. There was some discussion about 21 introducing new terminology, so now we've taking the risk 22 importance out and you won't see it again, but we call it 23 safety significance all the way through.
24 Now a little later, at the end of this (7- ) 25 presentation, I'm going to go through very quickly what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 363 ,
1 1 each of the pilot plants, our interpretation of the 7s 2 current pilot plant processes within this framework.
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- 3 And this is the second part of the engineering 4 evaluation which is the-conformance with safety 5 principles. We have this in here mainly to make sure that 6 we're conforming to the general reg. guide.
7 The only thing unsaid here is these two -- the 8 third and fourth one, individual plant risk does not 9 exceed change guidelines and only small increases in plant 10 risk are acceptable. We do a little differently, mostly 11 by first, being very careful about what we're going to 12 classify as high and low and only changing the 13 programmatic activities on what we consider low safety p
5 .-)
m 14 significance and through that process, we hope to insure 15 that these -- the third and the fourth bullet are 16 fulfilled.
17 CHAIRMAN APOSTOLAKIS: Again, as I said 18 yesterday, the words defense-in-depth is maintained really 19 and doesn't do much for me.
20 I was corrected yesterday that the actual reg.
21 guide doesn't say that, but this one does. On page 5, it 22 says defense-in-depth is maintained. We want the concept j 23 to be maintained, the principle.
24 MR. DINSMORE: Right.
(m The same with safety CHAIRMAN APOSTOLAKIS:
(v) 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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t l 364 1 margins.
,s 2 MEMBER POWERS: Is there really any change in
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l 3 plant risk associated with changes in the quality 1
4 assurance program?
l 5 MR. DINSMORE: If you would -- well, hopefully i 6 the' quality assurance program is contributing to the l 7 safety of the plants and if you reduce it one could e believe that the reliability of the components for which ,
l 9 it's been reduced would increase to some unknown extent at i
10 this time.
11 MEMBER POWERS: I mean I think that's the ;
12 operative thing. There's no mechanism in PRA with which 13 I'm familiar to translate a change in the QA program and a
(
\ ') 14 change in the reliability of values that go into the PRA 15 is there?
16 MR. DINSMORE: No, that's right. That's why 17 we don't try to do it. We talked to this Sergio --
18 CHAIRMAN APOSTOLAKIS: Oh, you did talk to Dr.
19 Guarro.
20 MR. DINSMORE: Guarro. And he indicated that 21 he took a look and his biggest problem was that the plants 22 were using QA equipment for non-QA purposes, so he was 23 saying it's hard to get reliability information on the QA l
l 24 equipment.
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(,) 25 CHAIRMAN APOSTOLAKIS: Can you tell the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) 2344433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
365 1 Committee what the -- I know what he did, but -- brief the f- w 2 Committee on what that issue was.
(v) 3 MR. DINSMORE: Well, the question was if therc 4 was any known relationship between the reliability of 5 equipment and the QA programs supplied to it and there was 6 a gentleman, Dr. Guarro, who took a look at it, excuse me, 7 a couple of years ago and I called him up and asked him 8 what the conclusions were and his conclusions were that 9 since the plant or the two plants which he looked at 10 tended to use a lot of their QA equipment for non-QA uses, 11 just because it was administratively easier there wasn't 12 going to be a lot of data available on non-QA equipment.
13 And his second. conclusion was was that maybe e i U' 14 it would be possible to eventually do it, but it's not an 15 easy thing to do. It would take a long time to have to go 16 out and really go through plant data and try to develop .
I 17 some type of relationship.
18 So that's where we stand with that 19 relationship now.
20 MEMBER POWERS: So it seems to me that the 21 first four elements on this slide really are -- they're 22 applicable to the graded QA, but they're just not 23 operative. They just don't make any difference once way or 24 another.
n i i
() 25 MR. DINSMORE: Well, the very last slide in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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366 1 the handout, I think, has a couple of things on it which r~N 2 we went through the material submitted to us by the Q,
3 licensees and tried to interpret what they submitted 1
4 within the framework which we have here and I forget where j l
5 CCFs is, if it's on a defense-in-depth or safety margins.
6 I'm not quite sure. But one of the plants specifically 7 says it won't mix high and low safety significance for 8 nominally identical items that are used. In other words, 9 if you had a pump here that was high and you had the same ;
1 10 pump here that was low, it wouldn't try to mix those in i
11 order to avoid the CCF possibility. So there is some type l 12 of -- you can do some interpretation and try to bring it p 13 back in.
/ \
/ 14 MR. GRAMM: If I could also respond to that j 15 particular question. On page 4-10, I'm sorry, 4-11 and 4-16 12, of the draft reg. guide, we have a series of bullets, 17 qualitative arguments as to why in the graded QA 18 environment we believe defense-in-depth and safety margins 19 will be maintained and again, plant configuration is not 20 being changed during this process. The low safety 21 significant components will still have a quality assurance 22 program that meets Appendix B applied to them, so they're 23 not falling off the edge of a cliff and having no QA.
24 We believe the design requirements will be
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367 1 CHAIRMAN APOSTOLAKIS: Regarding defense-in-
, 2 depth, I'm looking at the draft SRP chapter 19 revision J t 4 s
3 which was sent to us some time ago and there is a sentence 4 here that is sort of cryptic. "Provided that the PRA is 5 technically sound, the minimal cut sets therefore show the 6 effective redundancy and diversity of the plant design."
7 Page 9.
8 What does that mean? Okay, they do, but why 1 l
9 is it here? Is it a hint for the reviewer to start saying ,
l 10 that you have too many minimal cut sets with two l l
11 components? I want to see three? I hope not.
12 MR. DINSMORE: Well, that sentence started 13 out, as I recall, that we were going to ask them at one q
l i kJ 14 point to go through the cut sets and make sure it was at 15 least --
16 CHAIRMAN APOSTOLAKIS: Right, that's why I 17 raised the issue. There were several paragraphs following 18 this.
19 MR. DINSMORE: It's been through several 20 revisions and I'm not quite sure whether --
21 CHAIRMAN APOSTOLAKIS: I don't know. Okay, 22 this is correct. Yes. You have redundancy. You see that 23 in the minimal cut sets, but I hope there's no message 24 here that you should try to have as many events as you can n) 25 in the minimal cut sets, because that was the earlier NEAL R. GROSS .
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368 1 version, that they should check for two event cut sets, i
,. 2 three event cut sets and I understand it was killed by t I
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3 higher powers.
4 MR. DINSMORE: I don't think the intent was to 5 make sure you had more elements in the cut set. The 6 initial attempt which is no longer with us, is to make 7 sure you had at least one high.
8 CHAIRMAN APOSTOLAKIS: The whole paragraph 9 beginning on page 8 talks about it, at the bottom of page 10 8. "The cut sets, therefore, directly show one particular j 11 aspect of defense-in-depth in that they reveal how many j 12 failures must occur in order for the top event to occur."
13 And then you know, the minimal cut sets show the effective O
k-- 14 redundance. I mean is that for information only? I don't 15 know how to read that.
16 MR. HOLAHAN: Well I -- this is Gary Holahan.
17 I read it to say that this idea that we talked to the 18 Committee about before that you can use PRA insights to 19 address defense-in-depth and safety margin and these other 20 concepts, it's reminding the reviewer how you can answer 21 these other bullets on the slide, not just the risk 22 numbers, that you can use insights from the PRA to support 23 the fact that defense-in-depth is being maintained.
24 CHAIRMAN APOSTOLAKIS: Yes. Of course --
(o) x_/
25 MR. HOLAHAN: We took out the details because NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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369 1 --
l n 2 CHAIRMAN APOSTOLAKIS: Yes, I know.
1 MR. HOLAHAN: In effect, what we started to do
, 3 4 was develop two sets of rules.
5 CHAIRMAN APOS'IOLAKIS : Yes.
6 MR. HOLAHAN: And I think that was too much.
7 CHAIRMAN APOSTOLAKIS: And that's why I'm 8 bringing this up to make sure that we don't have a second 9 set of rules.
10 But even the statement here that most minimal 11 cut sets, in fact, do show how redundant your system is, 12 but the moment you start introducing common cause 13 failures, you may have minimal cut sets that have one or (3
U 14 two elements, one of which is a common cause failure of 15 four components.
16 I mean, so you have to really be careful there 17 not to say boy, this is only two events. I have to do 18 something about it because one of the events presumably is 19 very low probability occurrence because it represents the 20 simultaneous failure of several items. So it's not quite 21 right what it says here, although I understand the spirit 22 of it which is correct.
23 Then the three paragraphs following this on 1
j 24 page 9 --
fy
) 25 MR. WOODS: We have a slightly later version.
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370 1 CHAIRMAN APOSTOLAKIS: We do.
l
,s 2 MR. WOODS: I cant find where you are. I k~, i 3 CHAIRMAN APOSTOLAKIS: It's the January 16th--
l 4 MR. WOODS: We keep a running version and I 5 didn't happen to bring the one that you have. ;
6 CHAIRMAN APOSTOLAKIS: This is the draft SRP l 7 chapter 19. ,
l 8 MR. WOODS: We have that, but it's a later !
l 9 version I have here. )
10 MEMBER SHACK: You changed it again. )
11 MR. WOODS: Well, we change it daily. I'm !
I 12 sorry. I don't know how to handle this problem. I would j l
13 like to find out what your -- l
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14 MR. CARROLL: Why don't we give them a copy.
15 MR. DINSMORE.: I guess we're kind of uncertain ,
l 16 as to why we're going through the general SRP.
l 17 CHAIRMAN APOSTOLAKIS: This is quality i 18 assurance and defense-in-depth.
19 MR. GRAMM: We do not have an SRP generated 20 for GQA.
21 CHAIRMAN APOSTOLAKIS: This is not yours?
22 MR. GRAMM- And we are not the authors of the 23 general document.
l 24 MEMBER CATTON: No wonder they're so alert.
(%
. () 25 CHAIRMAN APOSTOLAKIS: All right, they have a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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3711 I 1 reg. guide, but they think that stuff is repeated. I 73 2 MR. WOODS: The reason there's no SRP, of
( )
3 course, is because many GQA programs won't get reviewed by )
4 the staff and it will be done by an inspection or whatever 5 on the site and it will be done with an inspection l
6 procedure, but we didn't feel we needed an SRP for this 7 topic. i 8 CHAIRMAN APOSTOLAKIS: That's why you seem to 9 be puzzled, Stephen. You were wondering why I'm asking 10 these questions. j 11 MR. WOODS: Well, I'm looking in the general 12 SRP, that's all we have that would be appropriate for 13 this.
\2 14 CHAIRMAN APOSTOLAKIS: Okay, but you do have 15 something here on defense-in-depth, I remember?
16 MR. DINSMORE: Yes, as Bob mentioned, I think 17 it's the bottom of 4-11.
18 CHAIRMAN APOSTOLAKIS: 4-11. 4-11? How come 19 I don't have 4-11.
20 MEMBER SHACK: The draft QA reg. guide.
21 CHAIRMAN APOSTOLAKIS: Okay, there it is.
22 Well, why don't you go on and I'll catch up.
23 MR. GRAMM: Following the determination of the 24 relative safety categorization process completion, then OA im
( ,i
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/ 25 program elements ought to be 18 criterion are graded NEAL R. GROSS I COURT REPORTERS AND TRANGCRIBERS i
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372 l
l 1 according to weekly function, safety significance. We ,
l l 2 also describe the feedback programs and monitoring i !, ~h 3 processes because of the fact that it's very difficult to
! l l 4 predict in advance the effects of changing QA. We've l 5 placed reliance, of course, upon the corrective action l
6 program, nonconformance detection of issues and apparent I l
7 cause resolution of those and feeding back into the safety 8 significance categorization processes, as necessary.
1 9 We've addressed various types of documentation 10 that either needs to be maintained by the licensee at the 11 site and available, as Roy said, for inspection purposes.
12 some documentation would be appropriate for inclusion in 13 the QA program for the staff review and evaluation in
( !
x/ 14 advance of the program implementation.
15 That's described in section 6 of the 1
1 16 regulatory guide.
l l
17 Because we're on a relatively fast track with i 18 providing these, getting these ready for public issuance, 19 there's been parallel reviews and due to some recent 20 inter-office comments, there's going to be some changes to 21 the document and we're just telegraphing this in advance.
22 So your copy does not reflect these particular items.
23 The first is we have amplified on the need for 24 augmented quality treatment of nonsafety related equipment
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( ,) 25 that's found to be of high safety significance. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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373 t
1 document speaks to the general design criterion and we've l
l
,, 2 added some amplifying discussion about the inter-
/\
3 relationship between the safety categorization process and l
4 the inherent assumptions that are made even for the non-l l
5 safety equipment performance and therefore the reliance or 6 the need for additional QA treatment on those.
7 The second bullet addresses the fact because 8 of the importance of the monitoring process, we're going 9 to also explicitly articulate the need for QA controls on 10 that. It needs to be under a control process to insure 11 the integrity of the monitoring program. We're amplifying 12 on what level of detail needs to be included into the QA 13 program in terms of licensee commitments on describing the
/ \
r J
\__/ 14 process and various important assumptions that are made l
15 that will have a bearing on the staff's review and 1 16 evaluation that's performed.
17 We'd like now to shift and talk a bit about 18 the volunteer plant activities. This has been going on 19 since about the 1994 time frame. We've had a variety of 20 interactions with licensees ranging from meetings here at 21 headquarters, meetings at the site. We've had the 22 opportunity to observe the actual conduct of expert panels 23 and this has been very illuminating because if you receive t
l 24 a procedure it may be very dry in terms of the discussion l
()r~h t
25 on what's actually done and a first-hand observation of NEAL R. GFM)SS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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374 1 the conduct of these activities has been very beneficial l
,-- 2 to the staff and the licensees have been very open and i ;
3 candid with us and we've seen a lot of good, very 0 4 excellent technical discussions during the course of that.
5 We have recuived one QA program change that's 6 currently under review. Two of the licensees,this is the 7 interesting nuance for graded QA. Two licensees are 8 implementing graded QA process without a QA program 9 change, so there is no need for a formal staff review and 10 approval for two of the three pilot plants and this is one 11 of the reasons why we've foregone the development of an 12 SRP because depending upon the content of the QA program, 13 licensees may have the flexibility to do this without the
.r's
- 14 need for NRC review.
15 There's been --
16 MR. CARROLL: If that's the case, why is the 17 third one --
18 MR. GRAMM: The third licensee, South Texas, 19 in particular, has an extensive description. I believe the 20 proper characterization would be they want to greater 21 advantage of making changes for the low safety significant 22 items. The first two licensees are approaching on a very 23 limited function, Larry had just associated with j 24 procurement. South Texas is approaching it on a very (m
( 25 broad arena in terms of making adjustments ia multiple a l
4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 l 375 1 areas and they're looking at amending QA program l
g3 2 commitments to allow that opportunity. So they've
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3 invested, I think, a substantially greater amount of 4 resources in this and they've come in with a formal 5 application to take advantage of that.
6 MEMBER MILLER: So South Texas is basically 7 following the guideline then? :
8 MR. GRAMM. We'll address some of those 9 aspects. I can't say that they're following it 100 10 percent. There is a great deal of correlation between 11 what they're doing and the guideline and the staff is 12 taking advantage of lessons learned during the observation 13 process, so some of the things South Texas was doing, this
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\- 14 was one of the reasons for the pilot program to have that 15 included into the regulatory guidance, to take advantage 16 of the practical implementation. It's not a 100 percent 1
17 correlation, but it's a fairly high degree of correlation. l l
18 MEMBER MILLER: Are they also following NEI's 19 guideline? Or any kind of conbination?
20 MR. GRAMM: My opinion of the NEI guidance in 21 96-02 is that it is very general in nature. It addresses 22 an interrelationship of what was done under the 23 maintenance rule risk ranking in 92-01 and so I believe it 24 would be safe to say they are following the NEI guidance i
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( ,) 25 and perhaps Mr. Gramm and Martin, during their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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376 1 presentations can define that, but I believe that was 2 taken into account as Texas developed their program.
73 i ) I
~
3 MEMBER SEALE: Could I ask, yesterday we were l
4 told that the people from the industry, that is, that your 5 reg. guides have not been released yet in the IST area.
6 Is that also true here? ;
1 l
7 MR. GRAMM: Yes sir, that is true. I 8 MEMBER SEALE: So there's a diode here where 9 you're looking at their response, but they're not as yet i
10 able to read your interpretation of their experience, is I I
11 that correct? I i
l 12 MR. GRAMM: That would be a fair statement. '
7 13 However, in early 1996 we issued an evaluar. ion guide for 1
14 the graded QA plants to the industry for public comment 15 which indicated what areas the staff would be probing and 16 evaluating during the conduct of this program. !
17 And there is -- that evaluation guide was a i l
1 18 predecessor to the regulatory guide and we've issued a 19 string of requests for additional information which would 20 telegraph, I think, the staff's interest in particular 21 areas. So reading between the lines, the licensee could 22 determine what areas we're most interested in.
23 MEMBER MILLER: So if they took that document, 24 plus NEI, they'd be pretty close to what we're doing now?
O
(_,/ 25 MEMBER SEALE: Either that or complete NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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377 1 loggerheads, one or the other.
7-2 MR. DINSMORE: In the classification process,
. '# i 3 the two main differences that I'm aware of at this time 4 are in the reg. guide it talks about functional safety 5 significance and in the NEI guide I think it talks about 6 SSC. And the reg. guide kind of concentrates on I 7 functional safety significance and then would like to go 8 from that to the SSCs themselves. And we allow them to 9 determine functional safety significance based on the SSC 10 safety significance, but we'd like to know the safety 11 significance of the function and that's the first 12 difference.
13 The second difference is we'd like to have
(
(~)) 14 some aggregate calculations done on the impact of the 15 potential impact or some type of measure on the total 16 change, if you change something for all these low safety 17 significance at the same time.
18 In planning this, we'd like to go into their 19 PRA and take everything that they've classified as low and 20 raise the failure rates by a factor of 10, 20, 30 and we'd 21 like to see what's coming out the top as the CDF, just to 22 get an idea as to how much of the risk we're dealing with
, 23 here. If we're dealing with -- if they raise the failure 24 rates by 10, we get an increase in the CDF by 100, we rh i ,) 25 might think that this -- we should do a better selection l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
(
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378 1 of the lows. If they raise the failure rates by 100 and p .s 2 we get a CDF increase by 10, we might think that that's --
! )
3 MEMBER MILLER: Can you go the opposite way 4 then, take high significance, you go down?
5 MR. DINSMORE: Well, we have the same problem.
6 We don't -- they could try it. They could say that okay, 7 we're going to put these in high so let's go down by 10 8 for the nonsafety related ones which they're going to 9 increase the QA controls on, I guess you're asking.
10 MEMBER MILLER: Well, what about safety 11 related?
12 MR. DINSMORE: They wouldn't increase their 13 controls on safety related.
7 I 1
\_/ 14 MEMBER MILLER: Can you decrease the controls?
15 MR. DINSMORE: Well, that would be the low 16 safety significance. ,
1 17 MEMBER MILLER: Okay.
18 MR. DINSMORE: Safety related ones.
19 CHAIRMAN APOSTOLAKIS: Isn't the -- go ahead.
20 MEMBER SEALE: I was going to say, presumably 21 they've already figured that out. They've asked 22 themselves how do I confirm that this is indeed a high 23 safety significance item. I would assume you'd test it 24 with your PRA to see whether or not it did that.
- tO
() 25 MEMBER MILLER: The question is can you test NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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379 1 with the PRA going both ways.
r~s
\
2 CHAIRMAN APOSTOLAKIS: Test what? I'm lost.
(
)
\
3 MEMBER MILLER: I think what he's trying to 4 say --
5 MR. DINSMORE: Yeah, we want to get some idea 6 of the liabilities.
7 CHAIRMAN APOSTOLAKIS: You said that you will 8 change a failure rate and see what happens. I mean I 9 thought the idea of the importance measures was to 10 actually do that in a more rational way, rather than 11 changing individual inputs and see what happens to the 12 result. Fussell-Vesselly or risk achievement work and so 13 on, they are trying to do it in a more systematic way.
())
\m 14 So I would discourage you from taking failure l
15 rates and raising them by a factor of 10.
16 MR. DINSMORE: Okay, the importance measures 17 though, those address the importance of that component 18 given that all other components rank, maintain their same 19 failure rate.
20 CHAIRMAN APOSTOLAKIS: So you're going to 21 start changing now to a frequent component rank?
22 MR. DINSMORE: We can maybe take 50 percent of i
23 the safety related stuff and put it into low safety 24 significance. We're going to change controls on 50
/
(_,)g 25 percent of the stuff in the plant. And we'd like to know i NEAL R. GROSS l
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380 j 1 how much risk is involved in that 50 percent.
l f3 2 CHAIRMAN APOSTOLAKIS: I'm sorry -- l i
i
_J l 3 MR. DINSMORE: The only way that we knew how l l
4 to do that in a relatively straight forward manner would !
l 5 be just to do these type of sensitivity studies.
I 6 CHAIRMAN APOSTOLAKIS: I don't like i
7 sensitivity studies, okay? Because I think they are 8 abused and they're not done correctly most of the time.
9 MEMBER MILLER: That's kind of a broad l 10 statement. I don't understand.
11 CHAIRMAN APOSTOLAKIS: It was intended to be 12 broad. l l
13 (Laughter.) i r~'s I
!L-) 14 CHAIRMAN APOSTOLA.KIS: I've seen so many 15 things, especially many years ago, you know, boy look, if 16 I change this thing, if I multiply by a factor of 10, the i
17 result also goes up by a factor of 10. What are you going 18 to do? Faint? Yes, it goea up by a factor of 10. The 19 question is is it reasonable to change the input by a 20 factor of 10.
21 MEMBER MILLER: If it's changed by a factor of 22 10, it doesn't change at all.
23 CHAIRMAN APOSTOLAKIS: Well, then, but you see 24 that's the thing. It's like the old days, nuclear power 7-()_
25 will be so cheap that you will not even need a meter. In i NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS i 1323 RHODE ISLAND AVE., N W.
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381 1 turns out you needed a meter. So if you keep saying --
,m 2 MEMBER MILLER: I lost your train of thought.
( )
3 CHAIRMAN APOSTOLAKIS: I'll tell you what. As 4 long as you raise failure rates and you see the result is 5 insensitive, you're in good shape.
6 Problems begin when the result begins to be 7 sensitive. Then you're in a corner. Because now you have 8 argued that when I change something, I shouldn't see any 9 impact on the result, and now you're beginning to see an 10 impact.
11 What I'm saying is that the actual way of 12 doing it is to look at the actual change in the input that 13 you are trying and ask yourself how reasonable is that and
/ \
l !
v' 14 the failure rate goes up by a factor of 10. Now that's 15 one.
16 MEMBER MILLER: What you're saying is you just 17 don't want to arbitrarily --
18 CHAIRMAN APOSTOLAKIS: Exactly. Exactly.
19 MEMBER MILLER: I agree with that.
20 CHAIRMAN APOSTOIAKIS: I'm losing my train of 21 thought.
22 MR. DINSMORE: That was the idea.
23 CHAIRMAN APOSTOLAKIS: He's a former UCLA guy 24 so. He can take liberties. That explains a little.
,m.
5,
/ 25 MR. ABBOTT: Can I ask a --
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382 1 CHAIRMAN APOSTOLAKIS: One of the things
~s 2 that's missing from all these discussions. I'm sorry, Ed. :
/ \
j
\' ') 3 MR. ABBOTT: That's okay. You're in charge.
i 4 CHAIRMAN APOSTOLAKIS: Is the major accident !
5 sequences. I think there is a tendency not just in your i
6 document, but in all these documents that I reviewed, 7 there's a tendency to attack the problem from a i
8 mathematical point of view. In other words, how many j l
9 events are in the minimal cut set. Look at the importance l 10 measures. Make sure that the importance measures do this 11 and do that. The importance measures have these l
12 properties.
13 Then Steve today is telling us now I will I
<~x
(_)4 14 change lambda by a factor of 10 and see what happens to 15 the result. I would call that a strictly mathematical 16 approach, the sensitivity studies and so on. ,
l 17 What really matters, it seems to me is the.
18 major contributors, to risk, to system unavailability or 19 to whatever. And there is very little, if any, discussion 20 of these in any of the documents as I may be corrected.
21 MR. WOODS: Keep in mind here what -- the 22 reason he's gone to this functional categorization is 23 because you're searching for a way to categorize system 24 structures and components, SSCs that are not modeled in n
(v) 25 the PRA because you're talking here largely about stuff
! NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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363 1 that has little safety significance. That's why they're
, 2 interested in downgrading the QA controls and they're not 3 specifically modeled as that specific component in the 4 PRA.
5 So you have to try to capture that by looking 6 at the functions and then looking for the SSCs that 7 support those functions. A large fraction of this stuff 8 is not modeled so this discussion of changing the failure 9 rate or whatever and getting the answer out of the PRA is 10 sort of irrelevant.
11 CHAIRMAN APOSTOLAKIS: But that's what I was 12 addressing.
13 MR. WOODS: Yes, why --
i 4
(/ 14 CHAIRMAN APOSTOLAKIS: If you can change a 15 failure rate and see the impact, then everything I'm )
16 saying --
17 MR. WOODS: But you often can't, so you're ;
i 18 looking for another way. l l
l 19 CHAIRMAN APOSTOLAKIS: But if something is i l
20 outside, then what I'm saying also does not apply because 21 you don't have --
22 MR. WOODS: Exactly.
23 CHAIRMAN APOSTOLAKIS: The minimal cut sets.
24 I'm addressing the issue of raising failure rates and see p)
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384 1 idea. I think we should do it in a more systematic way.
.s 2 The importance measures do it in a more systematic way and
( )
3 the major accident sequences are major contributors. I 4 mean that's really a major insight of any PRA.
5 We are placing too much importance on 6 importance measures.
7 MEMBER CATTON: When you look at these 8 systems, do you make an effort to be sure that it just 9 didn't get left out of the PRA?
10 MR. DINSMORE: That's --
11 MEMBER CATTON: I mean you can start working 12 your way, a pump, oil supply system, a filter somewhere.
13 CHAIRMAN APOSTOLAKIS: Sure.
(~\
w/ 14 MEMBER CATTON: Is this done each time you 1
15 pick one of these systems?
16 MR. DINSMORE: Well, the systems, there is a 17 process to review -- we start off with what you have in 18 the PRA as Roy was saying and then we expand on what came 19 out of the PRA to pick up this type of stuff, for example, 20 inverters which weren't modeled in the PRA because they 1
21 were extremely reliable and the utility chose not to model 22 them.
23 There is a long process, a whole process --
24 MEMBER CATTON: He's a utility guy and he
,-)
i 25 doesn't believe what you just said.
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l 385 l
i 1 CHAIRMAN APOSTOLAKIS: What did you just say? j i
l m ~
2 MR. DINSMORE: I said some utilities --
I )
3 MEMBER CATTON: Extreme reliability of 4 inverters.
5 MEMBER SEALE: He wants to know where you 6 bought them. He'd like to get some.
1 7 MR. DINSMORE: So as part of this process, 8 they're supposed to go through and find all the equipment 9 which supports what's modeled in the PRA which might not 10 have been modeled for one reason or another. They have to 11 go through the seismic models which might not have been 12 quantified and review that to find out stuff which should j 13 be high. It's part of the process.
I i l
(_/ 14 CHAIRMAN APOSTOLAKIS: Why are certain things 15 not modeled?
16 First of all, are we done with the stuff 17 that's modeled? I made my point clear there? j 18 MR. DINSMORE: Well, could I respond?
19 CHAIRMAN APOSTOLAKIS: Sure.
20 MR. HOLAHAN- I'd like to respond also, but 21 I'd like Mr. Dinsmore to respond first.
22 MEMBER CATTON: I have one more question and i
l 23 then -- what do the units of importance measure?
24 CHAIRMAN APOSTOLAKIS: No, no, no.
/
{3) 25 MEMBER MILLER: No units.
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386 1
l 1 MEMBER CATTON: No units.
s 2 CHAIRMAN APOSTOLAKIS: No units.
( )
~'
3 MEMBER CATTON: Okay.
4 CHAIRMAN APOSTOLAKIS: Why? You don't like 5 dimensionless numbers? I don't understand?
6 (Laughter.)
l 7 MEMBER POWERS: It would make him very happy.
8 It's like a Reynolds number except --
9 MR. ABBOTT: This is a little off the track, !
10 but if you took the regulatory guide as it exists today 11 and your knowledge of the South Texas graded QA program i i
12 and you did an inspection, would you be satisfied?
13 MR. DINSMORE: I'm not sure I should answer
's - 14 that.
15 CHAIRMAN APOSTOLAKIS: Satisfied? What does 16 that mean, satisfied?
17 MR. ABBOTT: Well, would there be an extensive 18 difference between what they had on paper and what this 19 reg. guide says and would there be a lot of --
20 MR. DINSMORE: With some modifications, they 21 could satisfy what's in the reg. guide.
22 MR. ABBOTT: So they're fairly close.
23 MEMBER MILLER: When you say some, are they l
l 24 major or kind of trivial modifications?
/~N k,) 25 MR. DINSMORE: Well, they'd have to go back.
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387 1 They already look at functions and the components
, .s 2 supported functions, but they don't automatically put all
/ \
i !
V 3 functions which have -- they don't automatically put all 4 SSCs which support high safety significant function in 5 high, for example.
6 MR. ABBOTT: So your fairly close then. The 7 only reason I'm asking this is what I've been searching 8 for here in all these things is whether or not the 9 regulatory guide has been tested quote unquote in the 10 field. It looks as if to some extent it has been in this 11 case. l 12 MR. DINSMORE: It was written based on two 13 submittals and the Grand Gulf submittal is where we got l p
t s l
4
(_/ 14 most of the expansion into the numodeled equipment. And 15 South Texas is where we got most of the ideas of how to 16 deal with modeled equipment and then we've added on that 17 functional importance which is -- neither of them really 18 had. So --
19 MEMBER MILLER: In that area, didn't South 20 Texas then kind of follow what NEI does?
21 I am trying to still get the difference 22 between NEI and the guideline or the reg. guides as far as 23 functional versus component level.
24 MR. GRAMM: If I could address the NEI
,,- ~ .
() 25 document, we received their 96-02 document last year and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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388 l l
1 we commented back to NEI that we would take that into 2 consideration during the development of the reg. guide.
I,~)
3 However, it lacks sufficient detail from our standpoint to 4 be utilized by licensees and we said it should not be used 1 5 as a stand alone document, that it is not sufficiently 6 descriptive to address the staff's items of concern. So 7 the NEI document by no means has a level of detail that is 8 discussed in the regulatory guide. It does not go into a 9 great deal of discussion on ranking, how you adjust QA 10 controls. It's written, from my perspective, at a very 11 macroscopic level.
12 MEMBER MILLER: I was just addressing how you 13 categorize components.
7 ms l 14 CHAIRMAN APOSTOLAKIS: Mr. Grantom will 15 address your question.
16 MR. GRANTOM: This is Rick Grantom. We did 17 use the criterion in the NEI guideline. They have the 18 Fussell-Vessely criteria threshold and they have a risk 19 achievement worth threshold. That's what was used to l
20 establish the boundaries for what we use. And that's all 21 we used out of it.
22 The PRA modeling and everything like that goes )
23 to what's required for the system to perform its function j
> 1 l 24 and it is geared towards severe accidents and those types 7-() 25 of things. When we screen the system, we're looking at a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.
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I l
389 1 system and saying what does this system need in order to
,-m 2 perform or achieve its safety mission and we're looking at
\
3 those components.
1 4 So you see a lot of ancillary equipment that's l 1
l 5 associated with the system. One inch lines that have 6 valves, but they're all called safety related. They're 7 all part of the system, but they're not modeled in the PRA l
8 because their failure cannot cause the system to not 1
9 achieve its safety function. So that's where you get in l 10 the difference between how come some systems we don't l 11 include everything in the system because the system 12 function is high. There's a lot of little route valves l 13 and things that are tacked off to these things on every
,,~ .
(,V) 14 system, test connections, those types of things that l
l 15 couldn't fail the system, so it's essential to be able to I 16 go and look at a system and find out exactly what it needs 17 to achieve its function.
18 That's how come safety related in a sense is 19 way overscoped because everything that was attached to it 20 or hung on it, every ornament there is safety related by a 21 default of some sort.
22 So when we model it, that's how we do that.
23 CHAIRMAN APOSTOLAKIS: Okay.
24 MR. CARROLL: Let me make sure I understand g
() 25 something. You are looking at full scope of accident, not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODt! ISLAND AVE., N W.
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390 1 just design basis?
, s 2 MR. GRANTOM: Absolutely. As a matter of I i
3 fact, that reminded me about the screening of initiating 4 events. We do a Level I PRA, a full scope Level I PRA, 5 you go through an exhaustive initiating event screening 6 process. You look for internal initiators. You look for 7 external initiators and you also have this broad 8 classification of traditionally accepted types of 9 initiating events.
10 You look at what we call a general transient.
11 That's a regular turbine generator trip. That inc] 2 des a 12 whole broad classification of everything that can happen 13 on the BOP side, loss of condenser vacuum, loss of main (7
7 x'
14 feed water, partial loss of main feed water. I mean the 15 list goes on and on.
16 Things that we screened out, aircraft crashes, l
17 those kinds of things, when you start looking at the I 18 initiating event frequency of those things and then you 19 start looking at the systems that would be required, you l
20 don't gain any additional information when you're trying j 21 to compare 10 to the minus 5th number and you have an l 22 initiating event frequency that's on the order of 10 to
, 23 the minus tenth or something. There's no new information.
l l
l 24 There's no real information gained from it.
, ( ,) 25 So we do screen for initial internal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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391 1 initiators when we look for our own internal systems and gS 2 external, so all of the systems that are required to
( )
s~'/
3 mitigate or prevent a severe accident and this goes into 4 not only core damage, but other deleterious plant damage 5 states and then taking it from there, and going to release l 6 categories are all included and encompassed and documented 7 as to what the scope of that is. So I would say the 8 answer to that is absolutely yes, we include all systems 9 and all the component functions are required.
10 MR. CARROLL: And that does have the effect of 11 bringing things into this world historically when we were 12 thinking of design basis accidents categorized.
13 MR. GRANTOM: Usually characterized that as s '
\' 14 the PRA has a tendency to trample of sacred institutions.
I 15 (Laughter.)
16 Because you do get this other information out 1
17 there that tells you that really under certain situations 18 and under certain scenarios that some equipment can be 19 important that you don't presently call safety related and i
20 there is a huge amount of systems and equipment that --
21 I'll say equipment that you call safety related that plays 22 little to no role at all. It's that dichotomy that we're 23 really wrestling with here.
24 MR. CARROLL: And it's those components that f~m
(,) 25 you want to deal with to lower your quote unquote burden, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE IE'_AND AVE., N W.
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392 1 right?
, s, 2 MR. GRANTOM: Exactly, both of them really, I i \/
3 because we view graded QA as a risk positive step. I know 4 you had a slide over there that said it was an increase, i 5 but if we can do this right, we'll have additional focus 6 on high risk items and less focus on low risk or no risk 7 items and overall we're being allowed then to manage risk.
8 But right now you're locked in and we can't.
9 CHAIRMAN APOSTOLAKIS: It will be an 10 unquantifiable benefit?
11 MR. GRANTOM: It is unquantifiable.
12 CHAIRMAN APOSTOLAKIS: Right?
13 MR. GRANTOM: Right. j
(~~ <
k-)l 14 CHAIRMAN APOSTOLAKIS: The availability of 15 more resources for the high safety. But Rick has a whole 16 presentation later.
17 MR. CARROLL: I feel good about that question.
18 I feel like a lawyer. I ask a question that I know what 19 the answer was and I got it.
20 (Laughter.)
21 CHAIRMAN APOSTOLAKIS: You passed the test, 22 Rick. South Texas will have a presenmation later, so l
l 23 these questions can be asked.
24 MR. HOLAHAN: Before we leave this issue of
,,3
() 25 sensitivity studies --
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1 393 1 CHAIRMAN APOSTOLAKIS: Yes, and I want to go )
s 2 back to Steven as well. Let's start with him, you had the ;
\
l <
1 3 floor earlier.
l 4 MR. DINSMORE: You'd do better to start with 5 my boss. But okay, one of the -- when we're looking at --
6 CHAIRMAN APOSTOLAKIS: This is a test for you.
I 7 Rick just passed it. Go ahead.
1 l
8 MR. DINSMORE: We're looking at this big model 1 9 and we're changing lots of things in there at the same 10 time. We're potentially changing lots of things at the 11 same time and I'm a fan of sensitivity studies. I think 12 they're very useful to a certain extent. One of the uses 13 is if we go in and increase all the failure rates by a l
() 14 factor of 100, and we get a marginal change in the CDF, we 15 can st down and say well, what do we think is the i 16 likelihood that these failure rates are going to increase 17 by a factor of 100?? Well, we don't think it's very 18 likely.
19 Or maybe -- so it provides -- it's not the 20 decision, but it provides an input and I can go to my boss 21 and say hey look, they'll all go up by 100. We don't 22 think they're going to go up -- even if they go up by 100, 23 it's not going to make much difference and we don't think 24 they're going to go up by 100, so we get a lot of use out
(-
l of that.
( 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 394 i 1 CHAIRMAN APOSTOLAKIS: But my point is that 1
t m ;
2 you can do exactly the same thing using the various !
\
\ j \
3 importance measures that have been proposed and do it in a l
4 better way. I 1
5 MR. HOLAHAN: No.
6 CHAIRMAN APOSTOLAKIS: Why?
7 MR. HOLAHAN: No. I think there's a problem 8 with that. First, let me say that I think part of the 9 discomfort with this is that we don't have clear 10 communications on what is a sensitivity study and what is 11 a bounding analysis.
12 CHAIRMAN APOSTOLAKIS: Yes.
13 MR. HOLAHAN: I think when Stephen says he
,a f \
'v/ 14 brings his boss an analysis that says it changes the 15 reliabilities by a factor of 100 and he doesn't really 16 think they'll change by a factor of 100 and look at the 17 effect, to me that's an bounding analysis, not a 18 sensitivity study, because you made a judgment about more 19 than just a slope. You made a judgment about the 20 magnitude of the change.
21 I think bounding analyses are very useful as i 22 screening tools in deciding whether things are going to be 1
23 important or not important. l l
24 The reason that something like that needs to l
(-
() 25 play a role is -- and I think other people know this 1
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I I
395 1 better than I do, but it seems to me the definition of 2 importance measures don't really address individual 73 l
~
3 components. They're really sequence meccures. They're i
4 measures of the importance of sequences. And we stretched 5 that a little bit by identifying sequences with individual 6 components.
7 Then when you start to go further than that 8 and try to address the importance of groups of components, 9 it's not clear that importance measures that you haven't 10 gone beyond the definition of importance measures and you 11 need to do something else to tell you about the aggregate 12 effect of changing multiple things at the same time. This 13 is one approach. I would call it bounding analysis.
s
\~/ 14 CHAIRMAN APOSTOLAKIS: But --
15 MR. HOLAHAN: To get into that.
16 CHAIRMAN APOSTOLAKIS: I think this approach ,
l 17 has a lot of pitfalls. There's a lot of arbitrariness in l 18 it. Ycu pick five components and you raise the failure I
19 rates by a factor of 10. I mean the probability of that j i
20 actually happening may be very, very low or you may find -
21 - okay, as long as you can eliminate things, it's fine, i 22 the bounding analysis. The problem is when you can't any 23 more.
24 That's what I'm saying very little attention
[~'\ 25 has been paid to the actual dominant minimal cut sets.
(_,/
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I
! 396 l 1 That's another way of checking these things. The whole 2 approach here seems to be mathematical, a change says what 7-s 3 happens, finding importance measure, or finding Vessely's i
4 important measure. But really, when you have core damage, j l
5 you want the major accident sequences. For each function, )
6 you want tl.e major minimal cut sets. For each system, you l
7 can have the minimal cut sets. Then I think that's an I l
8 additional and very valuable perspective because then it 1
1 9 shows you really how groups of components lead to certain 10 things.
11 MR. HOLAHAN: Those things are not being 1 12 ignored.
i 13 CHAIRMAN APOSTOLAKIS: Well, they are not ,
f~) l l
~' 14 mentioned here.
15 It seems to me that when you talk about these 16 kinds of sensitivities, this should be a major input. In I 17 fact, I've always been uncomfortable with importance l
18 measures. I can see how that you have thousands of things i
19 that can help you, but it seems to me that the thing that 20 people should do after they have their importance measure I 21 is go to the major accident sequences or dominant minimal i 22 cut sets and see whether the insights they get from the 23 importance measures actually are confirmed by the minimal 24 cut sets or dominant cut sets.
(-
(_) 25 MR. DINSMORE: One of the importance measures NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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397 1 which is used by the maintenance rule is you take the top
~. 2 90 percent of the cut sets and you take very component in 3 that top 90 percent.
4 CHAIRMAN APOSTOLAKIS: Ninety percent of what?
5 MR. DINSMORE: You take the cut sets which 6 contribute to the top 90 percent of your calculated CDF 7 and every component in all those cut sets is high.
8 Doesn't that address your issue? You want to 9 know what are the major contributors to each sequence?
10 CHAIRMAN APOSTOLAKIS: Yes, 90 percent is 11 probably more than the dominant ones. The dominant ones 12 are usually few.
13 MEMBER KRESS: Well, George, if you do what g
ksl 14 you said that helps you to focus, but no matter, you still 15 come down to the same point, that you have to have some 16 measure of how the change and what they're doing affects 17 the reliability of components and you don't have -- I 18 don't think such a model exists.
19 MR. HOLAHAN: But you can have a bounding 20 measure.
21 MEMBER KRESS: You can having a bounding 22 value, that's what I started to say. And in fact, I think 23 that's your only recourse at the moment.
l 24 CHAIRMAN APOSTOLAKIS: There is a history of
(~ I
( )T 25 this, Tom. In the 1970s and 1980s when PRA was still NEAL R. GROSS I COURT REPORTERS AND TRANSCRIBERS 1323 RHOf"c ISLAND AVE., N W.
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398 1 young, there were a lot of sensitivity studies, some of
,_ 2 them from members of this Committee.
/ \
3 And you went to the conference and said look, 4 if I raise this by 10, the core damage frequency will go 5 up by 10. And everybody said ah, it's impressive. Well, 6 you expect that. You change something and it's going to 7 change. The real question is can you assume that this 8 input can go up by a factor of 10. That's a real 9 question.
10 It was never addressed. ,
I 11 MEMBER KRESS: They have to have this model, 12 I'm talking about, of whatever they do affects the 13 reliability by some relationship. !
r~hs l
(._/ 14 CHAIRMAN APOSTOLAKIS: That's light . !
15 MEMBER KRESS: That doesn't exist.
16 CHAIRMAN APOSTOLAKIS: It does not exist. j 17 MEMBER KRESS: So you have to do what I think 18 Gary says, you have to have some judgment on what are the 19 bounds on what they do and that takes the place of the i
20 model.
i 21 It's not a sensitivity, it's a bounding I i
22 analysis. !
23 CHAIRMAN APOSTOLAKIS: But you do that --
24 don't you need the model?
/~N (s/ 4 25 MEMBER KRESS: I think you have to have some NEAL R. GROSS COURT REPORTERS AND TPANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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399 l 1 sort of information, some sort of judgment, but you can't ,
l
_s 2 just plug in a number and say what we are doing here l
/ \
\ ]
3 changes the reliability this much.
4 CHAIRMAN APOSTOLAKIS: That's what I was l 5 attacking. j 6 MEMBER KRESS: I think the way you arrive at 7 these bounds is probably through an expert judgment panel. l 8 CHAIRMAN APOSTOLAKIS: Let me understand j 9 what's happening here. We have one class of problems 10 where we d have models for these components, right? Then 11 you can raise failure rates and I'm saying you shouldn't 12 do that, they should do something else. Or , you should do 13 it under very strict controlled rules, okay? l
/ \
l )
x> 14 The other one is -- l 15 MR. HOLAHAN: And also, you should be careful i 16 about what you call it.
17 CHAIRMAN APOSTOLAKIS: And careful about what 18 you call it. The other one is when we don't have models.
19 Now Dr. Kress just said that you may do some judgment 20 evaluations with expert panels, but I don't see how that 21 can be quantitative though.
22 MR. DINSMORE: Which one is the QA? With l 23 models or without? I'm sorry, you lost me a little bit.
24 CHAIRMAN APOSTOLAKIS: If you don't have
("
( ,)/ 25 models, I don't see what you can do. That's what I'm NEAL R. GROSS CO'URT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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I 400 1 saying.
- ,3 2 MR. DINSMORE
- Okay, I don't think we have a
( i 3 model here.
l l 4 CHAIRMAN APOSTOLAKIS: That's what I'm saying.
5 MR. HOLAHAN: I thought he was talking about 6 when the components are modeled, some are and some aren't.
7 CHAIRMAN APOSTOLAKIS: Components.
8 MR. DINSMORE: That are modeled.
9 CHAIRMAN APOSTOLAKIS: See, if components are 10 read in the PRA, even if you don't have a model for QA, at 11 least you can say look, the failure rate can go up so I 12 can see what happens, right?
- 13 MR. HOLAHAN- Bounding analysis.
~
k./ 14 CHAIRMAN APOSTOLAKIS: Yes, but in the other 15 case the component is not even in the PRA. Another little 16 detail that I didn't see in the reg guide that conflicts 17 this is that maybe there is a reason why it's not in the 18 PRA. It's not an arbitrary decision. Maybe it was 19 irrelevant to what the PRA was trying to do.
20 Now, if you have another function in mind, 21 then I'd like to know that, but we can't jus say gee, what l 22 do we do about components that are not in the PRA? We 23 have to do something and I'm scratching my head, well, why 24 aren't they in the PRA? Probably, they are not important.
(s- / 25 MEMBER CATTON: Well, nobody thought of the NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N.W.
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l
401 1 sequence that included them. j
,-x 2 CHAIRMAN APOSTOLAKIS: That's not true.
( )
3 They're not talking about that. They're only talking 4 about the incompleteness. They're talking about ,
I 1
5 components that are not modeled, l 6 They're insignificant or they are considered 7 to be highly reliable like pipes --
1 8 MEMBER MILLER: Inverters.
9 CHAIRMAN APOSTOLAKIS: And these are studied 10 somewhere else. Livermore had for years a major study to 11 investigate the failure of piping on the seismic 12 conditions and so on, so it's not that that's outside the l j
13 PRA. It's that --
gg i h
\ >'
14 MEMBER CATTON: And then it's treated as an 15 initiator. l 16 CHAIRMAN APOSTOLAKIS: As a separate issue, 17 yes, as a separate issue.
18 MR. DINSMORE: A good example of a component 19 which we're trying to pick up like this would be a MOV in 20 the flow line which is normally locked open.
21 CHAIRMAN APOSTOLAKIS: Yes, why is it not in l 22 the PRA?
23 MR. DINSMORE: Because the -- it's not 24 expected to be closed. They would never -- a lot of those o i I
( ,/ 25 technical components are modeled.
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, - - , . . - - . . - - - - - . . . . . ._. ~ . . - . ~ . - . . . . . - . . -...
402 1 CHAIRMAN APOSTOLAKIS: Actually, so what fi 2 you're saying is it has been screened out?
O 3- MR. DINSMORE: Screened out, right, j
'4 . CHAIRMAN APOSTOLAKIS: So the reas'on why it's- .
j i
5 not-in the PRA is because it's'not a class of events'that >
6 have been screened out. l l
[
7 MR. DINSMORE: The reliability -- ;
t 8 CHAIRMAN APOSTOLAKIS: What do they call that? ;
9 To the cut off level? Dr. Parry wants to say something.
10 MR. PARRY: Yes, this is Gareth Parry. A ;
i 11 couple of' points. First of all, I think you seem to be !
12 objecting to sensitivity studies.
13 CHAIRMAN APOSTOLAKIS: No. This particular Ii
'\ 14' sensitivity study.
15 MR. PARRY: Okay, to certain types of 16 sensitivity studies. Let me just make'a comment abut 17 importance measures. If you think about them,.they're an l' 18 extreme form.of sensitivity study because you take the i
19 component probability typically to zero or one'so they're 20 really extreme. There are lots of concerns about the use j i.
- '21 of importance measures that have been. raised by several l'
22 people. !
! 23 .If you read carefully in Appendix A of the j..
24 reg. guide and Appendix C of the SRP, many of the caveats NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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- ny
.. . _. . . . - . . . . . . . . _ _ . _ _ . _ _ _ . . _ . _ . _ , _ - _ _ _ - _ = . . _ - _ _ - . .
403 you to look at:the content of the cut sets,-to really 2 understand what's going on in the model. That's where the-
' 3 engineering judgment comes in to make sensible use of the 4' importance measures. So I believe it may not'come across p.
~.5 very well yet, but that's what we're trying to.do with !
6 those steps in those appendices.
]
.7 CHAIRMAN APOSTOLAKIS: Well, I'm glad to hear 8 you say.that because it did not.indeed come.across very-9 well. I was looking for the words major accident
'10 sequences, dominant minimal cut sets, I-couldn't find 11- them. Now --
12 MEMBER POWERS: George, maybe I can ask a 13 question --
14 CHAIRMAN APOSTOLAKIS: Because I agree-with 15- what you said, yes.
16 MEMBER POWERS: -- out of ignorance, maybe.
17 Isn't the problem that.you face here inherently one that 18 there's not a quantitative relationship between the QA l 19 program and the reliability'or availability of the-
~
- 20 function. And that-the problem then becomes that this ,
21 whole program is a bit too timid, that we've taken things
, 22. that the PRA and most people say gee, these are low safety .
J I
23 significant items and we're going t'o look and see-how low 1 l
! 24 they are, rather than looking at the things that we all 25 recognize to be high safety significant and look and see NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i 1323 RHODE ISLAND AVE., N.W.
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\.
2 . u_. _.a. . _ . . ,
l 404 I 1 are they very high, in which case we should take all s 2 precautions to assure their reliability and availability l t i
\/
3 even if we can't quantify that, or just maybe important in 4 which case we can relieve things.
5 I mean it seems to me we're dealing in the 6 noise right now and when a more aggressive program would 7 go deal with things where we could use the PRA to evaluate 8 that.
9 MEMBER SEALE: You're saying we're trying to 10 figure out what to throw away and what we ought to do is 11 try to figure out what to keep.
12 MEMBER POWERS: I think that's very much the 13 question that comes through when you read this document
,/,_N.i
\_) 14 because they start off with the ground state that says 15 everything is safety significant and now what can you move l 16 to the low safety significance?
17 CHAIRMAN APOSTOLAKIS: Because that's the 18 current state, but everything is safety significant.
19 Maybe a good way of doing this is instead of asking which j 20 one of these components I should move down to the low 1
21 safety significance so I spend less money, put it in a i
22 different way. Which one of the components I now have on 23 the list would I like to spend more attention, more money l 1
24 on , like what Rick said, that by freeing money down here,
,/ 3 i ,) 25 you're spending more up there. Then maybe you get a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.
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405 1 different perspective.
- 2 I was bothered by the way a few minutes later
\ \
v 3 --
4 MR. CARROLL: I guess I have to jump in and 5 say how could you spend more money than you're doing now 6 on QA?
7 CHAIRMAN APOSTOLAKIS: Wel1 then, Rick *s 8 argument doesn't apply. It seems that you are freeing 9 resources, so you can use --
10 MEMBER CATTON: He's going to correct that.
11 CHAIRMAN APOSTOLAKIS: If I elect him, right?
12 MR. GRANTOM: Yes, what we mean by that, 13 there's currently some components out there for which you 7 .,
i V 14 do nothing on. There are several non-safety related 15 components out there that you do nothing.
16 CHAIRMAN APOSTOLAKIS: On non-safety.
17 MR. GRANTOM: Yes. And we found that there l
18 are non-safety, so when you go in and enhance the controls 19 on there, if you assume, if you make the assumption that l 20 quality is related to reliability, then you would expect 21 some gains in that or at least even apply some barriers to 22 failures of those components.
23 But I also would agree that you can't do much 24 more on the high safety significance other than what we're 25 already doing for those.
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406 1 I'd like to address one other thing though.
7- 2 Mr. Dinsmore's comment was correct that there are some U 3 failure modes on components that are screened out and the 4 reasons that that happens is one, there's no data to l
5 support the failure mode that we can find either plant 6 specific or generic data and that happens, but usually 7 components that are passive in nature are included for 8 things like plugging transfer closed failures of valves '
l i
9 are included, and there's some things like transfer open 10 that may not be included, because we can't find data to l 11 support it, either internally or even within the industry. !
12 MR. CARROLL: I wanted to go back to your 13 motor operated valve normally open. Discussed this a l
[ \ l
\- ' 14 little bit yesterday also. Davis-Besse suggests that that l 15 valve should be capable of opening inadvertently in the i
l 16 closed position, when it was inadvertently put in the 17 closed position, open against flow. )
i l
18 MR. DINSMORE: Well, th way that we set this 19 up is that if that valve is normally opened, they would i
1 20 initially and it was in a high safety significant 21 function, they would initially have to classify it high.
22 Now the reg. guide is set up now so that they don't have 23 to finally classify it high, but they have to start out 24 with the knowledge that that valve has to remain open.
,m
(_,) 25 Now they can in this case we would maybe allow them to NEAL R. GROSS COURT REPORTER!. AND TRANSCRIBERS 1323 RHODE l', LAND AVE., N.W.
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407 1 classify it, the motor operator as low. What I'm trying 2 to say is that you're right, the way it's set up, the way 7-(" )
3 we have it set up now i they could probably classify that 4 motor operator is low, but they'd have to classify the ;
I 5 valve body as high because the function of the valve body 6 supports is important.
7 So we give a little kick from the MOV problem ,
i 8 if they classified as low and they would have to do l l
1 9 reduced QA controls on it. l l
10 CHAIRMAN APOSTOLAKIS: But isn't -- l I
11 MR. CARROLL: I think you're missing my point.
12 I agree with you completely that the valve body is capable 13 of handling any temperatures that are involved, but motor f I k.) 14 operator also should be able to -- at least you've got to !
15 ask the question, can the motor operator open this valve l l
16 against full pressure and flow, because the valve could be 17 inadvertently closed.
18 MR. DINSMORE: We wouldn't directly ask that 19 question.
20 CHAIRMAN APOSTOLAKIS: But maybe that's the 21 question that the PRA must ask.
22 MR. DINSMORE: Yes.
23 CHAIRMAN APOSTOLAKIS: Ask himself or herself 24 what the probability of this thing failing is very low.
n
(
\s) 25 We don't know that. There is a reason why the thing is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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408 1 down in the noise.
, 2 MR. CARROLL: It may be that since Davis-Besse
! 1 3 people have gotten more serious about racking out breakers 1
4 or doing other things to assure that that valve will stay I
5 open. i 6 CHAIRMAN APOSTOLAKIS: Now the other thing is 7 we don't have a model that shows how QA activities change 8 the failure rate, right? i i
9 MR. HOLAHAN: I think Jay's problem goes back 1
l 10 to something that isn't modeled very well. That is, the l
l 11 Davis-Besse event was an error of commission. The {
12 operator the wrong buttons. He pushed the isolation i
13 buttons instead of the start up buttons for the feedwater !
, j U 14 system, emergency feedwater system. l 1
15 And when you don't model that very well, you !
16 don't understand the importance of getting those valves 17 back open. ;
18 CHAIRMAN APOSTOLAKIS: So you are looking then l 19 and the purpose of all this is to make sure the PRA is 20 sound?
21 MR. HOLAHAN: I think in this area, a lot 22 needs to be done. The current state of the art won't 23 capture these things, so we're going to be a little overly 24 conservative.
/%
) 25 CHAIRMAN APOSTOLAKIS: That's my point. ,What l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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. . - . . . ~ . - - . - . - . - - - - - . . . _ . . ~ _ . . - . ~ . - . . . . . - , . . . . . , .
409 1 is conservatism.here? Let's say you remove this thing 2 from the high category.
.b v' 3 MR. HOLAHAN: The motor operator?
4 CHAIRMAN APOSTOLAKIS: Yes, whatever it is.
5 Event A or component A. What'do you think happens to its 6 probability if you remove it?
7- MR. HOLAHAN: We think that there's a 8- likelihood that it might increase to some extent.
-9. CHAIRMAN APOSTOLAKIS: 'Okay, so let's say the 10 probability of the thing happening, the failure occurring 11 was 10 to the minus 3. Now you move it down to the lower 12 category. What do you think is going to happen? It's 13 going to become 1? No. How much? My. question is is it i (
V 14 worth all this trouble to worry about all these details I l
15 just because the failure probability may go up by a factor l i
16 of 2 perhaps, 3, we don't even know that.
17 Is quality assurance so powerful that makes i
18 these failure rates really go down?
19 MR. HOLAHAN: It's so pervasive.
i i 20 CHAIRMAN APOSTOLAKIS: What does that mean?
l 21 MR. HOLAHAN: There may.be 20,000 or 30,000 l
22 components in the plant that are under the QA program, so 23 it's all over the place. So if one goes up by a factor'of f
, 24 one or.two --
25 CHAIRMAN APOSTOLAKIS: Oh, you mean it would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE N.W.
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- _ - - . . . , _ _ ._ ~ , . _ _ , . _
l 410 l 1 be all over the place?
l , ~s 2 MR. HOLAHAN: Yes, they're all over. I
>t l 1 x
/
3 MEMBER CATTON: But you don't know that l 1
4 either.
5 CHAIRMAN APOSTOLAKIS: But we don't know that 6 either.
7 MEMBER CATTON: What you'd like, I guess, is a 8 change in reliability per dollar spent on QA, but you 9 don't know that at all.
10 CHAIRMAN APOSTOLAKIS: My question is we 11 shouldn't really look at this as if by removing the 12 component from the high category, moving it to the low 13 category the failure rate becomes one or something.
/_,s
-- 14 MEMBER CATTON: No, but --
15 CHAIRMAN APOSTOLAKIS: There will be some 16 impact, perhaps, which we don't know, but in general, we 17 expect it to be relatively small. Wouldn't you agree with 18 that?
19 MR. EINSMORE: That's right, but we want to 20 know what the bound is.
I 21 CHAIRMAN APOSTOLAKIS: You are not going to 22 get that, Steve, by changing failure rates by a factor of 23 10.
1 24 MR. DINSMORE: If you took things up by a j
( ,) 25 factor of 10, in your monitoring program we could use --
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411 1 we consider using that information as part of the r3 2 monitoring program. Try taking the failure rates up to v
l 3 some level where you could measure.
4 MEMBER CATTON: I don't think you need PRA for 5 that --
6 MR. DINSMORE: And in your monitoring program 7 you would monitor and make sure that you're not going to 8 exceed that.
9 CHAIRMAN APOSTOLAKIS: Let me put it in a 10 different way because I think we have to close this 11 discussion. I have a PRA, a reasonable PRA, okay? Gives 12 you results that say for these components, 350 valves, p_ 13 whatever it was, these do not really contribute
( )
\/ 14 significantly to risk. And I can have six or seven 15 different measures of risk, metrics. And all of them say 16 no, these components are low. j 17 The question in my mind is why don't I 18 automatically without any further study say yes, move it 1
1 19 into the low category? I'm willing to tolerate some i 20 change in the failure rate distribution. I know it's not 21 going to move by a factor of 100 or 10, even. Some 22 change. They tried hard. They couldn't find any impact.
! 23 Move it. Don't spend any more money. Why do you start 24 asking questions what if, what is part of the real
,/~T (m_,) 25 combination if I multiply by 10 nd this and that. That's
! NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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412 1 not -- it's not clear to me why we have to go through this
-s 2 effort.
/ T
'~'
3 I mean unless the PRA has missed something 1
4 major, because again, what is it that's happening here?
l I
5 By moving it to the low category, you're just changing the 6 failure rate a little bit.
7 MEMBER CATTON: Isn't this an example of ,
l 8 something where judgment should be the primary tool?
9 CHAIRMAN APOSTOLAKIS: Yes and that's what I'm 10 saying that we are acting as if by moving it down, if I 11 didn't know any better I would say my God, the failure 12 rate is 10 to the minus 2 and now it's 1. 1 l
13 MR. HOLAHAN: But George, you've been
(~N j
(- 14 recommending importance measures and they're the most 15 extreme way of doing that, of changing the failure rate. ,
i 16 CHAIRMAN APOSTOLAKIS: No, no. Fussell-17 Vessely doesn't do that. ;
18 MR. HOLAHAN: It certainly does.
19 CHAIRMAN APOSTOLAKIS: It just takes the 20 sequences, the thing up here and divides by the total. ;
21 Right, Rick?
22 MR. SHERRY: No, basically the importance 23 matrices are derived by changing the reliability to either 24 100 percent reliable to zero.
(A) 25 CHAIRMAN APOSTOLAKIS: So I know that too. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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413 j
1 what? I know that too when I make my decisions. The 1
2 important thing to bear in mind is that -- the following, 7- l
( ) l 3 what -- the question -- what are the consequences of 1
4 taking the thing from category A and putting it to 5 category B? I submit it's a change, small change in the 6 failure rate. Does anybody disagree with that?
7 MR. HOLAHAN: There's a piece missing from 8 that argument which is until you do something to address 9 the effect of changing all of those things from where it I 10 was to what it is, vou don't understand the aggregate 11 effect and one of the most powerful things about PRA is it 12 gives you an integrated treatment of the plant.
13 CHAIRMAN APOSTOLAKIS: I agree with that.
(. 14 MR. HOLAHAN: that's the additional piece that 15 we want to address.
16 CHAIRMAN APOSTOLAKIS: Right, but I'm not sure i
17 you are addressing that.
1 18 MR. HOLAHAN: We've suggested one way to do i I
19 that. l 20 CHAIRMAN APOSTOLAKIS: I didn't get that 21 impression that that's what you were trying to do. In 22 other words, you tried to prevent a huge common cause l
23 failure so to speak.
24 MR. HOLAHAN: Right.
(")
! / 25 CHAIRMAN APOSTOLAKIS: A huge --
w/
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1
l 414 1 I
1 MR. HOLAHAN: Or even just a huge common cause 7s 2 influence to change the reliability of thousands of tnings i ) :
! \',/
I 3 by 50 percent.
l 4 CHAIRMAN APOSTOLAKIS: I don't go and pick an l
l 5 event that doesn't even appear in the minimal cut sets and i
6 change its failure rate by a factor of 10. What I'm 7 trying to visualize what you just said, why don't I go to i
8 the minimal cut sets that dominate the risk and change all i
9 the distribution by a small percentage and see what 10 happens? That would give me a much better idea of how j 11 sensitive the risk is.
12 MR. HOLAHAN: That's the sensitivity study.
1 13 CHAIRMAN APOSTOLAKIS: That's not what he l ['N 5- J 14 said. No, I didn't say -- I said the distributions. I 15 was very careful. Stretch them up by the highest side for l 16 example.
17 MR. DINSMORE: But the mean values might also 18 change.
i 19 CHAIRMAN APOSTOLAKIS: Sure they will, but not 20 by a factor of 10.
21 MR. DINSMORE: But we don't know how much it's l
l 22 going to change and we'd have to have some assurance that l
23 the change is --
24 CHAIRMAN APOSTOLAKIS: I think it's -- it's a
()
O 25 different view. You see,I've taken a different point of NEAL R. GROSS l
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i
i 415 1 view. I'm taking the point of view that I don't expect my
,s ~ 2 basis premise is that I don't expect huge changes in the
)
3 failure rates.
4 MEMBER MILLER: In other words, if you take a I 5 QA program from Appendix B to zero, you don't expect a lot 6 of change? Is that what you're saying?
7 MEMBER CATTON: Some change.
l 8 CHAIRMAN APOSTOLAKIS: First of all, it's all 9 the way to zero.
10 MEMBER MILLER: I know it isn't.
11 CHAIRMAN APOSTOLAKIS: It's not zero. But if 12 you say zero, I might see some, but this is an industrial i 13 -- they're not going to tolerate things, you know. If
\
t'~.
! ( I l 's /
14 there's a financial interest here -- l l
15 MR. KING: I'd ask you a question, George.
16 This is Tom King. It sounds like you don't disagree with .
1 17 what's being proposed. Your only disagreement is we're j l
18 being too extreme in the values we choose.
19 CHAIRMAN APOSTOLAKIS: That's correct.
20 MR. KING: Because getting information on how l
21 risk changes, depending on some assumptions I think is 22 valuable and that's the whole idea of risk-informed l
23 regulation.
24 CHAIRMAN APOSTOLAKIS: Yes, I think you are
,o
(_) 25 right. I don't disagree with the intent of this. I think l
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416 l
1 -- the impression I get from the document, at least, is l
, 2 that if we move something to the lower category, there is
' N ']
t 3
i an implicit assumption that the failure rate perhaps goes 1
4 up significantly. It's not emphasized enough that it 5 might not, so you're not really committing a major crime 1
6 here by moving it down. I 7 Second, there is way too much emphasis on the 8 mathematics of it which the spirit may not be there. I i
9 mean look at the appendix on risk importance. Most of it 10 is on sensitivities of importance measures and this and I
11 that. The discussion of the major accident sequence is l 12 not there.
13 MR. GRANTOM: I'd just like -- this is Rick t
.'L/ 14 Grantom -- I'd just like to clarify. I don't believe that 15 the failure rates would go to 100. We did sensitivities l
16 on 2, 4, 10, 8, those types of things and I think they'll 17 probably get into this a little bit. We still have l
18 corrective action programs. You still have the 19 maintenance rule that establishes performance criteria on 20 the number of failures you can tolerate and when we do 21 studies on that we do assumptions on how much, how many 22 failures would translate to what failure rate that would 1
23 have what amount of impact on things like core damage 24 frequency and so I don't believe that you'll ever see q
) 25 anything that goes to a factor of 100 or anything, small i
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I 417 1 amounts of changes in failure rates, but the corrective
,_ 2 action programs that all the stations in a maintenance !
, f I l
\~ 3 rule are really effective barriers to prevent a wild swing l l
1 4 in failure rates. I l
l 5 CHAIRMAN APOSTOLAKIS: I think we've said i
6 enough about this.
7 MR. GRAMM: Moving on, I'd like to address the l \
8 third bullet briefly here. NEI has expressed some 9 concerns relative to the approach taken on graded QA by 10 the staff and we are having a meeting next week to further 11 discuss those issues with NEI in the voluntary plants.
12 What I'm going to do briefly is cover the 13 quality assurance aspects of the volunteer program and
,3 i k
\_/ 14 then I'll turn it over to Steve to go more into the safety 15 significance determination.
16 Again, Palo Verde is just approaching this, a 17 very small subset of activities in the area of commercial 18 grade dedication and this is a specific procurement 19 activity where rather than buying from appendix B vendor, 20 the licensee procures it from commercial stores and then 1
21 applies some testing or necessary verification of critical )
i 22 characteristics to insure the item can perform its safety I l
23 functions before classification it then as a safety-24 related item.
O iv ! 25 Palo Verde determined that there were about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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I
418 ,
. . j 1 900 or 1,000 components that they felt could be downgraded i 3
2: into this area. The regulations permitted their operating
- O ..
-Q-3 in full conformance with their QA program, as written, and
~ i 1
l' 4 so therefore a change was.not submitted for our review.
T 5 We went out to the site and took a look at a- l t
- 6 few cases where they had a handful of components procured l
i 7 in this manner and I gave some examples there, a relief i 8 valve, a radiation detector circuit board and we looked'at 9 the approaches they were taking on dedication practices.
'10 The_ staff offered some comments and concerns in the area i
11 of insufficient procedural guidance for the procurement i 12 engineers. They were basically left at their own i
13 discretion or judgment to determine how to proceed on the i O .14 graded arena. We' offered the comment that should be_
l I
15 proceduralized and more explicit guidance given to the . ;
16 engineering staff. j 17 We saw the absence of a feedback loop so a-t 18 failure has occurred at these components, once installed !
)
i 19 in.the plant, there wasn't a tie back to the procurement ;
20 people so that a clear relationship or understanding could 21 be ascertained as to when QA controls wer- changed, what 22 ultimate impact that has on the reliability -- well, the
.23 performance of the equipment in the plant.
I 24 There was some concerns about seismic j
- O g 25 qualification integrity. The initial concept that Palo NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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419 l
1 Verde had was just to do a kick and count verification,
,- 2 basically, look at the component identification, do a i
\/ 3 quick visual examination and declare that that satisfied l I
4 their design intent and we felt that for certain types of 5 commodities, there would be the necessity then to check 6 with the manufacturer to understand to make sure there 7 were no changes in the manufacturing processes, the 8 components assembly that would have a detrimental impact 9 or make the qualification of the item indeterminate.
1 10 Finally, the manner in which critical l l
11 characteristics were verified was questioned. We've 12 recently received some responses where Palo Verde has ,
l 13 augmented their procurement program and made enhancements
\ >6 14 to it and we're looking at that, but it appears like 15 they're on the path towards addressing these particular l 16 sets of issues and shortcomings which were identified back 17 in the end of 1995.
18 One other point on Palo Verde, too, is that 19 they exclude certain commodities from grading. They would 20 exclude ASME items and environmentally qualified items, 21 any item where a similar component is used in a high risk 22 application cannot be downgraded, so this limits the set 23 of items which the opportunity exists for grading.
24 They've tried to take advantage in many cases of the p
() 25 maintenance rule process. They want to have an integrated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N.W.
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420' I determination, a singular set of safety significance fs 2 that's driven by the maintenance rule results.
l i
)
/
3 For South Texas, they proposed a 3-tier 4 implementation program. Basically, for the high they 5 would keep their full appendix B program as described, all 6 of the ANSI standard commitments embodied in the program, 7 and we're now reviewing a QA program change where they 8 delineate a so-called basic program for the low 9 commodities and they would go through and explicitly 10 identify how the program controls will be changed for that ,
1 l
11 population of equipment and we're taking a look at it.
12 Again, it's a very broad scope application 13 across a number of areas. It's interesting though when we N /' 14 talked with them, say for example in design control, they 15 didn't express much interest in modifying that. They see 16 the necessity to have a robust design control program and 17 I don't anticipate that there will be substantive changes 18 in the way that is actually implemented even for low 19 safety significant items.
20 We issued a request for information and we're 1
21 looking at the response to that. And again, the expert 22 panel and working group activities at the site, we were 23 very impressed with the way those groups interacted. They 24 had an extremely high caliber of individuals with a very
(~%
() 25 questioning attitude and this qualitative assessment where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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]
)
421 1 items aren't modeled. There were very intensive fy 2 discussions as to whether those should be then categorized
! }
~'
3 high or low and there were a lot of diverse perspectives i
4 brought into that interchange and it was very illuminating )
5 to see that discussion take place.
6 It's extremely difficulty, however, to then 7 provide a cook book or a set of rigid criteria that one 8 could follow in all applications. This is often driven by 9 the technical competence and the knowledge and 10 understanding that the people have of their plant and when 11 you bring the design and operation staff together and the 12 PRA people, it's -- very qualitative, it's subjective in 13 many cases and we can't provide an equation to capture
( \
f s '
'- 14 some of the thought processes that would go on there.
15 The third volunteer plant we're interfacing 16 with is Grand Gulf. Again, their interest is in the area 17 of procurement and what they would propose to do is pursue 18 dedication of items where in the past they had 19 administratively procured appendix B. Now they just want I l
l 20 to procure under a commercial grade item dedication l l
1 21 program. We went there in November of last year and we 22 looked through a sample of packages. We're preparing a 23 trip report on that.
24 One other item of note though is they have n
( ,)
25 aggressively attacked high safety significant items in the NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE , N W.
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,. ._ -_ . _ _ - _ -- -. _ _.. _ _..- . _ .. _ . _ _ _ _.. m___. . . _ . _
I' 422 1
(1 non-safety related arena and a few examples are given here I 2 where they've.actually augmented controls in recognition i
- l. 3 of the' greater safety significance of those components and 4 essentially-treating them as though they-were. appendix B l
5 type items. ;
i' .
l 6 And so as Rick pointed out, this is a two-way l
[;" 7 street. Not only are controls being reduced, but in .
l l l 8 selected instances, controls would be-enhanced and we t-
.)4 9 can't quantify the impact of that, but it is being done in L 10 the field. 1 J
- j. 11 MEMBER MILLER: I got the feeling in reading 12 it that it was easier'to - how do I put it -- increase -i l
l 13 controls than decrease controls. Now that's just a kind -l D
V 14 of a feeling I had when reading the document. Maybe. South 15 Texas could comment on that.
,. 16 MR. GRAMM: Your perception is accurate. The l'
i 17 dichotomy we're faced here is.over laying safety.
18 significance in the traditional classification of safety 19 related items. -Once an item is safety related it has to l l
20 meet appendix B and there's very -- the culture is there 21 in terms of what it takes to meet appendix B and we're 22 struggling to move down this path of identifying what l
23 controls we can live without and still meet appendix B in 4
1 i 24 that process for these items that are low. And so yes, it
- ( 25 is difficult to cut away some of those traditionally l
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423 1 accepted items.
, 2 We're trying to use good judgment when we take
(,-}
3 a look at that, but it certainly is much easier to take 4 the conservative approach and lay more requirements on.
5 That's easy to do.
6 MEMBER MILLER: And then I've heard not from 7 your group, but I heard other staff members say if it's l 8 safety related, we're not going to down grade no matter 9 what. Now that's not from PRA people. Just give me a 10 comment from another group. If it's safety-related, we're 11 not going to down grade it.
12 MR. HOLAHAN: Could you tell me their names?
13 Because that's not our policy, j
'w '
14 (Laughter.)
15 MEMBER MILLER: No.
16 MR. GRAMM: Well, downgrade in what sense?
17 MEMBER MILLER: Well, we're not going to 18 downgrade the QA requirements on a safety-related 19 equipment.
20 MR. GRAMM: This reg. guide is written from a 1
21 very generic aspect, so I don't think we're at this point 22 excluding any particular commodities and it's written from 23 very general perspective.
24 We're not allowing items to drop off the Q
,a f 25 list, based merely on the PRA importance measure input
.x_-)
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424 1 because if it meets the deterministic criteria, it remains
,- m 2 safety related. And that's what --
f s
(~~'l 3 MR. ABBOTT: Then doesn't that fix what you 4 have to do to it? I mean once it's on the list, I mean 5 the regulations are pretty prescriptive on what has to be 6 done to that component in terms of purchasing replacement 7 parts, repair and all the rest of it. i 8 MR. GRAMM. Appendix B is written in a very 9 general nature. It's when you look at the reg. guides and 10 the implementing ANSI standards which go into a very great 11 level of detail on what needs to be done to meet appendix i
12 B and I think those are the aspects that are very resource j 13 intensive and which we're attacking.
(]
U/ 14 Appendix B is quite frankly, if you look at 15 the words merely in appendix B that would be easy to l 16 implement. The difficulty comes in when you look at the 17 body of standards which would fill several notebooks, if I i 18 were to lay them in front of you, and QA.
19 MR. ABBOTT: Okay, then, if I take something 20 from high to low, what do I peel off?
21 MR. GRAMM: That is what the staff in South 22 Texas is defining what you can peel away in terms of 23 personnel qualifications, doing more sampling inspections, 24 how you would adjust the rigor of your audit program,
,a adjust the approaches that one would take, how you could 5
()b 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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425 1 adjust design reviews and to back off on some of those 7 ~s, 2 controls in a manner which makes sense and which you would
(' ' '
)
3 still meet appendix B at the end.
4 MR. ABBOTT: And this sort of realignment 5 would take place in the utilities quality assurance plan 6 which is submitted for review.
7 MR. GRAMM: Yes. If they make a reduction in 8 commitment, that would then come in for our review, yes.
9 MR. ABBOTT: And then you'd use this reg.
10 guide to do that review?
11 MR. GRAMM: The reg. guide was written for the
?
12 licensee's purposes in formulating their submittal.
13 MR. ABBOTT: But you use it to inspect, too?
'w- 14 MR. GRAMM: We plan on developing an 15 inspection procedure.
16 MR. CARROLL: What does the bullet bout 50.59 17 mean?
18 MR. GRAMM: During the course of some 19 interactions, Grar.d Gulf identified some systems in 20 particular stand by liquid control system where they 21 hypothesized using 50.59 controls and looking at their 22 seismic design envelope and downgrading that. The staff 23 issued some cautions that if one were to approach that on t
i 24 a system basis, we felt it would then constitute an 7 s.
, ! ,,/ 25 unreviewed safety question and to not declassify an entire NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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426 1 system of that magnitude.
,s 2 MR. CARROLL: From seismic requirements?
'~'
3 MR. GRAMM: Yes sir. That would be a 4 technical requirement where the FSAR elaborates how that 5 will be designed and treated.
6 MR, CARROLL: When we speak of graded QA, I 7 guess another area that we're not talking about here is QA 8 on some of the other programs that you have in a nuclear -
9 - what are the QA requirements employed, chemistry or 10 health physics. When I was still earning a living 11 honestly 10 years ago -- i 12 MEMBER MILLER: When did that quit?
13 MR. CARROLL: We started deciding that it was f x
( )
' ' ' 14 solely to be flying full QA. Has industry moved in that 15 direction independent of all this?
16 MR. GRAMM: I've never seen a QA program that 17 describes QA for bullets. That may be --
18 MR. CARROLL: We had been told by inspectors 19 that we had to have one.
20 MR. GRAMM: And if that were then described in 21 the security program, there is a separate change control 22 mechanism whereby the licensee would propose changes in 23 the security program implementation and that would be 24 reviewed under a different process.
(,,) 25 MR. CARROLL: We were told that it wasn't good NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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427 1 enough to have laboratcry equipment vendors certification
-s 2 that a 100 milliliter pipette was a 100 milliliters.
(
)
3 MEMBER CATTON: Did he say bullets?
l 4 MEMBER SEALE: He said bullets. !
l 5 MEMBER CATTON: Well, what's the reliability ,
l l
6 of a bullet? l I
7 MR. CARROLL: That's my question.
i 8 MEMBER MILLER: I'd think the military would !
9 have a lot of data on that one.
l 10 MEMBER CATTON: Yes, but if you had one that l l
11 misfires, no problem. There's another one popping right l i
12 in behind it. l l
13 CHAIRMAN APOSTOLAKIS: Why don't we go on to f
,, a V 14 next -- l 15 MR. CARROLL: Well, I guess my basic question l l
l 16 is that situation that existed 10 years ago -- are people 1
1 17 doing graded QA on -- I don't know what to call it, ;
18 program type of things?
19 MR. GRAMM: I can't speak to those specific 20 instances, but the regulations allow the grading of 21 quality practices based on the importance to safety of the 22 items, in general.
23 MEMBER BARTON: Jay, to answer your question, 24 yes, I'm familiar with it. Utilities have done that.
(
) 25 They have gone through and have documented it with the NRC l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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428 I changes or downgrades in a QA program have gotten them
~s 2 approved for things that you're talking abut, so that is
() ~
3 going on.
i 4 MR. CARROLL: The sirens and your emergency. ,
1 5 MEMBER BARTON: Those types of things, yes.
6 MR. ABBOTT: Could we just for a moment go 7 back to the standby liquid control problem that you l 8 described with Grand Gulf. What were they exactly doing?
9 Taking away the seismic qualification required for the 10 system or downgrading it somehow?
11 MR. GRAMM: This was a hypothetical example 12 where their engineering department had looked at the 13 combination of design basis events where the standby
- a
\/ ~ 14 liquid control system would be called upon to function 15 relative to the sequential occurrence of a seismic event i
16 and they hypothesized that that was not within the design 17 basis envelope and they felt the system could be 18 downgraded to a nonseismic --
19 MR. ABBOTT: So it had nothing to do with the 20 functionality of the system in the PRA?
21 MR. GRAMM: Not directly, no. This would have 22 been from a modification standpoint, presumably.
23 MR. DINSMORE: Okay, I'm just going to finish 24 up real quick here. One of the questions which comes up
.s
() 25 is how do the pilots compare to the process so what we did NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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429 1 was we went through real quick. We don't have a whole lot 73 2 of information, well, for South Texas project we have the
(') 3 submittal. We have the first RAIs which they answered and 4 we were down there once and talked to them.
5 Grand Gulf gave us a report describing their 6 process and we submitted or we gave RAIs to Grand Gulf and 7 Grand Gulf visited us and orally answered the RAIs.
8 Palo Verde, we haven't had much contact with 9 them last couple of years. We sent them eight questions, 10 I think, a year and a half ago, but they're in the IST 11 program and they got a set of q.lestions from the IST guys 12 and I looked through those questions. So this information 13 is from different places and it is of different vintage il 14 and that's why at the top of every one of these slides 15 you're going to see current staff understanding of 16 volunteer plant safety significant categorization and I 17 was looking at South Texas this morning and they looked a 18 little uncertain as to whether we'd done it right, so I'm 19 sure they'll tell us.
20 Okay, the first step we asked them to do is 21 identify system functions. South Texas actually 22 identifies or defines in categories every function that 23 each system performs as they do it. They do it system by 24 system.
/ \
Grand Gulf and Palo Verde both categorize
() 25 1
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430 ,
1 systems as a whole, so they don't really go in and look at f3 2 the functions.
( )
~
3 MR. CARROLL: Give me an example of that, 4 categorized system versus function?
5 MR. DINSMORE: Well, they would just say the 6 HPSI system is important.
7 MR. CARROLL: And what do you want them to 8 say?
9 MR. DINSMORE: High pressure injection for 10 small break LOCAs, we need two pumps, high pressure 11 injection.
12 The categorized safety significance of the 13 functions itself, again, this is guided by PRA importance p_
! )
\/ 14 measures. This is the quantitative part of it.
15 South Texas has quite an extensive PRA and is 16 quite good at manipulating it and using it so they tend to l
17 ignore, not ignore them, but they emphasize the basic l i
18 event importance. !
l 19 Grand Gulf, again, they categorize systems and I 1
20 they base the categorization of the system on surrogate !
l 21 basic event categorization which means they go through the l 22 importance measures and they do some type of analysis of 23 those and they say well, if this system has a high 24 important basic event, then the system is high.
(3
( ,) 25 Palo Verde apparently does the same thing, but
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431 l 1 I got that from the maintenance rule report, but I think q 2 they do the same.
G 3 Then the next one is how you categorize 4 functions which aren't in the PRA. South Texas again, 5 they have a nice list and they have every function in the 6 system it performs listed down there. They categorize 7 things as critical and noncritical and since we haven't 8 had that much interaction, we're not entirely sure what 9 that means, but they do categorize it.
10 And Grand Gulf then goes through systems which 11 have not been addressed by the PRA which are -- I think 12 Grand Gulf has a -- they might have a seismic PRA, but 13 they don't include those numbers, so they go through the
14 seismic PRA and look for systems which have components l
l 15 which are not yet categorized as high and they would put i 16 those systems in as high, used for containment integrity.
17 One thing that actually South Texas told us was the LERF 18 doesn't cover containment spray. It doesn't always pick 19 up systems which are important for long term containment 20 protection.
21 So they go through and look at those. They 22 have something called minimum success path where they look 23 at the different functions like decay heat removal, i
i 24 reactor pressure coolant injection for different sequences r~S
!q,) 25 and they make sure that at least one system in each of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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432 1 these high level functions is initially categorized as
,- 2 high. They look for systems which are excluded from the I' ')
~
3 PRA due to the inherent reliability, the inverted system.
4 That's where that came from.
5 They also look for systems --
6 MR. CARROLL: If I were you I would say show I 7 me your data. l 8 MR. DINSMORE: Okay, next time I see them, 9 I'll ask. I 10 MEMBER CATTON: Maybe they buy better quality 11 than they do at Diablo. l l
12 MR. HOLAHAN. Maybe you should ask him about 13 the room cooling.
- 9 s
(_/ 14 MR. DINSMORE: And the last one is criteria to l 15 support operator action. That's actually how they found 16 the first one because they figured out the operators 17 needed instrumentation and instrumentation needs vital AC 18 and vital AC needs inverters.
19 Palo Verde, we're not -- I don't really know 20 how they do it. That doesn't mean, of course, that they 21 don't do something. It just means that we didn't have it 22 written down.
23 Then the next step is once you have the high 24 safety significant functions, you need to identify the 73 (v) 25 SSCs that support those functions. This is where we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 1
433 1 deviate somewhat from the industry at the moment.
l 2 South Texas, however, has a very comprehensive
("f 3 system where they write down every component and they tell i
4 you exactly which system functions which I identified I l
5 earlier are supported by that component. l 1
6 Grand Gulf initially classifies all high 7 safety significant -- all components in high safety j i
8 significance as high safety significance.
9 So they don't need to do that connection. ,
i l
10 Palo Verde, again, we're not sure. ;
11 MR. CARROLL: But you say initially --
12 MR. DINSMORE: Here comes the next step.
13 MEMBER MILLER: This is the difference between g
V; 14 industry and guideline are? I'm going to hear this now?
l 15 MR. DINSMORE: This slide?
16 MEMBER MILLER: Yes. l i
i 17 MR. DINSMORE: No, the main difference is in 18 the classification of system functions.
19 MEMBER MILLER: Okay, 20 MR. DINSMORE: As opposed to basic. And then 21 the last step is to actually categorize the SSCs in some 22 form or manner.
23 South Texas, the stuff modeled in the PRA, 24 they tend to emphasize the importance measures if it's j 25 above a certain level, then it's high. If it's below a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 434 1 certain level, then it's low. For those SSCs which aren't l 1
fs 2 in the PRA and that big list which they develop for each
/ \
\
~) 3 system, the working group goes through and this is what 1 l
4 Bob was talking about. l l
5 This discussion within the working group and 6 they eventually assign grading factors to different ;
1 7 contributions to safety significance, for example. They 8 look at does the SSC mitigate accidents. Is it involved 9 in EOPs. Could its failure fail an SSC which is high? So j i
10 they go through each one and then they make a final 11 judgment based on the total score and just talking about 12 it and deliberating over whether it should be high or low. ,
13 Grand Gulf, again, they start out, they say t
r~N 4 1
\-) 14 okay, everything in this high safety significant is high 15 and then they start to push stuff down and they say well, 16 if it's not -- this is an "and" gate by the way, these 17 four points. It has to meet each one of these criteria.
18 If it's modeled in the PRA, it's not needed to support a 19 high PRA SSC. It's not needed to perform these external 20 event mitigating functione and it's not needed to support 21 the operator action.
22 These things are all fairly similar, as you 23 might see here and what they can't take out is left as 24 high. Palo Verde, again, we don't really know how they do (w) ,
25 it.
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l 435 .
I 1 CHAIRMAN APOSTOLAKIS: Well, the key word here 73 2 s "high", what Grand Gulf does. Right? Not needed to i \
~'
3 support high.
4 MR. DINSMORE: Yes, that's right. And then 5 the last thing we did, I'm beginning not be sure whether !
6 we should have done it, we went through and tried to fit i 7 things which told us which they were doing with defense-8 in-depth and safety margins. The first thing up there I 9 guess I should change to initial response of the pilots is 10 that the aggregate CDF and LERP bounding calculations are 11 not useful. They've all three told us that.
12 Grand Gulf -- and then as far as the different 13 points regarding defense-in-depth and for Grand Gulf they
- 14 have this minimum success path requirement. Then they 15 explicitly put fission product barriers in high, even if 16 they're not modeled, if they don't meet any of the 17 criterion and so on.
18 Palo Verde, they explicitly exclude from i 19 grading anything in the ASME and the EQ and I guess Bob is 20 going to help me with that one if you guys have any 21 questions. I'm not entirely sure what that means.
i 22 They reduce the pool of stuff they're looking 23 at. Then they have the CCF protection which I mentioned ]
24 earlier, by they don't categorize nominally identical
() 25 components of both these high and low functions.
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436 1 South Texas, again, tends to be -- to rely 2 more on its PRA because it has substantially improved PRA 7-3 compared to some people, perhaps. So they're essentially 4 saying that there's only programmatic changes. They're 5 protecting defense in depth by that type of process, and 6 only the programmatic activities of high safety 7 significant SSCs are not decreased.
8 MR. CARROLL: Back to the first star at Palo 9 Verde, what is an ASME SSC?
10 MR. GRAMM: That would be any Momponent that's 11 classified as an ASME class 1, 2, or 3 item they are l
12 currently excluding because of the code requirements.
13 MR. DINSMORE: That was it, I guess.
Ik ') 14 MEMBER POWERS: Could you go back to your 15 slide 14, and it's related to this slide as well. In your 16 discussion of your slide, you said that people were 17 finding that the LERF measures did not pick up things that 18 were useful for long-term preservation of containment 19 integrity and source term related items.
20 MR. DINSMORE: You couldn't guarantee that l 21 they would be picked up, no.
22 MEMBER POWERS: Does that imply to you that 23 the LERF measure, as currently constituted, is not 24 adequate for your purposes?
/~'N
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437 1 inclusion of the specific request that they look at
,f- 2 systems which take long-term containment heat removal.
( )
3 That's about where we stopped.
4 MEMBER POWERS: You'd be happier if there was 5 a different LERF measure that would pick up those systems.
6 MR. DINSMORE: I'm not a great proponent of 7 using the quantitative safety goals, so I really don't 8 have an opinion on that. All I want is if they use LERF, 9 then they should also look at this.
10 MEMBER POWERS: But they wouldn't have to if 11 you had a different measure to --
12 MR. DINSMORE: Perhaps.
13 MEMBER MILLER: I have a question, and it's
,/
' _/
14 back on slide 8. You kind of zipped real quickly by 15 interactions with NEI. There's really not much there 16 except interactions with NEI.
1 17 Now, I read with some curiosity a series of l 18 letters that went back and forth over the last few years 19 between NEI and NRC. And it seemed like the major 20 difference was how the maintenance rule might factor into 21 a graded QA. Is that still the major difference, as far 22 as -- I agree with you, by the way, that the NEI document 23 did lack specificity in those things. But there seemed to 24 be philosophical differences, too, and the major ones
, , 25 seemed like the use of the maintenance rule.
R.
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i 438 1
1 MR. GRAMM: In October of '96, NEI wrote a
-~ 2 letter which I think amplified on their concerns. And I i
~'
3 there's a linkage between graded QA and their concept of 4 performance-based regulation. It's linked with the rule-5 making petition on 50.54a, which controls QA plan changes.
6 The NEI argument would be there should be less 7 detail in the QA program. And licensees should have the 8 flexibility to define monitoring goals and criteria, like 9 the maintenance rule, and regulators should not worry as 10 much about a compliance-oriented quality program. So 11 they --
12 MEMBER MILLER: If I thought -- and he also 13 wanted to just argue to use information gained from the
/\
/ )
'w./ 14 maintenance rule. Is that really the same thing? I 15 thought that was NEI's argument, they wanted to use 16 information gained from the maintenance rule or acquired 17 from it.
18 MR. GRAMM: I think that's a fair 1
19 characterizatien. I J
20 MR. DINSMORE: At Palo Verde, for example, I 21 think that their SSCs, their high SSCs or the high SSCs 22 which they got from the maintenance rule, expanded to 23 include non-maintainable -- what *oes that say? .
l 24 MR. GRAMM: Non-maintenance preventable l r~ l I
(N) 25 functional failure. So when they actually did the i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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439 j 1 categorization, it was beyond what NUMARC 93-01 would have
, ,x
, 2 specified, in terms of only having to evaluate maintenance s
' k i t
3 preventable functional --
4 MEMBER MILLER: Well, a further question then.
5 You indicated they're going to have a meeting, and l 6 apparently with a lot of disagreements with where we stand 7 here. Because there are disagreements expanded beyond 8 what they were in this series of letters, or are they --
9 MR. GRAMM: Well, again, NEI has not seen the 10 reg. guide, and so I think their concerns are addressed 11 from the standpoint of the RAIs that have been generated 12 by the staff. They address some concerns about the level 13 of detail to which the staff was probing for low safety
- 14 significant QA treatment and also PRA treatment. And this 15 is leading to some consternation on behalf of the 16 industry. We can provide you with that correspondence 17 that they sent in October if you'd like a copy.
18 CHAIRMAN APOSTOLAKIS: Speaking of the i
19 emphasis that NEI is placing on performance, I'm glad you 20 said that, because I had also the impression by reading 21 the document again -- and I'm willing to stand corrected 22 -- that you really don't place sufficient emphasis on i
23 performance and monitoring programs.
24 I mean, I know they're mentioned, but it seems
{} 25 to me that instead of arguing whether this has to go down
(,/
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440 l
1 to the low safety category, and play with the failure
! r3 2 rates, and see what happens and this and that, somebody (r \
i 3 said, "Look, I'm going to move it down to this category.
j 4 I'm going to do less on it. But I will have this i t i I 5 monitoring program. So if there is any change of 6 substance, then I'm going to do something about it, and j 7 you will know about it. But until then, leave me alone."
8 And I think th&t's essentially NEI's position.
9 "If we meet the performance criteria, please 10 leave us alone." And I don't see that being as prominent 11 as it should be in these documents, especially in your 12 case where you have such difficulties finding models that 13 tell you, you know, if I make this change, what happens to
{}/
14 the risk? If there were monitoring failures, you want to 15 worry about groups, okay, then we'll monitor groups too.
16 And they have a good monitoring program. Why wouldn't 17 that be enough? Unless, of course, you have situations 18 where things are supposed to respond under accident 19 conditions and so on, in which case the monitoring program 20 doesn't help --
21 MEMBER CATTON: Does the monitoring take place 22 under the maintenance rule?
23 CHAIRMAN APOSTOLAKIS: Yes, that's why they 24 keep mentioning the maintenance rule.
('~\
(_j 25 MS. BLACK: Well, my name is Suzy Black, and j l
l
\
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l i
441 l 1 I'm the branch chief for QA maintenance. And I think one l
, ,x 2 of the problems with the original concept was that the
- ! \
3 items that are going into the low safety significant are l
4 modeled at the plant level under the maintenance rule, and 5 that wouldn't give you the kind of information you'd be 6 looking for for QA changes and changes in failure rates, 7 because the failure would have to be so -- such a large i 8 failure that it would a plant scaam or a run back or a 9 safety system actuation. And we'd be looking for a lower 10 level of failures of the components.
11 CHAIRMAN APOSTOLAKIS: So the maintenance rule 12 would not do that, is that what you said?
i 13 MS. BLACK: The maintenance rule may partially
/, T
-) 14 cover it, but a lot of the things that are going to have l 1
15 reduced QA wouldn't be monitored at such a level to 16 identify these. ;
1 17 CHAIRMAN APOSTOLAKIS: Right. But what I'm I 18 saying is that somebody may come back using now this new i
1 19 guide, 1064, and propose additional monitoring programs.
20 MS. BLACK: Yes, they could do that.
21 CHAIRMAN APOSTOLAKIS: But the significance of l 22 those programs and what benefit they would get from it is 1
- 23 not really discussed in the guide.
24 MR. WOODS: In fact, in Section 5.3 of the --
/~N
( ,) 25 page 5-6 in 1064 --
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l 442 1
1 CHAIRMAN APOSTOLAKIS: I know.
,, - . 2 MR. WOODS: -- I thought we had put in some i~'/ 3 words to put great importance on the monitoring and 4 feedback program. The last paragraph in that section 5 right above 5.3.1 says, "Thus, in the GQA program, the 6 operational feedback and directed action portions assume 7 considerable importance in GQA programs, and the 8 acceptability must be pivotal in the determination."
9 MR. ABBOTT: Where is that?
10 CHAIRMAN APOSTOLAKIS: Page 5-6.
11 MR. WOODS: Section 5.3. It's dangerous to 12 give you a page number because --
13 MR. ABBOTT: Okay.
(~~'s i i A/ 14 MR. GRAMM: It's the very last paragraph in 15 Section --
16 MR. WOODS: We did realize that these programs 17 would have great importance in GQA because you aren't able 18 to model things as precisely as you would like to, say, in 19 tech. specs., which I was here yesterday. Those systems 20 are modeled; these often aren't. And you do place great 21 emphasis on this. And, in fact, we've got some shells in 22 here where somebody eventually may take it out, but you 1
23 don't normally have that kind of emphasis --
24 CHAIRMAN APOSTOLAKIS: Well, I understand what
/ g
( ,) 25 you're saying, but I guess it's a matter of degree. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 443
. I would like -- well, again, if you guys disagree, that's l
i
,, 2 fine. But I would like to see more emphasis when you talk
,( )
i t l
3 on the performance monitoring, when you're discussing 4 Section 4, all of these limitations of PRA and this and 5 that. I mean, that's a way out, it seems to me.
6 MR. CARROLL: Well, but there's a real 7 practical difficulty that we talked about yesterday, and 8 that is on these systems that -- where you're expecting 9 very high reliability. You can monitor until you're blue 10 in the face, and you're still not going to really have any 11 statistically convincing --
12 CHAIRMAN APOSTOLAKIS: Well --
13 MR. CARROLL: -- it's a reliability
) 14 requirement.
15 CHAIRMAN APOSTOLAKIS: Well, you don't 16 necessarily have to look for failures. You may look for 17 other indicators of graded performance.
18 MR. CARROLL: Well, it helps, but I don't 19 think it's a cure all for the problem.
20 CHAIRMAN APOSTOLAKIS: But here you have now a 21 situation for some of these things -- remember now, we're 22 talking about items in the low safety -- so the PRA has 23 already told you there are low safety significance. The 24 expert panel has already declared them of low safety n
( ,) 25 significance.
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444 1 Now, Jay, you are saying and they are of such
.s 2 high reliability that I'm not going to see it in the
( )
3 performance monitoring program. I mean, I have everything 4 I need. They are not very important, and they have high 5 reliability. Why do I need to worry about them anymore?
6 MR. DINSMORE: If they came to us and said, 7 "We have this monitoring program that shows that we can 8 show convincingly, over a short period of time, t'.iat the 9 failure rate doesn't increase by a factor o' ' " then l
10 our bounding analysis would stop at a factor of two.
11 CHAIRMAN APOSTOLAKIS: Well, you are taking it i
12 to an extreme now. That's not what I meant. I mean, I s
13 there will be a monitoring program that will alert me to
/"N
\_/)
f 14 possible changes in failure rate of the component.
15 MR. DINSMORE: Well, they could do that with 16 group components. I mean, the option is in here that they 17 could --
18 CHAIRMAN APOSTOLAKIS: It's not emphasized 19 enough. I don't know where --
20 MR. DINSMORE: Okay.
21 CHAIRMAN APOSTOLAKIS: -- you got the same 22 impression. But the monitoring is the way out of 23 demonstrating this and demonstrating that.
24 MEMBER MILLER: Well, I got more the
(~'% \
( ,) 25 impression from the letters that it was traded back and NEAL R. GROSS i I
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445 I
1 forth between NEI and NRC. In addition, of course, they ,
,-m 2 do have the section in here that's talking about i
/ ) !
\" ') l 3 performance monitoring. But this was using the i maintenance rule performance monitoring.
5 CHAIRMAN APOSTOLAKIS: No, I agree with Suzy. ;
l 4
6 You will need more than that. i 7 I think all of these documents -- I mean, 8 that's my general impression, Gary, that they are really 9 risk informed, but reluctantly to performance based. l 10 MR. HOLAHAN: I think you should remember 11 whe re we started out. l 12 CHAIRMAN APOSTOLAKIS: Yes.
13 MR. HOLAHAN. Said they were risk informed and 14 they had performance elements.
15 CHAIRMAN APOSTOLAKIS: Yes, elements.
16 MR. HOLAHAN: But they were not structured as j 17 a performance-based approach. I think this, again, is at 18 most a small step in terms of performance-based 19 regulation.
20 CHAIRMAN APOSTOLAKIS: Any other questions for 21 the three gentlemen?
22 MR. CARROLL: But one large step for mankind?
l 23 MR. HOLAHAN. Absolutely.
24 (Laughter.)
( / 25 CHAIRMAN APOSTOLAKIS: I think I've heard NEAL R. GROSG COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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446 l
1 that. l
,q 2 Ed?
] 3 MR. ABBOTT: Yes. The regulations aren't 4 going to change. The standards aren't going to change.
5 So, therefore, the Q list isn't going to change. We'll 6 end up --
7 MR. CARROLL: Oh, I don't think that's true, 8 is it?
9 MR. ABBOTT: Well, the list of equipment on 10 the o list will not change. I mean, that's what we heard.
11 Correct?
l 12 MR. GRAMM: That is correct. What will 13 happen --
7
( 1 k/ 14 MR. CARROLL: Wouldn't it be having to, for i
15 example?
16 MR. ABBOTT: Well, that's what I'm getting to.
17 MR. GRAMM: The licensees maintain a master 18 equipment database, for example, and they will then 19 designate for safety-related items whether they are high l
1 20 or low safety significant. It's just one more indicator 21 that's attached to -- l 22 MR. ABBOTT: I mean, what you're going to do 23 is reorder the list somewhat.
24 MR. GRAMM: Yes.
,m 25 MR. ABBOTT: Now, at least some of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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447 1 documents I've read seem to indicate that if the PRA shows
,s 2 that something that is not currently on the list is
! i i _)
3 important, it ought to be added, such as the condensate 4 pump. And a BWR is fairly important to preventing core 5 melt in the event that -- you know, because there's a 6 direct path to the vessel, and all that stuff. I mean, so 7 you may want to add something. And that turns on the 8 balance of plant, so the list could get longer.
9 But the things that are important are going to 10 stay on the list. For example, and people may argue with 11 me on this, the reactor vessel level instrumentation 12 system on a PWR, the post-accident sampling system, the 13 safety parameter display system, those things that were s
( )
(/ 14 imposed, most of which were after TMI but were given the 15 safety-related stamp ended up on the Q list. And if you 16 look at the PRAs, they really have no function whatsoever.
17 Those things are still going to stay on the list.
18 So at least from the industry's perspective, 19 at least the way I see it, is that my QA program is going 20 to increase in scope. It's going to get more difficult to 21 manage, so why don't I just continue doing what I'm doing.
22 Now, that's not necessarily my opinion at this point, but 23 I think that's one way the industry could look at it. And 24 how do you respond to that?
("h 25 MR. GRAMM: The tradeoff is for those items
( ,/
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l 448 1 that remain on the list but are found to be low safety :
, 2 cignificant. There would be a reduction in the QA control ,
8
/
4 1
s
application on those items.
3 Each licensee would then have 4 to do a cost-cenefit analysis to assess whether those 5 gains equate to the amount of resources they would have to 6 apply to er.ter into this program. So it's going to be a 7 tradeoff where each licensee will have to individually 8 configure their new program and make a decision whether 9 it's economically feasible or viable to proceed with it.
10 MR. ABBOTT: So someone could decide not to do 11 this.
12 MR. GRAMM: This is a voluntary --
13 MR. ABBOTT: That's the point I'm getting to.
n m- 14 But from a risk informed approach, by not going into it 15 you're not caring and feeding for some things which are 16 really important to risk. I mean, that's the problem. ?
17 mean, we're cutting off a huge amount of equipment that is !
l 18 important to risk because we can't strike a deal.
19 MEMBER MILLER: I like the way you put that. l I
20 MR. DINSMORE: The non-safety related stuff, l 1
21 which is important to risk, requires augmented QA controls 22 under this program.
23 MR. ABBOTT: Under this program. But if I 24 don't do the program, I don't do anything. I could do (a) ,
25 diddly squat on the condensate pump.
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449 1 MR. HOLAHAN: If you remember the figure we i
,s 2 put up yesterday morning, which talked about the I' ')
3 collection of approaches on how to change licensing basis, I
4 what it says -- if the licensee doesn't volunteer for this 5 program, then putting additional constraints or 6 requirements on the important systems would have to be l 7 done in a different way. The burden on the staff would be 8 to use the backfit process to do that.
9 MR. ABBOTT: Okay. No, I understand that. I 10 understand that. Doesn't mean it won't be done. Just 11 means it gets harder, and I think the standard is 12 different.
13 MEMBER CATTON: But how do you do cost benefit
- 14 when you can't relate to cost of QA to change in 15 reliability?
16 MR. GRAMM: I think that would be a good 17 question for the utility representative because they --
18 MEMBER CATTON: I think it's a good guestion 19 for you, because you just asked for cost benefit.
20 MR. GRAMM: No, sir, we don't ask for it. But 21 that is part of the --
22 MEMBER CATTON: Then I didn't understand you.
l 23 MR. GRAMM- The decisionmaking process for a 24 licensee to enter into this program would have to consider rr
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l 450 1 associated with categorizing each system, and it made
,s 2 X number of dollars. South Texas I'm sure could provide
< \
3 you those figures. They can then extrapolate over the 4 remaining life of the plant how much they anticipate 5 saving by imposing reduced QA controls.
6 MEMBER CATTON: Oh. So when you say cost 7 benefit, you're not referring to the risk side of the 8 equation at all. Okay. I misunderstood.
l 9 MEMBER SEALE: Yes. But let's take this one 10 step further. Suppose the utility decides that the honor 11 is not worth the ride and --
12 (Laughter.)
13 Okay? And so now, as Gary says, it comes back
(, '1
\~/ 14 to the staff to figure out how to find these kinds of 15 requirements, or impose them if you will, in a different 16 way. I think you then have a cost-benefit problem to 17 resolve, don't you?
18 MR. HOLAHAN: Yes, you do.
19 MEMBER CATTON: And if we refer to his 20 condensate pump, what if I argue changing the QA will not 21 change its reliability one bit.
22 MEMBER SEALE: Yes.
23 MEMBER CATTON: So why the hell do I have to l
24 do it? It won't change it.
,y
() ,
25 MR. HOLAHAN. Well, all you have to do is look NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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451 1 historically at the kind of things that the NRC has fx 2 backfit. I can't remember even one example where the NRC N ']
'~
l 3 said there's a -- found a particularly important piece of l 4 equipment, and what it needs is more QA. That was our i
5 backfit. I don't think it has ever been done.
6 As a matter of fact, quite to the contrary, 7 when we have done backfits, like station blackout rule and l
8 ATWS, we generally haven't said that you have to put the I 9 whole level of Appendix B QA requirements on those. They l
10 are usually done in the selective way that seemed to make I 11 sense for that particular application.
12 MEMBER CATTON: Well, that's the point. That 13 makes it all the more important to draw the utility into l
[, s\ t \
t
\ 14 this in a voluntary way.
15 MR. ABBOTT: Well, I don't disagree with what 16 you said. But if you look at the ATWS rule, I'm sure all 17 of the equipment that was backfit to meet the ATWS rule is 18 on the Q list.
19 MR. HOLAHAN: Well, that would be a surprise 20 to me, because that's absolutely contrary to the guidance 21 that the NRC put out.
22 MR. ABBOTT: Well, is it on the Q list, or 23 isn't it?
24 MR. GRAMM: The augmented quality programs for
/~h
() 25 ATWS, SBO, and fire protection, do not explicitly need to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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452 1 be on the safety-related Q list.
,-g 2 MR. ABBOTT: All right.
( )
3 MR. CARROLL: ATWS is a bad example, because 4 the rule would never have been promulgated if we were in a 5 risk-informed mode at that time.
6 CHAIRMAN APOSTOLAKIS: Anything else?
l 7 MR. HOLAHAN: I don't want to assent to that l 1
1 8 just because I didn't answer it. I think if we did the I 9 analysis over again today it would come out different, but 10 we've learned a few things since then.
11 CHAIRMAN APOSTOLAKIS: Okay. ;
I 12 MR. HOLAHAN: Control rods stick a little more 13 often than we thought.
C) 14 CHAIRMAN APOSTOLAKIS: Thank you very much, l 15 gentlemen. !
16 We'll take a 20-minute break. ,
l 17 (Whereupon, the proceedings in the foregoing 18 matter went off the record at 10:30 a.m. and 19 went back on the record at 10:53 a.m.)
20 CHAIRMAN APOSTOLAKIS: Okay. Now we'11 hear 21 from one of the pilot plants, Mr. Grantom and Mr. Martin 22 from South Texas Project.
23 Rick?
24 MR. GRANTOM: I'd like to start out, first of (3 all, I heard a lot of the discussions here yesterday and
\ ) 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 PHODE ISLAND AVE., N.W.
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453 1 today, and I appreciate the efforts that the staff has 7_x 2 done. I know that some of this stuff is difficult. It
'~
3 causes a new thinking process to come in play, and it's 4 not always easy. Of course, on the other hand, sometimes 5 I ask myself why it's so hard also.
6 But then again, it's difficult to change 7 mindsets and cultures that have occurred over a period of i
8 time. But we're bere today to talk to you not only about l l
9 graded QA but an overall perspective on risk-informed and l l
10 performance-based regulation.
1 11 Part of the reason that we feel that we can l l
12 provide a perspective to you is we've had quite an 13 extensive history in PRA -- 14 years of monitoring and r^x :
! ) i
\m/ 14 participating in risk-informed programs, even though at l l
15 the time back then we didn't call it risk informed. We 1 16 thought we were providing a risk-based effort. l i
17 We have an SER on a Level 1 PRA that was used '
18 in our technical specification, so we feel we have a i
19 quality PRA and would meet all of the requirements of a )
20 quality PRA. Our early risk-informed performance-based 21 applications were approved, but they required extensive 22 reviews.
23 We had extensive review of our PRA internal 24 events and fire events that was documented in the NUREG, q
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454 1 of the very first original reviews of AOTs and STIs. It 7, 2 took about four years to get accomplished, and we maintain
( )
3 an ongoing investment in our risk-informed technology.
4 As part of this risk-informed technology --
5 CHAIRMAN APOSTOLAKIS: Move it higher, a 6 little bit. Thank you.
7 MR. GRANTOM: -- we've implemented a means by 8 which to facilitate that by a comprehensive risk 9 management program. And our comprehensive risk management 10 program has an expert panel, and it's a little bit 11 different than what you may have heard about before with 12 expert panels. We realized early on that we had a 13 maintenance rule expert panel, an MOV expert panel. We I
\
l \/ 14 had a risk-based IST expert panel. We had expert panels 15 everywhere.
16 But in order to address and assess the 1
l 17 aggregate effects and cumulative effects, what we really 18 needed was an expert panel that got to review and see all l 19 of those risk-informed performance-based applications. So 20 we have a comprehensive risk management program that's l
21 governed by plant procedure that incorporates a high level l
22 expert panel and for which we have working groups that 23 perform activities for that expert panel. l I
24 We recognize -- and the reason for those types
((~N,) 25 of programs is the fact that we do recognize that we can i
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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455 1 improve safety level and costs with risk-informed and g- 2 performance-based programs. We have about five
- ~
3 applications that are either submitted, waiting to be 4 submitted, or in progress.
5 Now, I've got some other items that are 6 scheduled to be submitted in the near future. I've got 7 graded QA that's submitted, and I have an improved tech.
8 spec. submittal that's sitting there which uses risk-9 informed information. I have IST, and I have an 10 Appendix J item that are sitting there waiting. And have 11 MOVs that are in progress right now -- all using risk-12 informed and performance-based methods.
13 I have some others that are in the queue that
\-) 14 are waiting to be scheduled, but I want to let Lawrence 15 allude to here in a minute. There are some reasons that 16 we've had to rethink that.
I 17 MR. CARROLL: Tell me about this super expert l I
18 panel. What are the kinds of people that are on it? l 19 MR. GRANTOM: Those are normally like plant 20 managers -- is on the expert panel. We have the manager 21 of industry relations there. These are all senior 22 management folks, department-level managers. We have 23 collectively over 150 years of nuclear experience between 24 all of us that sit on there. I sit on the expert panel.
(_) 25 The licensing manager sits on the expert panel. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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456 1 quality manager sits on the expert panel. Like I said,
,S 2 the plant manager and the system engineering manager sits
\
\' /
3 on the expert panel, as well as the design engineering 4 manager.
i 5 MEMBER SEALE: A total of how many people? j l
6 MR. GRANTOM: About seven or eight. How many I 7 did I just nam??
8 MEMBER CATTON: You don't have any outsiders? ;
1 9 MR. GRANTOM: No outsiders at this time, 10 although we have given consideration to having some other 11 person come in. It's not quite like an NSRB at that 12 point, but we do have an expert panel at that level.
13 CHAIRMAN APOSTOLAKIS: What is your official I '
i
\/ 14 title of the company?
15 MR. GRANTOM: I'm the Administrator of Risk 16 and Reliability Analysis. That's my official title.
17 CHAIRMAN APOSTOLAKIS: Larry Martin?
18 MR. MARTIN: General Manager, Nuclear 19 Assurance and Licensing.
20 CHAIRMAN APOSTOLAKIS: Thank you.
21 MEMBER CATTON: So you administer risk.
22 MR. GRANTOM: Yes.
23 (Laughter.)
24 Risk and reliability analysis. Yes.
(~
(_)\ 25 MR. CARROLL: A little risk here, a little NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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457 1 risk there.
73 2 MR. GRANTOM: Well, and that's just it,
( )
3 comprehensive risk is -- there's more than just nuclear 4 safety risk involved. And we try to look at all of those 5 aspects. So that's where we're at. !
6 But we've had to rethink our schedule here l 7 recently, because I don't how many of these risk-informed 8 performance-based applications we can submit and have hope 9 of actually getting implementation on them, which is one 1
I 10 of the things that we want to really focus on here today.
11 We've heard a lot of good things about what l 12 the efforts are, as far as putting together risk-informed 13 and performance-based activities here, but it's the l r~x '
l 1
\s / 14 implementation side of this thing that I haven't heard a 15 whole lot about, exactly how we're going to implement and 16 what we're going to be allowed to implement. And we are 17 expending significant resources on producing these 18 applications.
19 We also expect we're going to have significant 20 gains if we are, in fact, granted the opportunity to 21 manage risk at these stations.
22 MEMBER FONTANA: I'm just curious.
23 Significant resources, in manyears, what does it look 24 like?
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458 1 this is a troubling trend, too, that I think you need to 2 be made aware of. I seem to be an exception because we s
'~'
)
3 have been successful before at showing gains by using 4 risk-informed information in PRA. I have a management 5 that appreciates and recognizes the benefit of it. I have ,
l 6 a staff of about five people, I have a little bit of 7 admin. support, and I've got a fairly significant staff in 1
8 terms of a PRA group at a nuclear power plant.
i 1
9 Now, I contrast that with you with some other l 10 utilities over there who are eliminating their PRA groups. l 11 And this seems to be a growing trend right now.
l 12 MR. CARROLL: Why is that?
13 MR. GRANTOM: Well, I believe that, really,
. ,/ \
I I V 14 the reason is is because they see it as overhead that will i 1
1 15 ultimately result in some -- in additional burden rather l 16 than gains. It's just like what you said. It could l l
17 possibly cascade into more regulation instead of less.
18 And without gains, if I can't demonstrate that I'm earning 19 my keep, they're not going to keep me. It's not a good 20 business to --
21 MR. CARROLL: Not at the pre sent utility 22 climate.
23 MR. GRANTOM: That's right. Nell, we're in a l
i 24 business, and that's very real. I know several utilities f%
25 that are reducing their PRA staffs, and I can tell you
!.v)
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459 1 quite honestly that if you've got a PRA staff of two
.3
, 2 people, you have no hope of being able to apply risk-t i i /
3 informed regulation. You might be able to maintain your 4 model. Maybe. But you have no hope of actually being 5 able to produce this kind of analysis to give the level of 6 information that's requirement.
7 MEMBER FONTANA: You know, you mentioned you 8 say you're in a business, but there's a probability here 9 that it could be out of business.
10 MR. GRANTOM: That's true, too, and that's 11 what we're trying to --
12 MEMBER FONTANA: And that could be addressed 13 probabilistically, too, you know.
,\
! )
't/ 14 MR. GRANTOM: Absolutely.
15 MEMBER FONTANA: With some reach.
16 MR. GRANTOM: I don't know that it's so much 17 of a reach, because really when you look at PRA, and 18 particularly in something like graded QA, what we're 19 really doing is we're reevaluating commitments and 20 requirements. And you're finding out that E. Jot of 21 commitments and requirements give no benefit to the health 22 and safety of the public, or to the health and sately of 23 our own plant personnel.
24 So you ask yourselves the question: if we're
,rh
(
U) 25 not given the risk consumers anything for a particular NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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I 460 1
1: application or a.particular regulation, then we probably
!g 2 are doing something adverse to them. And it's that s
1 3 correction that we're trying to accomplish here, and it's 4 difficult to change some of the institutional and cultural 4
5 efforts that have-to occur here in order to make that i
- 6 happen, i
4 7 But really, that's in a sense what the risk
.8 assessment is starting to show. ~ And we can all sit here
- 9 and talk about, well, there's parts of-the things that are 10 modeled in PRA, there's things that aren't modeled in PRA.
11 We certainly recognize that. That's why we tried to 12 institute-this concept of expert panels.and bring into 13 blended approaches the risk informed, the performance
.14 based. And in my experience, it has been seen 15 particularly with the recent MOV study.
16 It has a tremendous and a very, as I heard 17 before, elegant type of solution to managing risk and to 18 optimizing safety over a large class of components, when 19 you blend those two things together. In isolation, either
'20 one of them isn't nearly as good and has pitfalls. But
'21 blended together, they work very, very well together. So 22 we're trying to do-that is really what we're trying to do.
23 There's a lot of -- appears to be barriers.
24 There is'a lot of moving and effort in the 25 form of these reg. guides and standard review plans. .But NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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l 461 1 I think that we've gone through a decade now -- 14 years 2 now -- of doing this, and we've produced a lot of V'
3 information that could allow some experimentation, some 4 efforts to see what works best, but it's very difficult to 5 get those because you have to gain approval to do those ,
I 6 types of things.
i 1
7 I'd like to give you just a little bit of a '
8 background. We heard yesterday about the technical 9 specifications. In 1993, we did a comprehensive tech.
10 spec. review. And the reason I want to bring this up, il quite frankly, is that during that time we revised allowed 12 outage times and surveillance test intervals. Along with i 1
13 those surveillance test intervals went the associated Ik-) 14 relief request for changes to the code. We're involved 4
15 right now in risk-based IST, and then sometimes I look at 16 this and I think to myself, you know, we did this in 1993.
17 We, in a sense, did the pilot, and we have 18 this experience of what's needed. In 1996, we did a 14-19 day tech. spec. for our diesel generators, which once 20 again we kind of had to go and reinvent the wheel again it 21 seemed. We extended our methodology and our technology to 22 be able to do risk profiling, and risk profiling in terms 23 of configuration risk management, where we can actually 24 take a look at how -- a snapshot of how is the picture
( ,/ 25 configured at this hour, and how does the risk change NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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462 1 based on defense in depth, what equipment is in service
~s 2 and out of service at that given time.
t \
]
3 So, you know, now we're able to actually 4 estimate configurations that are high risk, we're able to 5 actually produce compensatory measures that can be 6 addressed and put in a particular point in time to help 7 minimize the risk.
8 Now, when this thing went through -- and I 9 think you heard something about it yesterday -- it started 10 out as a 21-day special test exception, and this kind of 11 gives you an idea of what happens when you put an analysis 12 out here like this that's risk informed and performance 13 based. We went through the effort of a 21-day special
~s
- 8 1l 14 test exception. We went through several RAIs.
15 It was my experience in this particular item 16 that it was a situation where they wanted a deterministic 17 justificaticn. Even though there was the risk profiling, 18 there was the risk information, there was all of this 19 technical quantification information there, they were 20 still reluctant to grant it based on the risk assessment 21 itself. They wanted a deterministic reason.
22 We went back. We provided the deterministic 23 reasons of why we felt we could do this. This went up 24 through EDO at that point in time, and it came back down
, /~
(w/ ) 25 to us and said, "We aren't going to grant a special test NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISI.AND AVE., N.W.
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463 1 exception. We'll give you an allowed outage time." Me 7, 2 being a risk person, I viewed that as kind of a blank l \
V 3 check. Special test exception, once per cycle per diesel, 4 but now you're going to give me an AOT that I can use any 5 time.
6 So when I see things like that, I feel like 7 there's something missing between the Commission and the 8 people doing the reviews of exactly how risk-informed and 9 performance-based methods work. How do you really 10 optimize safety and do t. hose types of things using those 11 tools?
12 So we recast it, answered the deterministic 13 questions, and then I got the feeling that risk informed
/m I i C/ 14 was really a deterministic analysis with a sprinkling of 15 PRA. We're going to grant you this based on it 16 deterministically, and it's nice that the PRA said it's a i
17 good thing, too, and not the other way around.
18 Now, I don't necessarily disagree with that 19 approach. I think a blended approach is important to do.
20 I think you've got to look at the performance, you've got 21 to look at the deterministic aspects, and that's what we 22 use the expert panel -- and that's how we try to answer a 23 lot of these things.
24 But again, I want to emphasize I feel that the
() 25 blended approach is the proper way to do it. One without NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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~ - - . . . ~ - - . . - . - . .. - ~.. - . . . - - . ~ - . . - . - - - - . . . - - . - .
3; ^
'464 1 the other is not nearly as optimal and may, under certain k
2 circumstances, be adverse to' safety.
]O
- 3 ' CHAIRMAN-APOSTOLAKIS
- Now, do you think, a
{ 4 though, Rick, what was missing was the SRP_ documents and
. 5 the regulatory guides that we have been discussing the 1
, .6 last-day and a half, that after these are in place perhaps-
. 7 this gap between what the Commission wants and what the ,
~
8 reviewers are doing will not be a gap anymore? Did you '
.9 get that impression? I know you haven't read them, but --
10- MR. GRANTOM: Yes. Well, I haven't read them.
11 But I would like to think that that-is going to provide a i 12 path by which one.can determine what are the tasks that we 13 have to do in order to go from initial -- beginning of an !
). 14 application to the end of an application. What concerns ,
t.
15 me that I haven't looked at them.i's as we said before, you .
16 know, the devil is in the details. And we see i
4 17 paraphrasing up here on'these slides, and stuff like that, ,
l I 1
i 18 but I really don't know what they say at that point.
i 19 What I would really hope is that there would
{.
s 20 be a streamlined process after the reg. guide is put out 21 that, you know, if you march down this path here, you have
- 22 a streamline process by which'you can go from starting an d 23 application to implementation at that point in time.
- 24~ What I get concerned about is that the
- .W-
! -([ 25 interpretations of what's said in a particular area in the l
- NEAL R.' GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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_ __ __ . u . _. . . . - . _ . ,
465 1 reg. guide are then fraught with additional RAIs and
(
> 1 N ,! MOVs, we're using the PRA information to determine, you 3
i 4 know, what are the effective failure modes that have to -- I 5 that the MOV has to perform.
6 We're also using a blended approach where we 7 determine the deterministic margins of those valves --
8 steam factors, degradation factors, the uncertainties that 9 go in there. And those have been worked out to the 10 various folks who are experts in those systems, and we 11 blend those two things together to come up with a l
12 suggested test frequency and a suggested test strategy, 13 I believe that we have some issues that we'll i \
\s / 14 have to discuss about the test strategy. There will be 15 some that might feel that you can't use PRA to adjust the 16 test strategy. I feel adamant that if you don't use the i
17 PRA to adjust the test strategy, once again you may cause 18 situations that may be adverse to safety.
19 MEMBER CATTON: Just out of curiosity, how are l 20 you going to deal with this failure to close under full l 21 system pressure?
22 MR. GRANTOM: Well, in many of those kinds of 23 cases like that, that's one of the areas where they've 24 gone back and done calculations to determine what the
,,~r
( ) 25 deterministic margins of those valves are. In the case l NEAL R. GROSS l
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l
473 1 that we're looking at, if that comes up with a low
,_s 2 deterministic margin, and it maybe has medium or it's up
! \
3 to high PRA importance, that gets lumped into the full 4 thing, full diagnostic, full static testing. And as 5 research and industry tells us more, those things will be 6 incorporated accordingly. l 7 The other part of those -- and mispositioning 8 is the other issue that may be out there also. Those are 9 human errors and in my cases are errors of commission.
10 There are standards that when a valve is mispositioned you 11 know it, based on annunciation in the control room. You 12 may know it in other areas. So there are some issues and l
13 stuff about that. l
/~S e 4 l
(_/ 14 And I'm not saying that there's a closed I
15 issue, but this is providing a tool that provides an input j 1
16 to like an expert panel, and that says, "Here is what the l 17 analysis from the deterministic margins show. Here is 18 what the risk margins show. Here is the blending. Here 19 is a recommendation on what the testing frequency and 20 strategy should be for these valves." You know, this 21 isn't a little thing. This is an exhaustive and extensive 22 review, a component by component of these things and 23 making an informed decision about it. To me, it is the 24 essence of risk-informed performance-based regulation.
rm (v ) 25 But the generic letter and the new code cases NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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- ~ ~ . . - -
l: !
474 1 that are being worked'out recognize-that. But will you 2 actually be able to use it to adjust the test strategy? H 3' Because in some cases, we may say that exercise only is ;
'4 -
sufficient for a valve,= because it may be a normally open 5 MOV that just has to stay open under accident conditions. !
6 If it were closed, we would know through annunciation )
l 7 immediately that there was no flow. ;
I 8 Now, one can go and postulate that, you.know, -!
l 9 the light is burned out in the annunciator. I mean, we' 10 can go carry this,and model the world if we have to. But I
11 in PRA, we have to cut it at some point in time that's l l
12 reasonable. l l
'l 13 So those types of things are out there,. and I l i
^l
'4O 14 can kind of see that on each one of these steps -- and it l l
15 goes back -- what I'm trying to indicate to you is that !
16 every one of these applications has a tortuous path from 17 birth to death in a sense right now. I'm hoping with the l-18 reg. guides that it does tend to streamline it out, but I 19 just have to hope that right now.
20 I'd like to give you just a little bit of some 21 of the status of some of the things'that we've seen out 22 here. Our current risk-informed and performance-based 23 applications here and at other stations indicate some l l'
i 24 areas of concern. I'll have to admit that after hearing
- ()
25 yesterday and somewhat today that I personally feel a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W. ,
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475 1 little more comforted that there are active efforts
,3
, 2 involved, but I do see that there is still some general
-: 1 Y^./ 3 traits that I notice.
4 It appears to me that lessons learned from one 5 application doesn't necessarily translate to another 6 application. When I did the 1993 tech. spec. study, I had 7 to go through a fairly exhaustive path. When I did it 8 again this last year, I had to do it again.
9 MEMBER CATTON: When you say you have to do it 10 again, do you mean you can't reference the documentation 11 on the first effort, or you don't have sufficient 12 documentation? I mean, I don't understand where the -- I 13 mean, if I have a report that covers something, why can't p
'u) 14 I use it twice?
15 MR. GRANTOM: Well, you can, and we did ;
i 16 reference it. But it wasn't used very much, but I think i 17 there are some good reasons that it wasn't used. We 18 changed the methodology in a sense. Back in '93, we did 19 delta CDFs. This year, we did risk profiling, we did 20 cumulative risk. We did a configuration risk.
21 MEMBER CATTON: When you do these things, do 22 you document them well?
l l 23 MR. GRANTOM: Absolutely. I feel absolutely 24 we do.
,o
(,) 25 MEMBER CATTON: Lots of verbiages to support a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i 1323 RHODE ISLAND AVE., N W.
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476 1 particular position.
s 2 MR. GRANTOM: Well, let me address that a 1 i
.i / l 3 little bit, for example, in the configuration risk area. l 4 Back in the '93 effort, we handed our models over to the l
l 5 reviewer, a team of Brookhaven folks. We handed the model 6 over. You do the sensitivity study; we do the sensitivity l l
7 study. Did you get the same number we did? Do you agree l l
8 with the approach? And that worked very well.
9 I, and we, have always been willing to give 10 you the model. If you have questions and concerns about I
11 our PRA model, I'm willing to hand it to you and we'll 12 work together on it, and your opinion is as good as mine l 13 on how you want to manipulate that model.
! b k/ 14 So it gets documented in that sense. Every 15 one of our submittals has been a fairly thick submittal.
16 When you look at the RAIs that get produced, there is, you 17 know, 20, 30, 40 pages of response that comes to those 18 RAIs.
19 MEMBER CATTON: Was this included with your 20 submittal? I mean, when you're finally done, and you have 21 a document, are those RAIs a part of that document?
22 MR. GRANTOM: Yes, they're a part of it. They 23 go into our permanent file system and they're grouped 24 together. So we have all of that together, and we have a
.m
( ,) 25 program, and we've even gone through and proceduralized NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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477 i 1 the' program. Configuration risk management is a procedure ~
l 2 at South Texas. !
~
I
-3 MR. CARROLL: Your point is that they keep '
4 changing the rock they want you to bring them, 5' MR. GRANTOM: Well, I just noted that with the
-6 improved tech. specs., I've got a procedure on 7 configuration risk. It's already in the tech, specs. in 8- the admin. section, but I'm going to get told under the 9 approved tech, specs. that I can't'go-and~ evaluate the l
'10 remaining systems allowed outage times. I'm going to.have 11 to make another submittal for that, because it's'out of I
.12 the scope of ITS. And it is.
- j. 13 I would agree with them that, yes, they are 14 trying to cookie cutter. They know all of these plants. -
15' That piece of it is out of the scope. How that gets
- 16 reviewed and incorporated could be quick, could be slow.
17 I don't really know what to expect out of it.
18 I do think that technically it's a l I
19 tremendously robust approach. 'It covers all of the I i
i 20 integrated combinations of different systems. .I have {
21 2,900 completely quantified Level 1, pre-approved, 22 archived calculations of different system configurations.
l
- 23 Those translate, when you look at dependent systems and t
t-2 :24 other things -- there is like 48,000.different i 25 configurations.
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478 1 So, I mean, I've got a program to do that, and
,_s 2 I've calculated all of these AOTs. The problem that you j
/ T l
\ !
~ ' 3 get into is when you take out one particular system, and l l
4 you do it in the same format that the tech. specs, are in, l 5 the tech. specs. are system by system. It takes out --
I 6 take one train of containment spray out. When we take 7 that one train of containment spray out, it might be five 8 years before you accumulate enough risk to mean anything.
9 But that's because of the role containment spray plays.
10 You take out one train of the safety-related 11 cooling water. That's different. That's, you know, two 12 days maybe. A terry turbine is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. You know, and 13 you try to adjust your AOTs that way and produce a
,\
l )
(_/ 14 backstop. And unless you manage the configuration of 15 these things less than that, well, that's a step beyond 16 where they're at right now. But we're ready to go there, 17 and there are several of us that are doing risk monitoring 18 and those types of things that are ready to take that l 19 step, because we see benefits and we realize it's a safer 20 way to do business. I 21 MEMBER CATTON: I missed earlier -- how many 22 people are working on these sorts of things? I mean,. what 23 is the size of your staff that is --
24 MR. GRANTOM: My staff -- I have a staff of
! j 25 five, and I have some contractor augmentation that I use, v
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l
479 1 And that's why I was alluding to the fact that if you find i ,mx 2 out somebody has a PRA staff of two, I don't believe they
(
r u'~j 3 have much hope.
4 MEMBER CATTON: I heard that part of it. I l
5 just didn't hear how many.
6 MR. GRANTOM: About five.
7 MEMBER CATTON: Okay.
8 MR. GRANTOM: And I have an open position, 9 too, if anybody knows of anybody that's --
10 (Laughter.)
1 11 MR. CARROLL: Ivan? ,
12 MEMBER CATTON: I need all the help I can get, I l
13 Jay. i
'/ 14 MEMBER POWERS: Well, Ivan, the other day you l 15 did say that shutdown risk would be easy to model.
16 MEMPAR CATTON: Yes, no problem.
17 Mit. GRANTOM: With regard to the graded QA 18 process, we've been marching along this path for about two 19 years now, and risk-based IST has been moving for one and 20 a half years. I realize there is challenges for the staff 21 to produce these risk-informed and performance-based 22 regulations in these reg. guides and standard review 23 plans.
24 There certainly has been challenges in that,
./ ^ ',
s , ) 25 but it certainly doesn't seem to me that -- it certainly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i ll 480 o i 1 ceems that we could have probably done this a little bit !
7-m 2 faster had we had some of the more pilot involvement in
\
~
3 putting together some of these things. I also feel like 4 there were some opportunities that have been missed now to 5 get lessons learned and good practices from having pilot 6 plan involvement, because particularly with graded QA, we 7 wanted to get data on what's the correlation between 8 quality controls and reliability.
9 Let us try it for a year or two on some low 10 risk significant systems. Let's see if there is 11 something Let's try to get some data. But we can't get 12 to that hurdle to do those things, to get some empirical 13 data, to find out what works best. So what's the type of
- 3
/
\'
1 14 monitoring program that works well? Those kinds of things 15 are opportunities that I feel like we're missing and 16 consideration should be given to look at that. ;
17 IST is another example. Try something j 18 different. Allow somebody to do something and get some 19 data to make an informed decision about these things.
20 So the result of kind of what I've seen in 21 some of the pilots really leads me to believe, in some 22 cases, that they've continued Lo emphasize the 23 deterministic criteria and deemphasize the risk criteria.
24 I think a lot of people are more comfortable with that. I q
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i I
481 'l i
1 go with the knowledge and level of awareness of what is 2- involved in a PRA.
!O l 3 And I think if more people understood that 4 this is an analysis that extends the deterministic l 5 engineering work that you've done for years,.it shows the ;
i l
6 integrated effects of all of those deterministic j
- 7 characteristics of the equipment together, and usually ;
1 8 after you get through this for a while the light comes on- i i
.9 with folks and they start to see that, j s
10 I see that in the.second bullet here -- and I l
.i1 11 want to emphasize that we're perfectly aware of what our !
I
- 12 licensing basis and design basis is, and we intend to 13 adhere to those. But our experience over the last 14 l
i - ;
l' 14 years, in looking at these things -- and I've cited a 15-- couple of examples here -- is.let us to see that there are 16' regulations and' requirements that are marginal.to safety, l
-i r :
l 17 and.under cert nn conditions can be outright adverse to 1 18 safety. l L 19 So those kinds of things, when I look'at that 20 as a risk person, I get a little skeptical and I-ask ;
21 myself, why is this so hard? You know this information.
22 You can see this. It seems like you would be rapidly 23 trying to go and do things that would improve safety. The
[
- 24 problem with that is I think what we hear is they're going 25 to improve safety by adding a lot of.-things. But when you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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l
3 482 I 1
1 look at the non-safety contribution of things that don't p
~ 2 matter, they're not taking into account the additional
~~'
3 risk that's associated with diluting your resources for 4 those items that don't have any safety impacts.
5 Now, when you do that, and you're really 6 trying to apply more, I think if you really looked at the 7 non-quantitative things and looked qualitatively, you 8 probably would be increasing risk. And I don't think 9 that's the way we want to go.
10 MEMBER CATTON: I think in another area that's 11 what has been found. But the big problem is shift from 12 deterministic to risk is a difficult one.
13 MR. GRANTOM: It's a difficult one, and I k/ 14 think you need to --
15 MEMBER CATTON: In some countries, for 16 something much less than a nuclear power plant, it took 10 I
17 years. l 1
l 18 MR. GRANTOM: Well, you kind of see it all the ,
1 19 time. I get guys from our balance of plant, and they know 20 other guys that work down the road there at Selenese and 21 they say, "How come we can't do what those chemical boys 22 do?" They make a commitment to say they're going to have 23 a system available and reliable X percentage of the time.
24 Their merit is on the line for that. And they don't care
/%.
(,) 25 what they do as long as those systems are reliable and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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483 l
1 available that period of time. Now --
p- 2 MEMBER CATTON: Yes. But the period of time
! ! i i f l 3 is much less. It's --
)
4 MR. GRANTOM: Well, I don't know exactly what 5 their -- ,
6 MEMBER CATTON: It's quite a bit different.
7 MR. GRANTOM: -- requirements are, but I think 8 I can maybe do that for things like pot water and a few 9 that balance of plant systems, demineralized systems. I 10 probably certainly wouldn't want to do it for some of the 11 more safety significant things. We're going to have a lot 12 higher level of controls for those things, and we're not 13 proposing those types of things.
i i (m/ 14 But when you start looking at parts of the 15 reasons of why we do what we do when you look at 16 commitments and requirements and how those translate into 17 regulations, and it translates into commitments that we've I I
18 made to satisfy those things, one does start to ask I
19 yourself questions of why is this component cooling water 20 valve, you know, require so much level of effort to 21 satisfy the requirements when I've got a steam generator !
1 22 pore block valve that's much more risk significant. I 23 don't have to really do anything for that other than i
I l 24 maintain it for the most part.
,3
()
25 So these dichotomies come up and they're very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 484 l 1 real for the most part. And trying to find a way to deal
,m . 2 with them, where you're not just adding additional burden, j
- 1 t
/ 1 3 because I think that's one of the characteristics of why i 4 you're seeing some utilities reducing the staff, because 5 they're thinking -- and I think in some cases -- that PRA 6 is a means to bring the balance of plant into Appendix B.
7 PRA is the means by which we're going to add 8 all of these other controls. Yoa'd better get through the 9 PRA group, because those are going to be the guys that are l 10 unknowing and unwilling participants in the expansion of 11 *his thing.
. And I've been trying to try to always provide )
l 12 information to the contrary that no, if you're armed with 1
13 a good analysis -- and I've got experience to date that p 4
(
ks' 14 shows that the NRC does listen to good analysis when you l
15 give them the proper information. They do. !
1 16 I've got tech. specs. to prove it. I've got 17 examples where they have actually relaxed areas, but I 18 don't think everybody has that flavor and that example of 19 that. And some of it's -- maybe it's because they don't 20 invest in their PRA.
21 But a lot of them will sit there and tell me, 22 "Well, Rick, I don't want to be the first. I just want 23 you to go do it because you've already got . hat Cadillac.
24 And, you know, if you've got to do it, than that will just
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485 1 do." But I think if they really saw the economic benefit
<s 2 of what happens when you do a PRA, because PRA analysis is
! \
N.) 3 peanuts compared -- the cost of that is peanuts compared 4 to 20 or 30 years left of a plant in getting a relief in 5 particular areas. It really is.
6 But the thing that we get hung up on sometimes i
7 is, well, you know -- and I've heard this before from the ;
l 8 highest levels of the PRA -- if it's wrong, you need to go 9 change it. Get the rule changed. Get an exemption. But 10 those are monumental efforts. And to go and do that is l 11 huge, and it's not an effective option for us to go effect l l
12 a rule change, l 13 I have yet, in any of these conversations,
/T ,
52 14 ever heard the NRC come and say, "That's a bad rule. We 15 need to go and change it. We're going to go initiate 16 rulemaking to go make this better and reduce the burden, 17 because we know that it's not safe." I haven't heard that I i
18 yet.
19 MR. CARROLL: Could you even venture a guess ;
20 as to how many -- what percentage of the nuclear utilities l l
21 are downgrading --
22 MR. GRANTOM: Well, let me put it to you this 23 way. Let me give you the number of utilities that I think 24 are really actively involved in trying to improve,
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486 1 ourselves, certainly some of the pilots that you've listed
(~x i 2 here, but Southern California Edison, South Texas. Texas e
V 3 Utilities did have a very good group. Actually, Millstone 4 had a good group. Yankee guys have a good group. But I 5 don't know exactly what's going to happen with those, but 6 those are the only ones that I really do --
7 CHAIRMAN APOSTOLAKIS: How about Diablo? Is 8 Diablo doing anything?
9 MR. GRANTOM: Diablo has a fairly good group I 10 think, so yes, they are. But with that --
11 CHAIRMAN APOSTOLAKIS: Seabrook, yes.
12 MR. GRANTOM: Seabrook has a good group.
13 There's another one. But those are about the only ones
,I l
)
' 14 that I know of that are really maintaining, promoting --
l 15 CHAIPMAN APOSTOLAKIS: Chicago Commonwealth l 16 Edison, are they active in this? They've done two or 17 three major PRAs for Zion.
l 18 MR. GRANTOM: Well, I know they've done that, r
19 but I don't know how well or how active they are in moving .
l l
20 the technology. So how many of those did I name? You 1 i
l l 21 know, five, six, seven of them, out of how many utilities 1 l
22 have we got out there?
23 CHAIRMAN APOSTOLAKIS: Duke Power.
24 MR. GRANTOM: Duke Power is good.
(_,/ 25 CHAIRMAN APOSTOLAKIS: Duke Power is --
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l 487 1 MR. GRANTOM: Duke Power is good.
- 2 One characteristic you will see a lot of l ' 3 times, and sometimes they will have a PRA group that has 4 got a central office -- and this is kind of an 5 organizational issue here, too. I think PRA works best 6 when the PRA group is at the site. When you have a 7 central office and you've got one guy sitting over there, 8 well, it doesn't seem to work as well.
9 But I have heard, you know, rumors of these 10 several -- the Perry plant has like one or two people in 1
11 their PRA group, and there are several that have just one 12 person or two people. TVA, I've gotten calls from those 13 folks, and it's just not -- doesn't seem to be a trait f 4
\/m 14 that everybody is building those up.
15 MR. CARROLL: You do recognize that being a 16 pioneer does have its burdens, light?
17 MR. GRANTOM: Yes, it does.
18 MR. CARROLL: I remember being taken by an 19 Ivan Selin comment that the problem with being a pioneer 20 is you end up with arrows both in your front and your 21 back.
!2 (Laughter.)
l 23 MR. GRANTOM: Yes. When I walk out of here, 24 I'll have some arrows in my back.
A
't ,) 25 (Laughter.)
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488 1 CHAIRMAN APOSTOLAKIS: There is also a certain
,_s 2 glory that goes with it, too.
I T 3 MR. GRANTOM: Yes. Well, what did he say?
4 I'm not worth the ride or --
5 (Laughter.)
6 MEMBER MILLER: We've gotten a number of good 7 quotes today.
8 MR. GRANTOM: That was a good one. I'm going 9 to remember that one.
10 Just a couple of other things, and I've 11 alluded to them before. When you try to look at 12 performance-based information, absence of risk 13 information, or vice versa, risk information without
\/s 14 performance -- and I mean this in deterministic methods 15 also -- you really can fall into -- you can really have 16 some pitfalls that can occur with that approach. I think 17 you really need to have both of them.
18 I don't know who came up with the blended l 19 approach. I don't really know. But I think it has turned 20 out to be, as I've gone through examples and applications, 21 a very good way to do these things.
22 Conclusions are pretty much simple, and I 23 think there is evidence that bears it out in the industry.
- 24 We do still expect to see schedule extensions. Reg.
r^3 25 guides will come out in '97. It takes us six months,
! x!
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489 1 eight months to produce an application. It will take --
es 2 and then here is the unknown. I don't know whether now, l )
'~
3 after we produce those applications, is that a three-month 4 turnaround, or is that a year turnaround? So we could 5 easily be, with some uncertainties, talking about the 6 '98/'99 timeframe; by the time we implement, 2000, '99.
7 So the cost versus the expected returns are 8 going to continue to be uncertain. And you may see a 9 cycle where the PRA group is going to go down, and then 10 maybe after they see something then they'll try to build 11 them back up again. So that's it.
12 MEMPER FOWERS: None of these observations are 13 inconsistent with any kind of first-of-a-kind engineering
, a
/ 14 effort. I believe I have quoted before the Rand studies 15 that found that typically first-of-a-kind engineering 16 efforts cost twice as much as anticipated at the 17 beginning, and produced results that were only 80 percent 18 of the expectations at the beginning.
19 MR. GRANTOM. Well, I guess with these 20 applications, if you can consider those first, but then I 21 would consider the configuration risk management stuff 22 that we did, that was in a sense first of a kind -- to be i
23 able to produce risk analyses at that level. But PRA, I 24 don't know that that's first of a kind. But certainly in n
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i l
l 490 1 believe you're exactly right, that there is some overhead 7
s 2 associated with being first.
, i I L) 3 MEMBER POWERS: It may not be an overhead l 4 that's exclusive to he who is first. At least in the Rand 5 work, they defined a first-of-a-kind engineering effort as 6 anything that your particular organization had never done.
7 That it didn't matter if some other organization had done 8 even the identical thing. That when your particular 9 organization -- and it was a first of a kind for you --
10 then you bore this tendency to overrun anticipated costs 11 substantially and to underrun expectations by a measurable 12 amount. I don't think the underrun in expectations was 13 nearly as big as the overrun in cost and time.
( )
I/ 14 MR. GRANTOM: Well, that's probably a little 15 bit of the source of why there is some reluctance in the 16 industry to embark upon this, because there is that 17 uncertain about a return, and how many years will I have l 1
18 to spend doing this.
19 MEMBER POWERS: The other point that ought not 20 be overlooked, in every one of the cases that Rand studied 21 the returns were so big that even only hitting 80 percent 22 of them was -- more than made up for the cost overruns.
23 MR. GRANTOM: That's why our management seemed 24 to benefit this --
,/--
(y) ,
25 MR. ABBOTT: Earlier in your discussion you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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491 ;
1 1
1 talked about the technical specifications, and the allowed I l
-~s 2 outage times, and how if I strictly complied with them in !
V '\ 3 a manner to suit maximum flexibility on my part, I could 4 introduce increases in the core melt frequency of a factor I 5 of 100?
6 MR. GRANTOM: Well, I was just saying there 7 are some combinations of equipment out of service that you i 1
8 could have that, but it would be perfectly legal in 9 technical specifications that when you go and look at 10 those combinations of equipment, out of service at the 11 same time have a large --
12 MR. ABBOTT: Could you give an example?
l 13 MR. GRANTOM: Yes, Terry turbine and a diesel l
,r~N '
(
\ ') 14 generator combined with a chilled water pump all can be l 15 legal. I can have them all out of service at the same l 1
l 16 time. When you go look at the combination of those --
17 MR. ABBOTT: There's nothing in the 18 maintenance rule that prevents you from doing that?
19 MR. GRANTOM: No.
20 MR. ABBOTT: Nothing in the quality assurance 21 program that prevents you from doing that? There's 22 nothing in the FSAR that prevents you from doing that?
! 23 MR. CARROLL: I think the maintenance rule 24 does --
i
<s \
\ ,) 25 MR. GRANTOM: It says -- the A3 portion of the l
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492 1 maintenance rule would say you have to assess the --
, , ,s 2 MR. CARROLL: The risk --
)
3 MR. GRANTOM: -- cumulative status of 4 equipment out of service.
5 MR. CARROLL: But that's the first time 6 that --
7 MR. GRANTOM: That's new. .
8 MR. CARROLL: That's new. 1 9 MR. GRANTOM: I mean, it wouldn't -- ,
10 MR. CARROLL: Historically, tech. specs.
11 allowed you to do some very dumb things.
12 MR. GRANTOM: Well, and when you think about j 13 those three combinations of equipment, you know, they all 7
- Y 14 lead to station blackout, either external station blackout 15 or internal station blackout through room cooling types of 16 things. So the tech. specs. don't assess the integrated 17 effects of equipment.
18 But now, you know, we're sitting here poised, 19 ready to go and do that thing, but there is another side 20 to the coin. Containment spray would tend to tell you 21 that, you know, gee, you can have it out of service for a 22 long time. Now, we wouldn't propose having it out for 23 five years, but it certainly could be longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 24 and not have any risk impact. And you see other systems
,. m
() 25 that are like that, too.
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493 1 So, I mean, if we're going to do.something on 2' one side that improves safety, but we're not going to be O '3 allowed to do something on the other side that takes
- 4. something'away or reduces something, there is not an 5 incentive -- there ultimately is not an incentive.
6 MR. ABBOTT: So what you're saying, really, is 7- you're constrained by the current format and content of 8 the technical specifications. You can't get around that 9- without some kind of a --
10 MR. GRANTOM: No. You can't get it without an 11 overall -- a complete restructuring of the format of the 12 tech. specs. The tech.-specs. are built on a system-by-l .
13 system or function-by-function basis. They don't il 14- recognize integrated-effects. They don't recognize l b 15 combinations of equipment. Configuration risk management 16 explicitly models configurations in that regard, but I'm 17 not -- I don't know when -- I think we will get there. I.
~ 18 - think that both the regulator and the regulated want to go-i 19 to there eventually. I just don't know how long it's 20 going to take to do that.
21 MR. HOLAHAN: A year or two years ago when the j l
22- tech. spec. rule was revised to have four criteria, the l l i l 23 first three: basically being deterministic design basis i
24 sort of stuff, and the fourth one being things that were j i
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l 494 1 that it should be one, two, three; one and two and three; ry 2 or four. I should put parentheses around one, two, and
)
3 three. In other words, either design basis or if risk 4 tells you it's important. Or maybe it had to be both.
5 But at the time, I don't think the agency was 6 prepared to do such a thing. And so the current rule says 7 if it plays a deterministic role, or if it's important --
8 I mean, you have to do things, too. So there is no 9 substitution of risk for design basis tech. specs. I 10 think it's something useful that maybe we could work on in 11 the future. Might be a good pilot or something like that.
12 But I think it would be unrealistic of anybody in the 13 industry to think that that would change very quickly or
/ \
\'v'l 14 easily.
15 MR. ABBOTT: Yes. But we're faced with a 16 situation where the current regulatory process, as it is l'/ currently structured, leads to the potential for having 18 plant configurations which are increasing the core melt 19 frequency by a factor of a hundred. And I don't see how i
20 anybody can find that acceptable. ;
21 MR. CARROLL: No. The maintenance rule, I i i
i 22 think -- l 23 MR. HOLAHAN: The maintenance rule provides 24 some guidance. But look, I mean, we can speculate about
'm
(,,)
25 these numbers, but the truth is the current levels of --
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495 )
1 the current PRAs reflect all of that experience. The 73 2 PRAs, which say these plants are largely around a high
- )
3 10-5ish, with the caveat that Dana will say for what was 4 analyzed, these are the plants as they operate with the 5 current tech. specs. Okay? Which means that they are 6 largely avoiding these outrageous risk situations.
7 MR. ABBOTT: Okay.
8 CRAIRMAN APOSTOLAKIS: I have -- any other 9 questions?
10 MR. MARTIN: I'd like to talk just a little 11 bit --
12 CHAIRMAN APOSTOLAKIS: Yes.
~
13 MR. MARTIN: -- before we finish here. And
'I-14 we've had some speculation today on what happens if we 15 don't go significantly more risk informed than we are, or 16 risk based. We've had some speculation this morning on 17 the value of quality assurance and what it achieves, and i
l 18 how much increased safety that that gets for you. '
19 I'd like to bring things a little bit back 20 into a real world. Rick works for me. I have to approve 21 his budgets. I have to get his budget approved every 22 year. He has a staff of five, and it's growing. The 23 reason it's growing is we see a significant possibility, 24 and, even though it's waning a little bit, a probability
(-)
( ,
25 that we're going to be able to get some payback out of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND A'K., N W.
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1 496 1 that money.
r'% 2 He alluded to staff augmentation and some
( )
v 3 initiatives that he has ongoing. We're spending about a i 4 million dollars a year. We had intended to spend about 5 $2 million a year on this. When we got into the pilot 6 program, and we were looking at where we were going with 7 our improved tech. specc., and some other things, we had i
8 some real motivators in that area. l 9 I don' t 'cnow if every one of you recognized 10 that South Texas is an outlier, okay. Yes, we're a large 11 PWR Westinghouse plant with four channels and three j 12 trains. When we originally licensed -- and I want to !
13 correct that just a minute -- 2.97 trains. Okay? Now 14 that's a key. l 15 When we licensed the plant, we licensed it l l
l 16 almost entirely on the basis of two trains. Okay? That 17 was expeditious for us at that time because, again, we 18 were dealing in areas that were new to us and new to the 19 regulator. We couldn't figure out how, in a timely 20 fashion, to get full credit for that 2.97 trains. The 21 regulator couldn't figure out how to give us credit for 22 that 2.97 trains. So we really licensed it as a two-train 23 plant.
24 That has given us about one-third more
/
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497 1 on an ongoing basis that we're getting little or no credit
,s 2 for. So we have a real incentive to be involved in this.
I i V
3 We have about $10 million invested in our PRA.
4 Not every plant in the country can afford to do that. Not 5 every plant in the country should do that. Not every 6 plant in the country should spend a million dollars a year 7 maintaining it and developing new initiatives for it. We 8 think it's important. Our owners provide us adequate 9 resources to maintain and run the plant the way it needs 10 to be and to keep it safe.
11 But we have an obligation to spend that money 12 wisely. And you need to uncerstand that that million 13 dollars a year that I'm spending on these initiatives O
\s / 14 could be spent elsewhere. We think that the payback on 15 that will be there. When we looked at graded QA, the only 16 place we are able to identify any savings right now is in 17 the procurement area.
18 But like the Rand studies that Dr. Powers was 19 talking about, the payback I know is bigger than that. I 20 know that it's bigger than that in other areas in 21 procurement. But the only area I can identify that in 22 right now is procurement, and that's $200,000 a year. I'm 23 spending a quarter of a million dollars a year to maintain l
l 24 the PRA, okay, and his staff.
/~g
- (_j 25 You just run a little magic on that, okay, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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I
498 !
1 you all have talked about all kinds of mathematics here, l 7- 2 you'll come out I'm losing just a little bit here, okay, j
'( ) i
3 if I don't get a bigger payback. !
4 MEMBER SEALE: And you can't make it up on --
1 l 5 (Laughter.)
6 MR. MARTIN: One of the things that -- as we 7 looked at this, we saw a lot of payback, and now we see 8 that eroding on us. Because one of the things that we see 9 happening here is the potential -- now, I haven't seen the 10 reg. guides. You asked a question: is the missing link 11 the reg. guides and the SRP? I don't think so. Okay?
12 And I'll come back and tell you why in a minute. But I 13 see a layer about to come on here that bothers me. Okay?
(~T
\_ / 14 It bothers me immensely.
15 One of the reasons that NEI backed out of the 16 pilot thing and has really been antagonistic for the NRC 17 -- and I'm not sure I support that, okay -- was that they 18 felt that they were about to layer on top of the 19 maintenance rule. Well, I'm more worried about not I
20 layering on top of the maintenance rule. I'm worried 21 about regulations now coming in where I've had programs
)
22 actively in place for years. j 23 I can tell you what my failure frequency is on 24 condensate pumps. I can tell you what the failure rate is
( ) 25 on the ground detector on the main generator. Okay?
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499 1 Because I have other reasons that drive me to look at
,3 2 that. I need to keep that plant up and operating every
()
day.
3 I need to maintain it well. It makes money for the 4 owners. If it's not making money for the owners, if I'm 5 not maintaining that equipment, it is down and I'm out of 6 a job. Okay?
7 So quality assurance isn't the only thing that 8 does that. We have been trending equipment failures for 9 years, before the maintenance rule ever came into effect.
10 We're going to continue to do that. But now, if I come 11 back and I say my condensate pump is a high risk item, and 12 I'm trending it and doing the analyzing on that, and I 13 analyze the wrong problem and fix the wrong problem, I'm l 14 not in NOV space. Okay?
15 But I've got plenty of drivers to make me want 16 to fix that to begin with. Do I need additional 17 regulation to do that? I question whether I do or not.
I 18 Okay? But I'm looking at the potential for that $200,000 19 savings I was hoping for eroding even farther, and I'm 20 sitting here on a day-to-day basis trying to evaluate 21 that.
22 We started out with $2 million we were wanting l
l 23 to spend a year on some of these initiatives. When I 24 became aware that having been a pilot plant was not going
/ %
( ,) 25 to get us anywhere down the road -- and we've been into l
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i 500 l l
1 1 graded QA for two years now, okay -- farther down, and we 1
l f3 2 were probably going to have to wait on the reg. guides and
! ! l j
\'^/
3 standard review plan before we really understood where we l 1
4 were and I saw that schedule slipping out, I automatically 5 cut the expenditures one-half, because I thought I was now 6 risking more money in a year than I was going to get the 7 potential for payback if I wasn't real careful. So that's 8 a real-world perspective.
9 There's another real-world perspective that we 10 need to understand. We are talking about configuration 11 management and where you have that and where you don't.
i 12 One of the things that I deal with every day at the plant, l
13 as well as in the regulatory body, the engineering group
,/
k}- / 14 right now sitting looking at graded QA. Okay? Would they 15 do anything different with configuration management, 16 configuration control, and their design program than we're 17 doing today? No. Why? Because it makes sense to do that 18 kind of design for any piece of equipment we're doing.
19 Now, it might make a little difference on 20 whether or not we have an independent reviewer or a peer 21 reviewer. Okay? But that's not a significant savings to 22 us. Where the significant savings comes is if you look 23 farther down the line, and we -- the NRC says, well, this l 24 won't be a mechanism to change the Q Jist, I am not so i () 25 sure it's not. But I do that through a different process.
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501 1 Okay?
,N
, 2 I've got a screen wash system on our ECW pond.
I \
)
3 And our ECW pond is a little bit different than a lot of 4 the plants. Now, I've been to some of them that are on 5 major rivers, have seaweed in them, all this kind of 6 stuff. Our ECW pond is a small pond that sits out by our 7 building, totally enclosed. Our cooling water pond is 8 back from that, is totally enclosed. It's ours. We're 9 not on a river. Okay? I don't have freezing weather.
10 I maintain that thing and have it in tech.
11 specs. for the screen wash system on it. Okay? The major 12 reason that is is because that's standard tech. specs.,
13 standard design for Westinghouse plants. But I don't have i- 14 a lot of the initiators that they could get. I could tell 15 you that the events that we have that ECW pond screen wash 16 system there for is a tornado, hurricane, or a large break 17 on one of the dams way up on a river that's not even close 18 to us. Okay?
19 But if any one of those things happened, I 20 could go out and have two people go out and clean that 21 screen if it became clogged. But yet I treat that as 22 safety related. I have the same maintenance on it that I
- 23 have on my aux. feedwater. Okay? And there's a l 24 significant difference in risk. It's in the tech. specs.
( ,/ 25 I've got surveillances on it. I came very close to having NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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502 1 1
1 to shut the plant down just here a while back because of l 1
l
,_3 2 that screen wash system. That would have induced more l \
~
3 risk to that plant in shutting it down for that screec 4 wash system, okay, but that's where we are. And it 5 doesn't make sense to me.
1 6 Now, my career -- I've been in this business i
7 -- I'm not going to tell you. It's more years than I can i 8 count almost. Okay? And I've worked at a number of 9 different plants. But a large portion of it has been in 10 the regulatory -- I worked for the NRC for a number of l 11 years and in quality assurance. And I believe in quality l 12 assurance. There is no doubt in my mind that I believe in j I
13 quality assurance.
,/ ~ N <
(sl 14 The quality assurance is verification that 15 what you're doing is what you want to do, what you said 16 you'd do. Okay? But the engineers and the maintenance When I go back and look at l 17 people maintain that plant.
18 the significant events that we've had over the years, the 19 most recent Davis-Besse thing, the Millstone thing, that 20 was all with QA programs that met the current regulatory 21 process. Okay? That's all within our processes that we 22 have today -- IST, ISJ, ITS. You name the acronyms, and 23 it was all within that.
l 24 Did the QA program prevent those from i
,m l (' ) 25 happening? And I'm telling you it's a cultural thing.
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503
~i l 1 And I deal with.that cultural thing every day; so does the !
I l 2 NRC. Ifve got a culture out there at South Texas that ,
l
\ l 3 says what we're doing today is exactly what we ought to be l
-4 doing a year from now. We just ought to be tweaking the j i
l 5 process and improving it. .
6 I believe that the risk-informed performance- ,
- l. 7' based initiatives that we're talking about here are a step .
8 change to improve safety and reliability of our plants. ;
9 That's why we're investing that amount of money in it. ,
.. t 10 That's why we're going to continue to as long as I think
-11 there is a payback, as soon as I determine there's not a ,
i 12 payback, or my management determines that my discretion or 13 judgment in that area may be questionable. i p !
-d 14 Rick may only have one or two people working j
15 for him, and we may be periodically setting that PRA up on [
16 the shelf and saying, "Well, it can't work for us today. -j l 17 But if I need it tomorrow, I'11 drag it down, update it, t
18 and we'll go get the numbers out of it we need." That's '!
l
-19 the real world to me when you talk about risk informed
[-
20 performance based. 1 21 Thank'you. 1 i
22 CHAIRMAN APOSTOLAKIS: I have a couple of 1, 23 questions that I would like to ask.
24 I appreciate the fact that you have not read
,Q 25 the documents, but you have heard the discussions and seen L NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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504 1 the viewgraphs the last day and a half. Do you think that 7 _.
2 what is being presented goes far enough?
i )
~ 3 MR. GRANTOM: I think they have a lot of good 4 approaches in there and some of them are consistent with 5 us. But once again, they don't allow for any scope 6 reductions.
7 CHAIRMAN APOSTOLAKIS: Any what?
8 MR. GRANTOM: They don't allow for any scope 9 reductions at all. What you've got is what you've got. I 10 can't go change the 6S-1r, program and say these valves 11 shouldn't have been in there. I can't go change -- I 12 can't do a risk-informed approach to say these components 13 shouldn't be in the IST program. They only allow for r~~x 1 s_/ 14 additions to scope. They don't allow for any scope 15 reductions.
16 Now, one can argue -- and what I mean is the 17 number of components, the number of things that had to be 18 included. One can argue it says, well, if you move the 19 frequency out to six years, you effectively change the 20 scope. But if you think in terms of budget and dollars, 21 yes, you have done something to the overall scope. !
1 22 But I'm still a believer that unless you use l l
23 the risk-informed information, then you're just scoping 1
24 components out there because they deterministically, under f:)
s_-
25 some scenario, no matter how bizarre it may be, could NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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505 l
1 require component X under some strange configuration, even
, -s 2 though that configuration may be a 10-', 10-2 event. It's
~
3 still going to be the IST program. You're still throwing 4 baggage on us by doing that.
5 MR. ABBOTT: See, I think the problem is the 6 falling, and maybe I'm oversimplifying here. But the top 7 event, to use a PRA term, in all these regulatory guides 8 and standard review plans is the proposed change meets the 9 current regulations. So when a risk-informed insight 10 comes about as a result of exercising a PRA, and that 11 change does not conform to the current regulations, you ,
l 12 can't do it.
I 13 CHAIRMAN APOSTOLAKIS: No. That's why they l
/ \ 1
'v) t 14 have --
i I
15 MR. HOLAHAN You have to read the whole 16 phrase. If you want to quote the phrase, please read the 17 whole phase.
18 MR. ABBOTT: Okay. No, I will. But I haven't 19 finished yet. And the reason you're not going to go any 20 further, at least from Rick slys, if you go back to one of 21 his slides, the laat bullet says getting an exemption is a 22 very difficult process. Suro. I can get an exemption, 23 but it's going to take me a long time to do. And the 24 question then becomes is whether the effort for doing that (3,
, ( ,/
25 is going to be the benefit -- is going to be equal to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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506 ,
1 benefit I'm going.to get back from the approval. And'I'm 12 not -- I guess what you're saying is that it may not be.
3 MR. MARTIN: One of the reasons that we l
.4 elected to go with a total QA program rather than just a i t
~
5' procurement piece was -- graded QA is not a new thing.
6 Okay? 1989, I believe it was, or 1990, we got graded QA 7 approved at TVA. And the reason was is we were using it f 8- strictly on a performance-based _ type thing. Okay?
9 We elected to go with the total program,
- f. .
i 10 because we recognized'that every time we wanted to.come 11 back in and change incrementally what we were doing, and i
12 take. exception to a reg. guide,Ethat required'a different-i-
l' . !
L 13 submittal. Okay? And I think'the NRC is recognizing i L \~n/'
l 14 this, too, and I believe that's really what they've gone I l
15 back to Grand Gulf and said, that if you're going to take
{
16 exception to the reg. guides and standards that you've L _17 committed to in your FSAR, you need to advise us and we'll-18 evaluate whether or not that's a-reduction. And they do.
19 And we decided that it.was better to take that L 20 on at.one' time, because I see some-payback in.a lot of I
21 areas besides.the procurement area. Okay?
i 22 'But you need to understand:that when you deal 23 -- and I absolutely support the NEI on their 50.54a L 24 position -- okay? It has bothered me for a number of 4
! 25 years, even as a QA professional, that it's easier for me L
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l~
l
507 l ,
1 to change significant portions of the plant than it is for 73 2 me to change my audit frequency. Okay? )
( )
3 Now, I understand that QA is pervasive. Okay?
4 But so is the type of --
5 MR. CARROLL: But it's described as other 6 things also. ,
i 7 MR. MARTIN: I understand that, and I've been l
8 called a lot of things, too.
i 9 (Laughter.) l I
10 But we felt that it was important to go one I 11 time. The thing is is the NRC is like the rest of us. l l
12 They have only a certain amount of time, a certain amount 13 of resources. Okay? And every time you go in with a l e
r~Ni l'
\)~ 14 submittal, you're behind so many people. So you'll wait 15 your turn and go through that. We've been working on 16 graded QA for two years now. We've been working on our 17 ITS for 18 months, a number of these programs.
18 The last time we submitted a round of changes 19 for getting additional credit for PRA information into the 20 tech. specs., it took us four years. So it's not a real 21 nice " submit it and you'll get it back in 60 days." Okay?
22 And you will expend a lot of resources on RAIs in there.
l l 23 They expend a lot of resources reviewing it. You expend a 24 lot of resources.
p
(_) 25 Now, in a graded QA program, in a QA NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N.W.
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508 .
1 submittal,. typically hereois what happens, is they will i 2 take that. .You will either say it's a reduction or not a
() 3 reduction. If it's a reduction, then.they make'a decision l,
4 on whether or not that reduction is appropriate. ~ But they 5 will take-your plan and go down through it. If it's just I
6 minor changes, then they read-it word for word and see if l
7 there's any changes in here, and then ask the question:
t.
! 8 why did they make that change? 'And is that a reduction or l'
9 isn't it a' reduction, okay?
l 10 We've got'a submittal in.to them now where we I-11 changed the name of our program from surveillance program 12 tb monitoring program. And really what we were trying to-13 do there was deal:with our staff and it's a-cultural 14 issue. The staff was.doing mini audits and calling them 15' surveillances. Okay?
16 Well,- that's not the purpose of surveillance.
17 Surveillance is to get out there and see what's really i 18 going on in a plant, real' time'. So we changed.it to-19 monitoring and started looking at them for snapshots. 1
'l 20 Okay? We wanted them doing two or three surveillances or 21; monitoring activities a day, rather than one surveillance-I 22 activity a week. Okay?. I 23 We changed that, and they came back and 24 questioned whether or not we were dropping surveillances L ( )'
1:
25 out. Well, surveillances aren't required by the regs.
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.c, ,a. . ._ _ _ _ . . - . _ , _ _ _ - - , . - - - .
- , _ _ ..m . . _ ._ _._ _ . _ _ . . - . _ . _ _ . _ _ . . _ . . _ . - . _ _ ._
l 509 a T. I 1 anyway. -Okay?.~QA surveillances. But they were in our QA 2 plan, okay, so that was a potential reduction. 1 3 We~just changed our audit schedule name to.
j 4- oversight schedule, because we are not only scheduling -
i - .
j 5 audits in there, we are scheduling oversight. All-of our l
6 monitoring activit'ies, surveillance activities,. audit 7 activities, assessing activities, and the question came !
8 back to us, "You don't have.an audit-schedule anymore. It j 9 looks-like that's a potential reduction." Okay? So you
$ 10 get those kind of questions. j l
11 So when you do it you want to do it right the l 12 first time, because if you do that incrementally, it's a 13 tortuous path to get through. And I just talked with you I l't about 0A changes, tech. spec. changes, any kind of' program
~
j' 14 I
j 15 changes like that.
2 16 MR. GRANTOM: George, you were asking me'about 17 the reg. guides and whether I felt they were adequate or 18 not. Let me just add one real quick thing.
19 CHAIRMAN APOSTOLAKIS: Yes,'okay.
20 MR. GRANTOM: I know you're pressed for time i 21 here just a little bit. !
22 I do think that-they put together a good ';
23 effort. I think there is a lot of risk information that 24 are in those that accounts for risk information and O
d 25' performance information. I think there are some real good NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.- N.W.
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510 1 things in there. I haven't seen the total text --
,q, 2 CHAIRMAN APOSTOLAKIS: I know.
! )
3 MR. GRANTOM: -- but from what I've seen.
4 But, you know, when you're looking at scope, you're 5 looking at not being able to do strategies, you know, 6 using that risk information, I would just hope that you're 7 able to use the risk information and the performance 8 information together to the fullest extent that's 9 practical. And I don't know if that's the case, but I 10 would hope that that's the case. And I think that they've 11 made a good faith effort to try to do that. Maybe there 12 is some reasons that they can't say the words " reduce" or 13 " relax." I don't understand all of that. But I think (4
\'/ 14 that there are some good things in --
15 CHAIRMAN APOSTOLAKIS: It's one of the three 16 reasons why you should be submitting this. The second 17 reason I think is to reduce burden, so they have used the 18 word -- we have some interviews to conduct. But you are 19 leaving right after lunch, or you are staying for a while?
20 MR. GRANTOM: No, I'm staying.
21 CHAIRMAN APOSTOLAKIS: One of the questions 22 that I think is very important for -- this is a critical 23 meeting of the committee, by the way -- I don't know if 24 you're aware of it -- because we're supposed to write the 77
( ,) 25 letter in two weeks roughly and send it to the Commission.
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1 511 1 So we are really trying to organize our thoughts today and 7x 2 decide what to say in the letter.
i 3 One of the things that I think it's important, 4 and we -- I think we'll discuss it this afternoon, is .
1 5 where do we go from here? Can we develop a plan of 6 action, given that, as Mr. Holahan told us yesterday, l
7 there is a very high probability these documents will go l
8 to the Commission by the end of April, or will be released i 1
1 9 in April some time #or public comment. l 10 So given that fact, and given that you know 11 something about what they're planning to do, and we'll 12 know more because we've had the benefit of reading these l i
1
,, 13 documents, can we formulate some sort of a plan where we '
/
14 want to go and by when? By when -- I think that's a 15 critical issue here, because from talking to industry l 16 people, I get the impression that they feel that things 17 are dragging on for too long.
18 MR. GRANTOM: Well, I think that there is --
19 yes. I think we can put together what I'd like to 20 characterize as an implementation plan with some 21 milestones, you know, at least for pilots.
22 CHAIRMAN APOSTOLAKIS: Yes.
l 23 MR. GRANTOM: I guess one of the things that 24 has to be concerned about -- you know, where is going to p
(_) 25 be the review and approval cycle for these types of I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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512 1 things? If everything has to go to the commissioners for
-~, 2 this, I mean, I see that as going to be a fairly long and
! \
\'~/ 3 tortuous path, once it has to make up through all of those 4 rungs of managers to make it up to Chairman Jackson. I 5 mean, those are going to be difficult. I don't know if we 6 can get around that.
7 CHAIRMAN APOSTOLAKIS: One other item that I 8 would like to have some discussion on is this issue of 9 performance, because I believe that there is a 10 disagreement between NEI and the staff. And, in fact, Mr.
11 Holahan again told us that this has elements of 12 performance, okay, so it's not rer11y performance based, 13 but elements of performance.
?
,23
's >' 14 Again, I don't want to -- I'm not asking for 15 comments, you know, to say, yes, this is bad or this is 16 good. But in formulating this longer term plan, should we 17 try to make the performance part play a more important 18 role than it is playing now? And again, you are at a 19 disadvantage. You haven't really read it. But the staff 20 also will comment on this.
21 Because I noticed that in your presentation, 22 Rick, you always said RIPB. I mean, you are taking it as 23 a package. It's not just risk informed with some elements ;
24 of performance. I mean, the whole package, and I think
,r m, I
( ,)
25 that's an important part of the whole effort. So maybe NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N.W.
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i 1
1 513 1 1 during lunch we can think about these questions. And I'm
,m 2 glad you are not leaving right away.
)
(
3 Yes, Bob?
4 MEMBER SEALE: I would also be interested in 5 your response to Dr. Powers' earlier comment about going 6 at this from the approach of finding out what should be on 7 the high safety significance list, rather than what can be 8 put on the low safety significance list. Okay? If you 9 feel comfortable commenting about that -- I think it 10 addresses one of the questions you raised earlier, and I'd 11 be interested in your response to it.
12 MR. MARTIN: Do we want to do this after 13 lunch?
\/ 14 CHAIRMAN APOSTOLAKIS: Yes. And by the way, 15 other people are invited to -- of course, the staff --
16 but, I mean, the public, if you have any comments. But 17 these are the kinds or questions that I would like to have 18 discussed this afternoon before we go on to the points I 19 that we want to include in the letter, because I think l
20 this is important, where we're going from here. l 21 Gentlemen, thank you very much for taking the 22 time to come.
l 23 (Whereupon, at 12:10 p.m., the proceedings in 24 the foregoing matter went off the record for a A
25 lunch break.)
()
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514 1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 2 (1:24 p.m.)
S
(" )
3 CHAIRMAN APOSTOLAKIS: Okay. Now this 4 afternoon the first part will be a general discussion of 5 issues, items to resolve, and then we'll talk about points 6 or issues or ideas that will help me start drafting a 7 letter, and also we'll discuss the full ACRS review. But 8 I think the full ACRS is here today anyway, so that's 9 happening already.
10 Right now --
11 MR. CARROLL: By design.
12 CHAIRMAN APOSTOLAKIS: What?
13 MR. CARROLL: By design.
(-
t a
'v' 14 CHAIRMAN APOSTOLAKIS: By design.
15 There are five items that are listed here as 16 general -- as issues to be discussed: LERF and CDF, 17 defense in depth, safety margins, temporary changes, 18 expert panels, peer reviews. And I would like to add to 19 them two or three that I mentioned before we broke for 20 lunch. What kind of implementation plan should be put in 21 place? Are we placing sufficient emphasis on the 22 performance part of risk-informed and performance-based 23 regulation? And if not, what do we need to do in the 24 future?
.s (j 25 And I think that's -- oh, and I think Dr.
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l 515 l
1 Powers' question regarding the need for shutdown -- lower l
,cy 2 and shutdown PRAs, and so on. Can we make any useful i i
\J ,
3 decisions without this kind of information? I think l 4 that's also a key issue to be discussed.
5 So it says here Gary Holahan and Tom King. So l l
1 6 you gentlemen will come here, up front there as usual, or l
l 7 how do you want to handle this? ;
1 8 MR. KING: We had prepared a handout that 1
1 9 covered the issues you had listed in the agenda -- l 10 CHAIRMAN APOSTOLAKIS: Very good.
l l
11 MR. KING: -- if you want to start with that. l 12 CHAIRMAN APOSTOLAKIS: Maybe we can do that, 13 yes. l J
('
14 MR. KING: Okay.
15 CHAIRMAN APOSTOLAKIS: And then use those as a 16 starting point of discussion.
17 MEMBER FONTANA: At least we can see him over 18 here.
19 CHAIRMAN APOSTOLAKIS: Yes, they are coming 20 there.
21 MEMBER FONTANA: Oh, okay.
22 MR. CARROLL: Would we want to reorder those, 23 fitting for Tom and --
24 CHAIRMAN APOSTOLAKIS: Yes. Definitely, Tom I'h
( ,/ 25 has to be here when we discuss the temporary changes.
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516 1 MEMBER SHACK: We need him for LERF and CDF.
r-3 2 CHAIRMAN APOSTOLAKIS: We need both him and
.J' 3 Dana I think for that.
4 All right. So --
5 MEMBER SHACK: Now, the next question is:
6 when are you guys going to get a decent font for your 7 viewgraphs? l 8 MR. KING: You don't like that? Something a 9 little fancier? i l
10 MEMBER SHACK: I mean, I haven't seen that in 11 20 years anywhere except here.
12 (Laughter.)
13 MEMBER CATTON: If you look at your word
( )
- ' 14 processor, you'11 find it.
15 MEMBER SHACK: But 20 years ago, right.
16 MEMBER CATTON: No, even now, it's there. You j l
17 just don't use it. l l
18 MEMBER SHACK: I got it off of my Mac a long 19 time ago.
I 20 MEMBER CATTON: Oh, you erased it.
21 MEMBER MILLER: What's wrong with this font?
22 MEMBER SHACK: Orator is dead.
23 MEMBER FONTANA: What's dead?
24 CHAIRMAN APOSTOLAKIS: Orator.
p
(,,) 25 MEMBER FONTANA: Orator?
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517 1 MR. KING: All right. What I had was one page
- 7. 2 on each of these subjects that were listed on the agenda, i
\~') 3 and I think for the most part you've seen those. The 4 slides I've got are the same ones we had at the full 5 committee meeting, with a few minor changes which I'll 6 point out. And then we can come back later and talk about 7 how we want to -- what we want to present and cover at the 8 full committee meeting, which I understand is March 6th 9 now, not March 7th.
10 CHAIRMAN APOSTOLAKIS: The afternoon, I think.
11 MR. KING: Is that right? Okay.
12 CHAIRMAN APOSTOLAKIS: Okay. So I think we 13 can start with defense in depth and safety margins.
f'h.
I s
(_/' 14 MR. MARKLEY: Just for the benefit of the 15 public and everyone else, it's 3:15 to 4:45 on March 6th.
16 CHAIRMAN APOSTOLAKIS: Okay. And then I hope 17 that Dr. Powers and Dr. Kress will be here before we start 18 the discussion on LER and temporary changes.
19 MR. HOLAHAN. Or we can skip around on that.
20 MR. KING: What we've got in the general reg.
21 guide and in the application-specific ones is the 22 principle that we need to maintain defense in depth. And i 23 that's really a very high level principle. It doesn't i
24 mean that you can't change the way things are being done m
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518 1 in depth, we're not giving that up.
,_ 2 And in the reg. guide itself, we tried to put
( ) i 3 some additional subelements under what do we mean, or what )
4 do you look at when you consider defense in depth. And 5 these items are the ones that are listed in the reg.
6 guide. There has been one change to the fourth bullet 7 from the version that you've seen before. I 8 It used to say defenses against common cause 1
9 failures are maintained, and the potential for 10 introduction of new ones is avoided. That seemed to go a 11 little too far, so we've changed " avoided" to " assessed,"
1 12 and added the word " potential" in here, potential for '
13 introduction of new common cause failures is assessed. !
r~~S I
\~- 14 CHAIRMAN APOSTOLAKIS: Tom, the word 15 " maintained" bothers me a little bit. Maybe I 1
16 misunderstand it. Could this be interpreted by a reviewer 17 as meaning that the defense that you have now should be 18 maintained? Because I think you mean we will want to see ,
l 19 defenses against common cause failures, but not exactly 20 the ones -- because that's the whole idea, right?
21 MR. KING: Yes. Yes.
22 CHAIRMAN APOSTOLAKIS: Relax some of the 23 requirements.
24 MR. KING: Right.
?~
(
v) 25 CHAIRMAN APOSTOLAKIS: Would that be l NEAL R. GROSS
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519 1- misconstrued?
2 MR. HOLAHAN: Would it help if it said
\~ j' 3 maintain the defense-in-depth philosophy?
4 CHAIRMAN APOSTOLAKIS: Yes, I think that would l
5 be closer to what I have in mind.
6 MEMBER SHACK: Or adequate defenses against 7 are maintained.
8 CHAIRMAN APOSTOLAKIS: What did you say, Bill? .
9 I'm sorry.
10 MEMBER SHACK- Adequate defenses.
11 MR. HOLAHAN: Well, we've been trying to avoid 12 the word " adequate," because it shows up in the Atomic 13 Energy Act, and it has been interpreted to have a certain tp) v 14 legal maaning that we'd rather avoid.
15 CHAIRMAN APOSTOLAKIS: No. I that one 16 philosophy will have it, because that means you will worry 17 about it, but you don't necessarily maintain what you 18 already have.
19 MR. HOLAHAN: Right.
20 MR. KING: Well, I think the whole principle 21 is we want to maintain the philosophy.
22 CHAIRMAN APOSTOLAKIS: No, I understand that.
23 MR. KING: And what do you look at when you're 24 seeing if you're maintaining that philosophy.
) 25 CHAIRMAN APOSTOLAKIS: So I think that word NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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520 l' would help a lot.
2 MR. KING: Okay.
' .- 3 CHAIRMAN APOSTOLAKIS: And make sure that the j '4' other guides change, too, because some of them really i
1 '5 use --
6 MR. KING: Yes.
7 CHAIRMAN APOSTOLAKIS: -- they lack the words.
8 MR. HOLAHAN: I think that --
i' 2
9 MR. KING: And the principle itself has 10 maintained in it.
11 MR. HOLAHAN: In the policy statement, I 12 notice that what the Commission has expressed in-its 13 policy statement is that we should be doing things in such 14 a way that it supports NRC's traditional defense-in-depth 15 philosophy.
16 CHAIRMAN APOSTOLAKIS: Philosophy.
17 -MR. HOLAHAN: So I thirik we can carry that on 18 directly.
19 MR. KING: Now, when we talked in one of our 20 earlier meetings, there was some concern about what's the 21 role of PRA in evaluating these things. j
- 22. MR. CARROLLi Tell me about that fifth bullet. .
23 MR. KING: Well',-I think it's a catch-all item 24 that takes a look at -- we have the traditional barriers, 25 cladding, coolant system, containment, and so forth. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N,W.
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l
521 1 don't want to do anything that would have a common cause g3 2 failure of those barriers or have a common point where you i 4 3 could reach two of them at the same time.
4 MEMBER FONTANA: Or consequential.
5 MR. KING: Or consequential. You know, I'm 6 not sure we had anything specific in mind in terms of an 7 event sequence when we put that in there, but we felt the 8 barrier concept was important. It probably was the 9 original thought of -- when people thought of defense in 10 depth years ago, and we felt we didn't want to lose that. ,
i 11 MR. JONES: Yes. I mean, we're not.saying l
l 12 that -- whatever dependent properties there may exist 13 between the barriers today, we're not saying that you have !
(~)
- )
14 to change those to make them independent. We're saying l'
15 when you evaluate a proposed change, you want to make sure 16 that the proposed change isn't introducing some new l 17 interaction which leads to a degradation of this 18 independence. ,
1 19 Or, as was stated earlier, something that now 20 leads to a consequential failure as a result of the l 21 change, so that you would now effectively have done .
l 22 something that would actually impact the defense-in-depth l 23 attributes at a plant.
24 MR. CARROLL: And in the next bullet I see the 7..
() 25 " maintained" word again.
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522 1 MR. KING: Yes. Yes. I think we'll take a f .- 2 look at the -- wherever the word " maintained" shows up and
( )
3 see if it is used in the right fashion.
4 CHAIRMAN APOSTOLAKIS: Does Wordperfect have 5 this feature, wherever " maintained" --
6 MEMBER CATTON: Yes, but I think it's okay to 7 use it in that bullet. If you change --
8 MR. HOLAHAN: I think we have to read each 9 one.
10 CHAIRMAN APOSTOLAKIS: Yes, especially the 11 other guider.
12 MEMBER CATTON: It's a balance, but --
13 MR. KING: It's not intended to imply you
,o
! l
\v' 14 can't change anything. And if that's the way it's being 15 read, then that's wrong.
16 MR. CARROLL: It can be read that way.
17 MR. KING: Yes, I understand.
18 CHAIRMAN APOSTOLAKIS: Okay.
19 MR. KING: In the reg. guide itself, in 20 addition to listing those elements, there are also several 21 paragraphs on implementing those elements. Particularly, 22 we had talked the last time about what's the role of risk 23 assessment in evaluating those six items. And we added 24 some words into the reg. guide which you haven't seen yet, g3 I
) 25 but basically what they talk about is when you are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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523 1 evaluating the proposed change, there are certain things i
-s 2 that you can have risk information on, and there are
's
certain things that aren't.
3 !
4 Either they weren't modeled in the PRA, or :
i 5 there aren't any methods to model them, or the scope of 6 the PRA didn't go that far, or there is a lot of l
7 uncertainty. They were modeled, but there's a lot of 8 uncertainty. And what the reg. guide says is for areas l
9 that either aren't modeled or there is a lot of l 10 uncertainty, you pretty much have to rely on the 11 traditional engineering judgment that we've been doing for I 12 years in terms of what do you want in the way of defense 13 in depth.
(3 E_/ 14 For those areas where there are risk insights, )
l 15 both the reg. guide and the SRP now have some words that 16 basically say, "Use risk insights to help guide the 17 application of defense ir dept' -d that would be doing 18 things like looking at your dominant accident sequences, 19 what are the lines of defense that are associated with 20 those in terms of active components, passive components, 21 human actions, how many failures does it take to get 22 through that sequence, and are you having an overreliance
- 23 on programmatic or human actions involved in that 24 sequence, and taking that information and using it to help n
( ,j 25 see whether those six items on the previous page are, in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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524 1 fact, sufficiently maintained.
. ~s 2 MEMBER POWPRS: Tom, I know that words like an i )
3 overreliance on programmatic efforts is one of those 1
4 things that you know it when you see it, and I doubt you i 5 can define it, but can you give me an example of when I
6 you've known it and when you've seen it?
l 7 MR. HOLAHAN: Well, one example is automated ]
1 I
8 systems, if you look at reactor protection systems. I ;
l 9 mean, traditionally, it seems to me the reactor scram and j 10 ECCS actuation systems are all automatic, which goes ]
11 basically to this issue. So I think if a licensee were to l
12 propose to make, let's say, an aux, feedwater system i
13 manually operated, instead of automatically operated -- !
/m.
_s 14 and so you could construct an argument that says, well, I 15 mean, there is physically enough time to do that. Steam 16 generators don't dry out in 10, 20 minutes. So there is 17 physically time to do that.
18 I think you would find out in that case that 19 those operator actions would be extremely important.
20 They're in probably several very dominant sequences, and 21 you probably wouldn't want to do that.
22 MEMBER POWERS: So when you say 23 "overreliance," you're really cautioning your reviewers to 24 look carefully when additional operator actions -- that's l 7
'(,) 25 really all you're intending there.
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! 525 1 MR. HOLAHAN: Yes.
l l
,x 2 MR. KING: There's no numerical guides, like
!( ~
)
3 no more than two operator --
4 MEMBER POWERS: No. No. And I would be l
l 5 reluctant to see that kind of thing put in there, because i
6 again I think this is one of those things that you know it 7 when you see it. What it is is just an alert, and I think 1
8 there are a lot of alerts in these documents, and just l
9 things to be sensitive to, which I think is fine. This is 10 the appropriate place to put them.
11 MR. HOLAHAN: In my mind, one of the tests is 12 if you look at the unreliability of equipment, and it's 99 l
13 percent from the operator and one percent from the
/'"s
, i )
k/ 14 hardware, then there is something wrong there. Okay?
15 Even though you would like all, you know, unreliability to 16 be as low as possible, there is some sense in which the 17 starting of the equipment and the running of the equipment 18 and the initiating signals and the operator piece and the 19 maintenance piece all -- you know, should all be 20 relatively balanced small pieces. Why would I be 21 suppressing the operator piece ten times below something j 22 else because it's having no effect?
l l
23 So it seems -- watch out for outliers where 24 unreliability is coming -- whether it's equipment (3
,,/ 25 unreliability or dominant sequence, branch values, are NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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526 1 coming too much from one thing like operator reliability.
,r~x, 2 CHAIRMAN APOSTOLAKIS: Yes. There is another
!v) 3 example from a real case. In a fire risk assessment, 4 typically you require amounts of oil or -- yes, of oil in 5 rooms that are not allowed there by administrative 6 controls. So one way of handling it and getting very low 7 risk numbers is to say, you know, I will have very i
8 stringent controls here, so that kind of fuel will never 9 be found there. And then the probabilities all go down, 10 you know --
11 MEMBER CATTON: To Zip.
12 CHAIRMAN APOSTOLAKIS: -- several orders of i 1
13 magnitude. And that's an overreliance I think on --
I,_s)
'2
'- 14 MR. HOLAHAN: But I think that there's a 15 judgment involved. If that turned out to be a very large 16 amount, which is physically difficult to get through a 17 doorway, and has --
18 CHAIRMAN APOSTOLAKIS: That's true.
19 MR. HOLAHAN: -- never happened before, and 20 they said, "Well, maybe it's appropriately."
21 CHAIRMAN APOSTOLAKIS: But it has happened 22 before. The kinds of --
l 23 MR. HOLAHAN: Right.
24 CHAIRMAN APOSTOLAKIS: -- we're talking about ID
(_) 25 have been found.
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l
527 1 MR. HOLAHAN: Any time you are relying on p- 2 operators to do things, or avoid doing things which have
\
)
3 actually happened in the past, I think you have to be 4 quite careful about how sure you are that history won't 5 repeat itself.
6 CHAIRMAN APOSTOLAKIS: Yes.
7 MEMBER FONTANA: Well, a good example of the 8 first bullet I think would be sabotage. You set up rules 9 to prevent sabotage and that sort of thing, but you can't l
10 really put a number on it all that well. I 11 MEMBER KRESS: Let me make a comment that may i
12 be off the mark just a little bit. But these elements of ]
1 13 defense in depth seem to me like all -- they're a little l r~'s l k_) 14 incomplete because they only deal with the elements of l 15 defense in depth that are appropriate for this activity. !
16 It seems to me like they come close to being probably the 17 most complete definition of defense in depth I've seen 18 just about anywhere.
19 Have you guys considered writing up a separate 20 little treatise on what defense in depth means and include 21 these, and make it fully complete? Because, you know, I 22 really haven't seen a good definition of defense in depth, 23 and I think these elements come pretty close to defining 24 it, rr Tom, I'm crushed.
25 MEMBER POWERS:
(% )'
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528 1 (Laughter.)
l
, 2 MEMBER KRESS: I'm sorry. Well, I have seen ;
. 6 i
! i /
3 one that was equally --
4 (Laughter.)
5 I just forgot about it.
6 (Laughter.)
7 I meant to say I haven't seen it written up by 8 NRC as an official NRC --
9 MEMBER POWERS: Yes. You can crayfish about 10 as good as anyone, I can tell.
11 (Laughter.)
12 MEMBER SEALE: That's how you knew this one !
13 was good.
,r\
Cl 14 MEMBER KRESS: Yes. i 15 CHAIRMAN APOSTOLAKIS: Speaking of that, I l l
16 just remembered the six bullets you have in the previous j 17 slide that sort of -- well, the elements of defense in 18 depth, they are really hardware oriented, aren't they? Is 19 evacuation planning part of defense in depth?
20 MEMBER KRESS: Yes.
21 CHAIRMAN APOSTOLAKIS: Accident monitoring is 22 part of defense in depth?
23 MEMBER KRESS: But they're not -- that's why I 24 said that it is not really --
,e j 25 MR. HOLAHAN: Yes and yes.
x/
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529 l l
l 1 MEMBER KRESS: -- appropriate for this l i
2 activity, but they're part of -- l
,3
- ()
3 CHAIRMAN APOSTOLAKIS: Okay. I 4 MEMBER SEALE: But the sixth one is certainly 5 not hardware oriented.
6 MR. KING: Right.
l 7 CRAIRMAN APOSTOLAKIS: Well, again, if you 8 want to say --
9 MR. KING: And the second one is not hardware 10 oriented. I mean, to some extent it is.
11 CHAIRMAN APOSTOLAKIS: Yes. But the spirit l l
12 there is that you would like something manageable instead 13 of relying on human error, so you could say in that sense I
/~s ,
'w-) 14 it is -- so, but why isn't, say, an accident monitoring 15 strategy programmatic activity?
16 MR. KING: Well, I think an accident 17 management strategy could be considered a programmatic 18 activity.
19 CHAIRMAN APOSTOLAKIS: So then the second 20 bullet will take over and say, gee, I'm not going to give 21 you much credit.
22 MEMBER FONTANA: It's overreliance.
23 CHAIRMAN APOSTOLAKIS: Oh, overreliance. Oh, 24 that makes it crystal clear now. Okay. Okay. I think --
(~'N
( ,/ 25 MR. KING: Heroic things by the operator may NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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530 1 be part of your ac'ident management proposal, but, you
, ~g 2 know --
l 3 CHAIRMAN APOSTOLAKIS: I don't think we can do 4 any more than that besides what Dr. Kress suggested.
5 MR. HOLAHAN: I think the answer to Dr. Kress' 6 question is we have not thought about elevating this 7 discussion to the heights of Dr. Powers' work for some --
8 MEMBER KRESS: I don't think it's necessary --
9 CHAIRMAN APOSTOLAKIS: Which you have not 10 seen.
11 (Laughter.)
12 MR. HOLAHAN: I still have full confidence 13 in --
t
)
(./ 14 (Laughter.)
15 CHAIRMAN APOSTOLAKIS: The industry can see 16 it, but not --
17 (Laughter.)
18 MEMBER CATTON: On the first bullet of the 19 next slide that you had up there, you have an "or." Why 20 can't I still do a risk analysis when there's large 21 uncertainty? I just have to deal with it within the risk, 22 within the PRA mechanism.
23 MR. KING: No, you can. All I'm trying to say 24 herre was these are areas where --
(g) 25 MEMBER CATTON: And then that gives you the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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531
! 1 basis for your judgment. Take the word " traditional" out
<- 2 of there.
i'~ '/
3 CHAIRMAN APOSTOLAKIS: Oh, I thought you were j 1
4 going to say, Ivan, move that part of the first to the l l
l 5 second bullet. In other words, as long as you can 1
6 quantify, use those insights to guide your application of j 7 defense in depth, and the first bullet stands alone, when l l
l 8 you don't quantify then you really have to rely on defense 9 in depth. I mean, it's the same ideas, but rearrange --
10 MR. KING: Either you don't quantify, or the 1
11 uncertainties are so large that you don't -- i 12 CHAIRMAN APOSTOLAKIS: But that's part of the i 13 second bullet, is it not? In the second bullet you have p_
(4 '-
)
14 risk insights, and, of course, the larger the uncertainty 15 the more cautious you are. That's really I think what 16 I --
17 MEMBER CATTON: And you may get to the point 18 that the uncertainty is so broad, the bottom line on the 19 95 percent point or something is so high you can't live 20 with it, so you say, okay, you've got to do a design 21 change.
22 MR. HOLAHAN: I think this even makes more 23 sense if you're thinking about aliatory uncertainties 24 rather than epistemic uncertainties.
T'~'N l
) 25 (Laughter.)
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i 532 1 MEMBER CATTON: You know, it's bad enough 2 having one person around this table who keeps doing that.
I
)
3 MR. JONES: If I could, just in response to 4 your comment, Ivan, about the uncertainty -- the specific 5 words that Tom is trying to summarize have items in it 6 like, " Defense in depth has been, and continues to be, an 7 effective way to account for uncertainties in equipment 8 and human performance. In some cases, risk analysis can 9 help quantify the range of the uncertainty. However, 10 there will likely remain areas of large uncertainty or 11 areas not covered by the analysis where a comprehensive 12 risk analysis can be done. It can be used to help 13 determine the appropriate extent of defense in depth,"
,a i \
C/ 14 etcetera. ,
15 So we were trying to add -- you know, these 16 were --
17 MEMBER CATTON: You don't say you can't do it, 18 because there is something with large uncertainty.
19 MR. JONES: No. No. These were the words 20 that are --
21 MEMBER FONTANA: I think you resolve this 22 problem if you just swap the order of the bullets and take 23 traditional out. I think -- in other words, the thing you l 24 want to get across is you're using risk insights to guide
, g l (,) 25 application of defense in depth, and then -- but, when you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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533 1 can't do it that way, use engineering judgment, la de da.
,, 2 The main thing I would think in the next 1
( \
'"' 3 millennium or something, all you really need is that last 4 bullet, because the risk insights will automatically tell 5 you what the allocation of defense in depth is. But i'
6 that's so far in the future that --
7 MEMBER CATTON: But, in fact, that's the 8 beauty of the risk-based approach is you can deal with i
9 those uncertainties.
10 CHAIRMAN APOSTOLAKIS: But I think my point ,
1 11 was that defense in depth is really necessary in areas not 12 covered by risk analysis. And I wanted that point made j 13 very clear, so that's why I think it deserves its own (s'
( )
14 bullet.
15 MR. KING: Well, it's not so much defense in 16 depth. It's engineering judgment that is important where 17 you have the areas not covered. Defense in depth is 18 important no matter what you --
19 CHAIRMAN APOSTOLAKIS: But defense in depth 20 relies on judgment. I mean --
21 MEMBER SEALE: It's the response.
22 CHAIRMAN APOSTOLAKIS: -- the whole thing.
23 But when you have dequantified, you really want to rely on 24 these traditional analyses and make sure you have your n
25 barriers, and so on.
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534 1 MR. KING: Right.
,- 2 CHAIRMAN APOSTOLAKIS: Once you have
( )
~ 3 quantified, then you have all of these insights, what's i
4 important, what's not important, how uncertain how you 5 are, and that's a separate class.
6 Now, in my mind, defense in depth now acquires I
7 a secondary role, maybe -- in fact, I would venture to say l
8 that maybe for a few years -- and as the years go by, its I l
9 role vill be diminished more and more as we gain l
1 10 confidence in the PRA and we start believing these i
11 distributions more and more.
i 12 MEMBER CATTON: You see, the way -- the reason i 13 you have defense in depth is because of uncertainty.
,\ ,
e v_) 14 CHAIRMAN APOSTOLAKIS: Unquantified 15 uncertainty. That's my point. ,
1 16 MEMBER CATTON: Well, but you can always pick 17 a range that covers it, and then you can say, okay, the 18 only way I can deal with this is with defense in depth.
19 CHAIRMAN APOSTOLAKIS: I think that --
20 MEMBER CATTON: So if I go back and I 21 elimi. late tnat uncertainty, you ought to be able to relax 22 defense in depth a little bit.
23 CHAIRMAN APOSTOLAKIS: But the first step is 24 to quantify.
/s xs
) 25 MEMBER CATTON: Sure.
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535 1 CHAIRMA? APOSTOLAKIS: That's what I'm trying 2 to --
i /
3 MEMBER CATTON: And what you do, though, is if 4 you do your PRA properly, and you build in what you know, 5 you say, " Gee, the uncertainty associated with this is so 6 broad," this one, and I wind up with an answer I can't 7 live with if I take something out. I either have to 8 quantify it or live with it.
9 CHAIRMAN APOSTOLAKIS: But you assume, I think 10 -- we had this discussion some time ago. You assume that 11 in the PRA I allow for things I cannot quantify. If I 12 have model uncertainty, for instance, sometimes I do, 13 sometimes I don't. There are certain things that are not 75 \
o I_/ 14 at all in the PRA, and I think that for those things you 15 really have to have a good defense in depth analysis or 16 evaluation.
17 But the moment you quantify, then it's a 18 different ball game. That's my point.
19 MEMBER CATTON: But if I don't know about it, 20 I'll never know that I quantified it.
21 CHAIRMAN APOSTOLAKIS: No, no. You know.
22 Like there are so many areas. I don't know. Once again, 23 organization --
r 24 MEMBER CATTON: Okay.
yl 25 MEMBER KRESS: If you look at uncertainty as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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536 1 degree of belief, quantification may not help you all that 73 2 much if it's just too much that you can't live with.
[ I l 3 CHAIRMAN APOSTOLAKIS: That's the second
\
1 4 bullet.
5 MEMBER KRESS: Yes.
6 CHAIRMAN APOSTOLAKIS: I don't object to that.
7 All I'm saying is separate what says all areas not covered 8 by risk analysis. Make that a bullet in its own right and 9 emphasize that that's where defense in depth really is 10 essential. That's all I'm saying. I am not eliminating 11 anything. I agree with what they have. That's all.
12 MEMBER KRESS: You're agreeing with --
13 CHAIRMAN APOSTOLAKIS: Yes. I agree with it.
('s) 14 MR. JONES: The specific words, I think, 15 George, does that. It says, "Where a comprehensive risk 16 analysis is not or cannot be done, traditional defense in 17 depth consideration should be used or maintained to 18 account for uncertainties."
19 MR. KING: These are not verbatim words in the 20 reg. guide. They are just --
21 MR. JONES: I don't think we have captured 22 your thoughts from the last meeting.
23 CHAIRMAN APOSTOLAKIS: All right. I think we 24 discussed this enough. Okay.
,A ;
q/ 25 MR. KING: Safety margins. We talked last NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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537 1 time about how do you know or make a judgment on whether
,_ 2 you've maintained sufficient safety margins. Again, the
(/ 3 reg. guide, the two bullets up there under the first line, 4 are what the reg, guide says. That you've got codes and 5 standards which are required to be met in certain areas, l 6 and then you've got your traditional engineering analysis, 7 Chapter 15 FSAR type things, which have specific numerical I
8 limits associated with them. And usually they're done j l
9 with a conservative or a bounding type calculation to I 10 judge whether you meet those limits or not.
11 But you also have risk assessment now in this i 12 process, and the way we view risk assessment -- and the 13 words are in the SRP -- basically says that you can use
,y
' 1
\_s 14 risk assessment to really help you focus on the important !
15 items, and the items where there is large uncertainty, i 16 where you might want to go and take a look at your 17 analysis methods, the conservatism in your methodology, 18 and so forth, to see if in doing your traditional 19 engineering analysis, and comparing it against whatever 20 your criteria are, is it sufficient, is it conservative 21 enough, does it need to be upgraded. Put the attention on 22 the areas that are really risk important.
l 23 Again, there has been words added into the SRP 24 that get that thought across, and that's how we view the
( ,) 25 use of risk assessment in the safety margin area.
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538 1 MEMBER CATTON: How do you measure margin
, ,_ 2 without the use of a probabilistic approac7? You can't.
i
'~-
3 MR. KING: Oh, sure you can.
4 MEMBER CATION: How?
5 MR. KING: And you can look at the -- you do 6 Part 100 dose calculations now. You've got a criteria 7 that you're supposed to meet.
8 MEMBER CATTON: Okay.
9 MR. KING: Some plants meet it better than 10 others.
11 MEMBER CATTON: You can say -- but that's very 12 deterministic. You either meet it or you don't. Okay.
13 But there are other arenas where you talk
,7 i )
\_/ 14 about safety margin, and then it becomes probabilistic.
15 So if you want to maintain the safety margin, you've got i
16 to -- you have a tough problem at hand. This has blocked 17 some people's entry into this arena, because they -- until l 18 they could come to grips with it.
19 MR. KING: We don't really have any criteria 20 that are expressed in terms or probabilistic values.
21 MEMBER CATTON: Well, it does help with the 22 word " sufficient" up there. It waffles it a little bit.
23 MR. KING: Yes. We put " sufficient" in l
24 because we didn't want to give the impression that you
(.
() 25 can't change your safety margin.
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_ . , . _ _ . _ _ . _ . _ _ _~_.____.__.__.._..........._..._.._.._.m>_m . _ . . . _ . ,
l 539 1 MEMBER CATTON: Well, see, that's not the-l- . .
2 problem. I don't think you can determine what it is with --
-1
. (m :
3- any -- without-a' lot of uncertainty.
~4' MR. HOLAHAN: Yes.
J t
S MEMBER CATTON: So if you want to maintain it, j 6 what are you maintaining?
'7 MEMBER' SHACK: You maintain sufficient safety j 8- margin. You may.be able to bound it initially , and you, 9 can bound it again, as'long as they're both' adequate. You 10 still don't know whether --
11' MEMBER CATTON: That's okay. But then you're 12 maintaining safety. You don't know if you're maintaining ;
13 a margin. ]
14 MR. HOLAHAN: No. There~are many cases,where i
15 it's the other way around. For example, just a simplified J 16 case where design criteria for a steam generator tube.may
-17 be that it's able to take three times its normal pressure 18 before it bursts.
, i l 19 MEMBER CATTON: Okay. I 1
l 20 MR. HOLAHAN: Okay? Deterministic design j l l 21 basis. This has nothing to do with the probability of -- !
22 ' MEMBER CATTON: It has nothing to do with 23 safety either, directly.
! l 24 MR. HOLAHAN: That's right. But what it says j
- 1 I 25 is when you're changing things, be careful about there NEAL R. GROSS
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~ -,r s--< v
540 1 being some safety margin in these sorts of components.
4 1
e- 2 Now, when you want to change that criteria,
\, i 1
~
3 what we're saying is you don't want to remove all of the l l
4 safety margin. For example, what you don't want is to j 5 design a system in which steam generator tubes burst all I 6 of the time, but you have very reliable systems to deal 7 with that situation. Okay? i 1
8 It says when you're doing engineering 9 calculations, and you're putting systems in place, you 10 should expect those systems to do what they were designed 11 for. So you're putting safety margin on the equipment 12 level, in addition to all of the other risk --
13 MEMBER CATTON: It's not really a safety
'- 14 margin, is it?
15 MR. HOLAHAN: Well, it's called safety margin.
16 MEMBER CATTON: Okay.
1 17 MR. HOLAHAN: You can call it engineering l 18 margin or design margin.
l 19 MEMBER CATTON: Because see, when you put the 20 word " safety" in there, and you use safety margin together 21 and maintaining it, you're talking about risk neutrality.
22 That is a major problem.
23 MR. HOLAHAN: Yes. I don't --
24 MEMBER CATTON: But that's not your intent.
O.
(,,/ 25 MEMBER FONTANA: The margins vary depending on NEAL R. GROSS COURT REPORTERS AND TRANSCRIPERS 1323 RHODE ISLAND AVE., N W.
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_ _ _ _ . _ . . _ _ .._..__.._._.m _ _ . . . . . _ ... _ __ _ .._ ._ _ _ . _ _ .
541 1 how precise you are. Like, for example, we design an 2 airplane to very exact things, and I design a bridge to
-t
'l 3 something else. And you design a bridge,.and put a factor ;
t- . .
l 4 of four on it; you can't do'~that on an airplane. ,
l- 'S MR. HOLAHAN: Right. .
-i
~6 MEMBER FONTANA: You could design it for all 7 of the loads impact -- the loads are much more precise and i 8 detailed. So that margin is going to vary.
l .-
! 9 MR. HOLAHAN: And it does vary now.
10 MEMBER FONTANA: And you've got some of that i
^
L 11 margin that's built into the codes and stand.srds I think
)
-.12 is why it - - ;
13 MR. HOLAHAN: Yes. i j- 14 MEMBER FONTANA: -- and it gives yo'u a margin i
l 15 for the component.
l l 16 MR. HOLAHAN: Right, i
17 To a certain extent, this says that, really,
- 18 that you should be doing good engineering. Okay? And 19 that it's not the intent of this risk-informed activity to
- . 20 encourage people to do ba'd engineering.
i l 21 CHAIRMAN APOSTOLAKIS: We can argue that l- 22 point, Gary, but let's go on.
I 24 I wasn't sure'.what the issue was you wanted to talk about, l
.25' because I think we had covered several times where we came l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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S42 l
1 up with the value that we're choosing for the CDF l 7- 2 benchmark, as well as the delta CDF guidelines that are in l( )
'~
3 the reg. guide.
4 MEMBER KRESS: I don't recall anybody having a l
l 5 problem with that.
l l
6 MEMBER FONTANA: No, we didn't have a problem.
1 7 At one time I asked why did you use 10 to the minus --
8 MEMBER CATTON: Dana did.
9 MEMBER FONTANA: He's not here. l 10 CHAIRMAN APOSTOLAKIS: I'm sorry. Mario?
11 MEMBER FONTANA: At one time, I asked the
, i l 12 question, why are you using 10-5 instead of 10-6 for large 1 l
13 release, and you said you back it off --
g
's- 14 CHAIRMAN APOSTOLAKIS: That's coming up.
15 MEMBER FONTANA: -- you back it off from the 16 quantitative health objectives, and it was more j 17 consistent. And that solved my problem. ;
I 18 CHAIRMAN APOSTOLAKIS: The real question here 19 is when we say 10" per reactor year, we mean all 20 initiators, all modes of operation.
21 MR. KING: Yes.
22 CHAIRMAN APOSTOLAKIS: Internal and external.
i 23 MEMBER CATTON: This is a yes.
24 MR. HOLAHAN: This is a yes, with the
,e 3
(_,) 25 exception of those things that the Commission said NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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S13 1 shouldn't be included in the sabotage.
,_s 2 MEMBER KRESS: Yes. I think that was the only l \
( 3 question we had.
4 CHAIRMAN APOSTOLAKIS: Okay. So that's a )
1 5 given, because that question will come up later.
6 MR. KING: And it's explicitly stated in the l
7 reg. guide now.
l 8 CHAIRMAN APOSTOLAKIS: Okay. So this is 9 almost and only initiators. j 10 MR. KING: Yes.
11 MR. HOLAHAN. Right. I 12 MR. KING: Yes. l l
13 CHAIRMAN APOSTOLAKIS: All right. Let's go em
)
- s. / 14 on.
15 MEMBER FONTANA: That might be all right, but 16 some of those things are not very well known.
17 CHAIRMAN APOSTOLAKIS: That's irrelevant.
18 MEMBER FONTANA: Right.
19 CHAIRMAN APOSTOLAKIS: Also, it doesn't 20 necessarily mean that you have to have all of these things 21 to make certain --
22 MR. HOLAHAN: Right. Right.
23 CHAIRMAN APOSTOLAKIS: It's like Level 3 PRA.
24 It would be nice to have it, but you don't always need it.
,/m (v ) 25 MR. HOLAHAN: Right. But you always have --
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544 1 MEMBER CATTON: I think Tom has been hammered i
f .s i
2 down. He has been hammered down.
\~'] 3 MEMBER KRESS: I really think you do need it, 4 but I think you have enough Level 3 information to --
5 MR. HOLAHAN: I would say that always have to 6 think about it.
7 CHAIRMAN APOSTOLAKIS: That's a nice way of 8 putting it.
9 MEMBER KRESS: If you didn't have the body of 10 Level 3 information you already have --
11 CHAIRMAN APOSTOLAKIS: It wouldn't be able to 12 move.
13 MR. HOLAHAN: Right.
p
) 14 CHAIRMAN A?OSTOLAKIS: Speaking of Level 3, 15 Rick Sherry raised an interesting point yesterday, he said 16 we have guidance how to make decisions using the 17 subsidiary goals, but we don't if we want to use the QHOs.
18 MR. HOLAHAN: Right. That's right.
19 CHAIRMAN APOSTOLAKIS: Did you hear that?
20 MEMBER KRESS: No, I didn't.
21 CHAIRMAN APOSTOLAKIS: Great. Why don't you 22 repeat what you told me yesterday.
23 MR. SHERRY: Earlier on, we were discussing 24 what were the fundamental objectives. We talked about
, O (j\ 25 CDF, LERF, and the safety goal QHOs. And the committee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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545 1 wrote a letter to the commission indicating that they e3 2 thought that the QHOs and the CDF should be elevated to a b 3 fundamental objective. But the LERF could be used as a 4 subsidiary objective for the safety goal QHOs.
5 And what I was remarking on was in the 6 regulatory guide, there are no guidelines for the QHOs for 7 one of the fundamental -- or the fundamental objective.
8 So for the case that an applicant may come in with a full 9 Level 3 PRA, for comparison against the safety goal --
10 directly for comparison against the safety goal QHO, there 11 are no guidelines in the regulatory guide. And I'm afraid 12 that this would result in the staff delaying the review of 13 that particular applicant's request.
l i
14 CHAIRMAN APOSTOLAKIS: So if you have a lot 15 of, say, PRA, you may be penalized, in fact, and not use l
16 the final results.
l 17 MR. HOLAHAN: I guess I -- maybe I'm not 18 reading the same letter. But when I read the 19 November 18th letter from the ACRS on the subject, I 20 thought it was suggesting that CDF and some qualitative or 21 quantitative evaluation of possible Level 2 and Level 3 i
22 PRA issues should be done. And then the suggestion was 23 this idea of actually using Level 3s and QHOs was 24 something to be thought of in the distant future, but not i
.) 25 necessarily something that we were ready to do now.
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546 1 MEMBER CATTON: On the other hand, you don't rs 2 want to discourage it.
I \
L/
l 3 MR. HOLAHAN: Well --
4 MEMBER KRESS: I think you're reading that 5 correctly.
6 MR. HOLAHAN: Yes. And so we're writing 7 guidance documents based on what is the current state of 8 the art, and so our criteria address fundamentally Level 1 ,
9 and Level 2, and we've picked the Level 1 and Level 2 10 guidelines to be what we think is consistent with the 11 QHOs. And that's about the best level of practical 12 guidance that you can use today.
13 CHAIRMAN APOSTOLAKIS: Well, there is no l
gS 1 ? i
'7 14 question that that's the case. The thing is that it's a 15 little ironic that the basic objective is really the QHO, I 16 and yet there are no guidelines what to do if somebody 17 takes the time and effort to do a Level 3 PRA. So --
18 MR. HOLAHAN: Well, I think necessarily, I 19 mean, any applicant who would do that ought to recognize 20 that it wouldn't be so easy for us to decide how to deal 21 with that.
22 CHAIRMAN APOSTOLAKIS: Maybe that's something 23 we can think about for the future.
24 MR. KING: Yes. We do have a question in the (q_,/ 25 Federal Recister notice that's going to issue these things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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547 1 for comment.
-, ~3 2 CHAIRMAN APOSTOLAKIS: Is that out?
t 4 N/ !
3 MR. KING: No. No. It will announce the J 4 availabilities for comments and have a bunch of questions. ,
l 5 One of those questions is: should we have guidelines on 6 using QHOs to assess changes? So we have kicked this ;
7 around internally and have decided at this point the best 8 thing to do is put it out for comment, put that question !
9 out for comment and see what kind of feedback we get.
10 CHAIRMAN APOSTOLAKIS: That's fine.
11 MEMBER KRESS: Now, the only real problem I 12 have with this is I sure do wish you would change what 13 you're calling the LERF and call it an early containment (y
t s A's 14 failure frequency, because it just confuses people every 15 time they see LERF. You know, I don't know if that's a 16 substantial change you'd have to make, because you'd just 17 go through and change it to early containment failure 18 frequency. But --
19 CHAIRMAN APOSTOLAKIS: Is this containment 20 frequency?
21 MEMBER KRESS: That's what that is, LERF.
22 MR. HOLAHAN: Well, but it's contingent on 23 there being a substantial core melt. Okay? And it takes 24 into consideration -- I mean, this was part of the lh is ) 25 discussion yesterday. It takes into consideration the l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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..______.__.__.._.___..__-.,_._.__.__..__._-__..._._..._.m _
l 548 .l I
1 size of the source term. I mean, there is an element of- l l
2~ large to it, in addition to there'being an element of 'l V 3 early. I 4 MEMBER KRESS: Large early containment 5 failure.,
6 MEMBER SHACK: It also takes into account l
)
I 7 scrubbed and unscrubbed.
8 MR. HOLAHAN: Right.
]
9 MEMBER KRESS: Yes,.it does.
10 MR. HOLAHAN: Yes. l 11 MR. SHERRY: But I think we're -- we have to 12' make a distinction between two things. One is the 13 definition of LERF that's in the body of the regulatory b
b 14 guide, and the way that you perform the simple calculation
-15 if you don't have a full-blown Level.2 in Appendix B. And 16 Appendix B'is where you bring in the idea of looking at a 17 scrub release, you-look at timing of release. relative to- -
18 time,-and you get protective actions. But that's not.
19 apparent in the definition of the LERF in the regulatory 20 guide which is simply a definition of early containment-L 21 failure with core damage.
22 MEMBER SHACK: I went back and I looked at 23 that yesterday, and it was true that you guys changed the l: _
24 definition of a LERF. 'You first had the scrubbing in it, f
25 and then you took it out and I believe you explained it to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.; N.W.
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5491
! 1 us that it was because you were being consistent with the
,,S - 2 way LERF was defined in other documents.
I
~
3 MR. HOLAHAN: Yes.
I 1
4 MEMBER SHACK: And so you're basically l 5 following a bad precedent. l 6 (Laughter.) j l
4 7 MR. HOLAHAN And the footnote says so.
]
l 8 (Laughter.) ,
l l
9 MR. KING: The official definition in the reg.
10 guide follows the precedent set in the regulatory analysis 11 guidelines. Our simplified method in Appendix B refines 12 that a little bit in that it eliminates the scrubbed 13 releases. If we were going to do it exactly, we'd go back
- 14 and leave everything in, and it would be a containment 15 failure frequency.
16 CHAIRMAN APOSTOLAKIS: So where does this 17 leave us? What do we do with this?
i j
18 MEMBER SHACK: It's a question of whether it's j 19 a foolish consistency or not.
20 MEMBER KRESS: Well, as long as you -- )
l 21 MEMBER SHACK: The operational defir.ition l l
l 22 seems sensible enough. The formal definition has 23 problems.
24 MEMBER KRESS: Yes.
- (n i, ,) 25 MR. HOLAHAN
- I think we have to think about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 550 )
! i 1 that. I'm not sure what -- how many degrees of freedom we i
! l 7w 2 have in -- to be inconsistent with the regulatory analysis !
, i I O'
3 guidelines.
l 4 MEMBER KRESS: Well, just think about it. You 5 know, if --
6 MR. HOLAHAN: Yes.
7 MEMBER KRESS: It's not that big a deal, since 8 you do define it and discuss it pretty well.
9 MR. HOLAHAN: Yes.
l i
10 MEMBER KRESS: Every time I see it, I'm -
11 looking for magnitudes of source terms. It's really not 12 that, but it's implied in it.
13 MR. HOLAHAN: In the footnote, it talks about ip)
V 14 there being an accident.
15 MEMBER KRESS: Yes.
16 MR. HCLAHAN: And it seems to me that we could i
17 put in a parenthetical description of what kind of j 18 accident you're talking about, identifying, you know, the 19 magnitude of the source term and the scrubbed or not 20 scrubbed, or something like that. l 21 MR. KING: We could clearly do that.
22 MEMBER KRESS: But clearly, you guys know what 23 you're talking about, and you've got the right idea. So I 24 don't have problems with it conceptually.
/^T
- (/ 25 MR. HOLAHAN
- But I can see a problem in not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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551 1 doing it, because when we come back to the committee on l
,s 2 issues like the steam generator rule, you'll want to know ,
( )
s~~/
3 which one we're talking about.
4 MEMBER KRESS: Yes.
5 CHAIRMAN APOSTOLAKIS: So --
6 MR. HOLAHAN: All right. Why don't we relook 7 at that. Okay, i
8 CHAIRMAN APOSTOLAKIS: Okay. )
l 9 MEMBER KRESS: And I think you -- the question i
10 I have had previously about this, whether the .1 was 11 really a bounding analysis for all sites. It was pretty l 12 well answered, I think, by your discussion on that, and so 13 I no longer have an issue with that or a question.
[VI 14 MR. HOLAHAN: Okay.
15 (Slide) 16 MR. KING: Temporary changes in risk. I had j 17 shown the Committee a slide a couple of weeks ago that had !
18 some wrong information on it. And I was informed of that.
19 What has changed is the next to the last bullet.
20 What I had shown you before was something that )
21 was said during an AOT during the time period we looked at 22 the entire CDF as part of looking at temporary changes in 23 the tech spec area. That's not true. We only look at the increment above the baseline CDF in terms of comparing to 24 f3
's ) 25 these probability limits up there.
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1 552 l
1 I think you went through all of this yesterday
, .s 2 with the tech spec folks. I'm not sure if there's another i s t.1 3 other issue you wanted to talk about.
\
1 I
4 CHAIRMAN APOSTOLAKIS: So the bullet before 5 last?
6 MR. KING: Yes, the next to the last bullet.
7 CHAIRMAN APOSTOLAKIS: Next to the last.
8 MEMBER FONTANA: Does the bullet before last, 9 then, say that you can increase a CDF by 10 percent, 10-4, 10 10'8 and --
11 CHAIRMAN APOSTOLAKIS: No. Let me understand ,
i 12 first what that means. Let's understand what it means 13 first. I have a five-hour AOT. How do I convert that to p).
U 14 10'3 per reactor year?
15 MR. KING: During that five-hour period, 16 you've got some equipment out of service. That causes i
l 17 your risk to be higher. If you would assume that that 18 condition was in place for a full year, that would 19 correspond to a 10'3 per reactor year CDF.
20 MR. JONES: Take the five times 10-7 and divide 21 it by the time frame, five hours, convert it back to 22 years.
23 CHAIRMAN APOSTOLAKIS: That's one way of 24 defining it per reactor year. Another way might be here
()
/\
25 is the probability that in one of these outages, I will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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553 l
1 have a core melt. Then here is how many times I do this
, 2 in a year. And multiply it by that probability. That is,
( )
s'/
3 then, the frequency per year.
4 MR. KING: That's another way to do it.
5 CHAIRMAN APOSTOLAKIS: But it seems to me 6 that's the correct way --
7 MR. JONES: But the problem is --
8 MEMBER KRESS: You're looking at each 9 individual.
10 CHAIRMAN APOSTOLAKIS: Yes, that's looking at 11 the individual.
12 MR. JONES: The problem is the AOTs are not 13 directly related to what you're saying, George. You can't
,r 3
'k /) 14 say an AOT is used six times a year at a plant 15 necessarily. We --
16 CHAIRMAN APOSTOLAKIS: How many times did --
17 MR. JONES: We looked at the difference 18 between AOTs, short ones and long ones, and to what impact 19 it had on equipment unavailability. At least that's what 20 the tech spec people said yesterday.
21 And there is no correlation. The fact that 22 AOT may be long or short for a piece of equipment does not 23 appear to directly correspond to an unreliability or an 24 unavailability for the piece of equipment.
( .- 25 MEMBER KRESS: Yes. But that doesn't address NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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554 1 doing it over and over and over again.
,m 2 MR. JONES: Right. Now, the way the tech t \
C/ 3 specs are put together, what if they are planning to use 4 -- if they come in for an AOT for some extended period of 5 time and if their plan is to then use thm. co do online 6 maintenance, for example, then they are supposed to take.
7 They're supposed to estimate the effect of doing the l
8 additional online maintenance, however many times they i 1
9 intend to do it, and look at its overall impact on risk .
I 1
10 over the year, the oCDF over the year. ,
I 11 This is a control on just what's the effect l
12 over a real outage time. They've got to do both.
13 CHAIRMAN APOSTOLAKIS: This is artificial.
ps, 3 t
G 14 Let's not talk about how we ought to do it. I mean, 15 assuming that this condition applies to the whole year is 16 as artificial as anything.
17 MR. KING: Yes. Buc I only did that to --
18 MEMBER FONTANA: Let me make a comment here.
19 Why don't you just get rid of that bullet, second to the 20 last bullet, and go back up to the two big fat bullets i
21 there and use the formula that they used yesterday? Then 22 you're home free, aren't you?
23 CHAIRMAN APOSTOLAKIS: I don't like the 24 formula.
(.
(/ 25 MR. KING: The only reason the next to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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555 l 1 last bullet is in there is I thought it might be helpful l
g,x 2 to the Committee since people usually think in annual
' \
~'
)
3 average terms just to convert these probability numbers to 4 some annual average CDF.
5 MEMBER KRESS: But that's just a normalizing 6 term. That doesn't really enter into the principle thing.
7 MR. KING: No, it doesn't. It's just an 8 illustration. That's all.
9 MEMBER KRESS: Yes.
10 MEMBER FONTANA: If you know how to do the two 11 big, fat bullets up there, I don't think you'd need the 12 example. Art I not right?
13 MR. KING: This example doesn't show up in the
\' ') 14 reg guide or the SRP. It's only on this viewgraph because 15 I thought it might help the Subcommittee.
16 CHAIRMAN APOSTOLAKIS: Yes. But my point is i
17 that if you do what I suggested to the example, then you l l
18 may end up with a core damage frequency per year that's i
19 pretty high. And you may have to go back and change the 20 increment.
21 MEMBER KRESS: Yes, you might have to change i
22 that.
23 CHAIRMAN APOSTOLAKIS: Because when you say 24 "per year," it really has to be realistic.
,/ 3
( ,)
25 MEMBER KRESS: It's the principle of both the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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556 1 first bullet and this thing we're talking about.
p 2 CHAIRMAN APOSTOLAKIS: Yes.
3 MEMBER KRESS: They're both involved in the 4 principle.
5 CHAIRMAN APOSTOLAKIS: Yes. Now, would the 1
I 6 third collection of bullets there, "These guidelines are 7 stated," apply also to low power in shutdown? And if not, 8 why not?
9 And why do we have an incremental conditional 1
10 core damage frequency probability here of this magnitude?
11 Essentially what you're saying is that you have a 12 configuration that is really not desirable.
,_ 13 MR. KING: Yes. You mean would it apply for i \
t
\- 14 the entire shutdown period, --
l 15 CHAIRMAN APOSTOLAKIS: Yes. I l
16 MR. KING: -- that that's your AOT basically?
17 CHAIRMAN APOSTOLAKIS: No. At 5 times 10-' .
l 18 In other words, you go out for so many days. Make sure 19 that the incremental conditional core damage probability 20 is less than 5 times 10
21 MR. KING: Yes. I'm not sure --
22 MR. CARROLL: That's going to be difficult, l 23 though, because of decay heat.
24 MR. KING: But a number of tech specs don't p
(_) 25 apply it.
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557 1 MR. JONES: How we use this --
,-- 2 MR. HOLAHAN: I wouldn't do that because if I
)
3 you go back up to the big bullets, remember what we said.
4 Those numbers correspond to one-half of one percent of the 5 risk. Okay? I don't think we want to establish that as 6 our guideline for how much of the risk ought to be 7 associated with shutdown.
l l
8 It seems to me one-half of one percent is an l l
9 unrealistically low goal for the portion of risk 10 associated with plant outage. It doesn't need to be that 11 low. These are things that apply to numerous systems and 12 could be used every month numerous times on various pieces 13 of equipment. Presumably your -- i
,./"'N l
'ss' 14 MEMBER KRESS: It's a different animal. i 1
15 You're right.
16 CHAIRMAN APOSTOLAKIS: But this applies to l
17 each individual outage.
18 MR. HOLAHAN- Right.
19 MEMBER KRESS: That's why it's --
20 CHAIRMAN APOSTOLAKIS: Even though you have 21 numerous pieces of equipment.
22 MEMBER SHACK: But then you go to the next 23 bullet. You have to put the annual average on top of it, 24 too.
7m
! ) 25 CHAIRMAN APOSTOLAKIS: Yes. See, the v
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l 558 l 1 essential element that's missing here is how many times 7- 2 you do it.
i! )
3 MEMBER KRESS: Yes. And I think that is 4 essential. And it has to be sort of implied in this 5 number.
6 CHAIRMAN APOSTOLAKIS: And it was implied, 7 yes.
8 MEMBER KRESS: So it could be, for example, 9 you would have a different item in the AOT ell the time so 10 that you could be operating all the time at a CDF 10-3 11 MR. HOLAHAN: Yes.
12 MEMBER KRESS: And that addresses your number.
13 You're saying that never happens.
n 1
?
)
L/ 14 MR. HOLAHAN: Right.
15 MEMBER KRESS: And your experience has been l
16 that now that things are out of service a given amount of l 17 time over the year is such that you could probably stay in ]
18 this level.
19 MR. HOLAHAN: Right.
20 MEMBER KRESS: And I think that's reasonable.
21 MR. HOLAHAN: Our experience is the PRA values 22 that we see out there now, to the extent that they're 23 calculated with the unavailabilities that plants actually 24 experience.
A
( 25 MEMBER KRESS: I still think there's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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559 1 principle here that needs to be better articulated. i 1
g~3 2 MEMBER SHACK: But the annual average gives )
() 3 you the benefit of cumulative.
4 CHAIRMA.N APOSTOLAKIS: Which annual? There's 5 no annual. i 6 MR. JONES: The Bullet 4, Bullet 4.
7 CHAIRMAN APOSTOLAKIS: What is that?
8 MR. JONES: "these guidelines are applied in 9 addition to the guidelines on annual average CDF/LERF 10 contained in the general SRP."
11 MEMBER SHACK: There's a limit on the 12 increment and on the --
13 MEMBER KRESS: Oh, you're right. You're V 14 right.
15 CHAIRMAN APOSTOLAKIS: Where is the annual 16 again? l l
17 MEMBER KRESS: Does the annual average include l 18 these temporary specs? I 19 CHAIRMAN APOSTOLAKIS: In addition to the !
20 others.
21 MR. JONES: Yes. Specifically in the reg 22 guide, the tech spec reg guide, they are to estimate the 23 annual effect associated with the change of the AOT.
24 MEMBER KRESS: Okay.
(,) 25 MR. JONES: So if they are intending, in fact, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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560 1 to change their practices, which could impact, then, of i
,S 2 course, the unavailability, they're to try to estimate i 1 L.J 3 what that means. So if they think they're now going to 4 use it 20 times, they'd have to account for it 20 times.
5 MEMBER KRESS: In that case, these two bullets 6 seem to cover it.
7 CHAIRMAN APOSTOLAKIS: Well, I don't know. I 8 don't think we should talk about it. Let n.e offer you an 9 alternative. Let's think in terms of aleatory changes. I 10 look at time and --
11 MR. CARROLL: What are those, George?
12 CHAIRMAN APOSTOLAKIS: Look at my hand. This 13 is time. And the frequency of core damage, the way PRA
/
/^si x' 14 calculates it, is an average over time at full power 15 because there are some variations that we have. So these 16 aleatory random kind of variations are average time.
17 There are certain instances, though, where you 18 have significant changes in the plant, that you don't want 19 to average those. And this is when you're at low power, 20 certain major things. The configuration now is different.
21 But these are again changes in time. So if I 22 look at the time axis, I will have some sort of an average 23 here. But then they will have some aleatory changes. How 24 about if -- yes, down, too.
/~
\ ,)T 25 How about if we say the goal is 10~4 per NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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561 1 reactor year for the average and at no time, under no 7-^3 2 configuration, you should exceed 10-2? That's an alternate U 3 way of doing it.
4 MR. HOLAHAN: That's an alternate way of doing 5 it. However, it seems to me that you probably don't need 6 that criteria, that it will never be controlling. I don't 7 object to it.
8 CHAIRMAN APOSTOLAKIS: Why?
9 MR. HOLAHAN: Because I don't think you can 10 achieve --
11 CHAIRMAN APOSTOLAKIS: Then I don't have to 12 distinguish between AOTs and low power and shutdown. I 13 mean, I have a universal criterion. You will not be
/ )
Y2 14 allowed to be in a configuration where the core damage 15 frequency now exceeds this 10-2 This is unacceptable.
16 MR. HOLAHAN: How could you get to a 17 configuration that reached 10-27 18 CHAIRMAN APOSTOLAKIS: Well, not all. You 19 want to argue about the number. No. I want to establish 20 a principle as the job goes.
21 MEMBER KRESS: Do you have the --
22 CHAIRMAN APOSTOLAKIS: Better we negotiate the 23 number.
24 (Laughter.) ;
i ,) 25 MEMBER KRESS: Do you have any initiating NEAL R. GROSS I I
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1 562 1 frequencies that are bigger than 10-27 2 MR. HOLAHAN: Yes.
O 3 MEMBER KRESS: Okay.
4 MR. HOLAHAN: .But for none of those do we 5 allow the plant'to operate with no equipment available.
6 MEMBER KRESS: Yes.
7 CHAIRMAN APOSTOLAKIS: How about 5 ties 10'3?
8 I mean, I. don't care.
9 MEMBER KRESS: Whatever the number is?
10 CHAIRMAN APOSTOLAKIS: Yes, whatever the 11 number.is.
12 MEMBER KRESS: How about 10 ~ 3 during a 5-hour 13 --
l 1
C 14 CHAIRMAN APOSTOLAKIS: No, no. Don't specify_ ;
- - 't 15 the time. l
- 16. MEMBER SHACK: He has basically limited the i
17 peak alreadyLto 10',3 18 MR. HOLAHAN: No. !
L 19 CHAIRMAN APOSTOLAKIS: That's an unrealistic 20 number, then, because1he assumes that you are in that
- 2'1 condition for-the whole year. How many times.you do it is t
l 22 not embedded in this.
! 23 MR. KING: And that's just an illustration.
1-24 If it was an one-hour AOT, it would be 5~ times --
25 CHAIRMAN APOSTOLAKIS: Yes.
f L NEAL R. GROSS
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+ -
c -,- , . - , , , _ . - -
563 1 MEMBER CATTON: I could increase it at 10-' to
,, 2 one if I reduced the time to --
l x
'- 3 MR. HOLAHAN: That's right.
4 MR. KING: See, that's what I'm saying.
5 MR. HOLAHAN: However, in doing that, if you ;
6 look at those configurations, you'll see that they're )
7 eliminated by other considerations.
8 CHAIRMAN APOSTOLAKIS: There is also an issue l l
l 9 of consistency that we are regulating in terms of core 10 damage frequency. And I think it's a clean way of doing 11 it.
i 12 What I think is really that we haven't thought j 13 about this.
() 14 MR. HOLAHAN: Yes. And that's why I've l l
15 written a note that says, "The staff needs to clarify the 16 intent, definition, and need for an additional guideline 17 on temporary changes, including the" -- i l
18 CHAIRMAN APOSTOLAKIS: So I offered you an 19 alternative, then, --
20 MR. HOLA1UW: Yes.
21 CHAIRMAN APOSTOLAKIS: -- which I think is the 22 advantage of being --
23 MR. KING: And you will notice the last 24 bullet. We've already realized that. And we do have a x
() 25 question in the " Federal Register." Is this good enough NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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564
' 1' or do we --
2 CHAIRMAN APOSTOLAKIS: So let's agree to think O 3 about it.
MR. HOLAHAN:
4 And I t.hink the level at which 5 you would like to think about it, I don't like inventing.
6 expectations or guidelines that don't have=any principles 7 to derive from. I think we need to think all the way back 8 to say, "Does this imply that'we have some hidden 9 principle that we haven't articulated?" --
10 CHAIRMAN APOSTOLAKIS: Correct.
11 ~MR. HOLAHAN: -- or is this some way of, some 12 mechanism of, implementing'some of those other principles?
- l'3 Is this providing defense-in-depth? What is this doing?
, rr 14 CHAIRMAN APOSTOLAKIS: Well, I'm giving you a i 15 principle of doing everything here in terms of core damage
( 16 frequency. And I want to maintain that philosophy.
l 17 MEMBER MILLER: So your philosophy was set an' 18 upper limit'.
.? CHAIRMAN APOSTOLAKIS:
Yes.
l 20 MEMBER MILLER: -- the upper limit they just j i..
(21 chose.
! l l
22 MEMBTR FONTANA: When I read this, this is.
23' going to be --
l 24- CHAIRMAN APOSTOLAKIS: .They go through the-25 traditional probability.
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l 565 1 MR. HOLAMAN: Remember, none of our other 2 principles have numerical values. They're some basic
\~j 3 principles for which then you would derive this 10-2 as a 4 good -- ,
I 5 MEMBER KRESS: There has to be a principle of 6 meeting a QHO or a principle of defense-in-depth or --
l 7 CHAIRMAN APOSTOLAKIS: No. '
8 MEMBER FONTANA: No. Wait a minute. I'm 9 going to be Napoleon's colonel here. When I get to read 10 what you guys write, I will know what the probability of 11 an event happening during an AOT is. And you're going to 12 tell me what the sum is for the whole year in some way.
13 And that will tell me how many AOTs of that kind I can i
G 14 have or something like that. Isn't that correct?
15 MR. HOLAHAN: Yes.
16 MEMBER FONTANA: Okay.
17 MR. HOLAHAN: That only addresses the integral 18 effect --
19 MEMBER FONTANA: That's right.
20 MR. HOLAHAN: -- and not the height of any 21 individual spike.
22 MEMBER FONTANA: Exactly.
23 MR. HOLAHAN. And the question is: At a 24 principle level, at a philosophical level, do we want to O,
( j 25 control how high risk can be, regardless of how limited in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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566 1- time that is?
2 MEMBER MILLER: See, last time you said you 3 didn't want to do that.
l 4' MEMBER FONTANA: You probably have other rules ,
S' covering that because --
6 MR. HOLAHAN: I'm not sure the answer is yes. !
7 MEMBER FONTANA: -- I could stand a l 8 containment wide open for something like -- ,
MR. HOLAHAN: Right.
10 MEMBER FONTANA: At 10-* core damage frequency, 11 I can stand a containment wide'open 2 and a half hours. ,
l 12 And you don't want to do that. There's.'something else
'. ; . hat's going to keep that from happening.
!O 14 MR. KING: Defense-in-depth. )
15- CHAIRMAN APOSTOLAKIS: I think the principle i l
16 that I'm advocating.is consistency. It's a non-spoken 17 principle. Since you are regulating everything in terms 18 of core. damage frequency except for this -- and I'm saying 19 this is -- but, again, let's go on.
L 20 MR.-HOLAHAN: I agree. I agree with your.
L i .
! 21' thinking about it l, 22 CHAIRMAN'APOSTOLAKIS: The point has been 23 made. '
[ 24 (Slide) l
~ 5 25 MR. KING: Okay. The last item on your list I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE. N.W.
(202) 234 4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 l ., ~. _ . . ,_ ,. _ , , _ . , _ . .
_ . _ . .. _ . _ . .. _. , - _ . _ ... ~ . _ _ _ ___ _ . _ _ _ . _ _ _ ._ _ ._ _ . _ _._. . . . _ .... _ .
567 1
1 of issues was'the subject of peer review ~versus expert You had seen this slide before briefly the last
- g. 2. panel.
V 3 time we talked. Basically peer review as.we' define it in 4 the reg guide and SRP is one acceptable way.for licensees S- to assure quality of a PRA. It's not required, but it is 6 something we recognize as if the licensee wants to have a
.7 peer. review, they can do that.
8 MEMBER CATTON: Here.it is. When you~say 9 " peer" --
10 MEMBER POWERS: Within the technical 11 community, there have been a lot of assaults on the 12 concept of peer review for a v'ariety of different reasons.
13 Have you had a chance to look at those various D
'.V- 14 investigations of peer review and see if any.of the 15 concerns.that people have expressed about peer review as a
'16 quality-assuring device are not applicable to.you?
/17 ' MR. KING: No. I'm not even sure which 18 studies lyou're referring to.
i 19 MEMBER POWERS: NSF had a study. NIH has had l 20 a study. There.have been a' lot'of them. And they tend to-l !
.21 be more academically oriented than this. .And a lot of the 22 concerns are things that may not be applicable, too, the
- 23. old boy networks and things like that, you know. He who L
i 24 writes the language the same way I do tends to get a
-25. better peer review than other people, things of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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568 1 nature.
,, 2 And so it may be that peer review in the l ) l 3 context you're doing is so different than where these 4 studies are that they're just not applicable. But people 5 have begun to question how valuable peer review is as a 6 quality-controlling mechanism.
7 MEMBER CATTON: It depends on how good the 8 person who selects the peer reviewers is. You can get 9 whatever level you want. That's what it was missing here. l 10 There's no statement of independence. Peer review is 11 really not peer review unless it's independent.
i 12 CHAIRMAN APOSTOLAKIS: And, again, what is <
13 independence is --
,r\ l
(_) 14 MEMBER CATTON: Doesn't work toc the 15 utilities.
16 CHAIRMAN APOSTOLAKIS: -- a discussion.
17 MEMBER CARTON: That would be one definition l
18 of independence you might use. l l
19 CHAIRMAN APOSTOLAKIS: Well, I think a useful 20 place to go to to get some more insights on this is this 21 document of which I'm a coauthor of. So I can't mention 22 it; right? It's an NRC document. Okay. I will not 23 mention the document you should go to. I have a conflict.
24 MR. KING: Pre-decisional. This is a
(-. 25 pre-decisional --
()
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569 1 CHAIRMAN APOSTOLAKIS: It's a NUREG in print.
fm 2 MR. KING: Well, then why can't you mention i \
%J 3 4 CHAIRMAN APOSTOLAKIS: Reviewed by the 5 academy.
6 MR. KING: This is the one on high-level waste 7 peer review, high-level waste --
8 CHAIRMAN APOSTOLAKIS: Can I send them to some I l
9 stock member? This is an entirely different thing.
l 10 MR. HOLAHAN: May I ask a question? Is Mr. ;
11 Markley one of the authors? l l
12 CHAIRMAN APOSTOLAKIS: No.
l 13 MR. HOLAHAN: Could he tell me the name of it?
p) i
\d 14 CHAIRMAN APOSTOLAKIS: He doesn't know. I can I 15 tell him, though. No, no. This is not human factors.
16 The mike. You're not using the mike. l 17 MR. MARKLEY: I'm not sure what document 18 you're talking about now, George.
19 CHAIRMAN APOSTOLAKIS: There's a hell of a lot 20 of discussion on peer review, though.
21 MR. HOLAHAN: Yes. And we recognize that 22 people are going to --
23 CHAIRMAN APOSTOLAKIS: Is it okay if I give 24 them the NRC staff member thing? Andy Murphy.
p i 25 MR. HOLAHAN: I don't understand the --
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y 570 1 CHAIRMAN APOSTOLAKIS: Andy Murphy.
gy 2 MR. HOLAHAN: Andy Murphy. We know who Andy
(~') 3 Murphy is.
4 CHAIRMAN APOSTOLAKIS: Okay.
5 MR. HOLAHAN: I don't understand the problem, 6 but I presume I'll be able to later.
7 CHAIRMAN APOSTOLAKIS: If I am involved in a 8 piece of work, --
9 MR. HOLAHAN: Yes.
10 CHAIRMAN APOSTOLAKIS: -- I'm not supposed to 11 talk about it as a member of this Committee because I'm 12 promoting my own work, --
13 MEMBER CATTON: But I don't think --
,n.
l 14 CHAIRMAN APOSTOLAKIS: -- which in this case 15 doesn't apply at all.
16 MEMBER CATTON: I don't think there are any 17 rules against you giving us information.
18 MR. CARROLL: That's a published work, George.
19 It isn't as if you're --
20 MEMBER KRESS: Don't question what George just 21 said because he's had some experience that leads him to 22 behave this way. And I think he's doing --
23 MEMBER FONTANA: We're not lawyers. So we'd 24 better be quiet.
(~'N, 25 MEMBER SEALE: If he's being bullheaded, it's
()
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i 571 l 1
1 because somebody has waved a red flag in front of him. j
,s-2 MR. MARKLEY: George is doing the right thing t >
x./
3 here. l I
4 CHAIRMAN APOSTOLAKIS: I can't tell you what 5 this excellent piece of work is.
6 (Laughter.)
7 MEMBER MILLER: If you find out about it, 8 you'll want to buy one.
9 CHAIRMAN APOSTOLAKIS: I don't even remember 10 the damn thing, but I gave him the name of the person 11 here. l 12 MR. KING: We'll find out. I know there's I
13 also a NUREG on peer review of the high-level waste I
(~'N i i
t )
\/ 14 repository that's out, published as well.
15 The National Research Council is doing a study 16 now on peer review of research programs for DOE. So, I 17 mean, I know there are things going on in peer review.
18 We do it in research on codes, on issue 19 resolution, and so forth.
20 CHAIRMAN APOSTOLAKIS: Look at the ACRS. What 21 kind of peer review was this one on risk-informed 22 regulation? It's what some people call participatory peer 23 review.
24 You guys have been coming here periodically,
/D
() 25 telling us. That brings up the issue of independence, by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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572 1 the way, telling us what you're doing. We gave you advice L
p 2 and so on.
U ~3- Then you have other things, such as I think 4 the human performance plan, which was presented to us i
i 5 after the fact. And we just made comments. That's a I l
-l 6 different peer review. Okay? .
1 l
7 So one question there is: Well, should you '
f 8 address'that? .I mean, should the peer review be j j_
L 9 participatory?- Should it be after the fact? How much 1
10 af ter-i )
i 11 I don't know. I don't know. But since you 1
12- raised the issue, these are the kinds of things people are l 13- talking about these days. 1 14 MR. KING: Well, we tried to lay out in our 7
15 NUREG-1602 - ..there's an appendix on peer. review. If'
! 16 somebody wants to use that as a way to ensure quality in
! 17 their PRA, we have.some information on what we consider-18 the elements of a good peer review. And those are the 19 topics that it covers.
l 20 CHAIRMAN APOSTOLAKIS: It may be a pattern.
i 21 These reviews are always after the fact. They never tell 22 you.
l
- l. 23 MEMBER. POWERS: -
Oh, no. j i
'24 CHAIRMAN APOSTOLAKIS: Very rarely they tell 4
'25 you something in --
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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573 1 MEMBER POWERS: Oh, no. The waste repository
,- 2 work has been an ongoing committee where everything had to i
3 go through them.
4 CHAIRMAN APOSTOLAKIS: Okay. Yes, yes. These 5 are the -- but they cannot tell you when you make a 6 presentation. They cannot do what we are doing now to 7 Gary and Tom and Bob and say, " Gee, I don't like this. I 8 like that " You can't have a discussion.
9 MEMBER POWERS: Why not's 10 CHAIRMAN APOSTOLAKIS: Because you have to 11 wait until they write the report because their report is 12 supposed to be reviewed by 11 other guys. It's much --
13 MEMBER POWERS: Before they write a report.
p
-) 14 But they would probably be anxious to_tell Gary if they 15 didn't like about anything he did. Everybody else does.
16 MEMBER KRESS: They wouldn't find anything.
17 CHAIRMAN APOSTOLAKIS: No, not Gary.
18 MEMBER KRESS: No.
19 MR. KING: The second topic, " Expert Panel,"
20 again, that's mentioned in the reg guides and SRPs as one 21 acceptable way to do the integrated decision-making. And 22 there is an appendix in the general SRP whose title is not 23 " Expert Panel." It's called " Integrated Decision-Making."
24 In there there is a discussion of expert panel.
25 So those are how we're using those two ideas (A)
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574 1 in the context of the reg guide and SRP.
s 2 MR. HOLAHAN: I think we really haven't i )
\~/ 3 officially defined and prescribed how these things should 4 be done. But what we're reflecting is the fact that our 5 experience I think has been good in both of these areas.
6 Where we have seen peer reviews done, where we 7 see one utility review another utility's PRA, or whether i 8 they go out and get a consultant to do them, they find 9 useful things.
10 And I think you heard both the staff and the 11 utility speak about how its expert panels have functioned 1
12 on some of these issues. And they appear to be very 1 1
13 valuable. So we're encouraging things that we think have j t
/~N t
\/ 14 been working well.
l 15 CHAIRMAN APOSTOLAKIS: And I'm not sure you j 16 need to prescribe everything. l 1
1 17 Now, I'm sorry. I should have members of the 18 public and the industry if they wanted to make any ;
I 19 comments on the stuff we have been discussing.
20 MEMBER POWERS: George, before you do that, 21 could I come back to a Slide 6 or on that LERF guideline?
22 I apologize I wasn't here when you discussed this, but I 23 just wanted some clarification.
24 It is for sure true that the LERF, as you've
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575 1 10" CDF and .1 conditional containment failure l l
,3 2 probability. I believe it's just a product of the two, I
( ~'
)
3 and so it's identical.
4 The one I didn't understand was why it is 5 consistent with the suggested 10" per reactor year large 6 release guideline, especially in light of the way that the
'7 calculational approach you adopt when you don't have a 8 Level II PRA seems that it would lead to something very 9 close to a 10" large release.
10 MR. KING: Yes. Maybe I was a little too 11 cryptic. It says, " consistent with previous analysis of
. 12 suggested 104." The previous analysis we did was because 13 the Commission had that number in their safety goal c',_N i- 14 policy, and they said, "Go tell us what a large release is 15 consistent with that number. And, by the way, don't make 16 it a de facto new goal."
l 17 We did a lot of analysis looking at how we l l
18 could define large release at that frequency. We 19 basically gave up because it did end up being a de facto 20 new goal. We wrote to the Commission and told them what 21 we did, recommended we drop further evaluation at 10", and 22 they agreed.
23 All I was trying to do was say -- somebody 24 asked, "Why didn' t you use 10-'? " That's the reason why,
(") 25 because it is essentially a de facto new goal. So maybe I
( ,/
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576 1 didn't say that very well, but that's the --
2 MEMBER POWERS: I just wasn't here when you
\s_) So I just wanted some clarification. And I 3 said it.
4 guess you prompted me to ask: Could I get a copy of what 5 you wrote to the Commission?
6 MR. KING: Sure. It's a SECY paper back in 7 '93, but I'll get you a copy.
8 MEMBER POWERS: Yes. I'd just like to see it.
9 CHAIRMAN APOSTOLAKIS: Okay.
10 MR. CARROLL: You also presented it to the 11 ACRS.
12 MR. KING: Yes. And we got the Committee's 13 agreement.
14 MEMBER KRESS: We agreed with your assessment.
15 MR. KING: Yes, yes.
16 CHAIRMAN APOSTOLAKIS: What I propose --
17 MEMBER POWERS: The LERF still puzzles me from 18 the perspective that Gary articulated earlier. It's not 19 transparent to me how this particular LERF follows 20 directly from the principles.
21 MR. HOLAHAN: It follows from the principle 22 that suggests not exceeding the safety goal, safety goal l
23 being the quantitative health objective and this being a 24 surrogate for that objective.
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577 1 is: Why is it the product of containment failure and core
,~) 2 damage freque.acy with no measure of the amount of I' ~'/
3 radioactivity seleased?
4 MR. KING: If you look at the first dash under 5 the first bullet, that's really how we came up with 10-5 6 We went back and looked at NUREG-1150. We looked at 7 LaSalle, all Level III PRAs.
8 And we looked at the QHO for early fatalities.
9 And all of those plants were below that QHO. And we 10 looked at: Okay. What will we have to raise the large 11 early release frequency to just meet that QHO?
12 MEMBER POWERS: I think what you're saying is 13 that you looked at what you had done for 1150, for f~s t i ,
\~.M 14 instance, -- l l
15 MR. KING: Yes. 4 l 16 MEMBER POWERS: -- and you understood from I l
17 1150 what the magnitude of the source term was from these 18 early releases.
19 MR. KING: Right, yes.
20 MEMBER POWERS: So you said, "Now, given that, 21 what kind of frequency do I have to have of that to exceed 22 the QHOs?"
23 MR. KING: And there's margin in there to 24 account for the fact that not all the 1150 plans covered
!,p),
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578 1 and shutdown. So we've added some margin in to recognize i
7s 2 the fact that 10 4 provides some room to account for those ,
l t )
~~
3 conditions as well. 1 4 MEMBER POWERS: When I do my complete PRA --
l 5 MEMBER KRESS: For everything?
6 MEMBER POWERS: For everything, for the works. !
7 -- and I come in at 2 times 10 4 for a LERF, 8 you say that's okay because --
9 MEMBER KRESS: Close enough.
10 MEMBER POWERS: -- it's okay because I got --
11 MR. HOLAHAN: No. What we say is that we 12 don't make decisions based on any one of the guidelines.
13 We'll consider that an integral proceus and look at i
im s
() 14 defense-in-depth and the other things we were talking 15 about and maybe it's okay and size of the uncertainties 16 about where you are and all of those things.
17 MEMBER POWERS: How do you respond to your 18 partners in this effort, who say, " Gee, I wish they had a 19 different LERF because this one doesn't capture things 20 related to long-term containment integrity and source term 21 mitigation"?
22 MR. KING: I'm not sure I follow you.
23 Long-term containment integrity. Are you talking about in 24 terms of -- j 7
(x. -j 25 MEMBER POWERS: People doing the graded QA i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 579 1 said that they found that this was a less useful LERF than 73 2 others that could be defined because it didn't capture any
( ')
'~
3 safety significance to long-term containment integrity and 4 fission product attenuation. And they needed that for 5 their objectives.
6 It just seems to me that if you have one of 7 these applications that needs a different LERF and the 8 others don't care which one you use, that you'd help them 9 out.
10 MEMBER KRESS: My suggestion was to lump those 1
11 other needs under something else, like defense-in-depth, l 12 and not muddy the waters up with this LERF here.
13 MEMBER POWERS: But that's not what they're
,i i /
'\ '
14 suggesting. j MEMBER KRESS: I know.. But we don't have to l 15 I
16 accept all the suggestions. l 17 MEMBER POWERS: But I'm trying to understand 18 why these people didn't help them out.
19 MEMBER KRESS: Oh. I don't think they had a 20 chance to answer yet.
21 MEMBER POWERS: I don't think so either.
22 MEMBER KRESS: Okay. But I would have just l
23 lumped it into under some other category, like 24 defense-in-depth or some other traditionalist
(,)
/ %
25 deterministic thing.
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580 1 MEMBER SEALE: Sometimes enlightenment is a r~y 2 low process.
( '^' )
3 MR. HOLAHAN: Also, a point to this, if you l
4 remember Trevor Pratt's presentation from yesterday, for l 5 those releases which are neither large nor early or not i 6 large and not early, there's still the 10-* CDF, which j i
7 would be controlling.
8 MEMBER POWERS: So why didn't you tell the 9 people doing the graded QA, "Stop worrying about those 10 things that had to do with long-term containment integrity 11 and fission product attenuation. They're not 12 risk-significant"?
13 MR. HOLAHAN: Well, I think they're not
- /
\/ 14 LERF-significant, but they might be significant from other 15 points of view.
16 MEMBER POWERS: So there's another criterion.
17 MR. HOLAHAN: Well, no. Those other points of 18 view are the other principles. They're the 19 defense-in-depth and safety --
20 MEMBER KRESS: I think that's the right way to 21 view it. The only real problem I had with the .1 is I 22 think it was derived on the basis of a limited sample of 23 the number of plants out there.
I 24 And I'm not sure that it's sufficiently l
[^s
(,) 25 bounding, but it looked to me like from what you've got to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W. l (202) 234 4433 WASHINGTON, D C. 20005-3701 (202) 234-4433 ,
l
581 1 show that it probably would be. And if you had all these
!gy 2 other plants in there, too, they would probably do it. )
Nj \
3 But I wasn't positive that it would. ;
I 4 MR. KING: You know, the plants -- we had a 5 high population. Zion, for example, was one of the plants 6 that we looked at where this number was backed out of it.
7 MEMBER KRESS: Yes. If you found the plant 8 with the -- the characteristics of the site were such that 9 the meteorology and the population were about as bad as 10 you could get, that one would probably be bounding. And 11 if that one fell below this, I think I would probably buy 12 that as --
13 MR. HOLAHAN: But it's not even that. You
!,_h, r
14 remember, if it's above 104, not 104, it's above 104, it's 15 already getting some additional consideration on issues 16 like population, siting.
17 And so I think there's the opportunity to 18 consider whether .1 really applies well to this site. For l 19 the cases that are very low, I think they're not of 4
20 concern. The ones that are between 10 4 and 10 I think l 21 they'll get more of these questions and considerations. l 22 MR. KING: One thing we could do -- it would 23 only take a half-hour; I might as well just do it -- is l
l 24 you remember the study, the generic environmental impact r~N
( ,) 25 statement.
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, 582 1 MEMBER KRESS: Yes.
, . .s 2 MR. KING: For license renewal, where we did ;
\
(' i 3 look at every site, population, and wind rose !
l 4 site-specific -- 1 l
5 MEMBER KRESS: I took a quick look at that.
6 Zion is not the controlling plant.
7 MR. KING: No. I think Limerick is, but Zion 8 is up near the top of the list.
9 MEMBER KRESS: Yes. I think it might have 10 been Limerick. I'm not sure.
11 MR. KING: Yes.
12 MEMBER KRESS: If you took that site and those 13 conditions and you came up with .1, then I'd say blah.
I i
'v/ 14 MR. KING: Yes. Well, we'11 take a look at 15 that. Okay.
16 MEMBER KRESS: That way you could better say, 17 "This one bounds pretty well."
18 MR. KING: Okay. ]
l 19 CHAIRMAN APOSTOLAKIS: Finished with this?
i l
20 MR. KING: We're done.
21 CHAIRMAN APOSTOLAKIS: Okay. What we have now i
22 is maybe going to have three hours. The first thing I 23 would like to propose that we do --
l l 24 MR. CARROLL: You got sidetracked a minute fM j() 25 ago. Did you want to hear from industry?
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583 l 1 CHAIRMAN APOSTOLAKIS: They said no. They i
1
,, 2 said no.
! )
\'#
3 Why don't we do it as follows? Identify 4 perhaps three or four additional issues that we should 5 discuss and then go on to discussing our letter. And I i
6 would like to invite everyone in the room to participate.
i 7 Now, the kinds of issues I have in mind, I !
8 have three. I would like to see some sort of a plan, j l
9 implementation plan, where we go from here, some l l
I 10 milestones and so on. ;
I 4
11 I would like to revisit the question that Dr.
12 Powers keeps coming back to, namely how can you make of )
l 13 these decisions without low power and shutdown PRA, I
r^s i
(~ 14 external events, and what kind of decisions can we make in l 15 the absence of these.
16 And third is: Should we recommend perhaps, 17 although that's coming back to the letter, but that's 18 something to discuss, that the performance pa.rt of all of 19 this should be emphasized in the future, and, instead of 20 having performance elements, we will have risk-informed 21 and performance-based approach? And what does that mean?
22 Okay? And I noticed that the Inspector General's report L 23 addresses that issue as well.
24 So these are my three items. We can go around
, - ~s
) 25 the table.
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584 !
i l
1 MR. CARROLL: On this last one, I'm trying to i l
2 recall what Gary said yesterday. I think it was Gary.
7m l i ) l
'~#
3 You started out just putting emphasis on risk-informed? i i
4 MR. HOLAHAN: Yes, yes.
5 MR. CARROLL: How did you --
6 MR. HOLAHAN: We started with just 7 risk-informed. I think then probably it was raised first 8 at some of the early Subcommittee meetings. And then we 9 went back and thought about, "Well, how can we put these 10 thoughts together?" And we produced this process which 11 has this fourth step in it.
12 MR. JONES: Fifth?
13 MR. HOLAHAN: Fourth.
ym (O I 14 MR. JONES: Fifth.
15 MR. HOLAHAN: Fifth that says as part of the 16 risk-informed activity, the licensee should identify and 17 the staff should review performance strategies, which are j i
18 basically validations of the assumptions in the analysis.
19 This sort of follows what Dr. Catton has I l
1 20 suggested several times is the way to do this is you do 21 the PRA and then you decide which of your assumptions were 1
22 really important. Then you put something in place to i
l 23 validate those. ,
24 So we've done that. I think the piece we
, .r~.
) 25 haven't done is to say: To what extent could performance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE.., N W.
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585 ,
1 be a substitute for some of the other steps?
f3 2 CHAIRMAN APOSTOLAKIS: Yes.
I )
3 MR. HOLAHAN: Can you do less analysis? Can )
I 4 you have fewer requirements because of the performance 5 monitoring?
6 CHAIRMAN APOSTOLAKIS: Which is really NEI's 7 position, is it not?
8 MR. HOLAHAN: Which is --
9 CHAIRMAN APOSTOLAKIS: Remember that figure 10 they have?
11 MR. HOLAHAN: Yes.
12 CHAIRMAN APOSTOLAKIS: To meet the performance 13 criteria, then don't do much below this. To violate them,
/ \
\ 'l 14 increase supervision, inspection.
15 MR. HOLAHAN: Yes.
16 CHAIRMAN APOSTOLAKIS: There was a figure in l
17 one of their earlier documents.
18 MR. HOLAHAN: Yes.
19 MR. JONES: I wouldn't say that the NEI figure 20 was put together from doing less analysis up front to go 21 and do the --
22 CHAIRMAN APOSTOLAKIS: No, no, no.
l 23 MR. JONES: -- thing. That was just for: How 24 would we inspect it in a --
,/ \
__) 25 CHAIRMAN APOSTOLAKIS: We can discuss this NEAL R. GROSS I COURT REPORTERS AND TRANSCRIBERS i
1323 RHODE ISLAND AVE , N.W.
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l
586 i l !
l 1 when the issue comes up. j i
l i
,S 2 Bob? I
/ !
V 3 MEMBER SEALE: Was there any comment abour ,
l 4 Dana's bold approach before we got back in after -- )
1 5 CHAIRMAN APOSTOLAKIS: Bold approach.
1 I
7 MEMBER SEALE: To QA. Remember, Dana had l
8 suggested that maybe, instead of trying to figure what all 9 goes into the low safety significance category and what's l 10 left, then, is the high, rather, you ask yourself what 11 should be in the high.
12 CHAIRMAN APOSTOLAKIS: Okay.
13 MR. HOLAHAN: Can I address that?
,a l
_ 14 MEMBER SEALE: Yes.
15 MR. HOLAHAN: We had sc.ae discussion earlier.
16 MEMBER SEALE: Okay.
17 MR. HOLAHAN: And I think wa're mixing issues l
18 up with respect to which documents they would be 19 considered in. What I consider is the general reg guide 20 and the general SRP. I 21 MEMBER SEALE: All right. That's certainly 22 under the QA thing. Okay.
23 MR. HOLAHAN: The general ones are guidelines 24 on how to do things that we've never done before. The ps
() 25 application-specific ones, like the graded QA one, where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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587 1 this issue came up, is really a guideline on how to
-s 2 implement the existing graded QA requirements, maybe in a
/ i
\ l 3 more thoughtful and risk-informed way. But it's an 4 interpretation of implementing the existing requirement.
5 And so from that point of view, it constrains 6 you with respect to if you're saying I'm going to play by 7 the Appendix B rules, although I'm going to try to figure 8 out the most flexible way to do that, I think you're 9 constrained with respect to scope, for example, because 10 Appendix B has a scope defined within it.
11 Now, if you want to change scope or be bolder 12 or change other things, I think you have to say, "Well, 13 that doesn't make sense as part of IST or the graded QA
,r x,_/ 14 application-specific reg guide."
15 Set those aside and say, "Now I want to think 16 about making bigger changes, change what the design basis 17 events are, ask: Why do I have design basis events? What 18 is safety-related? And why do I deal with anything that's 19 not important?"
20 Well, then you're talking about changing 21 several fundamental regulations. And I used the general 22 reg guide to guide me on that. And we could have a bold 23 approach, but I don't think you can force fit that into 24 the graded QA application.
,a i( )
l 25 MEMBER CATTON: Get rid of the large break NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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l 588 l 1 LOCA.
l
/,,\
2 CHAIRMAN APOSTOLAKIS: Any other issues that
\ /
3 the members would like to see discussed?
l 4 MR. CARROLL: Now, this is discussed what, by
)
5 --
1 6 CHAIRMAN APOSTOLAKIS: By all of us here i i
7 today.
I 8 MR. CARROLL: Here today. I 1
l 9 CHAIRMAN APOSTOLAKIS: This is just learning l l
10 for this afternoon. I 11 MR. CARROLL: Okay. I see what you're up to. l 12 CHAIRMAN APOSTOLAKIS: Yes.
13 MR. CARROLL: Well, I guess I would like to rs U) l 14 hear what thinking the staff has done on the issue of how 15 to package this document better from a public relations 16 point of view. Behind my thinking is that I heard today 17 -- and I guess I've had the perception for quite a well --
18 that we're going to lose valuable momentum that we've 19 built up on the PRA and using it in a sensible way and 20 relation if you don't sell this package to the industry.
21 CHAIRMAN APOSTOLAKIS: Okay. Good. Anything 22 else? Mario?
23 MEMBER FONTANA: That relates to something I 24 was going to say to try to emphasize a little more what n
() 25 kind of relief could be forthcoming from this. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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589 1 message seems to keep coming of adding things on top of f3 2 existing things. And I know you don't mean that, at least
- )
'~
3 not entirely.
4 MR. CARROLL: I thought they did when I came 5 here Tuesday evening, but --
6 MEMBER FONTANA: We'll give them the benefit 7 of the doubt.
8 MEMBER MILLER: Well, part of the 9 implementation plan is the training program.
10 CHAIRMAN APOSTOLAKIS: Yes.
11 MEMBER MILLER: I think that's a key part and 12 a key thing that's missing.
13 CHAIRMAN APOSTOLAKIS: And enforcement. We'll r~N
'u 14 discuss this.
15 MEMBER FONTANA: This is not an issue, but --
16 CHAIRMAN APOSTOLAKIS: No. We'll get -- l 17 MEMBER FONTANA: Can we get a promise to get a 18 NUREG written to support what's in Appendix B of Draft 19 Guide 1061?
20 MEMBER SEALE: Well, there's also the 21 question: Can you expedite the response to the efforts of 22 the people who have done the pilot program?
l 23 CHAIRMAN APOSTOLAKIS: Yes, yes. We'll 24 discuss that under the implementation plan. These are the
() 25 issues.
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i 590 1 Anything else? Ed? 1 2 MR. ABBOTT: Yes. I just want to follow'up on 7-~
(
3 what Gary said. It's kind of interesting. The --
4 CHAIRMAN APOSTOLAKIS: We're not discussing 5 issues now. We're raising issues.
6 MR. ABBOTT: I know we are. I'm getting to 7 that. I mean, the issue goes to what Mr. Carroll said 8 about selling it, that the pilot programs, from what I 9 understand, are somewhat constrained by what's gone on in 10 the past and what's currently in the regulatory guides.
11 But what you're saying is that if bold new i 12 steps need to be taken, then applying the reg guide, the l l
13 governing reg guide, -- and I forget the number; 1061 I i C
/ '\ l
-' 14 guess -- to that issue in the way that you described 15 yesterday in terms of the thermal hydraulic analysis 16 thing, then that would be acceptable to the staff for the 17 purposes of reviewing that particular exemption to the 18 rules and regulation, whatever was talked about.
19 So it's somewhat outside the traditional way 20 of doing things; right? I think if that point is made, I 21 think it's much more acceptable to the industry at this 22 point, isn't it?
l 23 MR. HOLAHAN: Yes. Well, what I would say is, 24 look, everything we were deriving here is consistent with g3
(_,/ 25 the Commission's policy statement on PRA. And not only NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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591 1 did it put no constraints on where we could go. It was, 1
,-s 2 in fact, the Commission that wrote in the word "all" in k' 3 that the staff should use PRA in all regulatory matters to 4 the extent that it makes sense.
5 So I know of no subject matter a priori that 6 cannot be approached for changes using these guidance 7 documents. That doesn't mean that everything will be 8 approved, but I think there's no forbidden request.
9 MR. ABBOTT: I think that point has to be made 10 somehow, whether you put it in the letter or whatever, 11 because it's only now that the light has turned on. I 12 don't know why, but it seems to me --
13 CHAIRMAN APOSTOLAKIS: Any other issues that g
kl m 14 anybody else wants to raise maybe for discussion?
15 (.o N response.)
16 CHAIRMAN APOSTOLAKIS: Okay. So I have here:
17 What should be the role of the performance part? Should 18 we recommend or what should be the role of the performance 19 part? And to what extent do we need low power and 20 shutdown PRAs and maybe external events? How do we 21 package these documents better? Maybe emphasize the 22 relief that is forthcoming from all this effort.
l 23 And, finally and most importantly, the 24 implementation plan. Can we identify a plan?
- ./)
~
25 Dana, do you want to add something?
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592 1 MEMBER POWERS: I was just going to say
,_. 2 perhaps after the break, I'd like to come back to the bold 3 approach and discuss it a little more.
4 CHAIRMAN APOSTOLAKIS: The whole approach?
5 MEMBER POWERS: The bold approach.
6 CHAIRMAN APOSTOLAKIS: Oh , the bold?
7 MEMBER POWERS: Yes, yes. Discuss a little 8 more on that.
9 CHAIRMAN APOSTOLAKIS: Yes, yes. Should the 10 program take more drastic action? Well, we can tie that 11 to the plan. But yes, let's do that. Okay. So --
12 MR. CARROLL: You want to do that after the 13 break?
,/ 14 MEMBER POWERS: After the break.
15 MR. HOLAHAN: After the break.
16 MR. ABBOTT: After the break.
17 CHAIRMAN APOSTOLAKIS: Which is coming up in 18 ten minutes. Which one of these can we dispose of in ten 19 minutes? I would say --
20 MEMBER POWERS: George, before you launch into 21 that, for the members' benefit, John has asked that you 22 put together your rankings of the candidates that you've 23 had a chance to speak to and give that to him.
24 CHAIRMAN APOSTOLAKIS: I've spoken only to
,a
( ) 25 one.
a l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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593 1 MEMBER POWERS: Presumably you --
- 2 MR. CARROLL: He's number one; right?
! l 4 3 MEMBER POWERS: Presumably you have some view 4 --
1 5 CHAIRMAN APOSTOLAKIS: Yes. ,
i 6 MEMBER POWERS: -- on the rankings of the 1
7 candidates. l l
8 CHAIRMAN APOSTOLAKIS: Yes. Okay. I will -- j i
9 MEMBER SEALE: We may want to discuss that a l l
10 little bit.
11 MEMBER KRESS: We probably want to discuss l 12 those.
13 MEMBER POWERS: His intention is to put the t i
\j 14 material together so that we can discuss it at the next 15 meeting.
16 MEMBER KRESS: I see.
17 CHAIRMAN APOSTOLAKIS: Okay. Okay. I'11 talk 18 to John.
19 MEMBER KRESS: Was that a generic --
20 MEMBER POWERS: That's a generic for all of 21 the members, yes.
22 CHAIRMAN APOSTOLAKIS: Now I am speculating i 23 here, using my judgment, --
24 MEMBER SEALE: Expert judgment.
i ) 25 CHAIRMAN APOSTOLAKIS: -- that we can finish l
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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594 1 in the next several minutes the question that Jay raised:
i s 2 How do we package these documents better? Do you think 3 that's something we can -- ;
1 4 MR. HOLAHAN: Well, we've been thinking about 5 it. I'm not sure that it's these documents that need to .
6 be packaged better because, in fact, most of the people l l
7 who were concerned about the subject haven't read these 8 documents. And packaging them a little better might not 9 be the way to get that accomplished. l 10 Mr. Jones and I have been talking about i
11 workshops and regional-type meetings to go around and to 12 talk to people about what's going on. l 13 MEMBER CATTON: Better yet --
5- 14 MR. HOLAHAN: And maybe I can get some sense 15 from the Ccmmittee. I mean, reading the documents is one 16 thing, but sitting down for a day I think with the staff I 17 think is also, or maybe even more so, useful in i 18 understanding: What does this really mean for the future?
19 CHAIRMAN APOSTOLAKIS: I also think, though, 20 that releasing them as soon as possible will help.
21 MR. HOLAHAN- Okay.
22 CHAIRMAN APOSTOLAKIS: And having the plan I 23 mentioned earlier where the utilities will see that there 24 are certain milestones, that things will happen, in other
(~'
( ,)/ 25 words, I think one of the complaints we've been hearing is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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595 1 that nothing seems to be happening.
.r w 2 MEMBER MILLER: Well, that fits into the
\
G 3 implementation plan.
4 CHAIRMAN APOSTOLAKIS: Yes. But it's related. I 1
5 MEMBER SEALE: And there the demonstration 6 that would be involved in expediting the response to the 7 people who have done the pilot studies would be very S useful in allaying some of those fears. l l
9 MR. ABBOTT: The thing that has to be overcoms 1
10 is the following. If someone sits down and reads these 11 documents in isolation, he will come away with the fact 12 that there's an awful lot more here that I have to do than 13 I would otherwise have to do if I didn't have to deal with q
d 14 this. And that is a problem.
15 And I don't think repackaging this is going to 16 -- first of all, it would take too long. And I don't 17 think it's needed. What's needed is the people who end up 18 receiving this have to get the message that read it over, 19 be patient, don't panic.
20 I don't knew how you get that message across, 21 but when I read it, I panicked.
22 CHAIRMAN APOSTOLAKIS: That's your nature.
23 You're in a constant state of panic.
24 I think that you have a good point. And I 7-(,) 25 think yesterday we had an example -- yesterday. No. Yes.
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596 1 Yesterday, yes. We had an example of that when I think
,_ 2 most of the people around the table were surprisee that --
( ')
3 MR. HOLAHAN: Right, the IST.
4 CHAIRMAN APOSTOLAKIS: The IST, yes.
E MR. A3BOTT: Yes.
6 CHAIRMAN APOSTOLAKIS: Would it help to have 7 an introduction someplace as to what the intent of these 8 documents is and what you can dc? Every time you say, 9 Gary, you address the issue of what you can do about it, I 10 learn something, even just a few minutes ago. .
11 Obviously you have a whole picture in your 12 mind as to how these documents are going to be used, but I 13 don't think that is written anywhere. Now, you might say x- 14 on Page 16 of this document, there is a line. Yes, I know 15 that. But how about pulling everything together up front
-16 and saying, "Look, this is what we're trying to do," what 17 you just said a few minutes ago?
18 MR. ABBOTT: Absolutely.
19 CHAIRMAJ 'OSTOLAKIS: Reg guide 1061 is the 20 general document. You can propose anything you want.
21 Now, you will add the parentheses. Don't expect approval 22 for everything.
23 But, then, the other guides are for specific 24 obligations. And give examples or something so that the gy
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597 1 who have not lived with them for as long as you guys have
,_s 2 lived with them.
- )
3 MR. ABBOTT: And the other problem, there's a 4 general feeling in the industry I think that applying for 5 an exemption to the regulations is not something that's 6 generally accepted by the staff at this point.
7 And that fact runs or that opinion -- whether 8 it's a fact or not, I don't know. The perception is 9 something that's going to prevent people from accepting 10 this process when they look at that first chart you sent 11 that was out there about applying for a rule.
12 Now, if the Commission has said in this 13 context of risk-based, risk-informed regulation that this i_,/ 14 reg guide can be used to change the regulations and that's 15 an acceptable process, then the point has to be made in 16 spite of what the current perception is.
17 Did I say that right?
18 MEMBER SEALE: There's an element --
19 MR. HOLAHAN: Yes. That's a good point.
20 MEMBER SEALE: -- of pay me now, pay me later, 21 to use the commercial idea. That never comes across in 22 the front discussion. Sure, there's more you have to do, l
23 but if you do it right and live by the commitments that 24 come out of it, you have to do less later.
(, ) 25 CHAIRMAN APOSTOLAKIS: Right.
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598 1 MEMBER SEALE: And somehow that needs to be 2 identified up front.
,I s#'
3 CHAIRMAN APOSTOLAKIS: Also, the return is 4 higher, 5 MEMBEP SEALE: Well, of course, yes.
6 CHAIRMAN APOSTOLAKIS: I think Gary has said 7 many times --
8 MEMBER SEALE: You don't get a bird out of --
9 CHAIRMAN APOSTOLAKIS: -- when you're asking 10 for changes, it's not unreasonable to ask you to do some 11 work. But it seems that people have the perception that 12 you're asking them to do work. They don't really 13 appreciate the magnitude of the changes and the --
(8 5 ;
v' 14 MEMBER MILLER: They don't see the carrots.
15 CHAIRMAN APOSTOLAKIS: -- the benefits. They 16 don't see the benefits.
17 MEMBER MILLER: I've been through this 18 document. I don't see the carrots either, --
19 CHAIRMAN APOSTOLAKIS: That's right.
20 MEMBER MILLER: -- to put it bluntly.
21 MR. MARKLEY: I'd juet like to point one thing 22 out. And that's the staff is also going to have to 23 consider the public at large and their perception of all i
l 24 of this. It can't be just perceived as a relaxation of l
. -m s
\ ) 25 things. There has to be a safety benefit involved in it.
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599 1 Otherwise, it falls on --
, 2 CHAIRMAN APOSTOLAKIS: Mr. Grantom gave us so I
i
'~'
3 many examples this morning that by implementing some of 4 this stuff, in his opinion --
5 MEMBER BARTON: Safety improves.
6 CHAIRMAN APOSTOLAKIS: -- safety improves. So 7 you can put some of these arguments --
8 MR. MARKLEY: But that has to be clear because 9 they're going to have to answer questions like that on 10 Capitol Hill.
11 CHAIRMAN APOSTOLAKIS: Sure.
12 MR. KING: We tried to put that emphasis in 13 here.
\
r3 )
V 14 CHAIRMAN A.POSTOLAKIS: Anything on this issue, l 15 anybody?
16 MR. MARTIN: This is Lawrence Martin.
17 And I heard Gary talking about some of the 18 flexibilities and everything else. Then we're talking 19 about exemptions and all this kind of stuff. This is 20 contrary to the message that we've been getting as 21 licensees, exemptions, exceptions, NOEDs, all of this.
22 That's out.
23 Don't come to us. Don't ask us for them.
24 You're not going to get them. If the rules and the
("'y
\ j 25 regulations aren't right, let's change the rules and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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_, . . . ~ . - . . . - . _ . - - - - _ ~ - . . . _ . - - . . - . . . - - - . ~ . - - . - - . . - _ - - . ~ . . ~ - - . .
600 I
'l 1 regulations. But we're not going to take exemptions to !
l~ 2 them and exceptions to them.
3 Now, if.I've read that wrong, then somebody l k 4- needs to tell me'that, but I've read it over and over
- 1 5 again. And I thought the Chairman was very clear, very i 6- explicit.
7 So I'm hard-pressed to understand how we're
- j. 8 going to get-from here to there. I hear what you're 9 saying, but I don't see how we'get there.
10 MR. HOLAHAN: .I agree that that message has ;
11 been sent by the agency and that if we really want to open
-12 up this avenue,-- 'and it is one of the principles -- it 13 seems to me either we have to send another message that- d 14 says, "In the risk-informed, performance-based arena, ,
Y \
- . 15 these are not only acceptable, but, in fact, if this is 4
16 the way-we want you to go, they have to be welcome" or,
~ 17 else, the staff has to be willing'to do a rule change
, 18- every time it sees one of.these desirable situations !
1 19 MEMBER MILLER: What you're saying is --
20 MR. MARTIN: The problem is rule change takes I 21 such a long time.
22 MR. HOLAHAN: I understand. ;
23' MR. MARTIN: Okey?
24 MR. HOLAHAN: Yes.
- 25. 'MR. MARTIN: .We're talking about decades.
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601 1 MEMBER SEALE: Wasn't there a recent
.-s 2 Commission letter on this subject?
/ \
\ "' j 3 MR. HOLAHAN: Yes.
4 MR. JONES: Yes.
5 MEMBER MILLER: What was the Commission 6 letter? What did it say?
7 MR. JONES: I think the Chairman made clear or 8 the Commission made clear that the staff should not say 9 that exemptions are not welcome. In fact, if they are 10 appropriate and they meet the test, they should be done 11 and they should be granted or the stand.
12 MR. HOLAHAN: I think the message was that --
13 MR. JONES: The only thing it did say
,,, l i ;
\_/ 14 different or the point that was emphasized is where you 15 should not, however, be generally regulating by exemptions 1
16 and where there are continued exemptions, you ought to i 17 change the regulation.
18 But I think the issue of the perception out to j 19 the industry, it was recognized that message was sent.
20 And it was a caution to the staff not to do that.
l 21 MEMBER SEALE: Yes. The real message on l
22 exemptions is to the staff --
23 MR. JONES: That's correct.
24 MEMBER SEALE: -- to fix the regulatory
',m 25
) process, not to deny the necessity for an exemption as a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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602 1 temporary way of doing business.
/ ,T 2 MR. JONES: Where valid reasons exist.
t i 3 MR. CARROLL: Many people in industry --
4 MEMBER SEALE: This is a very recent letter.
5 MR. JONES: Yes. It came out within the last 6 two to three weeks.
7 MR. HOLAHAN: Yes.
8 MEMBER MILLER: Yes. But before that's going 9 to be believed by industry, it ought to be somewhat "Do as 10 I say, not as I do" type of thing.
11 MEMBER KRESS: Well, don't you think releasing 12 this kind of document sends a message that you're willing 13 to do it?
,ry 1 14 MR. HOLAHAN: Yes.
15 MEMBER SEALE: But I think your point about 16 workshops --
17 MEMBER BARTON. It sends a mixed message.
18 MEMBER SEALE: Yes. I think --
19 MEMBER KRESS: I guess I had --
20 CHAIRMAN APOSTOLAKIS: Bob?
21 MEMBER SEALE: Your point about workshops, 22 where you could specifically identify that exemptions in 23 this area are welcome by the staff, if you will, or 24 whatever terminology you want, that's a coupling that
,a
( ) 25 could help a lot, I would think.
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603 1 MR. JONES: And I think to some extent we will
,s 2 start the process, if you wish, at the regulatory i s 3 information conference the first of April. There is a 4 risk-informed session. This is one of the items on the 5 agenda.
6 CHAIRMAN APOSTOLAKIS: Very good. i 1
7 MR. JONES: How much latitude do I have at 8 that point? Because the Commission hasn't fully read l 9 these documents, I'm not sure yet. But I'm sure we will 10 certainly start embarking on the process at that point.
l 11 CHAIRMAN APOSTOLAKIS: Is it customary to have 12 an executive summary here in these documents? I mean, 13 where would you summarize all of these great things?
- )
\/ 14 MR. KING: The " Federal Register" notice.
15 CHAIRMAN APOSTOLAKIS: No, no. That's --
16 MR. JONES: In the foreword is where it is.
17 MR. KING: Right now we have in the document a 18 foreword. In the document today, we have a foreword, 19 which you have not seen. There is a foreword in what 20 you've got, but it's been revised. And it was a lot that 21 had to deal with that chart that we showed yesterday.
22 CHAIRMAN APOSTOLAKIS: Which document is this, 23 Bob?
24 MR. KING: The reg guide and the SRP.
n
( ) 25 CHAIRMAN APOSTOLAKIS: Ten sixty-one?
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604 1 MR. KING: Yes.
l l
,q 2 CHAIRMAN APOSTOLAKIS: Oh, that would be l
\ ) l a ,
3 great.
4 MR. KING: And we have in that this general 5 process of how this works in the 50.59 and the stuff that 6 we went through yesterday. I think that that would be an 7 area that would be readily expandable to do that.
8 I mean, we have to think about it but I think 9 that would be a reasonable approach.
10 MR. HOLAHAN: We need to think about l
11 mechanisms for doing this. I i
12 CHAIRMAN APOSTOLAKIS: But, I mean, it would l 13 be nice for us to read someplace. Next time you're j
/
' O) 14 telling us, Gary, how this can be used, I don't want to l l
l 15 learn anything. I want to have read it. Every time you t6 open your mouth, I learn something.
17 MEMBER SEALE: That's why we like to see you 18 all the time.
19 MEMBER CATTON: George, that may be just your 20 problem.
21 CHAIRMAN APOSTOLAKIS: But not always useful.
22 MEMBER SEALE: Now's a good time for a recess.
23 CHAIRMAN APOSTOLAKIS: Are we done with this 24 subject? Yes. I think that was a -- let's take a break, 7
! ) 25 then. And we'll be back at 3:20.
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605 l
1 (Whereupon, the foregoing matter went off the !
(^x 2 record at 3:08 p.m. and went back on the N-3 record at 3:34 p.m.)
4 CHAIRMAN APOSTOLAKIS: Okay. The next item 5 was -- let's talk about the long-term plan because some 6 people want to contribute and they have to leave from NEI.
7 So let's start with the staff. I mean, as I said earlier, 8 assuming that the guide is released for public comment in 9 April sometime, then what is the time frame where --
10 MR. HOLAHAN: Bob has some. Do you have the 11 -- go through your list, Bob.
12 MR. JONES: We just tried to jot down a few
,.._ 13 thoughts. When the late April issuance for public comment i
N_' 14 --
15 MR. HOLAHAN: But, remember, that's an 16 estimate. We're not putting a constraint on the 17 Commission about how long they're allowed to think about 18 'this. They'll release it when they're ready. But, for 19 planning purposes, we're just giving it a guess.
20 CHAIRMAN APOSTOLAKIS: Okay. In April what 21 happens?
22 MR. JONES: That would be the release for 23 public comment, end of April. We will be looking at 24 probably doing the regional workshops from mid May to June A
j 25 time frame, mid June time frame.
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606 1 CHAIRMAN APOSTOLAKIS: These are workshops for
.~.s 2 the industry or --
\)
3 MR. JONES: Those would be for the public.
4 MR. HOLAHAN: During the comment period to --
5 MR. JONES: During the comment period to 6 explain what's been out there, what's there, answer any 7 questions, clarify what's in the documents.
8 CHAIRMAN APOSTOLAKIS: Two of these or one?
9 MR. HOLAHAN: I would think we would do five.
10 CHAIRMAN APOSTOLAKIS: Five?
11 MR. HOLAHAN: I would think we would do 1
12 headquarters and the four regional offices. j 13 CHAIRMAN APOSTOLAKIS: Okay.
,n
- ) 14 MR. CARROLL: That schedule doesn't help you 15 much, though, as far as being able to say anything at the 16 regulatory information conference.
17 MR. JONES: No. That's already scheduled.
18 MR. HOLAHAN: We'll say as much as we can.
19 but until the Commission releases it, I think we won't be 20 able to tell the story as definitively.
21 CHAIRMAN APOSTOLAKIS: Okay.
22 MR. KING: But we certainly could say exactly 23 what we said to the Committee. That's public. The 24 viewgraphs are public. That could be rehashed in that
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I 607 1 hopefully and so forth.
,. 2 CHAIRMAN APOSTOLAKIS: Well, plus what we 1
( )
3 discussed earlier, you know, the issue of making clearer i
4 what the intent is and what people can do and cannot do.
5 I think that's a key here.
6 MR. HOLAHAN: Yes. ;
7 MR. JONES: I think in the mid to late 8 summertime frame, there are going to be a number of j 9 activities that are going to be on the way. I think this I
10 initial training program will have been developed.
l 11 We'll probably start testing it internally.
12 We'd be receiving the public comments, of course, on the j 13 guide, giving a three-month turnaround. And we also l
/^N 4 t
(_/ 14 expect at that time to basically I think have completed 15 all the pilots. l 16 CHAIRMAN APOSTOLAKIS: Now, the training 17 program is in terms of short courses?
18 MR. JONES: I think this is the one of how you !
19 are going to process the amendments when they come in, the 20 IOU Gary has laid on me about a zillion times yesterday.
21 What is the process? Train the staff on how 22 to treat these applications when they come in. We not 23 only have to educate the industry what's in these 24 documents, but we've got to make this a practical,
() 25 implementable document internally.
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608 1 And so that would be what it is. And that 7s 2 comes from the receipt of the application to getting it to
( )
x' ' ' 3 the right people to how do they decide when they need or 4 don't need PRA expertise.
5 All those activities would have to be embodied 6 in that program along with concepts of: How are we going 7 to do the review? Gary mentioned yesterday a management 8 oversight panel for consistency. That may be one concept.
9 Another concept may be to receive 10 applications, go out to sites, or utility offices, review 11 the documents there and work with their staff for a week 12 to understand, then come back in another week or two, and 13 then write up an SER.
n k.- 14 I mean, I think we have to think how we would 15 do that and what's the criteria. You might use any of 16 those avenues. I think the more complex -- four weeks 17 won't be the time frame, but I would certainly think 18 something like tech specs would be amenable to a fairly 19 quick turnaround process.
20 CHAIRMAN APOSTOLAKIS: So when you say that 21 the pilots are expected to be completed, do you mean with 22 a Commission decision on each one?
23 MR. JONES: Well, I'd have to say on graded 24 QA, the pilots there are a little more uncertain because
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609 1 only have one official submittal. The other two is they 2 ate ,ompeting less than we are, gathering information and j I7,l 3 interacting, but we have no active requests.
4 So I think we will respond to the one pilot we 5 have, which is -- and then IST and the others, we will ;
1 6 process. I think their time frame was May-June. I don't 7 remember the details of the slide yesterday.
8 And the IST will be actually issuing some of l
9 those. Hopefully within the next month, some of those 10 should be coming out through the Commission. And we have 11 to look in more detail as to the list of those because I 12 think that one is a little more difficult because there 13 are lots of little ones that are in-house that we have to
,/m
\- / 14 think about the schedule.
15 This is just to get at the point that we'd 16 like to get the pilots kind of wrapped up. And that's the 17 time frame we're looking at. The only exception to that l l
l 18 may be ISI. The ISI pilots and stuff have been running a l
19 couple of months behind the general. So we really haven't I I
20 been focusing on ISI over the last few months because of 21 the focus on these documents.
22 I think at about this time in the summer, as 23 we're wrapping these up and the training, all of this is 24 underway, I think it's going to be important that we p.
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610 1 pilots. I think we will encourage that in the --
2 CHAIRMAN APOSTOLAKIS: What pilots?
p\
3 MR. JONES: Bold.
4 CHAIRMAN APOSTOLAKIS: Bold.
5 MR. JONES: Something that will test the 6 system, something that will really come in and exercise 7 the general reg guide, come in and change the regulations, 8 come in and say, "I would like to do tech specs 9 differently."
10 AOTs are one way of doing it, but maybe there 11 is a better way to do tech specs that's more 12 risk-informed. Maybe we can modify Appendix B, chop the Q 13 list.
i /
V 14 CHAIRMAN APOSTOLAKIS: And the guidance --
15 MR. JONES: Yes. Let's assume --
16 CHAIRMAN APOSTOLAKIS: -- would be 10617 17 MR. JONES: That would be 1061, would be the 18 backdrop. We would be inviting that again. So I think we 19 will push that concept in the regional workshops and 20 certainly put that out, but I think we up here at least 21 think that's a reasonable thing to do. And maybe even a 22 more formal interaction with NEI or the industry may be an 23 appropriate means to accomplish that.
24 After that, it's basically work our way n
(,) 25 through the various comments and get out the final guides NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W. j (202) 234 4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 i
i 611 1 in roughly the end of December depending on the magnitude
,. 2 and nature of the comments that come in.
3 CHAIRMAN APOSTOLAKIS: Will you come before 4 us?
5 MR. JONES: Yes. We will go through the 6 entire process over again. We're looking forward to it.
7 In the fall time frame, we'll go through CRGR again 8 through a year, through the Commission.
9 CHAIRMAN APOSTOLAKIS: So we will have another 10 opportunity or more than one opportunity --
11 MR. JONES: Yes.
12 CHAIRMAN APOSTOLAKIS: -- to make some 13 comments?
() 14 MR. JONES: Absolutely.
15 CHAIRMAN APOSTOLAKIS: Because this is ,
i 16 overwhelming to really understand everything that's there, )1 17 the formulas. It takes a while to digest it.
18 MR. JONES: And I think some of the 19 information even here, like the internal training program, 20 I would expect you to have some interest in understanding 21 what's going on, not necessarily that we would seek your 22 approval, but we would like to just keep you up to speed 23 as to where we're going and our thoughts along the way.
24 And if you had any thoughtful comments, we
() 25 would -- I'm sure they would be thoughtful comments --
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l 612 1 that we would take your comments and incorporate them as
_.s 2 appropriate.
>I )
'x ,1 i
3 MEMBER MILLER: Is the training program l
4 offered down at the training center?
5 MR. JONES: Probably not. My expectation is 6 this would be an internal, primarily headquarters: How do 7 you process license amendment, risk-informed license l 8 applications internally? So I think that would be here.
9 MR. HOLAHAN: There are already what I would 20 describe as technology-type courses for PRA, for managers 11 and for technical staff. And those are usually in the --
12 MEMBER MILLER: Those are at the training 13 center already.
s p a
- i. d 14 MR. HOLAHAN- -- training center, although 15 they have been giving some of them here to accommodate 16 more of the staff.
17 MEMBER MILLER: Have we had a lot of 18 participation in this program up to this point?
19 MR. HOLAHAN: Yes. No one from AEOD is here.
20 The last time I looked, the number was over 400 staff had 21 gotten some level of PRA training. And that was quite a 22 while ago.
23 MR. HOLAHAN: It's a three-day program?
24 MR. HOLAHAN. There are different ones.
(G)
%.J 25 There's a whole series of courses.
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.. . ~ . ..~.- . , , .. .. - - -..-... _ . . . _ . _
l 613 l
1 MEMBER CATTON: Do you do case studies as part )
i l
[- 2 of the course?
I ' \j' '{
- 3 MR. JONES
- In some. +
4 MEMBER CATTON: It seems to me that it would i l- -,
5 be essential in this case. l l
6 CHAIRMAN APOSTOLAKIS: " Case studies" meaning? !
l 7 MR. HOLAHAN: Examples. l i
.)
8 MEMBER CATTON: Well, it's one thing to learn ;
i 1
9 about PRA and you draw the trees or whatever you do. It's j 10 another to sort of come to grips with the kind of thinking l l
i 11 that's needed to put .n place this kind of regulation.
12 CHAIRMAN APOSTOLAKIS: Oh , I see because a 13 case study might say --
l 14 MEMBER CATTON: The best way to do that I 15 think would'be case. studies, where you actually go through 16 and work the decision-making process.
~
17 CHAIRMAN APOSTOLAKIS: After they-complete the 18 pilots perhaps.
19 MR. JONES: Right. I would think the training 20 program,.an' element would clearly be the pilots and how we ;
1 21 did the pilots.
i
.22~ MR. HOLAHAN: There is already a manual, a 23 short NUREG report that describes the approach and all of l
24 the courses. I don't remember the number, but I'm sure we 25 can --
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614 1 MEMBER POWERS: I think it has been n 2 distributed to members.
/ i
- /
Okay.
~
3 MR. HOLAHAN: But I think what we're 4 talking about is in addition to those technology courses.
l l
l 5 A lot of the philosophical stuff and approaches and j 6 decision-making process that we've talked about here you l
7 won't get from those courses. So how to implement these l l
8 guidance documents is something I think you have to work 9 through with staff. We'll have to do that. j 10 MEMBER MILLER: I was going to use the analogy 11 of the I&C, how they've done it.
12 MR. MARTIN: I'd like to suggest that if you 13 had gone ahead and get the RAIs in the last go-around to
, o\
c
/ 14 South Texas on graded QA, we'd be glad to participate with 15 you in the case study applications for the training.
16 MR. JONES: I'll take the IOU.
17 MEMBER CATTON: He's writing it down. ,
18 CHAIRMAN APOSTOLAKIS: I'm sorry. Dr. Miller?
l 19 MEMBER MILLER: Yes. In the I&C, the training l 20 program is along the same lines. The basic I&C is taught 1
21 down at the training center. Then they've had two 1 22 workshops where they share case studies amongst the l
l 23 regional and the headquarters staff. They're their 24 experiences. It seems like you might be going the same
/~
(T) 25 way, then.
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615 l
1 CHAIRMAN APOSTOLAKIS: So by the end of j
,f .3 2 December, then, you think that this first cycle will be
'w) 3 completed. Then you will be locking for these new bold 4 pilots to test the system and push the boundaries; 5 correct?
6 MR. HOLAHAN- Yes.
7 MR. JONES: That's correct.
8 CHAIRMAN APOSTOL.KIS: Okay.
9 MR. ABBOTT: Do the existing pilots have to be 10 completed before the bold new pilots are --
11 MR. JONES: No. That's why I just kind of put 12 it in the summer time frame. I think as a practical 13 matter from a staffing standpoint, probably. I mean, we
< s
( )
14 are reasonable well-staffed right now. And it's difficult 15 to do the guidance documents and the pilots. That's been 16 a fairly hefty constraint on us to date.
17 CHAIRMAN APOSTOLAKIS: Plus, I think the final I
18 documents, the ones we have reviewed, should expect the l 19 experience with the pilots. So the pilots should be 20 completed before you release the final document. Don't l l
21 you agree? l 22 MR. ABBOTT: I'm not sure that the pilots are 23 going to affect draft Reg Guide 1061. I'm not sure.
24 CHAIRMAN APOSTOLAKIS: No because --
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616 1 they have already. That's I think -- ,
l 2 CHAIRMAN APOSTOLAKIS: You never know.
! /
3 MR. ABBOTT: I mean, why couldn't this get on 4 the street before the rest of --
I 5 CHAIRMAN APOSTOLAKIS: Well, if that's the 6 case, that will be the case.
l 7 Do we have any comments from NEI on this? ;
8 MR. BRADLEY: Yes. Bif Bradley, NEI.
9 I just wanted to reiterate a few points that j i
10 we hope ACRS can consider in writing their letter. I 11 think these are things that have come up earlier, l
12 yesterday and today.
i 13 It is true that we have heard from a handful
\_/ 14 of utilities that have dropped or are considering dropping 15 their PRA organizations. It's certainly no avalanche of 16 anything yet. Certainly we have done our best to 17 discourage utilities from doing that. We still think 4
18 there's a lot of hope for this process.
19 However, I think there are a couple of things 20 that are contributing to that. One is the fact that the 21 actual documents haven't been seen. And there is a 22 perception that the process is potentially an onerous 23 process.
24 I think that's been exacerbated a little bit
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l 617 '
1 plants and the very extensive RAIs. Of course, these i l
2
,_s 2 kinds of things are to be expected with a pilot program, l 1l \/ '
t i 3 but there may be a perception on the part of utilities 4 that the follow-on effort for the industry as a whole is 5 going to be just as difficult.
1 6 I think it would be very useful if this 7 implementation plan could somehow suggest once we get l
8 beyond the pilot stage, how the rest of the industry would l 9 follow on and hopefully use some of the insights of the 10 pilot process, rather than have to reinvent the wheel on 11 every plant and every application.
12 You knce, as an example, I think the STP l l
13 effort very -- a three-train plant, which is already an p
(/ 14 advantage over everyone else in PRA space, very robust j 15 PRA, major effort to update it and put the resources into ,
I 1
16 it and still very, very arduous, difficult, lengthy, 17 time-intensive process trying to get any real changes out 18 of the end.
19 I was encouraged yesterday to hear that staff 20 is getting close to writing SERs on some of the tech 21 specs. Again, I think this is a message we've sent 22 before. The industry needs to see some successes in order l
23 to keep the momentum going. And we're all aware of that i
24 and encourage anything we can do to achieve that.
.~
()x 25 There's been a lot of discussion of exemptions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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618 1 and rulemaking. I really think changes that are going to i ,3 2 require those types of efforts, we shouldn't be worrying
( !
x'^'/
3 too much about those right now. All we need to do is 4 concentrate on the changes we can make within the current 5 regulations without using exemptions and get some J 6 successes there.
7 I think people have articulated the concerns 8 and the conflicting kind of signals that may be coming j i
9 down on exemptions. And it's true. Either one of those 10 is a very difficult, lengthy process. And it's just l l
11 unlikely to -- you know, we shouldn't be testing the water I
12 with something like that. We should try te get some I i
l 13 success with what we've got going. I
\ -)
14 So I guess that's really all I wanted to say 15 and, particularly, the emphasis on trying to show an i
16 implementation plan, show how the rest of the industry I l
17 will follow on the pilot efforts in some kind of practical l
18 way to make use of the lessons learned there. That's all 19 I have to say.
20 CHAIRMAN APOSTOLAKIS: Thank you.
21 MR. ABBOTT: Does that mean any NEA or 22 whatever your --
23 MEMBER BARTON: NEI.
24 MR. ABBOTT: Yes. Whatever.
,~,
(_,/ 25 -- is not in favor of making bold moves here?
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619 1 MR. BRADLEY: I think in favor of making bold l
gy 2 moves, but right now it seems that unbold moves aren't
+
)
3 achieving a lot of success. And we just want to get our 4 feet wet, I think, a little bit.
5 It's not to say we would object to some bold 6 moves. Certainly I think that's something we would all 7 like to see. But my concern is that by the time we get 8 around to making the bold moves, that we're going to lose 9 so much momentum that there won't be too many plants left 10 to take advantage of that. They still have the 11 organizations and the capabilities to use their PRAs in 12 that fashion.
13 CHAIRMAN APOSTOLAKIS: Would you like to make
. /
N/ 14 a comment on this or do you think --
15 MR. GRANTOM: This is Rick Grantom. A little 16 bit of a discussion.
17 We feel like moving with the pilots, this is 18 real important, but the bold moves and maybe challenging 19 some of the institutions is also in order if, in fact, the 20 general reg guide does, in fact, allow a path to do that.
21 We think that that might be worthwhile looking 22 at and trying to test things such as definitions of 23 safety-related in some limited way might be a first bold 24 step that we could look at.
(,) 25 I think we should try to pursue some of that, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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_ _ _ , . m.- . . _ _ _ ~.__ _. _ _ - _ . - _ _ . . _ . . _ _ - , _ . . . . _ . _ . _ _ _ _ . _
- 620
- 1 i
- 1. but I'm only going on what I heard that this general reg ,
[ 2 guide allows processes of that magnitude to be attempted
- t 3 here.
- 4. . CHAIRMAN APOSTOLAKIS: Anything else on this? '
5 (No response.)
r 6 CHAIRMAN APOSTOLAKIS: Okay. So we covered 4 7 that. We have a couple of more issues, I believe. This 8 issue of low power and shutdown PRA and external events, l-i
~9: we had discussion yesterday when I think it was comanche l
~ t' 10 Peak had core damage frequency of 5.7 times 10-5 And then t
'~
11' some decisions were made. And Dr. Powers pointed out that l
12 if you added external events and low power and' shutdown l . .
- u. 13 contributions, you may be'above the limit, the goal.
l k'
'(} 14 So you can't really do anything. And I think 15 as a result of the discussion, it's one of the things that' l 16 I learned from Gary, that the number is not the only thing !
l 17 that counts. :
I 18 So, even if you are above the goal, you'can 3 19 argue qualitatively that you are, in fact, reducing risk, 1
20 even though your calculated risk is an increment in risk.
21 That was maybe a way out there. The more 22 fundamental question is: What do you do about these i
t 23 contributions? I mean, there is evidence out there that !
i
-24 they may be comparable to the core damage frequency where
'25 calculating from power operations. ;
f 1 NEAL R. GROSS I COURT REPORTERS AND TRANSCRIBERS i 1323 RHODE ISLAND AVE., N.W.
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[.
. ~ . _ . ,-._ _-_ _. _ _. _._ . -~.., _ . .
- l. 621 l
! i lo So what do we do about that? And is that 1
2 something that has to be included in the long-term l 3 planning or do something else? I don't know.
4 MR. HOLAHAN: Well, our current approach would l 5 use the calculated values plus whatever qualitative 6 judgments could be brought to bear in making this first of i 7 a decision about whether the plant was -- where it fit 8 within the CDF and the LERF guidelines to decide whether 9 this was an easy case or one in which we ought to expect j 10 improvements or in this middle management attention area. I l
- - 11 What you saw yesterday is that there will be j i 12 some judgment cases. If the internal events.are 2 times j 13 10-5, then you're already in that. gray area. And there's a j
14 question about whether perhaps you might be beyond the 15 10-4 L 16 I guess since I'm not that much; inclined to l
17 make an ultimate decision based on the numerical value
! 18 anyway, what it says to me is that 2 times 10'S with some 19 judgment about how much has been left out -- and I don't 20 mean numerically how much because by definition you don't i
E 21 know what that is, but subject matter-wise what's been
- 22 excluded. I think the staff is going to'make some 1
l l 23' judgment about whether it's likely to be well within or
! 24 close to or well beyond this 10-4 guideline in the CDF, .for f_ 2'5 example. ,
t i- NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W. i
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622 1 And based on that, if it looks like the number
,_s 2 is fairly high already and there has been a fair amount of
' 1
~'
3 things left out and those things qualitatively would seem 4 to be reasonably important for this plant, then I think 5 you make a judgment that we should treat this plant as 6 though it is over the goal, the guideline. And we should 7 be looking for a net safety improvement, even though that 8 net improvement could be both, judgmentally both, 9 quantitative and qualitative.
10 If the licensee can argue and the staff makes 11 a judgment that 2 times 10 4 plus a reasonably short or not 12 so much concern over the other issues that haven't been 13 modeled, then fine. Then you treat it as though it's in is/ 14 this middle area, where it deserves some additional 15 management attention.
16 I think almost by definition what we've said 17 is the cases that are an order of magnitude below the l 18 guideline, they're in this area not requiring so much 19 management attention and for which we suggested that less 20 stringent criteria for the analysis might be appropriate.
21 I think if licensees are in those areas, it's 22 unlikely that the things, in most cases it's unlikely that 23 the things, that haven't been analyzed will push them over 24 the guideline.
i t' ~
( ) 25 Now, that's a judgment based on other analyses NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 623 1 that b ve been seen and clearly not based on the plant for i
,3 2 which tnere's no analysis.
! \
\'~~/
3 MEMBER POWERS: For which elements have there i
4 been the analysis? !
5 MR. HOLAHAN: Well, I think there has been 6 analysis of power shutdown, seismic fires and floods. Not 7 necessarily one plant has done all of those things, but )
8 all of those subjects have oeen addressed. Even those 9 areas that hav( v. t all been addressed quantitatively have ;
10 all been addressed qualitatively. The fact that seismic I 11 margins analysis has been done I think helps make those 12 decisions about where the plant lies and how it ought to l 13 be treated.
o
'ss 14 The IPEs and the IPEEEs, I think plus the 15 specific plants that have done shutdown and external 16 events all help in making those decisions.
17 MEMBER POWERS: Do I have an understanding of 18 how I take seismic margins and translate it in some 19 admittedly qualitative, semi-quantitative fashion into a 20 CDF or a LERF number?
21 MR. HOLAHAN: Well, I do. I don't know if the 22 staff does. I think when I see a seismic margin of two, 23 it means something to me. I think it means that seismic 24 is probably not an outlier.
g3
( ,) 25 It probably means -- if it were a good seismic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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- i l 624 i
[. 1 margins analysis, you could be concerned about the quality 2 and the scope of what was done. .But yes, it has some
- b 3 meaning to me.
4 MEMBER POWERS: And not being an outlier means ,
5 that it raises the CDF hy about 100 percent over what you I l-6 calculate for power operatlons?
7 MR. HOLAHAN: Well, I'm not sure I'd think of
- 8. it as 100 percent, as opposed to a few 10~5's. I mean, I'm ;
I 9 not sure that a 10-5 should be 100 percent of that and a- 'l i
[ 10 10+ plant it should be 10 percent of that.
l 11 CHAIRMAN APOSTOLAKIS: So are you saying,_ l l ;
i 12 Gary, that these extra contributors will be handled in a ,
L 13 qualitative, perhaps semi-quantitative way,.the same way b
L 14 that a Level . 2 analysis is handled scimetimes? l i
15 MR. HOLAHAN: Or maybe even less depending on !
l 16 the kind of decision that's to be made. !
17 CHAIRMAN APOSTOLAKIS: But they will have to 18 be addressed, though, in each decision?
19 MR. HOLAHAN: I think the supposition is that ,
l l 20 they shall be addressed.
t 21 CHAIRMAN APOSTOLAKIS: Yes.
r 22 MR. HOLAHAN: Yes-because otherwise you're 23 really not making decisions in light of the principles.
24 In order to say something about the principle, you ought a/ 25 to at least bring your best judgment to bear as to where i
f NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVE., N.W.
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625 1 you think you are, f3 2 MR. KING: Ultimately if there's a big enough I,
)
~'
3 uncertainty, you can go back to the licensee and ask them 4 to do more analysis.
5 The reg guide says that. I think it covers, 6 the reg guide covers, what Gary talked about. Now, we may 7 want to play with the words a little bit, but the concept 8 is in there. And the bottom line is if you really need 9 more analysis, we can go back and ask for it.
I 10 MR. HOLAHAN: And the very worst case is that i 11 the plant should be treated as though it's above 10-4, 1
12 which says that the net effect of the changes that are
]
13 being proposed ought to be net improvements.
/,_'T
- 1 :
\~/ 14 And from what we've seen in most of the l l
15 examples, so long as we're willing to take qualitative 16 insights into account, many applications will meet those 17 standards.
18 MEMBER POWERS: I guess I'm like George. I'm 19 learning too much. This seems to be a whole regimen of 20 considerations that either my scholarship out of Talmud is 21 not that good and I didn't distill it out of the words or 22 the words just are missing or somehow escaping me on l
l 23 theses steps that I should take.
24 And I don't see the steps taken, for instance, p
(,) 25 in the famous slide on Comanche Peak. There's no evidence NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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k 626 i
1- that the steps were being taken. But I understand that 2 this is early in the ball game. And maybe I'm premature O
3 on this.
4 MR. HOLAHAN: That slide was not an. integrated 5 decision-making slide.
-6'- MEMBER-POWERS: But I had a feeling that' 7 somebody was putting it up for me to have a take-home-8 lesson out of it.
9 - MR. HOLAHAN: I think what they presented were 10 some of the facts as we currently understand them.
11 MR. KING: A snapshot possibly.
12 MR. JONES: And 'I think'just, Dana', also that l i
! 1 13 the slide that came after it was: What do we expect.to-i i
14 raise or are about to raise in the next round of RAIs?
15 And those were issues that were on the plate as a general 16 rule.
17 MR. HOLAHAN: Yes. What we're doing here is
- 18 trying to write down the kind of regulatory thinking that l
l 19 the staff ought'to be doing all the time. And'what we're L= i ll 20 doing is we're doing it-in'a more systematic and a better, I 21 if'not perfect, at least in a better way with better-t- ,
I I - 22 documentation.
23 MEMBER POWERS: I don't argue with --
24 MR. HOLAHAN: All of these issues still-exist,
, 25 whether we write them into the reg guide or not. .
f-
! NEAL R. GROSS lI COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W, (202) 234-4433 .. WASHINGTON, D.C. 20005-3701 (202) 2344433
[
I - ,,--,,---->,-,m . , , _ , ,_. a e '.~ , r -, ,
. _m .-. . .. . _ . . _ .-_ _ _ _ __ ~.. _ . . . _ _ . _ . . - . . . - - _ _ . - . _ . . _ .
627
-1 MEMBER POWERS: Granted that. I guess I come 2 away. thinking that either there have to be some changes in O 3 the wording'to establish -- primarily in the reg guide i
)
.4 because.I think in the SRPs you've actually done a pretty i
5 good job awarding people two issues.
- l 6 And I-think you have used a case study or ,
l l
7 you've tried to raise examples. Especially in the QA ;
i 8 area, you list examples of where you can get in trouble on j i
9 these things. Especially in the reg guide, you need to be 10 much clearer about the kinds of information that you're 11 expecting to_see lest you,get into this flurry of RAIs as 12 you try to formulate that thinking on the fly.
L .
13 I, quite frankly, don't know how I would do it A
'U 14 right now because some of these translations I just don't 15 have.
16 MR. HOLAHAN: I think one of the reasons we 17 talked yesterday abcut the Jones process, having Mr. Jones 18 define exactly how the staff review was going to be done, l
19 was because it's pretty clear that you can't pick any two !
L 20 members of-the technical staff, no matter how bright they L,
21 are, and expect them to make these sorts of decisions that 22 have lots,of regulatory philosophy in them. And you !
23 certainly.can't do it without giving them some guidance in
(
l 24 training.
25 Now, you know, the basic level of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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I
628 1 guidance I think is what constitutes the reg guide and'the
.2 SRP. But some level of training and experience and 3 management oversight needs to be built into that process.
4 MEMBER POWERS: There is no substitute for 5 experience. And a well-experienced reviewer is a godsend 6 to all concern. But, unfortunately, not everybody can be 7 a well-experienced reviewer on day one.
8 And so you have to revert toward a 9: prescription, some sort of a systems-level approach, that 10 says, "Here are your requirements. Here's your mission.
11 Here are the requirements. And here are the functions 12 that you have to establish to meet those requirements in.
13' this team that you set up in some way."
i 14 And right now in the general guidance I just 15 don't come away with saying, "I can write down those
-16 functional requirements and those functions and set up a l'7 review team that will make this integrated decision-making I
18- easily."
19- MEMBER MILLER: On the issue of 20- well-experienced reviewers, do you have any 21 well-experienced reviewers?
22 .MR. HOLAHAN: Yes.
L l L
23 MEMBER POWERS: The three of them sitting up j i
l 24 here I have-every confidence in.
.5
- 25 ' MEMBER MILLER: The well-experienced reviewers I.
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629 1 are sitting before me.
7- 2 MR. HOLAHAN: No, no, I don't suggested that. l 3 I think we have some experienced regulators.
4 MEMBER MILLER: That's what I'm looking for.
5 MR. HOLAHAN: You probably have 60 years of 6 regulatory experience sitting here. But when it comes to i 1
7 expertise, I think the staff has sitting on -- I would 8 take those three gentlemen sitting over there against the l l
9 all as being as expert as anyone I've ever met in the area l l
10 of probablistic risk assessment. l l
l 11 MEMBER MILLER: Actually they've worked out in '
1 12 the field with licensees and so forth?
13 MR. HOLAHAN. Yes, yes.
I
'> 14 CHAIRMAN APOSTOLAKIS: We are on record, of 15 course.
16 MR. HOLAHAN. You are on record.
17 Unfortunately, their names weren't listed, but those of us 1
18 who are here know who they are.
19 MEMBER MILLER: I would think you would send 20 them out as emissaries, then.
l 21 MR. HOLAHAN: I'd be careful where to send 22 them because they did some of the PRAs that I would be 23 sending them out to look at.
24 MEMBER MILLER: Well, they can just go to --
e s f
() 25 CHAIRMAN APOSTOLAKIS: I strongly urge you to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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630 1 put the thoughts that you expressed earlier in this 73 2 introduction that you are preparing because they are very
}
~
3 enlightening.
4 And, second, I'm not sure that the years of 5 experience are an additive quantity, by the way.
6 MR. HOLAHAN. I'm not sure that --
7 CHAIRMAN APOSTOLAKIS: Are we done with this 8 topic? Okay. How about this other issue of taking more 9 drastic action? Bold. That was the word that was used.
10 MR. CARROLL: I'm getting worried about the 11 bold pilot under the old pilot, bold pilot, old/ bold.
12 CHAIRMAN APOSTOLAKIS: Have we settled that
,_ 13 issue? j k- 14 MEMBER POWERS: It certainly is no doubt about i
15 it that many a bold step has been met with a flamboyant 16 crash, but I'm willing to take the point of view that the 17 pain involved in changing a regulatory philosophy is 18 independent of the boldness of the step.
19 MR. HOLAHAN: Yes. In fact, there are some 20 people who are concerned about the level of effort on 21 minimal items. Yet, it isn't clear to me that the effect 22 is linear. It may be that if you're going to invest ten
! 23 million dollars in the PRA, maybe you ought to try 24 something bold to get a --
,-~
(_,) 25 MEMBER SEALE: The probability of success is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHCDE ISLAND AVE., N W.
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"631 ,
1 not adversely. proportional to the boldness of the 2 enterprise.
7 4
3 MR. HOLAHAN: The probability of success-is, 4 based on the weight of their arguments. ;
5 MEMBER KRESS: The logic and the-6- reasonableness of your arguments. ;
7 CHAIRMAN APOSTOLAKIS: As long as the --
8 MEMBER POWERS: But the step I guess I'm 9 interested in your thoughts on is~in the area of the 10 graded QA because it seems to me that that's one'that's I 11 the most quintessential example of where I think a 12 risk-informed analysis both is planned to be used and can 13 have singular impact. l
- )
14 Let me see if I understand that reg guide on.
15 graded QA in outline well or adequately because it's not l
16- clear that I do.
17 'MR. HOLAHAN: Okay.
i 18 MEMBER POWERS: But I see them using risk i
19 information derived'from PRAs that have been done, perhaps 20 a substantial dose of judgment on the omitted parts of the I l 21 PRA, but in'some way because it's used in a qualitative t
i .
i l 22 fashion, maybe I don't need such a detailed PRA on every ;
I L
l 23 aspect of-it,'to say, "Here are the risk-significant 24 functions of this plant."
25 And, of course, in each one of those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
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632 ,
l 1 functions, there are a. lot of: systems and components that '
I s 2 are _necessary for that- function to be met. And I put 3' those things'high in my QA list.
4 Then I use the FSAR and'the' current licensing ;
5 basis-to come up.with another set' of functions and, as a i lI 6 result, systems and components that are safety-significant-7 and may.or may not be risk-significant. And those, too, I 8 put up high on my QA list.
9- MR.'HOLAHAN: I think I lost.you at that 10' point.
11 MEMBER POWERS: Yes. I've got to do something 12 here.
~
13 MR. CARROLL: Taking the first draft.
14 MR.-HOLAHAN: Okay. Well, keep going. I put 15 a little footnote at that point. I may want to branch off 16- at that-point.
17 MEMBER POWERS: Now's the time to branch if 18_ you want to branch.
19 MR. HOLAHAN: 'Okay. I don't think things 20- become high simply because of a design basis analysis. If 21 there is something that's not modeled in the PRA and.you-22- want to, substitute a design basis judgment for putting.it 23
]
high because you don't have a good basis for-making it j I
24 low,.that might be the case.
l 25 'But'if it's something that's modeled'in the i
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633 1 PRA and you have a basis for judging through importance
,ess 2 measures and other things whether it's safety significance N ')
3 or not, the fact that it's a design basis component in the 4 FSAR seems to me not to be relevant. It stays in the QA 5 program because we're still calling this an Appendix B 6 activity, but it can be treated as low.
7 MEMBER POWERS: That is the step that I want 8 to get to quickly.
9 MR. HOLAHAN: Okay.
10 MEMBER POWERS: So let's get there quickly.
11 Why is it that we cannot use our risk information and say, 12 "All those things that fall in my risk-significant 13 category indeed should have a high level of QA attention?
< \
14 All those things that are not risk-significant based 15 either on quantitative PRA or this judgmental quality that 16 we have here but still are safety-significant at some 17 level, why can't we put those in a low QA program and rely 18 on our monitoring activity to catch our errors?"
19 MR. HOLAHAN: We are doing all of that up to 20 the point of saying, "And only use your monitoring program 21 to catch errors" because -- ,
2 22 MEMBER SEALE: And rely.
23 MR. HOLAHAN: And rely, although I think the j l
24 -- what we're doing is we're reviewing approaches that 1
(~)g
( 25 have been proposed to us. Okay? So it's a little bit NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS
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634 1 hypothetical for me to say whether we would have approved 2 that approach if it were suggested.
g 3, i
V 3 What has been suggested is putting them in a 4 low category. And that low category would address more 5 than just monitoring. It would have some level of all the 6 other pieces of QA program, some level of receipt 7 inspection and --
8 MEMBER POWERS: As far as I know, none of the 9 components --
10 MR. HOLAHAN: They're at a reduced level.
11 MEMBER POWERS: -- none of the components that 12 we're discussing here at all escape the requirements of 13 Appendix B. It is only the level of effort that we're
/ T t i
\' 14 applying to meeting those requirements.
15 MR. HOLAHAN: Yes. That appears to be the 16 nature of the proposals that we are reviewing, yes. That 17 doesn't say that we wouldn't be willing to review 18 something else if it were proposed.
19 CHA :tMAN APOSTOLAKIS : And I think we have a 20 comment.
21 MR. MARTIN: We originally started down that 22 track. Okay? And you've got to understand we're two 23 years into this thing. But about a little ove; a year 24 ago, we were on that track. We wanted to substitute or l
l p
_, ) 25 leave out some of the items at Appendix B and go a lot NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I 1323 RHODE ISLAND AVE., N.W.
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.1 635 1- more, maybe not totally relying on monitoring, but head in y-s 2 that direct' ion. i 3 And at that time the staff was not ready to do ,
I
~
4 that. Now, they did not have these reg guides and the new )
1 5 knowledge that we're gaining here today, but we were l 6 absolutely told they would remain-safety-related and you l i
7 would apply Appendix B to them. !
8 So it's not a case of if they could have had i 9 that proposal. We wanted to give them that proposal. The !
~
10 staff just wasn't ready for that. I'm about ready to give {
11' them one. Okay? f
-j 12 (Laughter.) .
I 13~ HMR. MARTIN: I'm going ^to tell.you how to deal l 14 with Appendix B and just tell you I'm going to have a l
-{
15 corrective action program for it. The staff.is still ?
16 having problems with that. And I want to tell you my 3
17 staff is having problems with that. j
- UB' How do I do that? Well, it's the same 19 corrective action program I have today, the same 20 inspection program I have today, when, in fact, I don't 21 need to do all of those elements for that. I may only 22_ need to do three of those elements for that. Okay?
23 We were told at the time we made our last i
24 submittal still that we had to deal with Appendix B if it )
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1 l
636 1 realm. We would have loved to have done that. We thought 1
1 2 it was a smart thing to do.
7
\) 3 MR. CARROLL: But doesn't graded QA, which is 4 permitted by Appendix B, infer that you can leave out or 5 at least put very minimal effort into certain of the 18 6 criteria?
7 MR. MARTIN: It talks about safety 8 significance. And I absolutely agree with that. The 9 approach that was taken when we made our last submittal, I 10 when we made our first submittal was for safety-related, i
11 that was safety-significant. And, therefore, you would 12 apply all 18 criteria.
i 13 MEMBER MILLER: In other words, all components I
?
( a l
k) 14 that fit within safety-related, no matter what their 15 significance is, it would still be Appendix B? I 16 MR. HOLAHAN: Well, within the scope of 17 Appendix B, but not necessarily high.
18 MEMBER MILLER: He just said all 18.
19 MR. HOLAHAN: Right.
20 MEMBER MILLER: In other words, I took it if I 21 had a safety-related function and I had so many components 22 in there and one of them was low low safety significance, 23 --
l 24 MR. HOLAHAN: Right.
g
! 25 MEMBER MILLER: -- it still would have to fit j
-_)
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i 637 l 1 Appendix B, all 18 elements. I think that's what I just 1
.,_ 2 heard. But be careful. All 18 elements doesn't mean that j
. r ,
\' ') 3 they're all treated the same. Each, many, or each of l
4 those 18 could be graded. Okay? And you could give it a ;
5 lower level treatment of corrective action or of the other 6 elements.
7 MR. CARROLL: Is zero a grade?
8 MR. HOLAHAN: No.
9 MEMBER MILLER: Does a low grade mean a whole I
10 lot less effort?
11 MEMBER CATTON: I'm kind of hearing that it 12 doesn't.
I 13 MEMBER MILLER: What I'm looking for is I'm
\
(x_)'\ 14 looking for the carrot. I don't see it here. I'm like 15 Dana, I guess, in a way. l 16 CHAIRMAN APOSTOLAKIS: Mr. Dinsmore has a 17 comment.
18 MR. DINSMORE: Yes. This is Stephen Dinsmore 19 from the PRA Branch.
20 I do the PRA stuff, but I sit around -- none 21 of the QA guys are reading at the moment. But I've picked 22 up a little bit of QA. And the key there is that there is l
l 23 a set of equipment called safety-related.
24 That equipment is in Appendix B. And they say I..) 25 we're not considering changing that at this time. I guess NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W (202) 234 4433 WASHINGTON, D C. 20005-3701 (202) 234-4433
l 638 why not I'm'not really sure. I guess it requires a rule
(...
K 2 change.
O 3 MR. HOLAHAN: Well, it'either requires a rule-J 4 change or an. exemption --
-. 5 MEMBER CATTON: Why? l I
6 MR. HOLAHAN: -- unless you want to interpret ;
! +
7 the rule to mean commensurate with safety means zero.for f
8 some items. I think that is disingenuous.
9 MR. DINSMORE: The grading the 18 elements, l l '
l 10 whether zero is a grade or not, they're discussing that. ;
11 They're trying to figure out how much weight to give to 12 each one or how to go about it. l l !
- i. 13 :And they've been going to the pilots'and ;
I .
1
> s 14 asking the pilots what they're planning ondoing, I think, l 15 and then kind of discussing with them back and-forth about ,
l 16' whether t. hat's'enough or whether that's not enough.
17 So yes, safety-related-is going to stay ;
{ .
l 18 safety-related. Safety significance will be used to l 19 determine how much QA is to be applied to the individual 20 on --
21 MEMBER POWERS: But why is it that we're f-
-22 staying welded, wedded, maybe welded,.but definitely j 23' wedded, to safety significance as our measure and not
[ 24 saying, "No. There's no rationality to that. Let's j l
- .f) g 25 attend to risk."
We are already admitting to going beyond
- NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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639 l 1 what we have in the quantitative PRA and allowing
,s 2 judgmental risk to be introduced here.
( '
)
3 MR. DINSMORE: Well, the extension to 4 functions not modeled in the internal event PRA, the 5 seismic events and that kind of stuff.
6 MEMBER POWERS: We've already admitted that 7 we're going to allow judgmental quality there.
8 MR. DINSMORE: Right. Well, that's where we 9 were going to apply these judgmental decisions. And it 10 would be more along the lines of you look at the systems 11 you're using to mitigate seismic accidents.
12 You look at your seismic margin analysis. And 13 you look which systems in there you're using. Then you go
\_) 14 back and you check to make sure that those systems have 15 not been graded low because of the internal event 16 analysis, the importance measures and all that stuff.
17 If they have been graded low, then you would 18 normally raise them to high. And so you do that for 19 tornadoes, for seismic, for winds, for shutdown. You 20 could do it for transition if you wanted to do it that 21 way. That's what we were --
22 MR. HOLAHAN: From a policy point of view, the 23 message you're getting is that at certain times and with l
24 certain information available, the staff is going to say l
g
(_,) 25 it's not prepared to change something, it's not prepared NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 640 1- to be bold on certain subjects. Okay? I mean, I'm 2 encouraging the industry to press the staff to figure out ;
- O 3 where we're willing to change.
i 4- Now, it seems to me maybe what we really need l 5; is some sort of screening activity where we can't expect.
6 licensees to put together a million-dollar program on :
I 7 something that's unlikely to be successful, j i
8 So maybe what we really need is to identify l 9 those things that the industry thinks would be valuable-10 changes and have some preliminary dialogue before people' 11 have put a lot of resources into the issues and think :
i
-12 through which issues are ripe for change and which ones --
13 perhaps they don't have the level of information available -l
( 14- to support a large change. ;
15 And pick things which are likely to;be i l
16 successes,-not based on the fact that they're unbold but 1 1
17 based on the fact that it's an area where the staff would i 1
18 be'not only receptive but reasonably comfortable making a 19 change because of the informction that could be brought to 20 bear on the subject.
21 I think that's one of the steps that needs to 22 be done. And I can't tell you right now whether graded l 23- elimination of Appendix B or redefining safety-related is 24' that subject or not. But I think we definitely ought to ;
12 5 put it on the table. Otherwise we'll never find out.
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1 641 l 1 MR. MARTIN: We're willing to do that. Okay?
,- 2 But what we need is -- and you need to understand, Gary,
() 3 that you're talking about things that when I talk to the I 4 QA Branch, they haven't quite received your message yet.
5 And I think that's reflected in some of the 6 sensitivity things that they talked about, where they're I
7 going well beyond your regular guideline in applying some i
8 of these things. l 9 And, if I understand it, I'm willing to j l
10 challenge. I may not always succeed, but I'm willing to 11 challenge. But when I get ready to do it and I'm i 12 interfacing with them and the staff cuts me off before I l
13 can get there, I understand and I will find out and
(~)
't I 14 memorize your phone number.
15 (Laughter.) i 16 CHAIRMAN APOSTOLAKIS: We have a comment from 17 NEI who would like --
18 MR. HOLAHAN: Can I respond to that?
19 CHAIRMAN APOSTOLAKIS: Very quickly.
20 MR. HOLAHAN: Yes. My phone number is 21 415-2884. And I think what the industry needs is not a 22 branch or an individual answer to how responsive the 23 agency is to making a change in an area, but you need an 24 agency answer.
i q ) 25 CHAIRMAN APOSTOLAKIS: We noticed you kept NEAL R. GFM)SS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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642
]
1 your area code secret.
7_3 2 MR. HEYMER: Mr. Chairman, South Texas is j e i
(/
3 quite right. We did go down that path, as was suggested, 4 as a bold move two years ago. Perhaps it was a concept 5 too far at the time.
6 We are meeting with the staff next week. And .
1 7 we are going to discuss some issues associated with 8 improving the QA process, which is along the lines that 9 have been suggested here today.
10 So whether it's bold, whether it's not bold, 11 whether we get an agency response or not, we are still ;
12 going to pursue that option. And, even if that door is 13 closed, we will not give up because this is an area where i
\_/ 14 we think there is improvement.
i 1
15 It's not a case of: Is there Q and non-Q? Is 1 16 it Appendix B or non-Appendix B? It's quality. And if 17 you look at any management process, whether it's Honda, l
18 whether it's Ishikaajima Heavy Industries or whether it's 19 Motorola, they have a OA program. And it's not because of 20 a regulatory requirement. It's because it makes sound 21 business sense.
22 And that's what we're after, operating out 23 plants most effectively and safely. So we're not going to 24 give up on the bold approach.
() 25 MR. CARROLL: Are you going to invite Gary to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l l 643 1 your meeting? l
- ,-s 2 MR. HEYMER
- He has been invited.
i . I i s
3 MR. CARROLL: And are you going to attend, l 4 Gary?
5 MR. HOLAHAN. I'll have to check my calendar.
6 Let me mention one thing --
7 MEMBER CATTON: I missed who you were with.
8 CHAIRMAN AFOSTOLAKIS: NEI.
9 MR. HEYMEF. : NEI.
10 MEMBER CATTON: NEI? Okay. j 11 MR. KING: What Gary proposed in terms of the l 4
12 screening process is precisely what was done in the 13 rulemaking area several years ago and resulted in what was .
(\/ ) '
14 called this marginal safety program, where we went out and ;
15 got from the industry the rulemakings that they felt were )
1 16 burdensome that they'd like to see changed.
17 We prepared a paper to the Commission that 18 said we propose changes in these areas, got the 19 Commission's endorsement of those areas. And that might 20 be a good thing to do in this particular instance if we 21 get industry's ideas for these plant-specific areas, get a 1
22 paper up to the Commission, get them to say, "Yes. We're 23 behind you in those areas." And then we've got the 24 endorsement, they've got the endorsement, and we could
,s
(_,) 25 fold that into our implementation plan.
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W.
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644 1 CHAIRMAN APOSTOLAKIS: Okay. Shall we move 7
-~ 2 on, then? Anybody wants -- okay. The performance part.
'~') 3 Maybe we can tie that to the implementation plan, 4 strategic plan.
5 First of all, I sense that there is a 6 disagreement between the staff and NEI. NEI would like to 7 see the performance part play a bigger role than it is 8 now.
9 When can we expect that Mr. Holahan will not 10 use the word " element" anymore, performance " element,"
11 that it will be a risk-informed, performance-based 12 regulation?
13 MR. HOLAHAN: I'm not sure that will ever
( )
N/ 14 happen in the sense that you outlined it this morning that 15 the performance monitoring is more than a validation of 16 the analysis but, in fact, it is a substitute for the )
l 17 analysis and a substitute for some of what would otherwise 18 be requirements. l 19 In many areas, I don't think that performance 20 monitoring alone if that's what performance-based means 21 will be the approach that we settle on.
22 CHAIRMAN APOSTOLAKIS: That's probably an 23 extreme, though. We're not suggesting -- I am not 24 suggesting that monitoring --
x k ,) 25 MEMBER MILLER: Is NEI suggesting that, too?
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Y 645
'1- CHAIRMAN APOSTOLAKIS: Is what?
L f
I 2 MEMBER MILLER: Does NEI suggest performance 3 only?
p
(. 4' CHAIRMAN APOSTOLAKIS: I don't believe they're i.
t 5 suggesting that either.
6 MEMBER MILLER: 'I didn't think they did.
7 CHAIRMAN APOSTOLAKIS: Yes. But let's not'go 8 to the extreme.
l l 9 MEMBER MILLER: Maybe we should call it l
L- 10 performance-informed.
l
-11 CHAIRMAN-APOSTOLAKIS: No, no. We '.1, the 12 thing is: First of all,'do we agree that in the present 13 set of regulatory guides performance is not emphasized as O
- 14. much as the risk-informed part?
l-
- 15 MR. HOLAHAN
- I think that's --
l 16 CHAIRMAN APOSTOLAKIS: That's correct. ;
l 17 MR. HOLAHAN: That's true. And I think that's 18- because we have more experience --
19 CHAIRMAN APOSTOLAKIS: Sure.
I i l ]
20 MR, HOLAHAN: -- and we know how, as difficult h
I-l 21 as this is, to figure out how to put risk insights.into l
22 the regulatory process. We know a lot more about that 1
23 than.in using a performance-based approach. j 24 CHAIRMAN APOSTOLAKIS: Yes. So as we learn I
25 more about the performance-based part, then maybe we can i NEAL R. GROSS ,
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l - - - . .. - ,-, . - .
646 3 L
1 --
l 4
-2 MR. HOLAHAN: Yes. And I see nothing ;
[. 3 inconsistent with that in the. reg guide and theLSRP. I 4- see no reason why you would have to completely overturn !
5 the reg guide or the SRP in order to put more reliance on i .i I 6 the performance part. I mean, it indicates that it is an t
I 7 element of the process. .
i 8 CHAIRMAN APOSTOLAKIS: If I take, say,~any of j t
.9 these guides -- and in some cases you.get.the. feeling that:
i '
i
- , 10 the authors were really in agony when they were writing 1 ,
~
- 11 certain things, _"You know, we really don't know how to .
f r
- 12 handle this, but-we have to do something. And let's do 13 that."
i: r\ . '
V 14, I was thinking, instead of doing thati, 'why 15 don't you say, I'm going to do-some analysis, what I can i
i 16 do now, but I will'put in place a performance-monitoring. H 17 program that will give me sufficient warning when 18 something goes wrong"? Okay?" Wouldn't that be 19 acceptable?
20 And then slowly I learn more from this program j
- 21. and maybe pilots and so on. I will place more and more 22 emphasis on this performance part and rely less and less 23' on analysis to convince myself that I ought to do certain 24 things.
25 MR. HOLAHAN: Well, I guess I agree'with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.
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647 1 direction, but I'm not sure where you stop in the sense
,, 2 that I think that the reg guide and the SRP take a step in i \
.) 3 the right direction of folding performance information 4 more into the regulatory process than has been before.
5 And perhaps we can do more of that as we're 6 more comfortable with how it works and there's more actual 7 data available until you do performance monitoring. But 8 I'm not sure where the balance stops.
9 CHAIRMAN APOSTOLAKIS: Now, let's say that 10 everything goes according to the plan that Bob described 11 to us, which means that this cycle is over by the end of 12 December or thereabouts and there are no bold verbiage.
13 What do we do about performance? Are there any plans to
,m
( )
K_/ 14 try to --
15 MR. HOLAHAN: The Commission has directed the 16 staff to develop I think what I would describe as a l 17 performance-based implementation plan parallel to the PRA ]
l 18 implementation plan. Now, it's given us until August.
19 CHAIRMAN APOSTOLAKIS: Yes, August 29th.
20 MR. HOLAHAN: August 29. I say "us" meaning 21 the staff. It's not clear that Mr. Jones will do that.
22 MR. CARROLL: What's he going to do with his 23 free time?
24 MR. HOLAHAN. Well, in the absence of 25 applications, I think we'll have to do rulemaking because
()
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i 648 )
1 I think we can think of some good things to do, but I !
,-- 2 would prefer to be responsive to industry initiatives. ;
( /
3 So the staff will owe the Commission a plan on 4 how to do more and to work more performance-based 5 initiatives into the regulatory process, both in the area 6 of risk-informed, performance-based, but also in those 7 areas for which perhaps it doesn't lend itself to a 8 risk-informed regulatory treatment.
9 MEMBER FONTANA: Well, it needn't be dependent 10 on the risk-informed. It could be independent to start 11 with. And I think what you are talking about is pulling 12 it together at some point.
13 CHAIRMAN APOSTOLAKIS: Yes, yes. Because you
/ N
> 4 l
\'~ 14 can have performance-based regulation without any risk. ;
15 MR. JONES: And, in fact, that's what the 16 Commission's SRM says. That's why we're saying, "I'm not i
17 sure it's mine because I've got PRA, not t
1 18 performance-based." j l
19 CHAIRMAN APOSTOLAKIS: No. But have to l
20 combine them.
21 MEMBER SEALE: But isn't that almost I
22 everybody?
23 MR. JONES: Right. And there are all 24 organizations --
7m
(. ) 25 MEMBER SEALE: You're having problems now with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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. - . . . - ~ . . . . . - - - - . - _ . - . . - . . . . . . - . . ... -. .-.- - - - .
.649
- 1 graded QA:because there's a QA group, --
1:
4
- n _2 MR. JONESi Right.
\
! 3 MEMBER'SEALE: -- who has got a say in what ,
j
- i. 4 you do. When you get into performance, you've got-I&C ;
5 people and whoever else all-the way across that are going !
. i y 6 to have the right to success criteria. ;
.t b 7 MR. CARROLL: Well, except I'm not sure people 8 take credit for it, but they make fitness for duty. ;
i 9 requirements in the performance of the industry.
]
10 MR. HOLAHAN: Yes.
11 MR. CARROLL: A relaxation of the requirements ,
i 12 based on good' performance. There's one where I wouldn't J 13 even think about risk-informed as a -- i 14 MR. HOLAHAN: Right. I
-15 CHAIRMAN.APOSTOLAKIS: Do you' plan to:get us )
16 involved in the development of your thoughts on'that?
17- MR. HOLAHAN: I can't speak to that. I don't 18 know what the staff's plans are on that yet. I wouldn't 19 be surprised. If the Committee expresses an interest, I l 20 don't see why the staff would avoid --
CHAIRMAN APOSTOLAKIS: Well, they can come at j 22 the end and show us what they plan to do or they can come 23 while they're. formulating their ideas. It can be 24 participatory or --
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650 1 are involved from the beginning the way the rules are now 3 2 or from the very near beginning -- ,
( \ l
\~~J l 3 MR. HOLAHAN: Well, frankly, we can call it 4 what we like, but I think the point is in this activity, I l
5 think the staff has not only shown up to the meetings i 1
6 where we have been invited, but I think there has been an i
7 active level of involvement, I think different from what I 1
1 8 we've had before. i l
l 9 And I think it's been useful. And so whoever j l
10 does a performance-based approach in the future, I would j l
11 recommend that they establish a good working relationship 12 with the --
l l
13 CHAIRMAN APOSTOLAKIS: So it won't be you? j i
! f ,
\' 14 MR. HOLAHAN: Well, I don't know. It isn't j 15 clear even what division of the NRC it belongs in.
16 MEMBER SEALE: You've got a young man standing 17 back there chewing on the microphone.
18 CHAIRMAN APOSTOLAKIS: Yes?
19 MR. GRANTOM: This is Grantom.
20 Well, I had wanted to -- what was just said 21 here and what was discussed was something that caused me 22 to put one of the bullets on the slides that I had. It 23 was this it seems like we reinvent the wheel every time or 24 lessons learned from one application doesn't translate to
( ,/ 25 another.
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651 1 And one of the reasons that that's happened to
, 2 me and that I've seen is that every time we've gone
(' ' ')
3 through a risk-informed or performance-based application, 4 we've had to go through a period of reeducating a 5 particular branch or another particular group of folks on 6 PSA, how you do PSA, what's involved in it.
7 And working with the PRA Branch, they 8 understand what's going on. They're familiar with what 9 we're doing. But it seemed like it was somewhat incumbent 10 upon me to go and try to bring the other branch up to 11 speed, the E2ectrical Branch up to speed, on how you do 12 PSA, how you model electrical systems in PRA.
13 What caught my attention here is I'm kind of
,3 k/ m 14 curious as to what is the plan to pay, let me try to use 15 the word, promoter or to advocate or to demonstrate 16 methods of risk in performance, performance-based 17 regulation to other branches that are outside the purview 18 of the PSA Branch or how we do that so that it's not 19 incumbent on me to go and try to explain this to them and 20 I look like the licensee coming in there and trying to 21 tell them something. I think they would probably rather 22 have it coming from your own house.
23 So I'd like to hear a little bit about that.
24 MR. HOLAHAN Well, the activity that Mr.
~j
) 25 Jones has been volunteered for, the guidance on how to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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652 1 reviews, is not just guidance for the PRA Branch. It is l
7, 2 guidance, in particular, for all those other people who
( )
3 don't know how to do these things. To me, that means the 4 project managers in the I&C Branch and Electrical Branch.
5 Yes. I'll leave out my other branches because 6 them I can control, I hope.
7 MEMBER SEALE: Until now.
8 MR. HOLAHAN: Yes.
9 CHAIRMAN APOSTOLAKIS: Okay. So there seems 10 to be an opportunity, then, to discuss this.
I 11 MR. HOLAHAN: Yes. We recognize that this is l 12 something that needs to be done. l 13 CHAIRMAN APOSTOLAKIS: The last item here, o s
\m / 14 which I think we have touched upon already, is by Mario:
15 What is the relief that's coming from all of this? I l 16 think we already discussed it under the name " carrot." Do 17 you want to discuss it further?
18 MEMBER FONTANA: No. Only that maybe not --
19 " emphasis" is maybe not the proper-word, but maybe nct so 20 much in the background that it is possible out of this and 21 available and this is one of the objectives. I think it 22 ought to be kind of sold that way.
23 MR. ABBOTT: I think it goes a little further 24 than that because I think there are numerous opportunities
,/ \
() 25 within the process that has been described here -- and I NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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653 )
1 hesitate to use the word, but to attack some of the
,s 2 regulations, which, in fact, don't increase safety and
]
3 would, in fact, if you did them differently increase l 4 safety and reduce costs.
5 So it's not just necessarily the payback in 6 economics. It's the payback in the fact that the risk of 7 the facility will be reduced. And I think one of the 8 things that we've talked about today is this whole 9 business of technical specifications and if they were more l
1 10 risk-based, the kinds of things that Rick talked about in 1
11 terms of having systems out of service, wouldn't happen. l 12 And not only would that reduce costs because )
13 we would eliminate -- I mean, if you've ever been in a 4
i/ 14 control room when a piece of equipment is out of service 15 and someone is trying to figure out what the hell they're 16 going to do, you'll see them sit at the control panel with 17 a thing that's about this thick called the technical 18 specifications going like this and acting like a 19 Philadelphia lawyer and trying to figure out what the hell 20 to do. And that's a problem.
21 That problem would be substantially eliminated 22 if more risk-informed processes were in place for making 23 the kinds of decisions that needed to be made when 24 equipment is taken out of service.
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654 1 increased safety.
! -~ 2 CHAIRMAN APOSTOLAKIS: Okay. Now, what we l ('")
! 3 need to do is discuss the letter. First of all, I will l 4 ask the members whether they would like a five-minute C break before we do that.
6 MEMBER SEALE: That sounds civilized.
7 CHAIRMAN APOSTOLAKIS: It's civilized.
8 The second thing -- let me tell you how I 9 propose to run this. And maybe you should disagree or you 10 won't. First, I think we should break it up into two 11 parts: the positive and the negative. So I propose that 12 first we go around the table and each one of you tell me 13 what positive things they would propose to include in the 7
t i
\/ 14 letter regarding this whole effort.
i 15 And, remember, bear in mind that the key issue 16 here is whether we would recommend to the Commission to i
17 issue these documents for public comment. It's not the I 18 final approval that this is it.
19 Let's talk about positive first, separating it 20 from negative. And then we'll go around for negative, if 21 any. I should have said if any positive or any negative.
22 And then we'll discuss -- so I will have a 23 much better idea of where to put in the zero draft of the l
l 24 letter, which will represent my own personal views and not s
i
_) 25 those of the Committee. And when you speak, you also l
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- . - - - ~ - - - _ . . .. . .- . . . - . . . - . - . . -
I 655 i 1
l 1 represent yourself, not the Committee. j
,g 2 The full Committee will decide in March. -
\
V.
3 MR. HOLAHAN: May I suggest something that 4 would be helpful to the staff? l 5 CHAIRMAN APOSTOLAKIS: Okay. ]
I 6 MR. HOLAHAN: And that is, in addition to all '
7 of the -- after we read the few pages of positive comments ;
8 and we get to the negative section, five pages, in terms j
'9 of negative comments, I think it would be important to 10 distinguish between those things that the Committee might l 11 think were important enough to be changed before something !
12 went out for comment, as opposed to those things which are l i
13 perhaps,'as.in some of your letters, sort of long-term LO
'14 visionary things, which might be a direction we are j
15 working towards, but not necessarily something that had to i
j 16 be worked into the document in a short -- ,
I l 17 CHAIRMAN APOSTOLAKIS: The comment I would !
18 make, although, of course, the Committee does not have to 19 abide, is that if there are any negative comments, let's l
20 see first if we can make them in the form of l
l- 21 recommendations for the next 8 months.
22 So these are the kinds of things we'd like to
! 23 see fixed before the thing is finalized, rather than 24 saying, "We don't like this." But, again, you'know a
- 25 member may propose something else and convince the NEAL R. GROSS !
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i-656 1 Committee to be outright negative.
I-2 So these are just some thoughts regarding the l O ~3~ rules of conduct for the next hour and a half or so. So i
4 let's take a six-minute break, until 4:45. l 5 (Whereupon, the foregoing matter went off the l t 6 record at 4:42 p.m. and went-back on the j t 7 record at 4:56 p.m.)
8 CHAIRMAN APOSTOLAKIS: Gentlemen, it's almost !
9 5:00 o' clock. Let's see if we can do something here. - So !
! 10 do you agree with this process? Go over the positive 7 11. first and then the negative --
12 MEMBER SEALE: Accentuate the positive. !
13 CHAIRMAN APOSTOLAKIS: - or the reservations, ;
n.. -
~ 1'4 let's put it, not negative. Dana, do you want to start?
i -
.}
.I was afraid.you'd ask me 15 MEMBER POWERS: -j l .
I 16 that. These are an extraordinary set of documents. And- .
17 there are a vast number of things that just impress the 18 hell out of me, actually. The first and. foremost of those 1
19 is this beginning of the documents with an axiomatic i 20- principled approach I thought was just one of the best g
21- ways to begin this at all.
22 Throughout the documents I see that they 23 truthfully are risk-informed and not risk-based in their l 24 applications, that that's the marching order. I think ;
t 25 that frequently they do a good job on that.
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657 l' The difficulty I'm running into right now in I 2 your spur-of-the-moment comment is that I've been focusing !
i 3- lots on the warts as I see them. And so I haven't-4 codified all the things that are good about this. I think l
5, the letter has to address this. !
6- Maybe I can't come up with spur of the moment, -
7' but-certainly those two things, the beginning with the ;
8 axiomatic approach and the way that they have articulated l 9 that it's a risk-informed document and not a risk-based I lo: document, are the two things that stick out in my mind .
11 right now as very good features of the document.
12 CHAIRMAN APOSTOLAKIS: Okay.
13 Bill?
O. 14 MEMBER SHACK: As far as sending it out, I
o 15 think.it's ready to go out. It's a very impressive-
~16- document. I've been impressed that every time we'seem to 17 have a question that seems to be addressed, Tom King., pulls 18 out a.viewgraph.
19 CHAIRMAN APOSTOLAKIS: So then you think the 20 staff has been very responsive to our comments.
' ' 21 MEMBER SHACK: And I think they have been 22 open. They seem to understand where a lot of the ;
23 difficulties are. And they're willing to talk.to us and 'j
\
24 to the public about it. ,
25 I think they're really getting it out there.
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658 1 Its just the most important thing to do at the moment.
2 MEMBER POWERS: Let me echo that I thought the '
3_ questions, the candidate questions, really were seminal ;
4 and' thoughtfully presented. l l
5 CHAIRMAN APOSTOLAKIS: 'Okay. Bob? l 6 MEMBER SEALE: It's probably about the right 7 time to send it out. I agree. I think your team ought to 8 be congratulated, Gary. And while I don't wish'any more l 9 particular clouds to follow you around, I hope the people ]
l 10 who have whatever the next step would be in this I 11 performance side will emulate what has been doing here in l
12 terms of interacting with the Committee and all. You have 13 been very responsive.
O i
1 14 MR. HOLAHAN: And I wish whoever it'is has a .!
15 helpful and extraordinary team to get that done as well.
16 MR. JONES: Jay?
17 MR. CARROLL: Well, I.came into this. sort of l 18 in the middle. I didn't attend the first. meeting. I came 19 back here with a very negative attitude towards this pile 20 of paper. And I've come away feeling that the concerns I H l'
21 have have been pretty much addressed and that the good 22 pile of paper still pushed my idea that this foreword or l
- 23. whatever it's called nort of put this all iri perspective
( E24 for the thought.
25 I guess the other concer.' I have is this is i
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659 1 something that in terms of its implementation is going to fx 2 be handled by Bob's group here. I guess I always worry in
,I this agency that everybody is not buying into something.
3 4 I mean, if one branch doesn't really want to do this, how 5 does Bob get them to do it? How does Gary get them to do 6 it, Gary's boss, or whatever?
7 I think it's very important that NRR from the 8 top down really be part of this and there be no rice bowl 9 kind of problems that we so often see. I don't know how 10 you do this.
11 MEMBER CATTON: You know what they had to do 12 in Sweden? They told them, "You get on the cart or you 13 leave the regulation agency."
14 CHAIRMAN APOSTOLAKIS: Well, but in terms of a 15 --
16 MEMBER CATTON: It was quite dramatic.
17 CHAIRMAN APOSTOLAKIS: Remember how I like to 18 do these letters and list the number of recommendations 19 and conclusions of those recommendations. How do we put 20 this in a positive way, sensitize the Commission to the 21 fact that there are many branches in this agency that have 22 to buy into it or do we need to do that?
! 23 MEMBER BARTON: I think you need to say that 24 there's a need for the agency to get on board to make sure m
) 25 that there's a single focus on moving ahead with this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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660 1 process.
p 2 CHAIRMAN APOSTOLAKIS: We have used the word 1 i 3 " ownership" in the past.
4 MEMBER BARTON: Okay.
5 CHAIRMAN APOSTOLAKIS: Do you want to use it 6 again?
7 MEMBER BARTON: Yes, yes.
8 MEMBER KRESS: That would be reasonable.
9 CHAIRMAN APOSTOLAKIS: Okay. And Jay will ask 10 us, "What do you mean?"
11 MEMBER CATTON: George, a way to irtroduce it 12 could be to comment on what we heard about the educational 13 aspects within the agency. We were told that they were
, )
\' 14 going to do something.
15 CHAIRMAN APOSTOLAKIS: Right.
16 MEMBER CATTON: I think here, then, we can 17 expand a little bit. We're pleased to hear it, but there 18 should be. workshops, case studies, not just a course in 19 PRA.
20 This is probably the most important part. And 21 this is where I think you can put across the concept to 22 everybody within the agency.
l 23 MR. CARROLL: It's fine to tell them, "This is 24 the policy." It's another thing to get them to really buy n '
( / 25 in and --
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L 661 l MEMBER ~BARTON: But you've got to start out j 2 with what your expectation is.
U
~
3 MEMBER MILLER: You've got to get them buying
. '4 in at the management level. And that has to come from the 1 5 Commission. We start --
6 CHAIRMAN APOSTOLAKIS: Yes, that's why I want
(
l 7 to-put some sort of_ recommendation here.
8 MEMBER CATTON: Well, the educational process
, 9 is important. George hammered it into me over a two-year ,
i 10 period. You need sort of forced exposure to a different ,
i l '11 way of thinking to begin to start to really appreciate it. .
12' CHAIRMAN APOSTOLAKIS: So it's a cultural 13 change that requires --
, b/
(3 14 MEMBER CATTON: It's'a cultural change. And i
15 you almost-have to be forced into it to accept it.
t
~
i 16 MR. CARROLL: Yes. But if you see it
- 17. affecting your rice bowl --
18 MEMBER CATTON: Yes. But what you find, Jay, 19 is it helps you with your rice bowl once you accept it. .
20 MR. CAFROLL: Maybe you can sort of --
21 CHAIRMAN APOSTOLAKIS: Not this 22 recommendation, guys.
l
' 23 MEMBER CATTON: No. I gave you a 24 recommendation.
O 25 MEMBER SHACK: Take away their rice bowls.
() -
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662
'l CHAIRMAN-APOSTOLAKIS: Ivan, give me the !
2 conclusion and then the recommendation.
O 3 MEMBER CATTON: No. I think you want to 4 introduce it. You're pleased to hear about'the plans for 5 educating the agency. I think you want to say the l 6 workshops for the utilities or whoever is interested, ;
f 7 internal courses, case studies are very important. And ;
8 it's much more than just PRA. It's probably the most 9 important part. !
i 10 CHAIRMAN APOSTOLAKIS: Yes. It's more than 11 PRA.
- 12. MEMBER CATTON: It's more than PRA. '!
~!
13 CHAIRMAN APOSTOLAKIS: It's regulating in a
{
O 14 different --
15 MR. CARROLL: ' Regulatory philosophy. !
16 MEMBER CATTON: You have to change the ;
i 17 regulatory philosophy. One of the big problems they have i 1
18 is that deterministic licensing means that they've met 19 something, that the~ book is'on the table. l 20 MR. CARROLL: Lesson 137. ,
21 CHAIRMAN APOSTOLAKIS: And-not too timid to 22 take on bold projects.
23 MEMBER CATTON: hight.
24 CHAIRMAN APOSTOLAKIS: I don't know about the 25 ownership, though. I mean, do we need somebody to own NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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663 l l
- 1. risk?-
i l 2 MR. HOLAHAN: Everybody has to own it.
I( '
i 3 MEMBER KRESS: Everybody. I don't think -- l 4 CHAIRMAN APOSTOLAKIS: Nobody owns it.
'5 MEMBER KRESS: I don't think this is the place L .6 where'you assign ownership. I think --
l- 7 CHAIRMAN APOSTOLAKIS: It's not like the human 8 performance proposal.
l 9 MEMBER KRESS: No,'it's'not the same. I don't I
i l 10. think it should be assigned.
11 CHAIRMAN APOSTOLAKIS: It's a cultural change.
1
!- 12 Gary? ]
l i 13 MR. HOLAHAN: Let me make-a few comments. One !
.l
- 14 is the staff recognized this as a potential problem two I
15 years ago. And that is the main reason why the staff j t ,
1 l 16 suggested that the Commission write a policy statement.
17 The Commission is'on record. I see that Ed'has brought.a 18 copy or at least our handout on'such activity.
i
> 19 And one'of the things'-- I have a pile of them 20 in my office. And we give them away. Okay? We' felt that
'2 1 it was important that it come from the top, that the l
22 Commission'had to send a signal'to the staff and to the
- 23 industry that this is real and that PRA was here to stay 'I
\
- l. 24' and that it was getting high-level endorsement. j
\ /
( 25 So I think that step at the philosophical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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l
664 1 level is done. Now I think what we're talking about is at l
,e3 2 the application level, branches and individuals saying,
(' ! !
3 "Oh. Well, I knew the Commission was going to do PRA. I 4 just didn't know that I had to do it."
5 MEMBER MILLER: Gary, I do think the 6 Commission has to keep reinforcing -- they have a policy 7 statement; right?
8 MR. HOLAHAN: Yes.
9 MEMBER MILLER: Of course, that was the past 10 Commission, not this Commission. This Commission has to 11 by their words and deeds keep reinforcing that this is 12 their policy.
13 CHAIRMAN APOSTOLAKIS: A policy is a policy.
fm,
%s 14 It doesn't 15 MR. HOLAHAN: This is the policy of the 16 Nuclear Regulatory Commission, not of any individual --
17 CHAIRMAN APOSTOLAKIS: We are emphasizing l 18 implementation now. {
l 19 MR. HOLAHAN: Yes. In implementation, I think l I
20 it is a real issue. I think it would be absolutely )
l 21 appropriate for the Committee to suggest that the staff at 22 all levels, including senior management levels, needs to 23 emphasize that this is something that needs to be pursued 24 and accepted as the implementation of a real Commission fm,
() 25 policy.
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665 1 MEMBER SEALE: We're going to have a meeting j ew. 2 with the new Director of NRR sometime soon. And you may
! I N,d 3 want to make the point. .
l 1
4 CHAIRMAN APOSTOLAKIS: Yes.
l 5 MR. HOLAHAN. And I think training helps.
6 Training explains to people what it is.
7 CHAIRMAH APOSTOLAKIS: Yes.
8 MR. HOLAHAN: But training is not commitment.
9 CHAIRMAN APOSTOLAKIS: It's not commitment. 1 10 That's right.
11 MEMBER MILLER: You have to have both.
12 MEMBER BARTON: You need expectations of 13 what's expected in training people.
/ \
\ 1 V 14 MR. HOLAHAN: Yes.
15 MEMBER CATTON: You need the case studies to 16 show them.
17 MR. HOLAHAN: That's part of the education I 18 part. But I think the staff will be responsive to its 19 management when it understands that this is what 20 management really wants.
21 MEMBER BARTON: Right.
22 MR. HOLAHAN: Okay?
23 CHAIRMAN APOSTOLAKIS: Okay.
24 MR. HOLAHAN: I think we've got that at the l
7 \
i
(,) 25 philosophy level. Now I think there needs to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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666 1 high-level management down through the organization that 2 says, "This is not only a philosophy. This means we're 7 ,
( '
'J 3 going to address real issues, and we're going to create 1
4 new paradigms and break the old mold." l 5 CHAIRMAN APOSTOLAKIS: Tom?
6 MEMBER KRESS: Well, I guess you're getting 7 tired of hearing this, but I think this is about as 8 well-done and competent a piece of work I've seen come out 9 of this agency. I think you guys should be congratulated.
10 As far as things I particularly like other 11 than what's already been mentioned, I think you were right 12 on the mark with the CDF and LERF definitions and values.
13 MR. CARROLL: Now if you would only change the p-Ib 14 name.
15 MEMBER KRESS: I have a little problem with 16 that, but I think they're right on the mark with that.
I 17 MR. HOLAHAN: That's negative. !
l 18 CHAIRMAN APOSTOLAKIS: That's negative, yes, 19 not allowed.
20 MEMBER KRESS: Not only that. I think you've 21 done a very good job of articulating the principles of 22 defense-in-depth and what's expected there. So I think 23 those are some very good parts that I particularly like.
24 CHAIRMAN APOSTOLAKIS: Don?
n
) 25 MEMBER MILLER: You guys have said it all.
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i 667 I
1 No. I agree with Dana and Tom. The integrating of the
, ,s
, 2 principles and so forth all the way through the document
/
"' 3 is very well-done. The interaction we've had in various 4 meetings, I'm starting to learn what's going on.
5 I have to say I'm slightly different than Jay.
6 I've been maybe too high on PPA. I've come down a little 7 bit, but I'm still pretty high on it. But I also want to 8 just reinforce the educational part as we're learning the 9 I&C area, which I think is a somewhat less challenging 10 situation than we have here.
11 It is critically important to make this all 12 work, education and get the management -- you've got to 13 get the regional managers to buy in as well as your
/m i i V 14 managers here at headquarters.
15 CHAIRMAN APOSTOLAKIS: Mario?
16 MEMBER FONTANA: Some things. First of all, I 17 think it would be a good idea if you get it across in some j l
18 way or other that this is a good basis for rationalizing 1 l
19 the regulatory structure.
20 I don't know if you don't want to reach that i
21 far, but the regulatory structure nos appears to me to be 22 a real patchwork. I could go into analogies, but I won't.
23 MR, HOLAHAN: Would the Committee like to say 24 that this constitutes coherent regulation?
) 25 MEMBER KRESS: I think we're on record of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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668 1 having said that before, but we could repeat it again.
,c 3 2 MEMBER POWERS: I think we --
! I 3 CHAIRMAN APOSTOLAKIS: No. But --
4 MR. CARROLL: The last time we said that, 5 though, we brought the world down on our head.
6 MEMBER KRESS: No. We've said it two or three 7 times since.
8 MEMBER CATTON: I thought you said it was 9 incoherent.
10 CHAIRMAN APOSTOLAKIS: But I think the 11 important point, though, is to maybe say that this 12 contributes to safety.
13 MEMBER FONTANA: Well, it does that, but the
?~s O 14 point I'm trying to make here, it provides a basis or a i 15 framework that some day you're going to get a coherent 16 regulatory structure, which you don't have now.
17 I don't know. You know how a word engineer 18 thinks better than I do. The point is that it's more chan 19 just adding on a patch every time something comes up, 20 which is what the present structure appears to be.
21 The perception is out there that this could be 22 just an added burden. I think the letter ought to say 23 something about it's not just an added burden, that there 24 are some benefits. It probably ought to say something
,9 i
_,1 25 about -- well, maybe not.
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I
! 669 1 Benefits of participating in the PRA is just a g3 2 process itself. Even just a process itself forces the it )
! \~/
I 3 discipline and the organized way of looking at things.
4 It has benefits I think when people start 5 buying into it improving -- a lot of people don't like 6 this word, but improving the safety culture, 7 organizational factors, whatever you want to call it.
8 And it could appear to be overwhelming when 9 you first look at it. If there's some way of softening 10 the appearance of just a tremendous piece of work.
11 MEMBER BARTON: That's that packaging thing 12 that Jay was talking about, how you package this thing.
13 MEMBER FONTANA: Now, another thing -- I think
.s
- s
\/ 14 this is probably not the subject of this particular l 15 discussion. But when I read SRP Chapter 19, it was really 16 hard to read.
17 I mean, it might be a good idea for someone l
18 to, like Napoleon's colonel, read through it and try and j 19 understand it and then write it in simpler terms, slim it 20 down some. But that's a different --
21 MR. CARROLL: Who's this Napoleon's colonel?
22 Was he the guy who let the artillery's powder get wet and 23 --
24 MEMBER FONTANA: No, no, no, no, no. Napoleon (q,) 25 had a colonel. He went and found the stupidest guy he NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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670 1 could find because -- and he'd have this guy read all the 73 2 orders. If this guy could understand the orders, anybody
'b 3 could understand the orders.
4 (Laughter.)
5 CHAIRMAN APOSTOLAKIS: Everybody knew he's the 6 stupidest guy and --
7 MEMBER BARTON: Yes. But he was a colonel.
8 So they respected him.
9 MEMBER CATTON: The stupidest colonel.
10 MEMBER FONTANA: But the idea is valid. It's 11 got to be understood.
12 MEMBER SHACK: I'm going to volunteer for the 13 job.
> 14 MR. HOLAHAN: We're going to have a hard time 15 assigning it to somebody now.
16 CHAIRMAN APOSTOLAKIS: Is the sense of the 17 members that we should not comment on individual guides?
18 I notice all the comments are kind of general for the 19 whole package. I'm inclined to submit a short letter with 20 a few messages and not bother with details.
21 MEMBER BARTON: Okay.
22 CHAIRMAN APOSTOLAKIS: That's okay?
23 MEMBER BARTON: Yes. That's good.
l 24 CHAIRMAN APOSTOLAKIS: Okay. John?
, ((- ,
) 25 MEMBER BARTON: A lot of it has been covered, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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i ,
, 671 l l
l l 1 but I think if we're serious about going to the l ,, s 2 risk-informed process, we need to get these out. I mean,
< s i i
~~'
3 we can sit here and keep tweaking them. I think we've got 4 to get on with it.
5 Industry is waiting for it. We're hearing a 6 lot of negatives back from the industry. Here are these 7 guys. These have put a lot of money into it and are ready l 8 to go. So I think we need to get them out, get the 9 comments on it, and stop further tweaking them.
10 A lot of work has been put into it. So I l l
11 think you've got to give these guys credit. And let's get )
l 12 on with it. I think the negative things Mario --
13 MEMBER POWERS: Wait. Not negatives this l l
,/'N k- 14 time.
15 MEMBER BARTON: Oh, we're not?
16 Recommendations? That's another round?
17 CHAIRMAN APOSTOLAKIS: I just thought these 18 guys didn't have any negatives.
19 (Laughter.)
20 MEMBER BARTON: I figured we were doing them 21 both at once here. That was an awful negative positive 22 that I heard from Jay.
23 (Laughter.)
24 MEMBER POWERS: Wait until you get to the g
"( ) 25 negative negatives.
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672 1 MEMBER MILLER: We've got three more hours.
2 MR. HOLAHAN: Makes me wich I had a gavel.
O 3- ' MEMBER POWERS: You don't.
l 4 MR. ABBOTT: I think it's the most positive 5 deivelopment since I can remember, even since WASH-1400 was 6 issued. It is a good document, which I didn't think three
'7. or.four days ago. I have nothing to add other than what's 8 already been said.
l- 9 MEMBER CATTON: My turn?
l-10 CHAIRMAN APOSTOLAKIS: Why did you guys change 11 your minds? What did they do?
12 MR. ABBOTT: I'11 tell you the one thing --
13 CHAIRMAN APOSTOLAKIS: Maybe they can repeat i 14 it somewhere else.
15 .MR. ABBOTT: No. We've already gone over 16 this. I think the thing that worried me the most was the l 17 fact that the success of this program depended upon being 18 able to get around the box.of complying with the current l
19 regulations.
20' I mean, that box is still there. But as long l 21 as I-felt'like a lot of other industry people felt that I
22 going in for an exemption was not permitted -- I mean, I-23- that's a strong way to put it, but exemptions were not I 24- looked upon as favorable things to do.
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i i
673 1 we've had two days of explanation of what's gone on and an s
2 explanation of the document, which goes back to why l l!\ ')
l 3 training is important. I'm satisfied. i 4 One of the things that has worried me all my 5 career in this industry is the way the tech specs are put G together because they lead you to conditions in the ,
1 7 extreme that most people don't do. But, nonetheless, if 8 you follow them maliciously, you can do what Rick said and 9 increase core melt frequency. And that's not a good thing 10 to do.
11 However, if it's been explained to us 12 appropriately, -- and I have no reason to disbelieve what 13 I've been told -- it will allow me or somebody who owns a o s
\~>' 14 plant who is worried about these issues to put something 15 together which makes some sense, give it to the staff, and 16 get on with it.
17 I mean, somebody once said that the regulatory i 18 process that you lived with since the beginning is like i l
19 decorating a Christmas tree. We add an ornament here. l 20 It's called Appendix B, which came out in 1971.
21 Then we added Appendix R, which came out after 22 Brown's Ferry. Then we get involved with TMI. That had 23 177 ornaments on it depending on who did the counting. A l 24 hundred and seventy-two?
t ,
! ( j 25 MR. HOLAHAN: I always counted 172.
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674 1 MR. ABBOTT: I thought it was '77. What's ;
(q 2 five amongst friends?
I
/
3 MR. HOLAHAN: Plus or +ninus .
l 4 MR. ABBOTT: Exactly. . Depends on who's doing l
5 the accounting. I remember Roger Madsen discussing that 6 with the Commission back in the early '80s about how many 7 items were in his action plan.
8 You can go on and on. When an event occurs, 9 there's this flurry of regulatory activity. The industry 10 gets all into this mode where you've got to beat the staff 11 back. It requires too much.
12 The staff starts to invent all these 13 regulations so that they're not criticized by Congress.
,a f 4
'd' 14 And now all that ends up in some kind of a regulation, 15 which everybody bitches about complying with.
16 I mean, I think this is a process which to 17 some extent will alleviate the problems we're seeing with 1
18 all these clashing requirements. And I think it's 19 reasonably well put together. And if what I've been told i
20 is true, it ought to work. And that's why I've changed my 21 mind.
22 CHAIRMAN APOSTOLAKIS: Good. Ivan?
23 MEMBER CATTON: I sort of agree with 24 everybody, but I'd just like to make a couple of comments.
i n
C) 25 I-like it, and I think it has a high potential for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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, 675 t ..
}- 1 enhancing safety while cutting costs. And that's really e
i 2 the reason'you do this, is to enhance safety and cut
\
j 3 costs.
4 I really think the figure.that they showed us 1
I 5 this morning, the one that had the branches on it, was j 6 good because you'could just look at it and you could see s
7 this is not really a complicated process. It just sounds i
! 8 like it'or reads like it.
t 9 Actually, it doesn't sound like it because 10 when you ask questions, you get answers back you can
- 11- understand. .And they make sense. When you try to read 1
'i 12 it,. I think what happens is you fall asleep by the time i-13 you get that --
k 14 (Laughter.)
I 15 MEMBER CATTON: It just is awful reading. And i
16- I think somebody. suggested an executive summary or its I 17 equivalent. That would really be'very helpful because
]
18 some'-- l l l
- 19 CHAIRMAN APOSTOLAKIS
- An introduction they 20 will put together.
- 21. MEMBER CATTON: And that figure is nice 22 because it has everything in it.
- 23. CHAIRMANLAPOSTOLAKIS: By the way, we would 24 Can we see that at the meeting like to see that in March.
f,O V 25 in March? Can we see that, the introduction?.
4 1'
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676 1 MR. JONES: I would think so.
- g. 2 MR. CARROLL: The foreword on the --
i \
t
'"/ 3 MR. JONES: I think we --
4 CHAIRMAN APOSTOLAKIS: Well, whatever. I 5 mean, the foreword and --
6 MR. JONES: I think we committed to try to 7 provide you updates of the document sometime late next 8 week depending on CRGR. And we're hoping to incorporate 9 the comments we had to --
10 MR. HOLAHAN: I'd like to hear the negative 11 comments before I made any offers.
12 CHAIRMAN APOSTOLAKIS: Yes?
13 MEMBER SEALE: I think we do need to at least 14 make a point.
15 CHAIRMAN APOSTOLAKIS: Please.
16 MEMBER SEALE: We do need to make the point 17 that the pilot study implementation should be expedited.
18 And this other process doesn't somehow sidetrack going 19 ahead and finishing that so the people who have done the 20 job get the carrot. Okay?
21 CHAIRMAN APOSTOLAKIS: We11, that's a 22 recommendation which is a little --
23 MEMBER SEALE: But it's a positive if it 24 happens.
m
) 25 CHAIRMAN APOSTOLAKIS: So expedite what?
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677 1 MEMBER SEALE: The acceptance and x 2 implementation of whatever you call it, --
i )
3 CHAIRMAN APOSTOLAKIS: Decision, decision.
4 MEMBER SEALE: -- the decision on the pilots.
5 MR. KING: In time to factor into the final 6 guides you mean?
7 MR. CARROLL: On the pilots, which are --
8 MR. HOLAHAN- On their own merits.
9 MEMBER SEALE: Yes, right, on their own 10 merits.
11 MR. CARROLL: But some of them obviously 12 aren't ready for --
13 MEMBER CATTON: One of the things -- can we
( )
k/ 14 just turn back and start with another --
15 CHAIRMAN APOSTOLAKIS: Well, we'll go to Dana 16 for the negative.
17 MEMBER CATTON: Well, if you let him start, 18 there may be nothing left for the rest of us.
19 MEMBER POWERS: That's all right. Just sit 20 and listen.
21 CHAIRMAN APOSTOLAKIS: Okay. We'11 do what 22 Ivan said. We'll go back this way.
23 MEMBER CATTON: Just start with me.
24 I think the negative is the document, frankly.
7
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678 1 could be lightened up a little and made a litt3.s bit more
'2 clear.
O 3 . What they did in New Zealand.when they did 4 this is the documents were handed to an expert group who 5 were out of the field. And if they-couldn't understand 6 it, it'got. changed.
7 CHAIRMAN APOSTOLAKIS: We need the -'-
8 MEMBER CATTON: I think the key to; making 19 risk-informed regulation work is clarity in the document.
10 It's just really important. That's really the only 11 negative thing I have.
12 CHAIRMAN APOSTOLAKIS: So, to turn it now into 13 a positive recommendation, you are recommending.a good 14 editing job to be done in the.next eight months.
15 MEMBER KRESS: He's on-the negative.
16 . MEMBER CATTON: Yes. I.think that's 17 important.
18 CHAIRMAN.APOSTOLAKIS: Yes. And I'm turning 19 the negatives into positive recommendations. So in the 20 next eight months, before a final version is produced, we 21' recommend that the documents be edited-to'become more --
22 MEMBER CATTON: Editing usually sounds'like
- 23. grammar, and that wasn't the problem with'this.
24 CHAIRMAN APOSTOLAKIS: Okay. So what do you
) 25 mean? What's the word that's stronger than editing?
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)
_ . . . . . . . .._. _ - _ _ . ~ . _ - _ - _ . - - _ . - _ _ _ . _ . . . . . . . - . . . . - _ .- . . . .
t 679 1 MR. KING: I think there's some consolidation 2 that could be done. There are some thoughts, similar V 3 thoughts, in different areas that ought to be
)
~
4 consolidated. I think organization might be looked at.
l
, 5 MEMBER CATTON: What did EPRI always say, !
6 " KISS: Keep it simple, stupid"?
] ;
7 CHAIRMAN APOSTOLAKIS: EPRI said that? ;
i 8 MEMBER CATTON: EPRI. They used to talk about i
- 9 the. KISS approach.
l 10 MR. CARROLL: It wasn't invented then. l
, 11 MEMBER CATTON: No, probably not, but --
j 12- MEMBER FONTANA: Vince Lombardi.
13 MEMBER KRESS: Considering this is a D 14 government document, I thought it was pretty well-written, i
.i
~
15 MEMBER SHACK: It's just the sheer thought of l
16 choking down all of these at once. 'If you had read one of 1 17 them, it wasn't so bad. By the time you'had read the 18 seventh one, I agree.
19 MEMBER KRESS: Yes. That's the problem.
i 20 MEMBER CATTON: Did you read them all?
21 MEMBER SHACK: Yes. !
22 CHAIRMAN APOSTOLAKIS: Okay. Are you done, i
'23 Ivan?
24 MEMBER CATTON: Yes.
,('
( 25 CHAIRMAN APOSTOLAKIS: Ed?
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_ . _ - . . _ , _ . ~ - . . _ . _ _ . _ . _ _ . _ . - _ _ _ _.. _ _ _.m __ _ . . _ . _ . _ . . . . . . . . . . _ _
680 1 MR.-ABBOTT: I disagree with Ivan. I think
'h 2 it's' fine. You ought to get it out as soon as possible.
'( ).- :3 The only negative thing --
4 CHAIRMAN APOSTOLAKIS: No, no, no. This is 5- for the December version.
6 MEMBER'CATTON: No.
7 MR. ABBOTT: No.
8, MEMBER CATTON: They should get it out t
9 straight away.
l 710 CHAIRMAN APOSTOLAKIS: Yes. They should get l'
'll it out immediately.
12 MR. ABBOTT: This should go out tomorrow, 13 CHAIRMAN APOSTOLAKIS: Yes.
14 MEMBER CATTON: That's right.
15 MR. ABBOTT: Tonight.
16 CHAIRMAN APOSTOLAKIS: But for the December 17 version, we're recommending --
18 MR. ABBOTT: Yesterday. Now, the only.
19' negative --
p '20 CHAIRMAN APOSTOLAKIS: -- consolidation. I l
( 21 MR. ABBOTT: The only negative thing that I l.
l~ -22' can think.of - and it's not really associated with the i !
-23 document; it's the process that's been defined -- is that u
- 24- there will be -- God, how do I say this without sounding l'O
.(j . 25 like a real idiot?
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681 l l
l 1 There will be utilities who will probably try
]
I es 2 to abuse it in the same manner that they have tried to j i ) i
\'-)
3 abuse the compliance-based regulation process. And I 1
4 think somehow -- and I'm not sure the document does it; l l
5 maybe it does -- there has to be a backstop, for lack of a 6 better term, to prevent that from happening. !
l 7 There are people who have PRAs that are not 8 and IPEs that aren't good enough to be used in this 9 process. And they should be excluded from using it until 10 they get their act together.
11 Now, maybe it goes back to the quality PRA.
1 12 So if that's the case, then I'm satisfied. I don't have j 13 any negatives other than that one. )
(~%
I i
(_/
14 CHAIRMAN APOSTOLAKIS: Okay. John?
15 MEMBER CATTON: You have negatives. It must l 16 be good.
17 MEMBER BARTON: I think I said this before.
18 Some of this is overwhelming. We've heard it before. So 19 I think I agree with Ivan. We'll try to make it more 20 palatable to the reader without alluding the message.
21 The other thing is somehow we need to make a 22 recommendation -- I think we talked about this a little !
1 23 before -- to make sure that -- and I don't know how we go 1 24 about doing this, but to make sure that the agency is on rx
- l. ) 25 board and is ready to go and implement this whole process.
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682 1 CHAIRMAN APOSTOLAKIS: That's similar to what 7- s 2 we were talking about in the positives.
( )
~"
3 MEMBER BARTON: Yes. I think you can also 4 come at it from the other way, too. i 5 MR. CARROLL: Carroll's negative positives.
6 MEMBER BARTON: Yes. It's a negative 7 positive.
8 CHAIRMAN APOSTOLAKIS: A negative positive.
9 MEMBER BARTON: An recommendation, I think we l 10 need to put in there that we need to communicate, j 1
1 11 communicate, communicate because the only way you're going l
l 12 to get this thing out so people really understand it, you 13 really need to communicate the heck out of it.
,,-~~
! 4
'd 14 CHAIRMAN APOSTOLAKIS: Okay.
15 MEMBER FONTANA: Is this a negative that goes l l
16 into the letter?
17 MEMBER BARTON: In the form of a 18 recommendation.
19 CHAIRMAN APOSTOLAKIS: In the form of a 20 recommendation. What is it that they should be doing in 21 the next eight months to improve this document? You can 22 also say that something is just plain wrong.
- 23 MEMBER FONTANA
- Well, I can play my little 24 bow fiddle here. I really would like to see more Level 2
(%
( ) 25 analysis. The screen is okay, but I really think Level 2 v
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i 683 i
1 analysis gives you a lot of insight on accident gs 2 management. !
3 That brings the other thing that doesn't 4 appear to be covered much, a potential for operator 5 actions to terminate things like the whole area of 6 accident management doesn't seem to consume much. i l
l 7 MR. CARROLL: Well, but that's not the point :
1 8 of it. j 9 MEMBER FONTANA: See, I don't know. l l
10 CHAIRMAN APOSTOLAKIS: That's not the point of j 11 this.
l 12 MEMBER FONTANA: Why not? You're doing a PRA. l l
l 13 You're doing risk-based management. And you should have i f} i U 14 opportunities for the operators -- l l
15 CHAIRMAN APOSTOLAKIS: Yes. There's room for i 16 it. But I mean, they don't need to single it out, I don't 17 think.
18 MEMBER FONTANA: Okay. Well, that's what I 19 said. I don't have any --
20 CHAIRMAN APOSTOLAKIS: Maybe the utility wants 21 to make a case and part of their argument is accident 22 management. I think there is room, plenty of room, for it 23 here.
24 MEMBER FONTANA: Yes. I guess that's right.
A
) 25 CHAIRMAN APOSTOLAKIS: Yes.
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684 I 1 MEMBER FONTANA: I don't have any negatives.
i
,y 2 MEMBER KRESS: I think your argument may be
> I
~} l 3 said: Is that Appendix B a process sufficient !
l 4 representation of Level 2 to end up getting an LERF? I 5 think it is.
6 MEMBER FONTANA: I think it is a screen. I 7 think it --
8 MEMBER KRESS: I think it is a screen, but I 9 think it is sufficient for it to get on with this thing.
10 And it would be nice to have a full Level 2, but I don't 11 think it's necessary to ask for that.
12 MEMBER FONTANA: No, it's not. It's not
,~
13 necessary, I don't think.
\ /
N/ 14 CHAIRMAN APOSTOLAKIS: We have a comment.
15 MR. MARTIN: We've got to go and catch a 16 flight. I'd like to thank you all for the opportunity to i
17 come and participate. Both Rick and I thank you.
18 I would, first of all, tell you that I would 1
19 be more than glad to be Napoleon's colonel --
20 (Laughter.)
1 21 MR. MARTIN: -- and will fit that very well.
l 22 But I also would like this -- and I heard the comment a 23 while ago that you don't want to comment on the individual 24 guides. But I suggest to you -- I haven't read them. I 7-~.,
( ,) 25 can only go on the presentation levels. Okay? But I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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685 1 think presentation level made by the QA group with regard 2 to their reg guide was a significantly more pessimistic 3 and guarded approach than you saw in the other
-4 presentations.
5 If that's reflected in that reg guide, I'm not 6 sure you shouldn't at least comment because that may be an 7 ownership issue. Okay?
8 MEMBER CATTON: Yes.
9 MR. MARTIN: That's my comment. ;
)
10 Thank you very much. 'i 11 MEMBER CATTON: In part, that can be dealt 12 with through the --
13 CHAIRMAN APOSTOLAKIS: Well, I think the --
14 . MEMBER CATTON: -- agency's owner process.
15 CHAIRMAN APOSTOLAKIS: Dana?
16 MEMBER POWERS: I think we owe it to our 17 visitors to thank them for their input here and hope that j i
18 they will be able to attend -- )
19 MR. GRANTOM: Thank.you, too, appreciate it. .
20 MEMBER-SEALE: Dana's got another comment.
21- MEMBER POWERS: I hope that you will be able 22' to attend future meetings that we discuss as we go through 23 this. process because I found_your comments very valuable.
24 MR. GRANTOM: Thank you very much. And I hope 25 to also.
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686 ;
l 1 CHAIRMAN APOSTOLAKIS: Where were we? ;
l 2 ' MEMBER KRESS: Going around.
O 3 MEMBER MILLER: I spent more time on the
{
i 4 graded quality assurance than the other ones. And I still 5 don't feel I understand the benefits of doing a GQA. I 6 felt a little bit of that coming.from the industry today.
7 I'm certain the benefits are there. I think ;
8' the-staff has to be maybe a little bit more tolerant or 9 whatever it has to be to articulate what they're going to
'l -
i 10 , Set. relieved from as far as Appendix B requirements.
11- We hear that you're still going to have to 12 meet all the Appendix B, but they're going to be less 13 intense reviews and less intense requirements. 'But in the. I f l Os- 14 end there are going to be more components and~more systems l 15 under Appendix B after you get through with that one'.
16 So I'm a little bit disturbed we don't have 17' the,- I put it earlier, carrots out there for the utilities 18 to buy into that particular one. I think the other ones -)
J19 sound'very positive. I mean, I spent less time on them, 20 but the-overall' plan is very positive. .)
21 -I think I didn't -- I'm not supporting our. i 22 industry people, but he picked out the one I felt was the 23 most negative. I still feel it's the most negative.
24 Perception-wise after you read it; I said when I read it O
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l
. . . . . . _ . - . ~ . _ - . . . _ ~.m -
687 1 it?" I'm.still not convinced I'd want to buy into it yet.
. 2 CHAIRMAN APOSTOLAKIS: Shall we include this 3 --
I 4 MEMBER MILLER: .I'll just put that as a !
5 positive. )
6 CHAIRMAN APOSTOLAKIS: Yes.
7- MEMBER MILLER: The positive, I think you can 8 articulate why.it can be a buy-in through your case i 9 studies. You need to have a case study that shows very- ;
10 clearly how if you take this graded quality assurance 11 document, it will be a payoff, a case-study, kind of a 12 quick winner you might put at the bold plan, wherever you 13 want to-put it, a quick winner.
+
\ 14 And I'm not certain it's any one of'the pilot 15 programs. Maybe it's the one in Texas,. South Texas ,
16 project, to show the industry if you buy into.this,~here's 17 the payoff, both in safety and in money.
18 CHAIRMAN APOSTOLAKIS: Can we lump this 19 together with the first recommendation that they organize-20 and consolidate, rearrange the documents? So one of the 21 recommendations would be to make sure that the benefits-22 that may be derived from this are more~ clearly stated, l
l 23. rather than have it as a separate recommendation.
l 24 MEMBER MILLER: I think that would be very
.;l 25 valuable.
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688 1 CHAIRMAN APOSTOLAKIS: Okay.
f- 2 MEMBER MILLER: I mean, the benefits -- I
( )
3 still have this euphoric look at this whole area -- are 4 out there, but I'm fearful, at least in the one document, 5 we'll scare the industry away from it and will never buy 6 into it.
7 CHAIRMAN APOSTOLAKIS: Yes. By the way, this 8 is a comment I got --
9 MEMBER MILLER: It's a marketing program 10 thing.
11 CHAIRMAN APOSTOLAKIS: Yes. This is a comment 12 --
13 MEMBER MILLER: It's a marketing program.
- 4
'v#
14 CHAIRMAN APOSTOLAKIS: -- I got from Tom Early 15 by phone. He couldn't be here today. His baeic comment 16 was that: Boy, this would be a tremendous burden on the 17 utilities. And why would they do it? What is their 18 return?
19 MEMBER CATTON: That was in the QA?
20 MEMBER MILLER: That was on everything.
21 CHAIRMAN APOSTOLAKIS: No. On all the 22 documents, the whole process.
23 MR. CARROLL: But he didn't sit through two 24 days and --
\u,/ 25 CHAIRMAN APOSTOLAKIS: That's right.
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689 1 MR. CARROLL: -- get his mind changed.
m 2 CHAIRMAN APOSTOLAKIS: But I think we should
( )
3 emphasize the issue of communication and that 1
4 organization. '
l 5 MR. CARROLL: I guess I go along with Don. I i
6 think what you're saying is -- I think of the three areas i 7 that we have pilot programs. The one I really think has l
8 got the most problems is the graded QA. I l
9 I've seen this before with QA people. Years 10 ago when QA was evolving, they really had a lot of power. )
i 11 I mean, they were just insufferable. And gradually people l I
12 said, "This is nonsense. And we're going to back away I 13 from all of this." And they just fought tooth and nail.
'd 14 We actually had to fire some people.
15 MEMBER BARTON: You fired QA people?
16 MR. CARROLL: How, wait a minute. Let's say 17 we reassigned them. They just wouldn't buy into this 18 performance-based QA. I think you're seeing a little of 19 that in the present situation.
20 MEMBER MILLER: Jay, just think it's 21 Shakespeare QA people. 1 I
I 22 MEMBER BARTON: That should not appear in the 23 letter, Ge'rge, that we ought to fire the QA people.
24 CHAIRMAN APOSTOLAKIS: One thing we should do: (
!q) 25 Let's kill all the QA people.
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)
1
690 1 MR. CARROLL: They took early retirement, r3 2 Let's say that.
V 3 CHAIRMAN APOSTOLAKIS: Tom?
4 MEMBER KRESS: I'm not sure where this comment 5 fits in and whether it's a negative one or whether it 6 becomes a recommendation, but let me throw it out anyway.
7 And maybe somebody can enlighten me a little bit.
8 In your risk acceptance criteria, the CDF and 9 LERF, you did a very good job of putting together a system 10 for dealing with the fact that thresh,lds aren't quite the 11 right way to do these. And you've got these buffer 12 regions, which at this point to me is a good way to do it.
13 I wian there were a better way because just a
, i' 14 factor of ten on each side, I wish there was a better way 15 to tie that buffer region to rea.' o.ncertainty in some way 16 in a technical manner.
17 And I don't have a good recommendation for how 18 to do that. And I don't think you ought to deal with it 19 in this document just yet, but I wish somewhere along the l
i 20 line you guys would think about how to deal with that kind 21 of buffer region in a mere mathematical systematic way 22'p.nat factors in the uncertainty in some way.
23 A.?ang the same lines before I finish, it seems 24 like throughn. the variout accuments, the various pilot c) 45 programs, there are other threshold values. They end up NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVE., N W.
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l 691 i
j 1 being high and low safety significance or high and low i
2 risk eignificance.
(7,,i
\# 3 And I didn't see the comparable treatment of 4 those with buffer regions. They look like they were real I
5 thresholds. And I'm not sure how you really plan to deal l
6 with those. And that's the part maybe you can enlighten j l
7 me on. I 8 I like what you did with the LERF and the CDF, 9 but I didn't see it filtering on down to the other 10 threshold values and at the lower levels of high and low l l
11 risk or safety component. l l
12 CHAIRMAN APOSTOLAKIS: Aren't these too l
~
13 detailed comments for this letter?
[ 'i kl m 14 %EN1ER KRESS: Yes. That's why I made that l
15 little prologue before.
16 CHAIRMAN APOSTOLAKIS: Okay. ;
17 MEMBER KRESS: I don't think it's negative for I
18 this thing. I don't think it ought to be in the letter !
19 probably.
20 CHAIRMAN APOSTOLAKIS: Okay. Okay.
21 MEMBER KRESS: But I did want to --
22 MEMBER SEALE: Maybe it's something for them 23 to --
24 MEMBER CATTON: Well, it may be something for
()
() 25 ResearcP to worry about. How do you figure out a way to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W (202) "!34-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433
692 1 do this meaningfully within the PRA perspective?
l s 2 MEMBER KRESS: Yes.
(t T
/ 3 MEMBER CATTON: Because that's what they need l
4 if they're going to risk-based. i 5 CHAIRMAN APOSTOLAKIS: Jay?
6 MR. CARROLL: I have nothing negative to say. l 7 CHAIRMAN APOSTOLAKIS: Bob?
8 MEMBER C. _ON: Hey, I don't believe it.
9 CHAIRMAN APOSTOLAKIS: Robert? I 10 MEMBER SEALE: I guess I am sensitive to the 11 comment that was made by Mr. Martin about the QA 12 presentation. I suspect buy-in is a part of the problem.
13 And it will be very interesting to see the different s~.
l
(..) 14 treatments that it gets in the responses compared to the 15 other ones.
16 I'm not sure you want to do too much more with 17 it right now except I would agree that if you could 18 perhaps articulate what the benefits are, potential 19 benefits are, in a little bit more forceful way because 20 the whole nexus between QA and risk is kind of fuzzy. And 21 that's part of the problem.
l 22 And so I think the benefit has to be explained 23 or presented in some other ways as well. And you might 24 think about that.
t, ! 25 CHAIRMAN APOSTOLAKIS: Dana?
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693 1 MEMBER CATTON: Everybody's holding their
, 2 breath, Dana.
(m) 3 MEMBER POWERS: Yes because I'm a good deal 4 more negative than everybody else.
5 I said one of the big advantages of the 6 document was that it began with an axiomatic principled I 7 approach, but, like the troubles I have with some of the l
8 theorems and math of functional analysis, I'll be damned '
i 9 if I can see how the theorems follow often from these l l
10 principles.
I 11 I think it's essential that that tracing l 12 between the statements that are made in those principles l
l 13 be made clear as you go through the document. And I would p.
( 1 s/ 14 think you would want to do that before you sent it out 15 because frequently in response to our questione, you go j 16 back to your axioms. And you show us how that those 17 seemingly capricious judgments actually tie in to those j 18 axioms.
19 I think that needs to be clear. I think it 20 needs to be clear especially in reg guide and SRPs because 21 people are going to use those things that have not been l
l 22 sitting in on the meetings.
l 23 I think there is insufficient attention to the 24 full range of risk that plants are exposed to through all n
() 25 modes of operation. I think the presentations that we had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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694 1 on the applications demonstrate that the staff doesn't f3 2 take a thorough understanding of all the risks plants are
( )
'w/
3 exposed to.
4 And, of course, what I'm referring to is 5 they're not understanding or not referring to, at least, 6 the risks during shutdown operations and due to external 7 events. It's not entering into the viewgraphs that are 8 presented before us.
9 When we raised these questions, some allusions 10 to the ability to take more qualitative insights and 11 translate them into the decision-making process were made.
12 But I don't think those appear in the document, and I 13 think they have to appear in the document unless you 7 g i
V 14 gentlemen are going to make all the decisions. And I 15 don't think you're going to.
16 One of the items that appears in the 17 applications that I think needs to come forward into the 18 general guidance is this criterion for the AOT. I've no 19 objections to the criterion, but I think it has to appear 20 forward because I think there are going to be other l 21 opportunities to use that criterion than just in the AOT 22 applications.
23 CHAIRMAN APOSTOLAKIS: The criterion? You 24 mean the conditional probability. l
(- l
,/ 25 MEMBER POWERS: That's right, the 5 times 10
1 NEAL R. GROSS l l
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., n W (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433 l
695 1 --
rm 2 CHAIRMAN APOSTOLAKIS: Yes. I have --
)
1._/
3 MEMBER POWERS: -- and 5 times 10-8 I think 4 that needs to appear in the guidance and show how it comes 5 from the principles, which I think it does.
6 CHAIRMAN APOSTOLAKIS: But we haven't settled 7 on whether to do it conditional probability. So with a 8 limit on the frequency.
9 MR. KING: We took an action to think about 10 that --
11 CHAIRMAN APOSTOLAKIS: Yes, to think about it.
12 MR. KING: -- in the long term.
13 CHAIRMAN APOSTOLAKIS: Yes. So we will talk i I
v/ 14 about it in March.
15 MEMBER POWERS: I'm thinking about it, I hope 16 that you give substantial weight to precedence in that 17 thinking because if this has been used in the past and 18 people are comfortable with it and it's simply a 19 judgmental number, change for the change's sake is not a 20 virtue here.
21 MR. KING: Is that something -- change you 22 feel ought to be made before the public comment period?
23 MEMBER POWERS: It would sure be nice to if I don't think it's absolutely essential.
,m s
, 24[iyoucould,but I_) 25 d But it would sure be nice to if you could. I don't think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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696 1 it's a big chore. I think it's just a matter of putting
,- 2 it in there. A paragraph does it for you.
! /
7 MEMBER POWERS: Yes. You would have to think I
8 about that.
I 9 MR. KING: -- to be broader than AOT. '
10 MEMBER POWERS: And perhaps what you have to 11 do before you send it out is put it in strictly for AOTs 12 and say you'll think about where else it might be used. )
13 CHAIRMAN APOSTOLAKIS: You can offer l
,c, 1 i a
' s.J 14 alternatives during this state, couldn't you?
15 MR. HOLAHAN: Sure. j 16 CHAIRMAN APOSTOLAKIS: One in terms of 17 conditional probability and so on in terms of frequency?
18 MR. HOLAHAN: Sure.
19 MR. KING: We can do that, solicit comments on 20 both.
21 CHAIRMAN APOSTOLAKIS: Yes. Okay.
l 22 MEMBER POWERS: One of the things that you've 23 done that's very nice in the document is that you have 24 come up with a way to finesse this technological shortfall gy
) 25 we have in the Level 2 area by offering people this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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697 1 prescription to follow. When they don't have confidence
-7s i 2 in their Level 2 capabilities, they can use yours, as 3 well-founded procedure based on your understanding of 4 Level 2 analyses that you have gained from your own PRAs 5 and presumably modified somewhat by the iPE process.
6 You have no counterpart of taat for either 7 external events or for the shutdown risk. And I think in 8 your planning for the future, you have to plan on how to 9 develop that counterpart.
10 MR. KING: When Trevor was talking, we noted 11 the fact that external events in shutdown were missing.
12 And that was something we were going to try and add in 13 parallel with the comment process.
n
_/ 14 MEMBER POWERS: Okay. It is, of course, my 15 personal view, and just my personal view, that you cannot 16 add it in the next six months for the shutdown risk, that i 17 it's a longer-term project than that.
1 18 I believe that you're being too timid, that I
19 you yourselves are not so timid. The documents are timid.
20 You yourselves are asking for and expressing a willingness 21 to have the regulations challenged.
22 I think that aggressiveness needs to come 23 through much more clearly in the documents. If you want 24 it, you've got to ask for it because the industry is not n
( ) 25 going to invest capital into developing something just to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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698 1 have it rejected.
2 And the area where that timidity comes through
\)
3 the clearly, of course, is in the QA reg guide, which 4 right now I believe that QA is the quintessential place we ,
5 can apply to profit the ideas of risk-based regulation. l 6 And I don't think we've gone far enough. In fact, I think 7 the QA reg guide is not ready to go out, that it should be ;
l 8 rethought and reworked before it is sent out for public !
l 9 comment. 1 10 MR. CARROLL: I certainly would like to add my 1
11 endorsement to that thought. )
l 12 MEMBER MILLER: So would I.
l 13 MEMBER CATTON: I'd go along with that, too, t/~'N.
'N~l 14 if it's a vote.
15 MEMBER SEALE: Is that a workable alternative?
l 16 MR. HOLAHAN: You can certainly send a 17 message.
18 MR. KING: We already have ISI, which is on a 19 separate schedule.
20 MR. CARROLL: But, on the other hand, it's 21 damned if you do and damned if you don't in terms of 22 getting these out on the --
23 MEMBER POWERS: But the problem I see with 24 putting the QA guide out on the street, I think it sends 7s
(_) 25 the wrong message. I think it sends a message that NEAL R. GROSS COURJ REPORTERS AND TRANSCRIBERS 13.'s RHODE ISLAND AVE., N.W.
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699 l
1 they're not intending to send. And I think you would not m 2 get useful comments at this stage. I think you would get ,
t i l i / !
3 exasperation.
4 MR. CARROLL: I think you're right. I 5 MEMBER POWERS: And I don't sense from these 1
6 gentlemen the timidity that that document reflects. In 7 fact, I hear them sayinc' things like, " Challenge us. Send 8 us something that exercises our regulation."
9 It looks to me like QA is just the place to do 10 it because you are using risk information. You really 11 don't have to worry too much about the bottom line 12 numbers. Your using qualicative categorization of things l.
13 for this operation is least sensitive to my concerns about
/ \ \
'C') 14 the breadth and the depth of the PRA Level 2 versus Level 15 1 and things like that. It seems to be the one that could j
!1 16 give us some real wins. !
17 Right now it looks to me like IST will give us l
18 the real win, but I think the QA is an even bigger winner 19 than that potentially.
20 MEMBER CATTON: Cost-benefit analysis.
21 MR. CARROLL: Words like the staff could be 22 encouraged to expedite this vision of --
l 23 MEMBER BARTON: QA.
24 CHAIRMAN APOSTOLAKIS: Yes. I was going to
(,) 25 ask: In the context of the plan that Bob presented, where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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700 1 does this fit? We still want to have the final document p 2 by December?
3 MR. KING: All documents are scheduled to be 4 final in December, including ISI.
5 CHAIRMAN APOSTOLAKIS: So even if we delay the 6 QA document now, we still have to do something to --
7 MR. KING: We're on the hook for December to 8 have them all done.
9 CHAIRMAN APOSTOLAKIS: Okay.
10 MR. CARROLL: Serious QA people ought to be 11 able to straighten this thing out.
12 CHAIRMAN APOSTOLAKIS: So what is the
,_ 13 recommendation? What kind of specific recommendation I'
)
14 shall we make? What is it we want to see there?
15 MEMBER POWERS: My recommendation: one, is do 16 not send out the QA document; two, communicate in the rest 17 of the documents the staff's willingness to apply boldly 18 the concepts of risk-based regulation.
19 MEMBER CATTON: That should be done in the 20 general guidance document.
21 MEMBER BARTON: Ten sixty-one or --
22 CHAIRMAN APOSTOLAKIS: No, no, no. In the QA.
23 You want to emphasize the QA.
24 MEMBER POWERS: And in the QA, I think it's, m
\
(_/ 25 as I say, a quintessential opportunity to apply it. In NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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701 1 the rest of the documents, I think you need to communicate l
l 2 somehow to the industry that'they're receptive to bold LO 3 applications =of these risk-informed concepts.
4 CHAIRMAN APOSTOLAKIS: -I guess we have to make 5 clear why we think it's timid. Now, a way to handle it is l
6 for you to send me four or five lines over e-mail. .
7 MEMBER POWERS: I suspect I'll be sending you .
8 a lot more than four or five lines.
L 9 CHAIRMAN APOSTOLAKIS: Okay. I appreciate it. i
- 10 It will make my life easier.
11 MR. ABBOTT: I have one question on the graded ,
I 12' QA thing. I'm not sure that -- I mean, the graded QA 13 thing has gone through years of development. It's sort of l.
l 14 at the end of its breath here. I'm not sure that process I
15 can be expanded to do the kind of bold moves we've talked ,
16 about.
l . .
l 17 My recommendation for this is let it-go and j 18' revisit the QA in a bolder manner sometime~1ater because i
19 isn't the document pretty much bound by what's happened in 20 the past at this point?
21- MR. CARROLL: I don't think so. I think 22 what's happened in the past was in a certain framework. I 23 think we are now saying, " Hey, we want to impose on that 24 framework the notion of risk-informed much more seriously.
1Q 25 than we.have in the past."
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702 1 MR. ABBOTT: It's not going to be called
.s 2 graded QA, then, is it?
/ \
\* l 3 MR. CARROLL: I think it's the only way you !
i 4 can go without having to revise the Appendix B. )
1 5 MR. ABBOTT: Yes. But if you take stuff off 6 the list because you don't think it's important and QA i 7 doesn't apply, that's not graded QA. That's truncated QA.
8 MR. CARROLL: Well, it's QA or it's -- l 9 MEMBER BARTON: It's graded down to zero. ,
I 10 CHAIRMAN APOSTOLAKIS: I think if you single 11 out the QA reg guide and hold it' back, I think there is a 12 clear message there. And in terms of change in the 13 culture, that message perhaus would be very useful to send n
O 14 at this point because judging from what you guys said, 15 these people need a message.
16 MR. ABBOTT: I'd go along with holding it i
17 back.
18 CHAIRMAN APOSTOLAKIS: Dana?
)
19 MEMBER POWERS: I'm done.
i l i
20 CHAIRMAN APOSTOLAKIS: So you'll say a few j 1
21 words on this or more than a few?
l i l
22 How about -- well, I agree with everything 23 I've heard. How about me, guys? Don't leave. Don't 24 leave. How about the performance part? Do we want to
(.
( ) 25 urge the staff to place more emphasis in the next round?
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703 1 MR. CARROLL: Well, I think we should indicate 3 2 we understand why the emphasis isn't there. And, yes, i
~'
3 they probably --
4 MEMBER KRESS: On a personal note, I like it 5 the way it is. I wish they'd just keep the performance 6 part out of it. That's my personal bias.
7 MEMBER POWERS: My feeling is I guess I have 8 not been so concerned about the performance because 9 certainly some of the concepts that were advanced in the 10 graded QA area, where they were saying, " Gee, let's look 11 and see if we cannot use monitoring activities and 12 correction processes to backstop our potential errors 13 here."
( ~\
w/ 14 It looked like they were moving toward 15 performance very nicely in an area where ultimately you 16 have to because your PRA does not quantitatively and 17 explicitly deal with this subject.
18 So I thought the performance was quite good 19 there. In several other areas, I thought enough 20 performance had been factored in for me to see what they 21 were doing.
22 MEMBER SEALE: I think we're going to get 23 enough shots at this performance side later on. I'm not 24 sure we want to delude our message at this point by
( ,) 25 talking about the performance side of it. l NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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704 1 CHAIRMAN APOSTOLAKIS: Well, at least say that f , 2 we'll wait until we see what they do with the other l lV )
3 project and --
l l
l l
4 MEMBER SEALE: Perhaps, yes. Sure. Indicate 5 interest but not --
6 CHAIRMAN APOSTOLAKIS: Yes, yes.
7 MEMBER SEALE: -- any commitment.
8 CHAIRMAN APOSTOLAKIS: Anything else from the 9 members? There's one other negative --
10 MEMBER FONTANA: Our cab's at 6:00. But, 11 other than that -- 6:00 o' clock we leave.
12 MEMBER KRESS: You've got ten more minutes.
13 CHAIRMAN APOSTOLAKIS: I think in terms of
,r
'd 14 reorganizing and consolidating and so on, I think adding a 15 few figures in 1061 will help.
16 MEMBER KRESS: I think, in particular, a 17 diagram of the LERF and CDF.
18 CHAIRMAN APOSTOLAKIS: Okay. So is this it?
l 19 MR. KING: What do you want on March 6th for ;
I 20 our hour and a half? I 1
l l 21 CHAIRMAN APOSTOLAKIS: The introduction that l l l
22 you guys are going to put together.
l 23 MR. KING: Okay. Do you want to go through j l
24 that? We're going to try and get you a revised version i 1
() 25 hopefully by this time next week. What it will have is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS N23 RHODE ISLAND AVE., N W.
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705 1 the revised introduction, the things we talked about maybe ey 2 relocating up front on qualitative indicators and so forth
- v}
3 that you would use, clarifying words on less than 4 full-scope PRA, some of the more general things that --
5 MEMBER SEALE: You had the whole Committee 6 here. So you don't have to reflog any horses.
I
's CHAIRMAN APOSTOLAKIS: yes. Maybe you should j 8 address some of the comments on the negative side.
9 MR. JONES: Yes. I was going to say that I'm 10 glad you liked my implementation plan, but hopefully it l 11 isn't cast in too much concrete. I think that is the i 1
12 general outline of where we're going to go.
13 I'd like to be able to certainly think about
,/_%.
- 14 that and present that, maybe with a little more thought at 15 the full Committee meeting, on where we're going.
16 CHAIRMAN APOSTOLAKIS: Sure.
17 MR. JONES: I think the graded QA comments 18 that we've heard, I mean, we've got to go back and think 19 about those. I don't know what we may want to do, but I l 20 think we may very well want to talk to you as a full 21 Committee on that.
22 There's AOT on the tech specs. We have an IOU j 23 on that one. I think that's controversial enough that 24 you'll probably want to hear that discussed, not so much n
(_) 25 the LT but the o, the incremental CDF, and then just NEAL R. GROSS j COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND $E., N W.
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706 1 generally how we modify the documents. That's kind of 2 what I saw as a reasonable basis for the agenda next week.
7.-
~
3 MEMBER SEALE: Okay.
4 CHAIRMAN APOSTOLAKIS: Yes. Dr. Miller would 5 like to say a few things.
6 MEMBER MILLER: This is on a totally different 7 subject. This is on digital I&c.
8 MR. CARROLL: Gary, do you want to wrap up on 9 this?
10 MR. HOLAHAN: Oh, yes, say thank you.
11 MEMBER MILLER: I just want to before you all 12 leave make a comment that each of you has a memo from me 13 on the -- because we have to write a letter on the f3 l t
\si 14 National Academy report. So what I've done is provided.my 15 viewpoint on the issues that we should be directing our 16 attention to.
17 I did that with some hesitation because I 18 don't want that to give you tunnel vision. Certainly look 19 at other issues that you believe we should pay attention 20 to as well as the ones I did, but I thought it would be 21 useful to at least give you some guidance.
22 Each one of you is assigned a separate section 23 within that National Academy study report. But certainly 24 we expect you to look at all of the sections.
g 25 I'm anxious to have your feedback on the
()
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707 1 introduction but, more importantly, the conclusion and how
,-. 2 you believe it all matches up with the rest of the report.
( ) !
'~'
3 MEMBER SEALE: All comments on the human 4 performance section will be appreciated, too.
l 5 MEMBER MILLER: Yes. I have not gone through 6 that one myself in any due care, but I will be between now l 1
7 and March 7th. .
8 CHAIRMAN APOSTOLAKIS: Okay. This meeting is 9 now closed. I 10 (Whereupon, the foregoing matter was concluded 1
11 at 5:56 p.m.) I 1
12 l l
1 13 g3 i j h
'a' 14 i
)
15 16 17 18 19 20 21 22 23 24
) 25 v
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l 1
I l
CERTIFICATE 4
This is to certify that the attached i
proceedings before the United States Nuclear 4
Regulatory Commission in the matter of:
Name of Proceeding: ACRS SUBCOMMITTEE ON PROBABILISTIC ;
RISK ASSESSMENT l
j Docket Number: N/A .
Place of Proceeding: ROCKVILLE, MARYLAND were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear f Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, _ and that the transcript is a true and accurate record of the foregoing proceedings.
ImlxlD bot D01RBETT RINER Official Reporter Neal R. Gross and Co., Inc.
v NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RIIODE ISLAND AVENUE, NW (202)234-4433 WASHINGTON, D.C. 20005 (202)2344433
o o o 9 GRADED QUALITY ASSURANCE REGULATORY GUIDE PRESENTATION TO THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (PRA SUBCOMMITTEE)
FEBRUARY 21,1997 Robert Gramm, NRR 415-1010 Roy Woods, RES 415-6622 Stephen Dinsmore, NRR 415-8482
O O O 'l GRADED QUALITY ASSERANCE (GQA) e PRIOR ACRS BRIEFINGS l e BACKGROUND OF GQA - SECY 95-059
- Process to identify SSC safety significance
- Application of QA controls based on safety function and ;
i significance l
- Effective root cause and corrective action program
- Operational feedback to assess QA controls and safety significance e DEVELOPMENT OF REGULATORY GUIDE t 1
7._-_
i
, i ELEMENT 1: DEFINE THE QA CHANGES e IDENTIFY REGULATORY COMMITMENTS e IDENTIFY CANDIDATE SSCs FOR GRADED QA
- IDENTIFY EXPECTED REVISIONS TO QA PROGRAM e EVALUATE RISK STUDY APPLICABILITY 2
O O O ELEMENT 2: ENGINEERING EVALUATION CATEGORIZE SSC SAFETY SIGNIFICANCE e IDENTIFY SYSTEM FUNCTIONS Define all operating and accident functions performed by systems e CATEGORIZE SAFETY SIGNIFICANCE OF SYSTEM FUNCTIONS Safety significance classification, guided by PRA importance measures Safety significance classification, guided by qualitative considerations l
- IDENTIFY SSCs THAT SUPPORT HIGH-SAFETY-SIGNIFICANT FUNCTIONS Complete list of all system components whose successful operation (passive and/or active) is needed for performance of system level function e CATEGORIZE SAFETY-SIGNIFICANCE OF SSCs Guiding principle: SSC operating modes (open, remain open, etc) required to support high-safety-significant system functions are also high-safety-significant 3
ELEMENT 2: ENGINEERING EVALUATI TN CONFORMANCE WITH SAFETY PRINCIPLES i
e DEFENSE-IN-DEPTH IS MAINTAINED e SAFETY MARGINS ARE MAINTAINED e INDIVIDUAL PLANT RISK DOES NOT EXCEED CHANGE GUIDELINES
- ONLY SMALL INCREASES IN PLANT RISK 1
! e INTEGRATED ASSESSMENT
- 4 I
ij
O O O ELEMENT 3: DEVELOP IMPLEMElNTATION AND MOMTORING STRATEGIES j e GRADING OF QA ACTIVITIES i
e OPERATIONAL FEEDBACK
- Operating Experience
- Plant Modifications
- Component Failure Monitoring
- PRA Updates Based on New Information i i
j e CORRECTIVE ACTIONS
O O O '
ELEME3T 4: DOCUMENTATION i
i e SCOPE OF SYSTEMS FOR GQA e FINAL CHARACTERIZATION OF SSC SAFETY SIGNIFICANCE e PLANT OPERATING EXPERIENCE .
e ENGINEERING EVALUATION '
- DEVELOPMENT OF GQA PROGRAM 6
i
O O O RECENT REVISIONS TO GUIDE e BASED ON INTER-OFFICE REVIEW e AMPLIFIED NEED FOR REGULATORY QA CONTROLS FOR NSR EQUIPMENT FOUND SAFETY SIGNIFICANT
)
e APPLICATION OF QA CONTROLS TO MONITORING PROCESS l
- INCLUSION OF ADDITIONAL MATERIAL IN QA PROGRAM
- Assumptions on SSC functional performance capabilities which l support GQA change i
- Programmatic activities associated with GQA process and performance monitoring aspects 7
a
O O O ,
VOLOTEER ACTIVITY e STAFF INTERACTIONS WITH 3 VOLUNTEER PLANTS
- Palo Verde
- South Texas
- Grand Gulf i
i e SPECTRUM OF INTERACTIONS
- Meetings
- Site Visits
- Review Of QA Program Change
- Observation Of Expert Panels
- Review Of Implementing Practices And Procedures !
- Review Of PRA e INTERACTIONS WITH NEI .
i 8 l l
t 6
O O O PALO VERDE QA ASPECTS e LICENSEE CURRENTLY PURSUING APPLICATION OF '
GRADED PROCUREMENT CONTROLS 1 e STAFF VISITS TO SITE ON SEVERAL OCCASIONS i
- Expanded Application of Commercial Grade Item Dedication
- Vacuum relief valve, HVAC damper blade seal, radiation detector circuit board, capacitors e REQUEST FOR QA INFORMATION ISSUED 12/4/95
- Procedural guidance
- Feedback Loop i
- Confirmation Of Manufacturing Practices
- Verification Of Critical Characteristics
- LICENSEE RESPONSE ON 9/12/96
- Modified Procurement Practices i
9 !
I
~
- LICENSEE SUBMITTED QA PROGRAM CHANGE ON 3/28/96
- Proposed 3 Tier Implementation Of Quality Program: Full, Targeted, Basic
- Proposed QA Controls For Safety-Related SSCs To Meet Appendix B In Alternate Manner e STAFF REQUEST FOR INFORMATION ISSUED ON 8/16/96
- STAFF OBSERVED CONDUCT OF WORKING GROUP AND EXPERT PANEL MEETINGS ON-SITE e LICENSEE RE-SUBMITTAL OF QAP RECEIVED 1/97
- Staff Review Underway 10
! A
O O O GRAND GLLF QA ASPECTS e LICENSEE QA CHANGE SUBMITTED ON 4/5/95 e LICENSEE ISSUED SAFETY-SIGNIFICANCE DETERMINATION PROCESS DESCRIPTION ON 10/11/95
- STAFF ISSUED CONCERNS ON QA COMMITMENT CONTROL ON 5/29/96 e STAFF CAUTIONED LICENSEE ON SCOPE OF CHANGES CONTEMPLATED UNDER 50.59 e SITE VISIT ON 11/21/96 1
- Reviewed Implementation Procedures And Reviewed Procurement
- Activities For Sample Components
- Examined Controls Imposed on NSR High-Safety Significant Items
- Service Water Valve, Fire Pump Diesel Throttle Cable
' t' 11
~
i O O O i i
CURRENT STAFF UNDERSTANDING OF VOLUNTEER PLANT SAFETY SIGNIFICANCE CATEGORIZATION IDENTIFY SYSTEM FUN ~CTIONS i
STP Defines and categorizes every system function (critical /non- !
critical)
! i GG Categorizes systems, does not appear to derme system function. l PV Categorizes systems, does not appear to derme system function !
3 12 if
. . .. . _ . -- , . - - . . - - . . - . _ ~ _ _ - - . . . . . . - . - ~ ~ - - - . - . - . . . - .
O O O CURRENT STAIT UNDERSTANDING OF VOLUNTEER PLANT SAFE'n' SIGNIFICANCE CATEGORIZATION CATEGORIZE SAFETY SIGMFICANCE OF SYSTEM FUNCTIONS
- guided by PRA importance measures STP Emphasizes basic event importance for quantified items supported by linked level 2, external events PRA, and a variety of sensitivity studies GG Surrogate basic event categorization, eg highest system basic event category determines system category PV Apparently surrogate basic event categorization, eg highest
- s. ystem basic event category determines system category 13 t
1;
O O O c m sstsrAr,usos srAsolsG orvetusres ,tisz SAFETY SIGNIFICANCE CATEGO IZATION j
i CATEGORIZE SAFETY SIGlVIFICANCE OF SYSTEM FUNCTIONS
- guided by qualitative considerations (eg no importance measures)
STP All system functions are assigned as critical or non-critical
- assignment considered during component categorization GG System level deterministic review to find systems
- used in non-quantified risk study (IPEEE, shutdown)
- used for containment integrity and LERF
- to check minimum success path requirements are met
- excluded from PRA due to inherent reliability
- required to support operator actions ,
4 PV Insufficient Information 14
.i
O O O :
CURRENT STAFF UNDERSTANDING OF VOLUNTEER PLANT SAFETY SIGNIFICANCE CATEGORIZATION IDENTIFY SSCs THAT SUPPORT HIGH-SAFETY-SIGMFICANT FUN'CTIONS i i
i STP Comprehensive cross-reference between system and component functions GG Initially, all components in high-safety-significant system are high PV Insufficient information 15 i i
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CURRENT STAFF UNDERSTANDING OF VOLUNTEER PLANT i SAFETY SIGNIFICANCE CATEGORIZATION CATEGORIZE SSCS' SAFETY-SIGlMFICANCE STP PRA Modelled SSCs
- Working group assignment of grading factors to Maintenance Rule deterministic factors
- final judgement made with consideration of SSC's total " score" and deterministic factors
- not modelled in the PRA,
- not needed to perform a risk significant (shutdown, IPEEE) function, and '
- not needed to support "High" PRA Operator action.
PV Insufficient Information 1
16
O O O CURRCNT STAFF UNDERSTANDING OF VOLUNTEER PLANT SAFETY SIGNIFICANCE CATEGORIZATION DEFENSE IN DEPTH / SAFETY MARGIN CONSIDERATIONS Initial response of pilots is that aggregate CDF and LERF sensitivity calculations are not useful, unanticipated and unacceptable trends will be picked up by periodic plant specine reliability data up-dates.
Grand Gulf minimum success path requirement for critical safety functions.
fission product barriers explicitly placed in High ,
Palo Verde
- Only QA programmatic changes
- Programmatic activities of high-safety-significant SSCs are not decreased 17.
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Risk Informed, Performance Based (RIPB) Regulation:
A Pilot Plant Per.spective ,
o m a r v n r:~s w an.. vm C. R. (Rick} Grantom South Texas Project i
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PRESENTED TO THE ACRS PRA/IPE .
SLBCOMMITTEE February 21,1997 -
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- PILOT PLANT BACKGROLXD e Over 14 years of monitoring and participating in risk informed programs and activities e SER issued on Level 1 PSA and approved for use to amend Technical Specifications e Early RIPB applications were approved but required extensive review and approval periods (1993 Tech Spec Study ~4 years) e STP maintains an on-going investment in risk informed technology
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O O PILOT PLANT PERSPECTIVE
_ _ . _ _ _ ~ . . _
e RIPB programs maintained and improved a Facilitated by Comprehensive Risk Management Program o STP recognizes that RIPB applications i improve both safety levels and costs u STP has 5 RIPB applications either submitted, waiting to be submitted, or in progress m Additional RIPB applications are scheduled
- Schedule revised to reflect management's anticipation of ability to achieve implementation
_ _ . _ _ _ _ _ _ _ ._ - - - - _ - -- - _ _ _ _ ____J
u PILOT PLANT PERSPECTIVE o Status of current STP RIPB activities:
a Graded QA
- Responses to RAls submitted, revised OQAP submitted
- Overall progress has been slow,
- Some concerns can only be addressed after GQA is implemented (e.g., QA levels vs. reliability)
- Planned implementation June 1997 a Risk Informed IST
- STP is prepared to submit awaiting approval of pilot applications :
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PILOT PLANT PERSPECTIVE
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a Technical Specifications
- 1993 Comprehensive Tech Spec evaluation
- 199614-day DG Tech Spec change approved, incorporates Configuration Risk Management program
- Currently, ITS submitted, presently addressing comments, uses similar risk informed method as DG submittal
- Future Tech Specs should include both deterministic and risk informed formats to account for integrated effects u Risk Informed Evaluation of Appendix J
PILOT PLANT PERSPECTIVE e Risk Informed Evaluation of MOVs a Draft RIPB approach is being finalized. STP's RIPB approach would be used to adjust testing frequencies and to also recommend appropriate ,
test strategy.
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PILOT PLANT PERSPECTIVE e Status of cmrent RIPB applications both at STP and at other stations indicates several i areas of concern a Approval process for implementation appears to be ,
redefined for each application
- Lessons leamed from one implemented RIPB application does not translate to the next RIPB application.
- Limitations on scoping are imposed for each RIPB application without assessing risk impacts
PILOT PLANT PERSPECTIVE
. z m Approval process has a clear beginning but not a clear ending
- GQA pilot activities going on two years ,
- Risk Based IST has been ongoing for 1-1/2 years u Opportunities to identify lessons learned and good practices are not being pursued with pilot plants 9
even for an interim trial basis period i F
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1 PILOT PLANT PERSPECTIVE eg ww.ygmuyr w+v4 - sw .-, et~ J',,q .'.n ,; , t; a Recently approved RIPB applications have emphasized deterministic criteria and de-emphasized risk information.
a Regulations and requirements that are marginal to safety or adverse to safety under certain conditions must be adhered to.
a Rule changes and exemptions are monumental efforts and are not effective options
PILOT PLANT PERSPECTIVE
. . ~ . - . -
o Performance based aspects seem to be more emphasized and risk informed aspects seem to be less emphasized.
o Pitfalls exist when performance information is used in isolation when corresponding risk
> information is available. ;
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CONCLUSIONS e Expect to see schedule extensions and potential delays e Costs versus expected return uncertain l
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__m_____.________ __________ _ . ___ _ . _______ _ _ ___ _
....-.---.---_---._._..-.-.------.-.__--.-----_..y O O O-
! \ United States i,
) Nuclear Regulatory Commission l
PRESENTATION TO ACRS ,
SLBCOMMITTEE ON PRA GENERAL DISCUSSION i FEBRUARY 21,1997 l
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Gary Holahan, NRR (415-2884)
Thomas King, RES (415-5790)
Robert Jones, NRR (415-2198)
Mark Cunningham, RES (415-6189) l
O O O- .
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GENERAL DISCUSSION
! e SPECIFIC TOPICS FOR DISCUSSION:
GUIDELINES ON'USE OF DEFENSE-IN-DEPTH HOW TO MAINTAIN SUFFICIENT SAFETY MARGIN CDF AND LERF TREATMENT OF TEMPORARY CHANGES IN RISK PEER REVIEW / EXPERT PANEL e PLAN AND ISSUES FOR DISCUSSION WITH FULL COBOGITTEE ON MARCH 7, 1997 1
O O O- .
DEFENSE-IN-DEPTH ELEMENTS OF DEFENSE-IN-DEPTH:
- A REASONABLE BALANCE AMONG PREVENTION OF CORE j DAMAGE, PREVENTION OF CONTAINMENT FAILURE, AND CONSEQUENCE MITIGATION IS PRESERVED
- OVER-RELIANCE ON PROGRAMMATIC ACTIVITIES TO COMPENSATE FOR WEAKNESSES IN PLANT DESIGN IS AVOIDED
- SYSTEM REDUNDANCY, INDEPENDENCE, AND DIVERSITY ARE MAIMTAINED COMMENSURATE WITH THE EXPECTED FREQUENCY AND CONSEQUENCES OF CHALLENGES TO THE SYSTEM (E.G., ;
NO RISK OUTLIERS)
- DEFENSES AGAINST POTENTIAL COMMON CAUSE FAILURES ARE MAINTAINED AND THE POTENTIAL FOR INTRODUCTION OF NEW ;
COMMON CAUSE FAILURE MECHANISMS IS ASSESSED
- INDEPENDENCE OF BARRIERS IS NOT DEGRADED
- DEFENSES AGAINST HUMAN ERRORS ARE MAINTAINED 2
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O O O .
DEFENSE-IN-DEPTH (CONT)
GUIDELINES FOR APPLICATION OF DEFENSE-IN-DEPTH PRINCIPLE:
- RELY ON TRADITIONAL ENGINEERING JUDGMENT FOR AREAS OF LARGE UNCERTAINTY OR AREAS NOT COVERED BY RISK .
ANALYSIS i
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O O O-SAFETY MARGINS GUIDELINES FOR MAINTAINING SUFFECIENT SAFETY MARGINS:
- CODES AND STANDARDS OR ALTERNATIVES APPROVED FOR USE BY THE NRC ARE MET
- SAFETY ANALYSIS ACCEPTANCE CRITERIA IN THE CURRENT LICENSING BASIS (E.G., FSAR, SUPPORTING ANALYSES)
ARE MET, OR PROPOSED REVISIONS PROVIDE SUFFICIENT MARGIN TO ACCOUNT FOR ANALYSIS AND DATA UNCERTAINTY MARGINS CAN BE MEASURED BY TRADITIONAL ENGINEERING ANALYSIS AND CRITERIA RESULTS FROM RISK ASSESSMENT AND ITS ASSOCIATED UNCERTAINTY ANALYSIS CAN PROVIDE USEFUL INFORMATION TO AID IN DECISION MAKING 4
O O O .
CDF GUIDELINES e A VALUE OF 10-d/RY IS RECOMMENDED AS A BENCHMARK CDF GUIDELINE, ALONG WITH A REGION OF INCREA GEMENT ATTENTION WHEN CDF IS IN THE RANGE OF 10 QED- 10-MANp/RY BASED UPON VALUE APPROVED BY COMMISSION AS A BENCHMARK FOR ACCIDENT PREVENTION l -
CONSISTENT WITH NRCS REGULATORY ANALYSIS GUIDELINES (NUREG/BR-0058, REV. 2) 3 5
LERF GUIDELINE
BASED UPON PROVIDING REASONABLE ASSURANCE THAT SAFETY GOAL QHO'S ARE MET, WITHOUT BEING A DEFACTO NEW GOAL COQSISTENT 10 /RY LARGE WITH PREVIOUS ANALYSIS OF SUGGESTED RELEASE GUIDELINE CONSISTENT WITH COMMISSION APPROVED 10-4/RY CDF AND 0.1 CCFP SAFETY GOAL SUBSIDIARY OBJECTIVES
- SINGLE VALUE CHOSEN TO:
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ALLOW USE OF LEVEL 1 AND 2 PRA ONLY AVOID UNCERTAINTY ASSOCIATED WITH LEVEL 3 ANALYSIS BE CONSISTENT WITH PREVIOUS COMISSION DIRECTION TO ;
DE U RM AN CON ST N G IDELINES TO ALL PLANTS 6
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O O O -
TREATMENT OF TEMPORARY CHANGES IN RISK GENERAL RG/SRP PROVIDE GUIDELINES ON CHANGES IN CDF/LERF IN TERMS OF ANNUAL AVERAGE VALUE RG/SRP ON TECHNICAL SPECIFICATIONS PROVIDES ADDITIONAL GUIDELINES FOR ASSESSING ALLOWABLE OUTAGE TIMES (A0TS),
SINCE A0TS ARE BY THEIR NATURE TEMPORARY CONDITIONS.
THESE GUIDELINES ARE STATED IN TERMS OF PROBABILITY (FREQUENCY TIMES A0T) FOR THE A0T PERIOD:
8 INCREq
<5x10 KNTAL CONDITIONAL CORE DAMAGE PROBABILITY
- INCREMENTAL CONDIT i PROBABILITY <5x10-,IONAL LARGE EARLY RELEASE THESE GUIDELINES ARE APPLIED IN ADDITION TO THE GUIDELINES ON ANNUAL AVERAGE CDF/LERF CONTAINED IN THE GENERAL RG/SRP.
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AS AN EXAMPLE, THESE GUIDELINES R t (TEMPORARY) INCREMENTAL CDF OF 10gSULT IN A CONDITIONAL /RY DURIN PERIOD.
FEDERAL REGISTER NOTICE WILL SOLICIT INPUT ON WHETHER ADDITIONAL GUIDANCE ON TEMPORARY CHANGES IN CDF/LERF !
ARE DESIRABLE AND, IF SO, WHAT THOSE SHOULD BE 7
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- PEER REVIEW / EXPERT PANEL l
PEER REVIEW -
ONE ACCEPTABLE WAY FOR LICENSEES TO ENSURE QUALITY OF PRA MENTIONED IN RGS/SRPS AS AN EXAMPLE DISCUSSED IN DRAFT NUREG-1602 (APPENDIX):
- PURPOSE
=l"*" :2:^""'^" "
DOCUMENTATION EXPERT PANEL - ONE ACCEPTABLE WAY FOR LICENSEES TO IMPLEMENT INTEGRATED DECISION PROCESS MENTIONED IN GENERAL RG AS AN EXAMPLE DISCUSSED IN DRAFT GENERAL SRP (APPENDIX).
STAFF REVIEW SHOULD DETERMINE THAT:
e PANEL'S EVALUATION REPRESENTS APPROPRIATE CONSIDERATION OF PRA,
- TRADITIONAL ENGINEERING, SENSITIVITY STUDIES, OPERATIONAL EXPERIENCE, ENGINEERING JUDGMENT AND CURRENT i REGULATORY REQUIREMENTS
- PANEL MEMBERSHIP HAD APPROPRIATE COMPETENCE IN PERTINENT DISCIPLINES, EXPERIENCE AND TRAINING 8
l 19N l I
January 29, 1997 '
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( MEMORANDUM TO: Hugh L. Thompson, Jr.
Acting Executive Director for Operations FROM: John C. Hoyle, Secretary /s/ ,
SUBJECT:
STAFF REQUIREMENTS - SECY-96-249 - STAFF RESPONSE TO SRM ON SECY-96-147 REG.ARDING REDUCING NEED FOR EXEMPTIONS AND CONSISTENCY OF THE EXEMPTION PROCESS The Commission has approved retaining (1) the current criteria ,
contained in 10 CFR 50.12 for considering exemption requests from reactor licensees, and (2) the current general criteria for considering specific exemptions requested by materials licensees. l In addition, the Commission agrees that the staff's own internal process for the staff's evaluation of exemption requests is
. adequate. With regard to this internal staff review process, the i
staff should develop more explicit guidance to ensure the quality, objectivity and consistency of exemption packages.
(EDO) (SECY Suspense: 7/31/97)
The Commission is concerned, however, that the recent Commission focus on exemptions (to identify regulations that are unclear or difficult to comply with so that such regulations may be d
W corrected) may have caused a misunderstanding by the staff and affected the application of the exemption criteria, resulting in an attempt by the staff to limit or reduce the number of exemptions that the NRC considers and grants. In fact, the
, Commission has not set any particular goals or limits on the +
number of exemption requests that can be considered or granted.
The Commission believes that the staff should apply the regulatory criteria for exemptions objectively and without a
! preconceived notion that exemptions should either be limited or circumscribed or, conversely, readily available for anyone who seeks an exemption. Objective evaluation of exemption requests will ensure that inappropriate regulatory requirements will be more readily identified through the number of exemption requests that are received.
If particular regulations are unclear or difficult to comply with such that they engender an inordinate volume of exemption requests (so called " recurring exemptions"), the staff should seek promptly to modify and correct these regulations and, in the interim period before completion of the corrective rulemaking, grant those exemptions that are properly justified under the exemption criteria. In addressing the " recurring exemption" problem, the staff should expeditiously proceed with the rulemaking fixes to those regulations that have engendered recurring exemption requests. These corrective rulemaking
actions should not be delayed to incorporate " performance-based" 1.~
regulatory concepts where such concepts are not necessary to address the " recurring exemption" issue. . Candidate rulemaking activities resulting from reviews of experience with exemptions O. should continue to be noted and progress reported in the semiannual updates of the Rulemaking Activity Plan.
?
j As a general practice, the grant or denial of specific exemptions
'is purely a staff responsibility that does not involve the l Commissioners. However, the Commission reserves to itself the 3 responsibility for policy determinations that guide these staff i actions. To allow for routine Commission monitoring (for
" recurring exemption" requests), the staff should include in the
)) semiannual updates of the Rulemaking Activity Plan a listing and description of the applications for exemptions that have been received and the exemption applications that have been granted or
! denied during the period which is the. subject of the semiannual 1 update.
i i cc: Chairman Jackson
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