ML20135F139
| ML20135F139 | |
| Person / Time | |
|---|---|
| Issue date: | 03/06/1997 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-2095, NUDOCS 9703110224 | |
| Download: ML20135F139 (146) | |
Text
._ . _. _ .
- Official Transcript cf Proce2 dings l
O NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards 439th Meeting l TRO4 (ACRs)
RETURN ORIGINAL TO BJWHITE Docket Number: (not applicable) 7(s, 2s2s THANKS!
Location: Rockville, Mar' land !
O l
Date: Thursday, March 6,1997 l 31 4 970306 ACRE'Te 30w-Ref'K !
fdheJeeFnCnmitei j Work Order No.: NRC-1034 Pages 1-9/72-79/124-243 Ol.oSEb Se%I W PP'l0 5 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 2 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 - -
(202) 234-4433 [ ,n, ~l
" 88 liia2N/I, 4 sumingamian J
DISCLAIMER PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MARCH 6, 1997 The contents of this transcript of the ,
proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards on MARCH 6, 1997, as reported herein, is a record of the discussions. recorded at the meeting held on the above date.
This transcript has not been reviewed, corrected and edited and it may contain inaccuracies.
O NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RIIODEISLAND AVENUE,NW (202)234-443i WASlIINGTON,D.C. 20005 (202)234-4433 ,
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1 1 UNITED STATES OF A14 ERICA g~s 2 NUCLEAR REGULATORY COMMISSION I \
3 + ++++
4 439th MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) l 6 + ++ + +
7 THURSDAY 8 MARCH 6, 1997 9 + ++++
10 ROCKVILLE, MARYLAND 11 12 The Advisory Committee met at the Nuclear 13 Regulatory Commission, Two White Flint North, Room T2B3,
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'LJ 14 11545 Rockville Pike, at 8:30 a.m., Robert L. Seale, 15 Chairman, presiding.
16 17 COMMITTEE MEMBERS:
18 ROBERT L. SEALE CHAIRMAN 19 DANA A. POWERS VICE CHAIRMAN 20 JOHN J. BARTON MEMBER 21 MARIO H. FONTANA MEMBER 22 THOMAS S. KRESS MEMBER 23 DON W. MILLER MEMBER 24 WILLIAM J. SHACK MEMBER (h
) 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 ACRS STAFF PRESENT:
,s 2 JOHN T. LARKINS Exec. Director
(
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3 ROXANNE SUMMERS Tech. Secretary 4 SAM DURAISWAMY l l
1 5 CAROL A. HARRIS l
6 RICHARD P. SAVIO l l
7 PAUL BOEHNERT '
8 NOEL DUDLEY 9 MEDHAT M. EL- ZEFLAh"(
10 MICHAEL MARKLEY 11 AMARJIT SINGH 12 13 ACRS CONSULTANTS PRESENT:
7
','\- 14 IVAN CATTON 15 16 ALSO PRESENT:
17 SANJOY BANERJEE 18 FAROUK ELTAWILA 19 JOE KELLY 20 WAYNE HODGES 21 DON FLETCHER 22 DAVE BESSETTE 23 BRIAN MCINTYRE 24 ALAN LEVIN
,O V 25 JOCELYN MITCHELL NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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3 ALSO PRESENT: (CONT.)
1
,- 2 RICHARD J. BARRETT
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3 LOUIS ALLENBACH 4 ERNIE ROSSI 5 STEVE FLOYD 6 BOB JONES 7 GARY HOLAHAN 8 TOM KING 9 MARK CUNNINGHAM 10 SUZANNE BLACK 11 12 13
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'y 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 A-G-E-N-D-A
- 2 Acenda Item Pace
)
3 Opening Remarks 5 4 Capability of RELAP5/ MOD 3 Code to 5 Assess the AP600 Design 6 Remarks by the Subcommitte Chairman 8 7 Arthur Andersen Report, " Recommendations 8 to Improve the Senior Management 9 Meeting Process" 10 Member Barton 124 11 Presentation by Mr. Barrett 126 12 Risk-Informed, Performance-Based Regulation 13 and Related Matters I
-,rmr l Y./
14 Vice Chairman Powers 190 15 l l
16 17 i l
18 19 20 21 22 23 24 rx
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5
- 1 P-R-O-C-E-E-D-I-N-G-S l
2 (8:35 a.m.)
(p)s-3 CHAIRMAN SEALE:
Good morning. The meeting 4 will now come to order. This is the first day of the 5 439th meeting of the Advisory Committee on Reactor 6 Safeguards. During today's meeting the committee will 7 consider the following:
8 (1) The capability of RELAPS/ MOD 3 to assess 9 the AP600 design; 10 (2) Release of AP600 test data from ROSA test 11 facility; 1 12 (3) Arthur Andersen Report, " Recommendations 13 to Improve the Senior Management Meeting Process";
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/ 14 (4) Risk-informed, Performance-based 15 regulation and related matters; and ,
1 16 (5) Proposed ACRS reports.
i 17 Portions of today's meeting may be closed to i 18 discuss Westinghouse proprietary information applicable to 19 the AP600 design.
20 This meeting is being conducted in accordance 21 with the provisions of the Federal Advisory Committee Act.
22 Dr. John T. Larkins is the designated federal 23 official for the initial portion of the meeting.
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24 We have received no written comments or
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( ,/ 25 requests for time to make oral statements from members of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 the public regarding today's sessions. A transcript of ex 2 portions of the meeting is being kept, and it is requested i
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'~'/ 3 that the speakers use one of the microphones, identify 4 themselves and speak with sufficient clarity and volume so 5 that they can be readily heard.
6 I'd like to begin with a few items of current 7 interest. I would remind the members that today we will 8 have a -- oh, that's tomorrow it is -- we will have a 9 potential candidate for membership available for interview 10 by the members, and you might plan your activities for the 11 next two days accordingly.
12 You have had passed out to you a rather thick, 13 compendium of items of interest and I must say, this list p
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14 has several things on it that are I think, of particular 15 interest. We have a couple of speeches by the Chairman 16 and also a rather interesting speech on joint American-17 Russian radiation health effects researched by 18 Commissioner Dykus, that I would recommend to you.
19 The 9th Annual Regulatory Information 20 Conference is coming up shortly. The agenda for that 21 meeting is on page 30 of the handout, and I think that 22 meeting could well be of interest to several of the 23 members. I'll urge you to look at that. It is the two 24 days prior to our next meeting, the one in April.
O k ,) 25 And so it might be convenient for some of you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1??3 RHODE ISLAND AVE., N.W.
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7 1 to come in early and try to attend that meeting. I urge 73 2 you to look at the agenda and if you do have a desire to i
i
'w) 3 attend, let the staff know at your earliest convenience.
4 Last year Dr. Kress and I attended and I can 5 say without reservation, that it proved to be an 6 interesting and informative meeting and I think there's 7 every chance that this one will be as well.
8 There's several other things here that are of 9 interest, including some discussions on violations and one ;
10 thing and another that you might find interesting as well. I l
11 We have seven letters as well as a few bones 12 of contention to knaw on at this meeting, and so I will 13 ask everyone to -- not necessarily restrict your
'- 14 comments -- but let's try to stay on the subject as we go 15 along, and maybe we can get through with those before i
16 Sunday morning sometime.
17 I have a very sad task of informing you --
18 those of you who knew hita will be sad to hear that Carson 19 Mark, a former member of this committee, passed away last 20 Sunday. He had been ill for a few months and I really 21 don't have many more details than that. But he died at 22 his home in Los Alamos. I'm sure we all remember Carson 23 with a great deal of humor and fondness.
24 Is there anything I missed, John?
h(_,f 25 DR. LARKINS: No. George -- as I think NEAL R. GROSS COURT REPORTERS AND TRANSCR!BERS 1323 RHODE ist.AND AVE., N.W.
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8 1 everybody knows -- George is out of the country and will I
,s 2 be in tomorrow. )
() 3 CHAIRMAN SEALE: That's true. George 4 Apostolakis' father is quite ill, and we don't know 1
5 exactly when George will be back here. Our attendants 6 this morning includes Dr. Catton as a consultant, and 7 later in this meeting I understand we'll have, among 8 others, Dr. Hal Lewis will be with us as well.
9 Without further ado, I guess we should go 10 ahead and get started with the meeting, and the first item 11 is the capability of the RELAP MOD 5 code to assess the 12 AP600 design, and Dr. Kress is the Chairman of that 13 subcommittee. Tom?
7 (m) 14 MEMBER KRESS: Thank you, Chairman Seale. Our 15 thermal-hydraulic subcommittee met in Los Angeles on 16 February 12th and 14th. The purpose of the meeting was 17 basically to complete our reviews of the scope and 18 adequacy of the approach the staff has taken to 19 demonstrate how adequate RELAP5/ MOD 3 code is in analyzing 20 the behavior of AP600.
21 At the meeting we had myself, Mario Fontana, 22 Bob Seale, Ivan Catton, and the consultant was Virgil 23 Shrock. We heard about the two scaling analyses that were i
1 24 sponsored in the Research staff. I personally thought ry
( ) 25 these were excellent pieces of work, very good.
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i 9 l 1 With respect to the code, we found that the
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2 code did have some weaknesses in it but that these were ;
I )
3 not significant with respect to its ability to deal with 4 the AP600 ECCS systems. It seems that AP600 has a very 5 robust design with respect to the ECCS, and essentially 6 under all the DBA conditions the core stays covered and 7 cool.
8 Today, Research plans to make abbreviated 9 presentations of what we had at the heart of the meeting.
10 We'll hear about the scaling methodology -- one of the i 11 scaling methodologies -- code data and sufficiency. l l
12 That's about all I have to say. Ivan, do you l
13 want to add anything to this?
7'~n.t 1 U/ 14 DR. CATTON: I don't think so.
15 MEMBER KRESS: Okay. I guess with that we'll 16 turn it over to the staff. Farouk --
17 CHAIRMAN SEALE: Do we want to close the 18 meeting?
19 MEMBER KRESS: Yes.
20 CHAIRMAN SEALE: Okay. The meeting will now 21 be closed and those of you who shouldn't be here are asked 22 to leave.
23 (Whereupon, at 8:44 a.m. the meeting went !
24 immediately into closed session.)
( ) 25
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72 1 MR. ELTAWILA: Yes, I rushed Professor
,-- 2 Banerjee because I was looking at the amount of time I
~
3 allotted for the presentation and Paul indicated to me 4 that he allotted time for discussion, so if you have any 5 questions for --
6 DR. CATTON: Well, you always have to keep 7 Professor Banerjee well in hand.
8 MR. ELTAWILA: I was worried about that, yes.
9 (laughter.)
10 MR. BOEHNERT: Tom, I can offer a suggestion.
11 We do have a copy of the draft letter available, if you 12 want to distribute it, we can discuss it. The other 13 option was to move ahead with the next presentation, A) i k/ 14 however, I think there's a couple of principals that are 15 not here. They didn't know we were this far ahead. One 16 is the OGC counsel who I think wants to be here and I 17 don't see Brian McIntyre either.
18 Bryan stepped out.
l 19 DR. CATTON: Paul, I'd like to kind of make a l
20 couple of comments to sort of end this. l l
l 21 MR. BOEHNERT: Certainly. )
22 DR. CATTON: I think the scaling study has 1
23 been, the results are exceptionally good and that the l
l 24 staff should be complimented for having gotten them done.
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73 1 and also Dr. Wulff from Brookhaven and you don't have the
, s, 2 report from the Brookhaven study yet and I'm not sure all
( )
'~'
3 of you have seen the report that Banerjee was associated l 4 with.
5 I think both studies are very good and what is 6 really sort of closes it as far as I was concerned was the 7 fact that the two arrived at the same conclusion and sort 8 of inwardly, I think, Wulff would have liked to have 9 showed everybody else in the world and he showed that the 10 other study was correct. That really goes a long way in 11 my mind. He's a very careful kind of guy.
12 The use of Lne code for AP600, I think as long 13 as you're sticking to design basis accidents and you are
- I
\_ ' 14 willing to accept that the code is going to give 15 conservative predictions, it certainly is adequate or I 16 would even use the word " reasonable."
l 17 But if you go beyond design basis accidenta l
I 18 where you want to know what the true behavior is for some 19 reason, for example, development of the simulator that 20 would go along with the AP600, you have to take a lot l l
I 21 closer look. If things like some detail of the behavior l 22 of the IRWST or some other aspect are of importance you 23 have to take a better look.
l 24 I think what this really leads to is the
( ,) 25 follow on work which is why I tried to pursue it just a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 little bit. It's important to realize that a thermal 2 hydraulic code is what simulates the circulatory system of 7s L' ~ '
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3 a nuclear power station and it's a complex composite of 4 models ranging from highly empirical to first principle.
5 You can't focus either on the numerics nor totally on the i 1
6 phenomological sites. Somehow you have to marry the two, l
i 7 yet be sure that the results that you're getting still ]
l 8 represent the real world in some kind of a meaningful way.
9 This is one of the reasons that I've been 10 harping for years about the sort of heart and soul of 11 these computer codes which in many aspects has been 12 ignored. What I'm hoping the new effort in consolidation 13 will lead to is paying more attention to these things.
k) - 14 For example, we don't know what the interfacial area is.
15 As a result, we don't know how to calculate the heat 16 transfer other than through some sort of empirical way.
17 That empiricism then gets built into the code. Now 18 there's surface areas associated with friction between the 19 phases as well as heat transfer. They should be 20 consistent. I don't know that they are.
21 These kinds of things have to be addressed.
22 Somebody needs to be doing the basic work that's going to 23 lead to these things. If you back up and figure well, I'm 24 going to derive the set of equations that I know are exact
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() 25 and use them, you can't solve tne damn things. And I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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75 1 think there are lots of examples of that. People like
,s 2 Delhay at Grenoble. He's given up. And if you look in
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3 the literature, you'll find papers by him that the 4 equations run for two or three pages.
5 It may be of interest at some academic level, 6 but this s a regulatory agency. You have to have a code 7 that's going to predict the behavior of your nuclear power 8 station and you have to know that it's going to do it 9 reliably.
10 I'm very excited about the possibilities that 11 are in front of us. And I have a concern that the 12 capability that today exists in RES which is composed of 13 four or five people, may be lost and I think that it would
(_) 14 good if the ACRS would comment on that and inform the 15 Commission that somehow you need to build in something to 16 what they're doing that is going to keep the interest of 17 the competent people and 1 think that's enough from me. I 18 MEMBER KRESS: We kind of thought the l
l 19 consolidated code effort, some ways fit that category. I 20 DR. CATTON: You see, just consolidating a 21 code, well -- if what you're going to do is consolidate a 22 code and that's all, you don't need people who understand l
l 23 or feel the physics of the processes. 1
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l 24 Now, if you're going to try to change it to I
/~T t, ) 25 improve models or to do things to it --
l
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76 1 MEMBER KRESS: I think --
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~.st 2 DR. CATTON: That is where you're going to t )
3 need people who have some kind of love for the field. I'm 4 not so concerned about code consolidation. 1 Lhink you 5 can find people anywhere who will do that for you. That 6 takes a person whose focus is the code. He needs to put 7 it together, make sure that it produces the same thing it 8 produced before.
9 MEMBER KRESS: I've heard though, we heard 10 that they were going to look at the model.
11 DR. CATTON: Yes.
12 MEMBER KRESS: To see where they were 13 deficient.
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\_/ 14 DR. CATTON: How well are they going to be 15 supported by the Commission? Is the Commission behind 16 this? I think the coinmission should be and I would like 17 to see the ACRS tell the Commission that.
18 MEMBER KRESS: That's what we told them in our 19 letter.
20 DR. CATTON: Well, maybe we need to tell them 21 again and again and again.
22 MEMBER KRESS: Okay.
l 23 CHAIRMAN SEALE: Your point is well taken.
24 DR. CATTON: Thank you.
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t ! 25 MR. ELTAWILA: Can I make one comment, Mr.
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77 1 Chairman?
- 7. x 2 MEMBER KRESS: Certainly.
'~~'
3 MR. ELTAWILA: Professor Catton, you're 4 correct about design basis action, but what's important 5 I'd like to mention is the AP600 as you correctly 6 indicated is a very robust system and you don't really 7 uncover the core unless you have a lot of failure that 8 goes in the 10 to 20 minus -- so a lot of the ROSA tests 9 and APEX tests that we have run are what you consider in 10 the class beyond design basis X and you take more than one 11 failure. And the codes still can predict the behavior in 12 these experiments. It's only when you have a drastic 13 change almost failing everything above the hot leg, that
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t- 14 you might challenge the code in this case.
15 DR. CATTON: Yes, but you see if the reason 16 that you're not challenging the code is because the AP600 17 is robust, well, that's nice and I'm sure Westinghouse is 18 extremely happy. But I'm a little unsettled because I 19 would like you have made that statement based on the heart 20 and soul of the code, not' the AP600 and that's what I'm 21 referring to.
22 MR. ELTAWILA: And that's what's going to be a 23 part of the future --
24 DR. CATTON: The future.
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( ,/ 25 MR. ELTAWILA: But we want to have the tool NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I 1323 RHODE ISLAND AVE., N.W.
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I 78 i 1 right now to be able to do confirmatory analysis. i
, 2 DR. CATTON: And you do and I think that this, 6
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3 I'm not sure, but I assume that this committee will 4 probably agree with that view but there's a whole other 5 spectrum.
6 We had somebody stand up in front of us here, I
7 I don't know, last meeting or a few meetings ago and when 1
1 8 he was asked how do you determine the fidelity of the l
9 simulators and he says well, I compare with RELAP 5, that ,
l 10 made me a little bit upset because the code and you've 11 shown it, is okay if what you want to do is to show that l 1
12 the system will survive, but it has nothing to do with l l
13 what the observer will see.
i ) 1 A/ 14 I think that if the code is to be used for l 15 those sort of things and I think it should, then it must 16 meet a different standard and it's that standard, I think, l
17 that I would like to see you pursue. l 18 I'm preaching and I'll shut up.
19 (laughter.)
20 MEMBER KRESS: That's all right. Are there 21 any other comments or questions from members?
22 I don't think we're prepared at this point, 23 Paul, to discuss our letter yet. So I don't think that's 24 a good option, co what I suggest we do now at this point
(~N
( ,) 25 is take a break. And --
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79 1 CHAIRMAN SEALE: We will, can we make an l
l gs 2 attempt to get the principals here. I i
i.)) 3 MR. BOEHNERT: We are trying to do that.
1 l
4 CHAIRMAN SEALE: Well, why don't we plan to 5 start at a quarter of 11. I 6 MEMBER KRESS: Quarter of 11, okay.
7 (Whereupon, the proceedings went off the 1 8 record at 10:27 a.m. and resumed at 10:50 a.m. ,
9 in closed session.) l 10 11 12 '
13
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14 15 16 17 18 19 20 21 22 23 24
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124 1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N
-. 2 (1:34 p.m.)
)
3 CHAIRMAN SEALE: It's 1:30 and the witching 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, I guess, is here. We're going to receive a 5 presentation from the staff on the Arthur Anderson study.
6 John Barton is the chairman of the subcommittee. So John, 7 do you want to introduce our speaker?
8 MEMBER BARTON: Yes; thank you, Mr. Chairman.
9 The purpose of this session this afternoon is 10 to hear a briefing by and hold discussions with 11 representatives of the staff regarding the Arthur Anderson 12 report titled Recommendations to Improve the Senior 13 Management Meeting Process.
\/ - 14 The report was prepared in response to the 15 staff requirements memo dated June 28, 1996 which directed
'a the staff to continue to evaluate the development of 17 indicators that can provide a basis for judging whether a 18 plant should be placed on or be deleted from the NRC's 19 watch list.
20 During the latest senior management meeting 21 with the Commission on January 29th, the Commission and 22 staff discussed the process used to derive the current 23 watch list. The staff requirements memo resulting from 24 this meeting was issued February 14th of this year.
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() 25 The Commission encouraged the staff to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W. l (202) 234-4433 WASHINGTON, D.C. 20006-3701 (202) 234-4433 I
l 125 1 continue its review of the process, use the evaluation of 7s 2 plant performance, specifically the senior management
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3 meeting process.
4 As part of this review, the staff was tasked 5 with conducting a detailed peer review of the Arthur 6 Anderson methodology and address whether that methodology 7 is more appropriate at the screening meetings or at the 8 senior management meetings themselves.
9 There has been a meeting with the Commission 10 and the staff since the January meeting. There was one on 11 February 18th concerning the Arthur Anderson report and a 12 meeting with the staff and representatives from the 13 Nuclear Energy Institute on February 25th.
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14 The staff has received comments for i
15 consideration from both these meetings. The staff !
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16 currently plans to issue a Commission paper on March 31st l 1
I 17 containing a plan for incorporating recommendations from j i
18 the report. ;
k 19 Today's briefing is for information so that 20 the committee can decide what action, if any, it wants to 21 take prior to the staff report to the Commission. Maybe 22 this is something we can discuss with the staff at the 23 conclusion of their presentation.
24 Making the presentation for the staff this
,a i, j 25 afternoon is Richard Barrett, Chief Emergency Response NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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126 l
1 Branch, AEOD.
,- , 2 MR. BARRETT: Thank you very much. Good l
l 3 afternoon, everyone. What we're going to talk about this l
4 afternoon is the senior management meeting which is one of i
5 the most important processes that the NRC has in terms of 6 its oversight of safe operation of nuclear power plants.
7 We're going to be discussing some issues that 8 have been raised in the recent past by the Commission.
9 We're going to tell you a little bit about some recent 10 activity that we have in place to try to improve the 11 process and some activities that are going to be going on 12 over the next 12 to 18 months.
13 And as a result of this briefing, we would g
(_/ 14 like to encourage the ACRS to get involved in this issue 15 because we feel that it's an issue that could very much 16 profit from some input from the ACRS, and it's an area 17 that I think the ACRS has not been heavily involved with 18 in the past.
19 I'm going to -- this afternoon I'm going to 20 briefly describe the senior management meeting process for 21 those of you who have not been following it ;ver the years 22 or perhaps have not been active in it. And then I'd like 23 to talk about what the recent issues are that.have been 24 raised by the Commission, issues that caused us to put in 7
(a) 25 place a comprehensive study involving Arthur Anderson NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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f 127 1 Consulting.
7s 2 I want to talk to you a little bit about the -
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3 - a lot actually about the Arthur Anderson study, about 4 the methodology they used, and about their findings; their 5 findings about their assessment of the outcomes cf past 6 senior management meetings, and their findings and 7 recommendations regarding the information that is used in 8 the senior management meeting, and about the process that 9 is used for conducting the senior management me ting.
l 10 I'd also like to talk about the ef forts -- in 1 11 broad terms about the efforts that the staff plans to take l
12 to put into place to implement the Arthur Anderson l 13 recommendations over the next year to year and a half. I r~% 1
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s_- 14 And as I said before, I'd like to suggest that the ACRS 15 put in place an ad hoc subcommittee to follow those 16 efforts.
17 The senior management meeting is about ten 18 years old now. It was put in place primarily as an 19 outgrowth of an event that happened in June of 1985 at 20 Davis-Besse plant. It was a loss of feedwater event.
21 And when the staff went back and looked at 22 that event and started trying to look at the root causes 23 that caused that event to become so serious, what we 24 realized was that there were various parts of the staff
( ,
j 25 that had information about the performance of the Davis-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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128 1 Besse plant, negative information.
73 2 And yet, there didn't seem to be any process
(") 3 to make sure that all that information could get to the 4 people who could make regulatory decisions and turn that 5 kind of p3rformance around; namely, the regions and NRR.
6 So as a result of that finding, it was decided 7 to have a meeting of all the principal offices that had 8 information about performance and that had regulatory 9 responsibility over the plants and have a discussion so 10 that all this information could be shared and a consensus 11 could be built about the performance of the various 12 plants.
13 And by doing that, we could identify the 7m e )
\> 14 plants that were getting into performance trouble and 15 begin to apply resources to reverse those trends. So it's 16 a process that is repeated on a six month cycle. The 17 process involves basically a lot of steps. In fact, it's 18 a continuous process almost.
19 The one cycle ends, and the next cycle begins 20 almost immediately. But the principal steps in the 21 process are, first of all, a screening meeting is held 22 between NRR principally and each of the four regions. And 23 at that screening meeting, all of the plants pretty much 24 are discussed.
,m
(_) 25 And based on that, decisions are made about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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129 1 which plants having sufficiently bad performance problems
,- 2 to be discussed at the actual senior management meeting,
( )
3 and these are called discussion plants.
4 Then more information is developed between 5 those screening meetings and the senior management meeting 6 itself, which is typically held -- is rotated around the 7 regional offices. And then at the senior management 8 meeting itself, all of the office directors and all of the 9 regional administrators meet together and discuss those 10 discussion plants and make decisions regarding what we 11 would refer to as formal actions.
12 And formal actions could mean that a plant 13 could get a trending letter indicating that performance is 7~3
'\ /1
. beginning to slip and is of concern to the NRC. Or , a 15 plant could be designated as a Category 2 plant, which is 16 a plant that requires close NRC monitoring, a plant that l
17 will be getting more inspection and more attention from 1 18 NRC management.
19 This is the Category 2 plants -- t; jically are l l
20 referred to as the watch list plants. Or a Category 3 l
)
21 plant, which is a plant that is shut down and requires NRC 22 approval to begin operation again, So these are the l l
l 23 formal actions that are taken as a result of the senior 24 management meeting.
()
/~N 25 There are other types of actions that might I
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, 1
130 1 come out of the meeting of a more informal nature that
, . , 2 might require follow up by the Executive Director for
( ~' )
3 Operation, the Director of NRR, or the regions.
4 The Commission, in the past year and a half, 5 has raised some questions about the conduct of the senior 6 management meeting. There has been a fair bit of 7 discussion at the briefings which are held following the 8 senior management meeting, the briefings for the 9 Commission, to inform the Commission of what decisions 10 have been made about the -- primarily about the 11 objectivity of the process and the consistency of the l 12 process from region to region, plant to plant.
13 And as a result of those discussions, there l
.e's
)
(_/ 14 was a staff requirements memorandum issued in June of 15 1996. And it asked the staff to evaluate the development 1 16 of indicators that can provide an objective basis for 17 judging whether a plant should be placed on the list or ;
1 18 removed from the list. So the SRM, the staff requirements I 19 memorandum, really dealt with the question of the 20 information base for the senior management meeting.
21 Now we contracted with Arthur Anderson 21 Consulting. And shortly after they came on board and 23 , began to become familiar with the process and the issues 24 that are involved with the senior management meeting, they e
(mv) 25 came back to us and recommended that, in addition to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 examining the information base, they really ought to 7 ~3 2 examine the process itself because they were beginning to b 3 see issues related to the process that were important to 4 the outcomes.
5 And so we concurred with that, modified the 6 contract, and the study actually dealt with both 7 information issues and process issues. The study was 8 completed in December 30th of this year with analytical 9 support from the Idaho National Engineering Laboratory.
10 And the other thing I'd like to point out is 11 that the NRC appointed a senior advisory panel consisting 12 of Deputy Executive Director for Operations, one of the 13 regional administrators, the Acting Director of NRR, and f-14 the director of Research, and the Director of AEOD to 15 provide input at key points throughout the study -- input 16 to Arthur Anderson.
17 The input was primarily to assure the factual 18 accuracy of the report. It was not to try to steer their 19 conclusi'ons or findings or recommendations of the report.
20 And I'm quite confident that the report itself really 21 represents an independent view on the part of Arthur 22 Anderson.
23 I'd like to point out a couple of the key 24 participants in this study. Sitting at the table over
( ,/ 25 here, we have Louis Allenbach who is a senior manager, one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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i 132 l 1 of the people in charge of the Arthur Anderson study. We l
fx 2 have Catherine Kelly back here in the audience and Aaron j l 1 l i /
'~'
3 Lieberman. )
4 They are three of actually nine people that 5 Arthur Anderson assigned to this task. The overall effort 6 was led by a partner of Arthur Anderson Consulting. The j 7 staff participants in overseeing this effort were 8 primarily Tom Wolf, who is in the audience today; and Mark 9 Padovan, who is also in the audience; both of AEOD.
10 The Arthur Anderson methodology was very 11 comprehensive. And first of all, they went back and 12 examined the written record of the senior management 13 meeting process from 1992 to 1996. That meant they
\/ 14 examined all of the briefing books that were supplied to 15 senior managers prior to the senior management meeting in 16 depth.
17 They examined the minutes of the meetings
, 18 after they were published. And they also examined the 19 transcripts of the briefings that senior management gave 20 to the Commission after each of these senior management 21 meetings. And in doing this examination, they developed a 22 data base.
i i
23 And the data base chronicles the 24 characteristics and measures and indicators that the staff f~s
( ,) 25 and the management used in making their decisions; at l NEAL R. GROSS
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133 1 least those that appeared in the written record. And g 2 these -- this data base actually has 1,700 records that LJ 3 can tell us now what were the principal concerns that our 4 senior managers had in making these decisions.
5 That was the first major portion of tra 1
6 issue -- of the study, and it was quite an extensive piece
)
7 of work, i
8 Secondly, they interviewed senior managers who )
9 have participated in the senior management meeting -- l 10 headquarter senior managers, regional senior managers.
l 1
11 Something on the order of 20 senior managers. They also j l
12 interviewed resident inspectors and their direct ;
p_
13 supervisors in the regions. ,
1 14 And finally, they interviewed five senior 15 utility executives at the Vice President-Nuclear level at i I
16 the utilities. Now the questions they asked of these i 1
17 various groups were different and the purpose of 18 interviewing them were different.
l 19 The purpose of interviewing our senior 20 managers was to get their views as to what are primarily 21 the most important factors that are used in the decisions. !
l 22 Secondly, what are the roles of the various decisions i j
23 makers -- various participants in the senior management !
l 24 meeting.
f (3) , 25 What are their impressions about the senior i i
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I
l 134 1
1 management meeting process and improvements that might be l 1
2 made there? And finally, we asked them what do they think (7- ) '
~~'
3 about the outcomes. Do they feel there were any plants 4 that have been missed?
5 The purpose of interviewing the regional 6 inspectors, the resident inspectors and their managers, 7 was for Arthur Anderson to get a sense of where the basic 8 information comes from and how it's manipulated, how it's 9 analyzed and brought to bear in the senior management 10 meeting process, because much of this information 11 basically goes back to the inspection process.
12 And the purpose of talking to utility 13 executives was to -- especially corporate; these were 7
\._s 14 corporate utility executives -- was to find out whether 15 and how they use performance indicators in their remote 16 locations to assess the plants that they oversee, both 17 from a safety and from an economic performance 18 perspective. And that was also quite interesting.
19 Arthur Anderson conducted analytical studies 20 to examine the various indicators -- candidate indicators 21 that might be of use as objective indicators of 22 performance. A lot of this work was performed at the 23 Idaho National Engineering Laboratory.
l 24 We're not going to go into detail today about g -)
( ,) 25 any of these analytical studies because of the limitation NEAL R. GROSS j COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N.W.
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135 1 in time, but I believe that we will have -- I hope we will
. 2 have several follow on briefings of the ACRS as we get
-) 3 into the staff's implementation. And I think we'll have 4 ample opportunity to get into questions related to 5 correlations of indicators and things of that nature.
6 Arthur Anderson developed performance trend 7 charts with candidate action criteria. We'll get into 8 these and show you one of these things and how this 9 demonstrates not how the staff should do it or which 10 indicators we should use, but demonstrates that it can be 11 done using information that's already available to the 12 NRC.
13 They also developed an integrated performance
,n +
(_,) 14 model which we will also talk about in some detail later 15 on which gives us an overview of how an objective set of 16 information can be used in an integrated way for 17 performance assessment.
18 And finally, they developed a process map for 19 the entire senior management meeting process which takes 20 the process all the way from the very basic data, which is 21 the inspection findings and the event reports and the 22 allegations and any other basic information that comes in, 23 all the way up through the various processes that analyze l
24 those data such as the SALP process, the enforcement t j 25 process, the PPR process (plant review process), and other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE lSLAND AVE., N.W.
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e-136 1 processes, and finally becomes part of the senior
-, 2 management meeting decision process.
1
\ '/
3 We're not going to talk about that process map 4 today because of time limitations, but it is in an 5 appendix to the report.
6 Arthur Anderson made some findings regarding 7 the outcomes of past senior management meetings. First of 8 all, they concluded that the current process identifies 9 most of the poor performing plants for discussion. That 10 is to say that the screening meetings are doing a good job 11 of finding which plants are of sufficient concern to 12 warrant discussion at the senior management meeting.
13 In addition, most of the senior managers we I !
V 14 interviewed, as well as the utility managers we 15 interviewed, generally agreed that the plants that have 16 actually made it onto the so-called watch list, the plants 17 that have been designated as Category 2 and Category 3 18 plants, were appropriately placed there.
19 In other words, we have not placed plants on 20 the list which really did not deserve to be on the list.
21 On the negative side, however, they 22 concluded -- Arthur Anderson concluded that the senior 23 management meeting has sometimes been slow to take formal 24 actions and that the outcomes of the senior management
(
p) v 25 meetings have not been consistent.
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l 137 1 Now what does that -- what's the basis for
.s 2 those statements? Well, really three things, and it goes
( I
\~~'j 3 back to the methodology they used. When Arthur Anderson 4 examined the written record of the senior management 5 meeting, they came to some certain conclusions about the 6 depth of the performance problems that were being 7 described for given plants and the durations of those 8 problems.
9 And based on those perceptions, they came to 10 conclusions about which plants they felt warranted 11 inclusion on the watch list.
12 Secondly, in the interview process, there were 13 several instances in which our senior managers said in
)
k/ 14 retrospect that there were plants that, now that they look 15 back on the record of what has happened since those senior i 16 management meetings occurred two, three, four five years l 17 ago, there are definitely plants that should have been 1
18 placed on the list that were not placed on the list at 19 that time.
20 And thirdly, when Arthur Anderson developed 21 the performance trend plots which we will see later on in 22 the project, again some of these same plants showed up as 23 having very high levels of indication that formal action 24 might have been taken.
f
(%) 25 So the bottom line was that the -- again, they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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138 1 concluded that the senior management meeting was sometimes 2 slow to take actions and that the results of the senior 3 management meeting had been inconsistent.
4 Now they looked at, as I mentioned, two 5 possible areas where problems with the senior management 6 meeting might have developed. One is the information 7 base; and the other, as I pointed out earlier, were 8 process issues. So let me spend a little bit of time 9 talking about some of the findings and recommendations 10 they made regarding the information base for the senior i 11 management meeting. I 12 On the positive side, they noted that the NRC 13 has a lot of very relevant data and other information i
'V 14 related to plant performance. There's no need for the NRC 15 to go out and develop new types of information. We 16 collect all kinds of information.
17 And while it might not appear in the report, 18 they've said to me on many occasions that compared with 19 other organizations they've assessed, the NRC is rich in 20 the information base for making the kind of decisions we 21 need to make.
22 VICE CHAIRMAN POWERS: Did they suggest it was l 23 excessive?
24 MR. BARRETT: They didn't say it was
/
) 25 excessive. What they said was that not all of it -- that
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139 1 you could probably make the decisions without using all of
,, 2 it; that you could probably sample to make tbs decisions.
/ s
('~' )
3 You may interpret that as meaning it's excessive.
4 A lot of the information that is used in the 5 senior management meeting is gathered for other purposes.
6 And so while it's not all needed for the senior management 7 meeting, they didn't make a judgement as to whether it's 8 needed for other purposes.
9 MEMBER MILLER: Dana, would you expect anybody 10 to say they had too much data?
11 VICE CHAIRMAN POWERS: Well, I expect the 12 industry to say that you're taking too much data from --
13 asking them to collect too much data.
(_ 2 14 MR. BARRETT: You know, it's interesting. One 15 of the participants -- in fact, Mr. Allenbach -- has 16 industrial experience and actually had some experience 17 with a former employer of his where he went through a 18 process of taking the information that corporate required 19 of their own plants and winnowed that down to the so-20 called critical few.
21 And maybe, Louis, if you could just take one 22 second and talk about the results of that, I think it's a 23 good place for your comment.
I l 24 MR. ALLENBACH: I had the privilege of working i
.gx q ) 25 for Scott Paper Company when Al Dunlop came in and decided 1
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140 1 to downsize Scott.
p_ 2 VICE CHAIRMAN POWERS: I'll bet you started i
( )
~' 3 working real hard, huh?
4 MR. ALLENBACH: And one of the interesting 5 learnings there was, with the downsizing of two-thirds of 6 our salaried employees, we needed to figure out how to get i
7 smarter with fewer people. And one of the organization 8 challenges that I was involved in leading was what is the ;
1 9 information we really need to manage the place.
10 And we ended up shedding 80-85% of what I l
11 would call data - there's a difference to me between data 12 and information -- so that we really only generated those 13 things that were absolutely critical to make decisions.
p
(,/ 14 And in fact, we shed much of the data generation processes ;
l 15 just because we didn't have the resources to do it; and it 16 fundamentally improved the way we did business.
17 I think that's what you were speaking to,
'. 18 Rich.
l 19 MR. BARRETT: Yes, it was. Thank you, Louis.
l 20 VICE CHAIRMAN POWERS: Well, it was certainly l 21 a famous and effective turn around effort.
l 22 MR. BARRETT: Okay, also on the positive side, 23 they concluded that the characteristics that we looked 24 to -- that we look at are indeed related to safety and n
(%J ) 25 risk. Okay, now we had as part of our effort, on the l
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l t
141 1 NRC's part, we developed for them a very, very simple risk
,s- 2 based model of how various types of performance data might
)
x /
3 relate to risk.
4 And as I said, it's a very simple model. It's 5 actually embodied in the report as Appendix 1. And the 6 characteristics and measures and indicators that they saw 7 when they examined the written record were very congruent 8 with the types of things we were showing them.
9 Now this is a very qualitative result. But 10 nevertheless, the point is that we were looking at 11 information -- or the senior managers in past decisions 12 have been looking at information that is directly relevant 13 to safety and specifically to risk.
(~\
wl 14 Now on the negative side, they concluded that 15 NRC assessments tend to focuu on the root causes of events 16 and other problems. In other words, what we're doing is 17 quite frequently we're finding a large event, a serious 18 event, or a serious licensing problem, and focusing on 19 that; and then using that ar a way of revealing the 20 fundamental problems of performance that a plant has or a 21 licensee has.
I i
22 And while there's nothing wrong with that per 23 se, that is a process that tends to identify problems late 24 in the process after they've become -- after they have :
7N.
() 25 conspired to produce a very bad result. j NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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142 1 And so the recommendation is that we need to
,3 2 find ways of assessing management effectiveness -- or
' }
3 actually, I would prefer to say organizational 4 effectiveness -- but management effectiveness and 5 operations effectiveness on an ongoing basis so that we 6 can reveal these problems early on in a time'., fashion 7 such that they can be reversed -- more easily reversed.
8 MEMBER MILLER: Can I ask a question about the 9 first bullet? You said considered. Does that imply that 10 the decisions were made primarily on those issues rather 11 than safety and risk, or they just considered them?
12 MR. BARRETT: What we did was --
13 MEMBER MILLER: In fact, it's only the second f )
\_ ' 14 bullet. I'm now wondering if they were de-focused from 15 safety and risk by those other problems.
16 MR. BARRETT: There was a -- well, let me say 17 this. When they say considered, what it means is that 18 people told us that these were important considerations.
l 19 Okay, so it wasn't just they looked at them. These were l 20 things that our own senior managers said were major j 21 factors in their decision making.
22 MEMBER MILLER: Did the industry agree with 23 that? l 24 MR. BARRETT: Well, the industry does not have
,e3
(_,)
25 access to that -- to the information that was -- in fact, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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143 1 that information is kept pre-decisional, and the industry
,x 2 doesn't have access to it. The only information they have
('~')
3 access to is, of course, the public information that's 4 made public afterwards, including the transcript of the 5 meeting.
6 So the things that are cited in that meeting 7 with the Commission, they have access to those.
8 Now what I'm going to get into later on is 9 that you'll see some of the problems with the way in which 10 the information is used. Okay, so while we're looking in 11 the right areas, we may not be looking at that information 12 in the right ways, and that will be some of the other 13 findings that we come to.
,7
! )
N/ 14 Okay, secondly, information for making 15 performance assessments remains inconsistent. Okay, now 16 what that means is that in looking at the data and looking 1
i 17 at the information, what we find is that from -- it varies ;
i 18 from plant to plant which information is important and l l
19 which information -- and even from region to region, you 20 might say, or from plant to plant -- which information is i
21 brought forward and is said to be important in the 22 decision.
23 For instance, let's just take SALP scores.
24 SALP scores are a piece of information that's used in the
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144 1 importance. In other places, the SALP score was not given
,_ 2 a great deal or importance.
\ '}
3 And in other places, a decision was made in 4 spite of the fact that the SALP score might have said 5 something else. So the information base for a particular 6 decision was inconsistent.
7 And Arthur Anderson recommends reengineering 8 the assessment information to better support the senior 9 management meeting. And I'm going to talk a little bit 10 about that later on -- how that reengineering might take 11 place.
12 MEMBER MILLER: Just a comment on those three 13 bullets. It seems for some reason, they disturb me, those p\s/ 14 three bullets. They don't tell me the same message or 15 give me fair -- sufficiently mixed message. I'm not 16 certain I have confidence in the process.
i 17 MR. BARRETT: Right, right. It is a mixed 18 message. l l
19 MEMBER MILLER: You're saying in one way they 20 do consider safety and risk. The second bullet says they 21 may be focusing on non-relevant issues. And the third 22 bullet says the information's fairly mixed up and you 23 don't know what they're considering.
24 MR. ROSSI: Well, I'm not sure the cecond
/m
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145 1 information. I think the root causes of events and
,.s 2 problems are clearly related to safety. I think what
~ l
[
~' )
3 they're really saying is that there may be other things 1
)
l 4 that we ought to be looking at before we get to the kind 5 of problems that we have to look at in events.
6 MEMBER MILLER: Okay.
7 MR. ROSSI: So it's a matter of looking at a 8 number of thingu. But clearly, the first two bullets I 9 think are both safety and risk significant.
10 MEMBER BARTON: Don, I think also the second 11 bullet alludes to discussion in the report that says --
12 that doesn't criticize that statement, but it does say 13 that you're looking -- after events have occurred, it's w/ 14 nice to know what the root cause is, but you're not 15 looking in predicting --
16 MEMBER MILLER: Well, I got -- in reading the 17 report, I definitely got the view that the process was 18 flawed in the sense they were not anticipating.
19 MEMBER BARTON: Right.
20 MR. BARRETT: Right.
21 MEMBER MILLER: But I also got the view that 22 the process was flawed because it was dominated by certain s
23 parts of the management team versus other parts. And then 24 I got the conclusion was that the process was okay, except
,m (x ) 25 it wasn't executed correctly.
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146 1 That's kind of my summary of the report. l 1
s 2 MR. BARRETT: Yeah, that's -- I think that is I ,
a good summary.
3 4 MEMBER MILLER: I'm looking for these things 5 as we go through.
6 MR. BARRETT: Yeah, I think that is a good 7 summary of the report. And I also have to agree with your 8 earlier statement. I would say that maybe not these two 9 bullets per se, but we have -- but as we go on and talk 10 about some of the other findings related to information, 11 the picture you get is that there's good information 12 available and that the senior managers are talking about 13 interesting and important information, but that the i r %,
kl - 14 information is not structured properly to make a good 15 decision.
16 And that also there's other information that's 17 being brought into play that maybe is having too much 18 weight and is too subjective.
19 MEMBER MILLER: Or you go back to Dana's 20 question. Maybe there's too much information to begin 21 with, and you just weren't using the right information.
22 MR. BARRETT: Yeah, I'm not sure that that's l
! 23 the problem. I think we are using the right information.
24 We're talking about management issues. I mean, we're
( ,) 25 saying here -- they're saying we need to have an ongoing i
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l
147 1 effort to look at management and operational
- 2 effectiveness. l
(/~
3 There's a lot of discussion of management and l l
4 organizational factors. There's a lot of discussion of l
5 operational effectiveness. It's just that the way in 6 which the information in brought together needs to be more l
7 consistent, more objective, and more structured. And j 8 we'll see later on how all that comes together.
l l
9 MR. ALLENBACH: Excuse me, Rich. l l
1 10 To your question, I think part of the '
11 potential inconsistency -- and I agree with your 1
12 observation -- is there's a fundamen'.al difference between 13 saying that the characteristics were considered and that
,/-
[ t !
' k/ -
14 those things were used in an orderly disciplined fashion l 15 to arrive at consistent conclusions.
16 That's a fundamental -- that's not what's said i 17 there.
18 MEMBER MILLER: Yeah, the word considered is 19 probably in the eyes of the beholder how much you 20 considered and how much you weighted it.
21 MR. BARRETT: But you know, if you look at the 22 written record, you'll find -- you can count up the number 23 of times a particular factor came in. And the factors 24 that rice to the top are important factors to risk and
(-
(_,) 25 safety. And if you ask the senior managers what were the i NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS
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148 1 most important factors they had in mind, you get a similar q 2 picture.
1
( /
3 So it's more than just considered. But then l
4 again, let me talk about some of the other problems, !
1 5 because they come along the lines of what you're saying.
6 They say that the decision making process is highly l l
7 subjective and that the process minimally values objective 8 indicators.
l 9 Now what does this mean? Primarily, when they l 10 say that the process is highly subjective, what they're l 11 saying is that they found a lot of indication that the 12 processes were driven by facters which were subjective in 13 the sense that one person could see a factor this way and n
!k '} 14 another person could see a factor that way.
15 Okay, I think the primary examples of 16 subjective factors were consideration of reorganizations 17 within a utility as being a very positive factor. Arthur 18 Anderson considered that to be a very subjective judgement 19 and that the NRC may not be able to tell whether a 20 reorganization is going to be -- really have a positive 21 effect, a negative effect, or no effect whatsoever.
22 The other example that comes up many, many 23 times in the documentation and in the interviews was a 24 utility putting into place a get well plan or performance
/~
( ,%) 25 improvement plan. The NRC -- that can be a very positive NEAL R. GROSS l
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149 1 thing if it's followed through and the resources are 7~ 2 applied and everyone gets on board and the staff at the
( '/
'~
3 plant implement it.
)
4 But the plan, in and of itself, no matter how 5 good it looks, the NRC is not in a position -- it's a 6 subjective judgement to say that this plan is positive, is 7 a good reason for not putting a plant on the watch list.
8 So that's what they're referring to in terms of highly 1
9 subjective judgements. l l
10 VICE CHAIRMAN POWERS: Rich, when you think l
11 about the mix of people that are on the senior management l 12 committee, is it not likely that what appears to be l
13 subjective is simply a viewpoint that a step is taken by a
,/-
\J 14 plant and somebody in charge of inspection thinks it's a 15 very good idea; somebody in charge off enforcement or some 16 other aspect of it is less sanguine about it simply ,
17 related to their operational -- the impact it has on their 18 part of the operations?
19 MR. BARRETT: Right, yeah; that's true. We'll {
20 see later that the meeting does tend to be dominated or 1 21 has tended to be dominated by the regional administrator, I
22 which has an effect on which information is more important j 23 than others. !
24 MEMBER MILLER: See, I think that's the flaw l r~T !
25 in the process, Dana, that the consensus process was i (s-) l NEAL R. GROSS !
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150 1 flawed and they somehow -- as Rich points out, the
/
,_.s s
2 regional manager tended to dominate the consensus process.
3 And that would then slant the manager. They're going to 4 look at certain things versus, say, somebody else in a 5 different part of the organization.
6 That's my view of what's going on here.
4 7 VICE CHAIRMAN POWERS: It's clear that the 8 wisdom or lack of wisdom of having the regional 9 administrator being dominant in the meeting is an area 10 where honest men can disagree.
11 MR. BARRETT: Let's get back to that because 12 we're going to talk about process issues in just a little 13 while.
5 J A_,/ 14 But the second half of that sentence, the 15 process minimally values objective indicators, really l
16 points to the fact that over the past ten years, we have 17 had performance indicators available that the NRC develops 18 on an ongoing basis. And the finding was that in general, 19 these were not a very important part of the decision 20 making process.
21 So the recommendation here is that the meeting 22 shift from subjective to objective factors. And of 23 course, that was the original question asked by the 24 Commission. And we'll talk a little more later about e
(n)
L 25 objective factors.
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151 1 Another finding was that the mass of
,x 2 unprioritized information tends to inundate the senior N 'l 3 managers. The amount of information --
4 VICE CHAIRMAN POWERS: Nobody on this 5 committee has any sympathy for that.
6 (Laughter.)
7 MR. BARRETT: I rest my case.
8 The amount of information that is developed 9 for the screening meetings is voluminous. And in 10 addition, after the screening meetings, there is another 11 large document that's developed for the briefing of the 12 senior managers. And in addition to that, a great deal of 13 information is presented by the regional administrator in I h
\2 14 the context of both of these meetings.
15 And the complaint from some of the senior 16 managers was -- that we interviewed -- was that it just l ', was like a blizzard of information, or it was like a 18 constant drumbeat of problems, and that it was difficult 19 to sort out the bigger picture from all of the mass of 20 information.
21 CHAIRMAN SEALE: Drinking from a fire hose.
22 MR. BARRETT: There you go; right.
! 23 So one of the recommendations is that to 24 restrict the format and volume of information to make the ry
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152 1 and help in digesting it.
,s 2 Continuing on with recommendations regarding i i
~'
3 the information base, this is a little different from some 4 of the other recommendations. Now this has to do with the i 5 fact that the NRC still uses a great deal of manual effort 6 to assimilate performance and information.
7 And Arthur Anderson would like to see us put ;
8 -- continue to put emphasis on automation of information 9 within the agency and to develop systems that can allow 10 information to be made available throughout the agency 11 that can minimize the amount of manual effort that's 12 required to take inspection findings and turn them into
~
13 enforcement information or turn them into PPR reports or I
\~/ 14 to SALP reports, or to input to the senior management 15 meeting or plant issues lists.
16 And also -- but to make the information 17 directly available to everyone. So everyone in the agency 18 who wants to study that information can have electronic 19 access to it in a way that's keyword searchable. And this 20 is an effort that the agency is putting some effort into.
21 And I don't plan to go into it in any detail today, but 22 this is something Arthur Anderson feels would really help.
23 By making more information available 24 throughout the agency, it might take away soma of this (3
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153 1 participation on the part of others.
,w 2 VICE CRAIRMAN POWERS: Rich, you're --
- i L.)
3 CHAIRMAN SEALE: Go ahead.
4 VICE CHAIRMAN POWERS: You're absolutely right 5 that the NRC's been trying to do this for some time. Do 6 you personally have any feeling that NRC's lagging behind 7 other government agencies in this or is in fact quite a 8 bit out in front of other government agencies?
9 MR. BARRETT: I have no feeling for that.
10 CHAIRMAN SEALE: Some of the information that 11 you're talking about is difficult not because it's part of 12 -
flood, but because it's got all of the sex appeal of 13 that wall. I mean, it's as dry as it can be. It has no -
l t
'w #
14 - it's very difficult to get excited about it.
15 You say you're looking at things. Are you 16 looking at the kinds of things that qualify as appropriate 17 root causes and asking yourselves how you capture that 18 data in a way that gives it an enhanced profile?
19 MR. BARRETT: Well, I'm not directly involved 20 in the NRC's efforts to automate information.
21 CHAIRMAN SEALE: Okay, well; do you see what 22 I'm driving at?
23 MR. BARRETT: Yes.
24 CHAIRMAN SEALE: I mean, the ugly part needs p.
() _
25 somehow to get some life to it.
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i 154 1 MR. BARRETT: Right. The idea of getting some 7- 2 -- for instance, what are the categories you would be i )
3 interested in?
4 If I could take the six week inspection report 5 from a resident inspector at some plant and I could get 6 that written in such a way that I could look at that 7 electronically, even with keyword searching, and I could 8 begin to understand what are the root causes, as you say 9 -- are we looking at human errors? ,
i 10 What kind of human errors are we looking at? l I
11 What are the root causes of those human errors? Or are 12 those equipment failures? And I could begin to look at 1
1 13 whether there's a pattern forming for that plant or for i (y
I x_/ 14 that type of plant or across the industry.
15 That would really help others in the agency to 16 become more directly involved in this process and in other 17 processes. But I'm not in a position to speak to the 18 agency's efforts to automate.
19 CHAIRMAN SEALE: Okay.
?n MR. BARRETT: There was a briefing for the 21 Commission a couple of weeks ago in which this was alluded 22 to. I know that there is a program called AIRS, which is 23 the automated inspection reporting system, which is in the l
24 planning stage or perhaps beyond the planning stage. And
()
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1
155 1 speak to it with any authority.
,_s 2 Finally, with regard to information base,
/ \
\ /
3 Arthur Anderson pointed out something that I don't think 4 at this point is going to be surprising to anyone. And 5 that is that deregulation may be a cause of economic 6 stress in the future which may in fact in turn affect 7 performance at nuclear power plants, and that we should be 8 looking at these things.
9 Now, they're not saying that these are 10 predictors -- that these are predictors of poor 11 performance. A plant can undergo economic stress of many 12 types and come out without a performance problem. A plant 13 can undergo stress and even perhaps improve its
_, 14 performance.
15 But they're saying this is something the NRC 16 should be conn d cm.-* of but not use it within the decision 17 making prc ense; at tha senior management meeting which is 18 -- they don't feel we can make that connection strongly I
19 enough. j i
20 So we should watch it. We should be cognizant l 21 of those plants that are having economic stress. We 22 should develop indicators and watch those indicators and i 23 use those to pay more attention to plants that are I l
24 experiencing economic stress, f
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156 1 of that as an indicator? What kind of feedback did you
,- 2 get from the industry when you met with them on that 3 issue?
4 MR. BARRETT: You know, I'm afraid I was not 5 at the meeting with the industry.
6 MR. ROSSI: Well, I don't know that we got any 7 feedback as yet on that particular thing. I've been to 8 two meetings -- a couple of meetings with the industry.
9 We had a meeting with representatives of NEI where we went 10 through essentially the same material that Rich Barrett is 11 going through, and I don't know that they gave any 12 particular comments about it.
13 I think they would be concerned about how we I a
's / 14 used it and how we understood it and that kind of thing.
15 But I think what's being suggested here is that if you 16 know of economic factors that could conceivably affect the 17 safety performance of a plant, you ought to be aware that 18 they exist.
19 And then you'd look for whether there are 20 effects on the safety performance of the plant before you 21 did anything else. So that's a little hard to disagree 1
22 with, I would think.
23 MEMBER BARTON: Is there any NEI i l
l 24 representative here that would like to speak to that j
(~% l
() 25 issue?
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157 1 MR. FLOYD: Yes, Steve Floyd from NEI. ;
f3 2 At the meeting, we did point out a caution in
- I
\
'^ '/
3 using economic performance indicators. We think you have 4 to be very, very careful how you develop those and how you 5 use those.
i 6 For example, from the correlation studies that 1 1
7 we've done, we show that there is a good correlation l
l 8 between the lowest cost producers in the country and the l l
9 AEOD safety performance indicators, the WANO performance I 10 indicators, just about any other group of measures that 11 you'd want to see.
12 So if your indicator says well, let's look for 13 a guy who is spending a low amount of money and use that i
\ 2' 14 7.s an indicator that that might be a problem, that may not j 1
15 be a good indicator. Another example would be also in the i
16 terms of trending. If you're using it just to look at it ]
l 17 as a trend rather than on an absolute level, just about i
18 every plant in the country today and has been over the 19 last several years been reducing their actual O&M budgets 20 and c.apital expenditure budgets. l 21 And again, the plants that seem to have the 22 best performance are the ones that have been most 23 successful at doing that. So again, you know, I'm not 24 sure how good of a discriminator tool that's going to be O)
(, 25 when everybody seems to be doing that.
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158 1 VICE CHAIRMAN POWERS: Mr. Floyd, the studies
,3 2 you mentioned, are those publicly available?
( )
3 MR. FLOYD: No, they're not publicly available 4 yet. This is -- they could be made publicly available, 5 and we may plan to do that in the future. But it's using 6 publicly available data through the Utility Data 7 Institute. Basically the economic performance data that 8 utilities report on Form 1.
9 CHAIRMAN SEALE: Rich, it's interesting to me; 10 we heard earlier about the Scott Paper example where it 11 was in fact economic pressure, or at least the pressure l
12 that was exerted was in the form of economic stress, that l l
13 (a) resulted in a simplification of requirements and so
[,) l l
\w/' 14 forth for data, and (b) ultimately, if anything, enhanced l 15 process. l l
l 16 It would be interesting to see what would have l 17 happened to Scott Paper if they had had a regulator that 18 had told them that there were certain of those data that 19 they could not abandon and what that would have done to 20 their performance.
21 MR. ROSSI: Oh, I don't think that he's got 22 the first bullet under the deregulation may cause economic 23 stress. I think says it right. It says economic stress i
24 does not necessarily predict changes to operating y-(y) 25 performance.
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1 159 1 And in cutting costs for operating a nuclear l
l
- 2 power plant, if you do that because you manage the plant j l
'^ ') 3 better and are more efficient, it's very likely that you I
4 can both reduce cost by being more efficient and improve 5 safety be being more efficient.
6 If you just reduce cost to reduce cost and 7 save money, then it might go the other way. So I think 8 the bullet up there is intended to make that point.
9 MR. ALLENBACH: Yeah, I'd like -- while we 10 didn't get specific in the report, I don't think it was 11 our intent to say you can draw specific conclusions from 12 what you see in the trends or from what you see in the 13 reduction.
Ii
\_/ 14 I think what I would suggest is when you may 15 see a substantial change in a pattern, it would cause you 16 to want to ask the utility to help you understand what's 17 going on and why that makes sense as opposed to drawing a 18 specific conclusion.
19 MR. BARRETT: I mentioned earlier that Arthur 20 Anderson suggested that we -- made a number of suggestions 21 or recommendations regarding the way in which we develop 22 and use information. This chart, I think, is very 23 interesting. It's the Arthur Anderson integrated 24 performance model, and it's a conceptual model, n
i,
) 25 It's a conceptual model or approach as to how NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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}
160 1 we could make use of four levels of information in our
- 2 performance assessment processes starting from the right
( I 3 to the left in terms of rank and the order in which they 4 might affect -- directly affect risk and have an impact on 5 risk and on resources.
6 The idea here is that you can, and we do, look 7 at results where results might be actual safety 8 significant events or problems at the plants as an 9 indicator of performance. We can key on that. But if 10 that's the main key, what we're going to be getting is 11 we're going to be getting a very late indication of 12 performance problems.
13 And if we wait until that le. vel to diagnose a m- / 14 performance problem, then we're going to be in an area 15 that is going to have greater impact on risk. That's why 16 that is the highest of the four bars. And is going to 17 require the greatest resource allocation to reverse the 18 trend.
19 So if we're going to look at safety 20 significant issues such as safety system failures or 21 significant events or accident sequence precursor events 22 or what have you, we may be in an area where we're getting 23 in too late. According to this model, if you want to get 24 a more timely indication of a problem, then you ought to j 25 be looking at operations effectiveness.
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161 1 You ought to have a systematic, ongoing way of 1
<- 2 assessing operations effectiveness. And operations
-'~) 3 effectiveness really refers to those things that we look 4 at in the SALP process. And these are the things that go 5 on every day on the floor of a nuclear power plant:
6 operations maintenance, engineering, other plant programs.
7 We need an ongoing, systematic, structured way 8 of rating operations effectiveness at nuclear power plants 9 across the country. If you want a more timely -- even 10 more timely way of assessing an impending performance 1 11 problem, then move to the left here and look at management l
12 effectiveness -- or as I said earlier, I think a better l l
13 term is organizational effectiveness.
I 1
'v / 14 Find an objective, structured way of 15 inspecting and observing and rating real occurrences in l
16 the plant that show whether the organization is operating 17 effectively or not.
18 And then finally, you have economic stress, I
19 which we said earlier on and we've heard all the cautions; !
20 and we're all aware of the cautions associated with using i 21 economic stress. Nevertheless, keep an eye on it as a 22 possible harbinger of problems to come. .
l 23 VICE CHAIRMAN POWERS: Which one of the --
]
1 I
24 when you look at this conceptual model -- say all this
(
(,)) 25 makes great sense. Seems appealing and whatnot. And then l I
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162 1 you start walking back just as you did in your
,3 2 presentation from the high parts to the earlier time l
3 parts.
4 And you come to this organizational term, and 5 you say whoa, yeah, very desirable to know what's going on 6 in that organization. But it seems to me I've been told 7 by our human performance people that they have issued 8 contracts and they themselves have looked to see if they 9 can find any of these parameters or any features of 10 organizations that they can subsequently tie to safety in 4
11 some unequivocal, objective way and have failed miserably. )
i 12 Those are their terms, not my terms. So you i l
13 say desirable, but impracticable.
)
-/ 14 MR. BARRETT: I don't think it's impractical.
15 For instance, I think we have -- we already have one that i 16 I believe is a very, very good indicator of organizational 17 effectiveness. And that is our own process for 18 determining civil penalties within tne NRC. It's a 19 process in which -- you know, we have a process whereby we 20 have inspection findings that are violations.
21 And there's a process for deciding which ones 22 of those are escalated enforcement and which ones are not.
23 For the ones that are significant enough to be escalated 24 enforcement, we have a process we go through for deciding
/~~N
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163 1 that civil penalty will be.
fm 2 If you look at that process which involves the
! )
v 3 regional people, the program office people, our office of 4 Enforcement, and in some cases others, what they're 5 looking at is real evidence of whether or not the 6 organization is working well or how well the organization 7 is working.
8 So if you're seeing, in terms of identifying 9 its own problems or whether the NRC has to identify their 10 problems, the quality of corrective actions that they put 11 in place, the quality of root cause analysis, their 12 ability to take operational experience and feed it into 13 their operations, these all come into play in making that l C )
14 decision.
15 So if a plant ends up with a civil penalty, 16 that is an indicator -- one indicator; you wouldn't want 17 to make a decision based on that -- that there may be an 18 organizational problem. I believe that there are many 19 real things that you can go to that are indicators of the 20 organizational effectiveness.
21 And these are things like the quality of 50.59 22 reviews, the quality of the onsite review committee 23 reviews, of their ability of the organization to identify 24 problems, track those problems, find the root causes, and j)'
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l 164 1 fixed. l l
7- 2 These are real things that the inspector I
\ )
3 inspects every day. We need to find a way to put these l
4 things together into a rating of the plant in this area.
5 And I think it can be done. And I don't believe that the 6 researchers -- my sense of the researchers is not as 7 negative as yours.
8 I don't believe -- what we don't want to do is 9 get into the business of rating managers: this manager is 10 a good manager or that manager is a bad manager. Or 11 management behaviors: this plant doesn't have a j l
12 questioning attitude. That's very subjective. We want to l
13 stay away from that, but there are things that actually l r~N
(>)
i 14 happen every day we can assess.
15 Now, can we do it today? I told you we're 16 going to be spending the next year to year and a half 17 implementing this process. One of the biggest questions 18 is going to be how can we develop the assessment process 19 for these two bars here?
20 CHAIRMAN SEALE: Rich, earlier you mentioned 21 that one of the earliest criticisms of the process that 22 was made was that it seemed like there was a -- I'll use
- 23 an inflammatory word -- there was too much compassion in 24 rating some plants as opposed to other plants, and all you
,~.
() 25 did was to delay the day of reckoning for those plants.
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165 1 MR. ROSSI: Optimism might be a better word in s 2 this discussion.
( )
3 CHAIRMAN SEALE: Okay, whatever, whatever. I 4 said I wanted to be a little inflammatory.
5 Have you got a -- have you looked at the 6 trajectory of the performance of plants over time? That 7 is, how they move across this spectrum from Category 1 8 with bells and whistles, to average to two, to the 9 doghouse, and back and forth. Have you looked at that?
10 MR. BARRETT: You mean case studies?
11 CHAIRMAN SEALE: Yes.
12 MR. BARRETT: No, that was not part of it to 13 look at case studies.
f3
' )\
i 14 CHAIRMAN SEALE: No, no; but I'm saying -- you l
15 know, it strikes me that for every -- not for every. But 16 some plants staggered around and fell over the precipice l
17 into the watch list. I can't believe that there weren't 18 other plants who crawled up real close and looked over the 19 side and then managed to walk back away from -- or work 20 their way back from it.
21 It would kind of be nice to know what the 22 difference was.
23 MR. BARRETT: Yeah, you're absolutely right.
24 I don't believe that the history of any two watch list
,~
) 25 plants is quite the same.
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166 1 CHAIRMAN SEALE: Yes.
,css 2 MR. BARRETT: And many of the plants have, as
(' ')
~
3 you said -- it would be difficult to document the case j 4 where a plant walked up to the edge, saw the light, and 5 took the actions to turn things around.
6 I think what we could probably say is look at 7 the cases where the NRC thought that the licensee had seen 8 the light, had gotten a new plant in place, perhaps even 9 reorganized; and then go back and look at the history of 10 what actually happened and try to see what the differences 11 were.
12 CHAIRMAN SEALE: Yes.
13 MR. BARRETT: I haven't done that. It was not p
l 14 part of the study. I think it would be a very interesting 15 thing to do.
16 CHAIRMAN SEALE: Okay.
17 MR. BARRETT: But you're -- but there are no 18 two cases alike. When I look back at my own experience 19 with the -- watching the plants that have come onto the 20 list and come off the list, some of which have gone back 21 onto the list, there doesn't seem to be any two stories 22 that are the same.
23 MEMBER BARTON: Rich, we'll have to move along 24 if you're going to finish the rest of your slides.
n (v) 25 MR. BARRETT: Yeah, sure.
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167 1 CHAIRMAN SEALE: I'm sorry.
7y 2 MR. BARRETT: Actually, I don't plan to finish
\ ?
~
3 all the slides. Some of them are back ups.
4 Okay, there were some findings regarding, as I 5 said, both the information base and the process. Arthur 6 Anderson felt that the senior management meeting process 7 is logically sound. Information is developed at the right 8 place. It's analyzed at the right place. It's looked at 9 by the right people.
10 It's brought together in a logical way. And 11 they get -- and we get the right people to the meeting to 12 make the decisions. There's no reason to completely 13 overhaul the senior management meeting process. And s
\/ 14 that's a very positive thing, and it makes a little easier 15 for us to actually implement the recommendations.
16 On the negative side, they came to the 17 conclusion that the senior management meeting is dominated 18 by the regional administrator for a number of reasons, and 19 not surprising.
20 First of all, a lot of the processes that go 21 on to develop the information for the senior management i
1 22 meeting are regional processes. So the management style 1
23 of the regional administrator and the things that the !
l l
24 regional administrator wants to emphasize are clearly A
() 25 reflected in all of the information that comes out of the NILAL R. GROSS ,
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168 1 region for this senior management meeting, gS 2 Secondly, the senior managers of the agency i
)
3 have a tendency to defer to the greater level of knowledge 4 and firsthand experience of the regional administrator on 5 questions related to plant performance, and not 6 surprisingly.
7 And thirdly, the regional administrator is the 8 main presenter at both the screening meeting and the 9 senior management meeting. And so the regional 10 administrator has an opportunity to put a great deal of 11 evidence on the table to support whatever view he or she 12 has, and then that is difficult -- at the point where all 13 that information has been presented, it's difficult for l' )
14 any single other manager to bring information that would l l
l 15 effectively rebut that.
l 16 So the process tends to be strongly dominated 17 by the Executive Director for Operation, the Director of 18 NRR, and the regional administrator; with the regional 19 administrator being the first of those three.
20 Now is that good or bad? It's good in a way 21 becausa the regional administrator does indeed have the 22 most direct firsthand knowledge. On the other hand, the 23 process was first developed to try to bring other 24 perspectives into the meeting.
, "N
(_,) 25 So it's believed that the roles of other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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169 1 managers need to be better defined. And the 73 2 recommendation from Arthur Anderson is that we find --
i i
~
3 strike a better balance among the roles of the other 4 managers such that perspectives on operational experience 5 from AEOD could play a bigger role.
6 This is a real honest -- this is a real 7 important perspective. Perspectives on the enforcement 8 process, which I mentioned earlier -- very important to 9 perspective. Investigations -- the Office of 10 Investigations; allegations, which is a completely 11 independent source of information to the agency could play 12 a bigger role.
13 And they're recommending that we strike a i
A \
\_/ 14 better balance. And they're also recommending that we give 15 consideration to consensus decision making techniques.
16 Because while the process is described as a consensus l 17 decision making process, a lot of the participants felt 18 that the process really comes down to what the regional --
19 very much what the regional administrator thinks. I 20 Now I have to say that in the most recent l
21 senior management meeting which was held in January of 22 1997 which had the benefit of the Arthur Anderson study, 23 at least to be able to look at it, some of the feedback 26 I've gotten is that steps were taken to bring more l
,9
(,) 25 participation from the other senior managers. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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- m. _ . - _ - _ . _ . _ _ . . _ . _ . . . . - . . _ -. _ . . _ . _ . . . ~ . _ _ . _ . . _ _ _ _ _ _ _ .
7 170 4 l
'l In fact, I heard'one estimate that the. amount 2' of" discussion went up by.a factor of six in number of 4
y hours. So that's clearly a very positive sign.
3 I did not 4 attend the meeting myself.
5 okay, there are no clear criteria'for various 6 levels of NRC' actions. 'We do not have-a set of criteria
-7. that tell you when you're a trending plant, when you're a 8 Category 2 plant, when you're a Category 3 plant. This is 9 something Arthur Anderson. feels we should get, and I'll 10 talk more about criteria in a moment.
11 The presentation of information is not j 12 balanced and structured. I said -- I mentioned earlier ;
l 13 the presentation being.very strongly oriented'toward the. ;
14' presentation -- the verbal presentation by the regional "15 administrator.
I f .16 TheJidea -- or the recommendation is that we 1
17 find a way to present the information in a rigorous and
- 18. structured way so that there's more balance among the 19 various types of information that are available. And 20 going along with one of the earlier recommendations, that 21 it be a compelling visual presentation if possible.
I 22 Another rather different finding was that the l 23 stakeholders in the process do not fully understand -- or j 24 do not understand very well at all the senior management l 25' meeting process and its outcomes. The sense was that the l
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171 1 industry doesn't understand where the yardstick is or
,s 2 where the bar is that they have to go over.
. \
~
3 And this relates, of course, to the criteria.
4 But the industry doesn't understand many times why this 5 plant is on the list and why this one is not on the list.
6 And the recommendation is that we develop a better process 7 for compiling the public record of the senior management 8 meeting so at least we can communicate to the public and 9 to the industry the decisions we've made and what the 10 basis of the decisions were.
11 VICE CHAIRMAN POWERS: At the beginning of the 12 talk, you indicated that utility managers felt that watch 13 list plants were appropriately placed. Are you saying 7m t )
N/ 14 here that other categories are not understood?
15 MR. BARRETT: Well, a couple of things.
16 First of all, the -- as a utility executive, I 17 think the feeling ic that they don't know what the NRC is 18 expecting. So you know, you might be doing what you think 19 is a pretty good job; but, you know, clearly, if a plant 20 is experiencing very bad problems, everyone's going to 21 understand that.
22 And yes, the plants that went on the problem l
23 plant list, there was a consensus that they were put on 24 there properly. There was question about well, other f3
( ,) 25 plants were not put on the problem plant list, which in l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
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172 1 many people's opinions, were as bad.
,~
, 2 And there's sometimes expressed questions i'~~')
3 about whether this plant -- you know, a process in which a 4 utility knows before the senior management meeting --
5 knows based on the data that they are looking at and the 6 performance that they are looking at can almost guess that 7 they're going to go on the list would be a better process 8 because then a utility could know exactly where to put 9 their resources to turn the performance around.
10 MEMBER BARTON: And I think it's the utility 11 looking for more objective process so they can relate to 12 knowing where they stand and they feel there's a lot of 13 subjectivity in the current process. That's really, I
- i
- 14 think, the problem.
15 VICE CHAIRMAN POWERS: Well, we certainly had 16 the NEI document that says exactly that, that they wanted 17 something -- that they claim if any objective measures, 18 that the worst of plants would show up well in comparison 19 to the average plants only seven years ago.
20 MEMBER BARTON: Right.
21 MR. ALLENBACH: Excuse me.
, 22 I think there's also a discussion -- we heard 23 from the utility executives around the timing. So while 24 they may have said they believe that the ones that got on (g,/ 25 there should have been, they didn't understand -- it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N.W.
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173 1 seemed like it was quick on the trigger he. and late fy 2 there.
- )
w ./
3 There was also a rather thorough discussion 4 about removal. So it's not just getting on; it's also 5 getting off with the same concerns.
6 MR. BARRETT: Let me move on. I want to talk 7 a little bit about the trend plots which are in your 8 package and what they mean, because I think they are kind 9 of a compelling way of looking at the information.
10 The trend plots are intended to thow -- to 11 demonstrate how information that's currently available to 12 the NRC can be used in an objective way using criteria --
13 and Arthur Anderson actually did put some strawman
( )
~ s' 14 criteria up there -- to inform our performance decisions.
15 The trend plots basically track the plants --
16 we actually did these for all 109 plants; I'll just show 17 you one -- against nine indicators. We didn't do a 18 careful study to choose which nine indicators. We took 19 the seven performance indicators of the NRC and added an 20 indicator for number of allegations and an indicator.for 21 dollars of civil penalties.
l 22 Tracks those nine -- tracks the plants against i
23 those nine. We're going to talk about a " hit " A hit is 24 any instance in which the industry -- or in which the
,m
- \
( ,/ 25 plant exceeds the industry average for that indicator by a NIDAL R. GIUDSS I l
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l
1 174 1 factor of two or m _e.
,s 2 So we'll be talking about hits. We're going
)
3 to look at the plot. You'll see that each point on the 4 plot is the running sum of four quarters. So nine 5 indicators means that a very bad plant could have as many 6 as nine hits in a quarter. Since there are four quarters, 7 the highest number of hits you could have at any given 8 point would be 36 hits.
9 Okay, and then the senior management meeting 10 action criteria are based on the trends in the hits.
11 Okay, and we'll look at these in a second. According to 12 the Arthur Anderson study and recommendations, meeting an 13 action criterion would create a rebuttable preeuruption.
( ~.
sji 14 That is to say if you met the action 15 criterion, then the presumption is that you would -- that 16 that action would be taken unless compelling information 17 of an objective type could be brought to bear to say that 18 there was some.hing wrong with that result.
19 Co let's look at the charts -- the example 20 chart. This is an actual plant. And as you will see, 21 this is a plant that people would say that the NRC was
]
22 slow to take formal action. As I said, each one of these 23 points is a four quarter moving sum of hits. l i
24 Now in this particular -- the orange diamonds )
() 25 are for the plant that we're plotting. The red squares )
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i 175 1 are the industry average number of hits. Every plant has
,_ 2 some number of hits. In fact, the average, as you can
) 3 see, looking at the right-hand side there, it is somewhere 4 between four and six hits or roughly one per quarter.
5 So this particular plant, as you can see, was 6 below the industry average or at the industry average up 7 until about 1991; at which time, there was a reversal of 8 that trend. And the number of hits actually peaked at 16 9 hits. That would be an average of four hits per quarter.
10 That's a plant that's tripping'a lot of our 11 indicators -- a lot of these nine indicators. It then 12 moves along and stays at that level until about 1995; at 13 which point it comes down again. One of the issues about
-'~N I
(m/)
14 this particular set of indicators is that it's not a very l 15 good set of indicators for a plant that's not operating, a 16 plant that's shut down. !
17 And so I can't really -- this particular plant 18 was shut down toward the end of that period, so I can't 19 really say how that's affecting this graph. But in the 20 yellow -- now on the left-hand margin, you see here action 21 steps from zero through five, and they're defined up here 22 on the top.
23 Five is a plant that is or should be a 24 Category 3 plant. That is to say a plant that's shut down (n) 25 needs our approval to operate. Four is a plant that's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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176 1 Category 2 plant, a so-called watch list plant. Three 7, 2 would be a plant getting a trending letter. Two is a
/ '
\
3 plant that's a discussion plant -- no other action. And 4 one is a plant that is actually being removed from the 5 list.
6 So the yellow bars indicate what the NRC 7 actually did. So in the case of this plant, when 8 performance started getting bad, we started making this 9 plant a discussion plant. And it was a discussion plant 10 for several senior management meetings from 1991 to 1995; 11 at which time the senior management meeting in 1996 12 decided to make it a Category 2, a watch list plant.
13 Now the Arthur Anderson process sets down a n
I i
\_/ 14 number of criteria. And based on those criteria, you can 15 see the green plots which would say what the Arthur 16 Anderson criteria would call for. Now the criteria are --
17 actually, there's a number of different criteria that you 18 can trip.
1 1
19 But I'll simply say that the criteria looked 1
20 for performance problems across a number of indicators and :
l l
21 for a sustained period of time. Okay, so you can see that 22 the Arthur Anderson doesn't say you should go on the list 23 immediately. It takes a while depending on how bad the 24 performance is.
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177 l 1 Anderson would say the plant would have gone on the list l 7y 2 three years earlier due to these criteria. Now the NRC
'~ ') l 3 has not -- the staff has not evaluated these criteria.
l 4 One of the follow up actions is to look at I l
5 what are the real indicators we actually want to use; i
6 which are the magic nine or ten or twelve or fifteen or l 1
7 five, whatever, that we want to use. The nine were not --
8 we didn't give a lot of thought to which nine we chose.
9 That's not that big of a fault because Arthur 10 Anderson will tell you that there is not a magic five or l
11 ten. If you look at enough indicators, you will see 12 performance problems. Because once performance problems 13 start, they're going to start -- they're going to pervade
!m 7
\ s
l 14 the operation of the plant and t. hey're going to show up in 15 different areas.
16 The other thing we're going to have to take a I 17 very close look at are the decision criteria. These are 18 strawman criteria, but we haven't accepted those either.
19 According to these criteria, for instance, about a third 20 of the plants in the country would currently be discussion 21 plants.
22 So that -- so perhaps the bar is being set too 23 low here according to these criteria.
24 By the way, this is a plant that when we n
(j 25 interviewed senior managers, they said in retrospect this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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178 1 is probably a plant we should have put on the watch list
. ~3 2 earlier. So there is a -- going back to this consistency
( )
3 and the method.
4 Okay, let me just quickly -- let me point out 5 that there have been a number of briefings for the 6 Commission on this study -- on this study and also on i 1
7 other related issues, including in January 29th the 1
1 8 Commission was briefed on the results of the latest senior 1
9 management meeting; and there are some staff requirements i 10 m( 'oranda which have either come out or in preparation.
11 And in general, the memoranda are encouraging i l
12 of the staff to continue this work and to look into i 13 developing a staff position and staff resources to carry l
/,_x
! l
\/ 14 on this work. So let me not dwell on that. l 15 VICE CHAIRMAN POWERS: Rich, if we coIld come 16 back to this -- these trend kinds of things and the l l
17 various things that you plotted there.
18 Have you given thought yet or did Arthur 19 Anderson give thought to -- I think we're very much in the 20 business now of establishing an absolute standard of 21 safety and not looking for continuous improvement.
22 MR. BARRETT: Right.
23 VICE CHAIRMAN POWERS: The Department of 24 Energy likes to look for continuous improvement, and
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179 1 to go yet. But in the commercial nuclear industry, we've
,, s 2 set safety goals and things like that.
1 3 And even though you do that, you can set a set 4 of criteria within that context and plants will deviate 5 around in those things. And no matter how they deviate, 6 if they're meeting the safety goals, we've got no business 7 messing with them and whatnot.
8 Have you given though to that kind of -- !
9 MR. BARRETT: Yes.
10 VICE CHAIRMAN POWERS: -- that there's a --
11 this is not a continuous improvement regulatory agency?
12 MR. BARRETT: Right. Yes, we have.
,~
13 As you can see, there are actually two steps 1 s
\. ' 14 in which we compare with the industry average in this 15 particular plot. The first step is where we -- at the 16 individual indicator level to get a hit, you have to be 17 more than twice the industry average.
18 We could set that as an absolute rather than 19 the current industry average.
20 VICE CHAIRMAN POWERS: You encourage the 21 industry be beat on its best plants to get its average up. i 22 MR. BARRETT: Right, that's right. 1 23 (Laughter.)
l l
24 MEMBER MILLER: C is fail. l 25 CHAIRMAN SEALE: The problem is that the l (N /s) l NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N.W.
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180 1 leverage is getting leaner and leaner on that.
7 .s 2 MR. BARRETT: Yes. Well, let me say this l l ) l 3 though. You know, the industry averages in a lot of these 4 indicators are extremely low. And they were extremely low 5 ten years ago. For instance, in this particular model, if '
6 a plant got a significant civil penalty, then that was --
7 that would be many, many more than two times the industry 8 average because very few plants get a civil penalty in any 9 given quarter.
10 I believe that's also true of a plant 11 experiencing a scram, because the average quarterly number 12 of scrams is very low. So the data are not as biased by 13 this downward trend or this improving trend over the past q(/ 14 ten years that the industry has experienced. Not as 15 biased as you might think at first blush.
16 Nevertheless, it's an obvious question.
17 Should we try to set an absolute standard for each of 18 these indicators, and should we set an absolute standard 19 number of hits? Yes, it's a good question. And we will 20 examine that along with other questions.
21 The possibility exists also that the trend 22 plot would look completely different frcm this. It's a 23 good --
24 VICE CHAIRMAN POWERS: I think it's just very en 25 important that we not get into this continuous improvement
( )
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181 1 business.
, ~s 2 MR. BARRETT: I agree with you. That's I
v) 3 clearly the agency's position. We're not a continuous 4 improvement agency. j l
1 5 Let me just say a little bit about what l l
\
6 happens next. The staff has committed to give the ;
1 7 Commission a commission paper by March 31st on the 8 implementation of the Arthur Anderson report. And we're 9 working very hard with the other parties within the agency 10 to develop that.
11 That paper will tell which of the process 12 changes we agree with, which ones we want to implement; 13 and in general terms how. Also, we'll talk about our plan
/
\
t N/ 14 for development of the leading indicators; namely the 15 management and operations effectiveness measures and 16 criteria.
17 That commission paper is currently on track 18 for March 31st. It's a very tight deadline, but we're 19 hoping to meet it. After we've gotten Commission policy 20 guidance, which we hope will be an endorsement of our plan 21 and options, we will go forth and implement.
22 The implementation as we currently look at it 23 will involve probably a year to a year and a half of 24 technical effort on the part of the staff with the help of p)
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182 l
l 1 really does a good job of developing the information we
-s 2 need for these performance assessments.
)
3 We currently believe that that is a process 4 that should have public comment as well. During that 5 period, we would expect to come back to the ACRS at 6 regular intervals to present the overall plan, the 7 schedule; and then as things progress, begin to present 8 you the technical details of what we're developing and 9 what the basis for those are.
10 And based on that, you know, I would suggest 11 you consider putting into place some sort of a 12 subcommittee that could focus on this because my 13 understanding is that the senior management meeting has
' %- 14 not been a major focus of the ACRS in the past.
15 For the short term, there are already plans 16 for incremental implementation of some of these things for 17 the June 1997 senior management meeting which is fast upon 18 us. As I said, this process rolls back pretty quickly, 19 and we' re already cn the '.look for developing some i
20 information for late March, early April for use in that in j 4
21 a pilot basis in the June 1997 senior management meeting. l I
i 22 Hopefully we'll have more information to put I a
23 into place on a trial basis for the January 1998 meeting. j i'
24 So that's really the -- my presentation. If 7
(7) ,
25 you have any further questions, I'll be happy to answer i
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183 1 them.
,r x i 2 MEMBER MILLER: I had one question. Somewhere O
3 along, you made a comment you didn't want to put a 4 criteria in related to the questioning attitude of the 5 staff. Yet, I read NRC reports and so forth where that is 6 a criterion. I've never understood quite how you judge 7 that criteria. Could you comment on that? You know, the 8 NRC, various levels, seem to use that as a criteria for 9 making judgements on plant performance and so forth.
10 Could you comment on -- seems like you're 11 taking a different position as the NRC.
12 MR. BARRETT: It's difficult to say when a 13 person says -- you know, if I were to say to you that such
/ \
A- 14 and such a plant had -- doesn't have a questioning 15 attitude, what's the basis for that statement? That could 16 be a subjective judgement based on my conversations with 17 the plant management, which I would say is probably not a 18 very good basis for the statement.
19 Or it could be a very objective judgement 20 based on my assessment of their internal processes and 21 examples of poor 50.59's and what have you. You know, my 22 resident inspector's observations of the onsite review 23 committees and it could -- the basis for that statement 24 could be very deep or very shallow.
/~~N
) 25 And it's very difficult to assess that. But NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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184 !
l 1 in general, one of the thrusts of the Arthur Anderson l l l
,_s 2 report is that statements of that type are not as useful
.(
)
, 1 3 and are subjective. And what would be more useful would 1
4 be to develop all that depth of basis that I just )
5 mentioned in a structured way that can be consistent from 1
1 6 region to region to region.
7 MEMBER BARTON: You could structure that and l
)
8 say a plant has -- exhibits a good questioning attitude, l 1
9 has the following characteristics or --
10 MR. BARRETT: Right.
11 MEMBER BARTON: So you could do it that way 12 and everybody understands what do you mean by good 13 questioning attitude or does not have a good questioning f-~s k-) 14 attitude.
15 MR. BARRETT: Right. And that's exactly the 16 thrust of our main way of looking at some of these things l
17 is to say this -- here's a plant that's a five on 18 questioning -- and I'm not saying questioning attitude is l
19 one of our general criteria. But here's a five and here's 20 three or four sentences that describe a five.
21 Here are three or four sentences that describe 22 a one, which is a very bad plant. You could ask people 23 who know that plant to rate that plant, and they might do 24' a pretty good job of it. I think we could.
,/-
( p/ 25 VICE CHAIRMAN POWERS: Don, I think when you NEAL R. GROSS COURT REPORTERS AND TriANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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185 1 see it, it's a code word for saying there was information
,~ 2 available that would have warned somebody that something
(
3 was happening and they didr** follow up on it.
4 MEMBER MILLER: Well, I always sort of look at 5 it as the -- trying to get to the bottom line, is 6 complacency creeping in to the overall operation. Because 7 according to some studies, when things are going well, I 8 think overall -- you know, performance ove7;all certainly 9 has dramatically improved over the last five or ten 10 years -- that you begin having this creeping complacency.
11 And I always felt maybe that question is 12 trying to delve into those -- that issue. And then I'm 13 going to ask you are your indicators going to have some k_-) 14 relationship to this complacency issue particularly when 15 you look at plants that are doing very well?
16 They may be the ones that have most -- with 17 tne most complacent viewpoint versus the ones that are 18 kind of edging up on the watch list.
19 MR. BARRETT: I would say that if complacency 20 is the opposite of having active learning processes that 21 bring problems up, identify the root causes, and resolve 22 them and then follow up to make sure that they're 23 resolved, then yes; we will be looking at the opposite of 24 complacency.
em
(
) 25 MEMBER MILLER: So in a sense, you will be --
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186 1 have an indicator of complacency or an indicator of non-f3 2 complacency?
i )
\g 3 MEMBER BARTON: Are you going to work on the 4 committee to help us develop that one, Don?
5 VICE CHAIRMAN POWERS: Rich, when you work --
6 MEMBER MILLER: I thought I was on your 7 committee al)eady'and that was your responsibility.
8 VICE CHAIRMAN POWERS: When you work with 9 multiple indicators, do you run into voting problems?
10 That is, non-communicative algebra -- a is greater than b 11 is greater than c is greater than a sort of thing.
12 MR. BARRETT: Well, that was not dealt with in 13 the trend charts you saw. All of the indicators were
\~/ 14 given the same weight. There was no -- also no attempt to 15 see if there were double counting among indicators. In 16 fact, we know there was double counting among some of the 17 indicators because it was just a pilot program.
18 But the questions related to the weight that 19 are given to various indicators, definitely that's a 20 question we have to look at. Indicators that are so --
21 how they correlated that they really amount to double 22 counting, we need to look at those.
23 But in the bottom -- again, in the final 24 analysis, I think Arthur Anderson would say, if you are
/^%
q,,) 25 looking at enough different and diverse indicators, that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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187 1 the key. And maybe it's not as important to weight them
',s 2 properly as it's important to look at ones that are
)
v 3 diverse enough so that you get a broad spectrum of the 4 performance of the plant.
5 MEMBER BARTON: Any other questions from the 6 committee?
7 NEI have anything further they want to add?
8 MR. FLOYD: Yes, Steve Floyd, NEI.
9 What we have been doing, and I hope -- again, 10 this is a study that we could make public not too far from 11 now. We have taken the AEOD performance indicators, given 12 that that is the set that is publicly available to us, and 13 treated them in like fashion. We gave them equal weight I
S 1 E/ 14 to all the indicaters and we plotted the industry average 15 value for those AEOD indicators from the period of time 16 from 1986 through September of 1996.
17 And then we also plotted a trend curve for all 18 of the plants in the country throughout that time period 19 and compared it against the average trend curve. And a 20 few interesting things do come out when you do look at 21 that. And I think what it really shows is the danger of 22 maybe not putting in some sort of absolute threshold to 23 address this issue of the danger of a rising standard.
24 Because what we see -- and I think it supports (g),
25 some of the things that came out in the Arthur Anderson NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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188 1 study -- is that about 80% of the plarits that have been
,S 2 placed on the watch list actually did have an improving
- i 3 trend prior to being placed on the watch list that 4 occurred after a poor trend.
5 We also found that about 80% of the plants 6 that have ever been placed on the watch list had 7 performance levels that were better than the industry 8 average in 1985, again based on the AEOD performance 9 indicators.
10 Now clearly the plants that were placed on the 11 watch list prior to 1989 were the groupings of plants that I i
l 12 had worse indicators than the industry average in 1986, 1
13 but we couldn't find a plant looking at the data that had
,s
( )
N/ 14 been placed on the watch list since 1989 that had 15 performance levels worse than the industry average in l
l 16 1986. l 17 And in fact, the average level of improvement 18 if you take a look at the current list of watch list l 19 plants and their performance prior to being placed on the 20 watch list and compare that back to the industry average 21 in 1986, there's about a two and a half times improvement 22 in their performance compared to the industry average.
23 And that's very consistent with what the 24 industry average has improved. If you look at the AEOD g
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l 189 l l
l 1 between three and four improvement in general collectively l 2 amongst the indicators. l
! i
~'
3 Some of the indicators show substantially more 4 improvement that Rich pointed out like scrams and 5 significant events, for example. And I guess that's just 6 what I wanted to point out.
7 But in general, we found that the Arthur 8 Anderson study I think was very consistent with the 9 results that we saw.
10 MEMBER BARTON: Mr. Chairman, any other 11 discussion you want to have with the committee now as to 12 where we ought to proceed?
13 CHAIRMAN SEALE: Yes, I think it would be
, s
'v' 14 worthwhile to do that.
15 VICE CHAIRMAN POWERS: We don't have an SRM on 16 this, do we?
17 MEMBER BARTON: No, we do not.
18 CHAIRMAN SEALE: No, we don't. On the other 19 hand, we have an ex~pression of staff interest in keeping 20 us informed and asking our input on a periodic basis.
21 MEMBER BARTON: Is this something we should 22 handle through the plant operation subcommittee?
23 CHAIRMAN SEALE: I think that's the 24 appropriate place to do it. I don't think it's something
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l 190 l 1 think when they're ready to tell us something, they'll let 1
s 2 us know about it. And at the time, we'll look at it I 'l 3 relative to the other things that are on the plate and ;
4 find out if we've got a corner for it.
5 Okay.
6 '1 EMBER BARTON: Thank you, Mr. Barrett, for 7 the presentation.
8 CHAIRMAN SEALE: Thank you very much.
9 MEMBER BARTON: I guess I'll turn the meeting 10 back over to the Chairman.
11 CHAIRMAN SEALE: Okay, we're due for a braak 12 right now, and so we will.
13 (Whereupon, the foregoing matter went off the
.N N,..s 14 record at 3:06 p.m. and went back on the 15 record at 3:19 p.m.)
16 CHAIRMAN SEALE: The next item is continuation 17 of our discussions on risk-informed performance-based 18 regulation and related matters.
19 It seems that this is the day for happy 20 comments. Apparently, we understand that Dr. Apostolakis' 1
21 father is quite ill, and he has been in Greece for the l l
l 22 last few days. He has been in communication with Dr. l 1
l 23 Powers, and Dr. Powers will conduct this part -- this 24 subcommittee meeting, or will act for Dr. Apostolakis. ,
1 r~N i
( ) 25 VICE CHAIRMAN POWERS: Yes, I have to l
\_/ l l
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191 1 apologize, my accident is not as strong as George's.
2 This is the discussion of the risk-informed
/es\
Q") 3 decisionmaking. Most of the members of the committee have 4 indeed participated in a continuing string of subcommittee 5 meetings. What we have now is a set of documents 6 describing risk-informed decisionmaking that the staff 7 feels very near to the point they can be issued for public 8 comment.
9 We have a draft reg. guide that provides an 10 overall process philosophy for bringing risk-informed 11 decisionmaking into the review of proposals to change the 12 current licensing basis of individual plants. We have 13 reg. guides in which this is applied to technical ln\
C 14 specifications, in-service testing. and graded quality 15 assurance.
16 As I've said, the subcommittees have been 17 reviewing these aggressively, and there has been a 18 tremendous dialogue between the subcommittees and the 19 staff as these documents have evolved. Our most recent 20 subcommittee meeting did come up with some conclusions l 21 that we are ready to submit to the full committee as a 22 preliminary indication prior to this final presentation to l
l 23 the full committee.
24 Those conclusions included things like the n,
) 25 general guidance reg. guide we thought was indeed ready i NEAL R. GROSS CCllRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. l (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433 l
! l l
192 1 for issuance for public comment. The documents describing fm 2 application to tech. specs. and in-serrice testing are
( )
3 very nearly ready for issuance. The committee felt it 4 would be desirable that these documents be edited to i 5 clarify and tighten their tie to the overall guidance 6 document.
I 7 The subcommittee did express some interest in i
8 elevating the criteria for allowed outages times into the l l
9 general guidance as perhaps a principle or some way of I l
10 elevated significance, so that its tie to a principled 11 foundation was clear. l l
\
12 The subcommittee felt that the application of 13 risk-informed decisionmaking to graded quality assurance 14 was not yet ready for issuance for public comment. The l l
15 subcommittee and its consultants felt the current approach l
16 adopted in the document was timid. And it might well be 17 viewed by the reviewe13 as a confirmation that risk-18 informed regulation was simply another layer of regulation 19 and that it created burden without producing tangible 20 benefits.
21 Those were the points that the subcommittee 22 raised. At the conclusion oi their last meeting, the 23 staff indicated that they were going to look at those 24 comments and act upon them and consider them, and today
/m\
Q 25 they are proposing to ccee forward with the last hurrah I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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193 1 guess. Next-to-the-last hurrah?
7 ; 2 MR. HOLAHAN: We'11 see.
t
\_/
3 (Laughter.)
4 VICE CHAIRMAN POWERS: So, Gary, you or Tom 5 or --
6 MR. HOLAHAN. Okay. I think Tom is going to 7 do his presentation.
8 MR. KING: Yes. We have a short presentation, 9 really, to focus on what changes we have made since we met 10 the last time, what we propose to do regarding upgrading 11 the documents in parallel with the public comment process, 12 and then we specifically want to talk graded QA.
p_
13 VICE CHAIRMAN POWERS: Tom, let me interrupt I )
l
\'/ 14 and maybe ask a question as well. It was the 15 subcommittee's impression that the questions you had 16 formulated to go with these documents when you sent them i 1
1 17 out for public comment were very good. You got rave l
18 reviews on those questions, as I recall. Are those l
19 questions now solidified, or are they still evolving, and 20 do we have -- are they well listed in the document, in the l
l 21 revised documents we have just received?
22 MR. KING: No. They're in the Federal 23 Register notice, which you have not received.
24 VICE CHAIRMAN POWERS: Okay.
/"N
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l 194 l
l 1 a month or so ago. They have evolved somewhat from the
~s 2 standpoint of adding things to them, not taking things
/ 1
\ )
3 out, and I think we'd probably want to sharpen some of 4 them up in terms of soliciting comment on temporary
- 5 increases in risk, for example.
6 VICE CHAIRMAN POWERS: Would it be an 7 imposition to ask you if we could get a list of those 8 questions as we prepare our letter?
9 MR. KING: No. No, we can get you a list. I 10 could get it for you probably tomorrow.
11 VICE CHAIRMAN POWERS: My motivation is simply 12 to be able to say with some confidence that we endorse the 13 questions, because I believe the subcommittee did.
' )
(_/ 14 MR. KING: I think that's reasonable, because 15 some of the things we're proposing are tied to asking a 16 question, and then based on its response take an action.
17 Just for the record, I'll tell you I'm Tom 18 King from Research. Gary Holahan and Bob Jones from NRR, 19 and Mark Cunningham from Research are here with me.
20 I won't dwell on, you know, why we're doing 21 what we're doing. We've been through that many times. As 22 you mentioned, what we have in front of the committee are 23 a general reg. guide and its companion SRP, and then l
l l 24 specific reg. guides specific to tech. specs., IST, and j' %
(v ) -
25 graded QA. We will be coming ir the next few months with l
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l l
195 i l
1 another specific reg. guide dealing with ISI, but we're l
,x 2 not talking about that today.
' ,)
/ \
3 We also had presented to the committee for l l
4 information what we called NUREG-1602, which was really a j 5 reference document that dealt with issues related to the ,
6 scope and quality of a PRA. It's not part of the l l
7 guidance. It's not a requirement or a standard. But it's 8 really put out there as information that the licensees 9 could use when they're trying to look at what should be l l
10 the scope and what should be the quality of the PRA that I l l
11 need to support mv application. It's more like a l l
12 reference document.
13 VICE CHAIRMAN POWERS: And you were not 1
-n 1 I ) l (s/ 14 looking for us to comment on that NUREG in our letter to l l
15 the Commission? l l
16 MR. KING: No, we were not looking for comment !
17 on that. It will be published for comment, along with 18 everything else, though.
19 We feel that the documents are ready for 20 public comments. What we want to do today is focus on the 21 changes we have made since the last subcommittee meeting.
22 Those are primarily in the general reg. guide and SRP, and 23 we'll go through those one by one. And you now have 24 copies -- I think you received on Monday copies of the
(-)
t,s_/- 25 revised general reg. guide and SRP.
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i 196 1 I also want to talk about the things we had 7s 2 planne,d to do in conjunction with the public comment u \
\ /
3 process. That includes the implementation plan that Bob 4 Jones briefly summarized at the last subcommittee meeting.
5 We'll get a little more detail on that.
6 And then we do want to specifically touch on 7 the graded QA issue and reg. guide and SRP. Suzie Black 8 from the NRR staff is going to talk about that. She has a 9 separate presentation that will follow this one.
10 And as we said, we're requesting a letter from 11 the committee endorsing going out for public comment with 12 this package of documents. And for our schedule or 13 purposes, we would like to get that letter by next Friday,
/ \
14 the 14th.
15 Just to recap an important point in terms of 16 the role of these documents in the regulatory process, the i l
17 use of these reg. guides and SRPs is voluntary on j 18 licensees. We view this as another acceptable way that 19 licensees could use to propose changes to their CLB. In l 20 essence, to implement 10 CFR 50.90 through 92. We don't 21 view these as an additional burden on top of existing 22 methods. We don't view this process as a backfit, since 23 it is voluntary. But basically, it provides an 24 alternative way for licensees to analyze and justify
,/~T
(,) 25 changes.
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197 1 From the staff's standpoint, we are obligated
-y 2 to comply with tne Commission's policy statement on PRA, t ;
~
3 and in that respect we would plan to give applications for 4 burden reduction to those licensees who do use risk 5 information consistent with the intent of the policy 6 statement. Clearly, any application that has got safety 7 implications is going to get high priority by its very 8 nature.
9 We also feel that the overall approach 10 described in the reg. guide and SRP, in terms of how do 11 you utilize risk and integrate risk in traditional 12 engineering methods, and the guidelines that are proposed 13 to do that, can apply to more than plant-specific changes i
\' -
14 to a plant's current licensing basis. We have added some 15 words to the reg. guide to imply that, and there may be '
16 some follow-on actions at some point to take this process 17 and integrate into this some other staff documents that 18 deal with more generic type things.
19 VICE CHAIRMAN POWERS: I was strongly of the ,
20 impression that the subcomm.ittee was supportive of that 21 idea. What i notice from this viewgraph with the emphasis i
22 on voluntary and staff utilization, it seems to be a step
]
i 23 down from the active solicitation comments that we were !
l 24 getting at the subcommittee meeting where you were really
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198 l 1 take advantage of this approach.
2 MR. HOLAHAN: Well, I don't think they are Q
3 inconsistent. I think what we're saying is the staff will ,
4 still encourage licensees to use risk information in their 5 applications. But there is a difference between 1
6 encouraging it and requiring it. j 1
7 VICE CHAIRMAN POWERS: Absolutely.
8 MR. HOLAHAN: What we're saying is we're 9 drawing a clear line to say you're not required. But I 10 think it's fair to say we've put a lot of effort into 11 this, and we would very much prefer that, you know, 12 licensees, you know, test out these approaches by actually 13 giving us risk-informed applications.
i\ -) 14 VICE CHAIRMAN POWERS: That still remains your 15 preference.
1 i
16 MR. HOLAHAN: That remains our approach. l l
l 17 Just one more time a slide you've '
MR. KING:
18 seen before. There are many ways that a plant's current 19 licensing basis can be changed. It can be changed by us. ,
20 It can be changed by the licensee. What we're talking 21 about with these reg. guides and SRPs is adding one more 1
22 way. We're talking about a new box to the process that i l
l 23 says if you want to utilize risk information to do things j 24 that haven't been done before, here are some guidelines f~s
/ )
i f 25 that you can use to do that.
r 1
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVE., N W.
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199 1 But it's your choice if you want to do that or ,
l
- f. 2 not. It's not a requirement. So what we're talking about L)
3 is documents that relate to that box in the various ways 4 that are available for a plant or the staff to change 5 things.
6 All right. Changes to the general reg. guide 7 and SRP since our last subcommittee meeting -- most of 8 these resulted from comments that we got at the 9 subcommittee meeting. All of these are incorporated in 10 the version you received on Monday. We expanded the 11 forward of the document to note the usefulness of the 12 principles and process to other activities that apply risk 13 information, other activities beyond changes to a plant-7 i \
')s_ 14 specific CLB.
15 You know, that could include things that the 16 licensee would do, like petitions for rulemaking. It also 17 could apply to things the staff does, like regulatory .
18 analysis guidelines. But we wanted to get that thought in 19 there that this has broader implications, potentially, 20 than just the plant-specific CLB changes, even though the 21 thrust of the document is for that.
22 The second thing we did was there was some l
23 concern from the subcommittee that we were not emphasizing 24 enough the role of qualitative factors in the
,m
( 25 decisionmaking process, so in two places we have added
)
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200 1 some additional words dealing with the fact that p._ 2 qualitative factors are important, unquantified benefits 3 should be considered, and we've put those right up fronc 4 at the first place we talk about the integrated 5 decisionmaking process on page 2-1. And then we've beefed 6 up the words back in the document on page 2-12 to 7 emphasize that a little more.
8 The third thing we've done is we've modified 9 the definition in the reg. guide on LERF to be consistent 10 with the Appendix B definition. And basically, what that 11 says is that when you calculate LERF, what we're 12 interested in are the unmitigated releases. Things that 13 are scrubbed or mitigated in some fashion should not be
(-
- m. 14 counted. That's consistent with Appendix B to the general 15 reg. guide which provides an approximate way to estimate l
16 LERF. So now the reg. guide and the appendix are 17 consistent in the definition of LERF.
18 The fourth thing we did was in the defense-in-19 depth section, there was concern that some of the words in 20 there -- we used " maintain" several times and it could be 21 read as you can't change anything when you're talking 22 defense in depth. That certainly wasn't our intent, so 23 we've changed some words to state that -- really, one is l
l 24 that it's the defense-in-depth philosophy that needs to be g'N i i 25 maintained.
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201 1 But the way that you actually show that you
,3 2 maintain that philosophy can result in changes in the
'~'
3 plant. And so what we've done is gone in and under the 4 six subelements to the defense-in-depth principle, we've 5 taken out the word " maintained and substituted 6 " preserved" and tried to put in some words to explain that 7 a little better.
l 8 VICE CHAIRMAN POWERS: How do you feel about l 9 that? I mean, it sounds to me off hand that you've 10 actually improved things. In moving this word 11 " maintained," though, I wasn't the one that was so 12 sensitive to it. How do you feel about it?
13 MR. KING: I personally think it's a
,7~
(-)l 14 reasonable thing to do. You can call it word engineering 15 if you want, but I think when you get down to some of 16 these fundamental aspects, it's important to pick your l
17 words carefully and get your concept or cost carefully. !
1 18 VICE CHAIRMAN POWERS: You don't feel like !
19 you've compromised any of your principles, do you? l 20 MR. IING: I personally don't. l 21 MR. HOLAHAN: No, I don't think we've changed 22 the intent. I think the intent always allowed for, you 23 know, changing how defense in depth would be met, you 24 know, under any given type of application. So I think
( ) 25 this is maybe just a little better explanation of what the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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202 1 intent war along. I don't think the intent has g~s 2 changed. ,
\~^/) l i
3 MR. KING: Okay. The last thing we did was we i 4 added some additional words to clarify that you don't need !
5 a full scope PRA to implement this document. I think it l
6 was discussed, but it was buried toward the back of cne of 7 tha sections and we tried to add that right up front where l 8 you get into how you compare the PRA analysis to the 9 guidelines. We tried to state that right up front as well 10 as leave the words in the back. So there was some concern l 11 from the subcommit1 >e that it implies you need a full 12 scope PRA, and we wanted to clarify that wasn't the 13 intent. l
'd 14 MEMBER KRESS: When you say " full scope," the 15 difference in it from partial scope, what do you have in 16 mind there?
17 MR. KING: Full power, external events, 18 shutdown conditions.
19 MEMBER KRESS: Full scope means full power, 20 external events --
21 MR. KING: Yes.
22 MEMBER KRESS: -- shutdown?
23 MR. KING: Yes.
24 MR. HOLAHAN: Fire.
/O
(,) 25 MEMBER KRESS: Fire.
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203 1 VICE CHAIRMAN POWERS: Can you give us -- it 73 2 seems to me the criticisms laid down at the subcommittee
\ \
x/
l 3 meeting went also the other way, that when you came to 1
4 making decisions that you were using only the partial '
5 scope, and not recognizing the other elements of risk.
6 I can remember at least one member going 7 through some numbers with you and saying, " Gee, if I go 8 through the numbers, you shouldn't be making this change 9 at all." For an example, change because you violate the 10 10-4 core damage frequency number when I go beyond the full 11 power operation to include other factors.
I 12 MR. HOLAHAN: But I don't think we entirely 13 agreed with that member and his comments -- l
- t
\' ~
14 (Laughter.)
15 -- at that time. And I think what our 16 discussion said was whatever scope of analysis you use, 17 you use that information, and you supplement it 18 qualitatively with whatever judgments you can make about 19 whether the plant, you know, within your judgment is above 20 or below the safety goals, which is, for decision 21 purposes, really the only thing you're trying to do.
22 You're trying to decide whether this is a plant for which, 23 you know, some level of increases is appropriate, or else 24 it's in this other range where only risk reductions ought
,) 25 to be considered.
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204 1 So I think what we talked about is where you 7s 2 have quantitative analysis, use the information. And
'~'
i 3 where you don't., make some judgments about, you know, 4 maybe in fact if you think that qualitatively this plant 5 would, in fact, be, you know, beyond the safety goals, 6 beyond the subsidiary objective -- lo-* CDF -- if you did 7 include shutdown or fires or whatever was left out, 8 because of the magnitude of that that you've seen on other 9 similar plants.
10 Then, in fact, you ought to treat it as though i
11 this plant is over that limit and incorporate that into 12 the integrated decisionmaking process. It's not 13 necessarily -- I mean, clearly, it's not the only element
,3 k' /
1 14 in the decision process.
15 But for that element of it, do the best you l
16 can. You know, consider everything you know about the 17 full scope of what would have been the PRA if it were l 18 done. At the moment, that's, you know, the best treatment i 19 that we can -- given the realities of, you know, some 20 plants have a larger scope PRA than others.
21 MEMBER KRESS: So you're saying your 22 acceptance criteria, you apply the full scope?
23 MR. HOLAHAN: The acceptance criteria applies 24 full scope.
r^,
() 25 MEMBER KRESS: But in deciding whether you NEAL R. GROSS COURT REPORTERS AND TRANSCRlBERS 1323 RHODE ISLAND AVE., N W.
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205 1 meet those, it's perfectly all right to use the 7s 2 qualitative information that accounts for the missing
/ \
3 parts?
4 MR. HOLAHAN- Yes.
5 MEMBER KRESS: Okay.
6 MR. KING: Yes.
7 MR. HOLAHAN: And you recognize that, I mean, l 8 that is going to be judgmental by its nature.
9 MEMBER KRESS: Yes.
10 MR. KING: And it also accounts for even if 11 your numerical values are slightly above the guidelines, 12 but there are good qualitative reasons why you think 13 that's conservative, or there are unquantifiable benefits
(_) 14 that override that, allows for those to be factored in and 15 influence the decision. Those were some of the words we l l
16 tried to clarify. j 17 MR. HOLAHAN: And I think what we would really J
18 like to do is have the document written in such a way that 19 the licensee feels that burden also. That when they are 20 making a proposal to go beyond things that have been l 21 accepted before, they present whatever they have analyzed, 22 and they present, you know, their argument about how the j
}
23 things that weren't analyzed -- what role they might play l 24 and how they might influence the decision. And then the n 25 staff, although we're making a judgment, we're making a
( j!
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206 1 judgnient based on, you know, some level of information f3 2 presented to us.
( )
3 MR. KING: Okay. Slide 6 is the list of 4 things, other things that we talked about at the 5 subcommittee meeting which to date have not been factored 6 into the general reg. guide and SRP. What we're proposing 7 to do is we think these are things that need to be worked 8 on, but to us it makes more sense to do that in parallel 9 with the public comment process and then reflect their 10 resolution in the final drafts which will come back to the 11 subcommittee and the committee in the fall.
l 12 There is five of those on the list. Let me 13 just run through them. We talked about assessing the need r
's / 14 for guidance on temporary increases in risk in the general 15 reg. guide. I think that's a fair comment. I think we l 16 had had in our Federal Reaister notice draft that question l l l
17 for quite a while, and I think what we'd like to do is to l 18 have some time for us to think about, do we need it? If 1
19 we need it, what form should it take? How would we make '
1 l
20 it consistent with the principles that we have in the l '
l l
21 document? l
(
1 1
22 We'd like to get the comments from the public, 23 see what they recommend, and then come back at the final 1
24 stage and give you our recommendation. So that's what l n
() 25 we're proposing on this one.
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207 1 Appendix B to the general reg. guide, which
, ~\ 2 provides a method for estimating LERF when you only have a i t
\~~/
3 Level 1 PRA. We recognize that needs to be upgraded to 4 cover shutdown conditions and external events. Right now 5 it only covers full power internal events. We've 6 committed to do that over the next several months, and in 7 conjunction with that develop a NUREG/CR document that 8 provides the basis for that estimation method so people 9 can see where it comes from. Again, those things would be 10 done in time to support tne final documents.
11 Fottrth item -- refine guidance on treatment of 12 uncertainty. What we have in there now is a description 13 of the various sources of uncertainty and things you need
\~s l 14 to think about when you're trying to make your decision.
15 But it doesn't provide any quantitative or even 16 qualitative guidelines as to how to make that decision.
17 Again, we have questions in the Federal 18 Recister notice soliciting information on that. We plan 19 to work on that ourselves as to can we say more in that 20 area. But at this point, we'd like to do that in parallel 21 with the public comment process.
22 And the last item, a question that came up at l
l 23 the subcommittee meeting about the role of performance 24 monitoring. In particular, can performance monitoring n
k) 25 help compensate, for example, for doing analysis or doing i
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?
I
208 1 a detailed review in some areas? So we'd like to think gs 2 about, can we expand the role of performance monitoring i \
'% )
3 beyond what it currently is in the reg. guide and SRP, to 4 be able to be used for more things?
5 So those are items that are on our list of 6 things to work on, and we'll present them as IOUs to you, 7 but IOUs in the sense that we deal with them at the final 8 draft stage, after we've gotten public input.
9 VICE CHAIRMAN POWERS: And it was my 10 recollection that the subcommittee had no troubles with 11 this kind of approach. The subcommittee felt the need 12 that you feel now to get other eyes looking at these 13 documents -- the relatively closed circle that had been N- 14 going on up until now.
15 Now, I did wonder, when you think about this 16 way we -- the Appendix B of estimating LERF, and then you 17 start thinking about external events, you say, " Gee, I'm 18 going to run into troublas trying to extrapolate it 19 easily." In some transparent fashion, I'm going to run 20 into a problem because external events interfere in my 21 capacity to do evacuation in some cases. l 22 I could certainly define accidents where l l
l 23 external events interfere with that, and that's the I l
24 criterion you would use to distinguish between early and l
(i l
'N ,/ 25 late release. It's whether you can evacuate or not.
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- - . . . -- -. . . _ . ~ - . . . ..-.-_ _ -..- - ._..--.- _.- .. . . . . .
[
s 209 l
- j. 1 And it's possible that in thinking.about this,
~
g 2 you might come up with shall we call it LERF prime or some ly
- 3. other definition of LERF that could be penalized at that-i i -
4- point. Does this precipitate ~another round of public l 4
5 comment, or are'there any changes that you've forecast .
j '- 6 that precipitate additional rounds'o'f public comment?.
7 MR. KING: Provided our set of questions i ,
, 8 touches on these points, and we're not introducing f
9 something totally new that nobody was given a chance to 10 think about, we do not need to go out again for public ,
1 i
', 11 comment. That's why we've-got so many questions written '
[ I 12' down, because we realize there are things like this that 13 we haven't dealt with in the current version that we t 14 probably do need to deal with.
15 And the best way to do that is put those on 16 the table for input, and then we will have input to deal
]
17 with and make a decision. And as long as we've done that, .
18 we don't have to go back out for public comment. Now, if 19 we introduce something totally new that we've never dealt 20 with before, then that could necessitate another round.
21 But our intent is not to have another round.
22 MR. HOLAHAN: Well, I think not to have 1 23 another round in the near future. But realistically, you 24 know, I think there will be a Rev. 1 and a Rev. 2 to these 25 documents at some_ point. ;
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I l
210 1
1 VICE CHAIRMAN POWERS: Sure.
n 2 MR. HOLAHAN: I think you suggested at one l \
\ /
~
3 point at a subcommittee meeting that there may be some 4 surrogate approaches to shutdown or fire or to deal with 5 other scope issues And I think if we're smart enough to 6 figure that out next year or the year after, their could 7 be a revision to these documents. And I think when you 8 put out a formal re"ision, there would probably be a 9 comment period, you know, on that version.
10 VICE CHAIRMAN POWERS: Well, certainly we hope 11 that in the exercising of these guidelines, through I 12 applications and submissions, that we'll learn something.
13 MR. HOLAHAN: Yes.
(--
'd 4
14 VICE CHAIRMAN POWERS: But that's the time ;
15 scale for thinking about a revision. l l
16 MR. HOLAHAN: Yes.
l 17 MEMBER KRESS: Are you giving any thought to i
18 Dana's suggestion that the LERF definition might ought to 19 be different for external events than for other things?
20 MR. CUNNINGHAM: Yes. That's the type of 21 thing we'll have to consider for precisely the reasons 22 that Dr. Powers raised, that there's different things 23 going on and you have to think about what that might mean 24 to your definition of LERF.
,~
25 MR. KING: We have thought about it, but I (w)
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211 1 don't have any -- we're not leaning one way or the other ,
l
,y 2 at this point.
( )
3 MEMBER KRESS: We really don't have any l l
l 4 suggestions for you either, I don't think.
5 VICE CHAIRMAN POWERS: It's very challenging.
6 Quite frankly, a lot of external events don't interfere in 7 the capacity to evacuate the population and --
8 MEMBER KRESS: Yes. And you'd somehow have to 9 factor that into your judgment.
10 VICE CHAIRMAN POWERS: And it's equally 11 challenging, I think, because in contrast to operation 12 accident -- accidents that occur during full power 13 operations -- our information base about shutdown and g3 r e
\~ s' 34 external events is small, biased, not been subject to the 15 level of scrutiny and details. The industrial capacity to 16 carry out such analyses is much more limited.
17 You know, whereas in the Appendix B approach 18 toward Level 2 and Level 3 analyses, one could say, " Gee, 19 I have looked at a lot of PRAs, an awful lot of PRAs, and i
20 a lot of IPEs, and I know when I'm being bounded, and I 1
21 know when I'm being optimistic." Here I think you're 22 looking at a sparse data set. l l
23 MEMBER KRESS: The main reason I asked the 24 question about whether you're thinking about the possible ,
f'N l
() 25 redefinition of LERF, for external events say, is because l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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212 1 what you come up with now has some real attractive
, 2 features in that it really is site independent. Once you i '"'
)
3 start doing this, then you're going to have to think once 4 again about variable LERFs for different sites, and it 5 will be site specific.
6 MR. KING: Or bounded, to make sure you --
I 7 MEMBER KRESS: Or bounded some way. And then 8 you start bounding -- if you're talking about bounding the l
9 seismic, you may have a real bound that is too much. So I 1
1 10 wanted to raise the flag, because --
l 11 VICE CHAIRMAN POWERS: Similarly, there are 12 some unattractive features about the current definition of 13 LERF, in that I chink it provides a very limited incentive
\_ / 14 to look for imaginative ways to decrease source terms in 15 cases where you do have the threat of early containment 16 failure.
17 MEMBER KRESS: Could be.
18 VICE CHAIRMAN POWERS: You get no benefit.
19 MEMBER KRESS: But they no longer will have 20 the ability to adjust the types of sequences they look at 21 to account for the LERF difference, if they change this 22 definition, which is a nice feature I think -- being able l
23 to define your sets of sequences.
24 VICE CHAIRMAN POWERS: Let me temper my rx
() 25 concern over the current definition. I think any plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
213 1 that is so sophisticated that it's worrying about 73 2 mitigating the source term probably doesn't have to use
- 1 v'
3 Appendix B.
4 (Laughter.)
5 MR. KING: Okay. Slide 6 is talking about 6 things that are primarily going to influence the general 7 reg. guide and SRP. There is also some things that are 8 going to be done in addition to that, in parallel with the 9 public comment process. One is complete the pilot 10 applications and get the feedback from that folded into 11 the final versions.
12 The other one is we discussed with the 13 subcommittee the limit in the tech. spec. reg. guide on
/
,,\
(\ ') 14 core damage probability during allowable outage times.
15 The current proposal that's in the reg. guide really comes 16 from what current staff practice is. l l
17 I said we're going to look on the general reg. )
l 18 guide about adding something in on the temporary changes 19 in risk. I think we're also going to relook at what is in 1
20 the tech. spec. reg. guide. But again, we'd like to do 21 that in parallel with the public comment process -- give 22 people a chance to comment on what's in there now and 23 revisit it when we get to the final stage. So we're not 24 proposing any change to the draft in that area at this
/3
! ) 25 time.
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i 214 l 1 VICE CHAIRMAN POWERS: I think you want to be 7 2 very careful about looking at those AOT limits that are
( i
\, /
3 based on past practice -- you know, deviating from that, '
4 because it seems to be effective and it seems to meet our j 5 criterion for safe enough now. And I get very nervous l
6 when you start -- you want to dial a number a little -- l l
7 (Laughter.)
l 8 MR. KING: Yes. I think we want some time to 9 really think about it, not jump into a change.
10 MR. JONES: I think the key point is, though, ;
11 arguably --
12 CHAIRMAN SEALE: There was a second bullet 13 there you didn't cover.
(,
i i ws' 14 MR. KING: Well, I had mentioned that first.
15 That was the pilot programs that will influence the 16 ultimate products as well.
17 MR. JONES: I was going to say that, arguably, 18 the tech. spec. change ultimately, if we do come up with 19 temporary increase criteria and put it in the general, 20 then I think we would certainly revisit that criteria to 21 make sure they are consistent.
22 VICE CHAIRMAN POWERS: Consistent, yes.
23 MR. JONES: We think that what we've got makes 24 sense and is consistent with the framework. We've given
/ 25 some thoughts to that, so we think it's okay now. But if a
)
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l l 215 1 we do go with temporary change criteria, we will probably l
, 2 revisit and revise to be consistent at that point.
3 MR. KING: Okay. The last slide -- when we 4 were at the subcommittee meeting, Bob Jones had talked 5 about what are our plans for implementation. He has done 6 a little more thinking about that, and I'll let him 7 present the last slide.
8 MR. JONES: I don't want to belabor this slide 9 very much. It basically -- the last time I felt very 10 honored to try to put the whole plan together for getting 11 out all of the documents in 10 minutes.
12 (Laughter.)
13 And I thought I'd go back and revisit that a
/'T N- m 14 little bit.
15 VICE CHAIRMAN POWERS: We thought we were 16 giving you way more time than you needed.
17 (Laughter.)
18 MR. JONES: So what this represents -- I mean, 19 this is essentially what we told you. There are some 20 minor changes in some dates. I think the training -- we 21 pushed it out to when we would finish it in more like the 22 December timeframe, consistent with the ultimate date that 23 we would put the documents out, the final documents, so 24 they would all be merged together and effectively be
/7 25
!v) training on the documents as they go out in final version, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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216 1 so there wo11dn't be inconsistencies by training on drafts
-, 2 and go in the finals.
\
]
3 We also looked at the public workshops, and 4 we're trying to see how many we can do and what focus vc 5 would have. Can we really go out to all of the regions or 6 not with the staff we have? That decision is not fully 7 made at this point. That's why it says " workshop (s)" --
8 in parentheses. But we are continuing to go in that 9 direction. We will have at least one workshop. We will 10 likely have multiple ones. It's just a matter of how 11 many.
12 So we're just trying to figure out -- we also 13 have added the ACRS review schedule. We thought you might g
i,-) 14 like to understand where you fit into the picture, which 15 we didn't talk about the last time --
16 CHAIRMAN SEALE: Appreciate it.
17 MR. JONES: -- on the document. So this is 18 the basic framework. What's not on here is the comments 19 on the pilots. We are going to review the pilots 20 aggressively on the schedules, basically, this summer for 21 most of the pilots will be complete. So we just didn't 22 reiterate all of them and add them on here. We're going 23 on to them right after the guidance documents get issued.
24 MR. KING: Okay. At this point, the last
/^N
( ) 25 thing we want to talk about is the comments the committee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l l
I 217 l l
1 made on graded QA, and Suzie Black from the NRR, the j
,s 2 branch chief that has the QA program at NRR, is going to r s
( '~' /
3 talk about that.
4 VICE CHAIRMAN POWERS: Before we delve into 5 P. hat, could I just talk to the committee just a little bit 6 about the schedule? The way it is set up, we are going to 7 get a final briefing in December, and final documents go 8 to the Commission in December. That puts an enormous 9 burden on us to prepare a letter that goes up j 10 contemporaneously with the documents to the Commission.
11 MEMBER KRESS: Usually, it would. But we will j 12 be going into this one with a fairly broad understanding 13 of it all. It's not like this will be the first time
(-) 14 we've seen them, and it all depends on the nature of how 15 they respond to public comments. If there's major 16 changes, then -- I i
17 CHAIRMAN SEALE: Then we're in trouble.
l 18 MEMBER KRESS: -- then we may be in trouble.
l 19 VICE CHAIRMAN POWERS: Yes. We're going to 20 have to be careful how we schedule the November 21 subcommittee meeting versus that final meeting, so that 22 we're meeting largely as a committee of a whole in 23 November, so that our final meeting isn't as detailed as a 24 presentation as we're getting now on the documents, I p) i v 25 would think. That is, we already know them well enough NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 218 I
1 that it's dotting I's and crossing T's sort of things.
,m 2 Scheduling the champagne brunch that staff i ;
\
'~'
l 3 will undoubtedly host for us, having given them such a 4 rave review --
5 MEMBER KRESS: I'll have a Cuban cigar.
6 (Laughter.)
7 CHAIRMAN SEALE: Gentlemen, I'11 remind you 8 about the gratuitous --
9 (Laughter.)
10 VICE CHAIRMAN POWERS: But from the staff, I'm i 11 not sure it covers those.
12 (Laughter.)
13 Yes. It's just an alert to us that we've got L 14 to be careful about what we do, because we will get into a 15 time crunch on our side. And I don't see any way to 16 adjust this to relieve us of this burden.
17 CHAIRMAN SEALE: No.
18 MR. MARKLEY: Is October a better time for a 1
19 subcommittee, then? l 20 VICE CHAIRMAN POWERS: I don't think they have l l
21 things done. You know, I don't think they have done their 22 work. That's the problem. And it doesn't do -- they l
23 already have scheduled a meeting in -- what is that -- l l
24 September to review for us what they've been thinking l
,e ~. l
() 25 about and what significant comments they've gotten that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODF ISLAND AVE., N.W. ,
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219 1 might be of interest to us before they get into the nitty-
- 2 gritty of working them out.
l \
' \// 3 And so they have alerted us as much as they 4 can. Then they -- they're putting a lot of pressure on 5 themselves to handle all of those comments in such a short 6 time. I don't want to put any more burden on them. It's 7 our problem, and we need to -- we appreciate your telling 8 us about it.
9 MR. HOLAHAN. Let me make a few introductory 10 remarks, and then Suzie Black, who is the Branch Chief of 11 the Quality Assurance and Maintenance Branch, is going to 12 cover the details.
13 At the subcommittee meeting, there was
,~3 f i
(_/ 14 considerable discussion on all of the reg. guides and 15 SRPs. But when it came down to the end, I think there was 16 a clear message from the subcommittee that it felt 17 differently about the graded QA document, that partly 18 perception and partly reality -- there was a feeling that 19 this document was in some ways different from the others, 20 that it didn't quite have the same feeling of, let's say, 21 receptiveness on the part of the staff for change.
21 And I think there were also a number of 23 discussions during that meeting about the magnitude of the 24 burden on the licensees for the amount of analysis and the
() 25 type of analysis -- bounding analysis and screening NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISt.AND AVE., N W. j (202) 224-4433 WASHINGTON D C. 20005-3701 (202) 234-4433 j l
j
220 l
1 analyses -- that we were asking the licensees to do.
1 2 So I think we've taken those comments fairly
.g i
3 seriously. A number of us have gone back and reread the 4 documents with this sort of independent view, to see 5 whether it really feels the way the committee had 6 suggested. And I think we've probably had half a dozen 7 meetings since then discussing, well, should we change the 8 documents? Or what should we ask of the committee?
9 And I think going back and rereading the 10 document, you do feel that there is a level of imbalance.
11 I think what we had suggested all along was risk-informed 12 regulation was not a free ride. We do expect licensees to 13 do their homework, but there was expected to be some level l !
(.)\ 14 of balance, that when the licensees are asked to do more 15 analysis than they've done before, they should also expect l 16 to get some relief from requirements in some commensurate 17 way from what they were required to do before, i 18 And when you looked at the graded QA document,
! 19 it does give you the feeling that a lot of analysis is 20 required, and a relatively small reduction in 21 requirements. And so in that sense, there is an 22 imbalance, that we're asking for perhaps too much work for .
l l
23 too little relief. And I think with that in mind, we are l 24 relooking at the document on both ends to say, are we n)
(
v 25 really asking for more analysis than is necessary for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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221 1
1 determining what is high safety significance and what is l
,, - ~ 2 low safety significance? Are we really overkilling this i ; i
'~
3 problem?
l 4 And I think we're also going back and looking l
5 at it to say, have we been too timid in saying how much 6 relief we are utiling to give licensees? Aren't we 7 willing to do more than to say, well, a few less audits or 8 a few less samples would be required for low safety 9 significant versus high safety significant items.
l 10 So Mr. Jones is looking at the analysis burden 11 part, and particularly there are a number of paragraphs in 12 there that talk about how to address the aggregate effect.
13 I think because we are dealing with categorization, and
/~N
( )
k/ 14 high low categories, we do expect licensees to do 15 importance measures and to have a respectable PRA. I 16 mean, you don't want to come up with the wrong answers.
17 You do want the right answers.
18 But how much additional work, in terms of 19 really convincing yourself absolutely, 100 percent sure, 20 that you've got all of the high items in the high category 21 and the low ones in the low, perhaps that level of proof 22 has been too high, considering that if you get a few wrong 23 there is really not all that serious a problem. I mean, 24 there still are corrective action programs, and there is
,-m
(,
) 25 performance monitoring involved. So if you make a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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222 1 mistake, there are built-in corrective actions.
,s 2 So we're looking at lowering the hurdle a ,
3 ,
L
'~'
) l 3 little bit on how much analysis is required. And I think 4 Suzie has been talking to her QA people and looking at how 5 much flexibility you can really find in the regulations l
6 with respect to, you know, allowing for grading i
7 commensurate with safety. And I think what we'd really I 8 like the committee to do is rather than start over again !
l 9 and rereview the documents, we would welcome a letter from 10 the committee which says, "You weren't so impressed with 11 the version you had before."
12 But you recognize that the staff has at least I 13 acknowledged that this needs to be addressed, and at least 6
n 1
\- ' 14 we've told you that some,of this is what we're working on.
15 And what we really want you to do is not to tell us, 16 " Don't send it out for comment," because we think what we 17 need is -- is we need that comment period.
18 I think we need to put a message in there that 19 says we are more responsive than perhaps the feeling of 20 the document before. But until we get it out there in the 21 public arena, we're really not going to be making any 22 progress. And holding it back at this stage is probably 23 not helping really get us to the end point any faster.
24 So, Suzie, you wanted to comments on the p._
( ,) 25 graded QA aspects. Maybe we can --
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223 1 VICE CHAIRMAN POWERS: Can we come back to I
.-m 2 that?
( )
3 MR. HOLAHAN: Yes. l l
4 VICE CHAIRMAN POWERS: After we've listened to l 1
5 this presentation, I'd like to come back to that issue of 6 what you'd be receptive to, and what you would like not to 7 hear.
8 MR. HOLAHAN Okay.
9 MS. BLACK: Thank you. I, unfortunately, 10 wasn't here on I think it was Friday afternoon when this 11 discussion of the timid regulatory guide took place. But 12 I did read the transcript, and I went back and I read the 13 reg. guide with an open mind. I have read many, many
'0 14 revisions of this document, and I think as you get a few 15 changes along the lines of --
16 (Laughter.)
17 -- you lose sight of the big picture. So I 18 went back and I read it with an open mind, based on the 19 comments that the ACRS made on Friday afternoon, I think 20 it was the 21st of February. And I have to agree that it 21 seems like it has a slant of what we're going to require 22 more in the way of QA for things that weren't safety 23 related than it does for what we're going to give up as 24 far as what has to be done under the QA program for that
,a
{) 25 low safety significant structure systems and components.
! NEAL R. GROSS I COURT REPORTERS AND TRANSCRIBERS
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l (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234-4433
i 224 1 And so we will revise the guide to some extent fs 2 before we would issue it for public comment to show the
! i 3 flexibility, and to just change the flavor of it so that i 4 it doesn't look like it's a piling on of requirements.
5 I know the industry is anxious to see the 6 regulatory guide, and I wanted to go back to our basic 7 objective in graded QA, which we stated a couple of years 8 ago in a Commission paper that we see it as a safety 9 benefit and a cost savings, and the safety benefit comes l
10 from applying more QA to things that are more important. >
11 And it's cost savings because you can cut back on things 12 that are less important.
13 Our objective is to make sure that safety
(Tl
(~. 14 concerns are addressed. One of the issues that we had 15 from the very beginning was to make sure that you didn't 16 have a lot of components in low safety significant 17 applications, that perhaps there could be some defect that 18 creeps in and affects a whole lot of systems at one time.
19 But we think we can deal with that issue. !
20 We want to make fairly certain that the high 21 and low determinations are correct, as Gary said. We just i
22 want to make sure that we don't have a lot of things in i 23 the low category that could get you into trouble if you 24 made a mistake. But I think that the PRA requirements l r~
(3) ,
25 that they've put in this document have at least gotten us 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 1
225 1 to that point, if not beyond.
~ 2 And also, the key underpinnings of our program I )
3 to begin with was that there would be a good root cause 4 and corrective action program for low safety significant 5 structure systems and components, and that that would be 6 based on having adequate documentation to support the 7 program. And that document would not only permit a good 8 root cause analysis and a corrective action program, but 9 it would also be able to identify where similar components 10 were located in the plant. If you found a problem with 11 one Rosemont transmitter, you could locate the rest of 12 that batch.
13 Although we could have some flexibility in
,a
\ ,
s/ 14 that sense, even if the licensee wanted to take -- I guess 15 it would be more of a financial responsibility for not 16 knowing where each particular batch was, then they'd have 17 to go look at all of them. So it would be a judgment up 18 to them of how much documentation they wanted to keep.
19 And also, one of the other important 20 mechanisms for graded QA is the feedback process where if 21 you have made a mistake in the risk categorization that 22 you can determine that and then change it if that comes to 23 light, as well as looking at failures to see if perhaps 24 more QA would buy you something, whether you'd need to (n) v 25 change your program.
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226 1 Licensees can propose how to address the 18 3 2 criteria when they come in with their QA plan changes to
- \
~'
3 take advantage of this regulatory guide, and they can make 4 a case for how much is enough for each of the 18 criteria.
5 But for the low safety significant structure systems and 6 components, what we think is the most important is the 7 corrective action and the root cause.
8 Appendix B does have flexibility built in, and 9 if a licensee chooses to propose no controls for one of 10 the criteria, we'll consider it in our review process.
11 Our inspection program -- we intend to focus 12 on the failures and not look at the program for low safety 13 significant items. We would focus mostly on the
- 4
-' 14 corrective action and the feedback portions of the QA 15 program, and this would be a reactive inspection, although 16 we are still considering the idea of whether we need to do 17 a baseline inspection or graded QA like we've done for the 18 maintenance rule.
19 We met with NEI and several of the volunteer 20 p' ants on February 27th, last Thursday, and they are 21 anxious to get the guidance document. They talked about 22 the cost savings that they think are possible with graded 23 QA, especially in the procurement area.
24 VICE CHAIRMAN POWERS: I'm sure that the
(
( ,! 25 plants are acutely aware of the cost savings. Have you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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227 1 been able to get a similar awareness of the regulatory es 2 advantages of focus that comes with graded QA?
7
%) 3 MS. BLACK: Do you mean in the dollars and 4 sense standpoint or --
5 VICE CHAIRMAN POWERS: Manpower. I'd accept 6 almost any measure. Okay? But I'm perfectly willing to 7 let the plants worry about their cost savings.
8 MS. BLACK: Right.
9 VICE CHAIRMAN POWERS: I am much more 10 interested in knowing about what do we get doing this 11 graded quality assurance that makes the plants at least as 12 good as they were, and hopefully even better. And 13 efficiency that we get within the NRC as a functioning O' /
- 14 organization, it's the quality of its jobs and the 15 manpower it has to apply to those jobs. Do we have an l 16 understanding of what we can gain out of this?
17 MS. BLACK: I think it's more of a qualitative 18 understanding that as licensees have done these risk 19 categorizations, especially for the maintenance rule, 20 several non-safety related items come into the high 21 category, like for instance feedwater, because they are l
l 22 initiators but they aren't typically called safety l
l 23 related.
24 And as far as the cost to the licensees of
.rh
( ,) 25 adding quality assurance controls, it's not really clear i NEAL R. GROSS
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-228 1 whether there would be that much cost, because as I 2 understand'it, because-these same structure systems and rO 3 components often are important economically to the' plants, 4 that they already may be doing everything that we're 5 asking them:to.do under graded QA.
6 And so that you may get some: increase in 7 safety but not at much of a cost, because it's not.really 8 clear yet what kind of change they'd have to. implement to 9 apply more QA, in the regulatory sense,'to these systems.
b 10 MR. HOLAHAN: I'm not sure that we're.ever 1
l 11 going to get a measure of the advantage that you get by
! 12 focusing on the more important stuff and, you know,
!~
13 putting less attention on less important stuff. I think
/
-1t 14 you feel sort of -- it must be true that ,there is some 15 benefit to doing such a thing. It seems to make such ,
16 sense.
17 I don't know anyone who has measured such a 18 thing, and, you know, I don't think that we're going to 19 try. I'm not sure what you would get if you did.
20 MS. BLACK: And as far as the resource savings 21 in NRC, I don't think we've even considered that as one of 22 the aspects of this either.
23 MR. HOLAHAN: Yes. I think probably.both -- )
24 you know, the other thing that Suzie mentioned was, you
() 25 know, doing this program also captures some high safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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229 1 significance items that have been either ignored or g -. 2 treated differently in the past. That is probably easier
( i
'~'
)
3 to quantify. But even that is hard to say, you know, how l
I 4 much of a benefit there is.
5 I think you know that it's one of those casea 6 where you seem to know that you're doing the right thing l 7 because it's in the right direction. But I don't see any 8 easy measures of, you know, how much progress you're 9 making.
10 VICE CHAIRMAN POWERS: The cost savings of it 11 are tangible, measured, and frequently cited. That's not 12 why I'm interested in this program. I'd like cost savings 13 because I know that makes more resources available for
,/ 3
? ?
xJ 14 safety kinds of issues and what not, but I'm more 15 interested in what we can achieve in the safety realm here 16 than I am on cost savings. I'm sure the plants give 17 attention enough for both of us in that area.
18 MS. BLACK: Well, one of the things that we've 19 talked to the licensees about is changing their audit 20 schedules. And in the past, we've had a very prescriptive 21 requirement for how often they go back and do audits of 1
22 certain areas. And under the graded QA process, we have 23 looked at different audit schedules, both under the graded 24 QA and through other proposals that licensees have come in
/s
) 25 with where they would look at indicators and decide w/
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230 1 whether they need to do an audit in an area or not.
, - , 2 And then they could reprogram their resources I )
~'
3 to audit areas where they've seen more problems, where 4 it's more important from a safety standpoint than just 5 going back and doing a corrective action audit every six 6 months, even if they haven't seen any indicators of 7 problems. So that's one area where we see a benefit, a 8 safety benefit.
9 MEMBER KRESS: Dana, in order to have some 10 measure of what you're talking about, I think you have to 11 have a correlation between QA as graded and reliability of 12 components. And I just don't think that exists.
13 VICE CHAIRMAN POWERS: No, we just dcn't have 7 -
t 4 V 14 that.
15 MEMBER KRESS: Yes. .
16 MS. BLACK: The age-old question.
, 17 VICE CHAIRMAN POWERS: Well, what we do have l l
l 18 is an allowance in the regulations for flexibility if we j l'
19 can find a rational basis for it. And we've got a 20 rational basis now, and I think we just need to take care 21 of that.
22 Graded quality assurance suffered before the 23 subcommittee, because the aspirations were so high and the 24 reality was so -- felt farther from those aspirations than
/~'s
! ) 25 it did in the other areas.
%/
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231 l
1 MS. BLACK: I can see that. '
1 I
2 VICE CHAIRMAN POWERS: I'm sure that's a I (o\
\
u.Y 1
3 prcblem. '
4 MS. BLACK: And I can see that from reading 5 t.he reg. guide again with a fresh set of eyes. I could 6 see where it was coming through at a slant of what we were ;
7 requiring versus what we were going to permit licensees to 8 back off on.
9 Another interesting thing that came out of the 10 meeting last week with NEI and the volunteers was a new 11 proposal on performance monitoring. That has always been 12 an area of concern, and how do you monitor the impact of 13 graded QA? And they touched on a new proposal, and South s
7\ i
\w) 14 Texas may volunteer to pilot this approach. We don't know 15 much about it. We'd say we'd follow up at another 16 meeting, but --
17 VICE CHAIRMAN POWERS: He volunteered in the 18 meeting.
19 (Laughter.)
20 We got him on record, boy.
21 (Laughter.)
22 MS. BLACK: And NEI also stated at that 23 meeting that they think that graded QA is a great place to l
l 24 test performance-based monitoring. It's a good
( ) 25 opportunity to see what it can get you.
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232 1 I think it's important to understand that when 73 2 we formulated the regulatory guide, we had certain
- i LJ We would 3 regulatory constraints that we had to deal with.
4 like to promote interaction and timely feedback from the 5 industry. We think their feedback will be important, and 6 they are anxious to look at this reg. guide. The 7 volunteer plants especially are concerned about how this 8 reg. guide is different from what they're doing, so that 9 they can assess whether they are going down the right path 10 or the wrorg path.
11 We are working on revisions co the reg. guide.
12 I did some already this week, and we're going to do more 13 before we issue it for public comment. The --
- i N/ 14 VICE CHAIRMAN POWERS
- How have you formulated 15 the questions that you're going to pose for those public 16 comments now, or finalized them?
17 MR. KING: No, not in the graded QA area. I 18 think that's one that is evolving as we have been i 1
19 discussing this over the past couple of weeks. So I think 20 the set of questions I'll give you tomorrow is probably 21 going to be short in the graded QA area. But we do need 22 to settle exactly what we want to ask for.
i 23 VICE CHAIRMAN POWERS: I get the feeling what i
24 you're describing is I'm going to make -- let me put the (p ,
j 25 worst face on it, though I don't believe the worst face on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
l l (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 l
233 i
1 it.
73 2 MS. BLACK: Okay.
()
3 VICE CHAIRMAN POWERS: I'm going to slap l
4 together some quick fixes as I can, and I'm going to get 5 this out there fully with the intention of changing it in 6 response to the public comments. The committee was 7 worried precisely for your volunteer plants -- provide 8 volunteer plants the timely opportunity to assess the 9 delta. We were afraid they were going to look at this 10 delta and said, "Oh, my God. The delta is so far 11 different from what our aspirations are, let's give up."
12 MS. BLACK: I don't think that will happen, 13 because we try to keep an open line of communication with
/ T
\/ 14 them. And even if they did get that first impression from 15 reading it, I'm sure they'd call us before they pulled the 16 plug on it and we could have a dialogue.
+
17 VICE CHAIRMAN POWERS: And they fire-bombed 18 your house, or whatever they --
19 (Laughter.)
20 CHAIRMAN SEALE: That may be true for the 21 utilities that are involved in the graded QA pilot 22 studies. But I think you have to be very careful that as 23 you go through and make these changes, you make the point 24 that you are prepared to make some changes and that you do
()
,/'hz 25 need input from those other utilities. You don't want --
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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234 1 you know, what we said was what we saw was offputting, and 7- 2 you don't want to discourage those people that are not in
'~'
3 the game right now by seeing that offputting version.
4 MEMBER MILLER: Won't that in part be taken 5 care of? You're now I guess reinstituting dialogue with 6 NEI and trying to move the two documents together. Is 7 that what I look at here? Is that what I see in the last 8 bullet there?
9 MS. BLACK: Yes.
10 '4BER MILLER: I mean, I was kind of 11 disturbed when I saw that that kind of terminated some 12 time in '95.
13 MS. BLACK: Right. It did.
(^T/
F k/ 14 MEMBER MILLER: And that's restarting now.
15 MS. BLACK: I think based on our meeting last 16 week, we saw another coming together, a meeting of the 17 minds, that --
18 MEMBER MILLER: Won't this send a message to 19 the other plants that Bob Seale here is worried about l
20 that --
21 CHAIRMAN SEALE: I don't know how many of them 22 are going to know that message has gone out.
23 MS. BLACK: Well, it was inside NRC on 24 March 3rd.
g
( ,) 25 MR. HOLAHAN: But I think the point is we need i
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235 1 to do both.
,-- 2 MS. BLACK: Right.
3 MR. HOLAHAN: I think we do need to change the 4 flavor of the reg. guide in addition to looking for other, 5 you know, areas for communications with the industry.
6 VICE CHAIRMAN POWERS: And I'm very nervous 7 about informal lines of communication, because it is okay 8 for 10 percent not getting the word; 50 percent not 9 getting the word is very distressing.
10 MR. JONES: Well, I think along those lines, 11 again, I want to remind you we do intend to do workshops.
12 The workshops will not just be the general guide. They ;
13 will also include the application-specific guides. So I 1
(-~8 1 I_ 14 think we intend to go out, as we talked about the last l
l 15 time, to (quote) " sell" if you wish (unquote) the guides, l l
l 16 to make sure people understand what we're trying to 17 accomplish with them. And this is an area we will 18 certainly focus on on this one.
19 I also wanted to comment to what you said, 20 Dana, about I guess quickly throw together this document 21 with these revisions. We have been spending a fair amount 22 of time in looking at them carefully. I know Gary has, I 23 have, Suzie has, and I'm not sure even how many others 24 have, but Ashok has. We have spent some time looking at
^s 25 (v) them.
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236 1 I don't see -- I mean, Suzie can talk for her
,s 2 area probably better than I can, but I'm looking at her
? 8
~
3 area and I'm sure she's going to look at my area and give 4 me comments back, so that we cross-check each other that 5 the balance is there between the two. I have gone through 6 the analysis part. I anticipate the major changes will l
7 not be in the quantification -- I mean, in the 8 classification or ranking of the components.
9 I think that is done reasonably well, and in 10 fact is consistent with what we've seen from the pilot 11 program. So I don't anticipate we're going to change that j 1
12 very much. We will, however, back down on the back end l l
13 calculations. In fact, we will probably eliminate the
?~s 1
, i 1 N/ 14 guidance in that all together, and instead replace it 15 with, "These are some of our concerns at the back end,"
16 and you can address those.
17 For example, cross-component, cross-system l
18 commor mode failure potential. We were talking about l 19 doing calculations. That's a very difficult thing to do. .
l 20 We would have basically done a guess, got a number, and 21 I'm not sure we would have known what to do with it 22 anyway. At this point, we're looking at putting it out i
23 and saying you can address this in one of a myriad of 24 ways.
(~~)
( ,) 25 One of them could be to do a calculation, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
l (202) 234-4433 WASHINGTON, D C. 20005-3701 (202) 234 4433 l
237 1 assuming they fail, and show that it has minimal impact on .
,3 2 risk. You can tell us something about what you might do t :
I/
3 to treat the components upon receipt inspections. That 4 might have -- that reduces common cause failures, and that 5 might be a piece of your QA program.
6 You may do it by normal surveillance testing 7 and exercising, which will also tell us something about I l
8 the components and reduce cross-component failures. You l
9 might take care of it via your performance monitoring l
10 program. So we think that some combination, maybe one or 11 a combination thereof, of those kinds of thoughts will 12 deal with some of those concerns and take care of a lot of 13 the analytic burden that I think we were throwing in in 14 the back end, which is I think the biggest complaint we've 15 heard from the pilots anyway, and I think is the most 16 uncertain part of the analysis that we have put forth 17 anyway.
18 And that's where we anticipate we will modify 19 that section, and we're looking very carefully as to where 20 those area. We're looking for the words " bounded." We're 21 looking for high confidence words to make sure that we ,
l l
22 aren't putting burdens very high on the analysis that 23 aren't appropriate for this application. And that's the -
24 primary focus of what we're doing, and then we anticipate i 1
1 25 changing it along the lines of what I've just said.
l NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE N.W. l (202) 234-4433 WASHINGTON, D.C. 20005-5701 (20?) 234-4433 l
238 l 1 MR. HOLAHAN: Okay. I think that's our story.
73 2 I think you wanted to come back to this question of what
( )
~
3 might the committee say in its letter to the staff.
4 VICE CHAIRMAN POWERS: Yes. You're a little 5 bit asking us to buy a pig in a poke here.
6 MR. HOLAHAN: Yes. That's true.
7 VICE CHAIRMAN POWERS: And I guess what I ask 8 is: what is so different about graded QA from in-service 9 inspection that we have to have it in this package?
10 MR. HOLAHAN. Well, I think there is a 11 difference in the sense that in-service inspections, the 12 industry is working on a position. The staff isn't 13 holding anything up. I think in this area graded QA is
( \
-- 14 more than ready for change. I think it was ready for 15 change before we started putting it in as risk framework.
16 We are in danger of having, you know, risk 17 informed regulation which was supposed to be part of the 18 solution, turning out to be part of the problem. So I 19 think timing-wise, we are in the position of slowing down 20 the industry. I think we really will stand in the way of 21 progress. I think that's not the case for ISI because it 22 is in a much more developmental stage, and I think the 23 industry is pacing that. And at the moment, I think our 24 ability to get the reg. guide out on the street is really n
( ,) 25 what's setting the pace in the graded QA area.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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239 1 Now, I think this doesn't necessarily have to 2 be a pig in a poke. I think the committee can express its 73
)
3 concerns over what it saw very clearly, and leave the 4 burden on the staff to say, after all, we will have to go 5 to the Commission and explain to the Commission that these 6 concerns expressed by the committee are real, and that t 7 we've dealt with them in a responsible way.
8 So the only element of the discussion back 9 from the 21st that we'd like to change is that bottom line 10 that said you ought not to send it out. I think the 11 committee's concerns that the version of the document you 12 are given has a flavor that you think is 13 counterproductive, I think it's perfectly appropriate for
/ ~';
\_/ 14 the committee to say so.
15 And I think that leaves it to the staff to 16 say, yes, we recognize that. We've made changes here, 17 there, and this other place, to show the Commission that 18 we've been responsive to that in putting it out.
19 I think if you'll look at this decision sort 20 of the other way around, if the committee writes its 21 letter in such a way as to say " don't send it out," it 22 will be prejudging that the staff, you know, can't be 23 responsive enough to those concerns to address them before 24 it goes out for public comment.
( ,) 25 So, you know, I'd rather have the committee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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240 1 express its concerns.and give the staff the opportunity
,- 2 to --
/ 3 3 MR. HOLAHAN: The coup de grace is the problem 4 that you fear.
5 MR. KING: Yes. I agree with Gary. Just the 6 fact that we put it out for comment doesn't sweep your 7 concerns under the rug. Your concerns will still get 8 attention. You will still be elevated to the saa.e level 9 that they would have been if it was held up. So I agree, 10 I'd say let's put it out and let us work on it.
11 CHAIRMAN SEALE: Well, my concern is the 12 offputting again. I think if you send out a defective 13 version that you may be sending a very bad message to the
,m I
'x_s) 14 utilities, and you may not get the kind of constructive, 15 frank, and innovative response from the public comment 16 period that you want.
17 MR. HOLAHAN: I agree with that entirely, and 18 I have to tell you that when I reread the document I 19 decided that I would not support sending out that version.
20 Okay? But I think that, you know, given the discussions 21 that we've had and looking at areas where we are receptive 22 to changing the document, that we can make it into a 23 version that can go out and be helpful and move the
- 24 process along. And I think we can do that.
I
(,,. ) 25 MS. BLACK: And I also think if we put the l N _,/
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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241 1
1 right questions in the Federal Reaister notice with it, 2 and ask for constructive criticism, acknowledge that there
\)~'
3 may be some problems the industry may see with it --
4 CHAIRMAN SEALE: You can go a fair part of the 5 way and indicate that you're willing to negotiate even 6 further. l 7 MR. HOLAHAN: Yes. But that doesn't mean 8 we're going to put out a version that we don't like, and 9 I'd suggest that people can shoot at it. You know, I l 10 think we have the opportunity to make, you know, this into I 11 a respectable document.
12 VICE CHAIRMAN POWERS: Would it be an 13 imposition to ask that when Tom brings down his questions
,o .s
! )
v 14 that you've thought about and formulated that maybe you l l
15 could give us just a list of the topical areas that you l l
16 would pose questions in for the graded QA?
17 MR. HOLAHAN: We can try. I mean, I'm not -- l 18 VICE CHAIRMAN POWERS: I, truthfully, do not 1
l 19 want an imposition on you people. I think you must be l
20 close to death. I know you've been working very hard.
21 MR. HOLAHAN: But we're used to it.
22 VICE CHAIRMAN POWERS: You're used to it.
23 (Laughter.)
l l
24 This intensity? That's admirable. Maybe get .
f3 j t
) 25 a life, Gary.
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l 242 l l
1 (Laughter.)
j.3 2 But if you could give us an idea of the
( )
'~'
3 topical areas, and I'm certainly not asking for anything 4 very much more than a sheet of paper that's scribbled on, 5 so that we could understand where you see the questions 6 that you'd like further input on, that would be helpful in 7 understanding what we were getting.
8 MR. KING: Okay. We'll -- l l
9 VICE CHAIRMAN POWERS: I'm asking for at least l 10 a squeal on this piggy.
11 MR. KING: We'll give you our best shot at the 12 set of questions that will go along with this reg. guide. l t i l
13 VICE CHAIRMAN POWERS: But again, if you spend l
/_Ni r
\s' 14 more than a half an hour on it, you're overkilling --
15 MR. KING: I understand.
16 VICE CHAIRMAN POWERS: -- my interest here.
17 Are there people from industry that care to 18 comment?
19 I think we've saved you 15 minutes.
20 CHAIRMAN SEALE: Well, we can probably use it, 21 looking at all that's on the schedule. We want to thank 22 you very much for your willingness to come again today.
23 This is -- you know, we are beginning to wonder about all 24 of this time we're spending with each other.
S
() 25 VICE CHAIRMAN POWERS: It's the company NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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243 1 they're keeping.
r- S 2 CHAIRMAN SEALE: Yes, right. i f i
\. /
3 (Laughter.)
4 But we do want to tell you how much we 5 appreciate your willingness to respond to our desire to 6 see something tomorrow, and we look forward to hearing 7 from you then. And I'm going to call another 15-minute 8 recess, and then we're going to start on letters.
9 MEMBER KRESS: Bob, I'd like to note that 10 everybody in Tennessee knows that a poke is too little to 11 put a pig in.
12 (Laughter.)
13 (Whereupon, at 4:33 p.m., the proceedings in f
r T.
'd 14 the foregoing matter went off the record.)
15 16 1
17 l 18 ,
1 l
19 l 1
20 l
21 l 22 23 24 (x
) 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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/~
V CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
Name of Proceeding: 439" ACRS (OPEN SESSION)
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 Regulatory Commission taken by me and, thereafter reduced to i
\ 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.
1 A1 d ~
MA))L DONBETT RINER ' '
official Reporter Neal R. Gross and Co., Inc.
1 i
O l l
NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RiiODEISLAND AVENUE,NW :
(202)234-4433 WASil!NGTON, D.C. 20005 (202)234-4433 1
. _ - . - - . - - - . . ~ . _. . . . - . - . . _ - . - - - - - . . . - . - . .
. /
2 INTRODUCTORY STATEMENT BY THE ACRS CHAIRMAN 439TH ACRS MEETING, MARCH 6-8, 1997 THE MEETING WILL NOW COME TO ORDER. THIS IS THE FIRST DAY OF THE 439TH MEETING OF THE ADVISORY COMMITTEE ON REACTOR I SAFEGUARDS. DURING TODAY'S MEETING, THE COMMITTEE WILL CONSIDER-
! THE FOLLOWING:
I (1)
CAPABILITY OF RELAP5/ MOD 3 CODE TO ASSESS THE AP600-DESIGN j-(2)
RELEASE OF AP600 TEST DATA FROM ROSA TEST FACILITY (3) ARTHUR ANDERSEN REPORT, "
t RECOMMENDATIONS TO IMPROVE THE SENIOR MANAGEMENT MEETING PROCESS" 4
(4) RISK-INFORMED, PERFORMANCE-BASED REGULATION AND RELATED
- MATTERS (5) PROPOSED ACRS REPORTS 1
PORTIONS OF TODAY'S MEETING MAY BE CLOSED TO DISCUSS WESTINGHOUSE PROPRIETARY INFORMATION APPLICABLE TO THE AP600 DESIGN.
THIS MEETING IS BEING CONDUCTED IN ACCORDANCE WITH THE PROVISIONS OF THE FEDERAL ADVISORY COMMITTEE ACT.
J DR. JOHN T. LARKINS IS THE DESIGNATED FEDERAL OFFICIAL FOR THE INITIAL PORTION OF THE MEETING.
WE HAVE RECEIVED NO WRIT""N COMMENTS OR REQUESTS FOR TIME TO MAKE ORAL STATEMENTS FROM MEGERS OF THE PUBLIC REGARDING TODAY'S SESSIONS. A TRANSCRIPT OF PORTIONS OF THE MEETING IS BEING KEPT, AND IT IS REQUESTED THAT THE SPEAKERS USE ONE OF THE MICROPHONES, IDENTIFY THEMSELVES AND SPEAK WITH SUFFICIENT CLARITY AND VOLUME SO THAT THEY CAN BE READILY HEARD.
I WILL BEGIN WITH SOME ITEMS OF CURRENT INTEREST.
p.
n, * . , ,w-... - e ww,m-
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- : : t g fghN Ol/
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< S l t; r,. ft41z ~ ,,
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"\QS~ gh Y,
++**+
l ARTHUR ANDERSEN ASSESSMENT i OFTHE
, SENIOR MANAGEMENT MEETING PROCESS AND INFORMATION BASE l March 6,1997 Richard J. Bar rett
O O O '!
l .l OUTLINE i
- Chronology
- Arthur Andersen Methodology i
- Assessment of Senior Management Meeting Outcomes e Senior Management Meeting information base e Senior Management Meeting process ,
e Schedule for NRC evaluation and implementation t
i 2
O O O =l SENIOR MANAGEMENT
! MEETING PROCESS
- Outgrowth of 1985 Davis-Besse feedwater event
- Process repeated on six-month cycle
- Screening meetings to select " discussion" plants l
- Senior Management Meeting selects plants for I
formal action
- Trending letter
- Category 2: Plants requiring close NRC monitoring
- Category 3: Shutdown Plants that require NRC authorization to operate a
4 CHRONOLOGY e June 28,1996 SRM: Evaluate indicators that can provide an objective basis for judging whether a plant should be placed on or removed from the watch list e Staff adopted Arthur Anderen recommendation to j assess processes that use inspection and event information for judgments regarding plant performance
- Independent assessment of SMM by Arthur
- Andersen completed December 30,1996
- Idaho National Engineering Laboratory provided
- analytical support -
j
- NRC Senior Advisory Panel provided oversight at t key milestones in the study l
i 4
I
! ARTHUR ANDERSEN METHODOLOGY e Examined written record of Senior Management ;
Meetings from 1992 to 1996 e Interviewed NRC senior managers, regional inspection staff and utility executives l
e Conducted analytical studies of several candidate indicators l e Developed Performance Trend Charts with
, candidate action criteria e Developed an Integrated Performance Model l for NRC assessment process e Developed process map for the SMM 1
5
O O O
ARTHUR ANDERSEN ASSESSMENT OF SMM OUTCOMES .
- Current process identifies most poor performing plants for discussion
- Most NRC senior manager and utility executives interviewed agreed that plants on the watch list l were appropriately placed e Senior Management Meeting has sometimes been slow to take formal actions e Outcomes of Senior Management Meetings have not been consistent i
6
0 O O =l ARTHUR ANDERSEN FINDINGS AND RECOMMENDATIONS ON SMM INFORMATION BASE i
- NRC considered characteristics related to safety and risk in past decisions e NRC assessments tend to focus on root causes of events and other problems
- Recommend assessing management and .
operational effectiveness on an ongoing basis e information for making performance assessments remains inconsistent .
- Recommend re-engineering assessment ,
information to better support SMM
i FINDINGS AND RECOMMENDATIONS ON INFORMATION BASE (CONTINUED) l
- e Decision making process is highly subjective and minimally values objective indicators
- Recommend shift from subjective to objective factors
- The mass of unprioritized information inundates senior managers .
j
- Recommend restricting format and volume of information 8
.l FINDINGS AND RECOMMENDATIONS ON INFORMATION BASE (CONTINUED) e NRC uses a great deal of manual effort to i assimilate performance information 4
- Recommend continued effort to improve information access through automation
- Deregulation may cause economic stress
- Economic stress does not necessarily predict ,
changes to operating performance
- Recommend using new econoniic indicators ,
outside the SMM process 9
O O O l ,
l l
..l l
i i
ARTHUR ANDERSEN i
INTEGRATED PERFORMANCE MODEL !
I
) k )(
Performance ;
indicators
- 2 C
o z : Measures = Results 8
o
=
s> -
I 4 e 3
e x 2 Operations .m
- s O Effectiveness E m
e ,
E Economic Management i Indicators Effectiveness Economic Stress ___
Time l
l 10
ARTHUR ANDERSEN FINDINGS AND RECOMMENDATIONS ON SMM PROCESS
- Senior management meeting process is logically sound
- Senior Management Meeting process is dominated by the Regional Administrator e Roles of some senior managers not clear
- Recommend attaining better balance in participants' roles in decision process
- Recommend consideration of consensus decision-making techniques 11
i
~
FINDINGS AND RECOMMENDATIONS ON PROCESS (CONTINUED) e There are no clear criteria for various levels of NRC actions e Presentation of information not balanced and 1
structured
- Recommend presenting information in a rigorous and structured way
- Stakeholders do not understand SMM process and outcomes -
- Recommend developing a better process for compiHngthe public record of the SMM l
12 i
O O O ~!
. -l ARTHUR ANDERSEN PERFORMANCE TREND MODEL
- Tracks plants against nine individual indicators, including the seven NRC Performance Indicators plus enforcement and allegations
- A " hit" is any instance of exceeding twice the industry average for an individual indicator
- Each point on the plot represents a four-quarter moving sum of hits
- SMM action criteria based on trend in number of hits
- Meeting an action criterion would create a
" rebuttable presumption" 13
O O O t i
ARTHUR ANDERSEN PERFORMANCE TREND MODEL :
t Plant A i
I 0-Not Discussed 1 - Category 1 2-Discussed but No ActionTaken MPlant A AA Action j 3-Trending Letter 4 - Category 2 5 - Category 3 i > Plant A,NRC Action
-+- Plant A Performance f
--m- ALL PLANT AVERAGE 5 ^
16 4~ 14 i m 12 3 10 m x l 8 4 z 2 5 W 9 ___M ____
-I5 t = = -
6 1
O ::
0 E E E E E E E E E E E E E E*I I E E E E E E 9 E 8 E E E E E E E 8 E 8 E E E 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 TIME 14 i
O O O ~!
1 STAFF REQUIREMENTS MEMORANDA
- Encourage staff to continue
- Emphasis on the screening meetinge
- Plant Performance Template
- Consistency of SMM with other NRC evaluative processes
- Make process more readily transparent to public j l
i 15
IMPLEMENTATION MILESTONES
- Commission Paper on implementation plan 4
by March 31
- Options for process changes
- Plan for development of management and operational effectiveness measures and criteria e Commission policy guidance
RECOMMENDED PROCESS
- Select discussion plants using Trend Charts and decision criteria
- Prepare SMM input using Evaluation Sheets and Trend Charts
- SMM discussions focus on rebuttable presumption
- Brief Commission on decisions, including rationale for all accepted rebuttals
- Document results, including accepted rebuttals 17
o o o y MONITORING PROGRAM i EFFECTIVENESS
- Track number, type and nature of accepted rebuttals
- Adjust indicators, measures and criteria based i on experience
- Monitor important NRC processes for consistency
- Verify accuracy of licensee-based information i
18 i
o o o ')
ECONOMIC INDICATORS PROPOSED i
l BY ARTHUR ANDERSEN e Operating Cost per Kilowatt Hour e Debt-to-Equity Ratio !:
e Operating Cost Trend
- Capital Spending Trend i
- Percent of utility generating capacity from nuclear '
19
O O O INDEPENDENCE AND DIVERSITY IN THE SENIOR MANAGEMENT MEETING PROCESS
- e Independence of information sources
- inspection, reporting and allegations e Diverse process criteria: SALP, Escalated enforcement, Significant Events i
e Independence of ownership
- Regions, OE, NRR: Escalated enforcement
- AEOD, NRR: Significant Events Panel
- 01: Investigations 20
- -\
~
United States -
\f'~)\.....
Nuclear Regulatory Commission REGELATORY GLIDES AXD STANDARD REVIEW PLANS IX SLPPORT OF RISK INFORMED REGELATION PRESENTATION TO ACRS FELL COWMITTEE MARCH 6,1997 t
Gary Holahan, NRR (415-2884)
Thomas King, RES (415-5790)
Robert Jones, NRR (415-2198)
Mark Cunningham, RES (415-6189) l
~
-l INTRODUCTION e FOLLOWING ISSUANCE OF THE COMMISSION'S POLICY STATEMENT ON PRA, DRAFT R.G.S AND SRPS HAVE BEEN PREPARED TO*
PROVIDE GUIDANCE ON AN ACCEPTABLE METHOD AND PROCESS FOR CONSIDERING RISK INFORMATION IN PLANT SPECIFIC CHANGES TO THE CURRENT LICENSING BASIS (CLB)
ENCOURAGE LICENSEES AND STAFF TO UTILIZE RISK INFORMATION TO:
e IMPROVE DECISION MAKING e BETTER UTILIZE RESOURCES e REDUCE UNNECESSARY BURDEN e DRAFT R.G.S AND SRPS COVER:
GENERAL GUIDANCE ON PROCESS, GUIDELINES, DOCUMENTATION SPECIFIC GUIDANCE FOR TECH SPECS, IST, GRADED OA ISI ON A LATER SCHEDULE l 1
s INTRODUCTION (CONTINUED) e DRAFT NUREG (NUREG-1602) ALSO PREPARED AS REFERENCE DOCUMENT ON SCOPE AND QUALITY OF PRA e DOCUMENTS READY FOR PUBLIC COMMENT e PURPOSE OF STAFF PRESENTATION:
SUMMARIZE CHANGES IN DOCUMENTS SINCE 2/20-21/97
- - SUBCOMMITTEE MEETING SUMMARIZE ITEMS TO BE DONE IN CONJUNCTION WITH PUBLIC COMMENT PROCESS j SUMMARIZE IMPLEMENTATION PLAN ADDRESS PREVIOUS ACRS COMMENTS ON GRADED QA REQUEST ACRS LETTER ENDORSING ISSUING DOCUMENTS FOR PUBLIC COMMENT AND STAFF PLANS FOR ' IMPLEMENTATION j i
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- O O O*l-ROLE IN REGULATORY PROCESS e USE OF R.G.S AND SRPS IS VOLUNTARY ON LICENSEES:
REPRESENTS ANOTHER ACCEPTABLE WAY TO CHANGE THE Cl3 (I.E., IMPLEMENT 10CFR50.90-92)
NOT AN ADDITIONAL BURDEN NOT A BACKFIT STAFF WILL UTILIZE RISK INFORMATION, WHERE APPROPRIATE, IN ITS REVIEWS AND WILL GIVE PRIORITY TO APPLICATIONS FOR BURDEN REDUCTION THAT UTILIZE RISK INFORMATION e OVERALL APPROACH DESCRIBED IN R.G./SRP COULD ALSO APPLY TO MORE THAN PLANT SPECIFIC CLB CHANGES 3
CHANGES TO THE CURRENT LICENSING BASIS STAFF PROPOSES INCREASED REQUIREMENTS - USE 50.109 BACKFIT RULE (REG. ANALYSIS GUIDELINES) a
" CURRENT LICENSING BASIS" LICENSEE REQUESTS CHANGE CONSISTENT LICENSEE MAKES CHANGE wITH APPROVED STAFF POSITION CONSISTENT WITH 50.59 (RULE, RG, SRP, BTP...) PaoCESS
("NonMAL" STAFF REVIEW
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i LICENSEE REQUESTS A CHANGE IN REQUIREMENTS BEYOND ANY APPROVED STAFF POSITIONS -
10CFR50.90-92 DOES NOT PRESENT DOES PRESENT RISK RISK INFORMATION INFORMATION
" NORMAL STAFF "USE RISK-INFORMED REVIEW" RG/SRP" ,
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CHANGES TO GENERAL R.G./SRP SINCE 2/20-21/97 SUBCOMMITTEE MEETING
- EXPANDED FOREWORD TO NOTE USEFULNESS OF PRINCIPLES, '
PROCESS AND APPROACH TO OTHER ACTIVITIES APPLYING i RISK INFORMATION
- ADDED ADDITIONAL WORDS IN R.G. ON ACCEPTABILITY OF QUALITATIVE FACTORS IN THE INTEGRATED DECISION PROCESS e MODIFIED R.G. DEFINITION OF LERF TO BE CONSISTENT WITH APPD B (E.G., LERF DOES NOT INCLUDE SCRUBBED RELEASES)
- EMPHASIZED THAT PHILOSOPHY OF DEFENSE-IN-DEPTH IS TO BE PRESERVED e CLARIFIED THAT LESS THAN FULL SCOPE PRA INFORMATION MAY BE USED 5 j
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ITEMS TO BE DONE IN CONJUNCTION WITH THE PUBLIC COMMENT PROCESS e GENERAL R.G./SRP:
ASSESS NEED FOR GUIDANCE ON TEMPORARY INCREASES IN RISK REFINE APPD B ON ESTIMATING LERF (E.G., SHUTDOWN CONDITIONS, EXTERNAL EVENTS) -
DEVELOP REFERENCE NUREG/CR DOCUMENTING LERF ESTIMATION METHOD (APPD B)
REFINE GUIDANCE ON TREATMENT OF UNCERTAINTY ASSESS EXPANDING ROLE OF PERFORMANCE MONITORING AS PART OF INTEGRATED DECISION MAKING j l,
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o o o7l ITEMS TO BE DONE IN CONJUNCTION WITH THE PUBLIC C0l#IENT PROCESS (CONTINUED) i e APPLICATION SPECIFIC R.G.s/SRPs: ;
REEVALUATE TS LIMIT ON CORE DAMAGE PROBABILITY.
DURING A0T e COMPLETE REVIEW OF PILOT APPLICATIONS AND FEEDBACK OF EXPERIENCE I
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IMPLEMENTATION PLAN MILESTONES FOR FINALIZING REGULATORY GUIDANCE e DRAFT GUIDANCE DOCUMENTS ISSUED FOR PUBLIC CODG4ENT 4/97 (PENDING CODG4ISSION APPROVAL) e PUBLIC WORKSHOP (S) ON DRAFT GUIDANCE DOCUMENTS .6/97 '
e PUBLIC COMMENT PERIOD ENDS 7/97 e ACRS BRIEFING ON RESULTS OF WORKSHOP AND 8/97 !
SIGNIFICANT PUBLIC CODG4ENTS e PuBLIC CODG4ENTS CONSIDERED AND REVISED DOCUMENTS 10/97 FORWARDED TO ACRS AND CRGR e ACRS PRA SUBCOMMITTEE BRIEFING 11/97 e FULL ACRS BRIEFING 12/97 e FINAL DOCUMENTS FORWARDED TO THE COMMISSION 12/97 l e TRAIN PMS AND REVIEWERS 12/97 t
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&VA GRADED QUALITY ASSURANCE l j e STAFF POSITIONS
- Documentation and Corrective Action Expected to Remain Strong
- For LSSCs, Will Allow Grading of Appendix B Controls and Expect Minimal Controls for Some Aspects of Program O
- Will Inspect LSSC QA Based On Performance
- Considering Need for Baseline Inspections of I GQA l
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- O GRADED QUALITY ASSURANCE l
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- MEETING WITH NEI ON 2/27 l
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- Volunteer Plants Want to Obtain the GQA j Regulatory Guide i
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- Significant Cost Savings Possible with GQA O - V lunteer Plants Are Concerned With Potential Delta Between RG and Their Programs
- NEI Proposed Conceptual Monitoring Approach to Integrate with Graded QA
- NEI Belief That GQA Provides Greatest Opportunity For Performance Based Approach O
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GRADED QUALITY ASSURANCE io 1 i
- e NRC STAFF ADVOCATES ISSUANCE OF l DRAFT REGULATORY GUIDE l - Staff Has Formulated RG Within Regulatory
! Constraints
) - Will Promote Interaction and Timely Feedback j From Industry
! - Will Provide Volunteer Plants Timely
- Opportunity to Assess Delta
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- Staff Will Revise RG to be Consistent With Its l Position on GQA i
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- - GQA Elements Are Similar to Evaluation Guide l Issued to Industry 1/96
! - RG Based On Lessons Learned Through j Volunteer Plant Evaluations + January,1996 Staff j Evaluation Guide
} - NEI Stated (at 2/21 ACRS) Desire to Continue l With Incremental Development I i l lO l
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