ML20141A743

Submits Nuclear Safety Research Review Committee Responses to Commission Questions Posed in 960910 SRM to ET Boulette

ML20141A743
Person / Time
Issue date:	03/13/1997
From:	Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, Rogers K, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20141A507	List: ML20141A504 ML20141A534 ML20141A597 ML20141A683 ML20141A736 ML20141A743
References
ACRS-3055, NACNSRRC, NUDOCS 9705140444
Download: ML20141A743 (17)

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UNITED STATES.

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.. j NUCLEAR REGULATORY COMMISSION o

e WASHINGTON, D.C. 2055!K21 v

• • .j March 13, 1997 i

MEMORANDUM TO:

Chairman Jackson i

Comissioner Rogers Commissioner Dicus Commissioner Diaz i

Comissioner McGaffigan FROM:

L. Joseph Callan Executive Direct r f' Operations

SUBJECT:

RESPONSE TO THE SEPTEMBER 10, 1996 SRM TO E. THOMAS i

BOULETTE, CHAIRMAN, NUCLEAR SAFETY RESEARCH REVIEW COMMITTEE (NSRRC) 4 Below please find the NSRRC Comittee responses to the Comission's questions 4

posed in the September 10, 1996 SRM to E. Thomas Boulette, Chairman, NSRRC.

In this SRM, the Comission requested that the NSRRC coordinate its activities with those of the ACRS in areas of joint interest to ensure that the i

activities are supportive and complimentary and not duplicative. The NSRRC l

was also asked to continue to review the progress of human factors research.

NSRRC ResDonse: We have done as requested joining the ACRS subcomittee meetings where appropriate and meeting with the RES staff to review l

their program.

The Comission also recomended that the NSRRC identify those human factor aspects that can be treated adequately in PRA, as well as those human factor areas where progress for inclusion in PRA is likely.

I NSRRC Response: None of the current HRA capabilities is perfect and all could benefit substantially from further work. However, human factors can only be treated adequately in evaluation of HRA within PRAs in dealing with simple human actions (i.e., performance of well-defined tasks by an individual). All others are subject to substantial uncertainty, which must be dealt with via the transitional means of i

defense in depth and conservatism. Greater progress in HF leading to improvements in HRA can be made by organizing the NRC's activities better. However, even if that is done, substantial amounts of time and money will be needed before there will be a prospect for major improvements.

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. Lastly, the Commission also asked the NSRRC to provide recommendations for integrating these human factors considerations into PRA methods.

i NSRRC Response: In the preceding discussions, we have offered recommendations for doing this; specifically of requiring each HF project with RES to have products to be used in improving HRA capabilities and of reorganizing the HRA effort to be more comprehensive, realistic and ambitious.

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PLANNING AND PROCEDURES SUBCOMMITTEE To:

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From: D.A. Powers March 22,1997 i

subject:

OBSERVATIONS ON REVISED PROCEDUREfi

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FROM MARCH MEETING 1

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his memorandum is part of the %"kg effort to monitor the progress ACltS is

=*ia in the change ofits procedures. h-@- ! changes were r=ea==anM as ar:sult of the j

=nheammittee meeting in Boston. It was recognized that change in the ways of doing lnisiness mould take time. It will also require that practiocs be monitored to avoid %away's:nd to identify additional refinements in operating y.44. This memorandum records oc me l

observations about business practices at the March 1997 meeting 4

l The March meeting was extraordinarily productive despite there being several topics on i

the agenda that were quite controversial. Letter production was high at the meeting. his letter production went quite smoothly. Some ot. Mons and suggestions as to why the l otter production was so smoothly done are listed below:

I l

o RISK-INFORME.D REGULATION i

l It took well-over five hours to produce the letter on risk-informed reguation, but j

in light of the importance ascribed to the issues involved and the artentlon ACRS j

had devoted to this area, there is no need to be concemed about this t'me.

J Production of the letter was, in fact, far easier than anyone had antici1nted. The l

case of producing this final letter was probably the result of:

- the subcomminee chainnan had devoted a lot of time at the j

subcommittee meetings to solicit views ofmembers in advance of l

producing a draft, J

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. the subcommittee chairman did provide a draft letter before 2e meeting.

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. members provided the ah -i ee chainnan with written comments tt j

prior to the meeting and durmg the meeting to facilitate trei.;a of the i

draft letter, and i.

. the subcommittee chainnan worked hard to isryvi.i. all aabers l

views in the letter with an eye toward avoidag the need for aklitional j

comments in the louer.

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In other words, members and the sk-=i ee ^=4==a followed tie revised tt i

procedures developed in Boston quite clesely. This really helped us gelthings done.1 think the sk-mi ee chairman deservas a vote of thanks fnm the full tt i

ACRS for his efforts in producing the letter and his efforts to organize and i

conduct a series ofexeclient ske=h meetings. The sukea==ht oe chairman's intsase belief that additional aa==aate should be avoided lf at all possible is an intmsting addition to the proceduras discussed in Bostos.ACRS may want to discuss this philosophical approach more, i

Two concams 1 have on this letter are minor, but worth moording. Fim,can

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indeed all members defcad all points in the lottar or was there compmmise l

without persuasion? S~aA we did have an instance of citing materini not i

examined by the whole ACRS in the letter. I fear that we may be overly sensitive on this point. My view is that the whole ACRS need not szamine every item of l

cited information. It only necessary that every item be readily availahlo i

e FUBLISMING ROSA DATA i

The letter on publishing data frosn the ROSA facility was produced au ily. This 4

l was probably W -:

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- the letter involved a single, well-defined issue,

- the suke==i 2

ttee chairman produced a well written first draft letterg and l

- the ACRS did not undertake a detailed, word-by-word editing of the letter.

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o RISK ACCEPTANCE CRITERIA i

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The letter on risk acceptance criteria was produced easily perhaps bocase:

l the ACRS had seen and discussed previous versions of this letter. We Inve, j

however, encountered delays because ACRS did not review the attaf=a to the j

letter in detail. My impression is that this was b=> the ACRS as a whole did j

not unk.mnd the strategy of the letter and its anachmeats well. It espears to me l

that if ACRS evolves into a more proactive, rather than :: active, body, it will be i

very important that everyone understand the strategy ofinitiatives we undertake.

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Though letter production at the March meeting was hign, it is still true that ACRS did not complete its agenda. Finalized letters were not all avadable by Friday night. We depri

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i ourselves of opportunities to raDect on what all was being created. We wers, in fact,;

orking on w

l letters right up to the last minute. There was not time to discuss strategic pt-ia: onesearch j

needs.

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Dana A. Powers Advisory Committee on Reactor Safeguards (505) 821-2735 voice 7964 Sartan Way,NE (505) 821-0245 fax Albuquerque, NM 87109-3128 FACSIMILE TRANSMITTAL i

Please deliver the following message of I pages including the cover page to:

NAME:

PLANNING AND PROCEDURES SUBCOMMITTEE a

Fax #:

Voice #:

i

SUBJECT:

EVENT AT THE CLINTON POWER STATION i

j The event at the Clinton Power Station on September 5, Iq96 l

seemed to involve a litany of errors *. Among these errors were a variety j

of things associated with organizational aspects of the plant l

management. This is a topic near and dear to the heart of ACRS) I j

wonder if we shouldn't hear more about this event in connectidn with our discussions of the organizational issue?

I

• SER I-97, Nonconservative Operations DuringIsolation ofa Reactor Recirculation Pump Seal Leak, January 1,1997.

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I Dana A. Powers Advisory Committee on Reactor Safeguards (505) 821-2735 voice 7964 Sartan Way, NE i

j (505) 821-0245 fax Albuquerque, NM 87109-3128 i

FACSIMILE TRANSMITTAL l

t Please deliver the following message of 1 pages including the cover page to:

NAME: MICHAEL T. MARKLEY i

Fax #:

Voice #:

1

SUBJECT:

COMMISSION BRIEFING ON 10CFR50.59 4

1 On page 25, line 12, of the proposed guidance for the implementation of the 10CFR50.59 rule, there is a statement that c! he 3

imp. icates language to Criterion xvi of 10CFR 50 appendix B t t

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effect that "... the condition is to be promptly corrected, commensurate with its safety significance." I cannot find this language in the hopy of appendix B I have. To the contrary, the version I have seems to say that everything of safety significance has to be corrected, and that tiiings of great safety significance need an additional step to assure the malfunction isn't repeated. Do you know where the guidance on 50.59 is getting its language concerning Appendix B? If, indeed, the

" commensurate with safety significance" phrase actually exists;in i

Appendix B, then risk informed graded QA can be implemented BOLDLY without rulemaking!

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questioned this mix. There are those who think all NRC reseal ch should i

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based on user need.

RESEARCH TOPICS - APPLIED o Evaluation of LERF at each nuclear power plant site.

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1 o Predictive metrics and leading indicators ofplant performance.

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o Quantification of shutdown risk.

j o - Use of" formal methods"in the regulation of digital electronics for safety systems NAS COMMITTEE During the March meeting the ACRS heard from the National Research Council's Committee on Application of Digital Instrumentation and Control Systems to NucleW Power Plant Operations and Safety (NAS Committee). The NAS Committee identified reseVeh topics that ACRS might want to consider especially if ACRS can figure out what they mead l

- identify and pursue a balance between research on requirements and research on coding, s

- define " adequate diversity" in digital instrumentation and control systems i

- develop a sufficient level of expertise for gaining confidence in digital implementations i

of system functions and the limitations of quantitative assessment,

- support development of advanced techniques for analysis of digital systems to reduce uncertainty in quantitative assessments,

- support research exploring higher-levelissues ofhuman-system integration control and automation including research on operator models to more effectively specif) system designs.

- develop a data base on problems of digital implementation in nuclear powcr plants and other safety-critical applications,

- research to support NRC acceptance of Commercial-Off-the Shelf hardware for safety applications.

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The NAS Committee also raised two issues concermng the way that NRC conducts its research on digital instrumentation and control:

The NAS Committee strongly suggested that NRC staff and its contractop o

do not participate enough in technical meetings and standards panels. The criticismis particularly interesting since an examination of the credentials of NRC's Laffand l

contractors involved in digital instrumentati su and control issues sugges that their participation in technical meetings and standards panels may be well abo e

participation in such activities by NRC staffinvolved in other areas ofNC research.

Certainly, Apostolakis and Catton have raised similar concerns about par f NRC staffin technical meetings dealing with probabilistic risk assessmen,ri ip tand hydraulics.

the NAS Committec questioned the adequacy of NRC " peer review" pract. ces.In o

particular, they questioned the practice ofhiring a panel of consultants to' conduct a detailed review of particular pieces of work. At first blush, this criticism sdrprises. It would appear that NRC's practice ofhiring peer reviewers is a very positive step since it insures timely, independent, in-depth examintions of the work. It gpears that the NAS Committee has more confidence in the voluntary review that could come from a broad dissemination of NRC-sponsored work. Others have $nde similar comments. Those involved in the NRC's source term research will no doh

" chemist in Bangladesh" with fantastic, untapped insight. The NAS Comtr:ittee did not indicate how NRC could assure voluntary review occurs on a timely basis. Nor did the NAS Committee provide any assurances that NRC work, which olchupies such a rmnD part of the digital world, would attract in-depth attention from thel Echnical t

community.

One is tempted to excuse the NAS Committee concems for a variety ofreasons. Butgese concerns are repetitions of concerns raised in the past. They may be,indeed, festeringissues that ACRS ought to examine:

- What should be the level of technical participation of NRC staff within } e various technical communities and is this level of technical participation an aspect ofefforts now underway to improve the technical capabilities ofNRC's research stkf'

- How should NRC technical work, much of which is very applied and likely not to be at the forefront of technology by intent, be made available to the technical communities? Can NRC go beyond the public comment practices and tr* i/to get work in the archiva] literature? Ha not the NRC together with other reactor safdty research organizations in the world created its own technical community? Is this ah ood thing to have done, or would it be better to rely on the technical communities o'f the various specialized disciplines?

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Perhaps, the ACRS could take some time at one ofits meetings to discuss and refmg these questions. The questions could, then, be put to the Director ofNuclear Regulatory hearch on the occasion of the next meeting with him.

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Janet / Patty Disk: Travel.Frm 9/9/94 ACRS SPECIAL TRAVEL ENDORSEMENT FORM THIS FORM IS TO BE USED TO REQUEST ACRS ENDORSEMENT OF SPECIAL TRAVEL WHEN NRC SUPPORT FOR PARTIAL OR FULL REIMBURSEMENT OF EXPENSES AND/0R T THIS PROCEDURE IN ND WAY LIMITS THE FREEDOM OF A MEMBER TO PARTICIPATE IN A INDIVIDUAL AT PERSONAL EXPENSE. PLEASE SUBMIT THIS FORM TO THE PLANNING AN SUBCOMMITTEE AT LEAST 60 DAYS PRIOR TO THE MEETING. IF POSSIBLE. SUPPLEMENTAL MAY BE ADDED AS DETAILS DEVELOP.

Member Name: N. //, b 7 A A/A Date Submitted:

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i ACRS SPECIAL TRAVEL ENDORSEMENT FORM THIS FORM IS TO BE USED TO REQUEST ACRS EWORSEMENT OF SPECIAL WEN MtC SUPPORT FGL PARTIAL OR FULL REIEURSEMENT OF EXPENSES AW THIS PROCEDURE IN W WAY LIMITS THE FREEDOM OF A EWER TO PARTICIPA INDIVIDUAL AT PERSONAL EXPENSE. PLEASE SUBMIT THIS FORM TO THE PLAN SUBCOMMITTEE AT LEAST 60 DAYS PRIOR TO THE EETING. IF POSSIBLE. SUPPL MAY BE ADDED AS DETAILS DEVELOP.

T 5 Melc53 Member Name: d TE7'3 X/A Date Submitted:

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9/9/94 ACRS SPECIAL TRAVEL ENDORSEMENT FORM THIS FORM IS TO BE USED TO REQUEST ACRS ENDORSEMENT OF SPECIAL TRAVEL REQUESTS BY'NEMBERS WHEN NRC SUPPORT FOR PARTIAL OR FULL REIMBURSEMENT OF EXPENSES AND/0R TIME IS DESIRED.

THIS PROCEDURE IN NO WAY' LIMITS THE FREEDOM OF A HEMBER TO PARTICIPATE IN A MEETING AS AN INDIVIOUAL AT PERSONAL EXPENSE-PLEASE SUBMIT THIS FORM TO THE PLANNING AND PROCEDURES SUBCOMMITTEE AT LEAST 60 OAYS PRIOR TO THE MEETING IF POSSIBLE.

SUPPLEMENTAL INFORMATION MAY BE ADOED AS DETAILS DEVELOP.

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kMANAGE$ENT) y 4

Nuclear Utilities Software l

Management Group Sixteenth Semi-Annual Workshop Theme:

Regulatory Compliance & Issues j

i May 7 - 8,1997 Hosted by:

Illinois Power Company at the Jumer Hotels Chateau Bloomington, IL (309) 662-2020 Mr. Hick Rogers Stooring Committee Chairman (804)885 3011 Mr. Morgon Libby Staering Committee Mnmber (860)832 4726 Mr. Rich Lomax Steuring Cornmittee Mernbar 1402) 825 5201 Mr. Will.ain Olseo Program Manager (610)582 5945

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...,......w. rim 1 ACRS SPECIAL TMVEL ENDORSEMENT FORM THIS FORM IS TO BE USED TO REQUEST ACRS ENDO WHEN NRC $UPPORT FOR PARTIAL OR FULL REIMBURS THIS PRDCEDURE IN NO WAY LIMITS THE FREED 0H OF INDIVIDUAL AT PERSONAL EXPENSE. SUBCOMMITTEE AT LEAST 60 DAYS PRIOR TD THE HEETING, IF POSSIBL MAY BE ADDED AS DETAILS DEVELOP. SUPPLEMENTAL INFORMTION Nesbtr Name: G. Apostolakis Date Submitted:_ March 31, 1997 Dates of Planned Trip: 4/14/97 to 4/15/97 Destination: Atlanta Meeting or Facility to be Visited:

1. 0 Off1**8 Purpose / Relevance to ACRS Business:

Mr Stephen Rosen and Mr. Rick ___ \\ Grantom of the South Texas Project are organizing a meeting w1Ln senior anyv managemeni iv '*aan U s wn TTE G ; ;i ' -- - w n, .,,a +n hvier & hem en the risk-informed activities that the industry is sponsoring. I have been invited as the chair of the PRA subcommittee to talk about the latest NRC activities on rufun anu re Auvaut m n5 v4.... Participation (Invited Speaker, paper presented. etc.): Invited speaker. Justification' (Foreign Travel Only): Ntc SUPPDRT REQUESTED Air Fare: Yes No Per Diem: Yes % No Daysck Registration: $ 4$L Compensation: Yes No M Days TOTAL P.02 ~, p

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4 } The Light comp any9848at Tese. %.4 Ensetete D.serettag asetten F 0 pos aSe Waareceth. To.se 77483 4 1 sas.es useismeap April 2,1997 i Dr.Gooege Apos01 akin Massachu>etts Inatitute of Technology 77 Massachusetts Avenue 1 Room 24 221 Department of Nuclear Engbeering: Cambridge, MA 02139-4307

Dear Professor Apouolakis:

We are pleased that you will be able to join Rs:k Grantom and myselfin the acminar on Probabilistic Safety Analysis (PS A) at the institute et Nuc! car Power Operations (INPO) in 1 l Atlanta beginning at I:00 p m. on April 15,1997. This wminar is being prownted at the request j or 1NPO rnar.agenwnt to proside key 1NPO perwonnel with -

1. a background in the history of the development nf PS A techniques,recent ACRS activities in the area of Risk informed. Performance Based regulation and related Nuclear Regulatoiy Commission Regulatory Guide development status.-Profcanor Apodolskit i

2. e utility management's perxpective on the uses of PSA-Steve Roacn liouston Lighting &

Power / South Texa> Project und

3. attributes of good PSA development and utilization practices at nuclear inflities-Rick Grantom-flouston Lighting & Power / South Texas Prvject The adience will be INPO Senior and Evaluation Team management and evaluators We th' ink this will he a particularly useful and lively seminar and we look forward to weing you there.

Sincerely, .. )

5. L. Rose

Manager, Risk Management & Industry Relatitms c: Rick Grantom L. E. Martin Bruce Keener (INPO)

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