ML20137Q204
| ML20137Q204 | |
| Person / Time | |
|---|---|
| Issue date: | 04/03/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| FACA, SECY-97-076, SECY-97-076-R, SECY-97-76, SECY-97-76-R, NUDOCS 9704100155 | |
| Download: ML20137Q204 (28) | |
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POLICY ISSUE (Information)
April 3, 1997 SECY-97-076 FOR:
The Commissioners FROM:
L. Joseph Callan Executive Director for Operations
SUBJECT:
QUARTERLY STATUS UPDATE FOR THE PROBABILISTIC RISK ASSESSMENT (PRA) IMPLEMENTATION PLAN PURPOSE:
To present a quarterly update on the progress of activities in the PRA Implementation Plan, including the development of risk-informed standards and guidance; and to respond to those items in the staff requirements memorandum of January 22,1997, for which the Commission has requested a staff response in this calendar quarter.
BACKGROUND:
In a memorandum dated January 3,1996, from the Executive Director for Operations to Chairman Jackson, the staff committed to submit quarterly updates on the status of its development of risk-informed standards and guidance. Previous updates on the status of activities in the PRA Implementation Plan, including the status of the staff's development of risk-informed standards and guidance, were sent to the Commission on March 26, June 20, and October 11,1996, and on January 13,1997.
DISCUSSION:
The staff has updated the status of activities in the agency's PRA Implementation Plan in. Significant achievements in the past quarter follow-D'
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The staff has incorporated proposed resolutions of the policy, technical, and process
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issues in new drafts of (1) the broad-scope general regulatory guide (RG) and standard g)
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review plan (SRP) and (2) the application-specific RG and SRP for inservice testing (IST),
U graded quality assurance (GQA)(RG only), and technical specifications (TS), and has discussed these new drafts with the Advisory Committee on Reactor Safeguards (ACRS)
CONTACT:
NOTE:
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The Commissioners ;
I and the Committee To Review Generic Requirements (CRGR). Both the ACRS and the CRGR have reviewe:d the guidance and concurred in the staff's proposal to issue the guidance for comme.nt by the public. By the end of March 1997, the staff intends to forward the draft guidance documents to the Commission and request its approval for i
issuing the documents for comment by the public.
i In completing the draft RGs and SRPs to date, the staff has found that a greater than i
expected effort is required to consider all points of view and gain a concensus on draft l
guidance. With this experience and, because submittals from industry on inservice inspection (ISI) are delayed, the staff projects that the draft ISI RG and SRP will not be issued before July 1997 and the final RG and SRP will not be issued before February 1998.
Regarding the pilot,)rogram for risk-informed technical specifications (TS), the staff has prepared a safety evaluation to provide the basis for granting the amendments for TS-allowed outage times (AOTs) for the safety injection tanks and low-pressure safety injection system at the lead plant, which is Arkansas Nuclear One, Unit 2 (ANO-2). The j
safety evaluation will be forwarded to the Commission shortly, in a separate Commission paper. Issuance of the ANO-2 amendments will complete Task 1.2 of the PRA implementation Plan for the pilot application regarding technical specifications.
in February 1997, the staff published interim Revision 8 of NUREG-1021, " Operator e
Licensing Examination Standards for Operating Reactors." This revision to the operator i
licensing process treats the application of risk insights in operator licensing (Task 1.4).
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Licensees will implement the interim revision voluntarily until such time as NRC requirements in 10 CFR Part 55 are amended. The staff is developir.g a proposed revision to 10 CFR Part 55.
j The staff completed nine more maintenance rule baseline inspections, which included l
e inspection of licensee methods for applying PRA in maintenance programs as well as inspection of safety assess'ments licensees perform when removing equipment from service for maintenance in accordance with Paragraph (a)(3) of the maintenance rule.
l The staff has now cornpleted a total of 21 inspections. The staff intends to inspect all j
reactor sites by the third quarter of calendar year 1998.
l Six senior reliability analysts (SRAs) have completed their initial training requirements and e
are preparing certification request packages for review by the SRA Oversight Panel.
These SRAs are currently working in their permanent positions at headquarters (HQ), and in Regions I,11, and IV.
The staff wishes to note that, in regard to the regulatory effectiveness evaluation (Task 1.7), they intend to include recent insights on the risks of pressure-induced and thermally-induced steam generator tube ruptures (SGTR) in determining whether there is adequate closure of severe accident issues addressed in the station blackout rule. This will involve consideration of the interrelationships between the induced SGTR issue and reactor coolant pump (RCP) seal failure and station blackout issues. Because potential backfits may draw benefits for averted risk from multiple related severe accident issues, it is important to consider such interrelationships in deciding whether further backfitting is warranted in these areas.
The Coinmissioners In its January 22,1997 staff requirements memorandum (SRM), the Commission requested that in the March 31,1997, update of the PRA Implementation Plan, the staff describe how performance monitoring is being addressed in the current PRA pilot applications and, where appropriate, other planned performance-based approaches, including treatment of the four key technicalissues associated with performance monitoring presented to the Commission in the October 11,1996 update of the PRA implementation Plan (SECY-96-218). The four key technical issues are (1) the scope of systems, structures, and components (SSCs) to be.
monitored, (2) selection of performance characteristics, (3) process for performance monitoring, and (4) feedback of results into program implementation. The Commission requested that for maintenance rule implementation activities, the four issues be discussed in the context of the inspection process. Attachment 2 addresses the Commission's request made in the January 22, 1997, SRM.
COORDINATION:
The Office of the General Counsel has reviewed this paper and has no legal objections to its issuance.
L.
sep Callan ecutive Director for Operations Attachments:
As stated DISTRIBUTION:
Commissioners OGC OCAA OIG OPA OCA ACRS EDO SECY
ATTACHMENT 1 QUARTERLY STATUS UPDATE OF THE AGENCY-WIDE i
IMPLEMENTATION PLAN FOR PROBABILISTIC RISK ASSESSMENT (PRA)
(from January 1,1997 to March 31,1997) l
SUMMARY
OF SIGNIFICANT PROGRESS (1)
Reaulatory Guide (RG) and Standard Review Plan (SRP) Development (Tasks 1.1 and 2.1)
The staff incorporated its proposed resolutions of policy, technical, and process issues into new drafts of (a) the broad-scope general regulatory guide (RG) and standard review plan (SRP) and (b) the application-specific RG and SRP for inservice testing (IST), graded quality assurance (GQA) (RG only), and technical specifications (TS). The staff discussed the new drafts with senior agency management, the Advisory Committee on Reactor Safeguards (ACRS), and the i
Committee to Review Generic Requirements (CRGR) in a number of meetings held over the past i
three months. Both the ACRS and the CRGR have completed their reviews of the guidance and I
concur in the staff's proposal to issue the guidance for comment by the public. By the end of March 1997, the staff intends to forward the draft guidance documents to the Commission and request Commission approval for issuing the documents for comment by the public. In completing the draft RGs and SRPs to date, the staff has found that a greater than expected effort is required to consider all points of view and gain a concensus on draft guidance. With this experience and, because submittals from industry on inservice inspection (ISI) are delayed, the staff projects that the draft ISI RG and SRP will not be issued before July 1997 and the final RG and SRP will not be issued before February 1998.
(2)
Pilot Applications (Task 1.2)
The staff is reviewing a quality assurance (QA) program revision submitted by Houston Power and Light (South Texas) on January 21,1997, in response to a staff request for additional information (RAI). The staffis continuing to review a submittal from Arizona Public Service Company (Palo Verde) dated September 12,1996, that outlines plenned enhancements in Palo Verde's procurement process based on previous staff evaluations. On Februaiy 27,1997, the staff met with Nuclear Energy institute (NEI) representatives and staff from the two volunteer plants to discuss the GQA initiative. At that meeting, industry representatives articulated a conceptual approach for a performance-based monitoring methodology that they propose be integrated with the GQA pilot implementation.
Regarding the risk-informed TS pilot application, the staff is preparing the safety evaluation to provide the basis for granting amendments for the extension of TS allowed outage times (AOTs) for the safety injection tanks and low-pressure safety injection system at the lead plant. The lead plant is Arkansas Nuclear One, Unit 2 (ANO-2). The safety evaluation is undergoing management review and will be forwarded to the Commission shortly, in a separate Commission paper issuance of the ANO-2 amendments will complete Task 1.2 of the PRA implementation Plan for the technical specifications pilot application.
Regarding the risk-informed inservice testing (RI-lST) pilot applications, the staff recently sent a second RAI to the licensee of the Comanche Peak Steam Electric Station (CPSES) and the Palo Al-1
1 Verde Nuclear Generating Station (PVNGS). The second RAI was based primarily on proposed staff positions as described in the draft Rl-IST regulatory guide and standard review plan. The i
second RAI also contained questions based on Oak Ridge National Laboratory's review of Nuclear Plant Reliability Data System (NPRDS) data on pumps and valves at the pilot plant sites.
Because of ongoing work on the draft risk-informed RGs and SRP sections, the staff will need a furtherinformation request in addition to questions contained in the second RAl. It is anticipated that the final RAI will be sent to the RI-IST pilot plant licensees shortly after the draft RI-IST RG and SRP are issued for public comment.
Significant PRA-related technical support has been provided for the agency's maintenance rule i
(MR) baseline inspection effort. The goal of the MR baseline program is to conduct a full team inspection at each reactor facility in the first two years following the implementation date of the rule (July 10,1996). To date,21 fullinspections have been conducted. These inspections have been conducted with the support of experienced staff and contractor personnel trained in the use of PRA, using an inspection procedure that focuses on the inspection and assessment of the relevant PRA-related technical aspects of the NRC-approved industry guideline for implementing the rule (i.e., NUMARC 93-01).
For risk-informed ISI, the staff has not received any of the pilot plant submittals. Because of this significant delay, the staff will not complete its review regarding the acceptability of pilot plant applications until April 1998.
(3)
Trainina for Inspectors (Task 1.3)
Six SRAs have completed their initial training requirements and are preparing certification request packages for review by the SRA Oversight Panel. These SRAs are currently working in' their permanent positions at HQ, and in Regions I, ll, and IV. Two additional SRAs are expected to be ready for certification in June 1997. Two vacant SRA positions in Region ill are being posted.
The staff is continuing to develop a new PRA course series for inspectors and other technical personnel within the reactor program. This PRA Technology and Regulatory Perspectives course will address the special needs of regionalinspectors, resident inspectors, and other technical personnel who require knowledge of probabilistic risk assessment (PRA) issues and insights to perform better evaluations of the effects of design, testing, maintenance, and operating strategies on system reliability. Presentation of the pilot course is planned for May
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1997. It is anticipated that the PRA Technology and Regulatory Perspectives course will replace Inspection Manual Chapter (IMC) 1245 requirements for the PRA Basics for Regulatory Applications course for NRR and regional employees. The staff plans to offer the course four times a year.
(4)
Application of Risk insiahts in Operator Licensino (Task 1.4)
The staff recommended in SECY-96-123," Proposed Changes to the NRC Operator Licensing Program," that the revised operator licensing process be implemented on a voluntary basis with the issuance of interim Revision 8 of NUREG-1021, " Operator Licensing Examination Standards for Power Reactors," and that the Commission approve the staff's pursuit of rulemaking to require power reactor facility licensees to prepare the operator licensing examinations in accordance with NUREG-1021. This revision to the operator licensing process treats the application of risk insights in operator licensing (Task 1.4). In a staff requirements memorandum Al-2
dated December 17,1997, the Commission documented its approval the staff's request, and NUREG-1021, Revision 8, was published in February 1997. In addition, a proposed rule was developed; it will be forwarded to the Commission shortly.
(5)
Individual Plant Examination (IPE) and IPE of Extemally initiated Events (IPEEE) Reviews (Task 2.5)
IPE Of the 75 IPE submittals received by RES,68 were reviewed and the associated staff evaluation reports (SERs) have been submitted to NRR. Two of the 68 completed SERs, for the Dresden and Quad Cities facilities, indicated that the staff could not conclude that these iPEs met the intent of Generic Letter 88-20. The licensee has submitted an updated IPE; the staff is reviewing the revised submittal and, as necessary, is revising the associated SERs.
With respect to the remaining seven reviews, RES will complete the SERs for Crystal River, St. Lucie, and Summer by the end of the current calendar quarter, and is awaiting additional information from the licensees regarding the Braidwood, Byron, Ginna, and Susquehanna IPEs.
It should also be noted that TVA has not submitted an IPE for Browns Ferry Unit 3. Thus, no staff review has been performed.
IPEEE The staff has received 63 of 74 expected IPEEE submittals. Currently,33 submittals are under review. Ten additional submittals are expected to be received by the end of December 1997, and the submittal date of one IPEEE has yet to be determined.
Final IPE Insiahts and IPEEE Reports The IPE Insights Report, NUREG-1560, was issued in October 1996 as a draft report for public comment. A public workshop will be held on April 7,8, and 9,1997, in Austin, Texas, to solicit public comments and discuss the draft report. The final version of the report is scheduled to be issued in June 1997; however, depending on the level and types of comments and information provided at the workshop, this date may be changed.
An initial structure for the IPEEE insights report has been develop-ed on the basis of information in the first 24 submittalc reviewed by the staff. An initial version of the report will be sent to the Commission as part of the annual Severe Accident Integration Plan update in May 1997; an additional update will be sent in September 1997 and a final report in September 1998.
(6)
Accident Seouence Precursor (Task 3.2)
The independent contractor-based QA review of the revised plant-specific simplified plant models for accident sequence precursor (ASP) analysis was completed in March 1997. After the prime contractor and the ASP Technical Coordinating Group review the report, the staff will incorporate final changes to the models and the models will be available for use in August 1997.
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Reliability Data Rule (Task 3.5)
The staff completed its evaluation of industry's proposed voluntary attemative to the rule.
Industry submitted data from the Safety System Performance Indicator (SSPI) program for six sites. A meeting was held in January 1997 to discuss technical problems with the SSPI data.
Industry has since proposed modifications to the Equipment Performance information Exchange (EPIX) system under development by the Institute of Nuclear Power Operations (INPO) to resolve j
concems raised at the January meeting. The staff will prepare a paper for Commission approval 1
detailing the status and options for future activity relating to the proposed rule.
(8)
Staff Trainina (Task 3.6)
The staff presented the first PRA for Technical Managers course, February 11,12, and 13,1997.
This course is designed to provide all levels of staff managers with a basic understanding of PRA
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methods, strengths, and limitations needed to implement risk-informed, performance-based j
regulations. Three utility personnel (coordinated through NEI) also attended. Current plans are i
to present the course three times a year.
The first presentation of the new PRA Level 2 course, Accident Progression Analysis, was held February 25,26, and 27,1997. This three-day course addresses accident phenomenology under post-core damage conditions and development of PRA models for this severe-accident regime.
Development has also been completed for a new PRA Level 3 course, Accident Consequence Analysis. This three-day course addresses environmental transport of radionuclides and estimation of offsite consequences from core damage accidents. The first course is scheduled to be presented in March 1997. Current plans are to present each of these courses twice a year.
The development of a new course on extemal events should be completed by May 1997. This three-day course will address extemal events (such as fires, floods, earthquakes, high winds, and transportation accidents) and the development of extemal event PRA models such as those used in the IPEEEs. Development of this course is currently in the design phase. The course is l
scheduled for its first presentation in July 1997.
i REVISIONS TO THE EXISTING PRA IMPLEMENTATION PLAN in completing the draft RGs and SRPs to date, the staff has found that a greater than expected effort is required to consider all points of view and gain a concensus on draft guidance. With this experience and, because submittals from industry on inservice inspection (ISI) are delayed, the staff projects that the draft ISI RG and SRP will not be issued for comment by the public before July 1997 and the final RG and SRP will not be issued before February 1998.
The staff has not received any of the pilot plant submittals for the risk-informed ISI pilot program.
This significant delay postpones the completion date for the staff's review regarding the acceptability of the pilot plant applications to April 1998.
The staff's evaluation of the GQA volunteer plant activities had been scheduled to be completed by June 1997. Progress on the GQA pilot activity has been delayed due to a redirection of resources to the development of the draft regulatory guidance. The staff will complete the review of the South Texas Project's proposal for a revised GQA program by the end of June 1997.
Lessons leamed from implementation of the South Texas program will be factored into the remainder of the pilot reviews which the staff expects to complete by December 1997.
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The first offering of the regulatory applications training course (Task 1.3) has been delayed from May 1997 to October 1997. This three-week course is intended primarily for inspectors and other technical personnelin the reactor program. These delays are the result of both course contractors and inhouse staff being diverted to higher priority activities. The contractor has begun to develop the course, but progress has been slowed to support the higher priority maintenance rule baseline team inspections. Also, since this course is applications-oriented, considerable NRC staff involvement is anticipated to prepare examples for the development of case studies and workshops. Only a single individualin NRR is currently assigned part-time to developing this course due to competing assignments to support risk informed inspection activities. Thus, the date for competing development of this course has been changed from May 1997 to August 1997. Course development willinclude one " dry run" of the course using staff persons experienc.ed in the material and knowledgable of the intended student audience.
Resolution of comments from the dry run and from the PRA Training Focus Group is expected to require significant additional time (2 months) before the course is offered for the first time.
The IPE/IPEEE process has led to the resolution of a number of substantial generic issues, including Unresolved Safety issue (USI) A-45 (Decay Heat Removal Reliability). The staff has begun the evaluation process to (1) evaluate IPE insights to deteimine necessary followup activities (Task 1.10); (2) identify plant-specific applicability of generic issues that were closed out on the basis of IPE and IPEEE programs (Task 1.6); and (3) assess the regulatory effectiveness of major safety issue resolution efforts, e.g.,10 CFR 50.63 (station blackout) and 10 CFR 50.62 (anticipated transients without scram)(Task 1.7). A target date of December 1997 has been established for developing the framework to address these major and complex regulatory activities. A target date for completing these regulatory activities is to be determined after the number and complexity of the issues are clarified. A schedule for any plant-specific backfit issues, however, would need to be determined on a case-by-case basis.
In regard to the regulatory effectiveness evaluation (Task 1.7), the staff intends to include recent
. insights on the risks of pressure-induced and thermally-induced steam generator tube ruptures (SGTR) in determining whether there is adequate closure of severe accident issues addressed in the station blackout rule. This willinvolve consideration of the interrelationships between the induced SGTR issue and reactor coolant pump (RCP) seal failure and station blackout issues.
Because potential backfits may draw benefits for aveded risk from multiple related severe accident issues, it is important to consider such interrelationships in deciding whether further backfitting is warranted in these areas.
j Work has been placed on hold for developing PRA methods (Task 2.4) for use in evaluating medical devices containing nuclear material, because of the loss of key staff and the availability of staff relative to other, higher priority, PRA support activities.
Development of methods for incorporating aging effects in PRA has been delayed due to the loss of the contractor's principalinvestigator.
The demonstration analysis portion of the human reliability work in Task 2.4 is being delayed because the cooperating licensee had to allocate needed resources to other, higher priority, issues at the site.
Task 3.1 (Risk-based Trends and Pattems Analysis) will experience delays due to an unexpected loss of resources (1/3 of the staff has been out of work because of injury or illness for significant Al-5 i
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parts of the period), additional work assignments not previously part of the PIP (such as the review of the Senior Management Meeting process), and technical difficulties encountered by contractors working on elements in the risk-based analysis of reactor operating experience.
Subtasks for trending the performance of risk-important components and initiating events analyses will be delayed seven months and three months, respectively. The subtask for trending i
of performance of risk important systems will not be complete until September 1998.
4 Tasks 3.3 (Industry Risk Trends) and 3.4 (Risk-based Performance Indicators) require the completion of the elements in Task 3.1 mentioned above. Since the activities in Task 3.1 won't be complete until the end of 1998, there will consequently be a 1-year delay completing Task 3.3 and a 1-year delay completing Task 3.4.
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Work on the development of PRA methods for use on industrial devices containing nuclear material (Task 4.4) has begun and is proceeding more slowly than expected using NRC staff and limited contractor support. The schedule for completing this work has been delayed from June 1997 to the end of FY1998 in order to maintain resources on higher priority PRA support activities.
A draft user's request has been developed for performing a PRA on spent fuel storage facilities (dry casks).
REVISED TASK TABLES The attached task tables have been updated to reflect the progress and revisions to the PRA implementation Plan from January 1,1997, to March 31,1997.
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ATTACHMENT 2 l
SUMMARY
DISCUSSION ON PERFORMANCE MONITORING IN THE CURRENT PRA PILOT APPLICATIONS
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Performance Monitorina in PRA Pilot Acolications i
In its January 22,1997 Staff Requirements Memorandum (SRM), the Commission stated that the staff should provide a summary discussion on how performance monitoring is being addressed in j
the current PRA Pilot Applications and, where appropriate, other planned performance-based j
approaches.
The PRA Pilot Applications are activities associated with evaluating risk-informed approaches to technical specifications, inservice testing of pumps and valves, inservice inspection, and quality
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assurance. Although the PRA Pilot Applications are not performance-based pilots, the staff has considered how performance-based strategies may be used to complement these risk-informed l-approaches. As a result of interactions with PRA Pilot Application licensees and the development of the risk-informed regulatory guides and standard review plans, the staff determined that implementation and performance-monitoring stratrugies are a key element of the risk-informed decision-making process. In fact, the fifth principle for considering risk-informed i
regulatory approaches indicates that the staff should ensure that "(p]erformance-based implementation and monitoring strategies are proposed that address uncertainties in analysis models and data and provide for timely feedback and corrective action."
In general, the PRA Pilot Application licensees considered the monitoring required by the maintenance rule (10 CFR 50.65) as the starting point for establishing application-specific perforraance-monitoring strategies.
Reliability and availability monitoring aspects of this section can be performed using the data anticipated from the proposed reliability and availability data rule for those systems and components under the scope of the rule. For systems and components outside the proposed rule scope, similar data would suffice for monitoring equipment reliability and availability performance.
PRA Pilot Acolications and Technicalissues Associated with Imolementation and Monitorina In SECY-96-218, " Quarterly Status Update for the Probabilistic Risk Assessment (PRA)
Implementation Plan, including a Discussion of Four Emerging Policy Issues Associated with Risk-Informed Performance-Based Regulation," dated October 11,1996, the staff provided a summary list of key technical and process issues associated with moving toward risk-informed, performance-based approaches. In its January 22,1997 SRM, the Commission indicated that the staff should address the technical issues conceming how the implementation and monitoring aspects of performance-based regulations are considered in current or planned performance-based approaches.
Staff experiences with the PRA Pilot Applications, experiences with recent or proposed rulemaking conceming containment leakage requirements, fire protection and shutdown risk, and experiences developing and implementing the maintenance rule account for a large percentags of the staff's experience with performance-based regulatory approaches. As previously mentioned, although the PRA Pilot Applications are not performance-based pilott, the staff has A2-1
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considered how performance-based strategies may be used to complement these risk-informed J
approaches. In the draft risk-informed regulatory guidance documents, the staff identified 4
acceptable attematives to address the technical issues associated with implementation and monitoring in a risk-informed decision-making process.
1 The first issue concems identifying the appropriate performance characteristics to monitor, in each application-specific regulatory document, there is a discussion of the performance-monitoring attributes. The regulatory guides provide licensees with flexibility to determine l
appropriate parameters to monitor to ensure that the performance of the component does not deteriorate to an unacceptable level and ensure that appropriate corrective action is pursued.
1 In graded QA, the availability of the components is the performance characteristic of interest, but may be difficult or impossible to measure directly in practice at the magnitudes credited in the PRA. Graded QA would rely on performance indicators associated with the monitoring of equipment failures, and would also include industry experience input. It is envisioned that for i
some aspects, the Maintenance Rule monitoring could be useful for graded QA purposes.
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However, low safety significant equipment may only be monitored at the plant level under the Maintenance Rule. In that case, individual equipment failures attributable to reduced QA controls may not be identified under the Maintenance Rule monitoring approach. This would preempt the l
ability to perform further evaluation of those failures to ascertain whether the QA controls need to i
be adjusted. The licensee will be expected to detect and correct unacceptable practices which, j
l if uncorrected, may cause the availability of low-safety-significant SSCs to deteriorate beyond the j
bounding values used in the safety categorization process. The graded QA descriptions of the monitoring approach have only been discussed at the conceptuallevels. Detailed implementation will be developed as the pilot reviews and completed with additional guidance provided in the final GQA RG.
l For inservice testing pilot activities, the staff is working with pilot licensees to ensure that a performance-monitoring program is included as part of the pilot licensee's risk-informed inservice i
testing program if the licensee proposes to extend the test intervals for low safety significant components (LSSC) or change testing strategies for high safety significant components (HSSC).
i The performance-monitoring programs should have the following attributes: 1) enough tests are included to provide meaningful data,2) the test is devised such that the incipient degradation can reasonably be expected to be detected, and 3) the licensee trends appropriate parameters as required by the ASME Code or ASME Code Case and (as nesessary) to provide validation of the PRA. This will ensure that degradation is not significant for components that are placed on an extended test interval and that the failure rate assumptions for these components are not compromised. Therefore, and in contrast to the performance monitoring required by the i
maintenance rule, performance monitoring for risk-informed inservice testing must be done at the component level.' The staff acknowledges that any component monitoring that is performed as
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part of the Maintenance Rule implementation can be used to satisfy monitoring as described in the RI-IST program guidance provided the performance criteria chosen are compatible with the i
RI-IST guidance provided in DR-1062. Where a licensee chooses to rely upon the monitoring by the Maintenance Rule to satisfy monitoring conducted in support of a RI-IST program for j
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i.j 2 Under the maintenance rule, the performance of low safety significant SSCs is monitored at the plant or system level usually through monitoring unplanned scrams, unplanned j
capability loss, and/or unplanned safety system actuations.
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l safety-related and important to safety SSCs, that monitoring.should be subject to the l
requirements of 10 CFR Part 50, Appendix B.
e In service inspection must also use performance indicato'rs at a level below pipe rupture. Current 4
plans are to characterize weld performance as the lack of flaw growth and the lack of leaks. The i
staff is investigating the option of establishing the number of inspections and frequency of i
inspections based on leak target goals. A performance-based inspection program may be J
developed with those target goals as indicators. Applying these goals in a risk-informed inservice inspection program may provide an attemative that assures an acceptable level of quality and l
safety {per 50.55a(a)(3)(l)}, while at the same time reducing excessive conservatisms in the present programs, directing inspection programs on critical weld locations, adhering to the i
i ALARA principles (reduction in personnel radiation exposure), and enhancing safety by 1
inspecting high-safety-significant piping that is presently not under the ASME Section XI i
inspection programs (roughly estimated as contributing to 20% of the risk from pipe breaks).
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i The second issue (related to performance-based implementation) concems how the equipment 4
i to be monitored is selected For risk-informed program changes, a monitoring program should
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be establish for equipment covered by the proposed change. For some of the risk-informed pilot d
applications, the selection of components to be monitored is straightforward. In general, risk-informed applications include SSCs within the associated issues regulatory scope, as well as additional SSCs categorized as high safety significant components. The scope of the SSCs to categorize is similar to the maintenance rule scope, expanded to included SSCs characterized by i
j non-maintenance preventable failures.
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i For graded QA, the scope of' application will be similar to the Maintenance Rule scope. In graded i
QA as currently envisioned, the QA controls on high-safety-significant, safety related SSCs will not be changed. Oversight of low-safety-significant but safety related SSCs may be reduced l
l commensurate with their importance to safety. This includes a reduction of QA controls on equipment associated with spec!fic operating modes which do not support the high-safety-j significant operating mode. This allows, for example, a reduction in QA controls on the motor i
operator of a locked open, motor operated valve while maintaining full Appendix B requirements l
on the pressure boundary function of the valve.
l For risk-informed inservice testing the components to be monitored include the current ASME Code required components as well as non-Code components that are categorized as high safety j
significant components In ISI, pipe segments are defined but the inspection program is applied to selected welds within a segment as appropriate. Current plans are to inspect the welds exposed to the worst degradation mechanisms in a segment, or a representative selection if all degradation j
mechanisms are the same.
i The third issue concems how the selected equipment's performance be monitored, in graded QA, the current industry proposals and staff guidance emphasize the monitoring of equipment failures and the feedback of observed failures into a plant specific quantitative data base for further evaluation by the licensee. The staff plans to also include the more traditional monitoring (use of audits and surveiNances) of the licensee implementation of the graded QA implementation plan itself.
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In ISI, the monitoring (inservice inspection type and equipment) is to be adapted to the degradation mechanisms to which the selected welds are exposed. This should result in an improvement of the detection capability.
Once the components to be monitored are identified, the monitoring program should provide a means to adequately track the performance of the equipment affected by the proposed change and should be capable of trending equipment performance after the change has been implemented to demonstrate that performance is consistent with that predicted by the traditional engineering and probabilistic analyses that were conducted to justify the change.in the case of risk-informed technical specifications, for example, the monitoring under the requirements of the maintenance rule would satisfy the monitoring program requirements necessary to support risk-informed changes to technical specification, provided that this monitoring is subject to the
)
requirements of 10 CFR Part 50 Appendix B. For risk-informed inservice testing, licensees should monitor performance characteristics as required by a test strategy that is developed from looking at the failure modes and the associated failure causes. Testing should be designed to detect failures as well as degradation that leads to these failure causes (e.g., as described in ASME Code case OMN-1).
Finally, the fourth performance-based issue deals with how feedback from the monitoring will be used to make adjustments in implementation. For risk-informed graded quality assurance, 1
operating experience, plant modifications and SSC replacements, degradation monitoring, and PRA monitoring shall be used by the licensee to assess the need to revise SSC safety significance categorizations or adjust QA controls. ISI will include expanded testing if flaws are discovered during inspections. The discovery of new types of weld flaws in the industry is also
' intended to initiate a re-evaluation and expansion of the test program but it is not yet clear how
]
Such an industry wide program will be put in place. For technical specifications, a three-tiered upproach will be used to support the overall configuration risk management process. If j
performance-monitoring reveals adverse trends in reliability or availability, the licensee shall i
taken appropriate corrective action that may include changes to the technical specifications.
)
For risk-informed inservice testing, the feedback mechanism should ensure that if a particular
)
component's test strategy is adjusted in a way that is ineffective in detecting component degradation and failure, the IST program weakness is promptly detected and corrected.
Subsequent corrective actions should 1) assess the validity of the PRA failure rate and unavailability assumptions in light of the failure (s), and 2) consider the effectiveness of the component's test strategy in detecting the failure or nonconforming condition. These corrective
' actions may result in adjustments to the test frequency and/or methods where the component (or group of components) experiences repeated failures or nonconforming conditions.
Addressina the TechnicalIssues Associated with Imolementation and Monitorina in Maintenance Rule Insoection Activities Monitoring performance under the Maintenance Rule is accomplished through the approach described in NUMARC 93-01, which was endorsed by the NRC through RG 1.160. The purpose of monitoring under the maintenance rule is to determine the effectiveness of maintenance.
Monitoring programs developed using the guidance in NUMARC 93-01 evaluate performance at the system or train level for high safety significant and standby SSCs and at the plant level for low safety significant normally operating SSCs.' High safety significant SSCs are determined by the expert panel using input from the PRA as well as knowledge of plant design and operation and existing engineering analyses. For high safety significant and stand-by SSCs, performance A2-4 4
is monitored by considering unavailability and reliability or condition of the SSC, usually at the train level. For low safety significant normally operating SSCs, performance is monitored at the
. plant level usual!y through monitoring unplanned scrams, unplanned capability loss, and/or unplanned safety system actuations. The reliability of low-safety significant stand-by systems is monitored at the train level. All SSCs in scope of the rule are monitored by one of these means, unless the licensee makes the determination that the SSC is either inherently reliable (such as cable trays) or can be "run to failure" (such as fuses). Feedback from the monitoring of preventive maintenance determines whether the SSC can continue to be monitored using these criteria (meeting the criteria substantiates the effectiveness of the preventive maintenance); or, when preventive maintenance is no longer effective, the SSC is subject to corrective action and goal setting. Goal setting is a form of performance monitoring that is specific to the equipment and identified failure mechanism. Feedback from the monitoring programs is used to adjust preventive maintenance activities to balance reliability and availability of SSCs and, as necessary, to reevaluate risk significance based on actual performance.
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DOCUMENT COVER PAGE DOCUMENT NAME:
SUBJECT:
QUARTERLY STATUS UPDATE FOR THE PROBABILISTIC RISK ASSESSMENT (PRA)
IMPLEMENTATION PLAN, INCLUDING A DISCUSSION OF FOUR EMERGING POLICY ISSUES ASSOCIATED WITH RISK-INFORMED REGULATION ORIGINATOR:
MARK CARUSO l
l LOG #:
f l
SECRETARY:
Caryn Faircloth DATE:
March 31,1997 see ROUTING LIST ***
l NAME DATE i
- 1. MARK CARUSO
/ /97 l
- 2. TECH EDITOR
/ /97
- 3. MARK RUBIN
/ /97 4.
GARY HOLAHAN
/ /97
- 5. BRIAN SHERON
/ /97 6.
BRUCE BOGER
/ /97
- 7. ASHOK THADANI
/ /97
- 8. SAM COLLINS
/ /97
- 9. MARK CUNNINGHAM
/ /97
- 10. DAVID MORRISON
/ /97
- 11. JOHN AUSTIN
/ /97
- 12. CARL PAPERIELLO
/197
- 13. PAT BARANOWSKY
/ /97
- 14. _ED JORDAN
/ /97
- 15. OGC
/ /97
- 16. HUGH THOMPSON
//97 l
A2-7 i
l
n REVISED PRA IMPLEMENTATION PLAN l
TASK TABLE (March 199T) l h
5 f
1.0 REACTOR REGULATION
[
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Regulatory Activity Objectives Methods Target Lead f
Schedule offee(s) 1.1 DEVELOP STANDARD Standard review plans for NRC staff to use in risk-
- Evaluate available industry guidance.
NRR REVIEW PLANS FOR RISK-informed regulatory decision-making.
INFORMED REGULATION
- Develop a broad scope standard review plan (SRP) i l
chapters and a series of application specirc standard review plan chapters that correspond to industry initiatives.
I
- These SRPs will be consistent with,the Regubtory Guides devek pM for the industry.
- Draft SRPs transtndted to Commission to issue for public i
General 3/97 t
TS 3/97
TS 12/97 1.2 PILOT APPLICATION
- Evaluate the PRA methodology and develop staff
- Interface with industry groups.
NRR I
I FOR RISK-INFORMED positions on emerging, risk-informed initiatives.
- Evaluaton of appropriate documentation (e g.,
REGULATORY INITIATIVES including those associated with.
10 CFR, SRP, Reg Guides, inspectx)n procedures, and i'
- 1. Motor operated valves.
industry codes) to identify elements critical to achieving the
- 1. 2/96C*
- 2. IST requirements.
Intent of existing requirements.
2.6/97
- 3. ISI requirements.
- Evaluation of industry proposals.
3.498 4 Graded quality assurance.
- Evaluahon of industry pilot program implementation.
- 4. 6/97 (STP)
[
- 5. Maintenance Rule.
12/97 (others) 6 Twhnicalspecifications.
- As appropnate, complete pilot reviews and issue staff S 9/95C
- 7. Other applications to be identifed later.
findings on regulatory requests.
6 3/97 L
f I
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Regutatory ActMty Objectives Methods Target Lead Schedule OfficeM 1.3 INSPECTIONS
- Provide guidance on the use of plant-specific and
- Develop IMC 9900 technical gu6 dance on the use of 4G7 NRR generic informaton from IPEs and othei plant-PRAs in the power reactor inspection program.
specific PRAs.
Revise IMC 2515 Appendix C on the use of PRAs in the 6/97 power reactor inspection program.
- Propose guidance options for inspection procedures 10/97 related to 50.59 evaluations and regular maintenance ut r.a;w.
- Review core inspection procedures and propose PRA 697 guidance where needed.
-
- lssue draft Graded Q A Inspection Procedure for public 9eS7 comment
- lssue final Graded Q A Inspection Procedure 3/98
- Provide PRA training for inspectors.
- Idenhfy inspector functions which should utilize PRA 7/96C NRR methods, as input to AEOD/TTD for their development and refnement of PRA training for inspectors.
- Develop consohdated/ comprehensive 2 3 week PRA for 8/97 NRR/
regulatory applications training course.
- First course offenng.
10/97 NRR/
- Conde:t trainmg for Maintenance Rute baseline 8/96C inspections
- Provide PRA training for Senior Reactor Analysts
- Rotational assignments for SR As to gain working 3/97 NRR/RES expenence
- Continue to provide expertrse in risk assessment
- Monitor the use of risk in inspection reports.
Ongoing NRR to support regionalinspection activities and to communicate inspection program guidance and
- Develop new methodologies and communicate examples of its implementaten appropriate uses of risk insights to regional offices.
- Update inspecton procedures as needed.
- Assist regional offices as needed.
- Conduct Maintenance Rule baseline inspections 7/98 2
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Regulatory Activty Objectives Methods Target Lead Schedule Officer')
1 A OPERATOR LICENSING Monitor insights from HRA$ and PRAs (including
- Revise the Knowledge and Abilities (KfA) Catalogs 8/95C NRR IPEs and IPEEEs) and operating experience to (NUREGs 1122 and 1123) to incorporate operating identify possible enhancements for inclusion in experience and risk insights.
planned revisions to guidance for operator licensing activities (initial and requalification)
- Revise the Examiner Standards (NUREG-1021), as 3/97C NRR needed, to reflect PRA insights.
1.5 EVENT ASSESSMENT
- Continue to conduct quantitative event
- Continue to eva!uate 50.72 events using ASP models.
Ongoing NRR assessments of reactor events while at-power and during low power and shutdown conditions.
- Assess the desirability and feasibility of
- Define the current use of risk anafysis methods and TBD NRR conducting quantitative risk assessments on non-Insights in current event assessments.
power reactor events
- Assess the feasibility of developing appropriate risk assessment models.
- Develop rn.v...
dations on the feasibility and desirability of conducting quantitative risk assessments.
16 EVALUATE USE OF PRA
- Audit the adequacy of hcensee analyses in IPEs
- Identify generic safety issues to be audited.
NRR IN RESOLUTION OF and IPEEEs to identify plant-specific apphcabshty of
- Select plants to be audited for each issue.
GENERIC ISSUES genene issues closed out based on IPE and IPEEE
- Describe and discuss licensees' analyses supporting programs.
issue resoluton.
- Evaluate results to determine regulatory response;i e., no TBG action, additional audsts, or regulatory action.
1.7 REGULATORY
- Assess the effectiveness of major safety issue
- Develop process / guidance for assessing regulatory NRR&
EFFECTIVENESS resolution efforts for reducing risk to public health effectiveness.
RES EVALUATION and safety.
- Apply method to assess reduct!on in risk.
- Evaluate result, effectiveness of rules.
- Propose modifications to resolution approaches, as needed.
- Identify other issues for assessment if appropriate.
TBD 18 ADVANCED REACTOR
- Continue staff reviews of PRAs for design
- Continue to apply current staff review process.
Ongoing NRR REVIEWS certification applications
- Develop draft SRP to tech staff for review and 6/98 NRR design certifcation reviews of evolutionary reactors concurrence.
(ABWR and System 80+)
- Fmatize SRP.
12/99 3
Regulatory Activity Objectives Methods Target Lead Schedule Officer)
- Develop independent techrucal analyses and
- Reevaluate risk based aspects of the technical bases for 12/96C NRR &
criterta for evaluating industry initiatives and EP (NUREG-0396) using insights from NUREG-1150. the RES petitions regarding simplifcation of Emergency new source term information from NUREG-1465, and Preparedness (EP) regulations.
available plant design and PRA information for the passive and evolutionary reactor designs.
1.9 ACCIDENT
- Develop generic and picnt specific risk insights to
- Perform an assessment of A/M-related information 6/97 NRR &
MANAGEMENT support staff audits of utility accidents managemet.1 contained in IPE databases to develop generic insights into RES (A/M) programs at selected plants.
A/M strategies and capabilities and document it in IPE Insights Report.
- Develop plant-specife A/M insights /information for TBD selected plants to serve as a basis for assessing completeness of utihty A/M program elements (e g.. severe accident training) 1.10 EVALUATING IPE
- Use insights from the staff review of IPEs to
INSIGHTS TO DETERMINE identify potential safety, policy, and technical issues, Reactor Safety and Plant Performance" and identify the RES NECESSARY FOLLOW-UP to determine an appropriate course of action to intiallist of required staff and industry actions (if any).
ACTIVITIES resolve these potential issues, and to identify possible safety enhancements.
Finalize hst of required staff and industry actions.
12/97
- Audd Icensee improvements that were credited in the TBD NRR IPEs to determine effectiveness of Icensee actrons to
- Determine appropriate approach for tracking the reduce risk.
regulatory uses of ?PE/IPEEE results.
- Define use for information, clanfy" regulatory use*, and 12/97 assess the most effective methods for data collecton.
- If appropriate, develop approach for linking IPE/IPEEE 12/98 data bases "C= Complete 4
10 REACTOR SAFETYRESEARCH Regulatory Activity Objectives Methods Target Lead Schedule Office (s) 11 DEVELOP REGULATORY Regulatory Guides for industry to use in risk-hformed
approvalto issue for public comment General 3/97 IST 397 ISI 7/97 GQA 3/97
~
TS 3/97
- isam final PRA Regulatory Guides.
General 12/97 IST 12/97 ISI 2/98 GQA 12/97 TS 12/97 2.2 TECH *4tCAL SUPPORT
- Provide technical support to agency users of risk
- Contume to provide ad hoc technical support to agency PRA Cordinuing RES assessment in the form of support for risk-based users.
regulation activities, technical reviews, issue risk
- Expand the database of PRA models available for staff use, Continuing RES assessments, statistical analyses, and develop expand the scope of available models to include external event guidance for agency uses of risk assessment and low power and shutdown accidents, and refrie the tools needed to use these models, and continue maintenance and user support for SAPHtRE and MACCS computer codes.
- Support agency efforts in reactor safety ;,,vess.wi-as in Cont:nuing RES former Soviet Union countries.
S 5
Regulatory Activity Objectives Methods Target Lead Schedule Officet )
2.3 SUPPORT FOR NRR
- Modify 10 CFR 52 and devetop guidance on the use of
- Develop draft guidance and rule.
5/98 RES STANDARD REACTOR PRA updated PRAs beyond design certification (as described
- Sorcit public comment.
11/98 RES REVIEWS in SECY 93-087).
- FinaF2e staff guidance and rule.
12/99 RES 2.4 METHODS DEVELOPMENT
- Develop, demonstrate, maintain, and ensure the quality
- Develop and demonstrate methods for including aging TBD RES AND DEMONSTRATION of methods for performing, reviewing, and using PRAs effects in PRAs.
and related techniques for existing reactor designs.
- To evaluate IPE/IPEE submittats to obtain reasonable
- Complete reviews of IPE submittals.
9/97*
RES assurance that the licensee has adequately analyzed the
- Complete reviews of IPEEE submittals.
12/98 RES plant design and operatons to discover vulnerabilities;
- Continue regional IPE presentations.
Ongoing RES and to document the significant safety insights resulting
- tssue iPE insights report for public comment.
10/96C RES from IPE/tPEEEs.
- FinalIPE insights report 6/97 RES
- tssue draft finalIPEEE insights report 9,98 RES 2.6 GENERIC ISSUES PROGRAM
- To conduct generic safety issue management
- Continue to priontize and resolve genere issues.
Continuing RES activities, including prioritization, resolution, and documentaton, for issues relating to currently operating reactors, for advanced reactors as appropriate, and for development or revision of associated regulatory and l
standards instruments.
- Sea text for discussion of IPE review status.
t 6
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3.0 ANALYSIS AND EVALUATION OF OPERATING EXPERIENCE, AND TRAINING l
4 Regulatory Objectives Methods Target Lead Activity Schedute Offee I
3.1 RISK-BASED
- Use reactor operating expenence data to assess
- Trend performance of risk-important components.
9,97 AEOD l
TRENDS AND the trends and patterr.s in equipment, systeras, PATTERNS ANALYSTS Irdtiating events, human performance, and important
- Trend performance of risk-important systems.
9/98 accident sequence.
- 'frend frequency of risk-important initiating events.
8,97
- Trend human perfo. 'ance for reliability characF~5 TBD
- Evaluate the effNess of licensee actions taken to
- Trend reactor operating expenence associated with specific As AF, resolve risk sigt ac
- safety issues.
safety issues and assess risk implications as a measure of safety Needed performance.
- Develop trending methods and special dahbases for use
- Develop standard trending and statistical analysis procedures for Complete AEOD in AEOD trending actmties and for PRA apphcations in identified areas for reliabihty and statrstical apptcations.
omer NRC offices.
- Develop special software and databases (e g common cause CCF-failure) for use a trending analyses and PR A studies.
Complete Periodic updates 3 2 ACCtDENT
- Identify and rank risk signifcance of operational events.
- Screen and analyze LERs, AITs. IITs. and events identified from Ongoing AEOD SEQUENCE other sources to obtain ASP events.
l PRECURSOR (ASP)
PROGRAM
- Perform independent review of each ASP anatyses. Licensees Annual and NRC staff peer review of each analysis.
- report, AEOD Ongoing
- Complete quakty assurarice of Rev 2 simplified plant specific 3/97C RES models
- Complete feasibihty study for low power and shutdown models.
11/96C RES
- Complete initial containment performance and consequence Complete RES models.
- Provide supplemertalinformation on plant specirc
- Share ASP analyses and insights with other NRC offces and Annual rp(
AEOD performance Regions.
l 7
t_____
Regulatory Actvky Objectives Methods
- Target Lead.
t Schedule Office 3.3 INDUSTRY RISK
- Provide a measure of industry risk that is as complete as
- Develop program plan which integrates NRR, RES, and AEOD Complete AEOD TRENDS possible to determine whether risk is increasing, actMties which use design and operating experience to assess the decreasing, or remaining constant over tinw.
Impfied level of risk and how it is changing.
- Implement program plan elements which will include plant.
9/98 specific models and insights from IPEs, wu pa and system reliability data, and other risk-important design and operational data in an integrated frame work to periodicafty evaluate industry trends.
3 4 RISK-BASED
- Establish a comprehensive set of performance indicators
- Identify new or improwd risk-based P!s which use component Complete AEOD r
PERFORMANCE and supplementary performance measures which are and system reliability models & human and organizational INDICATORS more closely related to risk and provide both early performance evaluation methods.
Indication and confirmation of plant performance problems.
- Develop and test candidate Pts / performance measures.
3s9
- Implement risk-based Pts with Commission approval 9/99 3 5 COMPILE
- Compile operating experience information in database
- Manage and maintain SCSS and the Pl data base, provide Ongoing AECD OPERATING systems suitable for quantitative rehabihty and risk analysis oversight and access to NPRDS, obtain INPO's SSPt, compile EXPERIENCE DATA applications. Information should be scrutable to the iPE fal lure data, collect plant-specific reliability and availability t
source at the event leve8 to the extent practical and be data.
sufficient for estimating rehabihty and availability
- Develop, manage, and maintain agency databases for Ongoing param'eters for NRC apphcations.
reliability / availability data (equipment performance, initiating events.
CCF, ASP and human performance data).
- Revise reporting rules to better capture equipment reliabihty 10/97 information.
- Evaluation of voluntary appmach for collecting reliability data 4/97
- Final rehability data rule ( if necessary) 6 mo.
After Decision on Vol Approach.
- Determine need to revise LER rule to eliminate unnecessary and 4/97 i
tess safety-significant reporting.
- Determine need to revise reporting rules and to better capture 6/98 ASP, CCF, and human performance events.
8
Regulatory Activity Objectives Methods Target Lead Schedule Office (')
3.6 STAFF TRAINING
- Present PRA curriculum as presently sct'eduled for FY -
- Continue current contracts to present courses as scheduled.
Ongomg
^AEOD 1996
- Maintain current reactor technology courses that include PRA Ongoing insights and applications.
- Improve courses via feedback.
Ongoing
- Review current PRA course material to ensure consistency with Complete Appendix C.
- Develop and present Appendix C training courses.
- Prepare course material based on Appendix C.
Complete RES and
- Present courses on Appendix C.
Complete AEOD
- Determine staff requirements for tcaining, including analysis
- Review JTAs performed to date.
Complete AEOD r
of knowledge and skills, needed by the NRC staff.
Frogram).
Complete
- Evaluate staff training requirements as identired in the PRA l
Implementation Plan and the Technical Training Needs Survey l
(Phase 2) and incorporate them into the training requirements Ongomg analysis.
- Analyze the results of the JTA Pilot Program and determine Ongoing requirements for additional JTAs.
Ongoing.
- Complete JTAs for other staff positions as needed.
Ongoing l
- Solidt a review of the proposed training requirements.
- Finalize the requirements.
- Revise current PRA curricutum and develop new training
- Prepare new courses to meet identired needs.
12/97 AEOD program to fulfill identified staff needs.
- Revise current PRA courses to meet identified needs.
12/97
- Revise current reactor technology courses as necessary to include Complete additional PRA insights and applications 3/96 i
- Present revised PRA trainng curriculum.
- Establish contracts for preserdation of new PRA curricutum.
Ongoing AEOD
- Present revised reactor technology courses.
Ongoing
- Improve courses based on feedback.
Ongoing S.
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4.0 NUCLEAR MATERIALS AND LOW-LEVEL WASTE SAFETY AND SAFEGUARDS REGULATION Hegulatory Activity Objectives Methods Target Lead Schedule Office (s) 4.1 Validate risk analysis
- Validate risk analysis methodology developed to
rnethodology developed to assess assess the relative profile of most likely to examine existing work and to provide recommendations Completed most likely failure modes and contributors to misadminestrations for the gamma for further methodologecal dc4.ut.
i human performance in the use of stereotactic device (gamma knife).
industrial and medical
Examine the use of Monte Carlo simulation and its 9/95 radiation devices.
application to relative risk profiling Completed
- Examine the use of expert judgement in developing error 9/95 rates and consequence measures Completed
(
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- Continue the C..,,mnt of the relative r6sk
- Develop functonally based generic event trees.
TBD RES/
j methodology, with the addition of event tree NMSS rnodeling of the brachytherapy remote.
t afterloader.
- Extend the application of the methodology and
- Develop generic risk approaches.
t its further dc. :,,wnt into additional devices.
}
including teletherapy and the pulsed high dose rate aftertoaoer i
4 2 Continue use of risk assessment
- Develop decision criteria to support
- Conduct enhanced participatory rulemaking to estabksh 8/94 PR RES &
L of allowable radiation releases and regulatory decision making that radclopi criteria for decommissioning nuc! ear sites; Complete NMSS doses associated with low-levet incorporates both deterministic and risk-based technical support for rulemaking including comprehensive Final Rule r
radioactive waste and residual engineering judgement.
risk based assessment of residual contamination.
4/97
. actuity.
(Dependent on EPA) i
- Work with DOE and EPA to the extent practicable to Ongoing develop common approaches, assumptions, and models for evaluating risks and alternative remediation i
methodologies (Risk harmonization)
{
t 4 3 Develop guidance for the review
- Develop a Branch Technical Position on
- Sohcit public comments 4/97 NMSS &
of nsk associated with waste conducting a Performance Assessment of a
- Publish final Branch Tecanical Position 8/97 RES j
repositories.
LLW disposal facihty.
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Regulatory ActMty Objectives Methods Target-Lead Schedule Ofree(T) 4.4 Risk assessment of Material
- Develop and demonstrate a risk assessmerf
- Develop and demonstrate methods for determhyng the
~ 7/98 uses.
for industrial gauges containing cesium-137 and risk associated with industrial gauges containing cesium-cobat-60 using PRA and other related 137 and coban-60.
- Final report as NUREG 10/98
- The assessment should allow for modification.
based on changes in regulatory requirements.
- Use emperical data as much as practicable.
- Develop and demonstrate risk assessment methods for application to medical and industrial
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licensee activities.
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5.0 HICH-LEVEL NUCLEAR WASTE REGULATION Regulatory Activity Objectives Methods Target Lead Schedule Office (s) 5.1 REGULATION OF HfGH-
- Develop guidance for the NRC and CNWRA staffs
- Assist the staff in pre-licensing actMties and in license Ongoing NMSS LEVEL NUCLEAR WASTE in the use nf PA to evaluate the safety of HLW application reviews.
programs.
- Develop a technical assessment e.apability in total-system and subsystem PA for uss n licensing and pre-licensing reviews.
- Comb lne specialized technica' discip!!nes (earth l
sciences and engineering) with those of system modelers to improve methodology.
- Identify significant events, processes, and
- Perform sensitivity studies of key technicalissues Ongoing NMSS parameters affecting total system performance.
using iterative performance assessment (IPA).
- Assist the staff to maintain and to refine the regulatory Ongoing NMSS o
evaluate proposed changes to regulations goveming structure in 10 CFR P r160 that pertains to PA.
the potential repository at Yucca, Mountain.
- Provide guidance to the DOE on site charactenzation Ongoing NMSS during the pre-hcensing phase of repository requirements, ongoing design work, and licensing development site characterization, and repository issues important to the DOE's development of a design.
complete and high-quality license application.
- Compare results of NRC's iterative performance assessment to DOE *s TSPA-95 to identify major differences / issues.
5 2 APPLY PRA TO SPENT FUEL
- Demonstrate methods for PRA of spent fuel
- Prepare user needs letter to RES 4/97 NMSS/RES STORAGE FACILITIES storage facilibcs
- Use PRA methods, results. and insights to evaluate
- Update the database en transportation of radioactive end of FY NMSS ASSESSMENT IN SUPPORT OF regulations goveming the transportation of radioactive materials for future applications 99 RADIOACTIVE MATERIAL material
- Revahdate the results of NUREG-0170 for spent fuel TRANSPORTATION shipment risk estimates 6/99 12
- -