ML20148A345

Transcript of ACRS 441st Meeting on 970502 in Rockville,Md. Pp 216-298.Certificate Encl

ML20148A345
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Issue date:	05/02/1997
From:	Advisory Committee on Reactor Safeguards
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ACRS-T-2099, NUDOCS 9705080178
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Official Transcript cf Prece: dings O

NUCLEAR REGULATORY COMMISSION

1. CRST-20 99

Title:

Advisory Committee on Reactor Safeguards 441st Meeting TRO4 (ACRS)

RETURN ORIGINAL TO BJWHITE Docket Number:

(not applicable)

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Location:

Rockville, Maryland O

4 Date:

Friday, May 2,1997 AD RS Of"ce Jopy-Ref-

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Work Order No.:

NRC-1101 Pages 216-298 l(j!!} ![.,I,ll, j

NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

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LJ DI8 CLAIMER PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MAY 2, 1997 The contents of this transcript of the proceedings of the United States Nuclear Regulatory i Commission's Advisory Committee on Reactor Safeguards on MAY O(_) 2, 1997, as reported herein, is a record of the discussions recorded at the meeting held on the above date. d This transcript has not been reviewed, corrected and edited and it may contain inaccuracies. O'%.s NEAL R. GROSS COURTREPORTERS ANDTRANSCRIBERS 1323 RllODEISLAND AVENUE,NW (702)234-443( WAS!!!NGTON, D C. 20005 (202)234 4433

216 1 UNITED STATES OF AMERI_'A 2 NUCLEAR REGULATORY CO%4ISSION ,m \\ 'Y 3 + ++++ 4 441st MEETING S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) 6 +++++ ) 7 FRIDAY, MAY 2, 1997 8 ++ +++ 9 ROCKVILLE, MARYLAND 10 11 The Advisory Committee met at the Nuclear 12 Regulatory Commission, Two White Flint North, Room T2B3, 13 11545 Rockville Pike, at 1:00 p.m., Robert L.

Seale,

,G 14 Chairman, presiding. 15 16 COMMITTEE MEMBERS: 17 ROBERT L. SEALE CHAIRMAN 18 DANA A. POWERS VlCE CHAIRMAN 19 GEORGE E. APOSTOLAKIS MEMBER 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 AQ 25 NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234 4433 WAS!!!NGTON, D C. 20005-3701 (202) 234-4433

217 1 ACRS STAFF PRESENT: 2 JOHN T. LARKINS Exec. Director ,s \\'~'] 3 MICHELE KELTON Tech. Secretary 4 ROXANNE SUMMERS Tech. Secretary 5 SAM DURAISWAMY 6 CAROL A. HARRIS 7 RICHARD P. S.AVIO 8 PAUL BOEHNERT 9 NOEL DUDLEY 10 MEDHAT M. EL-ZEFLAWY 11 MICHAEL MARKLEY 12 AMARJIT SINGH 13 ,r m 6 1 '\\ / 14 ALSO PRESENT: 15 RICHARD P. CORREIA 16 THOMAS A. BERGMAN 17 SUZANNE BLACK 18 MARK CUNNINGHAM 19 PETE WILSON 20 21 22 23 24 ,s ~% 'w.,) 25 NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 R1(ODE ISLAND AVE..N.W. (202) 234 4433 WASi!INGTON, D.C. 20005-3701 (202) 234 4433

218 1 A-G-E-N-D-A 2 Acenda Item Pace fcq \\) 3 Opening Remarks 219 4 5 Implementation of the Maintenance Rule 6 Richard Kress 220 7 Richard Correia 221 8 Thomas Bergman 240 9 10 Staff Requirements Memorandum (SRM) on 11 Direction Setting Issue 22, Research 12 Dana Powers 276 13 /^% 14 15 16 17 18 19 20 21 22 23 24 ?% $) 25 NEAL R. GROSS COURT REFURTERS ANDTRANSCRIDERS 1323 7110DE ISLAND AVE..N.W. (202) 234 4433 WAS'.!NGTON, D.C. 20005-3701 (202) 234-4433

219 1 P-R-O-C-E-E-D-I-N-G-S 2 (1:05 p.m.) 73 \\ LJ 3 CHAIRMAN SEALE: The meeting will now come to 4 order. Since we didn't have the tran3criber this morning 5 I thought I'd read this piece of paper. This is the 6 second day of the 441st meeting of the Advisory Committee 7 on Reactor Safeguards. During today's meeting the 8 committee will: 9 (1) Continue discussions on SRM -- pardon me, 10 the DSI 22 un Research; 11 (2) Implementation of the Maintenance Rule; 12 (3) Future ACRS Activities; 13 (4) Reconciliation of Comments; and /'~N 14 (5) Proposed ACRS Reports. 15 We've already met with the Commissioners to 16 discuss items of mutual interest. 17 This meeting is being conducted in accordance 18 with the provisions of the Federal Atomic Energy Act. 19 Mr. Sam Duraiswamy is the designated federal 20 official for the initial portion of this meeting. 21 We have received no written statements or 22 requests for time to make oral statements from members of i l 23 the public regarding today's sessions. 24 A transcript of portions of the meeting is r-) l ) 25 being kept. It is requested that the speakers use one of { s ) NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. [ (202) 234 4433 WASillNGTON, D.C. 2000$ 3701 (202) 234-4433 I

220 1 the microphones, identify themselves and speak with 2 sufficient clarity and volume so that they can be readily 7s 1 1 V 3 heard. 4 This afternoon we're going to hear about the 5 implementation of the maintenance rule; something that 6 we've all been very interested in. And Dr. Kress, that's 7 your subcommittee so I'll turn it over to you. 8 MEMBER KRESS: Thank you, Mr. Chairman. The 9 purpose of this session is to have a briefing. It's a 10 presentation by the NRC staff about the results and the 11 lessons learned from their implementation and initial 12 baseline inspections related to the maintenance rule, 13 which like you said, we all are very interested in. /m I \\ \\_/ 14 Partly because it's been touted as a risk-15 informed, perternance-based regulation, but in reality it 16 was crafted in the early '90s before the word risk-17 informed became in-vogue. But because of the inherent 18 nature of nuclear regulations, it is risk-informed to some 19 extent. But the actual rule I think, has been in effect 20 now for -- 21 MR. CORREIA: About nine months. 22 MEMBER KRESS: Nine months? And the NRC has 23 conducted pilot assessment programs for about three years 24 along with this. So today I guess we'll just hear a (3 t 1 25 briefing and see what lessons they've learned, and I'll %./ NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASil!NGTON, D.C. 20005-3701 (202) 234-4433

221 1 turn it over to you with that short introduction. 2 MR. CORREIA: Thank you. My name is Rich fs I \\ ~ 3 Correia. I'm a section chief in NRR responsible for 4 maintenance rule programs. I've bee-in that position 5 since shortly after the rule was i Jued in 1991. I'll be 6 giving part of the presentation today on the background of 7 the rule and an overview of the rule. 8 Tom Bergman, who is in my section, will give 9 the presentation on the baseline inspection results and 10 clarifi e.tions we've recently made to our Regulatory Guide 11 for the maintenance rule. And then I'll finish off with 12 some lessons learned and insights we've learned from the 13 initial implementation of the rule. (_/ 14 The rule was written and issued in July of 15 1991 for a number of reasons. The Commission -- one of 16 the most largest concerns the Commission had in the '80s 17 were the number of transients and scrams caused by 18 failures of balance of plant equipment due to ineffective 19 maintenance. And most of these systems weren't covered by 20 existing regulations. And still today, based on the 21 latest AEOD data it shows that many transients and scrams 22 are still initiated by failures in balance of plant 23 equipment. 24 Another reason the Commission was interested (O % </ 25 in establishing a maintenance rule was the results from NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASIIINGTON, D.C. 2(KK)5-3701 (202) 234-4433

222 1 the maintenance team inspections that were conducted in 2 the late 1980s. And there were three findings that g- .%_) 3 resulted from these inspections th&t the Commission 4 thought was significant and increased their concern with 5 having a maintenance rule. 6 One had to do with, there were no -- licensees 7 weren't trained in equipment performance. Another reason 8 was that risk wasn't being necessarily considered during 9 the planning and scheduling of preventive maintenance 10 activities. And another reason was, poor root cause 11 determinations and corrective actions that ultimately 12 resulted in additional failures of the same kind. 13 So those two issues I think, were the most .I~)J 14 significant of the concerns the Commission had at the time 15 and they went forward and issued the maintenance rule. 16 As Dr. Kress just said, initially it wasn't 17 called a risk-informed, performance-based rule. I think 18 it was called a results-oriented performance-based rule. 19 Because the rule focused on the results of licensee's 20 preventive maintenance activities and not on the processes 21 and procedures that they used to implement those programs. 22 But the rule does encourage, through the 23 statements of consideration, the use of risk insights. 24 lt's not a requirement but encourages the use of PRA A(,) 25 insights. For example, once a licensee determines which NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234-4433 WASillNGTON, D.C. 20005-370' (202) 234 4433

223 1 structures, systems, and components in their plant are in 2 the scope of the rule, they can use risk insights to ,g i i G' 3 categorize these SSCs into high or low, safety-significant 4 categories. 5 It's not that they're changing or reducing the 6 regulation based on these categorizations, it's just a 7 better way to manage the program, to pay most attention to 8 the high, safety-significant SSCs, and somewhat less for 9 the lower categorizations. 10 Licensees can also use risk insights to 11 establish goals required by (a) (1) of the rule, or 12 performance criteria that licensees use to demonstrate 13 compliance with (a) (2) of the rule. And certainly we've \\ N/ 14 seen in many cases, the (a) (3) safety assessments that are 15 recommended to be done before licensees perform preventive 36 maintenance. 17 Risk insights are used in combinations of 18 other deterministic information to evaluate the overall 19 plant safety before taking equipment out of service for 20 maintenance. 21 The rule gives licensees a lot of flexibility 22 on how to establish programs or how to implement them. 23 The goals and performance criteria that are used can be 24 modified / changed, based on actual system performance, A(,) 25 risk-insights. The rule even allows that goals not have NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234 4433 WAStilNGTON.D.C. 2(Nx)5-3701 (202) 234-4433

i 224 1 to be established or monitored if they demonstrate 2 effective preventive maintenance under paragraph (a) (2). I) 3 Initial results from the baseline inspections 4 have led us to believe that the rule can be inspected and 5 enforced consistently. We've spent a lot of effort in 6 training our inspectors, Headquarter's oversight of the 7 program. Each and every baseline inspection has someone 8 from my section on a team. We maintain constant contact 9 with the teams during the inspections and afterwards. 10 In fact, the first inspection, I was the team 11 leader, we had every team leader from the region on that 12 team as well as everyone from my section on that team. 13 And also, in the enforcement arena, in concert with the r~ f 14 office of enforcement and the regions, we developed 15 enforcement guidance specifically for the maintenance 16 rule, and a panel that reviews every potential enforcement 15 action for the maintenance rule to ensure consistency. 18 But the flexibility that the rule gives 19 licensees does give us some challenges in that they can 20 establish their programs specific to their facilities, of 21 course; each plant has different design features, system 22 boundaries; they can scope the structures, systems, 23 components in the rule either by system-specific 24 categorizations or they can do it by functions. We found p) 25 either case is acceptable. y NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASil[NGTON, D.C. 2tXX)$.3701 (202) 234-4433

225 1 So information that a particular inspector 2 learns about one site doesn't necessarily translate to the s [ \\ \\,') 3 next site; it's almost like starting all over again. So 4 it's quite a challenge, but we think with the 5 communications we've had with the industry, with our 6 regional people, amongst ourselves, the constant oversight 7 during the baseline inspections, we feel that we are being 8 consistent in the way that these inspections are being 1 9 conducted. 10 MEMBER APOSTOLAKIS: I have a question here. 11 I'm a little bit perplexed. Judging from what you've just 12 said, I would say this is indeed a performance-based rule, 13 and I don't know if you've seen it but there are four O 14 points or four definitions to this -- four points that 15 constitute the definition of a performance-based 16 regulation: define your measurable quantities, grant d 17 flexibility, and so on. L8 So I would say this is a performance-based "9 rule. And then I remember what I read in the special 20 evaluation report by the Office of Inspector General. 21 And, " Representatives of the industry told us that if, 22 under the maintenance rule they could still get Appendix B 23 violations even though they were meeting their performance 24 goals, then the rule was not truly performance-based. NRC O) ( 25 staff generally do not see the maintenance rule as a NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE.,N.W. (202) 234 4433 WASHINGTON, D C. 2(XX)5-3701 (202) 234-4433

226 1 vehicle for regulatory relief. Many staff members pointed 2 out that the current enforcement guidance for the rule -) 3 states that the rule does not supersede other 4 requirements, specifically referring to Appendix B." 5 So it seems to me that we have here a rule 6 that has certain performance requirements, but still the 7 licensee has to comply with everything that led the 8 licensee to meet the requirements. Is that correct? 9 Because you said they have flexibility and yet it says 10 here that that does not provide relief. You know, you can 11 meet the criteria, but still you have to do everything _2 else. 13 MR. CORREIA: That's true. The maintenance (k/ 14 rule is an additional regulation. Licensees still have to 15 meet Appendix B requirements as well as maintenance rule 16 requirements. 17 MEMBER APOSTOLAKIS: So the statement that 18 it's a performance-based rule is really very -- it's true 19 I think, in a sense, but it's very limited. The rule 20 itself is performance-based, but we have other regulations 21 that don't make it performance based in the broader sense. 22 And I'm wondering why that is the case. Why don't you 23 trust them? I mean, if they meet the performance goals, 24 what's the problem? ,em ) 25 MR. CORREIA: Well, we'll get into that -- I is NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RIIODE ISLAND AVE.,N.W. (202) 234 4433 W ASillNGTON, D C. 2(X105 3701 (202) 234 4433

227 1 might as well talk about that now. Right now, our 2 baseline inspections are very programmatic. To give us ,~ 3 the confidence that licensees have a program in place that 4 will give us reasonable assurance that in the future, when 5 we walk away from programmatic inspections and only look 6 at performance, they'll be doing it right consistently. 7 And this is a concern of the industry also. 8 But they understand this is really the first -- one of the 1 9 first performance-based inspections, but we need to assure j l 10 ourselves, and they need to assure themselves, that i 11 they're doing it right. Have a stable program in place to 12 allow them to go and implement the rule. And once we're l 13 doing with the baselines, fully expect to only look at the n l 1 k/ 14 resulte of their implementation and not the program. 15 MEMBER APOSTOLAKIS: So is it then correct to l 16 understand from this that we are in a transition period, 17 that you establish this rule, you don't want to grant I 18 relief anywhere else until you and the licensees are 19 convinced that the rule works? I mean, that's the only 20 way I can see this. And then of course the question is, 21 how long is this transition period? 22 MR. CORREIA: The baselines are scheduled 23 currently to be completed by mid-1998, next year. When l 24 you say grant relief, I think the maintenance rule, in f3 !,) 25 itself, won't grant relief to anything, but it could form NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE.,N.W. (202) 234 4433 WASil1N GTON, D.C. 20005-3701 (202) 234 4433

228 1 a basis for relief in other areas, if licensees take f3 2 credit for what they're doing under the maintenance rule. ( i L.,) 3 I believe that's a possibility. 4 I think where licensees will see relief is, 5 how many inspectors they see and how often, and what 6 they're looking at. 7 MEMBER APOSTOLAKIS: Especially the latter. 8 MR. CORREIA: Yes. Yes. 9 CHAIRMAN SEALE: A potentially related 10 question. We're aware of the fact that there have been i 11 some industry initiatives, things we've called the pilot 12 studies, and two of those -- in-service inspection and in-13 service -- a 14 MEMBER BARTON: Testing. 15 CRAIRMAN SEALE: -- testing, should -- not 16 just could, but should -- impinge rather specifically on 17 certain aspects of the maintenance program. Have you done 4 18 any forward-thinking about how that kind of proposal, if 19 it's granted, would impact upon your maintenance rule 20 enforcements? 21 And now you've brought up another issue and 22 that is, now you may have three piles or four piles of 23 regulation, none of which is precisely consistent with 24 each other. And I can understand how the Utilities begin (x (_,) 25 to believe that they're just getting bandaids on bandaids NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE..N.W. (202) 234-4433 WASillNGTON. D.c. 2tx105-3701 (202) 234-4433

229 1 but no real relief. The blood just flows. 2 MR. CORREIA: Personally, I don't have much (, sI %./ 3 knowledge of what they're doing in the ISI/IST area since 4 we are totally consumed by maintenance rule inspections, 5 but I would imagine that if a licensee crafted their 6 ISI/IST program such that it could be used as a way to 7 implement the rule and meet ISI/IST requirements, they 8 could just eliminate some redundant requirements. 9 CHAIRMAN SEALE: Yes. It's essentially 10 bringing the risk-informed element into the detail of the 11 maintenance process. But we still haven't figured out how 12 to resolve this multiple jurisdiction program. 13 MEMBER APOSTOLAKIS: Yes, and again, you know, \\s) 14 whether reinforcing this impression out there that the 15 Agency is not serious about performance-based and risk-16 informed regulations. And if we have a rule that is 17 performance-based, I just don't know why we don't treat it 18 as such. I mean, maybe that's not your job, but somebody 19 in the Agency has to think about it. 20 Here we have a rule, we advertise it as a 21 performance-based rule, we give licensees flexibility, but 22 then we have to realize that the rule does -- the NRC does 23 not. 24 MEMBER BARTON: Right. A $.,) 25 MEMBER APOSTOLAKIS: Okay. And I don't know NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234 4433 WASillNGTON, D.C. 20005-3701 (202) 234-4433

230 1 if the rest of you feel that's a reasonable thing to do. l l 2 I'm a little bit -- actually more than a little bit Q 3 perplexed. 4 MR. SHACK: Do you find it so unreasonable 5 that they have a baseline inspection to check that the 6 program is in place? I mean, you want to wait until you 7 see the results? You know, you think it's unreasonable to 8 ask for a baseline inspection of the program? 9 MEMBER APOSTOLAKIS: No, no. But I don't see 10 this as a problem. This is just an additional regulation. 11 MEMBER BARTON: That's right. The maintenance 12 rule is an additional rule above and beyond all the other 13 rules and regulations. (s N-- 14 MEMBER APOSTOLAKIS: Yes. And that's what I 15 find unacceptable. 16 M't. SHACK: Oh, but that was true in '91. I 17 mean, it was never advertised as anything but an 18 additional rule. 19 MEMBER APOSTOLAKIS: But if I look at this 20 slide, knowing nothing else, I would say we're making 21 tremendous strides towards risk-informed and performance-22 based regulations. And it turns out that we're not. In 23 fact, we're undermining the process. 24 VICE CHAIRMAN POWF'S: Well George, the only /") j 25 way you -- I mean, you cannot go after Appendix B without NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RIIODE ISLAND AVE.,N.W. (202) 234 4 433 WASillNGTON,D C. 20005 3701 (202) 234-4433

231 1 going after Appendix B. I mean, you cannot use some other 2 rule to say I get out of Appendix B. ) 3 MEMBER APOSTOLAKIS: Who, in this Agency, is 4 thinking at that level? You know, I understand that 5 VICE CHAIRMAN POWERS: You and I. 6 MEMBER APOSTOLAKIS: I'm trying to do that, 7 but I think my colleagues -- 8 VICE CHAIRMAN POWERS: We just disagree. 9 MEMBER APOSTOLAKIS: Pardon? 10 MEMBER BARTON: We're not disagreeing with 11 you. 12 MEMBER APOSTOLAKIS: No, I think Bill is. 13 MR. SHACK: Well, I mean, if the rule was set C'i \\2 14 up to increase the inspection of balance of plant 15 components, that's a new rule. Now, when you have a new 16 rule to do that you could do it with a new prescriptive 17 rule or you could do it with a new performance-based rule. 18 It's a new rule, there's no getting away from 19 that. They did choose to make the new rule a performance-20 based rule. So I mean, you could argue that there was no 21 new rule needed, which -- 22 MEMBER APOSTOLAKIS: No, I'm not talking that 23 24 MR. SHACK: -- industry certainly did for (~~)N quite some time. But given the fact that you're going to 25 NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE. N.W. (202) 234-4433 WASilINGTON, D.C. 20005-3701 (202) 234-4433

232 1 have a new rule, you have a performance-based rule. 2 MEMBER APOSTOLAKIS: But isn't this a very '~ 3 limited view of this? I mean, we are not talking -- I 4 mean the individual rule, yes, is performance-based, but 5 the idea is not really to have individual rules that are 6 performance-based, to have regulations that are 7 performance-based. 8 VICE CHAIRMAN POWERS: George, all you're 9 doing is railing against the fact that it takes time to 10 change all the rules. 11 MR. SHACK: This wasn't meant to overhaul the 12 whole regulatory system. 13 MEMBER APOSTOLAKIS: I know Rich is not. But 2 t' % r t \\/ 14 I think the record should reflect this and -- are we 15 writing a letter on this anytime soon? 16 MEMBER KRESS: Not unless you want to. 17 VICE CHAIRMAN POWERS: You can write a letter 18 on it anytime you want to. 19 MEMBER KRESS: This was just a briefing to let 20 us know what the progress has been, the lessons learned, 21 and if you've got some overriding points you want to make, 22 we can write a letter. 23 MEMBER APOSTOLAKIS: But you're willing to be 24 convinced? C\\ is,) 25 MS. BLACK: If I may say something -- Susie NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASillNGTON, D.C. 200(M-3701 (202) 234-4433

233 1 Black, branch chief. I have QA also, and NEI came in and 2 met with us -- I think it was towards the end of February 3 -- with a proposal that building on this monitoring 4 program to change QA requirements, and we are meeting with 5 them again -- I believe May 22nd is the date I've heard -- 6 to discuss their proposals for using this monitoring. 7 And in fact, in all of the performance-based, 8 risk-informed reg guides, we are giving the licensees the 9 option of using their maintenance rule program to satisfy 10 the monitoring requirements. 11 MEMBER APOSTOLAKIS: Yes, I mean, clearly you 12 cannot divorce this from Reg. Guide -- I think it's 1064? 13 MS. BLACK: Yes. [\\ 14 MEMBER APOSTOLAKIS: Yes. So if this is 15 happening then all I can saw is that I'm very pleased to 16 hear it. Yes. 2 17 MR. CORREIA: I believe many licensees want to 18 use their maintenance rule programs as a foundation for 19 many of these other pilot programs. I see they're all 20 using performance or condition monitoring, they want to 21 use the same process throughout, at least to be consistent 22 in the way they implement these programs. 23 CHAIRMAN SEALE: George, if we decide we would 24 like to write up something that would perhaps, anticipate r~T (_) 25 tying all of these things together and identifying some of NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. g202) 234-4433 WASillNGTON, D.C. 20005-3701 (202) 234-4433

234 1 the options that might be available to in fact, modify ] 2 things, then that's something we might want to do as an g-O 3 initiative. 4 MEMBER APOSTOLAKIS: Yes, and I think that 5 before we do that, though, I think we should hear from Ms. 6 Black and her colleagues about these new activities, 7 because it's a whole package. But that's something we'll 8 come back to, I'm sure. ) 9 MR. CUNNINGHAM: If I might -- 10 MEMBER APOSTOLAKIS: Excuse me -- Mark 11 Cunningham. 12 MR. CUNNINGHAM: Mark Cunningham from the 13 staff. I believe we're coming back in June to discuss the I \\~- 14 PRA implementation plan with the full committee -- the 15 middle of June or something -- and that might be a time 16 when we start to tie how the burden reduction regulatory 17 guide efforts depend, or rely, or make use of maintenance 18 rule work, l 19 Kind of look at it that way as opposed to 20 maintenance rule going the other way. It's an 21 underpinning of a lot of things in the risk-informed ISI 22 or some things like that. That might be a better forum 23 for that. 24 MEMBER APOSTOLAKIS: That's fine with me. m(,) 25 June is soon enough. NEAL R. GROSS COURT REM)RTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASil!NGTON.D C. 20005 3701 (202) 234-4433

235 1 MR. CORREIA: Thank you. j 2 MEMBER MILLER: Excuse me. Didn't the 7. i ) \\s~/ 3 industry originally want to tie the maintenance rule to 4 the graded quality assurance program? 5 MS. BLACK: Yes, that was part of their 6 proposal, but -- 7 MEMBER MILLER: That was back -- 8 MS. BLACK: Back -- way back in 1993 or '94. 9 But their monitoring program which they proposed in their 10 first guidance document, we didn't find acceptable. 11 Because as I stated, I think, in one of the more recent 12 ACRS meetings, their monitoring program for low, safety-13 significant SSCs, is at the train level, where you wait \\s / 14 till you have two scrams or two safety system actuations, 15 and we didn't think that was a fine enough monitoring 16 system for finding whether QA was breaking down. 17 Then we stopped our negotiations on that 18 altogether, and they wanted to go ahead with just the 19 risk-informed part. But the more we got into it we 20 realized you do need some sort of monitoring program to 21 see what the effectiveness of QA is, but not -- 22 MEMBER MILLER: So we're back to now, trying 23 to tie them again, together, is that what it is? 24 MS. BLACK: That'e the most recent proposal by n(,) 25 -- the maintenance rule has these high-level monitoring NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RIIODE ISLAND AVE..N.W. (202) 234 4433 WASI(INGTON, D C. 20005-3701 (202) 234 4433

236 1 programs, but they also rely on more detailed monitoring 2 programs that are already in place. ,~s (') 3 And so the latest proposal, NEI I think, is ) 4 going to come in with his taking advantage of these 5 underpinning monitoring programs that don't necessary show 6 up in the maintenance rule results but they are the basis 7 of it. 8 MR. CORREIA: In a way of background, briefly, 9 the rule was issued as you know, in July of 1991, with a 10 5-year implementation period. The first two years the 11 Commission directed the staff to develop regulatory 12 guidance; the last three years were for licensees to 13 implement that guidance. ,m 14 During the first two years -- almost 15 immediately after the rule was issued -- NUMARC at the 16 time, now NEI, came to the staff and proposed -- they 17 developed in parallel with our regulatory guide, an 18 industry consensus standard for implementing the rule. 19 Long story short, by May of 1993 they completed work on 20 NUMARC 93-01, which we turned around and endorsed through 21 the first version of Reg. Guide 1.16r. 22 And 1.160 was revised slightly in, I think, 23 1995, to reflect a relatively minor rule change where we 24 changed the periodic assessments from annual to once for A !) 25 refueling cycle. And we'll talk shortly about Revision 2. NEAL R. GROSS COURT REM)RTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASillN GTON, D.C. 20005-3701 (202) 234-4433

237 1 Late in December of 1993 we developed our 2 first version of the inspection procedure for the d 3 maintenance rule, 62706. We put it out for public 4 comment, we had a workshop, we had nine pilot inspections 5 at nine volunteer sites. 6 We had another public workshop to explain to 7 the industry and the public what the inspection procedure 8 was all about, how we would conduct these baseline 9 inspections, and then we issued the procedure final 10 shortly thereafter, in August of '95. 11 We also wrote a new procedures for our 12 resident inspectors -- or their code program, 62707 -- 13 that incorporatv: some of the more programmatic /^N ( ) 's > 14 inspections that they were currently doing, looking at 15 maintenance, process, and control, and we also brought in 16 maintenance rule requirements. 17 So on a routine basis, since the rule went 18 into effect, our resident inspectors are looking at a more 1 19 limited part of licensee's implementation of the 20 maintenance rule, but much more from a performance-based i 21 perspective than a program. 1 1 22 They're actually looking at work in the field, l 23 what preventive maintenance activities are going on, what 24 equipment has failed, and then following through with the ,\\(,) 25 requirements of the rule to see how the licensee has or f NEAL R. GROSS i COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASilINGTON, D C. 20005-3701 (202) 234-4433 )

238 1 has not implemented the rule. 2 And eventually over time this will be the 7s \\~,) \\ 3 maintenance rule inspection that will be conducted 4 routinely once the baselines are done. 5 With that, I'd like to turn it over to Tom 6 Bergman. Tom's been in our section for quite a few years 7 now. He's written I think, four of the most recent SECY i 6 papers on the status of the maintenance rule and was the 9 primary author of Revision 2 to Reg. Guide 1.160. And 10 he'll talk about the baseline inspection results and the 11 changes to the Reg. Guide. 12 MR. BERGMAN: To date, we've completed 24 13 inspections. As Rich mentioned earlier each inspection is 14 unique, largely because of the flexibility we gave 15 licensees. 16 VICE CHAIRMAN POWERS: Are the inspections 17 when you say 24, is that 24 units or is that 24 sites? 18 MR. BERGMAN: Well, it depends. For example, 19 Nine Mile -- there's two units at the site but we only di'd 20 one inspection. It depends if they have separate 21 maintenance rule programs or not, so I guess I'd 22 characterize it as 24 maintenance rule programs have been 23 inspected. 24 VICE CHAIRMAN POWERS: So you have something O 25 like 80 te do? NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234 4433 WASil!NGTON, D.C. 20005-3701 (202) 234-4433

i 239 1 MR. CORREIA: Yes. 2 MR. BERGMAN: Yes, 80 to 83, I think. 7 o s 3 VICE CHAIRMAN POWERS: Eighty-three total. 4 MR. BERGMAN: We're approximately on our 5 planned schedule. 6 MR. SHACK: Now again, each inspection is 7 unique. I assume they're all using the NUMARC guidance, 8 though -- 9 MR. BERGMAN: They all use -- 10 MR. SHACK: -- but even with that it's still - 11 12 MR. BERGMAN: Right, what the guidance does 13 is, it gives them similar approach to (a) (1) and (a) (2), (~'% k-14 there's common terminology, maintenance preventable 15 functioral failures, what performance criteria are, what 16 goals are. But even when you go to two very similar units 17 -- I was at inspections at both Nine Mile 1 and Oyster 18 Creek, which are both BWR IIs -- very different ways to 19 implement the rule. 20 They have different organizations, who's 21 responsible for what aspect is different. Nine Mile did 22 the scoping by systems so they had in the range of 150 23 systems. Oyster Creek took what we call this functional 24 approach; they had over 360 sort of subsystems. f~h ( ) 25 So you can't say, well I was at Nine Mile 1, NEAL R. GROSS COURT REPORTERS AND TRANSCRWERS 1323 Ri!ODr..SLAND AVE..N.W. (202) 234-4433 WASillNGTON.D.C. 2(X)05-3701 (202) 234-4433

i 240 1 how did they do it? Oyster Creek should look the same. 2 You really have to start over with each licensee's program L\\] 3 and say, is this a reasonable approach for meeting the 4 rule? But there are some commonalities. 5 VICE CHAIRMAN POWERS: Do you have a simple, 6 easy -- like 2-or 3-page comparison, one-on-one -- 7 illustrative of these differences that you see? 8 MR. BERGMAN: We didn't provide it here at the 9 Commission briafing. We provided for, I think, 13 sites 10 at the time. Yes, we do periodically do a small table 11 that shows like number of systems, number of systems in l 12 scope, number in (a) (1) versus (a) (2). 13 CHAIRMAN SEALE: Could we get a copy of that, ,/ ~ + \\ Cl 14 which would take care of us? 15 MR. CORREIA: You should have it. SECY-97-502 16 17 MR. BERGMAN: Well, it's in the slides, 18 though. It wasn't part of the paper. 19 Overall, we feel that licensees are adequately 20 implementing the rule. We have seen problems. We've 21 issued a fair number of violations, but the violations are 22 to specific aspects of a requirement. We're not saying 23 this licensee is flat-out not meeting any of the rule. 24 For example, high safety-significant SSCs are ,a ( ) 25 expected to monitor both reliability and availability. %/ NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASil!NGTON,D.C. 2tXX)5 3701 (202) 234 4 433

241 1 We've frequently seen where licensees are not monitoring 2 one or the other. That's a violation, but the rest of ,~s\\ / 3 their program could be perfectly fine and meet the rules. 4 So a number of violations shouldn't be characterized as, i 5 nobody's meeting the rule, period. 6 Where we've seen more than isolated problems 7 it's usually been because some licensees have implemented 8 the rule late, despite the implementation period of, 9 really three years since the guidance was out. Some 10 licensees, either because of organizational changes or not 11 understanding the complexity of complying with this rule, 12 really didn't implement it early enough, and we get there 13 and the program is still being developed when we get on-O 11 site. Those have been the more significant findings. 15 The two most common findings we've had have 16 been what we call inadequate reliability performance 17 criteria or goals. Normally this is because licensees 18 simply are counting the number of maintenance-preventable, 19 functional failures, but they have no technical 20 justification for that number. 21 They don't have any understanding of how that 22 number of failures relates to the number of demands on the 23 cystem during a certain time period; they can't 24 demonstrate any relationship to values assumed in the PRA, ,(,, 25 if that's the method they choose; and they have no NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 Rl! ODE ISLAND AVE.,N.W. (202) 234 4433 WASHINGTON, D.C. 20005 3701 (202) 234-4433

242 1 demonstration that the values of failures was commensurate 2 with safety as required by the rule. ,-s, ( ) 3 MEMBER APOSTOLAKIS: Let me understand that. 4 If my calculation of reliabili' or unreliability or 5 unavailability is number of failures over number of 6 demands or trials, you're saying they're focusing on the 7 numerator but they're not doing anything about the 8 denominator? 9 MR. BERGMAN: They don't know what the 10 denominator is. 11 MEMBER APOSTOLAKIS: Well, that doesn't make j 12 sense. 13 MR. BERGMAN: Well, it doesn't and that's why rs 's-14 they get violations. 15 MEMBER APOSTOLAKIS: But that's the first 16 thing I would derive if I were a licensee. 17 MR. BERGMAN: They're being pushed in that 18 direction. 19 MEMBER KRESS: But only if that were one of 20 your performance goals. 21 MR. CORREIA: That is true. 22 MEMBER KRESS: That wasn't the performance 23 goal, was it? 24 MR. BERGMAN: No, it is. They do call it /~N i ) 25 reliability -- NEAL R. GROSS COURT REPORTFA" ANDTRANSCRIBERS 1323 RiiOD? :sLAND AVE. N.W. (202) 234 4433 WASHINGTON, D.C. 20005-3701 (202) 234 4433

243 1 MEMBER KRESS: In that case it's clear. A 2 MEMBER APOSTOLAKIS: It doesn't make sense. l 3 MR. BERGMAN: And we found cases where the 4 allowed number of failures per cycle was more than the 5 number of demands they would normally expect to see -- 6 they would see like one surveillance per cycle -- 7 MEMBER APOSTOLAKIS: There is such a thing as 8 a principle of conservation of failures. It's right up 9 there with electric charge and mass. 10 MR. BERGMAN: So we're not debating if it 11 should be 90 or 95 percent; we don't want to give you that 12 impression. 13 MEMBER APOSTOLAKIS: I understand. / 3J 14 MR. BERGMAN: We're demanding, are you doing 15 it, period. 16 MEMBER APOSTOLAKIS: Now, the second question. 17 Are you reasonably satisfied that the reliability or 18 availability or whatever, that will be produced from these 19 calculations, is the reliability that applies really, to 20 an actual demand? 21 MR. BERGMAN: Pete, do you want -- I think the 22 question was, are the surveillance-type demands the same 23 as a real demand? 24 MEMBER APOSTOLAKIS: Yes. p-(,) 25 MR. WILSON: My name is Pete Wilson. I'm a NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WAsil!NGTON, D.C. 20005-3701 (202) 234-4433

244 1 senior reactor analyst with the PRA Branch at NRR. We 2 currently do not look at that during the inspection. -.s \\ i 3 Basically is, check to see if they're preserving the 4 assumptions in the PRA but not go into seeing if the 5 surveillance demands really test -- the system would 6 respond the same way in an actual demand. 7 MEMBER APOSTOLAKIS: Well, you said something 8 very interesting. That whether they observed the 9 assumptions of the PRA, you said? 10 MR. WILSON: Yes. 11 MEMBER APOSTOLAKIS: What does the PRA have to 12 do with this? 13 MR. WILSON: If the licensee has used a PRA s 14 for risk ranking, then we expect them to have performance 15 criteria that preserves that risk ranking. 16 MEMBER APOSTOLAKIS: Okay. Okay. Very 17 interesting. 18 MR. BERGMAN: I think every licensee we've 19 been to has sort of -- I don't want to say, baseo their 20 program on PRA, but certainly used PRA in the development 21 of their performance criteria and risk ranking. 22 The second issue was for high safety-23 significant SSCs. At a minimum, we expect the 24 demonstration of effective preventive maintenance to (p) 25 include both reliability and -- NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234 4433 WASil!NGTON. D.C. 20005 3701 (202) 234 4433

245 1 MEMBER APOSTOLAKIS: I thought you were going 2 to the second sub-bullet. It's just amazing. I had 7s l \\ \\ 3 another opportunity to see how some people in the industry 4 confuse these concepts, the site obscure books. 5 I find it incredible that people don't know I 6 the distinction between reliability and availability but 7 vidently -- see, the problem is I think, that before PRA 8 came in full force, people were using the word reliability 9 as a general English term for, you know, the thing working 10 for a period of time, being available when you want it, 11 and so on. 12 But now there is a strict mathematica] 13 definition which has to d) with successful performance c (_- 14 over a period of time. Wl' ether it starts or not is the 15 availability question, but evidently that's very hard to 16 change. 17 And I had opportunities just last week to see, 18 you know, the reliabilities point too, and then I don't 19 know whether it's going to work for a period of time; I 20 was scratching my head. And then I realized what was 21 happening. So I don't know. Maybe that should be part of 22 your courses, Mark. 23 MR. CUNNINGHAM: I believe we do, in those 24 courses, try to stress -- the courses that we have for the t'h ( ) 23 staff -- distinction and define both reliability and NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE. N.W. (202) 234-4433 WASilINGTON, D.C. 2tXX)5-3701 (202) 234-4433

ll 246 l 1 availability. If you go back to the PRA working group 2 days, that's one of the things that was of trouble then l ,y N~] 3 and we continue to work on. 4 MEMBER APOSTOLAKIS: Does the NUMARC document 5 define clearly, these concepts? 6 MR. BERGMAN: It provides a definition of both 7 reliability and availability. 8 MEMBER APOSTOLAKIS: Oh, okay, so there's no i 9 excuse, then. 10 MR. CORREIA: We agree. And they cite them. 11 It's puzzling. 12 MR. BERGMAN: The next issue -- we have issued 13 a number of violations on scoping but most of these have I) j \\/ 14 been on relatively low, safety uignificant SSCs, with the 15 most common problem relating to the scoping criteria for 16 including those non-safety-related SSCs that are relied 17 upon to mitigate accidents, and transients are used in the 18 EOPs. And we've had debate -- they're in the marginal -- 1 19 so they're violations but they're not major violations. 20 Reluctance to identify MPFFs. This one has 21 sort of mystified us. We're not sure why licensees are 22 reluctant to call failures MPFFs. From the standpoint of 23 us regulating the rule, the fact that you have an MPFF 24 isn't an issue; all it does is initiate a process to (q_,/ 25 identify the causes and corrective actions for the r NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RJiODE ISLAND AVE.,N.W. (202) 234-4433 WAS!!INGTON, D.C. 20005-3701 (202) 234 4433

247 1 failure. 2 To the contrary, the failure of a licensee to ,-~ 3 identify an MPFF that was, is a violation of the rule, and 4 so we do sometimes issues violations because we find 5 failures were MPFFs that the licensee did not call them 6 for one reason or the other. 7 On structural monitoring, before the rule even 8 went into effect we realized that the structural 9 monitoring guidance in the NUMARC 93-01 wasn't really 10 adecuate for what they needed to do. Structures are 11 different. You can't really use reliability or 12 availability in general; that you aeed to do condition 13 monitoring. ('S '- l 14 Industry has developed a guideline document 15 that has act yet been endorsed by the staff. We felt 16 enough time had gone by that we put some guidance in Rev 2 17 of the Reg. Guide to clarify it, and basically this change 18 just described to licensees when to move a structure from 19 (a) (2) to (a) (1) based on the conditica of the structure. 20 The last sort of result is on the (a) (3) 21 safety assessments which are not a requirement. That's a 22 "should" in the rule. All licensees have done something. 23 There's a couple of basic approaches: what we call the 24 . matrix approach -- which outlines accepted or prohibited j' \\ (,) 25 configtrations of equipment -- and some licensees also use NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASHINGTON. D.C. 20005-3701 (202) 234-4433

248 1 a risk monitor-type approach. 2 And typically, if they enter a configuration ,g wl 3 that's outside of the matrix they will contact a risk 4 group to get involved as to whether or not that new 5 configuration is acceptable. 6 MR. SHACK: What is structural monitoring? I 7 mean, is it a walkdown of the system? 8 MR. BERGMAN: That's how you monitor -- 9 MR. SHACK: Right. 10 MR. BERGMAN: -- but from a maintenance rule 11 standpoint what we expect them to see is that they will do 12 a periodic evaluation of the condition of the structure to 13 conclude that it is in an acceptable condition and can D, 14 meet its design basis and will continue to do so till the 15 next inspection. But they rely on their existing 16 structural monitoring programs. 17 Weaknesses in these (a) (3) safety assessments 18 have generally been related to the treatment of the non-19 frontline safety systems. Most licensees seem to have a 20 good understanding of the importance of those systems. 21 It's systems just beyond that level that become increased 22 risk when something else is out of service that we cannot 23 completely address in the matrix. 24 MEMBER APOSTOLAKIS: I thought you meant that (3 ,/ 25 they don't treat the support systems well. What you just s NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHGDE 1:'.AND AVE..N.W. ~ (202) 234 4433 WAS'ilNGTON, D.C 20005-3701 (202) 234-4433

249 1 said is different. That if something is out of service 2 then the configuration is different, and the risk fs 3 importance changes. Is that what you meant? 4 MR. BERGMAN: Right, yes. Things that 5 previously may not have been as -- 6 MEMBER APOSTOLAKIS: Ah, okay. 7 MR. BERGMAN: -- but it isn't clear that they 8 always catch that. 9 MEMBER APOSTOLAKIS: So they should have then, 10 least of importance measures under different 11 configurations. Assuming that certain components are 12 down, then they have a new set of risk importance 13 measures, so I may have a new ranking of the operating d 14 components -- 15 MR. BERGMAN: They might but -- that's one of 16 the, I guess you'd call it, a problem with the matrix 17 approach. You can only put so many configurations before 18 it just becomes unwieldy. 19 MEMBER APOSTOLAKIS: Right. 20 MR. BERGMAN: But they do -- we like to see 21 them have at least all the systems they've called risk 22 significant, on the matrix. Sometimes they don't, though. 23 This next slide has a few errors on it. We 24 have completed enforcement now on 18 inspections: three y-i., y) 25 of which had no maintenance rule violations; one had the NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASillNGTON.D C. 20(X)5-3701 (202) 234-4433

250 1 severity level III with no CP; and 14 had c7e or more 2 multiple severity level IV. I \\ 3 The remaining six inspect' ions, the results are '~ 4 still under review by the staff. And two of those six 5 have had escalated enforcement meetings, but a de cision 6 has not been reached by the staff. 7 MEMBER APOSTOLAKIS: Do we have the document - 8 - JIT describes the severity levels and all that? 9 MR. BERGMAN: The EGM? 10 MEMBER APOSTOLAKIS: Would you give me a copy? 11 MR. BERGMAN: Sure. 12 MEMBER APOSTOLAKIS: Thank you. 13 MR. BERGMAN: Now, I didn't plan to go over e i L/ 14 all the clarifications; I have two slides of 15 clarifications. This first slide are the four we thought 16 were most important. I'll go over them and then I'll put 17 up the other slide, and if you want me to address them I'm 18 happy to do so -- or just all of them. 19 'Ihe first sort of big area of clarification 20 was on scoping, which is section 1.1 of the Reg. Guide. 21 There were four clarifications on scoping. We clarified 22 when, due to redundancy or installed spares, SSCs that 23 could cause a scram, could be excluded from scope. 24 We know that the SSCs whose use is implied to 25 mitigate accidents and transients, are used in EOPs, and u. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 Ri! ODE ISLAND AVE..N.W. (202) 234 4433 WASIIINGTON, D.C. 20005-3701 (202) 234-4433

251 1 that provides significant fraction of the mitigating 2 function are included in scope. And this specific 7s lU) 3 clarification came out of really, communications and 4 emergency lighting. 5 We found a number of licensees were excluding 6 those from scope. We didn't feel that you could respond 7 to accidents and transients unless you could communicate 8 and see. So even though they weren't called out 9 explicitly, they were very important from an accident 10 mitigation standpoint. 11 The third clarification just says that you can 12 do scoping on a functional basis instead of a system 13 basis. And last in scoping was that you could exclude 14 those portions of a system that didn't have a maintenance 15 rule function even where the overall system function was 16 in scope. 17 So if there's a test loop aspect that doesn't, 18 on its own would not have a -- be in scope or the rule, 19 you can leave that portion of the system out, but they 20 have to look at that specifically. 4 21 The second clarification was MPFFs as a 22 reliability indicator, which is section 1.4. You can use 23 MPFFs, the number of MPFFs as reliability indicator, 24 provided that there's a technical understanding of how ,,,() 25 that number relates to the reliability of the system. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234-4433 W ASIIINGTON, D.C. 20005 3701 (202) 234-4433

252 1 Monitoring structures, as I discussed earlier, 2 we've added guidance on structures; that's section 1.5, 7g x] 3 and section 1.7 pertains to normally-operating SSCs of low 4 safety-significance. 5 For high safety-significant and standby, low 6 safety-significant SSCs you have to monitor at the system 7 or train level. It's only for the normally-operating, low 8 safety-significant systems that we allow monitoring at the 9 plant level, so they group all their systems together and 10 have plant level criteria. Typically that's scram, safety 11 system actuations, and unplanned capability loss factor. 12 We added three clarifications on this.

First, 13 if they break one of those plant-level performance 14 criteria they must do a cause determination including 15 corrective actions, and consider moving the SSC that 16 caused them to break the performance criteria from (a) (2) 17 to (a) (1).

.18 Second, we believe they must use unplanned 19 manual scrams as well as automatic. Some licensees were 20 not. From a performance indicator standpoint, the way you 21 trip the plant doesn't tell you anything about whether or 22 not you had a maintenance problem causing the trip. And 23 the maintenance rule focuses on the maintenance problems, 24 so we've said you have to look at both manual and /N (_,) 25 automatic scrams. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE. N.W. (202) 234-4433 WASillNGTON.D.C. 2(XX)5-3701 (202) 234-4433

253 1 And the third is, in some cases you may need 73 2 to establish system or train-specific criteria for these v) i 3 so-called plant-level systems. And the reason is, not all 4 these low safety-significant, normally-operating systems 5 are measured by scrams and safety system actuations or 6 unplanned capability and loss factors, such as spent fuel ? pull. 8 It can't cause you -- it isn't measured by any 9 of those criteria so you need to come up with a criteria 10 that does measure its performance. 11 If you like, I can go over any of these or 12 I'll turn it back over to Rich for insights. 13 MEMBER APOSTOLAKIS: How would you describe fm ) N' 14 your safety-significance categorization process -- 15 MR. BERGMAN: The -- 16 MEMBER APOSTOLAKIS: -- is -- 17 MR. BERGMAN: Oh, I'm sorry. 18 MEMBER APOSTOLAKIS: Is it timid or brave? 19 MR. BERGMAN: I think it encompasses a fair -- 20 well, we'll only divide it -- 21 MEMBER APOSTOLAKIS: Daring. 22 MR. BERGMAN: It only divides it into two 23 categories: high and low safety-significant. And I think 24 the systems that are brought into the so-called high ) 25 safety-significant -- it's a pretty large group of NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE.,N.W. j (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234 4433

254 1 systems. But this clarification that's mentioned here, we 2 note in the Reg. Guide that the process described in 93-01 f~ ) x 3 is endorsed only for the maintenance rule, not for any 4 other application like graded QA or ISI/IST. 5 MEMBER APOSTOLAKIS: And we have that, too? 6 MR. BERGMAN: Which one? 7 MEMBER APOSTOLAKIS: I'd like to read all that 8 -- safety-significance categorization process. Is there a 9 document that describes how you do that? 10 MR. CORREIA: That is in NUMARC 93-01. 11 MR. BERGMAN: A summary of it -- we issued a 12 SECY paper, 95-265, that describes that process in detail, 13 you know, how it's limited to the maintenance rule. ,7 s 4 l'J 14 MEMBER APOSTOLAKIS: Good. 15 MR. CORREIA: Again, as Tom said, it's a 16 fairly simple process for maintenance rule purposes, 17 because we just put things in two different categories and 18 it's combined with deterministic inputs that an expert 19 panel sits down and reviews. 20 MEMBER APOSTOLAKIS: Good. 21 VICE CHAIRMAN POWERS: Do you forecast in the 22 future -- and I'm not sure how far the future has to go 23 out -- that instead of having two categories you could 24 envision having a continuum? Or more closely to a ( ) 25 continuum? 'O NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASillNGTON, D.C. 20005-3701 (202) 234 4433

255 1 MR. CORREIA: I would imagine if a licensee 2 has the sophisticated tools to do that it could. I don't i'~') 3 know. Pete, has any licensee ever mentioned that? 4 MR. WILSON: No. 5 MR. CORREIA: No, I don't think so. 6 VICE CHAIRMAN POWERS: I think in answer to 7 your question, I think we would like to go through this 8 viewgraph. 9 MR. BERGMAN: Oh, ckay. As we already 10 discussed, the safety-significance categorization process 11 of 93-01 is limited to the maintenance rule. We changed - 12 - in the Reg. Guide we know that there have been two 13 changes to the maintenance rule since Revision 1 of the 7-N- 14 Reg. Guide was issued. 15 A change was made in August of '96 to make it 16 -- explicitly make it applicable to decommissioned plants. 17 And in December '96 the definition of safety-related was 18 changed in the maintenance rule to be consistent with l 19 other rules. That was part of the seismic rulemaking. 20 The definition -- 21 MEMBER BARTON: So the maintenance rule has to 22 be applied to the plant like Fermi 1? 23 MR. CORREIA: If the change was specific to 24 plants and decommissioning status, I think is the term n 25 that they used, and it's basically just for the safe () NEAL R. GROSS l COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234-4433 WASillNGTON. D.C. 20005-3701 (202) 234-4433

256 I 1 storage control and maintenance of spent fuel. Only those 2 systems apply. 3 3 MR. BERGMAN: Yes, it's very limited. 4 MR. CORREIA: It's very limited, 4 5 MR. BERGMAN: The definition of maintenance. 6 NUMARC 93-01 has always referenced the Commission's final 7 policy statement on maintenance. We just re-emphasized 8 that that is the definition of maintenance we expect to be j 9 used for the maintenance rule. And it really includes 10 everything from planning and scheduling of maintenance 11 through tag out and tag bag in. It's not just turning the 12 wrenches on the equipment. 13 Timeliness. Some licensees wanted us to Y-) 14 provide a specific time period to complete the activities 15 in the maintenance rule, like 30 days to do a cause 16 determination. We felt that was counter to the flexible 17 approach taken in the rule and we've just said, you should l 18 accomplish activities commensurate with the safety 19 significance and complexity of the issue. 20 The definition of standby. The definition of 21 standby is those systems where they could have a failure 22 where it won't be immediately apparent. We had a problem 23 with some licensees calling what we consider a standby 24 system as normally operating, so we ran into some ,() 25 performance criteria problems. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234-4433 WASHINGTON, D.C. 20(x)$-3701 (202) 234-4433

257 1 MPFFs related to design deficiencies. What we 2 said is, ;f you choose to live with a poor design for fy (v) 3 economic reasons that's acceptable, but you have to modify 4 your preventive maintenance program to prevent occurrences 5 of the failures anyway. You can't just say it's craft 6 design or just -- 7 VICE CHAIRMAN POWERS: Let the thing fall 8 apart -- 9 CHAIRMAN SEALE: Reality rears its ugly head. 10 VICE CHAIRMAN POWERS: Didn't like it; hope it 11 falls apart. 12 MR. BERGMAN: And the last clarification was 13 the number of SSCs in (a) (1). We just said that we don't 's-] 14 use that as a performance indicator. You can have two 15 plants with identical performance, but different numbers 16 of systems in (a) (1) just because they set difference 17 performance criteria. So it's not a true indicator of 18 performance. 19 So I'm done. Rich will cover the lessons 20 learned. 21 MR. CORREIA: In the short time that the rule 22 has been in place we have learned an awful lot about so 23 far, about performance-based regulations and even all the 24 efforto that we spent in the last, nearly six years, g(,) 25 getting t< this point. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASil!NGTON, D.C. 20005 3701 (202) 234-4433

258 1 Communications by far, has been extremely 2 important. Given this, again, flexibility and limited -- y ) ( 3 verbiage in the rule itself, having mutual underatanding 4 of what these words mean, and what licensees ought to do, 5 what our inspectors ought to do, and having everyone 6 understand that, has been very important. 7 MEMBER APOSTOLAKIS: So -- excuse me. You 8 refer to communication between the staff and the licensee 9 primarily? 10 MR. CORREIA: Both within the staff -- 11 MEMBER APOSTOLAKIS: And within the staff. 12 MR. CORREIA: -- and with industry. 13 Absolutely. / ) '/ 14 MEMBER APOSTOLAKIS: Not communication as an 15 organizational factor? 16 MR. CORREIA: No. 17 MEMBER APOSTOLAKIS: That is important. 18 MR. CORREIA: We saw a lot of value in a pilot 19 program before the rule went into effect. We were able to 20 go out to a licensee's plant that volunteered for us to 21 come out. It gave us an opportunity to test our 22 inspection procedure and give them feedback on what they 23 had done so far, without it being in an enforcement 24 environment. ( ) 25 We've seen that developing guidance, both for NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASHINGTON, D.C. 20(X)5-3701 (202) 234 4433

259 1 licensees and for our inspectors, was accomplished through 2 an iterative process. We developed drafts, we tested 7-( ) '~' 3 them, we worked with them, we took lessons learned from 4 all of these applications and revised them, and I see that 5 continuing. 6 Training. We've spent enormous amounts of 7 time training our inspectors and its staff, technical 8 staff and managers in the Agency. I think to-date we've 9 trained close to 1,000 people in various ways:

simple, 1-10 hour presentations all the way to 3-day workshop 11 activities for the baseline inspectors.

And we'll 12 continue to do that. 13 Something we talked about earlier is the need I \\-) 14 for a programmatic, baseline inspection program. We 15 thought it was important for the maintenance rule since 16 it's one of the first performance-based, risk-informed i 17 regulations, that we need to have confidence that 18 licensees will develop and implement a program that would 19 give them sustained, adequate implementation. 20 We found that such a rule can be inspected and i I 21 enforce consistently. It takes a lot of work and effort 22 to achieve that, and we acknowledge that up-front and 23 we're doing it. Again, training, guidance, 24 communications, are all essential to achieving that. But ,-(,) 25 all of these require an awful lot of resources. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASilINGTON, D.C. 20005-3701 (202) 234-4433

260 1 MEMBER APOSTOLAKIS: Is it because you're 2 doing it for the first time? 7-k' 3 MR. CORREIA: Probably that has a lot to do '^ 4 with it, yes. 5 MEMBER APOSTOLAKIS: Yes. j 6 MR. CORREIA: Because we've just never been 7 down this path before, and hopefully, the other programs 8 that are following us can learn from what we've done and 9 maybe not duplicate the same effort -- or have to 10 duplicate -- 11 VICE CHAIRMAN POWERS: Are you going to 12 prepare a lessons learned document of a generic nature, 13 like this? ,r~% N -) 14 MR. CORREIA: We produced one after we did the 15 pilot program, NUREG-1526. I fully expect -- what I'd 16 like to do is, halfway through the process probably have 17 another public workshop and lessons learned guidance 18 document. 19 VICE CHAIRMAN POWERS: And if you did that, 20 would you try to communicate that in fora other than the 21 workshop? I'm thinking of ANS meetings or similar types 22 of meetings? 23 MR. CORREIA: I don't think there's been a 24 year that has gone by where somebody from our branch, (3) 25 Susie, hasn't been at an ANS conference, ASME conference, f NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASillN GTON, D.C. 20005-3701 (202) 234-4433

i 261 1 international conferences -- we're scheduled to be at the 2 IEEE human factors conference this year and ANS. So that, ('"'I 3 I believe, will continue. 4 VICE CHAIRMAN POWERS: I'm thinking more in i 5 terms of just the lessons learned of a generic nature. 6 MR. CORREIA: Okay. 7 VICE CHAIRMAN POWERS: I think you're right; 8 that there are many, many lessons that have come out of 9 this that would be of broad use. I mean, I can't imagine 10 that communications won't be important to every single 11 program, and the anecdotal accounts you can present on 12 communications driva that home. 13 I can't imagine some of these innovative g-14 programs we're talking about not benefitting from a pilot 15 program. Anecdotal accounts that you provide, again, 16 drive that home. I think you have things to offer the 17 larger community, not only within this and the building 18 next door, but the larger community, et al., and I think 19 it would be useful to share that with them and get 20 feedback from them. They may have different views on what 21 the lessons learned are that you can learn from. 22 CHAIRMAN SEALE: But the fact that it's doable 23 is also something that people need to know. 24 VICE CHAIRMAN POWERS: It's a success story n* 25 that needs to be advertised as well. (m) NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASilINGTON, D.C. 20005-3701 (202) 234-4433

262 1 MR. BERGMAN: We did write up the lessons 2 learned and insights as part of our most recent Commission s ( ') i '~ 3 paper. 4 MR. CORREIA: And we've issued an information 5 notice on early implementation -- 6 VICE CHAIRMAN POWERS: Now, I don't know that 7 we have that information notice. 8 MR. CORREIA: That was just issued, I think -- 9 MS. BLACK: April 14th. 10 MR. CORREIA: -- April 14th. Information 11 notice 9718. We can get that for you. 12 VICE CHAIRMAN POWERS: I think it would be 13 useful to see that. ( ~.M 14 MR. CORREIA: Yes. Thank you for that 15 suggestion. And one issue that we're dealing with right 16 now is, as Tom mentioned earlier, the very last part of 17 paragraph (a) (3) of the rule says that licensees should 18 perform safety assessments before they take equipment out 19 of service for maintenance. 20 And our lawyers tell us, by virtue of the fact 21 the word "should" is in there, you can't enforce it. 22 MEMBER KRESS: I found that to be very 23 interesting. 24 MEMBER BARTON: You can f(,) 25 MR. CORREIA: Cannot. NEAL R.. GROSS cot 1RT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASillNGTON, D.C. 20005-3701 (202) 234-4433

263 1 MEMBER KRESS: Cannot. They should have had ,o 2 the word "shall" Shall would be a better word. t ) wr 3 MR. CORREIA: Shall. The Ccmmission has asked 4 us to advise them on that very subject so we're working on 5 that right now. 6 VICE CHAIRMAN POWERS: And what are you going 7 to advise them, or is it -- 8 MR. CORREIA: I can give you my personal 9 opinion. 10 VICE CHAIRMAN POWERS: I'll welcome your 11 personal opinion. 12 MEMBER APOSTOLAKIS: The committee's opinion, 13 really. / i 14 MR. CORREIA: Should we change to a shell? 15 Absolutely. And all licensees that do it -- 16 MEMBER KRESS: And the NRC should avoid using 17 the word "should". 18 MR. CORREIA: Yes, in all cases. Regulations 19 should not have -- what's the term, hortatory -- 20 provisions. 21 That concludes our presentation. I'll take 22 any questions. 23 MEMBER BARTON: Overall you feel that the 24 program's been successful? ,cy V 25 MR. CORREIA: We believe it has. Some -- NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.V. (202) 234 4433 WASilINGTON, D.C. 2(XX)S-3701 (202) 234 4433

264 1 MEMBER BARTON: Sounds like it. 2 MR. CORREIA: -- licensees disagree. J 3 MEMBER BARTON: Those are ones that have the 4 most violations, probably. 5 MR. CORREIA: Probably. 6 VICE CHAIRMAN POWERS: But I mean, you're 7 happy and it looks good to you. Do you have a 8 quantitative endorsement of that feeling, or is it too 9 soon? It's probably too soon to have a -- 10 MEMBER APOSTOLAKIS: A what, endorsement? 11 VICE CHAIRMAN POWERS: A quantitative. I 12 mean, it's -- 13 MEMBER KRESS: Reliability of equipment is -- r\\

\\ -)

14 VICE CHAIRMAN POWERS: You've only had nine 15 months of official operating experience, so it may be too 16 soon to have a quantitative measure. 17 MR. CORREIA: That's another question the 18 Commission has asked us to address. How can we measure 19 success of this rule? 20 VICE CHAIRMAN POWERS: And what's your 21 thinking? 22 MR. CORREIA: I believe it's very difficult 23 because of the variables that go into measuring successive 24 maintenance. r'% () 25 MEMBER APOSTOLAKIS: I don't understand what NEAL R. GROSS COURT REPORTERS ANDTRANSCR'BERS 1323 RiiODE ISLAND AVE.,N.W. (202) 234 4433 WASilINGTON, D.C. 2(XX)S-3701 (202) 234-4433

265 1 success means here. Unless the whole system becomes 2 performance-based, I -- ,s 3 MR. CORREIA: Perhaps through data -- 4 MEMBER APOSTOLAKIS: This is not very relevant 5 6 MR. CORREIA: If there's a reliability data 7 rule -- 8 MEMBER BARTON: Why wouldn't the data the 9 plants are collecting that you're inspecting to give you 10 some indication whether it's -- 11 MR. BERGMAN: In terms of availability and 12 reliability of equipment? 13 MEMBER BARTON: Yes. 14 MR. BERGMAN: We could. 15 MR. CORREIA: It could. 16 MR. BERGMAN: But again, especially with 17 reliability that would take an extremely long period of 18 time -- 19 MEMBER BARTON: Oh, sure it would. 20 MR. BERGMAN: -- to give you good information. 21 Subjective -- we expect that it will be primarily through 22 subjective measures: inspections, SALP process. But even 23 then it will take a fair number of years to get a feel for 24 how it's doing. (a) 25 CHAIRMAN SEALE: I realize this may require x NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASillNGTON, D C. 200t)5-T701 (202) 234-4433

266 1 concurrence by other offices or something like that, but 2 you have a performance-based rule. Have you thought about ( ) '-~# 3 what the appropriate subsidiary now -- I'll use that 4 terminology -- performance indicators might be on meeting 5 the requirements of this rule? It seems to me that would 6 be a reasonable first hack at your metrication of success. 7 VICE CHAIRMAN POWERS: Metrication? 8 CHAIRMAN SEALE: Measuring. 9 MR. CORREIA: I believe AEOD will continue to 10 monitor overall plant performance. Certainly they look at 11 transient scrams, they look at where they're initiated 12 from, and they have a pretty good idea of what's causing 13 them: human performance, maintenance issues, operations. <^x ( i L/ 14 CHAIRMAN SEALE: Yes, but there are things in 15 your inspection process that you know, and that's why I 16 called them subsidiary performance indicators. 17 MR. CORREIA: Right. Yes. 18 MEMBER APOSTOLAKIS: Well, you've already 19 mentioned two: the number of failures and the number of 20 demands. Right? These are indicators. Then you do a 21 simple calculation and -- the other problem that you 22 mentioned, that risk importance or significance may change 23 given different configurations. 24 Now, there you might want to figure out a way i 25 to have an indictor that the plant is indeed, doing that q) NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASillNGTON, D.C. 20005-3701 (202) 234-4433

267 1 in a reasonable way. It seems to me that in all these 2 rules, it's unavoidable that you will have to have some 7-) ( l '~' 3 indicators that are organizational indicators. You can't 4 just have number of failures, number of demands. So 5 you're going to have to get into that sooner or later. 6 And then speaking of AEOD, are your results 7 being fed into AEOD programs? 8 MR. BERGMAN: No, we don't collect data during 9 the inspections. The licensees don't have to submit any 10 data for the maintenance rule. ) 11 MEMBER APOSTOLAKIS: Okay. 12 MEMBER BARTON: That's why, talking about 13 reliability data rule. t 14 MEMBER APOSTOLAKIS: Yes. No, but still 15 though, I mean, they are trying to develop -- I think j 16 they're in the process of developing performance 17 indicators. 18 CHAIRMAN SEALE: Yes, there is a large -- 19 MEMBER APOSTOLAKIS: You might be able to help 20 them with that process, and you know, from your own 21 experience. 22 MR. BERGMAN: We interact with them on the 23 reliability data rule and on the maintenance performance 24 indicator. (,) 25 MEMBER APOSTOLAKIS: When is that rule coming NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASillNGTON. D.C. 20005-3701 (202) 234-4433

268 i 1 before the committee? Who is the chairman of the f w, 2 subcommittee -- the -- ) (V 3 MEMBER KRESS: I don't even know which 4 subcommittee -- 5 CHAIRMAN SEALE: I have heard a rumor that 6 there may in fact, be a disposition of that. 7 MR. CUNNINGHAM: The Commission paper, the 8 recommendation on how to proceed with the data rules, is 9 in, I believe in the EDO's office now. So I expect it 10 will get to the Commission pretty soon, j 11 MEMBER APOSTOLAKIS: Is it John's subcommittee 12 that's going to look at it? 13 MEMBER KRESS: Probably. /,_,\\ \\' 14 MEMBER BARTON: I haven't been told that 15 officially yet, George. 16 VICE CHAIRMAN POWERS: I wouldn't think so. 17 CHAIRMAN SEALE: No. 18 MEMBER APOSTOLAKIS: Do we have a reliability 19 rule subcommittee? 20 MEMBER KRESS: Yes. PRA. 21 VICE CHAIRMAN POWERS: It's called PRA. 22 MEMBER APOSTOLAKIS: Oh, it's under PRA? 23 VICE CHAIRMAN POWERS: Yes. 24 MEMBER APOSTJLAKIS: I would be very happy to (~h () 25 see that. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323. IlODE ISLAND AVE..N.W. (202) 234-4433 WASilINGTON. D.C. 20005 3701 (202) 234 4433

269 1 VICE CHAIRMAN POWERS: George, we're always 2 trying to find some basis to firm the foundation of this 3 i~~ 3 PRA business. 4 MEMBER BARTON: Ah, Dana is one step -- I 5 think an application of PRA. 6 VICE CHAIRMAN POWERS: I think this was a -- 7 my opinion it was an extraordinarily good briefing. 8 MR. CORREIA: Thank you very much. 9 MEMBER KRESS: We thank you very much for your 10 briefing. 11 VICE CHAIRMAN POWERS: I personally hope that 12 they will come back to us in, say one year, and give us 13 another update, and if you do produce papers on lessons lD i/ 14 learned of a generic -- or a specific nature -- sending a 15 copy down here would probably be very welcome. 16 MEMBER KRESS: Would you put that date on your 17 calendar? One year? 18 MR. CORREIA: Thank you. 19 MEMBER KRESS: Thank you very much. Mr. 20 Chairman. 21 CHAIRMAN SEALE: I understand there's no 22 industry people here to talk or comment. They were 23 invited. Maybe this is the day when they announce bonuses 24 or something. But I do hope that in the future we can get A ( ) 25 some industry input for this. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.,N.W. (202) 234-4433 WASillNGTON, D.C. 20005-3701 (2U2) 2344433

i 270 1 Okay. We are now going to go back and let, or 2 ask, Dana to complete his discussion of DSI-22 on 3 Research. We're understand there are going to be some 4 people here from staff, is that correct? 5 were there going to be some staf'f people here? 6 VICE CHAIRMAN POWERS: It mattereth not a 7 whit. 8 CHAIRMAN SEALE: I understand that but 9 somebody -- Sam told me that we were -- 10 MR. BOEHNERT: Yes, there were supposed to be 11 and I just let him know about this. I haven't talked to 12 them; I can't get them on the phone; I left them an E-13 mail. ,/N i () 14 CHAIRMAN SEALE: They may be announcing their ] 15 bonuses, too. 16 VICE CHAIRMAN POWERS: Okay, right now we are 17 18 MR. EL-ZEFTAWY: Dana has another handout 19 that's coming to you regarding the same topic. 20 VICE CHAIRMAN POWERS: Yes, these are the 21 details of the elements of the current research program 22 which we'll delve into in the second half of this talk. 23 MR. SHACK: Before you start, Dana, they were 1 24 talking about they had their criteria for picking -- /h 25 VICE CHAIRMAN POWERS: We will go into those (] ( NEAL R. GROSS COURT REPORTERS ANDTRANSCRIllERS 1323 RilODE ISLAND AVE.,N.W. (20.') 234 4433 WASillNGTON, D.C. 2(XXW3701 (202) 234-4433

271 1 criteria. 2 MR. SHACK: These are theirs, though? ,s l 1 ~ 3 VICE CHAIRMAN POWERS: These are theire. 4 Those are they. 5 MR. SHACK: Them's the one. 6 VICE CHAIRMAN POWERS: Yesterday I went i 7 through the mechanical parts of DSI-22, delineated the 8 options and discussed some of the options that have been j 9 selected by the Commission. In particular, I noted that 10 the Commission had selected option 5, along with 4. And 11 in option 5 they are to establish and maintain core 12 research capabilities. 13 Today in our meeting with the Commission, the \\> 14 Chairman asked if we had looked at what they were doing to 15 define what the core research capabilities ought to be. 16 If you will turn to slide 7 I will how you the criteria 17 that apparently had been selected for defining what a core 18 program is. 19 And what I cannot tell you is that there is 20 any importance in the top to bottom listings of these 21 items. It is my impression that they are all factors to 22 consider in defining whether an area should be labeled a 23 core program or not. 24 First on the list of course, is that a high (n) 25 risk, large uncertainty area, does it involve an emerging NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASilINGTON, D.C. 2tXX)5-3701 (202) 234-4433

272 1 issue or an emerging technology? Quite frankly, I don't I 2 understand why that should be part of a core program [ fs l ( ) i x/ l 3 rather than just a research needs issue. 4 Is expertise or the facility involved in this 5 kind of research, unique? And I think they use unique 6 precisely here. Is it precisely a one-of-a-kind or 7 difficult to reproduce facility? 8 Can NRC gain access in a timely manner to 9 either that expertise in facility or some alternate 10 expertise in facilD y? 11 Can NRC gain access to independent expertise 12 on a topic, or should it have its own in-house expertise? 13 How frequently does NRC need expertise or the ,o f i \\2 14 facility? 15 What impact will there be on the NRC if 16 expertise or the facility and the capability they 17 represent is lost? 18 What cost would be associated with 19 reassembling expertise that had been abandoned for some 20 interim time, and subsequently, a new issue had emerged? 21 And clearly that is to be compared against, what is the 22 cost of maintaining some current expertise? l 23 And finally, how important is expertise or 24 capability to ongoing cooperative agreements? I remind

/~';

(_,/ 25 you that in the SRM, the Commission encouraged the NRC to NEAL R. GROSS COURT REPORTERS ANDTRANSCRmERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASillNGTON, D.C. 2(XX)5-3701 (202) 234-4433

l 273 1 continue to be involved in these cooperative research 2 agreements internationally, and to solicit joint research g3U 3 programs -- the Department of Energy and other 4 institutions -- including the industry. l 5 Now, those tend to be tit-for-tat kinds of 6 arrangements where research done in one area is swapped 7 for research in another, and when you do that you've got 8 to have something to swap. And I think Dr. Fontana 9 pointed out to us, we're losing our ability to swap 10 because we ain't got nothing to swap. And clearly that is 11 in their thinking on this research. 12 MEMBER KRESS: Are they going to put scores 13 aside each of these and add them up and have a -- if a ^/\\ ('- 14 score exceeds a certain -- 15 MR. SHACK: They've apparently done that. 16 VICE CHAIRMAN POWERS: It is my impression 17 that they have done that and they have arrived at a 18 priority ranking. How the things were done is beyond me. 19 MR. SHACK: They have 39 core areas, I think. 20 VICE CHAIRMAN POWERS: Could be. And -- 21 MEMBER KRESS: There's not that many in the 22 whole world. 23 VICE CHAIRMAN POWERS: Oh, trust me Tom. 1 i l 24 You've been away from the National Laboratories too long. O) ( 25 MEMBER KRESS: We had 39 just in my section. ( NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RIIODE ISLAND AVE. N,W. (202) 234 4433 WASillNGTON D.C. 2(XX)$-3701 (202) 234 4433

274 1 VICE CHAIRMAN POWERS: Yes. Absolutely, 2 that's the way it is. f- \\ ) 3 MEMBER KRESS: Who made this list up? 4 VICE CHAIRMAN POWERS: I believe this list 5 comes from Research itself. 6 MEMBER KRESS: MorrisonT 7 VICE CHAIRMAN POWERS: I assume that Morrison 8 and his staf.f -- or someone on the Research staff came up 9 with this. 10 MEMBER APOSTOLAKIS: Can you tell me real 11 quick, what a core program is? 12 MEMBER KRESS: That's a good question. 13 VICE CHAIRMAN POWERS: Well, a core program /~s i \\ i-) 14 Gecrge, is one that apparently involves a high risk or 15 large uncertainty rese5rch area that may or may not be an 16 emerging issue or technology. It's an expertise that is 17 unique; that NRC has difficulty gaining access to. 18 MEMBER APOSTOLAKIS: I was under the 19 impression, which evidently is the wrong impression, that 20 you know, as budgets go down and so on, the Office of 21 Research has to decide, like there are certain 22 disciplines, certain kinds of expertise that are core. 23 Like when we give the general exam at MIT for 24 Ph.D. candidates, there is a morning there that's called e' N (,) 25 core. That means, everyone in this departmeat should NEAL R. GROSS COURT REPORTERS ANDTRANSCRI3ERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASillNGTON, D.C. 20005-3701 (202) 234-4433

~ 275 l 1 understand transport phenomena, should understand nuclear 3 physics. 7,\\ /i / g 3 VICE CHAIRMAN POWERS: This is different, 4 George. 5 MEMBER APOSTOLAKIS: So this isn't the same 6 use of the word " core"? 7 VICE CHAIRMAN POWERS: No, this.i-core 8 capabilities and it is a buzz word within the industry. I 9 would guess it really hit a peak about three or four years 10 ago when it really became fashionable to divide your 11 efforts up into what your core capabilities are. 12 It is one of the quality gurus who ran around 13 the country that had this as one of his central theses, p i 1 V 14 and you will find many. ma.y technological-based 15 companies, and I suspect all of the national laboratories 16 have what they call their core competencies or core 17 capability groups. 18 MR. MARKLEY: Or core line of business. 19 VICE CHAIRMAN POWERS: Yes, that's another 20 term. 21 MEMBER APOSTOLAKIS: But I think that's -- 22 VICE CHAIRMAN POWERS: And the way it's used, 23 George, is these are things that you preserve for the 24 long-haul, that you're always in this business, you always (n) 25 need it, and that you are the very best that you can v NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RIIODE ISLAND AVE.,N.W. (202) 234-4433 WASillNGTON, D.C. 20005-3701 (202) 234 4433

276 1 possibly be. 2 Now, most companies say we're world-class or 7 O 3 things like that, but let's be realistic; the best you can 4 possibly be is what they really mean, in these areas. For 5 instance, in the National Latoratories you find yourself 6 in much better stead if you can solicit programs that you 7 can argue, contribute to the core competencies. 8 MEMBER APOST?OLAKIS: Okay, I understand that. 9 But maybe we should question then, whether that's the way 10 we should interpret it, and I would go back to the exam 11 again. 12 It seems to me if you want to call yourself a 13 Ph.D. nuclear engineer, regardless of whether you do work p i ) \\/ 14 on radiation science or PRA or materials, you have to have 15 some nuclear physics, you have to have transporter -- so i 16 if you want to have an Office of Research in a nuclear 17 regulatory agency, what are these basic -- 18 VICE CHAIRMAN FOWERS: Well, I think the best 19 way to do that, George -- 20 MEMBER APOSTOLAKIS: No, no -- well, I don't 21 know about that. I think there are slight differences. 22 MEMBER FONTANA: The differences is in the 23 definition of the word " core". This was a management fad 24 like he was saying. If you change that to essential, I O, i I 25 think it would be more understandable -- t/ NEAL R. GROS 5 COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

277 1 MEMBER APOSTOLAKIS: But I don't understand 2 why -- , ~~s \\ ,'w) 3 MEMBER FONTANA: What you have to have for l 4 what you're going to do now -- 5 MEMBER APOSTOLAKIS: But why is there not 6 uncertainty areas -- 7 MEMBER FONTANA: -- and -- 8 MEMBER APOSTOLAKIS: -- that's a research 9 project that you may establish. 10 MR. SHACK: No, I think what it means is, it's 11 an area where we need more information. We still have -- 12 it contributes to risk and we still have uncertainties; we 13 don't know a lot about it. p 14 MEMBER APOSTOLAKIS: But that's not a core by i I 15 any interpretation of the word. 16 MEMBER FONTANA: It could be essential. 17 MEMBER APOSTOLAKIS: It is essential, but 18 whether it's core -- 19 MR. SHACK: It's only one of nir.e factors. 20 MEMBER APOSTOLAKIS: Yes, but what I'm saying 21 22 MR. SHACK: Even if it was important George 23 but if you knew everything about it, it wouldn't be part 24 of your research program. .r'T !.] 75 MEMBER APOSTOLAKIS: No, but that's my point. NEAL R. GROSS COURT REPORTERS ANDTRANSCRmERS 1323 RilODE ISLAND AVE.,N.W. (202) 234-4433 WASillNGTON, D.C. 20005-3701 (202) 234-4433

1 278 1 Oh, you mean you wouldn't put it in the office of ,o 2 Research? f V) 3 MR. SRACK: No. It might be an essential i 4 discipline for the Nuclear Regulatory Commission, but you j 5 might not need to do any more research on it. You know, 6 sometimes research actually ends. Not often, but l 7 sometimes. Never on pressure vessel, steam generators, or 1 1 8 materials problems. l 9 MEMBER MILLER: He needs to find the core -- { 10 his core. I i 11 MEMBER APOSTOLAKIS: Why is the word " core" i 12 used here? What is the message the word core is sending? 13 MEMBER FONTANA: Because everybody uses it ,/ m (id i v 14 nowadays. i l 15 MR. SHACK: I think when the budget shrinks, j 16 these are the things we've got to keep going. 17 MEMBER APOSTOLAKIS: I think you do these even i 18 if the budget doesn't shrink. 19 MR. SHACK: Well, you prioritize, these are 20 the things -- 21 <lAIRMAN SEALE: The trauma is when it does l 22 shrink. 1 23 VICE CHAIRMAN POWERS: When these things i 24 disappear when the last man in Research walks out and j (3 't) 25 turns out the light. And these they will preserve at the NEAL R. GROSS COURT REPORTERS ANDTRANERIBERS 1323 RilODE ISLAND AVE.,d.W. (202) 234 4433 WASl((NGTON, D.C. 20005-3701 (202) 234 4433

279 1 expense of other things. 2 MEMBER MILLER: Will the core always be the 7s( ) 3 same, or will it change slowly? 4 VICE CHAIRMAN POWERS: I think, oh, there's a 5 certain permanence attached to the core but the truth is, 6 when there is a change -- the time scale for change is 7 long compared to other things. 8 MEMBER MILLER: For example, in engineering -- 9 I think a better analogy rather than using the Ph.D. exam 10 would be the core disciplines in engineering. You know, 11 like mechanical, electrical and that. They're always 12 going to be there. Nuclear may not be there tomorrow but 13 that's -- 'k '/ 14 MEMBER FONTANA: Well, the elastic guys are 15 using a different -- they're training people vho are 16 supposed to be good for the next 50 years. 17 MEMBER MILLER: What I'm trying to do is 18 identify the fact that the core in Research -- 19 MEMBER APOSTOLAKIS: Yes, core means something 20 else. 21 MEMBER MILLER: -- this field is probably 22 going to be changing. 23 VICE CHAIRMAN POWERS: I think that's true and 24 it evolves and whatnot. I don't know that spending /a() 25 enormous amount of time discussing core gets to my core NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.N.W. (202) 234-4433 WASillNGTON, D C. 20005-3701 (202) 234-4433

280 1 problem here. Let me go on and go beyond what's in the 2 DSI and reveal to you some of the intelligence I've ,s (J 3 gathered about the Research program. 4 And I have passed out for you the current core 5 research programs and some of the detailed program G elements that are in each of those, and some indication of 7 how long they go on. I have on the next couple of slides, 8 tried to encapsulate some of that and offer some thoughts 9 on the Research programs. 10 Let's see, if I could have the next s]ide? 11 There are altogether, six or seven items on this list that 12 they have gone through with some effort to prioritize. I 4 13 could fit on this slide three of those: aging research, 7s k-) 14 reactor structural performance, and PRA. I expected 15 members from each wing of the table to stand up and salute 16 at this, but they didn't respond. I 17 MEMBER MILLER: You haven't gotten to my area 18 yet. 19 VICE CHAIRMAN POWERS: We'll get to your 20 particular fanaticism in a second. 21 MEMBER MILLER: Was FRA by the way, a core ten 22 years ago? 23 VICE CHAIRMAN POWERS: Yes, it was. 24 MEMBER APOSTOLAKIS: Thirty years ago it was ('N \\_-) 25 not. i NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASillNGTON D C. 20005-3701 (202) 234 4433

281 1 VICE CHAIRMAN POWERS: You'd have to go back - 2 3 l i 3 MEMBER MILLER: Twenty years ago, probably. '~~' 4 VICE CHAIRMAN POWERS: -- probably into '79 5 before you would see PRA merely as one of these 6 indulgences 7 MEMBER MILLER: So today it's a core, but now l 8 it's been pushed into the -- 9 MEMBER KRESS: What is this slide, Dana? 10 These are -- 11 MP.. SHACK: Dr.na's acerbic comments on the -- 12 VICE CHAIRMAN POWERS: There are my collective 13 acerbic comments on things that you have the details kj 14 about. 15 MEMBER KRESS: Okay, these are Research 16 programs that they have now -- 17 MR. SHACK: Right, reactor aging programs -- 18 VICE CHAIRMAN POWERS: That's right. 19 MEMBER KRESS: Okay, and these are your 20 acerbic comments. Okay, now I've got you. 21 VICE CHAIRMAN POWERS: My acerbic comments. 22 Let me give you overall, the acerbic comment that, there 23 is no element of the research planning that I would say 24 shows a tight coordination with what I would call, the () 25 mission needs of the Agency. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASHINGTON, D.C. 2(XX)5-3701 (202) 234-4433

282 1 There is not a tradition that parallels that 2 formalism that is common in the Department of Defense and ,S \\ ) 3 aspired to within the Department of Energy, to identify 4 mission needs, and from that, identify research needs. 5 Except that most of this research is done in response to a 6 user need -- 7 MEMBER KRESS: Yes, and NRC's mission is very 8 clear and simple. 9 VICE CHAIRMAN POWERS: The Agency's mission 10 may be very clear. The Agency's mission needs may not be 11 so clear. 12 MEMBER KRESS: Oh, I'm sure of that. 13 VICE CHAIRMAN POWERS: So when I see a large (~'N k -) \\ 14 program on aging research, my immediate thought when I saw 15 it was gec; I thought the aging rule had eliminated most 16 of the need for this. 17 In fact, I think when you look at the program 18 elements you may come to the conclusion that well, these 19 are things that have been undertaken and now they're just 20 wrapping them up, and that we may be seeing a vestige -- 21 vestigial activities here and fair enough, it's not 22 closely planned but it would be irrational just to stop 23 things abruptly and not reap the harvest that you've 24 started. Os (,) 25 Reactor structural performance is a research NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE..N.W (202) 234 4433 WASillNGTON, D.C. 2tK)05-3701 (202) 234 4433

283 1 area that seems to be more tightly coupled to user needs. 7-2 And I note that there are cooperative agreements with u-3 Japan that continue through fiscal year '99, and there 4 seems to be a healthy amount of testing and development of. 5 tools that you could anticipate the staff would need for 6 siting. 7 Unfortunately, it's a little difficult to get 8 too excited because we don't anticipate a whole lot of 9 applications for plants that would demand using tools for 10 evaluating siting. 11 PRA research -- 12 MEMBER FONTANA: Wait, back up just a second. 13 Does this include things like steam generator tube -- ,_I i Y 14 VICE CHAIRMAN POWERS: Yes, it does. 15 MEMBER BARTON: -- diagnostics and stuff like 16 that? 17 VICE CHAIRMAN POWERS: No, no, that's -- 18 MR. SHACK: That's under the aging research. 19 MEMBER FONTANA: It is? 20 MR. SHACK: Yes. 21 CHAIRMAN SEALE: I think their problem here is 22 that the aging research is a broader topic than the 23 remnining elements of the program would suggest. 24 VICE CHAIRMAN POWERS: It depends on how you f(,) 25 cut it. If you cut it based on costs, then it's classic NEAL R. GROSS COURT REPORTERS ANDTRANSCRIllERS 1323 RIIODE ISLAND AVE..N.W. (202) 234-4433 WA SillNGTON, D.C. 2(xx)5-3701 (202) 234-4433

284 1 aging research. If you cut it based on program elements, 2 then you're right. And you will have to look at the p tGr/ 3 details in my other handout to see what all the program 4 elements are. 5 MR. EL-ZEFTAWY: They have this -- if you look 6 at the elements. 7 MEMBER FONTANA: Oh, I hadn't looked at it. 8 MR. SHACK: Partly you call it whatever it 9 takes to get it funded. If aging is hot this year, it's 10 aging. If it's -- 11 VICE CHAIRMAN POWERS: I mean, that's one of 12 the problems, is that there is very much a persuasion 13 component in the way research is organized. That is, if ,f 3 i V 14 I'm an articulate, persuasive salesman, it is easier for 15 me to keep my research programs well-funded than if I'm 16 fairly inarticulate. That that again comes back to, 17 there's not a close tie to mission need. 18 CHAIRMAN SEALE: Yes, but I have to suggest 19 also that the ability to express disdain for old programs 20 is a management tool for putting pressure on research 21 programs to see whether or not they can stand up to the 22 gaff. 23 VICE CHAIRMAN POWERS: Well, I think that 24 there is a tendency in all research organizations that t'% ) 25 have not carefully planned their work, to argue something NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 2.14 4433 WASillNGTON, D.C. 20005-3701 (202) 234 4433

285 1 like this: we've worked on this issue for a number of 2 years; it must surely be done, whether it's done or not. 73 ( ) 3 CHAIRMAN SEALE: Yes. 4 VICE CHAIRMAN POWERS: I think that often 5 happens. And that's one of the things that you can try to 6 avoid when you -- if you tie planning of a research 7 program closely to mission need with agreed-upon 8 requirements and functions for that research. 9 MEMBER APOSTOLAKIS: Dana, under PRA, 10 shouldn't they have some research activity in the area of 11 risk management / decision-making? 12 VICE CHAIRMAN POWERS: I believe that that is 13 a topic that they -- certainly the management, and perhaps /~T k.- 14 even the Commission -- have said that accident management 15 is really a program that belongs to the licensees. And 16 that is, they have attempted then, not to intrude upon j 17 that as much as possible. 18 MEMBER APOSTOLAKIS: No, but I don't mean 19 accident management; I mean risk management. Like this 20 morning, all these questions about how do you handle 21 uncertainty, how do you make decisions in the light of 22 these uncertainties? 23 This Agency has shied away from doing work on 24 decision-making or risk management, or risk-informed ,() 25 decision making, and perhaps it's time for them to get NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE..N.W. (202) 234 4433 WASillNGTON, D.C. 20005-3701 (202) 234 4 433

286 1 into this a little bit more and understand better what the 2 elements of decision-making that are relative to their .~ ( ) 3 problems are. 4 VICE CHAIRMAN POWERS: I'm, certainly I think, 5 supportive of your point of view, and I suspect in every 6 one of these research topics we can identify things that 7 ought to be done, and we can go on and divine many, many 8 more research topics than what I've been able to put on 9 two viewgraphs. 10 MEMBER APOSTOLAKIS: Well, the reason why I'm 11 saying is -- 12 VICE CHAIRMAN POWERS: And I think we're going 13 to be asked to do that. /"h. 'w_ / 14 MEMBER APOSTOLAKIS: Yes. You say no shut 15 down, low power, so I thought you were soliciting -- I 16 mean, this just happened to come to your mind? 17 VICE CHAIRMAN POWERS: These are my own 18 personal acerbic comments. 19 MEMBER APOSTOLAKIS: I thought you were 20 soliciting input to put -- 21 CHAIRMAN SEALE: If you have an ox you want to 22 gore, why you write it down. 23 VICE CHAIRMAN POWERS: George, the intention 24 sf this entire discussion is simply to sensitize you to jq t ) 25 the question of the research program and to say yes, I s NEAL R. GROSS COURT REPORTERS ANDTRANSCRI11ERS 1323 RilODE ISt.AND AVE..N.W. (202) 234 4433 WASillNGTON,D C. 20tK15-3701 (202) 234-4433

i 287 1 think we're going to have to get more aggressively 2 involved in this. ,3 3 The queen of sciences is of course -- i 4 MEMBER FONTANA: PRA. 5 VICE CHAIRMAN POWERS: Not this one yet, Med - ) 6 - "RES Program, Cont'd", do you have that? 7 CHAIRMAN SEALE: Number 9. 8 VICE CHAIRMAN POWERS: The queen of the 9 sciences of course, is an element of the research program, 10 and I think this is one that we're fairly familiar with. 11 And it has -- 12 MR. SHACK: Simplified the fuel work under 13 there for some strange reason. p L i (/ 14 VICE CHAIRMAN POWERS: They do indeed. They 15 have a small component of a small program. 16 MEMBER KRESS: They could put a model on the 17 end. 18 VICE CHAIRMAN POWERS: Everything up to the 19 big bang and including the big bang, was thermal 20 hydraulics. We've been informed that many times before. 21, I read all this thermal hydraulics stuff and I 22 just said, gee, if you're in the position of having to be 23 very, very strict in your definition of what research 24 ongoing is, do you have that much programmatic need b y,j 25 forecast in the future for such an expansive program in NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234-4433 WASil!NGTON.D.C. 2(xx)5-3701 (202) 234-4433

288 1 thermal hydraulics? And I only pose the question; I did 2 not pose the answer to it. O 3 The kind of the sciences, I&C, is of course 4 listed here, unfortunately second. That was my 5 prerogative and not others. 6 MEMBER MILLER: Second on this page. 7 VICE CHAIRMAN POWERS: On this page, that's 8 all. 9 MEMBER MILLER: Fifth on your list, at least. 10 VICE CHAIRMAN POWERS: We all know that it 11 should figure very high since it is an element of physics, 12 one of the better ones. 13 CHAIRMAN SEALE: I thought it was the strong, ,O 'v') i 14 right arm. 15 VICE CHAIRMAN POWERS: Here's the one that 16 just flabbergasts me. We have I&C and human factors. 17 MEMBER KRESS: Why is "from" separated from 18 " separated"? 19 V.:CE CHAIRMAN POWERS: Because the word l 20 processing engineer that did this worked on two different 21 kinds of printers. 22 MEMBER MILLER: Why is your question that I&C 23 and human factors not be together? Why wouldn't you 24 expect it to be together? (m) 25 VICE CHAIRMAN POWERS: The two of them seem as NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234 4 433 WASifINGTON, D.C. 20005-3701 (202) 234-4433

289 1 unrelated as any two I can think of. 2 MEMBER MILLER: No, but if you look at it from ,r ] \\ l v 3 a systems' viewpoint, you draw a block diagram of a power 4 plant control system, you've got the human in the loop who 5 has to read the control room, and that's fed by the 6 instrumentation. 7 VICE CHAIRMAN POWERS: I won't argue with you. j 8 MR. SHACK: Certainly that's where human 9 factors grew out of in most engineering curriculums. 10 MEMBER MILLER: Electrically has the largest 11 human factors group I think, in engineering. 12 VICE CHAIRMAN POWERS: The question I 13 actually, explicitly posed is, why is human factors ('-) 14 separated from human reliability analysis? 15 MEMBER MILLER: That's a good point. l 16 VICE CHAIRMAN POWERS: And I'm now told that 17 they're no longer separated; that they are now closely 18 tied together. 19 MEMBER MILLER: They're now put together, yes. 20 They must have seen you do this overhead. 21 VICE CHAIRMAN POWERS: It is indicated that 22 there is some assessment of the aos quacy of industrial 23 standards that is to be a component of this overall 24 research program, but I'll be darned if I can find a task fs(,)\\ ( 25 that actually addressed that kind of a question. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE.,N.W. (202) 234 4433 WASilINGTON, D.C. 2(KX)S-3701 (202) 234-4433

290 1 The final issue here is severe accidents. 2 There are a variety of components involved in the severe / 8 i 3 accident program. Nearly all of them are code-associated. 4 There is a very limited amount of experimental work going 5 on. I think most of the experimental work going on in 6 this country is associated with the lower head integrity 7 issue, and my understanding is that research is wrapping 1 8 up. 9 The rest of it is code work, and experimental 10 work that is coming from the cooperative agreements -- and 11 there are a variety of them connected with source term, 12 fuel coolant interactions, hydrogen combustion. 13 Now, it is my understanding that the severe (D \\_/ 14 accidents program and this prioritization that Bill Shack 15 mentioned, has come in last on this, and it consequently 16 is on the chopping block. 17 MEMBER KRESS: A little strange to me. 18 VICE CHAIRMAN POWERS: It is a peculiarity. 19 CHAIRMAN SEALE: Now, let me ask you a 20 question. You mean that in its full scope, the program is 21 on the chopping block, not -- 22 VICE CHAIRMAN POWERS: That's exactly right. 23 It's my understanding -- and I have to admit, I'm very 24 sympathetic with this point of view of management -- and O (_p) 25 this is strictly hearsay, by the way -- NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234-4433 WASillNGTON. D C. 20005 3701 (202) 234-4433

291 1 CHAIRMAN SEALE: Let me finish my question, 2 though. It seems to me that it would be appropriate to ,s l t 3 judge the elements of that program independently and 4 decide whether FCI is on the chopping block, or hydrogen 5 combustion, or whatever. Because I can fully anticipate 6 there may be other topical arena and other centers, if you 7 will, or other focus areas, which may individually be on 8 the chopping block, before perhaps, some of the things 9 here are on the chopping block. 10 MEMBER FONTANA: That's a good point. 11 CHAIRMAN SEALE: I think you're making the 12 go/no-go decision at a level higher than is appropriate. 13 VICE CHAIRMAN POWERS: Understand, I'm making ,s 14 no no-go decisions at all -- 15 CHAIRMAN SEALE: But -- I know, but if they 16 are indeed, making it in a way you suggest -- 17 VICE CRAIRMAN POWERS: Let me explain what -- 18 MEMBER FONTANA: I talked to Morrison 19 yesterday a little while afterwards here and he said well, 20 he says if I let go of severe accidents what do I lose, 21 compared if I let to something else what do I lose? And 22 so on. He says, I already know enough about severe 23 accidents to tide me over. His position. 24 But you're right, Bob. If you want a line r~~3 (,) 25 item veto rather than the whole page. NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234-4433 WASillNGTON, D.C. 20005-3701 (202) 234-4433

292 1 VICE CHAIRMAN POWERS: I believe the rationale 2 went this way. That they had done the research budget c ~' 3 cutting in the past, much like you described, Bob. He had 4 reached the point now, there were no longer any overly S ripe elements to pluck out. He had a large nut to crack 6 and he did the voting a lot like Mario said. Is, what do 7 I lose? If I take anything else out of that list versus 8 what do I lose here? 9 Now, I don't know that these are carved in lo stone. In fact, it looks to me like a lot of it's a game 11 of chicken here. Or it's like -- I characterize it as 12 cancelling the football program when you have to cut the 13 high school budget. You know that a lot of people are (-U 14 going to squawk. 15 Again, my personal difficulty -- 16 MEMBER KRESS: When you really ought to cancel 17 the band from the -- 18 VICE CHAIRMAN POWERS: Well, you don't want to 1 19 cancel the girl's field hockey team anymore. ] i 20 CHAIRMAN SEALE: Or the cheerleaders. l l 21 VICE CHAIRMAN POWERS: You end up in court. 22 MEMBER KRESS: How did this degenerate so 23 quickly? Go ahead. 1 i 24 VICE CHAIRMAN POWERS: If I could have my last /; 3 (_ ) 25 slide of really acerbic comments. NEAL R. GROSS COURT REIMTERS ANDTRANSCRIBERS 1323 RllODE ISLAND AVE.,N.W. ll (202) 234-4433 WASillNGTON, D C. 20005-3701 (202) 234-4433

293 1 MEMBER KRESS: How come I don't have that 2 slide? -w I \\ \\'~/ 3 VICE CHAIRMAN POWERS: Because I didn't pass 4 it out. When I get very acerbic I don't want to leave 5 evidence. 6 This just says, some of my initial thoughts in 7 looking at the intelligence I've gathered on this subject 8 is, the basis of prioritization of the current research 9 activities is just not at all obvious to me -- and I list 10 some things here. 11 We have no applications for license extension 12 but lots of applications for high burnup fuel; 13 consequently, we have a large research program in plant )

\\'

14 aging and just a small component of a small program to 15 look at high burnup fuel. 16 MEMBER KRESS: This makes logical sense. 17 VICE CHAIRMAN POWERS: Makes no sense to me -- 18 MR. SHACK: I'd point out that steam 19 generators don't wait until you ask for license extension 20 to degenerate, nor do vessels wait for ycu to ask for a 21 license extension before they embrittle. 22 VICE CHAIRMAN POWERS: I will also remind you 23 that steam generators are part of the maintenance rule and 24 not part of the aging rule. p) 25 We have an Agency-wide effort to go into risk-NEAL R. GROSS COURT REM)RTERS ANDTRANSCRIBERS 1323 RIIODE ISLAND AVE. N.W. (202) 234-4433 WASilINGTON, D.C. 2(XX)5-3701 (202) 234-4433

294 1 informed, performance-based regulation, but we don't have x 2 any research to develop risk information in things like k~) 3 shutdown, and George has mentioned some others -- or to 4 extend this research concept into materials in the medical 5 use area. 6 And again, the planning that we have seen in 7 some of these research areas -- and the human performance 8 program plan is the one that comes most to mind -- they 9 tend to be much more listings of program -- 10 MEMBER KRESS: Does that mean they' re turning 11 over on their side and sinking? 12 VICE CHAIRMAN POWERS: No, that means that 13 there are enumerations. They seem to be enumerations of ,a ) '/ 14 programs that lack a focus on, and any tie to, what the 15 ultimate goals of the Agency are -- the mission needs, 16 again, and what the requirements are. 17 And I think that as we go into this examining 18 the Research program, I certainly would like to see us 19 encouraging the Agency to go to a more disciplined 20 practice in planning its research so that it is following 21 more of a DOD kind of principle than this -- gee, it seems 22 like a good idea to look into this -- type of principle. 23 That's what I have to say, Bob. 24 CHAIRMAN SEALE: Thank you very much, Dana. I n(,) 25 think you've done us all a real service here, and I think NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE. N.W. (202) 234-4433 WASil!NGTON, D.C. 2txX)5-3701 (202) 234-4433

295 1 you've set us all up for this planning effort. I would 2 urge everyone to take the time to go over the more -~s ) v 3 specific information on each of these programs so that we 4 can get ourselves up to speed to work more effectively on 5 the research program. 6 MEMBER MILLER: Are we going to -- Dana has 7 made kind of a recommendation. Are we going to discuss 8 further how we might be involved in that recommendation, 9 or are we going to -- 10 CHAIRMAN SEALE: Well, I think you have some 11 things planned for the near future to discuss elements of 12 the Research program. In the meantime, as you go along 13 and you find -- well, growing out of the I&C process 7 k-14 you're in right now, if there are research elements that 15 ought to be argued out, you should identify them for us 16 and perhaps write some things down on them so we'll have 17 something specific to talk about. And similarly, in other 18 areas. 19 MEMBER MILLER: My question is, should we as 20 individuals -- like I as Chair of this I&C committee -- 21 talk one-on-one with the I&C Research group ad hoc, or 22 should we not do that? 23 CHAIRMAN SEALE: Well, I think that would be 24 fine. f3 (,) 25 VICE CHAIRMAN POWERS: I think I'd encourage NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE..N.W. (202) 234 4433 WASil1NGTON,D C. 2(KKB-3701 (202) 234 4433

l 296 1 that. I think at some point we as an institution are 2 going to have to decide and formulate a strategy on what 7, i'~') 3 it is we want to do with respect to the Research program. 4 Are we going to let it come to us as it's 5 delivered, or are we going to get involved in the process 6 and say, what is it that the Agency really needs in the 7 area of research, and how can that research be organized 8 to meet those needs? 9 MEMBER FONTANA: Are we free to go talk to the 10 guya on the staff? I know I got a little dinged a little 11 bit for asking for something, and turned out it was 12 embargoed, or what the heck ever it was, and I should have 13 gone through -- r~% 14 CHAIRMAN SEALE: You weren't dinged; you were 15 told it was embargoed and it wasn't available to you at 16 this time, and that can happen. 17 MEMBER FONTANA: Yes, but I can -- 18 CHAIRMAN SEALE: But it's not as if you had 19 gone in there and mugged somebody or kissed the secretary 20 or anything like that. That's on a personal, one-on-one 21 basis, Mario. 22 MEMBER APOSTOLAKIS: You guys remember we're 23 on record, here. Because I forgot earlier myself, so 24 that's why I shut up. ,. \\ ( ) 25 CHAIRMAN SEALE: No, you can talk to NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE.,N.W. (202) 234-4433 WASHINGTON, D.C. 200(15 3701 (202) 234-4433

297 1 individuals, you should ask the cognizant staff engineer 2 to work with you on that. ~s' x'~ / 3 MEMBER FONTANA: There's no area there -- 4 CHAIRMAN SEALE: No, no. 5 MEMBER MILLER: So there's reason to be 6 somewhat proactive in all this. 7 CHAIRMAN SEALE: Yes. 8 MEMBER FONTANA: Okay, thank you. 9 CHAIRMAN SEALE: You didn't violate a 10 fundamental principle when you went to talk to someone. 11 When you found out it was embargoed, then that's a 12 constraint they have to live with and you have to honor 13 that. But you didn't do anything fundamentally wrong to r, ) x/ 14 approach them in the first place. 15 Okay. Now, I think before we quit, I should 16 mention that after we had our meeting with the 17 Commissioners, Commissioner McGaffigan asked me if we were 18 going to be looking at any of the other DSIs. And I had 19 the distinct impression that they would appreciate if we 20 would go through those and try to identify specific 21 components, or indeed the whole issue, that we would like 22 to make comments on. 23 So I thought I would try to get together with 24 John and go through the DSIs and perhaps dole them out (g) 25 appropriately and see if we could take a quick reading by NEAL R. GROSS COURT REPORTERS ANDTRANSCRIDERS 1323 RilODE ISLAND AVE.,N.W. (202) 234 4433 WASillNGTON, D C. 2'XX)5-3701 (202) 234 4433

298 1 the individual involved and then maybe at the next meeting 2 we'll take the time to see if there are things in the DSIs fs ) \\ ~'/ 3 that we should try to do some more in-depth work on, 4 similar to what Dana has done here on 22. 5 MEMBER MILLER: Would it be reasonable to dole 6 them out the way we doled them out before? 7 CHAIRMAN SEALE: Well, I think there have been 8 some changes and some personnel changes -- moving of 9 responsibilities -- 10 MEMBER MILLER: Well, I agree -- 11 CHAIRMAN SEALE: -- and so I'd like to 12 doublecheck that. 13 John? I think I would do my committee a favor 14 if I allowed them to take about a 10-minute break. We're 15 going to check on -- this 10-minute break will be a more 16 religiously observed philosophy. 17 DIRECTOR LARKINS: I'd just mention, everybody 18 did get the DSIs -- the individual Commissioner's comments 19 on many of them. 20 CRAIRMAN SEALE: Yes, right. Okay, we'll be 21 back. 22 (Whereupon, the foregoing matter went off the 23 record at 2:46 p.m.) 24 ,r3 (m,) 25 NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RilODE ISLAND AVE. N.W. (202) 234 4 33 WASHINGTON, D.C. 20005-3701 (202) 234-4433

l-CERTIFICATE l This is to certify that the attached proceedings before the United States Nuclear l Regulatory Commission in the matter of: Name of Proceeding: 441' ACRS 8 l l 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 O typewriting by me' or under the direction of the court I reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. 1 ( LCORBETT RINER Official Reporter Neal R. Gross and Co., Inc. ] G V NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RilODE ISLAND AVENUE, NW (202)234 4433 WASilINGTON,D.C. 20005 (202)234-4433

l INTRODUCTORY STATEMENT BY THE ACRS CHAIRMAN 441ST ACRS MEETING, MARCH 1-3, 1997 THE MEETING WILL NOW COME TO ORDER. THIS IS THE SECOND DAY OF THE 441ST MEETING OF THE ADVISORY COMMITTEF, ON REACTOR 1 SAFEGUARDS. DURING TODAY'S MEETING, THE COMMITTEE WILL CONSIDER THE FOLLOWING: (1) STAFF REQUIREMENTS MEMORANDUM (SRM) ON DIRECTION SETTING ISSUE 22, RESEARCH (2) IMPLEMENTATION OF THE MAINTENANCE RULE (3) FUTURE ACRS ACTIVITIES (4) RECONCILIATION OF ACRS COMMENTS AND RECOMMENDATIONS' (5) PROPOSED ACRS REPORTS IN ADDITION, THE COMMITTEE WILL MEET WITH THE NRC COMMISSIONERS BETWEEN 9:00 - 10:30 A.M. IN THE COMMISSIONERS' CONFERENCE ROOM TO DISCUSS ITEMS OF MUTUAL INTEREST. ()- THIS MEETING IS BEING CONDUCTED IN ACCORDANCE WITH THE PROVISIONS OF THE FEDERAL ADVISORY COMMITTEE ACT. MR. SAM DURAISWAMY IS THE DESIGNATED FEDERAL OFFICIAL FOR THE INITIAL PORTION OF THE MEETING. WE HAVE RECEIVED NO WRITTEN STATEMENTS OR REQUESTS FOR TIME l TO MAKE ORAL STATEMENTS FROM MEMBERS 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. O

i ? i STATUS OF THE MAINTENANCE RULE i l l I i Richard P. Correia t I Thomas A. Bergman l

Contact:

Rich Correia l l Phone: 415-1009 i May 2,1997 i l l l ?

AGENDA i Maintenance Rule Background e i Baseline Inspection Program Results e I i e Clarifications in Regulatory Guide (RG) 1.160, Revision 2 \\ L l i i e Lessons Learned and insights j t i L l f i I f i I

\\ OVERVIEW i e Need for a Rule ~t 3 l i Number of Transients and Scrams Maintenance Team inspections t e Developed Risk-informed, Performance-Based Rule l t i t Give Licensees Flexibility i i e Can Inspect and Enforce j i e Challenges Variation Between Licensees NRC Resources Required are High 2 -__----_--j

l O O O BACKGROUND 1 e Rule issued 7/10/91, in Effect 7/10/96 t e Industry Guideline Document NUMARC 93-01 .1 e RG 1.160 e inspection Procedure (IPD 62706 i e IP 62707 I l 3

O O O BASELINE INSPECTION RESULTS i I 24 Inspections Each inspection Unique i [ Overall Licensees Adequately implementing the Rule e Some Licensees implemented Late 1 l l i 4 l

O BASELINE INSkCTION RESULTS CONTINUED i i i i Two Common Findings e Inadequate Reliability Performance Criteria / Goals Failure to Moritor Both Reliability and Availability e Scoping i' Reluctance to identify Maintenance Preventable e Functional Failures (MPFFs? i Structural Monitoring i e t (a)(3) Safety Assessments e 5 I

O O O BASELINE INSPECTION RESULTS t CONTINUED Enforcement Complete on 13 Inspections Two Had No Maintenance Rule Violations One Had One Severity Level lli But No Civil Penalty Ten Had One or Multiple Severity Level IV Remaining inspection Findings Under Staff Evaluation 6

o O O i CLARIFICATIONS IN RG 1.160, i REVISION 2 i l Scoping e l l 4 MPFFs as Reliability Indicator e e Monitoring Structures i i Normally Operating SSCs of Low Safety e Significance j l l l

CLARIFICATIONS IN RG, CONTINUED l t t i Safety-Significance Categorization Process l Reflect Changes to Rule Since Revision 1 t Definition of Maintenance \\ Timehness Definition of Standby MPFFs Related to Design Deficiencies i Number of SSCs in Category (a?(1) i 8 I i i

i Importance of Communication t i Value of the Pilot Program Guidance Developed Through iterative Process Importance of Training May need Programmatic Baseline inspection Program i Can Consistently inspect and Enforce i Resource Requirements High Rules Must Only Contain Requirements e 9 l

l 4 l RESEARCH OPTIONS !O OPTION 1 QUITDOING RESEARCH j OPTION 2 l CONFIRMATORYRESEARCH ONLY OPTION 3 6 EXPLORATORYRESEARCH ONLY OPTION 4 l CONFIRMATORY & EXPLORATORY RESEARCH i !O PTION 5 i ESTABLISH & MAINTAIN CORE l RESEARCH CAPABILITIES i j OPTION 6 USE UNIVERSITIESMORE OPTION 7 PARTICIPATEININTERNATIONAL SAFETYPROGRAMS I 0

l' SELECTED OPTIONS

O i

o OPTION 4 i EXPLORATORY & CONFIRMATORY RESEARCH (BUSINESS AS USUAL ?) o OPTION 5 ESTABLISH & MAINTAIN CORE j RESEARCH CAPABILITIES 4 - RES IS TO DEFINE THESE CORE CAPABILITIES - CAN ACRS HELP ? i o COMMISSION SUPPORTS A BIGGER l FRACTION OF THE RESEARCH GOING TO UNIVERSITIES l - WANTS NEW APPROACHES TO l GRANTING MONEY ) o CONTINUE ACTIVE PARTICIPATION IN INTERNATIONAL RESEARCH PROGRAMS i 4 (

i OTHER POINTS i O EXPLORE COOPERATIVE RESEARCH WITH o l INDUSTRY & THE DOE -DOE BUDGETFOR NUCLEAR ENERGY \\ IS UNDER EXTREMEPRESSURE [ $0 TO $40MILLIONFOR FY'98 i i b o MOVE RULEMAKING OUT OF RES I o ESTABLISH RESEARCH EFFECTIVENESS REVIEW BOARD !O j o IDENTIFY RESEARCH NEEDS FOR NRC i OVERSIGHT OF DOE NUCLEAR FACILITIES o CONTINUE TO THINK ABOUT ITEMS ON PAGES 13,14 AND 18 OF THE DSI 3 0

i PAGES 13 & 14 lO j o ORGANIZATIONAL ISSUES e - FOCUS NOWON CONDUCT OFRESEARCH EFFECTIVELY & EFFICIENTLY l 0 ROGERS' PAPER i i -NRCIS A KNOWLEDGE BySc:2 iVSTITUTION I - REQUIRES MAINTENANCL., %' TENSION l OF THEKNOWLEDGE BASE - QUALIFIED STAFFESSENTIAL l o RELATIONSHIP BETWEEN RES & PROGRAM iO OFFICES IS KEY TO EFFECTIVE & EFFICIENT l CONDUCT OF RESEARCH .i l - SPECIALIZED EXPERTISEINPROGRAM l OFFICES OR JUSTINRES ? ) - CANNRCSTILL ATTRACT TOP TALENT? i -SHOULD THERE BE A BROADER EXPLORA TORYRESEARCH COMPONENT ? l l - IS AN INDEPENDENT OFFICE OF RESEARCH i ESSENTIAL ? i lO 4 l

i PAGE 18 4!O WHAT CORE CAPABILITIES ARE TO BE o MAINTAINED & WHAT SHOULD BE ALLOWED !j TO WITHER AS NEED DISAPPEARS ? i j MAINTENANCE OF CAPABILITIES BY o i -INHOUSE STAFF - CONTRACTORS - COMBINA TION 4 l SHOULD MORE ANALYTIC ACTIVITIES BE o i DONE IN HOUSE ? o HOW DO YOU DECIDE TO DROP A RESEARCH !O ACTIVITY ? I \\ - HOWDO YOURE-INITIA TEIFA SPECIFICNEED ARISESLATER ? i o DEPTH OF STAFF EXPERTISE NEEDED k e i i 1 6

O

.~

t j CRITERIA FOR A CORE PROGRAM !O l 1. High risk, large uncertainty area; does it myolve emerging issue or technology ? l; 2. Is expertise or facility unique ? l 3. Can NRC gain access in a timely manner ? ( l 4. Can NRC gain access to independent expertise ? i l 5. How frequently will expertise or facility be used ? !!O 6. What impact on NRC if capability is lost ? l \\ 7. What is cost of reassembling expertise ? l l 8. What is cost of maintaining expertise ? A l 9. How important is expertise or capability to ongoing i cooperative agreements ? 1 i i 7 i O i J + i w

RES PROGRAM lO o AGING RESEARCH i - CONTINUES THROUGH FY'99 i -I THOUGHT AGING RULE ELIMINATED j MOST OF THE NEED FOR THIS i 0 REACTOR STRUCTURAL PERFORMANCE l i. f - COOPERATIVE AGREEMENT WITH JAPAN l CONTINUES THROUGH FY'99 j - TESTING & DEVELOPMENT OF SEISMIC ANALYSIS TOOLS i o PRA ,iO - PRIMARILY IPE & IPEEE I - SOME METHODS DEVELOPMENT l HRA l . ORGANIZATIONAL PERFORMANCE l

• FIRE RISK l
• PLANT AGING

. DIGITAL I&C CONSEQUENCE UNCERTAINTY - NO SHUTDOWN / LOW-POWER COMPONENT 8 O i

RES PROGRAM, CONT'D o THERMAL HYDRAULICS

O

- CODE UPDATE I l -IS THERE REALLY THAT MUCH NEED ? -INCLUDES FUEL BEHAVIOR CODE UPDATE FOR HIGH BURNUP FUELS - SOME WORK AT HALDEN i o I&C AND HUMAN FACTORS l i - WHY IS HUMAN FACTORS SEPARATED FROM j HRA ? I -INCLUDES TESTING OF SMOKE ON DIGITAL j CIRCUITS l - SAYS ASSESSMENT OF THE ADEQUACY OF i INDUSTRIAL STANDARDS IS A COMPONENT

O bur THERE IS NO rASx FOR THIS o

SEVERE ACCIDENTS i i i - COMPONENTS INCLUDE i j

• FCI i
• HYDROGEN COMBUSTION l

. LOWER HEAD INTEGRITY SOURCE TERM

• SEVERE ACCIDENT CODES

- ORIENTED TOWARD COOPERATIVE PRGMS 4 9

O l

REACTOR AGING PROGRAM i e GOALS j u Provide data and analysis tools necessary to identify (anticipate), l quantify (inspect, validate), manage (mitigate effects and establish margins), and regulate effects of aging in nuclear power plants for current license periods and license renewal Maintain essential competence for NRC through highly qualified a technical staff and a few analytical and experimental contractors I Stimulate, provide leadership, and collaborate in international research a j projects e COMPONENTS l m Embrittlement of the reactor pressure vessel (RPV) l ~ Thermal annealing of the RPV m i RPV fracture analysis methods a l Environmentally assisted cracking of safety-critical systems and m f components Nondestructive evaluation techniques e Integrity of steam generator tubes = Aging of electrical cables a Mechanical components - inspection, surveillance, testing and a maintenance. e, O O

REACTOR AGING PROGRAM Major Deliverables international Collaborators 1 e Validate Annealing Rule & R. G. O Second International Pioing Intearity Research Group 5 Engineering Demonstrations 1997 (IPIRG-2)- 14 foreign collaborators E Recovery and Rembrittlement Trends 1999 e Working Group of the Joint Coordination Committee on e Revise PTS Regulatory Guide 1999 Civilian Nuclear Reactor Safety on Pressure Vessel e implement improved fracture mechanics Integrity (WG-3) - Russia, Ukraine methods into ASME Code and validate 1998 e Working Group of the Joint Coordinating Committee on e Evaluate and quantify material property Civilian Nuclear Safety on Nuclear Plant Aging and Life variability 1997 Extension (WG-12)-Russia, Ukraine O Validated models for SG tube severe accident e Internatiorial Group on Radiation Damage Mechanisms analyses to support NRR rulemaking 1997 for RPVs - 11 foreign contributors e Validated correlations for inspection, leak rate, e international Cooperative Group on Environmentally failure pressure and failure mode 1999 Assisted Cracking - 18 foreign collaborators e Complete LOCA testing and evaluation of cable e CSNI. Principal Working Group - 3. Subaroup on the - condition monitoring and provide guidelines Integrity of Metal Comoonents - The European to NRR on EQ 1999 Community, East European countries, and 2 other 4 e Provide review criteria for evaluating licensee foreign contributors IST programs for pumps and valves 1997 Key Contractors. O University of California at Santa Barbara e Brookhaven Nationals Laboratory (BNL) e Argonne National Laboratory (ANL) e Pacific Northwest National Laboratory (PNNL) e Battelle Columbus Laboratory (BCL) e Oak Ridge National Laboratory (ORNL) e Idaho National Engineering Laboratory (INEL) O O O

i i i REACTOR STRUCTURAL PERFORMANCE i e GOALS Provide information needed to develop regulatory acceptance criteria for a '{ judging site suitability considering seismological, geological, and j' geotechnical factors and other natural hazards Assess and validate analytical methods for structural performance e l Determine adequacy of margins of existing facilities through inspection m l procedures and evaluation of effects of degradation i 1 e COMPONENTS i l inspection and evaluation of aged / degraded structures and components a a Confirmation and assessment of design and operational capacity of j nuclear power plant structures, systems, and components j Assessment of the capacity and margins of reactor containments u j Earth science investigations u l = Assistance for evaluation of siting and structural aspects of non-reactor j facilities such as gaseous diffusion plants and independent fuel storage facilities t l. e e e'

REACTOR STRUCTURAL PERFORMANCE PROGRAM i Maior Deliverables International Collaborator.s e Trialimplementation of NRC, DOE and EPRI e Hualien Soil-structure interaction Exoeriment.- guidance on conducting probabilistic seismic France, Japan, Korea and Taiwan I analyses 1997 e Main Steam & FeedWater Seismic Provina Tests at e Revise Reg. Guides 1.60,1.61,1.92, etc. 1998 Tadotsu Shake Table -Japan e Seismic data from large-scale main steam and e Strong Ground Motion Propagation Through Shallow feedwater system 1997 Soil Columns - Japan, France e Data from large scale concrete containment e Containment Structural Intearity Model Test at SNL pressure tests 1999 -Japan i e Evaluation of methods to assess margins e CSNI. Princioal Working Group 3. Subaroups on of degraded containments 1998 Seismic Behavior of Structures and Behavior of e Assessment of grease leakage from Degraded Containments - EC, Eastern European prestressing tendons on strengths of Countries, Japan, Korea concrete containments 1997 O Data from seismic proving tests of e Seismic Proving Tests for Concrete Containments - Reinforced and Prestressed at Tadotsu Shake Ta_ble concrete containments -1998 - Japan Key Contractors e Lawrence Livermore National Laboratory (LLNL) e Brookhaven National Laboratory (BNL) e Oak Ridge National Laboratory (ORNL) e Sandia National Laboratory (SNL) e United States Geologic Survey (USGS) e City College of New York (CCNY) e University of Califernia at Santa Barbara e Energy Technology Engineering Center (ETEC) e Corps of Engineers / Waterway Experiment Station h

l PROBABILISTIC RISK ASSESSMENT PROGRAM e GOALS Support risk-informed regulation by developing guidance and methods = for PRA i Develop insights on the application of PRA through reviews of IPEs and = IPEEEs I j e COMPONENTS Development of Regulatory Guides on use of PRA in risk-informed a regulatory activities Develop and demonstrate methods: a ASP model Human reliability analysis Organizational performance influences on risk l Fire risk analysis Reliability and data analysis Digital l&C influences on risk Consequence uncertainty analysis Regulatory Reviews: s IPEs & lPEEEs Insights from set of submittals i Q

PROBABILISTIC RISK ASSESSMENT PROGRAM j Major Deliverables laternational collaborators e Finalize Reg. Guides in the area of oeerall PRA, ISI, e Bilateral agreement on PRA methods _- Spain IST, OA, and e Bilateral aareement on PRA methods - Switzerland Tech. Specs. 1997 e Bilateral agreement on PRA methods _ - Canada e initiate any needed rule changes for risk-informed e CSNI. Principal Working Group 5. - E.C., US, regulation 1998 Eastern European Countries, Japan, Korea e Initiate changes to 10 CFR 52 9 PRA technoloav transfer and WER-1000 PRA - regarding COL-PRA 1998 Russia (GAN) e Completion of methods developments e Research contract - Russian Academy of Sciences or improvements: O PRA technoloav transfer and WER - 440 PRA - E Human reliability analysis 1997 Ukraine 5 Organizational performance 1998 O Proposed intemational cooperative program on PRA E Fire risk 1999 E Plant aging 1998 E Digitall&C 1999 5 Consequence uricertainty 1997 O Issue draft IPE Insights report for Public Comment Complete O Complete final IPE insights report 1997 O Complete IPEEE SERs 1998 O Complete IPEEE insights Report 1998 Key Contractors e Brookhaven National Laboratory e Sandia National Laboratory e Idaho National Engineering Laboratory e Los Alamos National Laboratory e Energy Research, Inc. e e 6

\\ i l 1 THERMAL HYDRAULICS PROGRAM i e GOALS Develop and maintain experimental capability and analytical tools for the m j independent assessment of applicant / licensee submittals through highly j qualified technical staff and a few support contractors j Analyze and evaluate operating events and safety issues to assure an u appropriate basis for regulation i Stimulate and collaborate in international research in thermal hydraulics a and fuels j Train future engineers through focused research at universities u COMPONENTS i Plant transient analysis a Plant transient code improvements a Thermal hydraulic testing a { Fuel behavior and reactor physics m ? ,e O O

THERMAL-HYDRAULICS PROGRAM Maior Deliverables international collaborators e Complete incorporation and correction of e The Code Assessment and Maintenance Program currently identified deficiencies in thermal-hydraulics (CAMP) involves 25 countries. They provide cash codes 1997 contribution, assessment of the NRC thermal hydraulic e initiate development of an improved state-of-the-codes (RELAP5. TRAC-B and TRAC-P). East art code to replace the existing T/H codes 1997 European countries' contributions are provided by e Complete AP-600 related experiments 1997 AID. O initiate testing in support of future code e We are collaborating with CEA, France, RRC, Russia development 1997 and JAERl, Japan in the thermal hydraulic and high e Complete update of FRAPCON 1997 burnup fuel testing: e Complete' update of FRAP-T6 1998 - CABRI e initiate clad test program 1998 - NSRR - Halden e Actively participating in CSNI PWG-2; hosted and participated in several ISPs, workshop and specialists meeting Key Contractors e Los Alamos NationalLaboratory e Brookhaven National Laboratory e Scientech,Inc e Penn State University e Purdue University e University of Maryland e Oregon State University e Argonne NationalLaboratory O e

j 1 t CONTROL, INSTRUMENTATION, AND HUMAN FACTORS l i i 5 GOALS Develop a credible basis of understanding of the performance e characteristics of digital I&C systems, including software reliability and l man-machine interface, to provide guidance to regulatory decision making 3 l Develop methods for assessing human and organizational performance m { for use in regulatory applications i i e COMPONENTS Hybrid control rooms a Root cause investigations a a Human performance = Environmental qualification of digital I&C hardware j Programing languages and CASE tools u Adequacy ofindustry standards m l Guidelines for evaluation of the human-system interface m Total system reliability and acceptability a i e

CONTROL INSTRUMENTATION AND HUMAN FACTORS Maior Deliverables International collaborators e Complete development of a technical basis and e OECD Halden Reactor Project - Norway, Belgium, guidance on hybrid control room 1997 Denmark, Finland, France Germany Italy, Japan, O Complete technical basis report for advanced Korea, Spain, Sweden, Switzerland, UK, Czech control rooms 1997 Republic, Hungary, Netherlands, Russia e Complete technical basis report for a performance e Technical Exchange & Cooperation on Human based method to determine staffing levels for Factors - Switzerland (FOE) operating plants 1997 e Technical Exchange & Cooperation on Human e Revise Reg. Guide 1.8 1997 Factors - Spain (CSN) e Reg. GuMc 1.164, Time response criteria for e Exolorina cooperative effort with ISPN on software safety-related operator actions 1997 quahty - France e Complete revision to HPIP 1998 e in the area of Task Network Models E Complete first model on medical device 1997 E Complete first model on reactor related human performance model 1997 O Issue Reg. Guide on EMI/RFI 1997 O Complete smoke testing program 1997 O Report effects of smoke on digital l&C 1998 Key Contractora e Brookhaven National Laboratory e Institutt for Energiteknikk (Halden) e Army Research Laboratory (ARL) e Pacific Northwest National Laboratory e Oak Ridge National Laboratory e Sandia Nationa! Laboratory e NationalInstitute of Science & Technology (NIST) e Sohar,Inc { e Lawrence Livermore National Laboratory e 9

SEVERE ACCIDENTS PROGRAM i e GOALS 1 Develop and maintain tools for analysis of severe accidents m Expand experimental base through international collaboration to a understand and quantify phsnomena and potential challenges to reactor and containment integrity COMPONENTS e Fuel-coolant interactions a Hydrogen combustion a Lower head integrity / debris coolability a a Source term Severe accident codes a I e e G'

SEVERE ACCIDENTS PROGRAM ] Major Deliverables Irttemahnnal1ollaborators e Complete FCI experiments on chemical e CSARP (Coooerative Severe Accident Research Proaram) I augmentation of eneregetics 1998 - Belgium, Bulgaria, Canada, Czech Rep., Finland, France, e Complete high temperature hydrogen Gennany, Hungay, Italy, Japan, Korea, Lithuania, Netherlands, Slovcik Rep. Spain, Sweden, Switzerland, combustion experiments 1997 e Complete RASPLAV program 1999 e PH US F ssion Product Procram - France, European e Complete lower head failure experiments 1998 Union, Japan, Canada e Provide pretest support and conduct tests e FARO Proaram - Belgium, France, Germany, Italy, FTP-2 and FTP-4 1998 Netherlands, Spain, Sweden, Switzerland, UK e Coinplete updated code releases of MELCOR, e OECD RASPLAV Pro _iect - Russia, Belgium, Canada, SCDAP, and CONTAIN 1997 Finland, France, Germany, Italy, Japan, Korea, e Complete peer reviews of VICTORIA & Netherlands, Spain, Sweden, Switzerland, UK FCIcodes 1997 e MELCOR Cooperative Assessment Prooram - Belgium, e Complete analyses and developruent in support Canada, Czech Rep., Finland France, Germany, Hungary, Italy, Japan, Korea, Netherlands, Spam of AP-600 review 1997 " ~ e Complete in-vessel cooling experiments 1998 Czech Rep., Finland, Germany, Hungary, Korea, Netherlands, Spain e MACE - EPRI, Belgium, Canada, Finland, France, Germany, Hungary, Italy, Japan, Mexico, Netherlands, Spain Sweden, Taiwan, UK e Hydroaen Combustion - France, Germany, Japan Russia e in-Vessel Coolino Experiments'- EPRI, France, Japan e GASFLOW Code - Germany t$ry Contras1gg e University of Wisconsin e Argonne National Laboratory e JRCISPA (ISPRA) e Russian Research Center e California Institute of Technology (Cal Tech) e Sandia National Laboratory e Penn State University e Commissariat L' ENERGIE Atomique (CEA) e Brookhaven National Laboratory e Idaho National Engineering Laboratory O Oak Ridge Nation boratory 18 O Los Alamos Natio aboratory e Fnernv Rowarch inc -}}