ML20151Y316
| ML20151Y316 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1662, NUDOCS 8805040421 | |
| Download: ML20151Y316 (139) | |
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In the Matter of:
ADVISORY SUBCOMMITTEE ON THE GENERIC ITEMS ISAP II i
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2 ADVI'SORY SUBCOMMITTEE'ON THE GENERIC ITEMS
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7 Wednesday, April'27, 1988-8 Room 1046 9 1717 H Street, N.W.
Washington, D. C. 20555 10 11- The above-entitled matter came on fo'r hearing, 12 pursuant to notice, at 1:30 p.m.
13 ACRS SUBCOMMITTEE MEMBERS PRESENT:
14 DR. CHESTER P. SIESS, Professor Emeritus of Civil Engineering 15 University of Illinois, Urbana, Illinois 16 DR. FORREST J. REMICK 17 Associate Vice-President for Research and Professor of Nuclear Engineering, the 18 Pennsylvania State University, University Park, Pennsylvania 19 i MR. CARYLE MICHELSON, ,
20 retired Principal Nuclear Engineer, Tennessee Valley: Authority, Knoxville, Tennessee and 21 retired Director Office for Anaylsis and l
Evaluation of Operational Data, U. S. Nuclear 22 Regulatory Commission, Washington, D. C.
I O 23 MR. DAVID A. WARD,
) Research Manager on Special Assignment, E. I.
du Pont de Nemours & Company, Savanna River Labora-Q b
24 tory, Aiken, South Carolina
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3 .ACRS SUBCOMMITTEE MEMBERS PRESENT: (Cont'd) 2 MR. CHARLES J/,WYLIE, , _
r.etired Chief Engineer,_ Electrical, Division,
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. .j COGNIZANT! ACRS STAFF MEMBER:
5- SAM.DURAISWAMY e
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6 NRC STAFF. PRESENTERS:
7 Ms. Melanie Miller 8 Mr. Warren Minners 9
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dic y 3 1 EEEEEEE1EEE 2 DR. SIESS : Good afternoon. The meeting will 3 now come to order.
4 This is a meeting of the ACRS subcommittee on 5 Generic Items. I am Chester Siess, Subcommittee Chairman.
6 The other ACRS members in attendance, starting on my left:
7 Carlyle Michelson, Forrest Remick, David Ward and Charles 8 Wylie.
9 The purpose of this meeting is to discuss the Integerated Safety Assessment Drogan II, ISAP II. And in 11 secarately from that, with other participants, the 12 integration of related generic issues.
The llll 13 He have two principal items on the agenda.
l4 Cognizant Staff Member for the meeting, Sam Duraiswamy, is sitting on my right. The rules for participation in 15 16 the meeting were announced as part of the notice published 17 in the Federal Register on Monday, April 18.
18 A transcript is being kept and will be made 39 available as stated in the Federal Reaister notice. I 20 request that each speaker first identify himself or herself 21 and speak with sufficient clarity of volume so that he 22 or she can be readily heard.
He received neither written comments nor requests 23 24 for time to make oral statements from members of the 1
25 l public.
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dic 4
- I think the only speakers will be those at the h 2 table and I am sure that the Reporter has got everybody's 3 names by now.
4 As I stated, the subject is ISAP II and what 5 we have before us is a predecisional document which is 6 a report to the Commissioners from the Executive Director 7 of Operations making--summarizing the situation and 8 making recommendations regarding ISAP II.
9 And with that brief introduction, we might as go well get down to business and I will call on Melanie 11 Miller to take over from here.
12 She has been shepherding this thing through llll 13 the process since Year One, I guess.
14 MS. MILLER: At least since late 1987.
15 As Dr. Siess indicated, my name is Melanie 16 Miller and I am a technical assistant at NOR. In addition 17 to being a technical assistant, I also have a title of 18 being ISAP II program manager.
19 I have been in that position since about early 20 December of 1987 when we first started working on the 21 generic letter describing ISAP II to all power reactor 22 licensees.
23 Now before we actually get into the detailed l
24 I presentation I guess I am going to ruin the joke by 25 telling you the punch line first, and that is that i
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dlc 5 I currently the NOR recommendation regarding ISAP II is 2 that it not be implemented at this time due primarily 3 to resource constraints.
4 And I will be discussing that specific bottom 5 line recommendation a little bit later on in the 6 presentation. But I did want to let you know that so 7 you can keep that in mind as we go through this.
8 Now the presentation today I will start out 9 by talking about exactly what is ISAP II. And as 10 part of that definition I will explain the program 11 components, the difference between a pilot program and 12 the new program, ISAP II.
lllh 13 The process involved, exactly how it would 14 work; what some perceived benefits are to the utilities 15 and to NRC.
16 And then how ISAP II is related to both the 17 IPE and the integrated schedule policy . In addition to 18 that, I am also going to talk about the survey results, 19 what the utilities told us when they responded to the ,
20 generic letter 88-02 survey.
21 l And then we will discuss in a little bit more i
22 detail the specific NRR recommendations.
23 . Now ISAP II of course is a follow-on program t
that the staff has proposed to the pilot ISAP progran g 24 f 25 ql, l
which was initiated in about 1984 for two northeast f
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dlc 6 1 utility plants: Haddam Neck and Millstone I.
2 And the pilot ISAP was itself an outgrowth of 3 the SEP program, a means to implement for these two 4 plants the SEP findings.
5 Now both the pilot ISAP and ISAP II can really 6 be described as indicated in the second bullet, a 7 systematic program to address regulatory issues within 8 an integrated schedule.
9 The proposed ISAP II was described in, as I 10 have indicated, generic letter 88-02. He specifically 11 developed that generic letter in order to accomodate 12 a Commission request; that is, to provide the Commission lllh 13 with more information as to exactly what is the level of 14 industry interest in participating in such a program.
15 So in order to assess their interest, we had 16 to describe the programs so that they would have l'7 some information to base some answers on. And then 18 provided a brief five or six question survey asking 19 l about will you be interested in participating, what are 20 some of your concerns, what are some suggestions for l 21 improvements, would you be interested in participating h
22 ~ in a seninar with the NRC to understand more about the 23 I program.
24 And later on the presentation will be going 25 into more specific detail and exactly what we learned l
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7 I from the generic letter.
2 Now the objectives of ISAP II are three-fold.
3 The first we believe is that the ISAP II program would 4 contribute to enhancing safety and it would do this 5 by allowing both the utilities and NRC to direct their 6 resources and to appropriately prioritize regulatory 7 issues such that the most safety significant things 8 would typically be worked on and completed first.
9 Related to that is an increased efficiency 10 in the licensing process. And this will be accomplished 11 because of the fact that we would all be working on 12 the most safety significant things first and probably lllh 13 dropping out some less safety significant items such 14 that we would not be spending staff resources on working 15 on things in the wrong time frame that are not contributing 16 to our overall goal of properly regulating nuclear power 17 plants.
18 The third item was not a specific objective of 19 the pilot ISAP but it is something that has gotten 20 increased emphasis in ISAP II.
21 We believe that by providing'this program to 22 utilities it would have the positive benefit of encouraging l 23 ; the use of PRAs because as cart of ISAP II a utility would gg 24 be required to do at least a Level I PRA 25 They will be required to maintain it and in Horitogo Reporting Corporation im an.u.
8 I the process hopefully learn more about their plant 2 capabilities as well as the NRC interaction and us 3 learning more about their plant capabilities.
4 So we believe that is a positive benefit. Now 5 the explicit program component for ISAP II, or as I 6 mentioned the PRA, that is the framework real.ly around 7 which ISAP II is developed.
8 Now while a level I PRA is required at 9 191nimum , there may be situations where deterministic 10 analyses must be used in order to supplement a PPA.
Il There are certain issues which just cannot be 12 evaluated within the context of a PRA. And so, you know, 13 that's alloowed within the ISAP II framework.
14 In addition, we would require utilities to 15 maintain and update on a regular basis, probably every 16 refueling outage, their PRA in order to take credit and 17 understand plant configuration changes, procedural 18 changes, et cetera, which may affect some of the issues 19 that are being evaluated.
20 A second componu.it of ISAP II is the operating 21 experience review. And exactly how tne operatina experience 22 review factors into IFAP II is somewhat different 23 from the emphasis of the operating experience review in 21 the pilot program.
25 This is because in ISAP II the onerating Heritago Roporting Corporation (m m m.
9 i experience review will really only be emphasized for 2 those plants that are using generic industry data for 3 their component failure rates that they input into the 4 PRA.
5 For those plants that are using plant-specific 6 component failure data, in essence an operating experience 7 review is involved in accumulating that data and inputting 8 it into the PRA; therefore, there will not be a 9 supplemental experience review required.
10 MR. WARD: May I ask a question?
11 MS. MILLER: Yes.
12 MR. FARD: That sounds good, like Ted said the other day, if you say it fast.
lh 13 14 MS. MILLER: Okay.
15 (Laughs) 16 MR. WARD: But the PRAs I have had some 17 experience with and looked at, the reliability and failure 18 data, performance data, is really a mixture of a lot of 19 different kinds of things.
20 Can you really separate it? Are there PRAs 21 that have been done that really would neet this test of 22 having, you know, really exhaustively used their own i
23 j daca?
i 24 MS. MILLER: Well, I can't soeak to how 25 i exhaustively plants use their own data in their PP.A. But Horitago Roporting Corporation inn u.aus
10 i from what I understand, you know, the generic plant 2 failure data is the baseline. That is what every PRA 3 would start with.
4 And then those utilities who are using plant-5 specific information would take it a step further and 6 vary that generic data based on what they know about the 7 components in their plant.
8 And how exhaustive that process is, I really 9 don't know. You know, Glenn Kelly is a PRA staff member 10 and maybe he could better answer that question is you 11 want to follow-up onthat.
12 MR. MARD: Okay. But it seems like it is a 13 key distinction. I guess frankly I am sort of doubtful 14 if there are any PRAs out there ' hat have a--you know, 15 where their use of their own data is so conplete that 16 you could taka the option of not requiring an experience 17 review; that that option would be valid.
18 Maybe I'm wrong. But that is the impression that 19 I get.
20 , MS. MILLER: Do you want to respond to that, 21 Glenn?
P 22 l MR. KELLY: My name is Glenn F.elly. I am with 23 NRR.
l 24 Ordinarily if someone is going to perform a 25 l!4 PRA we would expect that if it is a plant that does have I
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i 11 I some experience as operating for some time, that they 2 will go back and look at their own experience and reflect 3 that in their data buse that they are coing to use in the 4 plant.
5 Most of the times we have seen this done by 6 what they call a basing update which is where they take 7 the generic data base and then they modify it according 8 to how their plant has been operated.
9 And if this plant has been updated and if it 10 is sufficiently different from the generic data, we 11 normally would want them to use their plant-specific 12 data rather than even modifying it by the generic g 13 data.
14 Does that help you?
15 MR. WARD: Well, I mean I understand that sort
!6 of process. It is sensible. But what I an--I mean my 17 question is really directed toward how complete does any 18 plant really have, any plant that has done a PRA, really l
19 have such a complete experience base that it hasn't had i
I 20 i to resort at all to generic data?
U MR. KELLY: No, there will always be some 21 h Il 22 !! generic data because for exanple if we are doing things 23 h like large pipe breaks, we don't have any large pipe breaks so we are going by generic data.
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12 i For things that are tested relatively frequently,
- 2 things like relays or valves that open or close relatively 3 frequently, those we can, if the plant has operated say 4 five, seven, ten years--I would say closer to seven to 5 ten years--they have an update there that you would 6 have expected for anything that is tested or tried 7 frequently.It can have a reasonable data base.
8 Things that you may only exercise a couple of
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9 times in the lifetime of a plant, there you have to go 10 by generic data because you have to take into account the 11 overall experience of the industry.
12 i MR. WARD: Okay. Well I guess I just remain lllh 13 suspicious--
14 l MR. KELLY: Yes.
I 15 MR. WARD:--that while this is a good theoretical 16 distinction, I am not sure in practice it can really 17 i be made validly. I think you need to look closely at 18 l that.
I 19 MS. MILLER: Okay.
20 Then the third component associated with ISAP II 21 really builds on the first two. That is, the PRA and
!i the operating experience review would be input into 22 h h
n 23 !i the utility and the staff's review of an integrated 24 l assessment where all the issues within the scope of 25 j ISAP II would he evaluated and ranked on the basis of il y Heritago Roporting Corporation j o.o . . ....
13 I such things as safety, risk reduction, personnel exposure, 2 et cetera.
3 And then of course the end result from all of a this is the integrated schedule itself. Now just to 5 highlight some significant differences betwern tie pilot 6 program and ISAP II.
7 One of the most significant differences is 8 that in ISAP II, utilities will not be required to 9 address findings from the SEP program.
10 This was a primary objective and really the 11 initiator for the pilot program but it will not be the 12 case in ISAP II.
lllll 13 Second thing is that the pilot program also 14 required utilities to address generic issues ahead of 15 the staff's resolution of thatissue.
16 In ISAP II, that will not be a requirement, 1 In other words, generic issues will not be factored into 17 i 18 the ISAP II progran until such time that the staff has 19 developed its resolution of that issue and all utilities 20 j would be asked to resolve it, h
21 The third item really is a corollary to the I
22 l first two, and that is the scoce of ISAP II will only 0
23 E include current and future issues for that plant.
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24 By "current" issues we mean things like items 25 h required by regulation, by order, by license condi tion,
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14 I commitments that the utility has already made to the 2 NRC. Those are future issues.
3 In addition, the utility would have the option of l
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including its own initiatives as part of the future t
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6 And we believe that component is a positive 7 benefit to a utility. For instance, a utility-initiaed 8 item that might be wise for them to include in ISAP II 9 would be activities associated with a trip teduction 10 progran, t
11 Because, if the utility can show that that l
12 has certain safety benefits or risk reduction benefits,
@ 13 that item may very well rank higher than certain NRC 14 required items.
15 So tilat would be somet hing for a utility to 16 consider very strongly. By "future" issues, we mean 17 such things as generic issues which are resolved in the 18 future or new safety issues which come up subsequentl'j, y
h 19 j' and those would be factored into the ISAP II process.
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The fourth bullet is something that was done 21 ;l as part of the nilot prggram . There was a draft 22 staff document called a draft integrated safety assessment l
23 report which went through a peer review as well as an r 24 ACRS review.
- 25 ; In ISAP II, which is not proposed as a pilot
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15 1 program or an extension of a pilot program, we would 2 envision only a final integrated safety assessment 3 report and we would not go through the draft process.
l 4 Therefore, there would not be this additional 5 level of review, 6 The next bullet regards with the licenre 7 condition. This is something that was originally proposed 8 in a generic letter for ISAP II, that there would be 9 a license condition to tie the utility to meeting the 10 approved ISAP II methodology and to--you know, meetings, 11 the schedule that is developed by ISAP II, 12 However, largely as a result of the number of g 13 comments that we receive from utilities to the generic 14 letter, we have decided that a license condition will not 15 be necessary to accomplish what we hope to accomplish i
16 l through such a program as ISAP II.
17 l Instead, the utility would be required to make i
18 ll a very firm commitment to the NRC that they will follow 19 l the approved methodology, that they will stick to the i
20 schedule stablished by ISAP II. And more of a good ,
21 q)lfaith sort of approach rather than the regulator rigor 22 ld associated with a licensed condition.
23 And lastly a key difference also between the c
24 pilot program and ISAP II would be the existence of 25 the IPE and the fact that ISAn II will provide a strong--
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16 I would provide a strong foundation for completion of 2 the utilities IPE.
3 And again we are going to get into that 4 explicitly a little bit later when I discuss the relationship 5
l between the two programs.
6 Now exactly what is the ISAP Process?
7 DR. REMICK: Melanie, I have a question.
8 MS. MILLER: Yes, Dr. Remick.
9 Where you talk about future issues--
DR. REMICK:
10 MS. MILLER: Yes.
11 DR. REMICK: --how about if the Commission comes 12 out with a regulation. Would that be integrated into 13 73Ap II7 I4 Let's say they come out with a new regulation 15 with some requirements.
l 16 MS MILLER: Yes it would.
17 DR. REMICK: It would be integrated?
l I8 f Yes. The important thing to MS. MILLER:
f 19 remember when we are talkir.g about regulations is, you I
20 know, current ones and future ones would be part of 21 i yggp 77, 22 ff If it would turn out that through the rank and i
23 prioritization scheme that that item is a low h
b 24 significant for that utili ty, ISAP II would easily provide 25 the justification for obtaining an exemption.
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17 i However, the regulatory burden, if you will, 2 the paperwork and exemption request and us issuing an 3 exemption, would still need to taxe place.
4 So ISAP II wouldn't obviate the need for l
5 ; the regulatory people work, but it would provide what i
6 we see as an easier justification for obtaining the 7
j dropping of lower priority items.
8 DR. REMICK: What comes to mind is that if.the 9 Commission does issue a regulation on fitness for duty 10 and that requires certain thinas includincT random testing 11 there could be a utility in the ISAP program that has a 12 fitness for duty program already; doesn't include random g 13 testing. They look at that and say that is not a very 14 high priority item. We already have a fitness for duty 15 program that is working and therefore that is a low 16
) priority that we can put off.
17 I am not differing with it but I could see 18 things like that happening and it is a specific example 19 l that comes to mind. I am not sure that the Commission 20 would be happy with that.
f 21 MS. MILLER: That sort of example is the type 1
22 jj of example that I would not see as fitting into the ISAP II i N framework for a couple reasons. First is, it is not 3]
24 readily evaluated in terms of a PRA or even a deterministic 25 analysis or safety risk is considered.
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18 i The second thing is I guess I don't see that 2 j as really taking a lot of utility resources in the sense d
30 that a major delay is because we don't have the money to 4 do randon testing.
5 So it doesn't fit in quite to the--
6 DR. REMICK: Some future regulations will be 7 included and some will not, is that your--
8 l MS. MILLER: 9ight, because some just don't i
9 fit into the ISAP II framework.
10 Okay. Now the ISAP II process is outlined here i
11 and we would expect it to take place over about a 24-month 12 period. And that 24-month period really starts after
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llll 13 " the staff has reviewed the PRA for acceptability.
14 Also, it is important to know that this listing 15 of the process is r.ot nccessarily in chronological 16 order in the sense that there is overlap here, e
17 One item does not have to finish before the 1
18 l!l next one will start. Naturally the startina pir. cess is i
19 the submittal of the PRA.
fi 20 h The .ttaff would first evaluate that FRA to il I
21 l nake sure that t~e methodology is acceptable and that 22 the utility has adequately incorporated, for instance, l
l 23 it's plant-specific data.
l l 24 Following a staff evaluation sayinq that the PRA g
25 [ is acceptable, the utility would submit the scope of ISAP II a
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19 I issues that it wants included.
2 The staff would review that list to make sure 3 l that everything is included that we believe is inportant 4 as well as to make sure that the wrong things are not i
i included in the ISAP II program.
5 6 Following a resolution of the issues question, i
I 7 i the utility would look at all the issues, evaluate them, l
8 l propose resolution, if that hasn't been done already, 9 and determine the ranking of each issue .
10 Now the ranking would be determined on such 11 things as safety significance, risk reduction, personnel J
12 '( exposure both to on-site workers and off-site public.
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l And the ranking then would show up as a high, l e, j medium or low ranking. Now it is important to note that in i
13 pl addition to the various criteria which I listed, the d
4 16 l utility would have some flexibility in determining I
17 h whether other ranking criteria could be applied in their 0
1 18 i prioritization scheme.
!l 19 jl And this is to account for things which a H
20 l utility--which one specific utility may find important
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22 requiring certain availabi]ity factors for that utility
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23 d or whatever. That is just one example, d
24 I MR. WARD: Melanie, could I ask a question?
g 25 MS. MILLER: Sure, i
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20 i MR. WARD: Why aren't Items 2 and 4 combined?
2 And what doca Item 3 amount to? Why is it necessary?
3 MS. MILLER: I supnose Items 2 and 4 could be 4
l combined.
5 l MR. WI.RD: Yes.
I 6 MS. MILLER: This is really the way that the 7 pilot ISAP process progressed. And it seemed to work 8 satisfactorily.
9 But I think if ISAP II were to be implemented, 10 we would have to get to a finer level of detail as to 11 how best to implement the program and what 3.)u suggest may 12 very well occur.
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l MR. WARD: Well, it sounds like Item 3 is just i
14 kind of a preliminary look to make sure they are going in l
i 15 l the right directions.
26 MS. MILLER: Yes.
I 17 MR. WARD: Maybe that is necessary. I don't j
i 18 l know.
19 p MS. MILLEP: Really, it could be the sort of 20 thing---- getting the list of issues is pretty much a 21 i mechanical process. It is not something that involves a 1
22 lot of work.
l 23 ! So they could be providing that to us while i
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21 3 which is more involved.. Like you say, we have a heads up 2 and will be able to get them on the wrong track if they 3 are off course.
4 j MR. WARD: Yes.
5 MS. MILLER: Now as far as the ranking of high, 6 medium or low, in general we would suggest the issues 7 which are ranked high would be implemented within one to l
g two refueling outages.
9 Issues which are ranked medium, about two to 10 four. And then issues which are categorized as low l
I would be beyond--would be four or more refueling outages.
11 j
12 Or, would be candidates for being dropped.
g 13 And I think it is important to point out that 34 that high, medium or low and their frame for implementation 15 are strictly guidelines because we do realize there is 16 a certain flexibility in any schedule and that is really 17 the purpose of ISAP II.
I 18 However, if the utility would find that they have five issues which are ranked high and they are 39 1
20 h proposing to us implementation all at three or four 23 refueling outages in the future, that would be a red flag i'
22 to us that wait a minute, this is not what we had 23 anticipated and we need to take some action to negotiate and get them to our way ,f thinking a little bit more.
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h 25 ji But conversely, that is to say that if there are h
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22 1 five issues ranked high, three of them could be done in 2 the first two refueling outages and the next two in maybe 3 the third because we realize that there are resource f
I 4 constraints.
5l So there is some flexibility in those guidelines 6
l naturally.
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7 li MR. WARD: That was an interesting definition 8 of negotiate.
I 9 (Laughter) j I
10 "To get them to our way of thinking."
11 MS. MILLER: Yes. Persuasion, whatever. Yes, 12 we would not agree to that sort of suggestion so maybe g 13 "negotiation" would be too soft.
14 Then following an agreement between the staff and l
15 j the utility as far as the ranking and the resolution 16 l the items, we would issue our document or integrated i
n 17 ,
safety assessment before we could describe the process 18 l
and discuss the issues and their resolution.
19 After that point or concurrently while that
!I 20 0 document is being developed, we would be actually 21 ,
negotiating the schedules to see when certain things are 22 l going to be implemented as proposed by the utility and l
23 l hopefully bring to quick agreement on what the utility U
24 l proposes.
25 Then subsequent to the initial schedule being d
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23 1 developed there would of course being a schedule of 2 modifications in line with new issues coming up.
3 We would probably propose to review new I schedules following each refueling outage which is probably 5 the time frame that the utility would be developing 6 its next schedule.
7 i As the process becomes nore of a routine l
8 1 maintenance sort of item, hopefully the NRC would be a 9 little bit more comfcrtable in backing off a little bit 10 and not getting a lot of technical staff involved in
!! reviewing the maintenance program but leave that up to 12 more the resident inspector and the project manager to llll 13 make sure things continue to work smoothly as originally 14 designed.
15 MR. WYLEI: Question.
16 f MS. MILLER: Yes.
I' 17 MR. WYLIE: Your estimate of 24 months begins 18 when and ends when?
19 h MS. MILLER: Okay. The 24 months begins following 4
20 the review of the PRA.
21 ; MR. WYLIE: Okaj, i
22 MS. MILLER: And when I say "review of PRA",
i 23 that is the initial review just for its adequacy. After l
d 24 that point--that is about a three-month time frame--after g
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that point, the PRA review for ISAP wouldn't actually be 1
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24 I a little bit more involved because the PRA people stay 2 involved as far as reviewing each individual issue.
3 l But that is taking place further down. And 4
4 l then the 24 months would end with the first schedule 5 being established.
6 MR. WYLIE: Yes. Thanks.
7 MS. MILLER: Here are listed some anticipated 8 ISAP II benefits. And for the most part there, they are 9 pretty self-explanatory and they were discussed a little 10 j
bit in the generic letter that we issued.
I 11 But there are a few things I want to highlight, i
12 I want to emphasize again the fact that ISAP II allows 13 for items to be dropped from a utility's implementation 14 plan.
15 And that potentially could be a very big benefit I
l 16 for utilities if they have especially a long list of l
i I
17 items.
18 And then of course it would also apply to 19 future issues. So the staff anticipates in the next 20 h few years a lot of generic issues to become resolved, I
I 21 1 and those future issues could also be things that would 1
22 j be dropped and that would fall into the same benefit 23 package for the utility.
[
24 }l Another point is having to do with the
- r 25 j; maintenance survei.11ance intervaln and their optimization.
d Heritage Reporting Corporation g -...
25 i Westinghouse owners group has done something similar in 2 this area with reactor trip set point frequency of 3 inspection and surveillance intervals and they were able 4
l to show through a PRA basis that intervals could be i
5 l extended and lengthened.
6 And we would anticipate that the same sort 7 of thing could be done with the utility that has their 8 pRA approved and is using ISAP.
9 DR. SIESS: Melanie--
10 MS MILLER: Yes.
11 DR. SIESS: --before you take--put that back up 12 there.
13 (Refers to viewgraph) 14 I think this is a very important slide because 15 ! in view of the outcome--first place, in view of the 16 l industry response I guess you haven't been successful i
17 I in selling the industry or a large portion of it on the h
18 l benefits.
19 And in view of NRR's response, haven't been 20 successful in selling NRR on the benefits.
I,l 21 So I was looking at this list as to which 22 Lil of these benefits accrued to the industry and which Il n
23 4 accrued to the NRR. Theoretically, improved safety 24 should benefit both the industry and the NRR.
But I will just arbitrarily say that improved 25 l D
l p
j Heritogo Reporting Corporation l
! m u.
i
26 I safety goes in the NRC column. The first item may not 2 show any benefits or at least the benefits might about 3 equal the cost, right, to the utility?
4 He has to do some work to have the scheduling.
5 The second one has a potential benefit to the utility.
6 MS. MILLER: As well as us because less 7 resources will be involved in reviewing issues that are 8
dropped.
9 Who do you think benefits from that?
DR. SIESS:
10 MS. MILLER: Both, 11 DR. SIESS: The fourth one you thir.k is the 12 utility?
13 11 S . MILLER: Yes.
14 DR. SIESS: And the fifth one?
15 MS. MILLER: Yes.
16 DR. SIESS: The sixth one is a little bit hard 17 to quantify, I guess. He should all benefit from that l
18 l one.
l 19 p MS. MILLER: Yes, I think that's both, b
20 [ DR. SIESS: But of course the in-depth plant l
21 understanding is going to come from the IPE. That is ll 22 the major--well that is the whole. One of the stated 1
23 objectives of the IPE is if they do a PRA, they participate ll 24 in it and they have a better understanding of their plant, 25 am I right? Did you get that sort of impression?
Heritage Reporting Corporation (maa4m
]
27 i So that I think comes from IPA and then the next 2 to the last one should be more safety for the buck but 3 whose buck it is, I am not quite sure.
4 MR. WYLIE: I know whose buck it is but whose 5 safety it is, I guess, is the question.
6 DR. SIESS: Well, it is everybody's safety.
i 7 And I think that some of the licensees think they l
8 might be spending the bucks.
9 MR. WYLIE: Yes.
10 DR. SIESS: And the last one i; probably one of 11 the most important and it is very intangible. Go ahead, 12 but I think we've got to come back to this question of l
13 why this thing isn't flying.
14 MR. WYLIE: It seems to me that this next slide 15 is very important in the relationship to IPE.
l 16 g DR. SIESS: Well, you know, I spent a fair amount j 17 of time going through the letters you got back from the i
18 i plants, comments back, and looking to see the reasons thc.y l
19 { gave for liking ISAP or saying they are interested.
I 20 And some flatly say they weren't interested and 21 I some say they need more information. And there are some 22 strange ones in there. There were SEP plants that expressed i
23 ; considerable skepticism to the whole process.
i 24 d And other SEP plants like Northeast Muclear that
- # 25 h h have been battering at the door now for three years to get j Heritogo Reporting Corporation l < m> ns .
28 I two more plants in this program.
2 But there was a general objection to the 3 licensing amendment which has gone away but you don't know 4 to what extent that affects, you know--
5 MS. MILLER: Right.
6 DR. SIESS: There was a considerable concern about 7 the resources for this as opposed to--in addition to IPE.
8 And I got to the feeling that there was some attempt to say 9
this was the same as IPE.
i 10 MS. MILLER: Yes. No, it is not even close.
11 DR. SIESS: They either didn't understand IPE 12 or they didn't understand this. There is an undercurrent 13 in there of general suspicion committing to anything 14 until they know how NRC is going to do it.
j I'
15 Correct.
MS. MILLER:
16 DR. SIESS: Not entirely unfounded. And there 17 were some very good suggestions.
18 There were several that raised the very interesting 19 question as to how this was going to relate to all the l
l 20 requirements put on them by the regions that you haven't 23 i
mentioned.
l 22 I will.
j MS. MILLER:
ll 23 DR. SIESS: You will get to them.
l !l i
g 24 Have you made any attempt to sort those things 25 out and figure out why the various people said no or--
d h
P 1 Heritage Reporting Corporation can n
I 29 I (Pause) 2 MS. MILLER: Well, I wouldn't say that I made 3 a rigorous attempt but I think I have a general understanding.
4 You know, some of the things you already alluded to, the 5 fact that a lot of utilities feel uncomfortable right 6 I now with the level of information and the level of detail i
k 7 4 that has been provided by ISAP II.
l 8 And I think, you know, like you say, rightly i
9 ! so. Maybe they have some points.
10 DR. SIESS: Most of those would be in the "maybe" 11 category.
12 MS. MILLER: Right. But I think some of the ll g 13 insights that I have based on my review of those 14 responses we'll get into when we talk about the results 15 of the survey.
I 16 DR. SIESS: For example, why would Commonwealth 17 Edison say yes, we would be interested for LaSalle and 18 Zion but know we would not be interested for Dresden, 19 Quad Cities, Byron and Braidwood.
20 MR. WYLIE: Well, there's the correlation.
21 They've got PRES for LaSalle and Zion.
22 DR. SIESS: They didn't say that, u
ll 23 p MS. MILLER: And I--
l!
24 MR. WYLIE: But I bet that's the correlation.
Il 25 B MS. MILLER: That may be. And I think part of l !!
D
[ Heritogo Reporting Corporation y = u . ..
H
30 1 it also at least in the case of not going onboard with 2 Byron and Braidwood is the fact that Byron and Braidwood 3 j are much new plants and their list of regulatory i
4 actions to be fed into ISAP is very small.
5 l And they don't believe that the resource--
6 MR. WYLIE: Yes, but if they say that about 7 Dresden II and III--
I 8 i MS. MILLER: You're right.
9! (Laughs) 10 DR. SIESS: Or Ouad Cities. Now Dresden II 11 went through the SEP program.
12 MR. WYLID: Yes but without a PRA of its own.
13 DR. SIESS: That's right. But again I don't 14 l think Com Ed said that PRA is their hang-up--
I!
15 MR. WYLIE: Well maybe they did not say it but
.I I
16 h I bet that is the hang-up.
I!
17 l DR. SIESS: Maybe.
1 l
18 MS MILLER: Another motivation for Commonwealth 19 ! Edison on Zion is the fact that they have an order which i
20 resulted from I guess TMI time frame and they have had 21 it on for years and years and years and they believe l
22 there are certain components of that order which could
\l\
23 be justified to do away with.
J 24 And they see the ISAn processes giving them i 25 '
that leeway to argue with us to take away the order.
1 il
[ Heritogo Reporting Corporation ino u.
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31 DR. SIESS: Everyone tied the PRA properly to 2 this. And some of them said we are not going to have a 3 PRA. We just started one; it is going to be three years 4 before we have it and then we will probably be interested.
5 And some of them said we don't have a PRA and 6 we are not going to have one; we are not interested.
7 ! We were told yesterday that in connection with i
8 the IPE they expected about 50 of the 80 plants, 80. designs 9 shall I say, will have PRAs and the other 30 will go the 10 , IPE methodology.
l 11 I We've been told in a different context that I
t 12 maybe not many of them--that maybe not that many are llll 13 going to the IPE because there are some pressures to go l4 PRA.
15 Now how many of those 50 are represented in l
16 this batch I don't know. But there were some strange i
17 i responses in there. But clearly it was very clear a il 18 l lot of them did not understand exactly what you were i
19 j proposing.
20 I Others probably understood it too well and said n
ll 21 ] gee, this sounds great but I know how you are going to 22 do it; I don't trust anybody. And they asked me a lot U
23 of good questions. What are you goina to do about the l
l 24 y regions and so forth, W 25 j il So I am trying to I guess settle in ny own mind ll ll Heritogo Reporting Corporation
<m asam
32 I why your management of NRR thought the response was so 2 poor.
3 I was a little bit somewhere between amused 4 and annoyed by the reference to a majority as if the 5 staff reacts to a majority plants, 6
l There wasn't a majority of the plants for this 7 so we won't do it. I didn't really know NRC was that 8 democratic.
9 (Laughter) 10 But go ahead.
Il j MS. MILLER: Okay. Because I think we will get 12 into this more when we get into the generic letter 13 itself.
l 14 i DR. SIESS: Yes. Good. Unless we cet into l
15 that, we don't have an ISAP.
16 MS. MILLER: RIght. Okay. As far as the relation-17 [ ship between ISAP II and tha IPE, I think naturally I
i 18 i the commonality is the PRA. That is what joins the two, t
19 i
Right now we had originally proposed in the i
20 l generic letter that ISAP II and the IPE are distinct l
'i 21 h and separate programs but compatible, h
22 And this is somewhat different from what had c
23 '
been proposed in the November paper talking about the 24 pilot ISAP and the results of that program. That is f
25 p something to keep in mind.
\!
g Heritogo Reporting Corporation j m .a m.
33 i But there are two perspectives that one can 2 take in actually viewing the relationship between the 3 two.
l 4l The first is looking at ISAP II as the initiating 5 f program. With the utility participating in ISAP II, 6 they are required to do the PRA.
I 7 Therefore, they have already initiated the 8 preferred means of completing the IPE. Then further to I
9 I complete the IPE of course they need to do the containment 10 vulnerability assessment.
Il DR. SIESS: I don't think the staff has said 12 the PRA is preferred. They say--
13 MS. MILLER: You're right.
14 DR. SIESS: They state the three alternatives--
15 l MS. MILLER: You're right. They haven't said 0
l 16 j that for a variety of reasons.
17 (! DR. SIESS: I mean some of us might think it is L
4 18 y preferred but--
f 19 MS. MILLER: I think that we all think it but u
N we haven't said it.
h J
s 21 j Okay. The second way to look at it is b
by looking at the IPE as the initiating analysis.
22 [
'l 23 The IPE of course is a requirement as part of the l
1 24 Commission's severe accident nolicy statenent.
25 h And if the utility, in fulfilling that Heritogo Reporting Corporation ll m u.
[
34 I requirement of the IPE, decides to do a PRA, it is a 2 simple matter for them to say all right, I have already d
3
] done the PRA: I might as well apply that PRA as well to 4 ISAP II and obtain some of the benefits that I can obtain l
5h from that program.
6d ,
Now an important point then is how do these i
7 two programs actually mesh. And the way that occurs 8 is the IPE, in looking at severe accidents, is going to i
- 9) have as an end-product or a result a list of risk lP 10 j reduction modifications which a utility needs to d
11 implement .
12 Once those are determined--it may be zero for h 13 some plants but let's assume that there are some. If U
14 {I there are some from the IPE that a utility needs to make t
i 15 modifications, those items would roll-over, if you will, 16 or would be input to the ISAP process, i
17 They would be evaluated and looked at in the g!
i i
18 overall integrated schedule to see how they rank compared 0
19 to items which the utility already has there by way of
]
h 20 h current items.
0 21 Now what this does is it specifically makes 0
22 4 sure that the IPE is the program where severe accident b
23 sequences are being evaluated.
24 / ISAP II does not look at severe accidents,
- 25 l
That is strictly an IPE function. By doing that, we are ,
o lj Horitogo Reporting Corporation imm.
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35 1 not going to have conflicting results or reviews resulting, 2 making the programs very compatible.
3I I think that is an important point. And then 4 we get to the actual criteria that are going to be used 5 to establish which risk reduction modifications need to 6 be implemented as part of the IPE are the adequate 79 protection standard--
\l 8 DR. SIESS: You are not up-to-date. Adequate l
9 protection no longer appears. It is compliance with 10 l NRC regulations, d
11 MS. MILLER: Ah-ha. Okay. Well, you throw me h
12 h for a loop.
lllh 13 DR. SIESS: Some people think it is the same 14 l thing. That's all right. Just replaco it with MRC h
15 regulations--adequate protection.
1 II 16 y MS. MILLER: Okay, a
l 17 l DR. SIESS: Unless you are a lawyer,'it doesn't 0
18 ! make any difference.
19 MS. MILLER: All right.
u 20 g The adequate protection standard would be il 21 1 used to indicate which of those IPE actions need to be ii 22 g implemented without doing the cost benefit analysis.
d 23 [ And then if there are additional items vou 0
want implemented as part of the IPE, we would fall back W 24 h
's h
1 on the backfit rule.
l J h
1 Heritogo Reporting Corporation i
i (272; 626 4644 l
36 i Now those same criteria would then be applied 2 in a sense to the ISAP program such that if additional 3 i risk reduction items are identified through ISAP II l!
4 f that were not identified as part of the IPE, that are 5 >
not in some means factored into severe accident sequences.
1 6J Those --
h!
7
.l DR. SIESS: Wait a minute. You don't identify l
8 l
items to us, do you? You only resolve items.
9 MS. MILLER: No. In the sense that you have 10 done a PRA for your plant, there may be certain sequences 11 l that fall out of that PRA that show you there--
12 DR. SIESS: That's an IPE function, though.
lllll 13 MR. WYLIE: Sure it is.
14 h DR. SIESS: That's what is confusing people, 11 h
15 I MR. WYLIE: They are the same thing.
I 16 MS MILLER: No. No.
i l
17 DR. SIESS: ISAP has only to deal with those
]
d 18 [ things that have already been imposed on you, b
19 '1R . THOMAS: Chet--I am Cecil Thomas. In i
20 h the pilot ISAP program, I think it is important to L
r 21 ,
recall that PRA was used for two purposes. One was to 22 Ii identify--
o 23 h DR. SIESS: We are not talking about the pilot d
24 program. We ara talking about the one right now.
25 ! MR. WYLIE: I would like to hear what Cecil says.
4 h
Heritogo Reporting Corporation ino .a m.
37 I But I think this is an important point. I was going to 1
2 bring that up.
3 The pilot program, as I recall it, clearly did I
4 that, what Melanie just said. And that was an awful lot 3 like IPE.
]
6 But what Melanie described a couple charts ago--
f 7
ISAP II, that step seemed to be omitted.
I 8
DR. SIESS: Yes.
9
, MR. Tl!OMAS : If I may, let me try to explain how i
10 we got from the pilot program to here.
I 11 DR. SIESS: Look, that isn't the issue right l'
12 l now. I think what I am trying to find out is why the h 33 industry doesn't like the program that went out to them I4 in the generic letter.
15 And that wasn't in that--
6 16 I think--maybe this will help.
MS. MILLER: I i
17 !! think--
0 IE DR. SIESS: New requirements were not a part of 19 what went out in that generic letter, am I right?
20 You know, history is history: SEP, IFAP, pilot h
- i uh s
program and so forth, b' hat we are faced with now is
\l 22 a generic letter that went out with a proposal for an h
f 23 q ISAP II and got a certain level of response.
24 Some of the requirements of sone of the features 25 l! of that generic letter have since been changed and there
[ Heritogo Reporting Corporation b w us .
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38 I has been no industry response to those changes because 2 ! they haven't seen then, l
3 MR. WYLIE: What' been changed?
l!
l1 4 ; DR. SIESS: Well, the license amendment 1
5 j requirement that was in the generic letter has been 0
6l dropped in this current proposal.
l 7 MR. WYLIE: Oh, okay.
8 So we are looking at two stages.
DR. SIESS:
9 There is a certain stage here that the industry commented 10 on and some changes have been made since then that 11 management has reached a decision on.
l 12 MR. WYLIE: Could I ask--did you say you've g 13
} added back into ISAP II this requirement to use the 14 PRA itself to identify issues?
d 15 MS. MILLER: Well I wouldn't--I suppose I i
16 wouldn't say we are adding back in that requirement.
J 17 h !!oweve r , the possibility exists that the IPE, because 0
I8 !i it focuses on severe accidents, may not turn up some other l
19 j significant risk reduction items that the detailed PRA F
20 dealing with all sequences on the plant would identify.
0
'l
- De it, we believe that possibility is a small g
F 22 one. We really don't think that there are that many 9
23 0 things that a PRA in ISAP could turn up that would be li 24 significant that the IPE hasn't already identified because 25 h it is so encompassing.
H u
g Heritogo Roporting Corporo' ion
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39 I DR. SIESS: I don't recall seeino that in the 2 generic letter that you sent out.
3 MS. MILLER: No, you didn't go into that level in 4 detail.
5 DR. SIESS: llad that been in there, you would L
6 L have gotten more noes than you got.
Il n
7b n MS. MILLER: I don't think so .
8 ji DR. SIESS: I think you would. Look, people 9 are very suspicious of the things you can find in a PRA.
U n
10 1 MR. THOMAS: One of the points we tried to b
11 l nake in our generic letter and I think we elaborated on 12 )
more during some subsequent meetings that we held with i
g 13 Brunswick, Commonwealth and also Duke came up--
b 14 DR. SIESS: Uhat did Duke finally tell you?
l I
15 i MS. MILLER: I'm sorry?
l DR. SIES: What did Duke finally decide? I 16 b
17 ! don't know.
I 18 i MS. MILLER: No, no. I just got their response 19 h last week. No, b
20 [ MR. THOMAS: One of the key points that we 21 j wanted to make here was for ISAP II nothing would be 22 3 required of the utility you wouldn't otherwise be b
23 required.
(
DR. SIESS: Okay. That's fine, W 24 25 h L[
h MR. THOMAS: Okay. Just to elaborate on Duke's 9
h Heritogo Reporting Corporation
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40 l
i l
I . point, they felt that they didn't have enough items on 2 their plate to justify doing it. They strongly supported I 3 1 the program for people that did have a lot of items on 4 hq their plate.
h They just didn't fool they had enough to do 5
ii 6 it.
L 7 4 DR. SIESS: Okay. If they feel the same way a
J 8y five years from now, it will be interesting.
9 MR. WYLIE: But what Cecil just said seemed to 10 j! be my understanding of ISAP II. But that doesn't seem to a
li
!! O be what Melanie said.
12 MS. MILLER: Yes, it's not.
llll 13 il There is the possibility that we would apply 14 f these criteria to the PRA finding from ISAP II and that L
t 15 ! something might turn out.
h 16 Now it is important to note that these criteria
]
17 are not different from the way we've done business for i
18 '
years and years.
U 19 0 DR. SIESS: But you are naking someone provide il 20 you with the tool--PRA tool--and they are suspicious.
21 " You are not going to get many people to volunteer to c
22 I give you ammunition, t!
23 MR. WYLIE: Well, they are going to be doing it 24 under IPE though.
25 , MS. MILLER: The difference is, too, in the Heritogo Reporting Corporation
- < nt u. j 1
41 I pilot ISAP where we are using the PRA to find additicnal N 2i I
line-ups, we did not rigorously apply for instance the 31 backfit rule.
I 4 [ In this case, if we would, I think we would be in h
5 p trouble, d
6[ i DR. SIESS: But let me go at this thing again, l
7 I: I think you tried to establish too much of a relationship 8 [/
li between ISAP and IPE. You said they have one thing in 9 common and that's a PRA.
i 10 That is 50--62.5 per cent true if what we heard l
11 ,
yesterday was correct, that 30 of the plants are going to 12 go IDCOR methodology, which is not a PRA.
ll 13 l MS. MILLER: Well, naturally, but then they 14 I wouldn't be able to work for ISAP.
I 15 I DR. SIESS: And let's assume that they all end h
16 j un going PRA. ISAP II addresses thase requirements which 1
17 o have been imposed on the plants by the NPC and how those H
are resolved on what time scale. That is priority.
18 fi L
19 j That is what ISAP II does. IPE does not 4
20 j impose any requirements on the licensees except to do 21 H the IPE.
22 U They look at the results of the IPE. They decide l make a fix. And if they 23 g whether they think they need to W 24 [l' 25 h decide they need to make a fix, ti.ey teli the NRC on what schedule they plan to do it.
L 1 Heritogo Reporting Corporation 1- ver .>
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42 1 Now NRC is going to review all this and it is 2 probably going to come out bhat NRC is going require 3 things more.
4 MR. WYLIE: And the NRC might suggest some things.
5 DR. SIESS: But the way it is stated, it says 6 you go otit and do it and we think you are going to find 7 some things you might want to fix. You come back and tell 8 us what you found. It is voluntary.
9 And we are going to review it. And if we find 10 sometiring that you didn't find or we think that so: : thing 11 is more important, if it docsn't meet the regulations, 12 we are going to require it.
lllll 13 If it does meet the regulations but it provides 14 a substantial increase in safety, we will do a 50.109 15 backfit analysis and see whether we can require it on 16 a cost-beneficial basis.
17 MR.WYLIE: And the third thing, the NRC says 18 we might even write a new regulation to make you do it 19 if it is ;o.
20 DR. SIE3S: If you find something that is generic 21 enough, we won't even do the backfit. We will make a new 22 ,
regulation.
23 R. WYLIE: Yes.
24 DR. SIESS: But again, once those things are g
25 imposed as requiremer ts, or once they are volunteered by Heritage Roporting Corporation (mm.
43 1 the licensee, they could then be handled within the ISAP 2 or within an integrated schedule.
3 DR. REMICK: Chet, I think that's what Melanie 4 is trying to say.
5 DR. SIESS: Let's face it. They could be 6 handled within an integrated schedule. It would be 7 extremely interesting if the IPE showed up an outlier 8 of significant vulnerability, and tsase are presumed to 9 be synonymous, that didn't end up as a high priority under 10 ISAP.
11 (Laughs) 12 That would be an interesting phenomenon. But lll l 13 I think that anything, oace it is a requirement or once 14 it is a fix, wnether the licensee calls it an improvement 15 or the NRC calls it a requirement , that then is looked at 16 and scheduled together.
17 That could be done under the integrated scheduled 18 because the only difference between that an ISAP is that 19 you have the PRA as a basis for altering things, you 20 see.
21 DR. REMICK: Not only altering but perhaps l
22 dropping.
23 DR. SIESS: And perhaps dropping.
'g 24 So I think you are making a more intricate 25 connection between the two. I think a lot of people Horitago Roporting Corporuflon unj u. au
44 g thought that IPE was the same as ISAP. I don't think you h should foster that at all.
2 3 MR. WYLIE: Could I? I think you've made the 4 distinction. And when Melanie says that ISAP might also--
3 the process of reviewing of PRA under ISAP might also 6 reveal new items, then you are blurring the distinction 7 between the two.
8 DR. SIESS: I think so.
9 MR. NYLIE: IPE is not just devoted to severe 10 accident sequences. But IPE is going to identify whatever
- j i it identifies. So you can't really make the severe 12 accident versus non-severe accident distinction.
13 I mean the distinction as I see it is strictly llh 34 between old stuff and new stuff identified by PRA. ISAP II 15 is old stuff, using the PRA to evaluate. IPE is using 16 the PRA to identify new stuff.
17 Now there is another distinction in that you 18 are for some reason using only a Level ~ PRA in ISAP but 39 that doesn't make any particular sense. There is no real 20 logic to it.
21 DR. SIESS: Well, you can use a --you can either 22 do a Level I with a back-end containment study or you 23 use a II or III.
MR. WYLIE: In ISAP?
W 24 25 l1l DR. SIESS: Oh no, i
Heritogo Reporting Corpoiotion I im3u..u.
J
45 1 t1R. WYLIE: I'm sorry.
2 MR. KELLY : Perhaps I can explain what Melanie 3 was talking about before. Because there is a difference 4 l between how the staff treats a PRA that is performed under 5 ipa and a PRA that is performed under ISAP.
6 PRAs that are performed under IPE were 7 anticipating approximittely a six-man month effort on 8 the staff's part for review of that PRA.
9 If we have a PRA performed under ISAP, we 10 anticipate a much longer and a more detailed review 11 because now we are talking about looking to resolve 12 regulatory licensing issues with the PRA.
% 13 And we want to have more confidence in that 14 case that we've really got--make sure that there aren't i
15 holes,tbat there aren't significant problems w th the I
16 i PRA.
l}
17 DR. SIESS: You will be doing a lot more on 18 the front-end.
19 MR. KELLY: That's correct.
i 20 ! DR. SIESS: You will be doing more sequences on 21 the front-end because you will be doing D3E sequences 22 on the front-end where the IPE front-end PnA is aimed 23 ' primarily at severe accident initiators.
24 MR. KELLY: It is not so much the PRA itself 25 h is going to be looking at different sequences but it is that i
Heritogo Reporting Corporation uu> u. au
46 b
1 the PRA --when we review the PRA, we are going to review l
2 ; it in more depth. We want to have a better feeling that the 3 quality and the depth of the work itself is there.
I 4 I DR. SIESS: So now what have we got--go ahead.
5 MR. WYLIEs Yes I don't really--this distinction t
6 ! between severe accident and something else really I think I
7 is a poor distinction.
8 I mean the only thing we care about are severe 9 accidents. The only reason I care about a sequenca at 10 all is that it might lead to a severe accident. That is 11 the only concern there is. That is the only basiness the
- 2 URC has.
13 DR. SIESS: That's true, what you are interested lll 14 in. But I don't think it is true of what the NRC is 15 interested in because there are an awful lot of things 16 that are out there as requirements that are intended to 17 bring something in line with the regulations and not--
18 MR. WYLIE: But this whole ISAP process is to 19 put--
20 DR. SIESS: I know.
21 MR. WYLIE: --regulatory requirements, to look 22 at them from a risk perspective and make some judgments i
23 about them from a risk perspective.
24 And from a risk perspective, the only thing 25 that counts is a severe accident.
Heritogo Reporting Corporation o.n u.
47 1 DR. SIESS: And it's going to be extremely 2 traumatic if there are a lot of those requirements that are 3 not imposed with that kind of risk perspective in mind.
4 And once they are interpreted in that fashion, 5 some of them are going to go away and some reviewers are 6 going to be awfully unhappy.
7 The opoint he was trying to make was as far as the 8 licensee is concerned, the PRA he does for IPE will not 9 necessarily satisfy their requirement of a PRA for ISAP.
10 MS. MILLER: No.
11 MR. KELLY: No. It is the same PRA. It is just 12 that when the staff goes to review the PRA that's done for lllh 13 ISAP, we would want to--we are going to spend more man, 14 more person-months or more FTE reviewing that PRA than 15 we would under IPE.
16 MR. WYLIE: That's because they are more l 17 interested in regulations than in safety. That is what it 18 sounds like.
19 DR. SIESS: And that means the licensee is going 20 to have some more questions and go back and do more 21 things--
22 MR. KELLY: That's right, because he is getting 23 more benefits out of it.
24 DR. SIESS: Well that, you will have to convince g
25 ! him. I am convinced that there are benefits in having a l
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48 I good PRA and a maintained PRA. Clearly the licensees 2
are not all convinced with that.
3 Most of thosa that have done it are sold on it.
4 A lot of them aren't sold on it. But, ISAP will require a
! 5 PRA and it may end up costing more than the PRA he has done 6
for IPE.
7 Because there is nothing in the IPE that 8 IPE is a one-shot process.
requires his PRA be maintained.
Once he is done, he is done.
10 ISAP Is going to require a maintained PRA which 11 means people on his staff, man-hours and man-years and 12 whatever, and constant interplay with the staff.
I3 So that is one of the costs to the licensee.
I4 Except for that, everything else in ISAP is a potential 15 benefit to the licensee.
16 If ha has only got three outstanding items 17 now, he may not see the benefit. If he thinks he is 38 not going to get 20 more next year, he may not see the 19 benefit.
20 Well, once he sees une IPE generic MR. WYLIE:
21 letter he ought to be able to see the benefits.
22 DR. SIESS: Well, I'm not sure frankly.
23 (Laughs) 24 Because IPE is a one-shot thing. It is an 25 expensive thing.
l i
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49 I MR. KELLY: IPE is one-shot in the sense that 2 you do not require the utility to update their PRA year 3 after year.
4 DR. SIESS: The staff told us yesterday that once 5 the IPE is finished it is finished.
6 MR. KELLY: That's right. But the accident 7 management program will be an ongoing thing.
8 DR. SIESS: That's an ongoing thing. That is 9 something else. But my point is that if I am looking at 10 this from a licensee's point of view, I've got to invest 11 in the PRA and commit to keeping it up and everything else 12 is a benefit.
lllll 13 And I can see that somebody that's got a lot 14 of items on them--I don't know. Does Northeast Nuclear 15 have a lot of items on that plant?
16 MR. KELLY: They have two plants that went
! 17 through SEP, cleaned them up.
1 18 MR. TIIOMAS : There's still a lot of issues wrapped 19 up in the SEP, a lot of carryovers. They have relatively 20 quite a few items.
21 DR. SIESS: The difference to me is very clear 22 }
and I don't think, looking at the letters that came in,
'l 23 !P maybe they hadn't seen the IPE generic letter. I'm sure 24 they haven't. I am not sure they will know any more.
I 25 (Laughter) l!
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I 50 1 MR. MICHAELSON: Question: Does the ISAP PRA 2 require external events?
3 MS. MILLER: No.
4 MR. MICHAELSON: They haven't yet looked at 5 external events? But the IPE will require external 6 events.
7 MR. THOt1AS : The IPE will require external 8 events eventually to be dealt with.
9 MR. MICHAELSON: That's what I thought.
10 DR. SIESS: Well, if the ISAP doesn't require 11 external events, you've got a number of seismic issues 12 out there that couldn't be address with ISAP.
There is a number of lllh 13 MR. MICHAELSON: Yes.
14 other issues that can't be addressed by ISAP.
15 MR. KELLY: Although we've said in ISAP that 16 the only things that a utility has to address in joining 17 ISAP are those things which are currently on their regulatory 18 or licensing plate.
19 There is nothing that prevents them from taking 20 i'
advantage of the ISAP process and adding things like 21 l seismic, fire or other concerns that they might have 22 into the program.
23 DR. SIESS: But it's not a requirement.
24 MR. WYLIE: If they have the PRA to support it.
DR. SIESS: And every requirement does not have 25 Heritage Reporting Corporation
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51 1 to be put into ISAP.
2 If they've got a seismic requirement that they 3 don't want to do a PRA to argue about it, they just go 4 ahead and do it on whatever schedule they had to bagin 5 with.
6 MR. THOMAS: That's correct. I also understand 7 that. As far as the IPE external event, part of the 8 IPE, that may or may not be done through PRA.
9 DR. REMICK: Glenn, what is the significance 10 of pointing out one case the staff reviews more thoroughly 11 than PRA.
12 To me that doesn't add to the factor of ten.
The staff will always come out with roughly a factor of lllll 13 14 ten.
15 But what does it have to do with the PRA 16 itself? A PRA should be a PRA.
17 MR. KELLY: The difference is--there are two 18 differences. The first difference is the staff--again 19 the reason why we are doing the review is that we want 20 to feel better about the PRA because we are actually going 21 to be allowing the licensee to potentially drop somt 22 items that other people might have to do that is on their l
23 regulatory license plate.
24 And also--
Let me pick up on that. That does 25 l DR. SICSS:
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not seem to be consistent with what was done under the 2 SEP.
3 On the SEP, we were looking at plants that would be efficient in relation to the regulations and 5 in some very major ways.
6 And many of those concerns were decided without 7 the benefit of a plant-specific PRA at all; simply on 8
sort of generic PRA-based insights as to significance.
9 It's largely beyond the SEP basis for issues that probably 10 are not comparable.
11 MR. TIIOMAS: But for the two SEP plants that 12 participated in the ISAP pilot program you did look at the I3 issues through the eyes of the PRA as they could be looked I4 at through PRA.
15 The other plants that didn't have DR. SIESS:
16 a PRA, we used the closest thing to it and got some 17 pretty good insights.
38 And 1 thought made some very good decisions.
19 I will admit if you are going to do this--I think the more 20 important thing is it must be an updated PRA. I think 2I that is a major commitment from a licensee.
22 You just can't go out and hire anybody to come 23 in and do a PRA an walk away. Of course that is rot the 24 commitment in the IPE. The commitment in the IPE is that i
25
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I 53 1 Again, I think you've intertwined these more than 2 they need to be.
3 DR. REMICK: Glenn, do you have more clarification 4 for me on what you meant?
5 MR. KELLY: Well, the other thing that I would 6 ask, I think we have come to the last page of our 7 submittal. The staff's recommendution is that because 8 of resource constraints they are not recommending go-ahead 9 of ISAP II at this time.
10 The majority of those resource constraints 11 come from the fact that you feel if we are going to 12 give in essence regulatory relief of the various items lllll 13 that we have to have that assurance that we are doing it in 14 a reasonable manner.
15 And to do that would require additional staff 16 review work of those PRAs.
17 DR. REMICK: But there is no reason for me to 18 feel that an IPE done under ISAP--excuse me--that a PRA 19 done under ISAP or a PRA done under IPE would be any 20 different from the utility standpoint. They could be one 21 and the same.
22 MR. KELLY: That's correct.
23 DR. REMICK: From that standpoint, you are 24 talking depth of review.
l 25 DR. SIESS: But a different depth of review Horitage Reporting Corporation can.a.u.
54 means that there is going to be more work done by the utility.
2 24R . MICHELSON: I think the PRAs are indeed 3
different. There is a certain number of initiators that 4
y u don't have to consider for an ISAP that you will have 5
to consider for an IPE.
6 There will be more events I think in the IPE.
7 MR. THOMAS: And also the other way around.
8 You won't--in the IPE you won't use the PRA to rank 9
issues that you have in ISAP.
10 So the whole objective here to try to boil it g
g down to simple terms is we wanted to not require or to insure that one PRA was enough if the utility chose to go 13 that way.
34 It is true that that one PPA may have some y3 16 additional elements but we didn't want to have to force g the utility to go through and do two totally separate PRAs at two different points in time.
33 That was bad from both the utility's standpoint
,9 and from our own standpoint. That was really the 20 bjective.
21 DR. REMICK: But a thoroughly done PRA should g
satisfy either one.
23 l MR. THOMAS: Exactly.
24 DR. SIESS: With one exception. That is that the 25 Heritogo Roporting Corporation (K?) 424-4444
55 I ISAP PRA must be maintained.
2 MR. MICIIAELSON : And that isn't a minor deal.
3 MR. WYLIE: Well, any utility that does a PRA 4 and doesn't maintain it is crazy. They ought to have 5 their license revoked based on lack of common sense.
6 DR. SIESS: Well, do you want to propose that 7 to the ACRS?
8 MR. WYLIE: Well, you know, that is probably 9 better than some regulations.
10 DR. SIESS: Personally I am not sure I would 11 go as far as you did but I think any utility that doesn't 12 do a PRA in this day and age ought to have his head h 13 investigated.
14 MR. MICilAELSON: It is quite a job to go back 15 and add external events to an ISAP PRA. I mean it is a 16 major undertaking. It is a major undertaking.
17 DR. SIESS: When I say external events, because 18 of the way I think I usually think earthquakes and floods 19 and you are not. You are thinking of pipe breaks, 20 inside containment, which are not external events to 21 me.
22 MR. MICIIAELSON: And there is also a lot of 23 regulatory thinking that hasn't gone into deciding yet 24 how we are going to handle for instance leak before break 25 which we know how to handle for ISAP when it doesn't break.
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56 I But for IPE it may break. The thinking just 2 hasn't been done yet to decide on these things.
3 DR. SIESS: The break has been looked at for 4 seismic.
5 MR. MICHAELSON: I don't want to get into any 6 arguments on it but at the moment if you ask the regulators 7 how they are going to handle it and I think the answer is 8 no, they don't.
9 They have got to think it through now and see 10 what to do next.
11 MR. THOMAS: That's why we are not requiring 12 external events for IPE for the time being.
lllll 13 MR. MICHAELSON: Yes. It is going to be 18 months 14 of thinking to decide just which ones are these we cope 15 with. The same way with fires that burn a little longer 16 than an hour. What do we do with them?
17 We have fairly good reason to believe that fires 18 can indeed burn beyond one hour.
19 DR. SIESS. Tlat is a probability.
20 MR. MICHAELSON: A very substantial probability.
i 21 You will hear about it in another week.
22 MR. WYLIE: Chet, there is just one more comment.
23 I can't agree with what you said that she's unnecessarily 24 entwined or whatever you said these two things, because g
25 they are very, very much related. ANd I agree the Horitago Reporting Corporation annn an l
57 3 dinstinctions have been made I think pretty clearly here.
2 But they are so closely related tha'eI really think that 3 serious consideration ought to be given to combining 4 these programs and make them just one program.
5 DR. SIESS: I don't quite understand. If I look 6 at IPE as a one-shot surge for outliers--
7 MR. WYLIE: Yes, but it isn't that anymore.
8 You heard what they were asking them yesterday. That is not 9 what it is. They are talking about a state-of-the-art 10 PRA.
jj DR. SIESS: Yes, but once you have finished IPE 12 and found your outliers and decided to do something or not lllll 13 do sometning about them, they say you are through.
14 ISAP to me is a way of running the plant, 15 managing the fixes and making the hardware changes and 16 just continue to do that over the next 20 years.
17 MR. WYLIE: But, Chet, the difference is 18 the PRA--let's put aside. You know, I think that all 19 PRAs ought to be full-scope and they ought to be Level III.
20 , And let's say we have the ideal world where all PRAs are 21 Level III and they include state-of-the- art external /
22 internal events bt ause there is really no distinct--the 4
23 P l ant really doesn't know the difference between an 24 f external and--that is just an artifact of history or ll i
L 25 l something.
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58 g So if we did a PRA of that sort on a plant 2
and with the impetus of IPE would identify any new issues 3
that have come out of that PRA, then you take all those 4 and you lump them in or put them on the same list with 5
all the outstanding regulatory issues and you evaluate 6 them with the ISAP style and you've got an ongoing program 7 then of resolving the extended double list of issues.
g I mean I can't see why that just isn't a 9 sensible enough approach to ought at least be considered.
10 DR. SIESS: But let's say that everybody had a ig PRA and ISAP was already in existence. They all had g: schedules worked cut based on all the things that were performed and behind them, and the si ff now comes and lllll 13 g4 says how do we implement the severe accident policy 15 statement that says we think plants are safe enough 16 but there night be some of them out there that have 17 outliers, plant-specific vult.erabilities that put them 1g outside the pail or push them into a category where we 39 would like to fix it.
20 We would say okay, take your PRA, look at your 21 plant and see if you've got any of those outliers.
If you have, put them on the list. Period.
22 i
23 It is a process for resolving issues, not for 24 f discovering issues.
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MR. NYLIC: Well, it's both. In the first, the Heritage Reporting Corporation mn m m.
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I pilot ISAP was both.
2 DR. SIESS: It was both.
l 3 MR. WYLIE: Right. And that is all I am saying. '
4 Make it both and that is IPE.
5 DR. SIESS: Well, the pilot ISAP was 6 voluntary and with both it didn't get many volunteers.
7 Now IPE is required. Now what you are saying is that 8 when you do your IPE and you get an item you want to 9 fix, whether you fix it now or not, the high, medium and 10 low or whatever that you fit into a program like ISAP, 11 now do you apply that.to all the other issues?
12 That is really just adding ISAP to the g 13 resolution of the IPE. One of them is a prvuess to dispose 14 of issues and the other is a way to discover issues.
15 Sure, you could combine them but--
16 MR. WYLIE: But they both require and they 17 both ideally would use as a tool a full-scope, external /
18 internal PRA.
19 DR. SIESS: Yes. But now you've got a three-step 20 The first requires everybody to have a full-scope l program.
21 PRA and maintain it.
22 MR. WYLIE: Or some reasonable approximation.
23 DR. SIESS: Now you can use that for a number 24 of things. One is you could use it for resolving issues.
I 25 I You can use it for a one-shot look to look for the outliers l
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that make you different from the guy across the street.
2 MR. WYLIE: That's right.
3 DR. SIES3: Now some people thought IPE was going 4
to be a way of requiring a PRA and it turns out it isn't.
5 Some of us have looked at ISAP. One of the nice features 6
of that is that it is requiring a PRA. It is only 7
requiring a PRA if you volunteer.
Now since IPE doesn't require a PRA and 9
certainly doesn't require a Level III PBA and it doesn't 10 require a maintained PRA, and since ISAP II is proposed II as a volunteer program, neither one is going to accomplish 12 your objective of everybody having a PRA.
13 That is going to take a ruling.
I That's all right. I say I want to MR. WYLIE:
I' do it differently. That's my point.
16 You would like to DR. SIESS: That's right.
' propose that the NRC promulgate a rule requiring every I8 plant within some period of time to have a Level III state-I' of-the-art PRA and maintain it.
20 MR. WYLIE: I don't know whether it has to be a
- l rule or not.
i i DR. SIESS: I think it has to be a rule.
23 Well, an IPE is going to be a generic MR. WYLIE:
24 letter.
' DR. SIESS: The IPE doesn't require anything. It Heritogo Reporting Corporation
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61 I gives you three choices.
2 MR. WYLIE: Sure. It requires you to do it.
3 I would issue a generic letter that didn't require anything; 4 just gave one choice.
5 (Laughter) 6 DR. SIESS: Maybe a generic letter can do it.
7 MR. WYLIE: I don't have any opinion on that.
8 DR. SIESS: But you see, there are three separate 9 issues. One is having a PRA. One is using it to look 10 for outliers. And the other is using it to audit your 11 business.
12 MR. WYLIE: That's right.
13 DR. SIESS: And to get things done in the proper 14 manner and the most risk-important things done first.
IS MR. THOMAS: If I may share the thought process 16 the staff went through on that very subject. Do you 17 recall last fall when we came down and talked to you 18 about the results of the Haddam Neck and Millstone pilot 19 program.
20 At that time I tnink we shared with you some 21 thinking of what as going into the Commission paper that j.
22 went to the Commission on maybe the fourth or November.
23 At that point--this takes a little bit of issue l
with what Chet said. I don't know of anybody at NRR 24 l 25 who doesn't think what I said was a good program and the Horitogo Reporting Corporation (m) u. ..u 1
62 I way to go.
2 We had thought it was such a good thing. We 3 wanted to combine it with the IPE program as an incentive, 4 as a way to hopefully motivate more people to take the 5 PRA route as opposed to the IDCOR route.
6 So we did at that time and in the Commission paper 7 we recommended the programs be combined. After listening 8 to ACRS and your discussions shortly after we were down 9 here, we wanted to provide as much incentive to the 10 utilities as possible to participate in the ISAP II 11 program.
12 We felt in some utilities' minds that tying lllll 13 the two programs together could be viewed as a 14 disincentive.
15 But what we wanted to do was --we viewed ISAP II 16 more as a process that had we to go back and reinvent 17 the licensing process, was really a good way to do 18 business.
l 19 You've got a lot of insight that you didn't 20 otherwise have when you did things deterministically.
l 1
21 I And given the chance in the future, we may very well l
22 propose to do it this way.
i 23 Nevertheless, we viewed ISAP as a process and i
11 felt that it really would be the most attractive to W 24 [
25 h the utilities to propose it as a separhte program. So that il l
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1 is how we came to where we are now.
2 DR. SIESS: But you weren't successful in 3 selling it to the industry-. They didn't see an advantage 4 to it.
5 And let's face it. You actually have six utilities 6 --you had 31 utilities out of 50-some odd that either 7 said yes cr they might be interested.
8 And somebody--I will blame it on Tom Burley--
9 says that is not a majority.
10 MR. THOMAS: If I may expand on that. It 11 wasn't as simple as that. I don't know if NRR has come 12 down and talked about this fiscal year or next or what g 13 we are doing on the five-year plan, but NRR for the 14 remainder of this fiscal year and the next fiscal year 15 is going to effectively lose 70 people, 16 We have also been asked by the chairman to f(
17 And if you look at the fraction of t prioritize our work.
18 the industry that would benefit, not withstanding the 19 fact that we would like the whole industry to participate 20 in this process, when we look at the fraction of.the h
21 li industry that would benefit and translate into the fraction 22 I that will benefit the NRR, we look at the cost.
23 And we estimated something like 10 or 15 FTE
{
24 per year, l
d 25 p DR. SIESS: A lot of that is in reviewing the 0
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64 1 the PRAs.
2 MR. TIlOMAS: Yes, but it goes beyond the IPE 3 review as Glenn described. We just couldn't justify it.
4 It came down real low on the priority.
5 DR. SIESS: Well, the benefits to NRC on the 6 voluntary proposed ISAP aren't that great in terms of 7 manpower and management resources.
8 AR. TIIOMAS : There is an upfront cost we would 9
recover with time.
10 DR. SIESS: So my feeling is you didn't convince 11 the industry that there was enough benefits and NRC 12 looked at it and said you know, if they don't want it, 13 it really benefits them more than it does us, so why go 14 ahead with it.
15 I think that is the position we are in.
16 MR. TIlOMAS: I just wanted to make clear. I don't 17 know of a single person at NRR who doesn't think ISAP 18 was the way to go.
19 I just wanted to nake that recorded in the 20 record.
21 i DR. SIESS: Not a single person?
22 MR. TIIOMAS : Yes.
23 1 DR. SIESS- If we went ISAP as a way of life, 24 as you say, that is quite a change.
l 25 MR. T!!OMAS : Yes.
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DR. SIESS: And I felt from the beginning it 2
was going to require philosophical changes all the way down the line, from the managers down to the reviewers.
3 4
Just like SEP did. But SEP was on a small scale.
5 Were you in SEP?
6 MR. THOMAS: I was in the ISAP pilot program.
7 DR. SIESS: Then you weren't in the original 8 SEP.
9 MR. THOMAS: Glenn was.
DR. SIESS: The project manager had to negotiate 10 gg with the reviewers.
12 MR. THOMAS: Right.
13 DR. SIESS: And make them think PRA so that g4 ocople think PRA a lot more now.
15 MR. THOMAS: This probably won't become a way of doing business until after the PRA is required. It is 16 ,
17 an evolutionary thing, surely, gg ,
DR. SIESS: Why was Northeast Nuclear so I
g9 l enthusiastic about this?
20 MR. THOMAS: In my opinion, and this is just my 21 Personal opinion, Northeast was developing a very strong 22 PRA staff that would--anyway, whether or not there was 23 the ISAP pilot program or not, they were convinced of the b benefits of PRA.
25 h They were developing a good staff to look at all l!
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66 g their plants in terms of PRAs. And they were able to k 2 devote more resources to that effort and defer actions 3 on issues that were on their plate by participating in 4 j the program to legitimatize that process.
5 DR. SIESS: Now they have got four plants. They 6 operate a big engineering staff. TVA is one. They have 7 got a big engineering staff. Commonwealth is sort of 8 so-so.
9 Duke decided no. What do you think about an 10 outfit like SPUD (ph), Omaha Public, outfit with one 11 600 megawatt plant. Do you think they would ever develop 12 a PRA group within their company to manage their 13 business?
14 MR. THOMAS: My personal opinion for a single unit 15 utility is not unless they had to. Generally. There may 16 be some exceptions.
I 17 DR. SIESS: I remember Consumers Power,which 18 ; at that time only had Palisades and Big Rock, did a i
19 l PRA, participate in it with their own people, and were very 20 happy about it.
l I
21 l Did they ever do one on Palisades?
l 22 h MR. KELLY: I believe there is an unpublished 23 PRA on Palisades.
24 DR. SIESS: Well, there are a lot of unpublished 0
25 h ones out there.
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1 (Laughter) 2 Sonehow we are back to the subject of PRAs.
3 Let's take a few minutes break and let Melanie 4 reorient herself and we will let her finish her 5 presentation.
6 (Whereupon, a brief recess was taken 7 at this time) 8 If 9
10 (Continued on next page) 11 12 13 14 15 86 17 18 19 20 ,
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68 1 DR. SIESS: Let's proceed. I see Melanie abandoned 2 the last slide. We worked her to death.
3 MS. MILLER: Wasn't that my cue. Okay.
4 The next relationship that I wanted to talk about 5 is that between ISAP II and the Integrated Schedules Policy.
6 The Policy itself on Integrated Schedules was issued in pro-7 posed form in the Federal Register in November of '87. We 8 have been holding off issuing a final Policy on Integrated 9 Schedules pending the outcome of the ISAP II program. The 10 basic reason being that both involve integrated schedules 11 and are very similar. The' differences being, of course, 12 that ISAP II is PRA based providing a stronger technical gg ll 13 justification for any action resulting from ISAP II. And 14 also ISAP II allows a dropping of issues and the moving of 15 issues to lower priority.
16 Now, what we would be thinking as far as I guess 17 combining the two programs or dealing with both of them is 18 that if ISAP II were implemented, we would opt for having 19 the Integrated Schedule Policy being subsumed as part of 20 the ISAP II program. So there would not be two separate and 21 distinct programo, each having integrated schedules.
r~ 22 DR. SIESS: This would be an incentive for people
( ;
23 to go into ISAP. If they wanted--
24 MS. MILLER: It could be, yes, if they wanted an g
23 integrated schedule.
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i Now, for those plants that currently have integrated 2 schedules or are currently working with the utility to develop 3 integrated schedules, this recommendation would not affect K_ 4 them. It would only apply to new utilities who are interested 5 in obtaining integrated schedules. We would recommend that 6 they go ISAP.
7 DR. SIESS: But with the integrated schedule now 8 the idea was if we did get together and assign priorities.
9 MS. MILLER: Yes.
l0 DR. SIESS: The priorities were based on what 11 judgement?
12 MS. MILLER: No. The utility would have a rigorous process where you'd have, you know, ranking each issue on lllh 13 34 certain various criteria and they'd use that process.
15 DR. SIESS: But the ranking wasn't necessarily PRA 16 type ranking?
17 MS. MILLER: No. Most likely not.
18 DR. SIESS: But the integrated schedule did allow 39 them to work in their fixes along with the--
20 MS. MILLER: Yes.
23 DR. SIESS: Plant improvements along with the NRC f
, 22 requirements.
V MS. MILLER: Right.
23 24 DR. SIESS: But if a requirement--some requirements g
25 must have deadlines attached to them. That could be changed--
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70 i MR. THOMAS: Without exception.
2 DR. SIESS: Without exemption.
3 MR. THOMAS: If it were for a deadline imposed by 4 a regulation.
5 DR. SIESS: Yes, okay. How many plants have inte-6 grated schedules now, do you know?
7 MS. MII LER: With licensed conditions, there are 8 four that I'm aware of.
9 DR. SIESS: Four?
10 MS, MILLER: our. Turkey Point, Big Rock Point, 11 Duane Arnold, and Pilgrim.
12 DR. SIESS: What about Southern Cal Edison?
MS. F'LLER: No.
lll h 13 14 DR. SIESS: Well, they mentioned--in their letter 15 they talked about their integrated schedule--
16 MS, MILLER: Mayce tha*_'s one that they use in-17 ternally without NRC involvement.
18 DR. SIESS: No. Let me find it.
19 !!S . MILLER: Or maybe that's one I'm not aware of.
20 l DR. SIESS: "Concerned about the impact of th.is l
'i ! p::ogram on Irtegrated implementation Schedule"--all capita- >
I I
,. ;i !l e nethodology already licensed."
l MS. MILLER. Already licensed?
- DR. SIESS: That's what they say.
25 MS. MILLER: I don t know what they mean.
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'l DR. SlESS: They did use "Integrated Implementation O 2 Schedule" methodology already licensed.
3 Anyuay--now, that did require a license amendment
()
4 on the integrated schedule, didn't it?
5 MS. MILLER: Yes. I believe though, at least the i 6 we had'done it before the proposed Policy Statement. I be-7 lieve the proposed Policy Statement talks abcut a means of 8 utilities having integrated schedules without a license 9 condition.
10 MR. 'fHOMAS : As a mattar of: fact, didn't the Commis-11 sion instruct us to take that out and not--somebody instructed ,
12 'us to take out'the requirement that there'be'a license condi-13 tion.
4 14 DR. SIESS:- For the integrated schedule?
15 MR. THOMAS: Right.
16 DR. SIESS: So you'd grandfather the existing inte-
- 17 grated schedule plants unless they wanted to come into ISAP?
18 MS. MILLER: T14at's right. ;
19 In fact, Duane Arnold, for . instance, is one of the 20 plant --
l 21 1 DR. SIESS: It's intercsting that that allowed some .
i 22 assignment of priorities, didn't require a PRA, didn't re-23 quire a licensa amendment, but still got only co.upanies into
{
! r
!- 24 it. It's interesting. And actually Big Rock was an SEP l
25 plant. An integrated safety evaluation.
Heritage Reporting Corporation (MI) M4000
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72 1 MR. THOMAS: I'm sure the majority of the elements 2 are--
3 DR. SIESS: Sure. Okay.
4 MS. MILLER: Okay.
5 Now, as far as the specific results to Generic 6 Letter 88-02, there were three categories to the first ques-7 tion which was, "Are you interested in participating in ISAP 8 II?"
9 Now, it's important to note that the staff put a 10 disclaimer on the the questionnaire to the effect that we are Il not taking these responses as commitments. In other words, 12 we are not going to hold you to participating if you answer llll 13 yes or, you know, likewise. There's going to be an additional 14 information exchange and we'll~be looking for your definite 15 answer at some future date.
16 So therefore, this is strictly a first cut at a 17 response. And when looking at the three categories, we see 18 six utilities that were definitely interested. Twenty-nine 19 that were possibly interested. And then eighteen that had 20 said no.
21 Now, in looking at it a little bit differently, c~x 22 that is, in grouping it into two groups, that is, the "no" l ! )
f 23 category and the "possibly" and "yes" categories, we come up 1
24 with a slightly different analysis of the data.
gg 25 The "no" group by and large were utilities that Heritage Reporting Corporation m su a
s 73 I were definitely no. They were adamant in their expression 2 of not being interested in ISAP II.
3 on the other hand, the "porsibly" and the "yes" 4 category, there was a little bit more overlap. It seemed 5 that in the "possibly" category there was about eight to ten 6 or so who were raising some questions but in general seemed 7 to be agreeable and seemed to be impressed with the presenta-8 tion of the program in the Generic Letter. And they are the 9 utilities that would most benefit from an industry NRC seminar H) where we'd be able to go into more detail about the program 11 and answer some explicit questions and may convince those 12 utilities that ISAP II is c viable option for them.
lllh 13 Now, as far as some of the specific comments that 14 we received, by and large all utilities that answered either 15 "possibly" or "yes" were interested in attending an NRC-16 industry seminar. So in that sense, I guess that's an opti-17 mistic look at the data. The fact that those utilities were 18 not closed to hearing more about the program.
19 There were some concerns that were raised by the 20 utilities that responded to the Generic Lettel The first 21 one wc talked abo"t, the license amendment. And I think we've 7s 22 made an ef fort to factor in comnients related to the license
/
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23 amendment as well as other comments. And on a license amend- ,
2.? ment case, we have opted to drop it.
25 Again, costs. What is ir going to cost me, 'he Heritage Reporting Corporation im> us a
n 74 I l
I utility, to implement this program? What are going to be the tI)
2 people requirements in order to start it up and keep it main-l 3 tained?
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's 4 There was some concern about the fact that getting i
j 5 involved with both ISAP II and initiating the IPE that there 6 would not be enough utility resources to accomplish both 7 in the same time frame.
8 Another common comment which came up for concern l
9 and question, if you will, is what exactly is the NRC going 10 to be reviewing? How detailed is the NRC review process going 3 11 to be and how is it going to work, the interaction between 12 NRC and the utility? And I tilink this is a key point in jh 13 something that the NRC would need to focus on if we would ever 14 implement ISAP II or a program like it. And that is to have 15 a strict implementation process to make sura that we really 16 are accomplishing this program in the twenty-four month or so 17 time frame that we start out with. You know, so that the 18 conceptualization transfer into implementation doesn't fall 19 apart. But that we really do have a handle on the program 20 in order that we can give comforting answers to the utilities 21 at this point in time.
i
- 22 The next item has to do with the proposed timetable
(_)s Where we gave a 23 that was included in the Generic Letter.
i tentati're schedule for the process taking about fifty-four 24 l 25 weeks. That fifty-four-week time trame referred to the coint Heritage Reporting Corporation (242) M64884
M 75 1 after the initial PRA acceptability has been established.
t 'l 2 What a lot of utilities were indicating was that that schedule 3 was too optimistic. So that is something that if ISAP II were 4 implemented, we would focus on a little bit more to see if we 5 could refine the schedule and maybe elongate it a little bit 6 and I think looking at it ourselves and proposing a twenty-7 four-month time frame, we nai come to that conclusion as 8 well.
9 DR. GIESS: That ties back into the cost of re-10 source requirements.
13 MS. MILLER: You are absolutely right. Absolutely 12 right.
DR. SIESS: It's all related.
llllh 13 MS. MILLER: Additionally we had questions and l 14 15 concerns about the duplication of effort involved in ISAP II 16 c.nd IPE. And that would be something--we've been trying to 17 alleviate that and trying to make sure that there is not a 18 lot of duplication of effort but rather that the two programa 19 are compatible, but as program details will be further deve-20 loped, that's something that we would fccus on.
21 The third bullet from the bottom about utility
~
22 initiative, I guess I think--we tried to explain that very i
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l 23 . Well in the Generic Letter that utility initiative would receive the same evaluation and go through the same ranking 24 l 25 process as all other items. But again, this is a case where Heritage Reporting Corporation i mm I
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4 76 1 I think utilities definitely need to be assured that their 2 items that they're interested in would not be given short 3 shift.
x 4 DR. SIESS: ' hey don't trust you, right?
$ MS. MILLER: Exactly.
6 DR. SIESS: Not without reason.
7 MS. MILLER: Right.
8 One utility in particular asked about the SEP progran 9 and the issues resulted from that program, and that was Nia-10 gara Mohawk and Nine Mile Point Unit 1. They were expressly 11 interested in including the SEP issues in the ISAP II program.
12 And I guess that was interesting from the standpoint that we ll l 13 looked at it by saying that the SEP issues would not be in-14 cluded in ISAP II. Would not be something the u ilities would 15 have to be considering. It would be a benefit in a sense to 16 those utilities. But here Nine Mile Point--and I suppose to 17 their creAit, wants to take an aggressive position and wants 18 to address those issues on their plant and unfortunately I 19 don't know that we really have the criteria established on 20 how to deal aith these other SEP issues for non-SEP plants, i
21 I
DR. SIESS: That's not unreasonable. Because those 22 issues were arrived at on a PRA-type basis. And if you are 7-\
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23 going to look at the other issues on a PRA basis, those might 24 fall into some pattern. They might go up or they might go 25 down. It didn't seem unreasonable. I didn't understand what Heritcge Reporting Corporation
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,0 77 I they meant, but now that you've explained it--
2 MS. MILLER: Yes. In fact, when I first Isad the 3 response, I didn't understand exactly what they were getting 7
i
'm> 4 at. But I talked to the individual listed as the contact who 5 was able to clarify that response for me.
6 M P. . WYLIE: Could you explain what you mean by 7 SEP issues for non-SEP plants?
8 MS. MILLER: Yes, In other words, in the SEP Pro-9 gram there were 137 different issues which were evaluated to 10 determine which ones were the most sifety significant and 11 which ones those ten SEP plants would have to make modifica-12 tion in order to upgrade and meet current licensing standards.
l jlllh 13 At least at that time frame in the late seventies.
14 And from that 137, the review boiled down to twenty-15 seven key issues or lessons learned that came out of the 16 SEP Program. Those issues were the ones that had to be imple-17 mented and theoretically need to be applied to non-SEP plants.
18 But the Commission hasn't taken a position on what i
19 to do with those lessons learned in non-SEP plants.
20 MR. WYLIE: All non-SEP plants or you mean just 21 older plants that weren't quite as old--
~s 22 DR. SIESS: No. Let me try.
f I vs 23 MS. MILLER: Older plants, right.
24 i
DR. SIESS: When they finished up with SEP--you 25 know, in SEP we started with all the issues and then Phase I Heritage Reporting Corporation
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78 I boiled them down to 137 I guess and the nine or ten or what-2 ever it was SEP plants, those issues were looked at.
3 When SEP was finished, and of course SEP was not 4 intended to be just ten plants. It was supposed to be a con-5 tinuing process. We do these ten and then we'll take ten 6 more and ten more and ten more.
7 Dave Okrent used to talk about the ten-year review, 8 you know. Well, when they finished with SEP, they said, 9 "After we've looked at these old plants, there were only 10 thirty-some odd issucs that turned out to be really risk 11 significant from the PRAs. The next round we'll only look 12 at those issues." Well, there never was a next round of lllll 13 SEP. The next round of SEP got converted to ISAP. And those 14 were the issues that were considered under the extension of 15 SEP. And then ISAP got converted to a voluntary program 16 rather than a required program.
17 But that's what she meant by applying them to the 18 non-SEP plants.
19 MR. WYLIE: So the Millstone and Haddan Neck did in 20 their ISP program they did consider those--
21 DR. SIESS: The Millstone 2 and Haddan Neck, 137 22 issues were considered.
I) 23 DR. WYLIE: So presumedly as you went through blocks 24 l of history--I mean kinds of OLs or cps or something, you'd 23 get to the point where the most modern plants, there weren't Heritage Reporting Corporotion
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j' 79 I any SEP issues left.
2 MS. MILLER: Right.
3 MR. WYLIE: --the process had gone out of them.
/\
-' 4 DR. SIESS: But even of the old plants, when they 5 looked at nine or ten plants, those 137 issues went away on 6 all of them, on a risk basis. And only these had to be 7 finally considered in the Integrated Safety Assessment Report.
8 But Millstone II and III--no, the continuing ISAP--I don't 9 want to get into that, because they just went into the ISAP 10 for continuing process.
11 MR. WYLIE: That's good enough fcr me. Thank you.
12 DR. SIESS: But that's what she meant by the non-SEPs. If we'd gone on with a continuing SEP, it was going
)lllh 13 14 to be boiled down to thirty-seven issues.
15 MS. MILLER: Right. Twenty-seven.
16 MR. WYLIE: But where in catch-up going to be 17 played on those, if it isn't under this program?
18 MS. MILLER: Good question.
19 MR. THOMAS: The staff still owes the Commission 20 an ar.swer on that. And we thought long and hard about it.
21 Presumably, as you pointed out, there will be a--if you look
- 22 at the importance of those twenty-seven issues, presumably 23 looking at the purpose of the SEP program, which is to see 24 how the criteria thac were imposed on a plant at the time gg 25 that it was licensed compared to current licensing criteria Heritage Reporting Corporation (set) 62S4444 i
g 80 I you would expect to see the largest deviation for the oldest 2 plants. Ts you move towards your more modern plants, like 3 one licensed yesterday, presumably there would be no deviation m
u- 4 from current requirements.
5 So the SEP program really looked at ten of the 6 ol/.est plants. There might be one on either end of the ten 7 wt looked at.
8 The staff has pretty much qualitatively made the 9 judgement that we would never puss the cost benefit test if to we tried to impose a requirement on the remainder of the 11 plants to look at.
12 DR. SIESS: That was supposed to be Phase III, 13 wasn't it?
14 MR. THOMAS: Exactly, exactly.
15 DR. SIESS: Phase I was getting the issues down to 16 127. Phase II was the nine or ten plants. I forget. We 17 dropped one. And Phase III was the next step. And Phase III 18 eventually got replaced--well, it got dropped. Let's face it.
19 MR. WYLIE: Okay. So you've really made tr.e risk 20 prospective judgement that it's not necessary to continue 21 with that program?
-- 22 MR. THOMAS: It's a judgement. It's a purely quali-
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~j 23 tative guess. But that would be our recommendation to the 24 Commission.
25 j MR. WYLIE: Okay.
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l 81 MS. MILLER: And then the last bullet just has to 2 do with the uncertainty about the IPE Generic Letter and what 3 it will hold fcr utilities. What they will be expected to do.
,, And how after assessing the IPE Generic Letter requirements how that would relate to ISAP II, 5
6 There were some other areas that I wouldn't cate-7 gorize quite as concerns, but things that utilities felt they g needed addition:.1 on in order to adequately assess ISAP II 9 and whether they should participate. Things like the inter-10 f ce between ISAP and IPE, as well as between ISAP and the 33 integrated s';hedules. You know, how would procedural changes 12 be made to the schedule themselves. And I think a lot of these things just reflect a need for additional detail. A 13 y level of detail that we had not established at the time the 15 H Generic Letter was issued. And quite honestly, that we pro-d 16 bably haven't established as of yet pencling final disposition 37 of the program. We were anticipating finali::ing the very low-gg level detail of the program after we had heard back from the i,
Commission.
20 i So a lot of these questions I can't answer just yet.
21
- Another question had to do with what is the magni-22 tude of generic issues that are going to be resolved in the
( ) ll
,3 l future? How many new items would I as a utility have to deal i
I with on my specific plant in order to help them gauge the 34 9 -
benefits of prioritizing and using an overall integrated 25 Heritage Reporting Corporation m u.
th 82 I schedule.
2 DR. CIE3S: They didn't expect an answer to that, 3 did they?
4 MS. MILLER: I guess they expected mavbe a range.
5 I guess there was also some skepticism as far as 6 how they'd be able to use their PRA in other ways. What might 7 be some of the other benefits that a utility would gain by 8 applying a PRA to such things as maintenance surveillance 9 intervals, et cetera. So they wanted exact examples of how to the staff would propose these PRAs to be used, 11 In addition, there was a request for additional 12 information on how ISAP might relate to plant life extension ll k 13 requests and plant aging issues, as well as the regional in-14 spection items which Dr. Siess had brought up a little bit i
15 carlier.
16 We had several utilities that suggested that in-l 17 spection items that result from, you know, regional inspec-l 18 tions or resident inspections, that require a lot of resources
, 19 or utility time to correct, that those things also be fac-20 tored into ISAP, included in the overall integrated schedule.
I 21 And this is something that we were entertaining l
22 and at least for those items of significant magnitude to see 23 if there would be some means that we could include them in 24 ISAP II-25 l Some of the regional inspection items that result i
Heritage Reporting Corporation imi m m.
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f 83
} I are very insignificant as far as utility resources and time 1
2 and those would not be the sort of things that we would want 3 to include in ISAP II. So if we would do it, we would have 4 to work out some distinction between the two and how they 5 would exactly be included.
6 There was also some question about the ranking 7 process. You know, exactly what sort of flexibility would 8 a utility have? Explain to us in more detail what t5e staff 9 guid31ines would be for establishing a ranking process, et 10 cetera. How would the backfit rule be used in various identi-11 fying issues?
12 DR. SIESS: How does that question come up? I (llh 13 mean once a requirement has been imposed on them, the backfit 14 decision has already been made.
15 MS. MILLER: I think they were referring to new 16 items that a PRA might turn uo.
17 DR. SIESS: Oh.
MR. THOMAS: That's correct.
19 DR. SIESS: But that's sort of out of the picture.
20 I don't see anything in that. Go ahead.
21 MS. MILLER: And then the last request for addi-l 3 22 ! tional information as a general category apply to--you know,
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23 we need a better explanation, a better understanding, of what 24 benefits would accrue to util.ities that participate in ISAP 25 II.
I
! Heritage Reporting Corporation l < =3 u. l 1
\l 84 1 DR. SIESS: If all the utilities had a PRA now, 2 how many of these concerns do you think would have been 3 raised? Some of them would have gone away, wouldn't they?
4 MS. MILLER: Did you mean the--
5 DR. SIESS: The resources--
6 MS. MILLER: Well, there are so many questions about 7 the interfaces with the other programs. You know, the modify-8 ing schedule, the procedural aspect of ISAP II, there wculd 9 still be that question. The things that might go away are lo how can we better use our PRA in other areas? I guess a small b number of this list would go away.
12 As far as the recommendation, I talked about that gglll 13 bcfore I got into the detailed presentation, and we also spoke about it in the middle of the presentation as far as what 14 l 15 NRR's thinking is. Again, the recommendation is we not pro-16 coed with ISAP II at this time. The primary reasons being 17 the resources. We are estimating approximately one FTE per 18 year per unit to implement ISAP II.
19 Now, for two unit sites that have similar reactors I
20 the PRAs would be very similar or presently identical theore-l 21 tically. And the resource requirements for that situation 22 would be slightly less. But in general, the heavy up front I)^ '
resource constraints and resource requirements in combination 23
(~~; 24 with the first cut of the survey indicating only rix utili-l U #
25 ties at this point that are definitely interested in ISAP II l
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" I based on the information we provided to them, we've decided 2 that our resources are'not best utilized at this point in
'3 time-to support ISAP II.
{'/N x~ 4 DR. SIESS: Resources are high. That's one state-5' . ment.
6 -MS. MILLER: Right.
7 DR. SIESS: Also a number of utilities that ulti-8 mately would participate in the benefits from ISAP did not' 9 represent a majority. I don't think we know who ultimately 10 would participate, il MS. MILLER: That's correct.
12 DR. SIESS: If everybody that expressed an interest ultimately participated, it would be a majority. Because of llllh 13 14 the expenditures and the likely relatively low number of 15 ultimate participants, that is,.,less than a majority, it 16 becomes a lower overall priority.
17 I think that' word ,"ultimate"~ bothers me. Now, 18 suppose that--just pick a number--a majority of the utilities 19 said yes. "We will participate'. Not all next year because L
20 you can't handle that many at one time, But we definitely 21 would like to participate." Balancing that against the re-22 source requirements, what would the outcome be?
l
( If the majority--and I really don't 23 MR. T!!OMAS :
24 want to get quantitative at all. I don't want to quibble be-25 tween 49 and 51 percent, Heritage Reporting Corporotlon
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86 I DR. SIESS: I just took the word out'of here.
- 2. MR. THOMAS: If the majority came back and said they 3 were interested, that would send a message to us that the in-(Vh 4 dustry sees the benefits of ISAP as we do and it_would en-5 courage us that the way we'd like to do business sometime in 6 the future as a fair chance of succeeding now. I think we 7 would make a stronger argument for it. Of course, the ulti-8 mate decision is with the EDO and the Commission.
9 DR. SIESS: Now, a second question. If you had a 10 workshop and got these people there and really answered their il questions, and I don't think you could do it tomorrow, be-12 cause they've got questions you can't answer today-or tomor-13 row. Do you think a lot more would be interested?
14 MS. MILLER: I think we'd have a more significant 15 number than indicated in the survey, yes. But whether that 16 would be stostantial is anybody's guess.
17 DR. SIESS: Right now I think this is a great idea.
18 On the basis of what you have in_ terms of' data and facts, 19 I think that the decision--I don't know your resource situa-20 tion--but I think the decicion is probably justified. But 21 to drop this without going to that workshop, you know, I 22 think is a mistake, because you got replies on a program that 23 in some respects has been changed since you sent out the 24 letter, the license amendment which certainly influenced some 25 ot the "maybes" and maybe some of the "noes." The Heritoge Reporting Corporation
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information~or incorrect information, a change of information.
5 So is it possible that the workshop could go ahead 6
and~ find-out whether the more informed electorate out there 7
might vote differently?
g MS.-MILLER: I suppose _we could.
9 DR. SIESS: Or would it be too much of an expendi-ture of resources to have a workshop?
10 gg_ MR. THOMAS: My own personal views in the matter.
If y u 1 k at the numbers we got back, given the disclaimers 12 that Melanie described, that saying yes, you are interested 13 g4 at this time does not constitute a commitment, we may lose i
15 some of the "yes, we're interested" when it came time to 16 pen the paper and sign a"contract, so to speak, g7 Some of the undecided would~very likely vote a is yes, and son.e o'f the undecided would .very likely vote a no.
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g, We're still talking here in the order of 20 percent of people
! 20 who probably would h, ave lined up at this time.
I The thing that you pointed out earlier that still gg concerns the staff is you've got the Integrated Schedules 22
.o 23 Program right now that doesn't require a PRA. It offers most of the benefits. The only one real benefit it doesn't offer 24 in terms of rewards versus costs--I am not talking about 25 Heritoge Reporting Corporation m.=
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4 88 g safety so much--is we can't drop _an issue. Where you had.the ~f O
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I 3 . turn out. We've.gct a half a dozen of the utilities who.
f p, 4 chose to participate in that. That came as.a real surprise ;
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'to us. [
1 6 DR. SIESS: Suppose you have roughly have the 7
utilities that wanted to go this way? What sort of a problem g .would thic present to NRR in managing half the' utilities on 9 an ISAP basis, just based priorities, and the other half on
.10 the conventional basis? Would this require a split persona-33 lity in your reviewers or project managers?
12 MR. THOMAS: It would certainly require a change. ,
i 13 in thinking. There's no doubt about that on the part of a 14 lot of--
15 DR. SIESS: Is the change in thinking something 16 that has to be done gradually? or must it be done all at 37 once?
a 18 MR. THOMAS: It's my own opinion that it's going to happen at some' point in the, future. And how we get there is 19 i 20 how important it is.
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- g DR. SIESS
- I've always felt that if we had tried 22 . to extend the ASAP process to other plants that it would have l O 23 n
been a real problem. It's almost a different culture.
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MR. THOMAS: That's one of the reasons we had to O
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' OF I Gentlemen, the staff has come up with DR. SIESS:
.h' 2 a considered resolution on the basis of evidence that's been 3 fairly well presented to us. I don't know how many of you i
4 went through the letters. But Melanie certainly summarized 5 'i t quite well.
6 MR. MICHELGON: I'd like to ask a question of the 7 staff. If we proceed with the IPE Program, would that change
' 8 And it does any of the utilities' minds about the ISAP?
9 appear that we're proceeding with the IPE although it isn't to clear yet whether or not a PRA will be used or whether an 11 in-core rule will be used.
12 DR. SIESS: We were told yesterday that about fifty 13 of them definitely will be PRAs.
14 MR. THOMAS: Maybe down the road. I don't think 15 so.
16 MR. MICHELSON: You don't think that would make any 17 difference?
18 MR. THOMAS: Right now, no. I don't believe so.
19 Down the road you can argue, okay,,more and more utilities 20 that have PRAs will see the benefit of the PRAs, will see 21 the light. But also hopefully as we go further and further 22 down the road there will be fewer issues on each utility's 23 plate, and as you get more into the future, so there would 24 less of a need for--
25 MR. MICHELSON: What makes you say that? Has the Heritoge Reporting Corporation m a.=
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r I number of' issues been decreasing, noticeably? .
c.
2 -MR. THOMAS: For some-utilities, yes.. Look at: Duke,
'3 for example.
O V 4 .DR. SIESS:
That's because they've been resolving l
s them or because there hasn't been any new ones?1 6 MR.-THOMAS: Because they've been resolving them.
7 Andlthe number.of new requirements I think has' tailed off.- -
8 MR. MICHELSON: But you don't think--do you think 9 the utilities will.see an advantage in doing an integrated-10 approach to these resolutions through ISAP and IPE and hope-11 fully even as-one kind of package?
12 MR. THOMAS: I would hope the utilities would see
{
13 the safety importance of trying to do the most safety signi-14 ficant things first. But I say that's a hope. I don't see
- 15 any--I don't see enough evidence out there to change to mind.
4 16 MR. MICHELSON: Your conclusion is you don't think ;
i 17 the IPE will change the decisions that we see for ISAP pre-18 sently?
j- 19 DR. SIESS: We've got coming up resolutions of I l I 20 USIA, A-17, A-44, A i45, A-46. Now they know those are out 21 there.
22 MR. THOMAS: Right.
23 DR. SIESS: They don't think they're--
24 MR. THOMAS: Yes, of course they know they are going 25 to get hit with them and from the staff's point of view ISAP >
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91 1 offers a beautiful' opportunity to maybe look at these~in an O 2 integrated way-and maybe' combine'some things.
3 DR. SIESS: I've got a feeling that--what station 4 blackout? 44?
5 MR. THOMAS: Yes.
6 DR. SIESS: If I went into 44 and looked at it 7 in relation to GSI something, something, something, and
~s something, they migh't go away.
9 MR. THOMAS: That's right, yeah. It's a possibility ,
10 Yeah.
Il DR. SIESS: I don't expect A-44 to go away, but I-12 expect fixing A-44 to pick up some other things out there 13 that don't look so important now.
14 MR. MICHELSON: But if they don't go the ISAP 15 route, then they got to go back and reach resolution one at 16 a time without really integrating them into their overall 17 safety picture, is DR. SIESS: They'can integrate them if they want 19 to. They could already and nobody wanted to. Four plants.
20 MR. MICHELSON: 'Well,' yeah.
21 DR. SIESS: But all they could.do would be to 22 schedule them, but they couldn't do, for example, what was 23 done in SEP and say, look, this fix will take care of three 24 or four things. It's an integrated assessment you see.
25 The utilities--somebody pointed out very well. The integrated Heritoge Reporting Corporation
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.1 schedula let's me reorder my priorities. ASAP lets me elimi-
'O. 2 nate some things.
3' MR. THOMAS: I agree with Carl. I am not at all
'( -
4 convinced that if the utility didn't really go out there and 5 do a good job and came in and talked to Tom Burley and said, 6 "Hey, look. I've got A-17,1 A-44, A-45 and so on. And here's 7 my proposed solution to the package." We certainly would a listen to them.
9 MR. MICilELSON: Yes.
'10 MR. THOMAS: ISAP or not, 11 MR. MICHELSON: I'm sure you would. You've taken 12 them to the trough, and if they don't want to drink, I guess you've made the right recommendation as I see it. I don't lllll 13
=
14 see any reason for us to go contrary to--
15 DR. SIESS: And you don't think things would change 16 that much if you had a chance to. talk to people? Now, you've 17 talked to Duke. You met with them, right?
18 MS. MILLER: 'Yes.
19 DR. SIESS: Who else did you meet with?
20 MS. MILLER , We met with Commonwealth Edison. And 21 Commonwealth Edison was in particular, you know, not very 22 interested in ISAP before they met with us. But afterwards, 23 it really got their interest and that's when they came back 24 and said that we are interested in pursuing this with you 25 on Nine and South.
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W u e 93 I DR. SIESS: Where they had PRAs?
.O 2 MS. MILLER: Yes.
3 -DR.-SIESS: So when'they had the PRA they could 4 see advantages?
$~ MS. MILLER: I don't know-if that was their exact f
6 rationale'though. It was a contributing factor.
7 Duke on the other hand was not interested. I think-8 in Duke's case we had too many unanswered questions for them 9 at'this point in time. You know, they expected us to :have
~
10 the-lower level of details of the program worked out in order il to factor it into their up-front decision at this point in 12 time. And we just haven't progressed to that point.
- 13' DR. SIESS: That's not going'to change easily. r 14 either. How are you going to review and how can you handle 15 these things? You are not going to know that either right 16 off the bat. I think you could lay out a review plan and 17 things will still be changing as you go along.
18 MS. MILLER: You are right. But we would hope to 19 minimize that.
20 DR. SIESS: It's as much a state of mind as it is 21 a process. I think there has to be a certain amount 22 of faith on the part of the licensees'and good will on the 23 part of the NRC, and I'm not sure how much faith there is out 24 there.
25 MR MICHELSCN: They got burned before I guess.
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94 l' DR.~;SIESS: They got burned in more ways than one, ,
_k _r;)[.. 12 you know. -Some of them found out that it wasn't good to go
- 3 out and'do things fast. I
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' 4 MR. MICHELSON: Too fast, yeah.
5 DR. SIESS: And this gets them out of that thing 6 and gives them a chance for more considered--
'I 7 MR. MICHELSON: Yeah.
8 DR. SIESS: On the other hand, to be able to defer 9 certain low-priority items--hell, they are deferring high-10 priority items. And getting away with it.
'll Forrest, what's yourcfeeling on it?
12 DR. REMI'CKS My feeling is it'.s unfortunate that there's not inkerest because'I think long term is the way to
~
llllh 13 14 go. It makes a lot of sense, but I certainly don't think--
15 I think the staff has done a credible job in trying to lay L 16 out a program and if there's not much interest, I agree with 17 Carl. I don't think we should try to impose it on them.
18 One issue that does come up and I think that maybe 19 ACRS should bite into this question of do we ever recommend !
20 to the Commission that over some period of time that licensees 21 have full-scope PRAs completed. I think that's something we s 22 were right to consider, and we should.
23 DR. SIESS: But do in not in terms of safety goals 4
24 but in terms of what you learn about the plant and what you
) ,
25 can do.
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. 95 DR. REMICK:^-Right; l'
2 Mr. Ward, are you one of:tha people that is enthu-3 -siastic about ISAP?
n U' 4 MR. WARD:. Well, I think it is a good program in r a word that seemed to be popular yesterday.. I think that the 6 IPEs-should subsume the ISAP. But'I don't know who is sub-7 suming whom?- But just as the IPE supposedly-is' going to 8 subsume the biggest USIA out there,.A-45.
9 DR. SIESS: Or vice versa.
10 MR. WARD: Right. But that's encroaching--I mean 11 that's what I meant' earlier when I said~the IPE certainly 12 isn't devoted only to the so-called obvious severe accident 13 scenarios, because the A-45 isn't concerned with containment 14 performance and that sort of thing. It's only with-- so it 15 seems to me, and I wrote a note to Kerr, the other subcommit-16 tee, in my recommendation coming out of this. I think it's 17 really fortunate that wo've timed these meetings to be back 18- to back, because I think it really clarifies the relation-19 ship.
20 DR. SILSS: What you are proposing is we say some-21 thing about ISAP II, tne approach,.in connection with our 22 comments on IPE?
23 MR. WARD: That's right. And I think that the 24 l programs are complementary. They take a lot of the same 25 resources. And they overlap to a large extent, and they Heritage Reporting Corporation l (102) 4 4
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A/ 4 .Right.
-$' 'MR.-MICHELSON: It would have to now.
6 MR. WARD ' I think we ought to go ahead and bite 7 that bullet.
8 _MR. WYLIE:- Are you promoting this as a recommenda-9 -tion'for a letter about it to the committee?
10 MR.' WARD: Yes, that's what I'm going to do.
11 MR. MICHELSON: You mean promote the requirement 12 for a PRA, is.that what you meant?
lllh 13 DR. SIESS: Well, we tacked an ISAP recommendation 14 on to a Generic Items Letter last month pointing out this 15 departmentalization of USIs and generic issues and IPEs and 16 all of that. And the fact that all of these things are de-17 veloped as requirements and then the implementation ignores 18 the interrelations among them. And we proposed an ISAP II 19 type of implementation' approach there. And even if we de-20 cide not to recommend to the Commission that they ignore Mr.
21 Stollo's recommendation, I sense that we.ought to keep push-
,e ing for this ISAP approach to things hung on to a PRA. And 23 I think if we got PRAs out of everybody this is a logical 24 extension.
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21 -some' changes in the regulatiors. It has been pointed out to i
i 2' me that to drop a requirement, whatever it was, requires an 3 exemption of whatever the order'was, however that requirement B
kl 4 was placed. And if there are five bases for exemptions, four 5 of.them refer to the regulations, and the fifth says "other."
6 And' except for the "other," there's no reference to risk as 7 a basis for the exemption. And "other" requires an . action by 8 the Commission.
~
9 So you see we are again dealing with the fact that 10 ~ we know risk is what we're trying to reduce, but the regula-Il tions do not refer to risk.
12 Now, certainly when a USI or a generic issue was posed on a plant, there was a regulatory analysis which looked llllh 13 14 at risk. It was assigned a priority. There was one when it
- 15 was imposed. But even though it might have been imposed on 16 a risk basis, there's nothing in the regulations that let 17 you deimpose it on a risk basis.
18 And we did mention the fact that a particular item 19 would reduce risk taken by itself, it might not reduce risk 20 considered along with other factors. And that this required I%
21 a more integrated a'pproach, which is what I think ISAP ie.
22 That word "integrated" in it.
23 I hope we can keep plugging at it. I see real 24 problems when making it a general approach in the Commission.
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y 1 managers and.might L require rule changes in order to avoid 4~'): 2. having everything go to the Commission.
- 3. But I. don't know how we can continue to regulate
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- 5. polief. statements which are not codified into the code of l
^
6 federal. regulations. There.is.something confusing the' devil 7 out of the licensees and,the staff in trying to work this 8- multifaceted two-faced operation.
9 Maybe this IPE has'got to be some way of addressing. .l i
-10 it. But you see, they backed into the IPE. They've got to 11 'say, "Do it." You know,.if you are good guys and.if you are 12 worried about your plant, and you find something, you are 13 going to fix it. And then come tell us about it. We're not 14 going to require it. All we're going to do is require that is you ta'ke a look and assume that if you find something you'll 16 fix it, which is probably 90 percent true.
17 MR. WARD: Well, they say that. And we'll look 18 over.your shoulders. And might have some suggestions. Be-19 cause they are asking for a report.
20 DR. SIESS: I know what they are going to do, but 21- I'm talking about what they said.
22 MR. WARD: . Well, they said that.
I 23 DR. SIESS: But again, I said they backed into it.
24 All they are requiring is a look. Right now they haven't l 25 required any more than a look. Now, after you look, they'll Heritoge Reporting Corporation (see) 6mmes
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1 'look,.and if they see something and they can justify a cost f_s 2 benefit, 50.109 or whatever, or a new rule.
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-3 Well, you talked them into that. But again, we j 4 do have-a problem. And I think that as much as I like ISAP' l
5 I've._never figured out how we were going to implement it in 6 this organization without confusing a lot of people.
7 MR. WARD: Well, Cecil said a little while ago that 8 he thought--you_know, you've talking about the risk oriented 9 cultures or something.
10 DR. SIESS: I think it's coming too and I was hoping 11 that this would be the way to get it started. But the argu- l 12 ment against it that was presented in here was that unless 13 there's more people in the industry that is going to benefit j 14 from it, we won't do it. ,
15 MR. WARD: Well, if you really want to use the i 16 benefit from it, that's the only way they can do the IPE.
3 17 DR. SIESS: That's forcing it on them. The other ,
18 approach was saying, okay, if we really want to go this way, d ;
19 ~ and that has to come from a little higher up than you are, 20 then, heck, let's take those six guys that said they wanted f
21 to do it and let's try~it out and see if we can train some t l
22 people to operate this way and then if it works, we'll get 23 more people into it.
24 MR. WARD: That's a good point.
25 DR. SIESS: That approach--let's say that's a !
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5' start somewhere.- You are better.off starting on a small' 1-
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6 scale in changing.the rules and making everybot.y do it. ,
t 7 Charlie.
t 8 MR. WYLIE: Well, I support what Dave said. I l
- 9 think that these programs ought to be integrated as part of 10 -the IPE pursuit of the severe accident policy statement. And 11 I think it's' time to face up to requiring a full scope PRA, ,.
I 12 and they--I think they ought to delay it frankly until they !
include external events in the application.
llllh 13 !
ja ' DR. SIESS: Well, I have a problem with this inte-I 15 gration because what Dave has said here, everybody have a I 16 PRA and the NRC will do it and an ISAP II is a means for im- ,
17 plementing the new requirements. It would also be 6 mears of j 18 implementing existing requirements.
39 MR. WARD: Outstanding existing--
i p 20 DR. SIESS: Now, of course, you are acauming that
.. 21 there will be new requirements out of IPE. If there are some. t 22 If there aren't any, that's zero. 'There should also be a i
(:) basis for implementing any volunteer fixes.
23
! 24 MR. WARD: But ISAP already accommodates that.
25 DR. SIESS: Well, there's two kinds of approaches I (
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101 1 - see. One of them-is;that.- And it has an advantage of being O' 2 brought up--well, what you.are' proposing if it works would
. 3 have'.the advantage of everybody having a PRA and I think ISAP
.O 4 would fall in fairly easily after that happens.
j 5 Tossing ISAP into the IPE I don't guess does any 6 harm. I don't think it does a heck of a lot of-good right 7 there.'
8 The other approach to ISAP alone is to try to tell 9 .the Commissioners that this is the way to go in the future-10 and why not start off on a small scale and see what you can 11 do. I don't know what the competing resources are. Some of l
12 them aJe in IPE l'm sure. I'm sure the committee could look 13 at NRR and decide things that have lower priority than this.
14 But it might decimate the outfit if ten'of us all took a 15 look. We couldn' t agree I'n, sure. That's interfering with 16 their business I guess.
17 MS. MILLER I guess one of the major disadvantages 18 that I see in combining the two problems is that IPE would 19 have this additional excess baggage, if you will, called ISAP 20 which would further hinder our r.bility to get out the Generic 21 Letter and implement'the IPE, I think by keeping them separ-22 ate, you know, we really accomplish the same thing and it's 23 just that their implementation can have slightly different 24 tracks and if one is ahead of the other, you can just fold 25 one into the other when they, you know, come on the same Heritage Reporting Corporation
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1'02 I track without impacting the implementation of each'other.
,. 2 MR. MICHELSON: But when you go to' evaluate the i 3 relative importance of things you found under ISAP and the=
O' 4 things you found under IPE,.you'd better be using the same 5 PRA:and that may help. -You can't put ISAP ahead of it be-6 cause-- ;
7 MR. THOMAS: All that he's'saying'is if you did 8 -ISAP in conjunction--if it's required as part'of IPE, you 9 could slow down IPE. If you are looking at I.Ss for the ;
10 significant outliers, if it's really important to safety, ,
11 you want to identify--- l 12 MR. MICHELSON: I was thinking it might slow down E
, ggllh 13 ISAP because ISAP is going to have to wait eighteen months 14 to' figure out how to handle external events.
15 MR. THOMAS: It will slow down ISAP. f i
16 DR. SIESS: What Dave has got is a proposal here, l 17 it's a back door type of implementation. What he is saying 18 is require PRA for IPE. Then go ahead and do it. Now, any-1
- i, thing that comes out of the IPE integrated with the other t
i M requirements, using an ISAP type approach. Now, that wouldn't :
1 i I
21 really make ISAP as such. If it doesn't agree in a risk-I f 22 related approach on deciding when to do the things that come 23 out of ITE if any. But everybody would now have a P."'..
1 24 They wouldn't have a commitment to a living PRA, but they ;
s 25 would have gotten a big start. And the ISAP approach would i Heritoge Reporting Corporation
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-ffJ 103 l have been introduced.
2 Now, following that by a year or two, to propose 3 an ISAP for everything would be-an entirely different climate. l l
\] 4 And it might be after the IPE offort is over that some re-
5 sources =may flow.
~6 IPE is an entirely different way of doing business.
7- I mean ISAP is. Can be. Initially it won't be that much.
8 But it'll develop. !
9 MR. WARD: I lost you when you said "after that."
10 There isn't anything after that, i
!! DR. SIESS: After IPE? ,
12 MR. WARD: No, you said--what-I'm proposing is 13 that there be--that the IPE process, let's say, require a 14 PRA of overy plant.
15 DR. SIESS: Okay.
16 MR. WARD: That that PRA would be used as it's now ;
17 proposed-in IPE for first the utility to identify and maybe
{
18 the NRC to help them identify anything that's indicated from 19 that PRA that really ought to e find, whether there's a j 20 regulation involved or not. I mean that's the outlier idea, f
21 DR. SIESS: Okay.
- 22 MR. WARD
- Okay. You take that list of zero or one O 23 hundred things and you list along side it all the outstanding l
24 other issues that that plant has. Then using that same PRA i 25 and the ISAP philosophy, you'd prepare a prioritized list and Heritage Reporting Corporot!on m m .= ,
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104-i the implementation schedule and integrate and prioritize the (b 2 things that need to.be done. And that's it. That's every-l i
3 thing. There isn't anything after.that. Unlass something ;
I 4 new happens. .
5 DR. SIESS: Then two years later,-A-17 and:A-44,
-6 A-45, A-46 impose--they would be integrated-in that list if 7 there was an ISAP, but not the way you put it, you see.
8 MR. WARD: No,-that would be my intent, is to keep 9 ISAP everybody would have-- -
10 DR. SIESS: You would start the process with your
!! IPE items, assuming they are--
]l-12 MR. WARD: With the IPE items and the existing-- ;
lllh 13 DR. SIESS: But you would then continue it.
14 MR. WARD: Sure. h t
15 DR. SIESS: Because IPE they say is a one-short .
16 affair.
17 MR. WARD: Well, I'm saying it shouldn't be. Well, 18 maybe IPE is. Maybe this identification of outliers. That's l 19 the thing coming out of the severe accident policy. That 20 might ce a one-shot--
h 21 DR. SIESS: I think that something more important wi ll i
22 coming out of it eventually and that's the accident management ,
i t
MR. MICl!ELSON:
~
23 There's no reason why there can't t
24 be a living PRA. '
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25 DR. SIESS: Except that a living PRA requires an Heritoge Reporting Corporation ;
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=2 resources, which'some utilities have made. *
'3 MR. WARD: The.IPE's Generic Letter d' aft now says ,
4 that that's an'important part of it.
5 DR. SIESS: It says that they'should be involved in 6 doing it, but it doesn't talk about a continuing maintenance
. 7 of it.
8 MR. MICHELSON: They don't talk about being a living 9 PRA.
10 DR. SIESS: You know, the whole ISAP program, once 11 you've made this fix you've r.ow changed the plant. .The risk 12 for the next one is different. Unless it's a living program-- l 13 MR. MICHELSON: You can't fit it in. ;
14 DR. SIESS: It doesn't work, you see. I mean you ;
15 order your priorities on risk and now you've put one in, and 16 now you've changed the whole picture. And only with a living 17 PRA can you do that. So the idea of a living PRA, a continu-18 ing updated PRA has to be in there somewhere.
! i 19 MR. MICHELSON: That's right. {
20 Full scope, external event, and living. Then 21 you've got it forever. As your new problems come up, you i
' fit them into the schedule of things that you're doing and 22 O 23 decide whether to do them. But that's not a small undertaking ,
24 DR. SIESS: No, but it's something that's been l
O done piecemeal now for about fifteen years. And it's about f 25 r
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l time'somebodyLfaces up to it.
2 MR. WARD: And, see, the IPE effort just as de-'
3 scribed in General Letter, the draft Generic Letter, we are p' :
is- 4 _ talking about a $300 million right there. I mean that's not c
5 a small undertaking. And this is just kind of a variation on -;
6 it.
7 MR.. MICHELSON: The PRAs they are talking about ;
r 8 involve human factor input, for instance, which are only in :
9 in a rather rudimentary way in an ISAP kind of level.
{
10 MR. KELLY I don't think the IPEs, PRAs, are going 11 to be more advanced in the state-of-the-art-- ,
i .-
12 MR. MICHELSON: Well, they can't be more advanced lllll 13 than the state-of-the-art. ,
14 MR. KELLY: Right. [
15 MR. MICHELSON: But they will be state-of-the-art. j 16 MR. KELLY: They will be state-of-the-art. i j 17 MR. MICHELSON: Unless we know how to do things 2
! 18 state-of-the-art. !
19 MR. KELLY: And the state-of-the-art ain't all that -
t l 20 great. 1 l,
21 MR. MICHELSON: But in the future as we begin to 7 22 understand the human factor, it may be the important outlier, j i 23 We don't know. We don't know because we haven't put it in 24 very well yet necessarily. And as we learn that it might be 25 more ',mportant than we thou~ght, I think it's nice to have a l t i i
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'107 I PRA now where we just go back and change our. numbers, change f .
1 2~ our mind a little bit, and find out how-important it is,'once 3 we got the data to go with it.
- 4 DR. SIESS
- Well, the argument on Level 1, 2 and 3 5 is--Charlie--Level 1, is where you are going to find most.
6 of your outliers, initiators. -Level 2 and 3 are going-to be 7 most useful in looking at accident management processes.
8 And another problem with this thing is if you are going to 9 go back to the safety goals and look at apything as . hey talk 10 about, there is no safety-goal related to Level 1. There's 11 no explicit core melt criteria and in the safety goals. And 12 there's a 10-6 large release undefined criterion in there and 13 that takes a Level 3 to get down to that one.
14 So again, to come back to it, we're trying to regu-15 late with the body of written regulations dealing with on 16 type of accident and policy statements dealing with another 17 type and the only place we can address risk is in terms of 18 policy statements. And maybe that's the way to go. We might 19 never want to put risk into regulations. Although I think 20 other countries have done it.
21 MR. WARD: I don't think I understand what you are 22 saying.
23 DR. SIESS: Regulations that explicitly refer to 24 risk.
25 MR. MICHELSON: Well, they refer to safety and that' s Heritoge Reporting Corporation (308) M eett
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. . l 1 inverse risk. . .l 2 DR. REMICK: Safety is in there.
3 DR. SIESS -_But you cant use it. Just like.ade- -
4 .quate protection.= Is that defined in terms of--
5- MR. WARD - I don't understand why you say you can't 6' use it. 'I mean it has the SEP and the pilot ISAP used risk 7 to make judgements=about whether details of particular regu-8 lations were going to enforced or not, or whether they could 9 be--
10 DR. SIESS: No. Those regulations were not enforce- ;
i 11 abe. Those plants met all the regulations in effect'at the 12 time they were licensed. And they were being looked at be- t 13 yond the regulation.
14 MR. WARD: Okay.
15- DR. SIESS: See, again SEP was working beyond the ,
i 16 regulations, not even in a policy statement. Sort of a good 17 will effort.
t 18 MR. WARD: Well, if that hadn't worked, there [
19 sure could have been new regulations to require--
20 DR. SIESS: They had backfits. There were threats 21 of backfits always implied and I don't think they had to in-22 voke the backfit rule once.
O 23 MR. WARD: Well, it wouldn't even have to be a 24 backfit. I mean if it had been decided that old plants had O. :
25 to be upgraded with this and that, new regulations, that could (
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2 DR. SIESS: But would it have been done in risk 3 terms.
4 MR. WARD: Well, it was done in risk terms instead 5 of taking that approach.
6 DR. SIESS: I think you missed--there are other 7 countries I think that have regulations that say the risk 8 shall not exceed so much of this size release at this level.
9 I don't know whether that's written into regulations like we 10 have or not. But our regulations are not written in terms 11 of probablistic risk assessments.
12 MR. WARD: Which eludes me why that's pertinent right now. Why we're--I agree in general, but I'm not sure llllh 13 14 what it has to do with what we do in a letter, a possible 15 letter.
16 DR. SIESS: Oh, I don't know whether it does or 17 not. But the thing is we are talking about using risk as a 18 basis for ordering and even deleting requirements which would 19 put down fewer regulatory processes that didn't explicitly 20 say this.
21 And the point I made to get an exemption under the 7 22 ISAP program based on a PRA, you'd have to go to the Commis-( )
23 sion. I'm not sure where that is in the regulations.
f
("3 24 MR. KELLY: 5012.
LJ \
DR. SIESS: I'm still concerned about this two-25 l4 Heritage Reporting Corporation (302) 6tl 4448 i
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'2 Anyway--they might think about' going ahead with !
3 'only five or six plants or five or six companies to break the ,
. 4 ice and try_it out as something now. ~ Reject in favor of
^
5 trying Dave's approach.- If that doesn't fly in the committee-- -
~
6 DR. REMICI( Well, apparently you folks had a sub-
- 7 committee yesterday where you talked about the IPEs-- .
4 i 8 DR. S7ESS: Yes. That's what generated this letter ;
9 that I hope you have. l 10 MR. MICHELSON: It's an important one not to have f
Il missed. j 12 DR. SIESS: Gentlemen, I think--we don't decide i
j 13 things in this committee. But how do we communicate the 14 situation to the full committee? Do you see any point in f
i is having Melanie, Thomas and any of these people come in next l J
16 month?
17 MR. WARD: By next month do you mean next week?
is DR. SIESS: Yes. I think that among us we can 39 certainly--I can summarize the situation. I can answer l 20 questions I think on most of the things as a subcommittee I
21 report, and the group here can offer opinions. !
22 Now, if we decide not to have a presentation by i O 23 Melanie, I think she ought to be here to answer questions.
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4 I
l 24 MR. MICHELSON: We already have the majority of j i
i 25 the committee here. i 1
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1 DR. SIESS: That's what we agreed to do yesterday, O 2 wasn't it? j 3 -MR. WARD: Yeah. Is this going to be at the full !
t O-- 4 committee back to back with the other topic?
5 DR. SIESSt- It should be. [
f 6 MR. NICHELSON: It ought to be almost integrated.
?
7 DR. SIESS: No. We're on at ore o' clock Thursday 8 and the IPE is on'at three o' clock--one to three Friday. :
9 MR. MICHELSON: I would suggest that they be inte- -
t 10 grated and presented twice. The first step--
11 DR. SIESS: The same time, different days.
12 MR. MICHELSON: And both of them on both days as >
llllh 13 an integrated package. !
14 MR. WARD: Well, that's it. If we just want to !
i 15 devote two hours to it. Maybe the second day could just be !
i 16 committee discussion on it.
t 17 MR. MICHELSON: Crystalizing your thoughts on the
, i a 18 second day, but keep the two together because they are not !
i 19 easily separable, f 20 DR. SIESS: Well, I think we could summarize the-- l 4
21 I'd be willing to try to summarize the situation on the ISAP. l t
22 MR. WARD: Yes, I think you could do that, but I '
23 suggest you do that on the f.irst day. j i [
24 DR. SIESS: Yes.
. 1 ,
4 112,'
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- 1. DR. SIESS: You.and Dean'will have to negotiate !
() 2 that with Mr. Fraley. ;
P MR.-WARD: Well, Ray is sitting here.
3
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O 4 - MR. MICHELSON: _There's no negotiation. It's just 5 changing the title. <
6 DR. SIESS: We don't negotiate. We just tell him, 7 huh? [
8 - MR. FRALEY: I ask the Advisory Committee Management j .
9 officer if it's all right. . He's the one--
10 MR. MICHELSON: Who is that?
11 DR. SIESS: You or whoever should be here to answer ;
12- . questions. ;
MS. MILLER:
j llllh 13 Yes.
14 MR. GRALEY: Bill'Kerr wanted IPE back to back with i
- 15 something else, so we do have to take a look at it. l l
16 ? With the containment systems, yes. [
17 MR. FRALEY: He wanted those two back to back as :
18 well.
.t 19 CR. SIESS: Well, that means we can take all--how I
20 about taking all Thursday afternoon on this. We've got human l i
9 i 21 factors on Thursday. Could you move that to Friday? l 22 1 MR. FRALEY: Yes, that could be moved as long as
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O 23 we notify the staff. f
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24 DR. SIESS: And thermal hydraulics why don't we i 2s just try to get everything back to back on Thursday afternoon Heritogo Reporting Corporation l t , u. t 4
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I then and some more time'on Friday and try to pull it together.
/ T i' 2 l MR. FRALEY: We'll see if we can work it out.
3 DR. SIESS: We already gave you generic items.
7-kJ 4 MR. MICHELSON: We are trying to write a letter 5 on Saturday for this?
6 DR. SIESS: Well, there will either be a letter on 7 this or there will be a letter on IPE that covers this.
8 MR. MICHELSON: One nuance on this whole PRA and 9 IPE business is whether or not we should really be pursuing to IPE without knowing what we're going to do about external 11 events. We're proceeding with a package without even knowing 12 how we're going to do part of the job. And I'm wondering 13 about the judgement of that.
14 MR. WYLIE: I think you ought to wait and nail 15 t that down first before we proceed.
16 MR. MICHELSON: You mean wait the eighteen months 17 until -
18 MR. WYLIE: Yeah. Whatever time it takes. And 19 do it right.
20 MR. MICHELSON: I'm awfully uneasy about proceeding 21 without knowing just how that's going to fit in. If I were
,- 22 a utility I would be reluctant to get stuck--
\-) i 23 DR. SIESS: Gentlemen, we will schedule this to-(
,e u )l gether. I will try to summarize the situation. Dave can s.-
25 l Present his proposal and we'll try to integrate our comments b
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,. ... ,. 4 - i de I to' the Commission ~on the process:somehow using PRAs to make .!
O 2 plants sa'fer. That's what the-whole subject is. j 3 Thank you. l 4 Now we have one more item. We got a document from. ,
5 the staff I guess it was saying that they will--integrating-- r i
6 no, this is more recent. May '86? !
' 86 is what mine says.
7 MR. MICHELSON: May 27th, l t
8 DR. SIESS: And we hadn't seen it. Let me put'it 9 this way. We learned that the staff had been trying to inte-10 grate some of the NUREG 0933 issues. That's the generic 11 issue encyclopedia. And we asked them what they were doing 12 and they sent us.a copy of a memo of two years ago and we asked them to come in and tell us a little bit about what they (lllh 13 14 are doing, since we've been fussing about just this thing.
15 And it's nice to know that had anticipated us.
16 Warron, if you want to explain why we weren't told, 17 but that's not important.
18 MR. MINNERS: I kept trying to tell you?
19 DR. SIESS: Huh? You didn't know whether we 20 cared.
21 MR. MINNERS: I keep telling you we've been inte-22 grating issuea since day one.
23 DR. SIESS: I couldn't find it in the minutes any-24 where.
25 MR. MINNERS: You have to let us review your minutes Heritoge Reporting Corporation misa
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o 2 DR. SIESS: You've got the floor. Everybody has j 3 got this May 27th letter in front of you?
O' 4 MR. MICHELSON: 1986. .
5 DR. SIESS: Oh, and the other thing you were in- j
.6 vited to do was to provide any comments on-our letter wo- ;
7 wrote last month on generic issues.
8 MR. MINNERS: Well, it's easy to do because_I can [
l 9 do both at once. Because my primary comment is on your ,
i 10 statements on the integration and tne scope of issues which 11 was Gistributed a little bit throughout the letter and onu- ;
i 12 place about-scope but that's all one thing, was integration !
i 13 and scope.
14 Tc make a little bit of a wise comment. Your l 15 first question is what are the issues that have been integrate d 16 so far. And my answer to that question would be all of them.- f 17 We have continually integrated issues and we con-
! 18 tinue to integrate issues. And maybe that's a definition of !
l 19 terms. When you say integrate, I mean I interpret that to l 20 mean that you go on and do whatever you have to do to be sure ;
' r 21 that all of the issues are related to each other in whatever ;
5 22 way they relate. That you take account of that in the reso- f O 23 lution. And it's a continuing process and it starts with the i
i l 24 prioritization and it continues on through the resolution and 25 it probably ought to continue on through the implementation. [
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tj6 116 i So I think--
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2 DR. SIESS: What was the last that probably should 3 continue on? 1 1
4 MR. MINNERS: Implementation.
5 DR. SIESS: Implementation, yes.
6 MR MINNERS: And I don't know that much about 7 implementation so I can't toll you what the status of that 8 , is. I guess maybe NRR can.
I 9
l Now, a subset of integrated issues is maybe what I
10 l you more mean by integrate, which I reserve the term consoli-11 date. And on the back of--the first part of 0933 at the end 12 i of the introduction there's Table 5 which is a summary of And it just goes down through llllh 13 consolidated generic issues.
14 the listed issues and then this--next to each issue, the 15 other issues that are consolidated into that issue. That 16 means that their scope is part of the scope of the primary 17 issue. And that's what I mean by consolidation.
l 18 l So that list is kept up to date. And I have trouble i
19 f getting the latest one and you may too. This is the latest 20 It's 12/31/87. And the best I could pull out of my l one.
21 book was something earlier than that. So it says a little h,
7m 22 0 more in it.
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23 ! DR. SIESS: Now, the first page and the second page h They
('; 24 H of TMI issues which God knows needed consolidation.
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25 f came from every direction. And then we've got what? The
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'* 3 DR. SIESS: Those are both USIs and what?
4 MR. MINNERS: You can tell'from the.next column C .- ;
5 whether they are USIs or whatever.
6 DR. SIESSt- And then the ones that come'in on that-- 'I 7 I'm having trouble reading these pages.
8 MR. MINNERS:- They got stapled together wrong.
9 DR. SIESS: They are all Task Action Plan items j u
10 down to the human factor issue one, right?
11 MR. MINNERS: That's right. -;
r 12 DR. SIESS: 119.1.
13 MR. MINNERS: Now, I don't guarantee that this'is 14 up to the last minute, okay? It's pretty good. I think it !
l 15 gives you the idea, f
- I l 16 MR. MICHELSON: The last column of items covered I 1 ;
17 by the major issues, does that mean that these items are f
18 subsumed by the particular one-- !
i 19 MR. MINNERS: So if somebody said, for instance, [
l 20 what are you doing about Issue 125.12A, you'd say, "liey, that's ;
I 21 whatever is going to be done about that." And be done as j 22 part of the 270. t O 23 DR. SIESS: I'll have to admit, this table is not !
i 24 something I look at regularly. But we have seen a number of 25 these things when it came at the prioritization stage.
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, Heritoge Reporting Corporation l 1
118 1 MR. MICHELSON: That'r right.
2 DR. SIESS: Something would be disposed of by 3 consolidating with another issue. And we've been aware of I )
4 that. But when I look at the Task Action Plan items, in most 5 cases just one or two issues have been added in, right?
6 MR. MINNERS: Well, I mean you get up to 845 and 1
7 i you'll cee you start loading on. As the issues get broader 8 4 more issues get dumped into it. So 845--
t 9 DR. SIESS: Or vice versa.
I 10 MR. MICHELSON: Isn't there also the case occasio-i 11 i d nally where a part of an issue got moved over into another i
12 l issue and the other part was resolved--
a MR. MINNERS:
llllh 13 I think that's happened. I can't 14 i give you an example off the top of my head, but sometimes 15 l issues are split. Well, it's just a matter of how the person 0
16 l submits the issues. Some of them, a part mcy go into another 17 llissueandtheremainingmaybesetupasanissuebyitself.
18 l Now, I don't think that's reflected in this table. You'd have 19 j to go back and read the prioritization.
b 20 h DR. SIESS: Now, does this table contain only those h
21 q 1ssues that have had other issues added to them, or is this b
7s 22 J a complete--
( ) i 23 MR. MINNERS: No. This is just the ones that have
'i 24 [ had other issues added to them. The total list is obviously f~']s L- l 25 [ longer than this. And I think that's Table II and 0933 has u
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2 DR. SIESS: Okay. Now, this attachment to the May j s=- y P y
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3 27 letter, where there are three enclosures each listing ;
-4 consolidated issues. That's not the same thing. Because now f
$ if I look at Enclosure 1, electrical power issues, a single ?
1 6 program is developed to consider these issues. They have not i- .
7 been consolidated, but you are doing an integrated-- l 8 MR. MINNERS: Well, these were consolidated. If ;
9 ~you look on Table V, Issue 128 is listed there, next to the i 10 last new issue on Table V.
i 11 DR. SIESS: Issue 128? {
, 12 MR. MINNERS: Yes.
' I 13 DR. SIESS: It's the now issue--
14 MR. MINNERS: That consolidates 48, 49 and 830.
[
i i i 15 DR. SIESS: So this issue now is 1287 !
16 MR MINNERS: Yes. And I don't know what happend [
! 17 to 76. I'll have to go look that up somewhere and find out i 18 what happened to it. Okay. That's here too. So tney made j
)
i 19 A separate issue out of it I guess. I i i j 20 DR. SIESS: Well, you left it as a separate issue. (
l !
21 ; MR. MINNERS: We left it as a separate issue. ;
I 4
2 22 Okay, now, Enclosure 2 you subsume 77 into A-17 and i i O 23 that's reflected in the Table.
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! 24 MR. MINNERS: I don't know. Good question.
l 25 DR. SIESS: Okay. And the steam generator issue, [
L j Heritoge Reporting Corporation !
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120 I what was the number that came out to be? It's got 67, 21--
2 MR. MINNERS: Well, let's see. 6731 went into 3 A-47. .
i ,
4 f DR. SIESS: Oh, I see. What happened to the other i,
5 jones? I'm just trying to get a feel for the complexity.
6 On Enclosure 3 it says "We;tinghouse steam generator l
7l n two rupture studies," and that really wasn't an issue, was 8 1 it? It wasn't a numbered issue.
9 MR. MINNERS: I guess not.
I 10 DR. SIESS: And then 67 with all its sub items--
11 677 ended up in 135.
12 MR. MINNERS: Yeah. And you can look them up in 13 the table, h
14 i DR. SIESS: That's what I'm doing.
15 j That's all for the record.
16 . (Whereupon, the proceedings were adjourned at 5:00 li 17 hp.m.)
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1 CERTIFICATE }
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2 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Cownission in the matter of:
5 Name: ACRS Subcommittee on Generic Items l 6
i .
7 Docket Numbers j 8 Place Washington, D. C.
9 Dats: Wednesday, April 27, 1988 !
0 10 were held as herein appears, and that this is the original [
11 transcript thereof for the file of the United States Nuc.' ear i
'~
12 Regulatory Commission taken stenographically by me and,
~
i 13 thereafter reduced to typewriting by me or undar the direction :
14 of the court reporting company, and that the transcript is a
. 15 true and accurate record of the foregoing proceedings.
16 /s/ n c (>h 6/k/ !
l 17 (Signature typed): IRWIN COFFENBE Y
' i 18 Official Reporter 19 Heritage Reporting Corporation '
i 20 l l
21 22 1 23 J !
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(202) 628-4888 4 i . I i
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1 7
NRR PRESENTATION TO THE ACRS GENERIC ITEMS SUBCOMMITTEE ,
ON INTEGRATED SAFETY ASSESSMENT PROGRAM II ,
APRIL 27, 1988 a
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ISAP II PRESENTATION ISAP II -- WHAT IS IT?
PROGRAM COMPONENTS PIL0T ISAP VS, ISAP 11 THE PROCESS 1
BENEFITS RELATIONSHIP TO IPE O
.. RELATIONSHIP TO INTEGRATED SCHEDULE POLICY SURVEY RESULTS ,
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- NRR RECOMMENDATION n
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4 2-h INTEGRATED SAFETY ASSESSMENT PROGRAM (ISAP) II FOLLOW-0N PROGRAM TO PILOT ISAP
- HADDAM NECK AND MILLSTONE I SYSTEMATIC PROGRAM TO ADDRESS REGULATORY ISSUES WITHIN AN INTEGRATED SCHEDULE DESCRIBED TO UTILITIES IN GENERIC LETTER 88-02 i
() OBJECTIVES
~
ENHANCE SAFETY INCREASE EFFICIENCY IN LICENSING ENC 0URAGE USE OF PRAs 1
1
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- o ISAP II: PROGRAM COMPONENTS PROBABILISTIC RISK ASSESSMENT LEVEL I AT MINIMUM OPERATING EXPERIENCE REVIEW EMPHASIZED FOR THOSE PLANTS WHO DO NOT HAVE A PLANT-SPECIFIC PRA IDENTIFY TRENDS, WEAKNESSES
(])
VALIDATE REASONABLENESS OF PRA INTEGRATED ASSESSMENT RANK ISSUES i
END RESULT IS INTEGRATED SCHEDULE O
4 O
DIFFERENCES BETWEEN ISAP AND ISAP II ISAP II WILL NOT REQUIRE UTILITIES TO ADDRESS SYSTEMATIC EVALUATION PROGRAM (SEP) ISSUES ISAP II WILL NOT REQUIRE UTILITIES TO ADDRESS UNRESOLVED GENERIC ISSUES ISAP II WILL ADDRESS ONLY CURRENT AND FUTURE ISSUES THAT WOULD OTHERWISE HAVE TO BE ADDRESSED O
- ISAP II WILL NOT REQUIRE A PEER OR ACRS REVIEW 0F THE INTEGRATED SAFETY ASSESSMENT REPORT ISAP II WILL NOT REQUIRE A LICENSE CONDITION ISAP II WILL PROVIDE FOUNDATION FOR COMPLETION OF AN INDIVIDUAL PLANT EXAMINATION (IPE)
O 1
. - - - - - . - - - . . . . - . - c- -. . - -
5 10 THE ISAP 11 PROCESS EACH PARTICIPATING' UTILITY SUBMITS PRA UTILITY SUBMITS ITS LIST OF ISAP II ISSUES NRC REVIEWS SCOPE OF ISSUES EACH UTILITY SUBMITS EVALUATION, PROPOSED RESOLUTION, AND RANKING OF EACH ISAP II ISSUE NRC REVIEWS RESOLUTION AND RANKING AND RESOLVES
() QUESTIONS STAFF ISSUES INTEGRATED SAFETY ASSESSMENT REPORT NRC AND EACH UTILITY NEGOTIATE SCHEDULES l
SCHEDULES REASSESSED FOLLOWING EACH REFUELING OUTAGE t
O SOME ANTICIPATED ISAP II BENEFITS PRIORITIZATION OF ACTIONS PROVIDES RATIONAL SCHEDULE FOR IMPLEMENTATION BASIS FOR POSSIBLE COMBINATION OR ELIMINATION OF ISSUES PREDICTABLE SAFETY BASIS TO MANAGE CURRENT WORKLOADS AND RESOURCE REQUIREMENTS BASES FOR OPTIMIZATION OF MAINTENANCE / SURVEILLANCE INTERVALS O
- PROCESS WOULD IMPROVE OUTAGE PLANNING l
PROVIDE LICENSEE WITH INDEPTH PLANT UNDERSTANDING l
l RECEIVE INCREASED SAFETY VALUE FOR DOLLARS SPENT BECAUSE ISSUES OF HIGHEST SAFETY SIGNIFICANCE GENERALLY WORKED ON FIRST l
- IMPROVE LICENSEE ENGINEERING /0PERATIONS INTERFACE l
l l
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ISAP II RELATIONSHIP TO IPE ISAP II
- BY PARTICIPATING, UTILITY HAS INITIATED PREFERRED MEANS OF DOING IPE LEVEL I PRA PLUS CONTAINMENT VULNERABILITY
- ASSESSMENT WOULD FULFILL IPE REQUIREMENTS IPE O -
REQUIREMENT
- IF A UTILITY DOES PRA TO FULFILL IPE, THEN CAN ALSO PARTICPATE IN ISAP II THE IPE CRITERIA FOR IDENTIFYING WHICH RISK REDUCTION 4
MODIFICATIONS ARE TO BE CORRECTED WOULD ALSO BE APPLIED TO ISAP II PRAs CRITERIA ADEQUATE PROTECTION t
BACKFIT RULE O
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l ISAP II RELATIONSHIP TO INTEGRATED SCHEDULE POLICY l
ISAP II IS PRA-BASED PROVIDES TECHNICAL JUSTIFICATION ISAP II ALLOWS DROPPING OF ISSUES, MOVING ISSUES TO LOWER PRIORITY IF ISAP II WERE IMPLEMENTED, INTEGRATED SCHEDULES Q WOULD ONLY BE AVAILABLE THROUGH ISAP II O
.n. . . - - _. _ _ _ - ., ..Q..-.-...-- . . . - , ,
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GENERIC LETTER 88 02 SURVEY RESULTS RAW DATA YES: 6 UTILITIES REPRESENTING 10 SITES (FLORIDA POWER, NIAGARA M0 HAWK, NORTHEAST, NORTHERN STATES POWER, OMAHA PUBLIC POWER DISTRICT, AND TVA)
POSSIBLY: 29 UTILITIES REPRESENTING 36 SITES NO: 18 UTILITIES REPRESENTING 24 SITES
([) INSIGHTS IN THE "POSSIBLY" CATEGORY 8 UTILITIES REPRESENTING 10 SITES ARE TENDING T0 "YES" 4 UTILITIES REPRESENTING 4 SITES ARE TENDING T0 "N0" O
1 10
~
O
SUMMARY
OF UTILITY COMMENTS MUCH INTEREST IN ATTENDING AN NRC/ INDUSTRY SEMINAR CONCERNS LICENSE AMENDMENT UTILITY COST OF IMPLEMENTATION RESOURCE REQUIREMENTS J
(])* OVEREXTENSION WITH IPE AND ISAP II i
LEVEL 0F NRC REVIEW AND THE PROCESS PROPOSED 54 WEEK SCHEDULE DUPLICATION OF EFFORT BETWEEN ISAP II AND IPE WHETHER UTILITY INITIATIVES WOULD RECEIVE APPROPRIATE PRIORITY CAN SEP ISSUES BE INCLUDED
- UNCERTAINTY ABOUT IPE GENERIC LETTER ,
1 l
i
..___________,-...._,,_....._._..__....____._..__.._[e _,_.____.._.,__.__.-..__r.,_ .
22-()
SUMMARY
OF UTILITY COMMENTS (CONTINUED)
NEEDED ADDITIONAL INFORMATION IPE/ISAP II INTERFACE ISAP II/ INTEGRATED SCHEDULES INTERFACE PROCEDURE FOR MODIFYING SCHEDULES MAGNITUDE OF UPCOMING GENERIC ISSUES
.($)* EXAMPLES OF PRA LICENSING APPLICATIONS RELATIONSHIPS TO PLANT AGING AND LIFE EXTENSION ISSUES REGIONAL INSPECTION ITEMS RANKING PROCESS BACKFIT RULE POTENTIAL BENEFITS TO UTILITIES i
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