ML20154H836
| ML20154H836 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/1998 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3054, NUDOCS 9810150035 | |
| Download: ML20154H836 (98) | |
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j yy , ]yf 5 . DISCLAIMER I ? UNITED' STATES NUCLEAR REGULATORY COMMISSION'S. j ADVISORY COMMITTEE ON REACTOR SAFEGUARDS. i 52.: \\ I -OCTOBER.2, 1998 i l i 1 . The. contents of this transcript of the proceeding-1 l lof'the UnitediStates Nuclear Regulatory' Commission Advisory. Committee on. Reactor-Safeguards,'taken on' October,.2, 1998,- -i as; reported.herein, is a record of the discussions recorded. at.the; meeting held'on~the above date. i-This transcript.had not been reviewed, corrected L. and' edited and it may contain inaccuracies. I l-i L i t.~ 4 l: 2 l' i ~s j [ (, e $ jm.. ( i> p',y I q ..hl
Y L 347 1' UNITED STATES OF AMERICA Iq. [N /o' -2 NUCLEAR REGULATORY COMMISSION- [ 3. ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 5 MEETING': 456TH' ADVISORY COMMITTEE -6 ON REACTOR SAFEGUARDS 7 m 8 U.S. Nuclear Regulatory Commission-l 9
- 2. White Flint
'10 ' Rockville, Maryland 11 Friday,' October 2, 1998 l
- 12.
13 The. committee met, pursuant to notice, at 8:28- .14 a.m. ' /'h Jg_,) j 15 MEMBERS.PRESENT: 16' ~ DR. ROBERT SEALE, Chairman ACRS i 1*7 DR. DANA ~ POWERS, Member, ACRS 18-MR.-JOHN J. BARTON, Member, ACRS .19 DR. ROBERT E. UHRIG, Member, ACRS DR. WILLIAM J. SHACK, Member, ACRS 21 DR. DON W. MILLER, Member, ACRS 22' DR. MARIO H. FONTANA, Member, ACRS 23 DR. THOMAS S. KRESS, Member, ACKS '24 DR. GRAHAM B. MALLIS, Member, ACRS 25 DR. GEORGE E. APOSTOLAKIS, Member, ACRS l-I' N k ANN RILEY & ASSOCIATES, LTD. p u/ Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
348 1 PRO'CEEDINGS .(w T. '2 [8:28 a.m.] '%) ' 3 CHAIRMAN SEALE: Good morning, I'm going to jump 4 the' gun.about two minutes and we'll get started. The 5 ~ meeting will now come to order. This is the third day of 6-the 456th' meeting of the Advisory Committee on Reactor 7 Safeguards. 8. .During today's meeting the Committee will consider 9 the.following: Integrated Review of Assessment Processes 10 and Proposed Improvements to the Senior Management Meeting 11 EmVess; Recollection of ACRS Comments and. Recommendations; 12 Proposed'ACRS Reports. In that regard, Tom, you have the 13: recollection letter on'the uprates, and I believe that's'the 14 -only one. So I hope-you'll'be ready to respond when the /N Q: .-15 . time comes. 16' This meeting is being conducted in accordance with 17' the provisions of.the Federal Advisory Committee Act. Mr. 18 Sam Duraiswamy is the designated Federal' Official for the 19 initial portion of the meeting. 20 We have received no' written statements or requests 21 forDtime to make oral statements from members of the public 22 regarding today's session. I 23 A transcript.of portions of the meeting is being 24 .kept and it is. requested that the speakers use one of the 25? microphones, identify themselves, and speak with sufficient j ). ANN RILEY.& ASSOCIATES, LTD. 'As Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
349 l ~ clarity and volume so that they can be readily heard. 1 [v) As I understand it, we're getting an update today 2 3 on the senior management review process. As we all recall, 4 Wednesday noting in our. initial comments that we recognized 5 that this was not a -- well, that this was a moving process 6 'because as I understand the SALP process has now been 7 suspended for some period of time depending -- I might even 8 be so bold as to say, " anticipating" perhaps the results of 9 some of these discussions. 10 MR. BARTON: That is a rather bold statement. 11 CHAIRMAN SEALE: Yeah. So, John, I think we're 12 all waiting with bated breath to find out what's going on 13 and I'll ask you to introduce our speakers. 14 MR. BARTON: Thank you, Mr. Chairman. There has p) ( 15 not been a package transmitted on the latest status. We'll 16' hear that today from NRR and I believe NEI would like to 17 make soma comments also after the staff's presentation. 18 CHAIRMAN SEALE: Excellent. 19 MR. BARTON: There's been a flurry of activity 20 since we last visited this subject in March and we submitted 21 a report at that time to the Chairman. Since then there was 22 an SRM issued to the staff. We recommended at that time not 23 to go' forward because we thought there were some issues that i l 24' needed to be worked on yet. There was an SRM issued by the 25 Commission to the staff on lost -- in June requesting that [3 ANN RILEY & ASSOCIATES, LTD. 'l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034
1 350 l 1 this process be put out for public comment.and resolve some . /'% '. j ). 'of.these issues. ..The directive in the SRM to the staff gave -2 v 3 'them some direction on which issues to get resolved during 4 the public comment period, and since then we've received a 5 memo-from the EDO with some proposed improvements to the ] 6 management meeting process. 7 Also we've seen a SECY paper suspending the SALP '8-process as you indicated-
- And I guess the latest activity
) i 9 on this'SMM project or process was the workshop that was TO . held the 28th of September to October 1st and I see both the 1 11 staff and EEI here, so I assume they survived the battles of 12 the three-day workshop and we'll hear about some of those 13 issues they talked about in the workshop today, I'm sure. ~~ - At this point I'll turn it'over to Michael Johnson .14 (,, =15'- 'from NRR to lead the presentation by the staff. 16. MR. JOHNSON: Good morning. My name is Michael i 17 Johnson from the Inspection Program Branch in NRR. I'm O 18 joined at the table by Alan Madison who is also these days .19 -with NRR, he's acting Chief of Performance Evaluation and l 20 Assessment Section; and also Frank Gillespie who is the '21
- Director of the Division of Inspection and Support Programs.
22 Also, at the side table we have Tim Frye and Dave ) 23' Gamberoni both from the Inspection Program Branch and Dave j 24 is actually the program manager for the efforts that we have j 12 5. undertaken to develop improvements to the assessment process i /n 0 -ANN RILEY & ASSOCIATES, LTD. ' \\- ' Court Repo&ters 1025 Connecticut Avenue, NW, Suite 1014 2 84 b3
+ + F 351' 1.
- and' Dave'and Tim *have worked longLand'hard'in getting us tu
- gy l2 Lwhere
- weLare today..And' so they're sitting at.the' side.
@N ^f L L3 ' table'and'they'll-help; keep us outLof: trouble'should welget. j, 14h .into trouble. 15 LLet.me justihit briefly what it is.I think'we're-i (6L Lgoing t'o do1today.or;whattwe plan to do today. And that is 4 7; t'o talk'about.theLobjectives of specifically the workshop, .4 8 'and1I'll, explain.where the wo?kshop fits in,Lin the overall-a h 19; staff efforts'and.trying to get from where we were atL the U^'I ltime of the'ACRS letter to where we need to be in' January 7 ^ 11- .and beyond. ~So I'll' focus on the objective.of the workshop I -12;
- at some; point.
13) We're: going to talk about the process that we'used' q L 0141 in'the' workshop and the'results of workshop and then'what we 1 (15L .see-as'next steps. And please keep in mind'that the .16.' workshopfwasfyesterday~and we're here talking today. So 17: 'some of.what'we tell you will be based'on what it is we've L 18-been.able to capture, but we don't have -- we don't have 19 minutes from the workshop and we haven't been able to sit b' 20 down~and think in any'real terms about what came out of the 1 21 . orkshop. So bear with us in that respect, please. w L 122: Before I actually talk about the workshop, let me f_ J23' go'back to where we were at the Commission briefing and sort 24 of what has happened between that time and today. As you L255 know,:we briefed the Commission on the IRAP process ~ the 7 ~ ANN RILEY & ASSOCIATES, LTD. JN ' ' Court Reporters '1025 Connecticut Avenue, mf, Suite 1014 a h, Washington, D.C. 20036 l' '(202)1842-0034 L
u. 352 L11 'results'of the' staff's effort and' recommendation to the l 2 1 -Commiss' ion'on what we would do in terms.of changes to the 3 Lassessment process.. '4. And,at that~ time, at that briefing,;.we sort-of E5- .tried!to' lay.out the philosophical approach to IRAP. We had- '6-' previously briefed ACRS and we talked about it with the-l
- 7..
.1 Commission..And the real purpose for that Commission-N briefing was to get permission from the Commission to'go-8? t 9. forward.with public comments on IRAP. And.at that time also '10
- you all'-have.had -- ACRS had had several briefings from NEI.
~11 ' NEI,. it. turns'.~out, had also begun working on a proposal for ~ 112 assessment or:really regulatory oversight and you got some .13 ' . briefings.on'that. ~ 14' And'soiat the time.where the Commission was ' + ,Lh - t,J 15 considering whether to go forward for public comment --- i I '16 / iallow uscto go forward for public comment, they had really. - 17_ two' proposals on hand. They had the IRAP proposal and they 118. had.the,NEI proposal. .19- ' The SRM came back and it said, do go forward for 20-publicEcomment. 'I think-the date of that SRM was the 30th i 21; of June or something. ' 22' MR. BARTON: :Right. ) 23-MR. JOHNSON: Something like that. It said, do go forward for public; comment, keep in. mind a number of 12 4
- 25
' Commission' concerns and they pointed out their concerns with 'l ANN RILEY-& ASSOCIATES, LTD. Court Reporters 10253 Connecticut Avenue, NW, Suite 1014 y Washington, D.C. 20036 L .(202) 842-0034 p 1
.m ) b 353 m our;use of e'nforcement as atdriverlfrom'their-perspe'ctive in 1 b. 12- -IRAP,.'and. numerous.other concerns.' They were,'. it 1 turns. out,.. A._/ 3 " concerned-as was the ACRS.with the public's response to; 4 2IRAP. And'while they did give us the permission'to go
- 5:
forward'fortpublicJcomment, I thinkithey really_did want us / 16 : to go back and-do some'more work. 7. InftheLintervening time between the' Commission 81 ' meeting and thelSRM, 'we.had several. meetings with NEI.where. 1 t 9: we heard exchanged information-on the sort-of the parallel 10 effort that-NEI h'ad undertaken. And so by the time.we had 11 received the SRM that said, now,-go forward'and.do public il2 ~ commentstand, oh, by the way,. get back to us at'the end of 13
- the year on.~a recommendation for revisions to the: assessment 14-process.
By the time we got that SRM,~we had~already begun .i (!ch). 15 to work;with NEI to try to figure'out.how'we would put these sw 16 processes.together.such that got to a single recommendation- - 17 at the January timeframe. 18. .We laid out a schedule and that schedule included v ~19 a public comment period, a 60-day public comment period that 20 ' began in August and ends on the 6th of October. Part of 'that public comment period was the workshop and we saw the 21' ~ 22-workshop really as a real means for us to try to meld - 23 together these-two approaches, if you will, to assessment 24 and oversight to come up with a single recommendation. And 12 5 co'it is today that we want to spend a lot of time talking . ~ [ (\\~ l ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)- 842-0034
354 about bhat'it-is we did at the workshop dnd what the results 1 T["). 2 were. That's sort of-the basisLand background behind why.it LJ 3L is that we're talking about the workshop so much today. 4 Let me talk about briefly the workshop objectives. ~ 5' We really'did want the workshop to be the vehicle, once 6 again, for us to'try1to bring together-the-various 7 7 recommendations on assessment into a single process. And so. 8 in the workshop we focused on -- and key areas, and I'll go 9 through each of these: areas in some more depth. I'll talk 10' about -- in; fact the first' area of the workshop which was -- 11-and the'first' objective which was trying to'get generali 12 agreement on the' framework, the overall. philosophical i' w 13 framework to regulatory oversight. -14 If you'll think back on IRAP, when we did the IRAP . ~,m i ) 15. effort, we really did stay within the bounds of the existing .] w 16 paradigm, if'you will, for regulatory oversight. And NEI. 17 and the approach that NEI proposed. caused us to look beyond 18f that paradigm-and to-look at the regulatory framework before '19; we began to take a look at oversight - ,I'm sorry, 20 assessment and inspection and their roles within the 21-oversight process.. So the first objective of the workshop 22, then was to focus.on that philosophical approach and get 23 ' agreement on that philosophical approach. 24: Then given that philosophical approach, we had -- l 125 we recognized that there were several defining issues, key l' i '(N ANN RILEY & ASSOCIATES, LTD. (l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 L (202) ^ 842-0034 g
} 355
- 1?
jissues, even-given:the: approach that you needed to get.the ' ;-Q
- v)D
.2: answer =toxbefore you could begin to actually scope'out what 3d 'the inspection program was -- what'a. revised inspection 14. ' program wouldilook like to fit within that oversight process 5~ .or, approach. And'so that was one of the areas of the 6; ' workshop'and oneof:the key objectives. 7 -And'the third area or the-last area was to make
- 8 Esome' progress'then and once we had this high-level'
.9 . philosophical' approach, once we:had>some defining l <10; principles,.we were then going-to take that approa'ch and try 11 to driveLdown in the workshop and do some detailed -- some. 12 -of.the first detailed development in trying to figure out 13 ' sort of how'you would begin to build this oversight process, 14; So those were the. key objectives. .The other one I p. js,/~ L15; haven't mentioned is the fact that:we were going to identify ~ 16 areas of disagreement. I mean, we recognize that a workshop .17 that.had 300 folks from varying perspectives, we were going 18 to have areas of disagreement.that we need to deal with, and 19; we did, and we'll try to point those out as we go through. '20' The next slide, process outline. In the workshop 21 .we.really broke down'the workshop into three major areas and 22 focused on the objectives that I just talked about. The j '23
- philosophical. approach, the fundamental issues, and then the 24
. detailed cornerstone development. And we're going to talk 25. through.each of those so I'll just spend no more time on lW 3(N ') ANN.RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)~ ~ 842-0034 L A
356 -1 this slide and get right to the philosophical approach. n (w,). 2 That was the starting point for the workshop. 3 Let me talk about the philosophical approach a 4 little bit before I talk about what we did at the workshop 5 and try to. explain the philosophical approach. One of the 6 thinge that -- when we last talked to ACRS, in fact, in the I i 17 number of briefings that we had with the ACRS that was sort 8 of a repeated theme by ACRS was sort of an urging that the 9 staff develop a top-down approach to developing oversight. 10 And, in fact, you know, I was reading the letter 11 -- the September 10th letter written by ACRS -- this morning 12 to sort of make myself fresh on what it was we talked.about 13 last and what you told us last. And it's interesting, you 14 know, one of the paragraphs said, "We would prefer to see a in. (,) 15 top-down' structure that starts with the point of decision, 16 identifies the objectives of the decision, and proceeds to 17 define informational needs. For example, in a risk-informed 18 approach one could envision an objective, the prevention of 4 19 the occurrence of initiating evc7ts, and the degradation of 20 safety functions. To satisfy this objective one would look 21. for precursors to the undesirable events and then would 22 proceed to identify. relevant performance indicators and to 23 address the issue of how these would be measured" and it 24 goes on. But it talks about, again, a top-down approach. 25 And so given the NEI lead that we had, or NEI ',n j 1dRT RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
357
- 1 stepping back and looking at the regulatory oversight l
) 2 process, we began to consider what the philosophical ./ 3 approach for regulatory oversight ought to look like. And 4 so'this slide'then talks about what it was we thought it was 5 .important to include in this philosophical approach. And we 6 thought, again, first based on the urgings of ACRS and the 7 Commission and others, we thought that the philosophical 8 approach really.ought to be higher hierarchial sort of 9 approach. That is, an approach that is a top-down approach '10 that starts with high-level objectives and decisions in the 11 words of ACRS, and then proceeds to define what the 12 -informational needs are. 13 We felt that the philosophical approach has to 14 certainly provide for the NRC's core values. And by that we 73(,) 15 mean, you know, let's not forget our first calling is to the 16 protection of public health and safety in the environment, 17 so on and so forth -- that's our first calling -- in a 18 manner that is risk informed, in a manner that is 19 performance based and we talked a lot about what those terms 20 mean. 21 We also think the philosophical approach needs to 22 provide for the important principles, the NRC's principles 23 of good regulation, you know, those principles that are 24 in' dependence and clarity, openness, reliability, and 25 efficiency. And finally we thought that the process has to (e,) ANN RILEY & ASSOCIATES, LTD. \\> Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
358 1 ~ recognize -- consider and recognize the overall success of ll 2 the industry while preserving the NRC's ability to take .J p 3 action on -- with those licensees, that. limited number of 4 licensees who do have performance problems. 5 You've been witness to the interactions of the 6 NRC, the interactions that we've had with had with 7 stakeholders, the various stakeholders at the meeting in 8-fact in this room with also the feedback that we've gotten 9 from the Senate, from the Congress, with respect to our 10 -activities, for the industry, and that has a resonant theme 11 and that resonant them is that the industry'has gotten 12 better. And so we think the philosophical approach.really 13 does need to provide for a. reflection of that improved 14 industry performance. Again, while making sure that we can ( .15 take action, focus on those licensees where problems do 16 exist. 17 Next slide. 18 So then we focused on now this philosophical 19 approach. And I would like to describe it briefly, and I 20 know the last time we were here Frank, in fact, talked about 21 the fact that we were on a philosophical approach. I want 22 to talk about how that philosophical approach evolved going 23 into the workshop. I want to talk about what came out of 24 the workshop in the way of changes to that philosophical 25' hpproach-and where we are today with that philosophical [h ANN RILEY & ASSOCIATES, LTD. .%/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.-20036 (202) 842-0034
. ~,. > ~... =! l 359 i 1 approach. c,~ 1 -{ )+. ..It' starts at the top at a veay high level, again, 2 se 13 topidown,' with the NRU's'overall mission. And, you know,. '4' thelNRC's overall mission;is established in the Atomic 5; -Energy Act._of 1954 as amended, Tit's established in'the j (6! ' Energy) Reorganization-Actfof 1974 - thank you, it's in the g 7l l National Environmental Policy Act and other environmental 8 l'egislation, and it's in the Nuclear Nonproliferation'Act of l5L 1978. And that mission is, and it's one that we share with 10~ .the industry, it's to ensure that civilian nuclear power 1 l11-reactor facilities are operated in;a manner-that~provides 11 2 1 adequate. protection of-public health and safety and the 13 environment and protects against radiological sabotage and 141 -theft or. diversion of=special nuclear material. . p( )L 15 That.overall mission is captured in our strategic
- 16 plan'and we think'it's;the place'where you start, this J
.17 top-down. apprc;ach when you look at the philosophical -- our 1-8 philosophicni framework to regulatory oversight. 19 Second then, if you move down from that, that -20 overall mission, that's where we want to be at the end of 21 the day. 1Then one of the questions that becomes -- that you 22 need to ask yourself is, what are the aspects of licensee 23 ' performance that are important and therefore require or '24 Emerit regulatory oversight. And I'm borrowing from a
- 25f question that was in.the NEI white paper.
It's one of the L r ANN RILEY & ASSOCIATES, LTD. ~ % /; Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 (202) 842-0034 f 1
360 L 1 'first questions they started with and we think it's a )
- 2' logical place to start, again, once you've set aside for
+ 3 yourself what that overall' mission is. 4-Well, the beginnings-of the answers to that 5 question is documented, again,- in the strategic plan. And I 6 want to just highlight some of the bullets from the 7 strategic plan that deal with that issue. The strategic 8 plan -- I'm having a lot'of trouble with that word this 9 morning. I will'try not to say " strategic" one more time in 10 the presentation. 11 [ Laughter. ] 12 .MR. BARTON: Just say "the plan". E13 MR. JOHNSON: The-plan. 14 [ Laughter.] (,) 15 .MR. JOHNSON: It says, "Zero civilian nuclear '16 reactor accidents,. maintain a low frequency of events which 17. could lead to a reactor accident; zero deaths due to 18 radiation or radioactivity releases from civilian nuclear 19 reactors; zero significant radiation exposures due to 20 civilian nuclear reactors; no substantiated breakdown of 21-physical protection that significantly weakens protection 22 against radioactivity sabotage or theft or diversion of 23 special nuclear materials; zero off-site releases from 24 civilian nuclear reactors or radioactivity material that 25
- have the potertial to cause an adverse impact on the
,m, ) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 e
361
- 1:
environment;;and-no increase..-in the number.of off-site- ') hf>-e - relea'ses from civilian nuclear reactors of radioactivity j LT )' ?2 w~' i '3. 'materihl that exceed 10 CFR.Part 20." l ( l I L4, And so when you look at the plan and those' goals, 5 you reallyfdo ---they really do~ fall-into several areasiand 6 we triedfto' capture those areasz in the second-level of'this .7- ~ diagram So,.in fact, going across-those'are the areas that ~ 8 the NRC has to perform,'the industry.has to perform in order 1 l 9' for us to ensure that we meet.our high-level, overall 10' mission of providing adequate health an'd safety of the 11 public. 12 And so'then that's the second tier of the diagram. 1 13-Then from each of those areas, you know, if you think about 14 it, there'are many regulatory requirements, licensees have 4Q 1,,/ - 115 many responsibilities, and, you know, we have a great-many .i 16 -areas of_ concern, but in fact in the words of the Chairman -17 in'a talk that she gave before the July senior management 18 meeting we believe it'really is possible to identify in .19 those areas the essential -- a set of essential' elements or . 20' cornerstones from a risk-informed perspective, the presence 21 ~ of which will enable the NRC to have assurance that our 22 responsibilities with respect to the overall mission are 2 3 '- 'being achieved. ' 24: Imd so these boxes at the bottom level, you know, 25' initiating events, mitigating events, containments systems, l. fw -- < 4 1 ANN RILEY & ASSOCIATES, LTD. ! k I. Court Reporters L 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034-
362 1 as we called it then, emergency preparedness, those boxes ') 2 going across at that level are-fundamental building-blocks N. f 3 cn the cornerstones, the presence of which will enable us to 4 Lensure that in the areas of our mission -- our regulatory 5-mission that we in fact are performing such that the overall .6~ mission of providing adequate protection of public health 1 7 'and safety are being met. 'Those are the cornerstones, and 8 those cornerstones really form'the heart of the work that we 9 did in the workshop and that w'e think that we need to i 10. continue with in terms of fleshing out the rest of the 11 oversight process and figuring out what it is we need to 12 look at in terms of inspection, what the objective 13 indicators are, and how they all fit together in terms of 14 assessment and enabling us to ultimately communicate the ) 15 results of that assessment'to licensees, to figure out what-16 -actions we're going to take internally, and to provide -- 17 again,'information to the public so that such that the 18' public'knows that we are meeting our overall public health 19 and' safety mission. 20 So this is a philosophical approach and we'll talk 21 a little bit more. In fact, Alan will talk about how then 22 you take what you have in each of the areas of the '23 cornerstone to continue to drive down -- l24 DR. KRESS: Could you clarify for me what -- in 25 that middle line, what the exposure from non-reactor / j ANN RILEY & ASSOCIATES, LTD. (.. / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
5 '363 >l1-Jaccident radiol'ogical releas'esfic?_ Is that medical use or l L-i i 222 cl N 6} j 13:
- MR.~ JOHNSON
- L No, it'is -- it,:ag'in, relates to a
(4 'the-reacto'rs,5but iftyou'look at the left four boxes, those ,r J5 funder! exposure from reactor, accident releases?- 6: DR. KRESS: Yes. T 17 'MR.-JOHNSON:.We recognize 1that -- and, in fact, 8. the earlier drawings that vn) had of thisFphilosophical 1 9 approach only had thosesfour boxes. 'And.we recognized that i 10 it:was pos'sible for'a plant to have no problems in terms-of, 11
- you know, limiting the number of initiating events,_you
.g 12; iknow, mitigation systems _ performing properly, you know, 1+ 13. thoseffour boxes wouldLbe fine, but there are routine 114 > releases,'-there are routine--- there are sort oftnormal l / ~,.. L15'
- activities' associated with the operation'of.a nuclear power j
' 16.- fplant,fand'there are limits and' responsibilities associated 117: !with"those. 18" -DR. KRESS: So that doesn't necessary mean '19? non-reactor,then?- 120 MR. JOHNSON: No. Yes, it is'non-accident. 21-: DR. KRESS: Non-accident. 1 22' MR. GILLESPIE: A mess up in the rad _ waste system 1 23; which gives you an undue effluent transportation accident -- -- 2 4 DR. KRESS: So the idea is to extend the i 25. ~ regulatory oversight to the whole range of fission product ['N ANN RILEY & ASSOCIATES, LTD. \\m-Court Reporters 3 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 r ..e
l 364 l 1 I' ). 2 MR. JOHNSON: Exactly. With respect to the w.j 3-operation of civilian nuclear reactors. 4 DR. KRESS: Thank you. Appreciate it. 1 5 DR. APOSTOLAKIS: Well, Michael, I haven't seen 15 the' rest of your slides, but I can~ assure you that this 7-slide, as far as I'm concerned is the beginning of a 8 beautiful friendship. 9 [ Laughter.] -10 .MR. JOHNSON: I'm relieved to hear you say that. 31 .[ Laughter.] 12 CHAIRMAN'SEALE: Boy, Claude Raines is getting a 13 lot of play -- 14' [ Laughter.] ,~. ).. 115 DR. APOSTOLAKIS: I just love.it. 16- [ Laughter.] 17 MR. JOHNSON: So for the workshop this was the 18 beginning -- again, the philosophical framework or approach 19 'is the starting point. It was the starting point for the 20 workshop. And so'we focused the effort first in this area, 21 and the issues that we've asked the workshop to deal with 22 was, is this the right philosophical approach? You know, is 23' there something about the philosophical approach that -- is
- 2. -
there some aspect of safety that is missing from that 4 25 philosophical approach? And, in fact, do we have the right ) ANN.RILEY & ASSOCIATES, LTD. _/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036; (202) 842-0034
'365 1-philosophical approach, and do we have the.right y~9 . cornerstones?. Are.there, cornerstones-that are missing? { 2 '3' .Have we defined the' cornerstones' properly? And so we spent 4' leffort in that first area _of the workshop looking at'this 54 philosophical approach. '6 Now,flet meLtalk.briefly about what it is that the ~ 7. workshop told us about. philosophical approach. Alan. 4n 8. In general what the workshop said was that the 4 19 'philosophicalJapproach was okay. I think we had good 10: . alignment. We talked at.the workshop in great length about 11-alignment as opposed.to. consensus'because we were really .._ orried about whether we could get something that you could 12 w ~13 ~ call consensus out of such a large group. But there was -- -14 ~there:was an overall' feeling, sort of a consensus p (,/ : 15 indirection,-if you.will, _on this overall philosophical" 16 approach. Again, starting at the high level the very high 17 . level public health and safety mission, going down through 18 'these. areas of. performance, and then ending with these --19 cornerstones or these fundamental building blocks as a 20 starting point for how we would depign this regulatory ~21 oversight process. 22 You'll note there were a few changes and those 123 ' changes reflect some of the consideration made by the group. 24 They thought, for example, that we could simplify the areas. -25 We had -- Alan, if you'll flip back to the previous t /s { -). ANN RILEY & ASSOCIATES, LTD. Court Reporters L 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
366 1 cornerstone. We broke out~ separately, you know, the .w) 2 exposure from non-accident radiological releases and we made ~ 3 that a separate are from the radiological worker exposure. 4 And.the workshop told us that really what we ought to be 5 concerned with as a whole is this area of radiatica safety 6 'and the fact that the radiation safety did in fact include 7 exposure to.the public and occupational exposure, that is, 8 exposure to the radiological workers. And so they really 9 simplified us -- simplified that area of the philosophical 10 approach and I think that was a good change. 11 The second area of concern in the workshop was the 12 area as we initially defined the safeguards area. I think 13 we called it -- sorry, Alan, you.have to keep flipping -- 14 DR. APOSTOLAKIS: So let me understand this, ,- s ( ) 15 Michael,.a little bit. Okay. Under " reactor safety" you 16 have now " barrier integrity" instead of the containment 17 systems. 18 CHAIRMAN SEALE: Instead of containment. 19 MR. JOHNSON: Yes, and I'll talk about that a 20 little bit. 21 ~DR. APOSTOLAKIS: Okay. But this is a result of 22 changing the second box? 23 CHAIRMAN SEALE: No. 24 MR. JOHNSON: No. 't 25 DR. APOSTOLAKIS: Oh, that's different. ,n. ( ) ANN RILEY & ASSOCIATES, LTD. N/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
367 1 MR. JOHNSON: That's different. Yeah, I'm J 2 focusing -- I focused -- my comments focused on this box. 3 DR. APOSTOLAKIS: Okay. 4 MR.-JOHNSON: Radiation safety -- Alan, would you 5 just'-- basically combining these two areas into a single, 6 ' area that is radiation safety with the associated 7 -cornerstones'that if we in fact keep track of and do a good 8 job in terms of what'we do with' respect to the public and 9 operational safety -- I'm sorry, occupational safety and 10 radiation safety, we will, in fact, fulfill our 11 responsibilities in that area. 12 The second area I was going to point out was this 13 area of safeguards. In the original construct, if you will, 14 we talked about reactor plant safeguards and what we had, or ,s(,) 15 we'weren't very sharp in terms of the definition of that. 16 And if-you go back to the words of the strategic plan of 17 what we were really trying to get at in terms of the 18-Agency's mission, we really were trying to focus on 19 diversion -- thefc and diversion of special nuclear 20 materials, sort of the narrow reading, that narrow aspect of 21 _ safeguards. And so one of the things the workshop told us 22 to do, and we didn't have a breakout session that really 23 dealt with the cornerstones in this area as we did with the 24 other cornerstones, but one of the thing the workshop told 25. us to do was to make sure that we do narrowly focus that [ ;( ANN RILEY & ASSOCIATES, LTD. i/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
L d' -n 368-7 -- il ' area; - BecausenifLyou think-about it, the oth'r-aspects;of' e f'}$? -2L safeguards'really.ought to be considered-in the areas under x c3L (reactor: safety. nr 4: If,.for examplei.-thereLis an impact due to the i 1 5: ifact thatJthereiwould be some; safeguards -- some; sabotage of 6'l-iTsome: plant l equipment, you really need to.make'sure that'you i 4. 17- ' consider /that where.it appropriately belongs, in the- ) ~ 8 -initiator; or the mitigation-f system 'and noti' try to hold it 9: out separately and1 treat it as a separate cornerstone. ~ ,10 ,DR. KRESS: Michael, when I go across left to 1
- 11L right on-those cornerstones,'the first four tell me'what to 112 Jfocus oniand:what I can do with itL, but-then I get to'the
'13-Lnext two and they-seem to be'of-a different nature'. -I don't j ~ '14 quiteLunderstand:how they fit'together. I don't know-what p( fp
- 15 1"public" and " occupational" means in the context of how I'm, Tgoingito develop. performance measures.
So I worry about 161 3
- 17 thatLbottom line,Jparticularly.those two because I~really 18' don't know what to do with:them.
l19: MR. GILLESPIE: ' Yeah, I think -- if Mike goes l "20: through it an orderly way,-one of the key elements of the 21. L. workshop,.once you agree on the name of the boxes -- -,-DR.~ KRESS: Yeah. '23: MR.LGILLESPIE: -- is what does the box mean? 24 ,DR. KRESS: Yeah, that's just a name right now. 25 MR. GILLESPIE: Yeah. t 'e#'( ANN RILEY & ASSOCIATES, LTD. b\\ / - Court: Reporters 1025" Connecticut Avenue, NW, Suite 1014 l Washington,lD.C. 20036 1 l: (202)'842-0034 lw en v~ e w s re-, -w
-369 51:- 'DR., KRESS: ;So'there may be.-- a -): 2 MR.-GILLESPIE: We took~that step and I-think'he's- 3 going to -- I I4 'MR. JOHNSON: Right. And incidentally, here is 5-what weLthink-thatzbox means. 'i 16 DR.7APOSTOLAKIS: How about let's go back to the' '7 ' boxes. 8 .MR.sJOHNSON:.Okay. 9; DR..APOSTOLAKIS: I think -- or I thought' Tom was '10 'getting_to the meaning of these. 11 DR. KRESSi 'Well, yeah. -12 DR. APOSTOLAKIS: Because.you see radiation safety 13 - !see, if you lookLat the reactor safety, what you are 14 saying there is for me reactor safety means I have to do- ) [ _15i .something about initiating events, mitigation systems and so 16-on which is sort of deductive kind of logic. You go down.
- 17 LRadiation' safety and then public and. occupational is really 118
- renaming radiation safety.
It's not -- you haven't gone .19 'down yet. Ek) you are putting them on the same level, so s i20 somehow you have to rearrange the diagram to snow that this T21-is a renaming of radiation safety really because you haven't ^22l .done anything there.
- 23 CHAIRMAN SEALE
No, it's not. 24 DR. APOSTOLAKIS: Well -- .25 [ Laughter.] i. ANN RILEY & ASSOCIATES, LTD. r -v Court Reporters 1025. Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r-370 1 . CHAIRMAN SEALE: And I think if you go into what's 7 iwJ: been happening'on the DOE side of the house perhaps you get 1 2 e 3-a better understanding of the differences and the 4 similarities of that problem. 5 There are basically two cohorts that you have to 6 worry about with respect to radiation safety, namely the 7 people that are in the plant and the rest of the public. 8 And that line gets very, very blurry when.you get to the 1 9 case of the scenographer that works in the plant in terms of 10 discipline, in terms of job expectation and so forth, she's 11 a member of the public. 12 DR. APOSTOLAKIS: That's not what I meant. 13-CHAIRMAN SEALE: Yeah, but 14 .DR. APOSTOLAKIS: Look at the reactor safety. The ,-) (,/ 15 reactor safety is violated. If I have an initiating event 16-my mitigation fails and my barriers fail. So I take the 17 same logic, being naive, and I go to radiation safety. So 18 I'll have a radiation safety issue if the public fails and 19 the occupational fails. The logic is not the same. 20 MR. MADISON: It's an.or gate, it's not public. 21 It's an or gate. And the concept that is we violated 22 something in 10 CFR 20 either by an occupational dosage that 23-exceeds some value in 10 CFR 20 or by dosing a member of the 24 public. 25 DR. APOSTOLAKIS: I think if you put those words ( ) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l ~N' R: 'h .371. s gg. _. 3f .(there_;they would;be.consistentiwith thel reactor. -Because: , we right now:publicland occupational.really is a' renaming of 3( p 12
- n. A.h 131 jradiation: safety. -But if you.say,' dose'to the public and.
4E dose lto -- 251 ~ MR'. BARTON: . orkers. W 6 DR'..- ~ APOSTOLAKIS : --Eworkers, then you'are z u [ 7: breaking-it'down'thejsame'way you broke down. reactor safety. ' 8: 'I mean, :it'slnot a big deal. It's just' labeled' R 197 Lconsistently. U l 1100 MR. JOHNSONi I think we're saying that with the 11 1 Idefinitions of the -- 12. [ Simultaneous conversation.] l13. -DR. POWERS: I'm not'sure that just adding in_ ?14 dosage does it for you. 'You;have -- you're describing an. .15' .effeet there and you're neglecting everything that stands in -16:: theLway of~taving-that effect. .17L DR. KRESS: Absolutely. ~ 18' DR' POWERS: And'you~didn't do that in the case of .19 the reactor. 20 DR. KRESS: And, in f'act, I think you would have 21" something similar to the same ones in the reactor. You 122 would-have an initiating something or other. You would have J23l a mitigating something or other. 24: DR. APOSTOLAKIS: Yeah, exactly. r 25' DR. POWERS: Well, you might want to make it more B< i h ' ANN.RILEY & ASSOCIATES, LTD. %/ Court Reporters t 1025 Connecticut Avenue, NW, Suite 1014 L~ Washington, D.C. 20036 (202).842-0034 y
.l 372 l' specific in the sense that you could have failures on the [ )\\ 12 part of the prescriber, failures on the"part of the q 3 ' deliverer: and equipment f ailures. - .4 DR. KRESS: That may be. 5 'DR. POWERS: And it might show up there in the 6 . boxes, but'I don't think~just adding " dosage" is going to do 7' Lanything or you.
- 8 DR. APOSTOLAKIS:
Yeah, but there must be'some 9
- sort of a sequence of events-that leads to public --
10 LDR. KRESS: And that's what you focus on. 11 DR. APOSTOLAKIS: Yeah, because the logical -- 12 MR. MADISON: And I think that will come further 13 on when I. talk a little bit about it. 14 ?DR. APOSTOLAKIS: Okay.
- Fine, p.
- g !
j.
- 15 MR. MADISON:
We're talking about here, this is 16: .the -- the event or the failure of what comes below this is ,17 when you do have a dosage that exceeds 10 CFR 20 or Part ~ 18 100. 19: DR. APOSTOLAKIS: I'm sure you have the logic, L20 it's~just the way the diagram is -- 21 MR. MADISON: Yeah, you're right. As you look at 22- -the diagram they're not -- 23 DR. APOSTOLAKIS: Yeah. 24 MR. MADISON: -- the boxes on the right are not 25: . parallel. /'} ANN RILEY & ASSOCIATES, LTD. ?s_/ Court Reporters 1025 Connecticut' Avenue, NW, Suite 1014 Washington, D.C'. 20036 (202)' 842-0034
373 l' DR' APOSTOLAKIS: Fine. Let's not make a big deal a f[,\\ 2 ~ out of it. 3. MR. JOHNSON: So let me continue on. Then, you 4 know,.we stuck these things around the dash line, human 5 performance, safety conscious work environment and problem 6 identification resolution and we recognized when we did 7 that, that was sort of a sloppy way to try to capture what 8-was - intended by the workshop, but let me try to describe 9 what happened. 10 When-you went back, if you looked at the original 11 construct -- Alan, would you throw that ane up one more 12 time. Sorry. 13-When you look at the original construct, you know, 14 folks said, well, you know, this is all well and good, this O 3 jT 15' sounds fine, but what1the heck happens with human 16 performance. That's important and why isn't that a-17 cornerstone? And, you know, where does problem 18 identification and resolution fit? That's got to be 191 - important. If-you're not -- the licensee is not finding .20-problems and resolving those problems -- and that doesn't -21 sh'ow on-this diagram. What's going on? There are some 22 issues, there are some areas of performance that are 23 crosscutting, all right, fundamental and crosscutting and 24 they don't show up. And how should you consider them?
- 25-Should they be separate cornerstones, or should you consider
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~ -~.- _ _ f 374 i 'l -human-performance,.for example, in the specific - and each (v-s)'
- 2?
'of the: specific,', nerstone? And so then this is just a 1 NL ~ <3 recognition of.the? fact,for the workshop participants that-4.
- we really dolneed1to. deal with those crosscutting, issues.
H -5' 'This isia placeholder to show it,'to'make-sure..that it is-15 . prominent i to L those1 who : consider. the ' philosophical approach. 7 7: But, againi'I mean,.I1really do think-that the 8-consensus of1the workshcp was:thattwe really should consider 91 them,Lagain, in a prominent.way-in the individual 10: cornerstones. :There doesn't need to be a cornerstone that-l 11 is problem identification and resolution. If, for example, J12-a licensee achieves success in.the areas of a. cornerstone, ' 13 J -that must mean that their problem and identification 14 resolution processes are effective and working. j kjj 15L _DR.fAPOSTOLAKIS: So you are already then telling
- 16 us.--
and~maybe-you're right -- that.you have identified the i
- r7
.three. broad areas of the organizational structure and safety 18 Jculture -- the. culture of.the plant that you and-the 15V workshop participants -.not agree -- aligned on; right? 20E MR~.. JOHNSON: Yes. And in fact, this may not'be L f21f Jall inclusive. .I mean,-we talked about other things also. 22 DR. APOSTOLAKIS: I understand that. H L23 MR. JOHNSON: But, yes, that is to capture those l ,1-L 24, crosscutting, sort of fundamental areas that are important V .251 within this-philosophical construct such that we can -- p e t.- ([ ANN RILEY &' ASSOCIATES, LTD. h\\ / Court Reporters-1025 Connecticut-Avenue, NW, Suite 1014 . Washington, D.C. 20036 (202) 842-0034 f ) W W
n, 7 375- ,1 DR. APOSTOLAKIS: AJsafety' conscious work l [
- 2, tenvironment istreally what peopleLcall safety culture; i
w. 31 cthat's.really what you mean? 'dL .MR. JOHNSON: Right'. _j ~5, MR.7BARTON: Right. 16' 'DR. APOSTOLAKIS: Problem identification ~and U ^ L72 resolution that's pretty broad. 8 MR. BARTON: Corrective' action - ' LSU .DR.'APOSTOLAKIS: 1 Yeah, corrective action on the -10 whole thing. So you envision then that there would be other fil so-called, " organizational factors" under-these things,fmore '12- . specific things 111ke what we see very often is that 3 13 organizational learning is a problem. So that would be part H 14- ..of ; the : problem ' identification resolution; - right? y-(3 ) - 15.- MR. JOHNSON: Right. Yes, there could be'other i16s J things that are_crossentting:that are fundamental. 17 IMt. APOSTOLAKIS : No, but I mean,.you intend to 18 ' refine these andlgo down.further? Or this is it? t19 MR. MADISON: 'This was an attempt, really, to make c20. -sure that-the workshop participants didn't forget or did not 21 focus-on:these as very important issues and not bury them in 22 the process later on. There was a concern by the workshop
- 23 fparticipants that'even though human performance -- and L 241 you'll see later as I talk about individual cornerstones, 25-
-you drive down to find out what supports those and what ANN RILEY & ASSOCIATES, LTD. N' Court Reporters a 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l-(202) 842-0034 l l
376 1-makes those cornerstones up. Human performance shows up in _7 3 't 2 each of those, but the concern by the workshop participants a 3 was that that. dilution, if you will, maybe didn't sharpen 4 the focus enough on human performance and raise it to a high 5 enough level. So by presenting it on the chart this way i 6 it's an attempt to make -- show how'important the human 7 performance aspect of problem identification and resolution 8 are. 9 DR. APOSTOLAKIS: Actually, this is pretty nice j 10 because I can take -- I see the analogy with Jim Reason's 11 barriers, you know, that figure he has in his book, where 12 the human. performance is really the immediate performance of i 13 the individuals, the psychological factors and all that. 14 Problem identification and resolution which I ,,() 15 .would put in the middle is really the organization. And the 16 safety conscious work environment is the policy stemming 17 from the very top? That's Figure 7.1, I believe, in the -- 18- [ Laughter.] 19 DR. APOSTOLAKIS: Isn't it?. No, this is the way 20 it works. This is the way it works. So.you go in layers 21 from the individual to the organization, to the top 22 management'that establishes policies and creates the safety 23. conscious work environment or not. i 24 MR. JOHNSON: And I think your point is a good 25 one. And maybe we need to think, as we move forward to make [\\ AIM RILEY & ASSOCIATES, LTD. !.'s /' Court Reporters 1025' Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i j 377' .d -l lt lsure that we've captured..all of:the.important areas that' I 7 %. j-. 2l scrosscut. 1You know, our; approach was toitaks then'the V 13
- cornerstones,fand Alanrisigoing to describe how we did this,-
K4-but-to drive down inLthat cornerstone:and ask,'you know, .y. i
- t 5 c
- whattis --Lif'this co'rnerstone is important, if' this is the-ic L61
. foundation, then whatfisitherinformation that you need, T7) Jwhether that information:comeslfromiobjective' indicators, a-18: what:comes'from inspection? 9 lDR. APOSTOLAKIS: Right. I 10 LMR. JOHNSON: -And so we were< going to' drive down 111 Lin(that way,?and it's_possible:when you do that that you may j 12' miss'some of those areas that'are crosscutting that ought to 'l c,1 j ~13-be considered. And so we at11 east need to considerLthat and j l 14? keep ~that:in mind. .]
- -~
' (_ ) l15 ' DR.-APOSTOLAKIS: One-las't point. I think:if you h 16 .put the problem identificaticn in the middle and move the 17-safety conscious work to the right,rthen you can'also say ~18 that there is'a dependence as you.go from right to left. In y
- 19'
'other words,-top management definitely affects-the i20- ' organizational processes that helps _you identify problems !2 11 and resolve them. ,1 f 22-MR. MADISON: That's true. l23' DR..APOSTOLAKIS: And'then the human performance-
- 24;
- is affected by all of these things.
The dependence issue is 25 from'right to left, or left to right whatever it is. 1 1 if ( ANN RILEY & ASSOCIATES, LTD. -\\_/f Court Reporters 1025 Connecticut Avenue, NW, Suite-1014 l Washington, D.C. 20036 (202) 842-0034
l ) 1 1 m 378 11^ . MR.' JOHNSON: Okay. So'that's the philosophical g f( Y ~2: approach. That was the firstLare of the workshop. And so. , EN J ' R
- 3 owe think we've.made some good' progress and'got some good 4
alignment on the overall_ philosophical approach. ~ f5l Okay. Alan?! 1 6.. DR.'APOSTOLAKIS: So what'is the meaning of the 1 7L four'bu'llets at_the bottom? That'you still havefto do these -8' things?' 9 MR.. JOHNSON: Oh, the four bullets. j 10 DR. APOSTOLAKIS: The performance' indicator, l11 inspection, you still have to do these things, but now'-- 12 MR. JOHNSON: Yes, let me talk about that a little .13 bit. 14 LSo, again,.within.that philosophical approach, [ 15-once you'veLidentified-the cornerstones, then you have the l -16 beginnings of being able to figure out :what is: the 17. - information that you need in each of those cornerstones? L18 ' What:has toicome from objective indicators? What should~ 19 come from the inspection program, or other information? And q L20J - then what should'the thresholds be? Once you have that 2 11 information, how do-you' establish-threshold that enable us 22I to decide as the regulator what actions ~we should take, what J23 we should leave in the words of -- or. sort of in the way 124 that NEI talks about it, what is the utility's response 25l band? You know, it's'then you can get down to figuring out l-c- [\\ ANN RILEY & ASSOCIATES, LTD. l ' LC Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 4 c - 4 m w w ,m
Om 379 110 ,what/theinspectionprogram;1ookslike,whatobjective ?[ g{. indicat' rs'are,.how you. tie those all together, setting .i 2 o %/ \\ 3 thresholdsto: figure out what' action.you.ought to take.. And j i 4 '- so that'sithe meaning.ofzthose~four. bullets =at th2 bottom-of 5~ that. And we'll talk a little-bit more about'how we do that i if as we,go'. ~7' .So next'Alanfis going'to talk aboutithe nextLarea 8; Lof the workshopLand'how we proceeded;thenLfrom this ) 9 (philosophical' approach. L10 MR. MADISON: 'As Mike' mentioned, we started off 'l 110 <with a processLto lookLfirst atithe philosophical-approach,. l .e .12 <: and then_to try to discuss some of what we considered. 13" fundamental issues that we would need to resolve and try to e 14 '; Lreach some alignment'on during the meeting before welcould 'fy (,) L15
- move forwardLand actually develop the. basis for the
~ 16 cornerstones. 17 So the second breakout group cn session -- we 1181 idefined it.as the fundamental. issue breakout session. And v 19; weLlisted in the' brochure'which I hope everybody did get a i C201 Leopy.of. My' understanding was every member of the ACRS Y21. received -- c2 2. DR. APOSTOLAKIS: 'I don't.have a copy. 23 'MR. BARTON: Yeah, I'think -- L2 4 = MR. MADISON: a copy.
- 25 DR. LARKINS:
We only had one copy. E h ANN RILEY & ASSOCIATES, LTD.
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~ 380 'l MR;; MADISON: We only had one copy? Okay. t .2 L .DR. APOSTOLAKIS: I would.like to get a copy of 3 that. '4-MR.. MAD" SON: We'll make sure that each of you has j gg _5 ; one. i 6l CHAIRMAN SEALEi Good. ) 7 MR.. MADISON: We had' listed in.there that-we-18' 1 wanted to discuss the fundamental' issues. But, as Mike- '9 pointed out, we really_needed to do a lot more than that. 10 We needed to -- if not achieve a consensus, at least achieve 11 some alignment-on these direction setting issues. 12 The four breakout sessions that we broke into-were 13 the general policy issues, the use of risk in the 14> ' assessment, and the use of performance indicators and the j p); fq_ _15-integration of performance indicators with this as-well'as 16 .other information sources, and then the role of enforcement, '17. and as a side issue.the communication with the public and 18 with the industry of our assessment, We lused. prof essional f acilitation. f rom LM;.AL to 19. 20 . assist us.in this. But we also tried -- and I think a kind .of a' unique way of doing it with having both industry 21 '22 represented by primarily NEI participants and NRC technical 231 experts.to also facilitate the breakout sessions. 124 ~ The process that we used with this is we had 25 Loriginally set up -- and I'really do wish you had this in ! -[\\ ' ANN RILEY & ASSOCIATES, LTD. \\. /1 Court Reporters i r: 1025 Connecticut Avenue, NW, Suite 1014 ~ Washington, D.C. 20036 (202) 842-0034 t
~.. ~. 1 381 i 1' f ront' of - you. WeLhad outlined basically a process to go 7" xf 2 through and develop. answers or proposed: positions to each'of I he' issues that we outlined for'the groups. L 3 t
- 4' And - -wrong one --
l 5-
- In advance; as Mike mentioned,.with the meetings 6-we' had with NEI, Ewe had developed some of these defining-
.7-issues in conjunction with folks from' industry'and.the'
- 8-publicjin these meetings and we'had come up with-some 19 background informationl some. discussion points, topics for.
10-consideration, and;a' proposed. position. It was basically a 11 strawman' position goingfin~to the meeting to start of H 4 12 discussion. 13-What came out of that then'-- go ahead -- for. 14< example _were~, in:some' cases,:new. issues. We redefined the 15- -issues,'got a -- 11 6 DR.'APOSTOLAKIS: Excuse me, Alan, you are going 17 to a higher detail.than -- I think there is another issue, 18 'maybe philosophical too, you' start philosophy with me, you .19 : don't'get away easily. - 20 MR. MADISON: Okay. 21 DR. APOSTOLAKIS: If we look at'the basic diagram 22 that you'have shown, you know, in its various forms a few 23 Ltimes -- yeah,-okay,. great. Isn't there a philosophical 24' question here as to how far down the Commission -- I mean, 25 the NRC should go in regulating nuclear power? I mean, o.[ ANN RILEY & ASSOCIATES, LTD. N-- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
382 l 1 isn't that a major issue'here because now with this, of f-[/.) !2 course, eventually you will have something that will help us l N_ 3 prevent initiating events; right? Mitigation, system i 4 integrity, and'so on? Then I can have another layer, 5
- another mitigation system pumps or I'll go and make sure all i he pumps work'.~
And, you know, I go down and down and 6 t Ji 1 ~7 eventually I have a tremendously intrusive system. So was-8 that question addressed at all at the workshop, or do you. 9-have a philosophical' approach, especially now with all-this 10 talk about performance-based regulation and maybe, you know
- 11
~12-MR. MADISON: Maybe not-quite in those words, E13 George, but we did address that type of issue. ,14. DR. APOSTOLAKIS: Okay. MAj - 15 '- MR. MADISON: And those are what we would call the -16 defining or. fundamental issues that we needed to address; 17 how intrusive, how leading is leading, that type of 18 ~ question. 11 9 ' DR. APOSTOLAKIS: Okay. Good. Good. 20 MR.' MADISON: And I:think we covered a lot of 21 that.
- 22_
DR. APOSTOLAKIS: Okay. 23' 'MR. MADISON: The first areas I mentioned we 24< called the general policy issues, and the first issue as ~25- -redefined is, is there a threshold of licensee safety ' b). ANN RILEY & ASSOCIATES, LTD. \\_-f Court Reporters 1025 Connecticut' Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
._ _. _ ~. \\ 383 i i performance above which the'NRC can allow licensees to j/h 2-address their own. weaknesses with' decreased NRC' action? And L 3 i think that'gets?to part of your question. In'other.words, 'at what leveliabove a zero-defect tolerance can licensees i
- 4 5
- safety' operate with-decreased'NRC interaction?
The general ~6 answer;out ofLthat group - _and th'ere's.more detail. Please L> '7 keepfin mind that the' workshop just ended-yesterday:and we? l haven't been able:to shift all the answers and put them all-13 - t 9l together in'one place. ;But'theigeneral answer was that, ~ 10 yes, there-is:a level'.of safety performance which could 11 warrant decreased NRC interaction. And I think this is ,12 c.something the NRC.--- or the industry has been' questioning { 13 ,and asking about. 114 That's;the' type of issue in.the general policies -r. ..15, that we address. .The next one was, given.the' threshold -- j_ 16f
- DR. WALLIS
This is.a continuum. ILmean, as they 17-Eget;better'and better, then there's a continuum of' decreased 18 interaction, not just one line? H19 MR. MADISON: That's correct. That's correct.
- 20:
.There would be - .then that's a philosophy change, however, 2 11 and that's why we wanted to ask this question at-the ^ ' 2 21 . workshop, get input not only from -- from:all the 23 'stakeholders, not just industry and the NRC, but the public L247 Las well. 25 DR. KRESS: That goes to your very first slide n l: h [ '\\ ANN RILEY & ASSOCIATES, LTD. \\~- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014'
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384 1 where you talked about the philosophy. Or this-recogni=es i.~ -( h 2
- good performance?
x_,/ = 3' MR., MADISON: Right..But there's a caveat on 4' there. ~If the threshold considers risk insights, or an 5 acceptable level of performance, there is~a safety margin- ~6 below that threshold to account for uncertainty. In other .7 words,1we need to maintain that --1we can't just stop:doing ) 81 what we're supposed to be doing,.we have.to maintain the-9 safety margin. .10 The second 'i ssue that was discussed -- '11 MR. GILLESPIE: I want to make sure -- this is 12 good, I want'to get.-- it's not a continuum though that 1 13-starts at zero. There was a recognition out of the workshop I /14 ithat there-is a baseline of independence at that the Agency 1
- fm k,)
15 .has to exercise, 16-MR. MADISON: And that's one of the other issues I ~17: .that was -- E18 MR. GILLESPIE: And so it's kind of a baseline and 19 then a' continuum. 'So it's not a -- 20 DR APOSTOLAKIS: You mean, zero interaction is 21 'not -- H 122 MR. MADISON: Zero interaction was not really 23' . viewed, I think, by any of the participants as an acceptable 324 place. In fact we need to communicate a certain assurance '25' to the public so that the industry can survive. So stepping l' A--} / ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ~ Washington, D.C. 20036 (202) 842-0034 l; 1-
'385 1- .back altogether.was not a consideration. 3md that was a A "I v). -/ .2-consensus,.that wasn't even alignment, 3 Now,.what we didn't have consensus on is how much 4 .is enoughon the'. baseline. 5 CHAIRMAN SEALE:. Yeah. 6'. -MR. MADISON: That is yet to be worked out. 7 CHAIRMAN SEALE: Yeah. 8-MR. MADISON: The'second issue discussed was, 9 given the. threshold for NRC interaction, what typelof
- 10
' leading indication does the NRC need to have in order to 11-provide.an early indication of changes in licensee 12; performance trends? Do additional performance criteria need ~13 to be monitored to provide a leading indication of declining 140 performance to ensure timely and complete corrective actions y, ,- Q l15. by licensee? 16-And, again, the short answer is that the 17 = assessment process should establish thresholds that would 18 trigger early interventions to arrest declining performance 19 Lprior to becoming unacceptable. And there was a lot of 20 discussion in this area,'you know, how leading is leading? 21' You know, do we nend to get deeply involved in a licensee's l 22 interactions'with the.'.r personnel, or do we need to step l 23-back and have more of~s performance indicator type paradigm 24
- where we look at performance indicators before we get deeply L25
' involved in the aspects of their performance. fx i \\-)- ANN-RILEY & ASSOCIATES, LTD. 1 Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 '202) 842-0034
386 1 The next issue was, can the NRC place mor emphasis ,~ ') ' 2 on licensee-generated information to perform assessments and w,- 3 still maintain its required independent regulatory oversight 4-function? 5 The answer -- the short answer is, yes, the l licensee can place reliance on licensee-generated 6 7 assessments. However, the NRC need to ensure adequate means 8 of validating and verifying the data.used in this regulatory 9 and decisionmaking process to maintain that independent 10 role. One of the core values of our Agency. 11' Issue four, and it's -- 12 CHAIRMAN SEALE: Was there a consensus on that?- 13 MR. MADISON: That is the consensus answer. 14 CHAIRMAN SEALE: Okay. (y '( )- 15 MR.. MADISON: Whet I'm talking about now is really 16 the outcome of the workshop. 17 CHAIRMAN SEALE: Okay. 18 MR.-MADISON: We went in with -- 19 CHAIRMAN SEALE: The proposed position then is a result, not an input? 21 MR. MADISON: That's correct. 22 CHAIRMAN SEALE: Okay. 23 MR. MADISON: Rather than give you the going in 24 position and then talking about the changes, I'd jusc rather 25 give you the output of the workshop. And in a lot of cases rm. ( ) ANN RILEY & ASSOCIATES, LTD. \\- / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
387 1- .the going imposition or the proposed position and the output jv,j 2. were very similar. Because'as I mentioned earlier, we had v m3' discussed this in_public meetings with NEI and others. L4 The-fourth issue, as Frank mentioned earlier, is
- 5' given.
And we started off with this position: "Given that-the'NRC'will: continue inspecting selected areas of licensee . 7.- performance,' how should NRC inspection findings be factored 8' into~the regulatory oversight. process?" The overall l
- 9 consensus of'this group, and again, a short answer was to I
10- . validate the accuracy of the performance data to be ensure d1' or to be used to assess the risk of significant areas not j 12-adequately covered by PIs. '13 In other words, part of the funct sn of the NRC 14 should be to make sure that these PIs are valid and that we /3. (,,{. L15 ver'ify.theiriaccuracy. 16 MR. JOHNSON: Alan, can I just -- of all of the 17 areas of all of the defining issues, this was the one, I 18 think.that we left the workshop with sort of the greatest 19 -sense of unease. I think there was alignment. There was 20-agreement that you're going to do this inspection and you 21-have to somehow have a way to look at what comes out of 22 inspection-and bounce it off what comes out of the objective 23- . indicators, should they be different?' But there really was 241 a: sense of unease on the part of folks with how you do that. 25 ~ And, you know, we really struggled. This was the-aspect l / ANN RILEY & ASSOCIATES, LTD. A- - Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
~.. .. ~ - -. ~-.. . - ~ ~ --~~. 388 l> l' that we really' struggled with, with respect to the IRAP / ~ '} 2 process. -You know, that whole scheme that we went on in ll N J ste'ms of lo' king at enforcement, you know, the severity 3. r o 4~ level of' enforcement actions, the whole purpose behind that, 1 5-nowlI think I can say " cockamamie scheme" now that we've j g 6-moved beyond it, but we.really thought it was reasonable-at 7 .the time. 8 The whole: purpose behind that.was to try to put ~9 some ' significance measure on the individual issues that roll 10 ~out of'an' inspection. And it was trying to -- we were { 11-trying to deal'with, how do you take what you get from 12' inspector.in an individual inspection, and how do you ~13 somehow ro'll that all up so you can-compare it with the more 14 objective things that'you have? And there still is a sense -( / L15 .of unease'about how you do that and we're not sure how you ~~/ 16. do that. One of the things;that we decided ~as a. result of 17' this group on this defining issue was that the objective Lindicators ought to form the rebuttable presumption such 18 7 11 9 that:if you get the right objective indicators and they tell 20 you that-a plant is green, for example, that is, the plant 21- .is/ good, they're not crossing that threshold,.that ought.to 22 be the' rebuttal presumption such that you've got to have 23 l compelling' reasons on the part of the insights from 24; . inspections-to overturn that, but how you actually factor u '25' that in, I really do think that was an area that we still y '(]J ANN RILEY & ASSOCIATES, LTD. 1\\. - Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
389 1 titeed to-dola lot of. work in terms of figuring out how it all ['[ [2; (comes'tegether. .It manifests'.itself in folks saying, well, v.- E3 :
- you~ know, the assessment process can~ consider inspection 4-
.results. When I.get to objective indicators and roll them is .up,,:that?had better give me the assessment.and that's got to .'6 'be green. :And thenLif-the-stuff that comes out of-7? inspectiongwasia little bit different, then we need to' find 8 a'!wayito talk about it:in the public in'a public document 19.
- such that we;can'put it in context, but it shouldn't change-10.
-my green to a white.or toLa red. You know, we need.tofdeal 111~ ewith that issue, it's important. 12 But, again, I think-we do have alignmentLon the >13 ffact that-you need-to somehow consider them with the
- 14:
objective indicator forming the rebuttable presumption in g4 .g) L151 Lthose situations where you have sufficient objective
- 16 indicato'rs.
17i MR. MADISON: Actually, Mike jumped ahead. That '18 was another1 breakout session. And part of the concern -- 19 MR. JOHNSON: It's okay. .20 MR. MADISON: -- well, part of the thing was, we di-had'four_ parallel breakout sessions going on, and it's hard, e22E
- when you talk about one issue, it's hard not to talk about 23'
'theLother issues. So this discussion and this breakout 24:
- session ~was one of the larger breakout sessions.
I think we 125: had'87 people originally signed up for the breakout session. ANN RILEY & ASSOCIATES, LTD. ! 4%- ' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l. r
390 '1 So-there wasia lot of discussion going on and a' lot of work L2l to get just to"these four conclusions. d. 3-MR. JOHNSON: Right. And I guess my point was l4x that in>this general -- I' sat in on this general' policy j ~ 5 igroup and that was their concern with. respect to this issue.
- \\
6l .And;you're right, Alan, it was reflected in other issues -- c; 7 breakout sessions. 8 DR.,KRESS: I'm aLlittle surprised,at that-9' _particular one. I'll tellLyou why. Number _one, I'm not f '10- .even sure'I know what it means, " proposed position",1but it-1 i 11l .would seem to me that_your inspection' process is your 12. -fundamental way of measuring'the performance'indicat'rs'. o 13. That'is how'you determin'e and quantify the performance 1 14-indicators'you-end up_with. ,gr~ss And that, you know;.I'm reading
- ()
15-the issue, how;do you use-the inspections? You use it to ~16-measure your performance. That's the measuring tool. But t ~ 17l -- and:I'm not sure what the' proposed' position says.- I 18 don't.know, maybe you_couldiclarify it a bit.
- 19-
'MR. GILLESPIE: Yeah, let me try that, Mike. We I -207 -may actually have then'miscommunicated the: philosophy going '21) in just based on what_you just said. Part of the proposed 122 l position was -- one of'the problems with IRAP-was the 23-grading; process. _Part of-the proposed position is that if 24: !someonefhas some set of indicators that'we can agree upon, 1 7 25- .or a're'asonable reflection of operations and those I
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~ ..~ 391 l1l? indicators are in a satisfactory, zone,.that is their .,3
- (d R
- 2
_ assessment, they're satisfactory independent of the i l 13 inspection,results., The inspection results then become an-41 Lindependent check against the rebuttable presumption.that it 5 ~ Jis satisfactory. 6
- And'what~we' haven't' dealt withLis, how much is i
7l enough from inspection to.ask two questions: one, you have d 8 -the wrong 1 indicators because the indicators'aren't telling. N H 9 you.that this terrible problem inspection' sees exists; and q i 110L two, what do:you do on a. plant-specific basis when you come d 11 'out with'some. preponderance of information on something?. We '121 . haven't dealt.past-that. I think we've recognized the- ~ i
- 13-conflict and that's what kind of came out of this session.
1 14 And what Mike is reflect-is, I__think~there was'a. p;b 151
- sense'that.you don't; weight objective performance indicators j
161 with.a beta factor from inspection. Okay. So if'you_ don't~ 17 weight them and?say, okay, you only get half credit for'not 18~ having'any transients last year.because we saw this in '19-Dinspection which would be a very complicated and convoluted _~ 20 process to'get into. Then what do you do with the '21 ' inspection res~ults if they're high-risk, very significant, )22~ ' repetitive?- And'we haven't figured that out yet. And I 23 think that's what Mike is saying. Jmd this was very, very
- 24 -
' controversial because the give and take in this whole .r E25 process is that we'll do this in a rational way. Jl ANN RILEY'& ASSOCIATES, LTD. ' VN-Court Reporters ~1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
.m. _1 392 'l 'I mean,--the idea _being;that there is some d r. f 2 satisfactory: operating _ band which a utility or unit can ! A_ e s ~ 3
- operatewithin,.and as long as they: stay within this band 1
i 41 they'refsafe. I mean,.it's a recognition. 5-It's -a tough question and I'm afraid we don't have 6' the-answer.to thatlone. .7~ CHAIRMAN.SEALE: But.part of the problem is,. if' ) .10 lyou look'at the_ nature of a performance: indicator as they L9 LareLpresently. defined'by One-0 or..INPO or NRC,.any;of:those" 10-very closely-related set of measures ~ in essence there is'a j , number'or observation that gets processed within the utility ' 12 : lor within'the community of theLutilities and essentially.is 113; =passedLfrom_the.' utility'to the NRC at the_ level;of top = 141 management, really. _The inspection process - 'and they're' W -A 15 rec'eived at the: level _of top management in the NRC. 16 ' The: inspection process requires intimate . 17-Lcommunication between working. level' inspectors in-~the NRC, 18 and-. working level operators, mechanics, supervisors in some ' 19l Jcases,7but notimanagers in.the utility. Now, the problem 20' is;. how do you compare data that flows in this channel with ' 2 11
- ' data that flows in'this channel in' coming up with a true
~ 322?
- assessmentiof what--the. utility is really doing on a 23
' day-to-dayLbasis. 3 524; lMR.. MADISON: We may be able to get into that'a !25 little bit more'as we drive through the structure -- the f ' ANN RILEY & ASSOCIATES, LTD. 5,/ ' Court' Reporters i L1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C. 20036 (202)_842-0034 \\ F k 6 w-w s e
m ~ 393 ' supporting structure for each of~the cornerstones. lL ~ [ 2: . CHAIRMAN SEALE:.But isn't that really the v 3 .. difficulty you have? 4 ~ ~MR.-JOHNSON: Yeah. 5 MR.l MADISON: Yeah, I'think you have to define 6: what:the indicator is supposed to-be looking at. -7 CHAIRMAN SEALE: Sure, sure, sure. 8 -MR. GILLESPIE: And_then you'need to verify and 9 validate that what the indicator says is a correct, '10 2 reflection of what-it was supposed to look like. 1 11 CHAIRMAN SEALE: But.'it gets cooked and distilled 12 and -. i13' MR. GILLESPIE: 'Well, and that's one of the ---the 14- 'other thing;that was' discussed in the workshop and I don't P-Q.
- 15-know that we're. going to be able_to go through three and a-
~
- 16 half days of every' session here.
I looked at the pile of 17- 'viewgraphs and 1[ got worried. .But, as Mike said, what 18, information do you need to make a decision on this
- 19 objectiva?
Where'does the information come from? !- 2 0 ' And one of the things that the workshop 21{ participants in the cornerstones asked.is, where does the 22 information come from? And this worried me and I charged 23' the. workshop with this specifically in a plenary session, if 2' 24; J the data has to go through a convoluted algorithm that no 12 5 one understands, then it doesn't meet the criteria for what ' [Y ANN RILEY & ASSOCIATES, LTD.
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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
394 1 I would consider an indicator of actual performance. And so ') 2 .the people went in and did a really -.tried to take that j 3-on. We haven't gotten there, but that was kind of a 4 in-going condition. 5 In one of the comments I had in the hall, they 6 said well, we could have all this stuff go through this 7 party and they would' collect it and they would give it to 8 you. And I said, well, now, if it goes through that party 9. now I have to defend why it goes through that. party, 10 shouldn't it just come from the unit to us. Just as a i 11 license amendment that the unit says that this is true and 12-verified data and this is what we'believe really happened. 13 So if this goes through some complicated algorithm 14 through the epic system and some reliability calculation ,3 ' () 15 we're going to spend all of our time focused on the 16-calculation and-not the indicators. 17 CHAIRMAN SEALE: Yeah 18 MR. GILLESPIE: So that's kind of an in-going 19 thing that'we're trying to stay really focused on. 20 CHAIRMAN SEALE: Okay. Good. 21 MR. GILLESPIE: It also should be something that 22 the< inspector can see at the site. He can see scrams, he 23 can see transients greater than 15 percent that were (4 24 unplanned, he can see systems that didn't work when called 25-upon. We have to get it down from that management level [' } ANN RILEY & ASSOCIATES, LTD. 'V../ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
E ' 'r, ~395 l'
- everyJsix~monthsfat six months old to.the worker 11evel.
l ~'s% "2 CHAIRMAN SEALE: 'Okay. 13; HMR,;GILLESPIE: So this was tough. I,, .41
- CHAIRMAN SEALEi I believe you.
~ l 5: MR. GILLESPIE: -We didn't get an answer, butyI ,y' '6L 'think. Mike got alignment and direction. JWe got a direction' <7j .-to go'in to'asklsome more questions. -8 CHAIRMAN SEALE: ' Yeah. 9 'MR; MADISON:.Actually, that's a good lead-in. '10 The. workshop.probably' developed more questions'than it-2 l11 answ'ered that:we need to keep working.on and try to' develop ) il2- .some"of thosejanswers' For example, one of the<other issues 13 -that-came outJof this portion of the workshop is the NRC.-- 14 we need:also to develop ~a controlled feedback' structure for L/'T 1. (,/ s15 .the.NRC'and the licensee to evaluate new processes. We "16H 'might set 6p something -- in other words, we can't remain-17. static. We're going to have to be-dynamic with whatever 2 ~ 18 system we. establish. L191 The.other' area, the second area was a use~of risk 20-insights into the assessment. Besides answering some of the '21; issues or trying to define more of the issues, there were
- 22
,some other comments or decisions that came out of this t 23-portion;of'the workshop. The decision that risk informed l24 insights and indicators should be used.to focus resources on 25'
- those areas of greatest importance to the health and safety f'N q
ANN RILEY & ASSOCIATES, LTD. f^ 'b' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 t ,,-e, y-e --y
-396 a . of the.public was;one'of.the recommendations that came out L :,-,F 2-of this portion'of the workshop. (d 3 'Alson'a, definition of what this group considered .4 -risk informed - they. felt was important. to. kind of reflect 5 'what their. understanding'was and where they were' coming 1 6' 'from'. And their' definition'of risk-informed was that it 7, considerfconsequences and probabilities.of those 8 consequences balanced with operational experience and 9i existing regulations. -And=I know'this sound maybe'too i, 10_- < general,1but?the really did help focus some of the-
- 11?
' discussion that went on-later. 1~ '12 The first' issue that was' resolved was, to what- ~ 13 extent should.the performance indicators and their j ~14 associated performance thresholds be risk-informed,'and what kJ i is the' role of deterministically-based indicators in an. 15
- 16 -
oversight process and what process and criteria should be 117 followed to select thesez information= sources? Again, a lot 18' of! questions'. The simple answer isLthat Pls and other s 19 measures and'their thresholds should be risk informed to the 20
- maximum extent practicable.
It took a-lot of discussion to 21-get to this point. - 22: 'DR. APOSTOLAKIS: I don't understand why it took 23 7 discussion. I mean, isn't.that obvious? -24'
- (Laughter '. ]
- 25 MR. GILLESPIE: No, it wasn't. L ^ h , [ d'. ANN'RILEY & ASSOCIATES, LTD. 5-- Court Reporters 21025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)-842-0034 4 d ( m Tw-W-- e
397 1 DR. APOSTOLAKIS: Well, why wasn't it? ) 2 MR. GILLESPIE: Because we had 300 people with 3-extremely diverse views coming from many, many backgrounds 4-and I'll tell you, this includes some of the industry.. 5- . people. It was real hard to give up the design basis as the 6' Bible. Real tough. 7 DR. APOSTOLAKIS: It's a matter of education. 8 MR. GILLESPIE: Well, there's two sides to it. If 9.- -you start looking at risk, that means you may look at things
- UD that go.beyond--the design basis that we don't look at today.
311 Juxi there's some sense in some industry quarters.that don't 12- 'let the regulator get out of that box. I mean, you know, \\ 13 that's here. l l'd CHAIRMAN SEALE: Better the devil you know than Q) 1h the devil you don't know. 16' MR. GILLESPIE: And there's some of that. And 17 -there's some NRC people, and we had a variety of people 18 there who felt far more comfortable with they comply with 19' theftech spec, do they comply with their admin limit, than 2-0. saying, I'm going to be told to look over here. They're 21 still required to do this, but I don't have to look at 22 everything they're required to do if I'm focusing on the 23. most risk-significant things. And it was a two-way street, 24 it was on both sides of the fence. 25 DR. APOSTOLAKIS: So I guess -- yeah -- t /~m ) ANN RILEY & ASSOCIATES, LTD. / ks/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 398 1 MR. GILLESPIE: It was interesting. ( 2 DR. APOSTOLAKIS: After your explanation, I think j 3 I understand what's going on. Intellectually this is an 4 obvious position. 5 MR. GILLESPIE: Yes. But practically it's got ) 6 some challenges. 7 DR. APOSTOLAKIS: Okay. And I agree with that. 8 MR. MADISON: And there's a clear recognition that 9.- the regulations -- we're not abandoning the regulations. 10 DR. APOSTOLAKIS: No, no, no. We're just trying 11 to change them. 12 MR. BARTON: Let me make a suggestion. Since 13 we're to run short on time, can you just kind of highlight 14 some of the other issues.and then go to your wrap up -- last 15 -three' slides. Because we can read the issues -- x' 16 MR. MADISON: Maybe we can stop with.some of the 17 -issues and we can move on to the third area. 18 MR..GILLESPIE: I'd like to spend just a few 19 minutes at the end giving you some insights of problems that 20 we may have as we go forward. 21 DR. APOSTOLAKIS: One of the issues that I would 22 11ike to -- or a question that I have is, you had in the old 23' -scheme of things that decisionmaking logic or what did you 24-call it, logic -- 25-MR. JOHNSON: There was a -- I guess we called it .[ / ANN RILEY & ASSOCIATES, LTD. k-Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
~. 1 1 H i 399 .1 a process -- [h -2 SPEAKER: It.'was'the -- diagram. p 3 MR. JOHNSON: No. Are you talking about'IRAP? 4: DR'. APOSTOLAKIS: Yeah, there was a little diamond i 5 that-you'had -- 6: MR. MADISON:: The decisionmaking -- the '7' decisionmaking diagram. I 8'- DR.LAPOSTOLAKIS: Yeah,' yeah. Is there an 9; equivalent-or; analogous step here? ~ '10 IUI.. JOHNSON: Not yet.
- 11
DR. APOSTOLAKIS: Okay. 12-MR. MADISON: Not yet. Because that's next steps. 13-DR. APOSTOLAKIS: How you.go from'the indicators .14 to the objectives -- p.- i ( s/( 15-MR. MADISON: Well, not just the indicators, but ~ 116-all.the information. .17-DR. APOSTOLAKIS: All the information. Okay..Go 18 ahead. CHAIRMAN SEALE: Inspection results, all of that. 20! MR. MADISON: All of that. And what I wanted to 21 gettinto next'is a little bit more of the. detail cornerstone
- 2 2.-
development. We started this portion of workshop out -- 23: again, trying to do it from top down from each of the -24 cornerstones, we broke out.into five workshop or breakout 125:
- sessions, dealing primarily with,-if you'll remember the L
?! IT ANN RILEY & ASSOCIATES, LTD. U:k s i Court Reporters ~~ 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
400 p. 1; ~ diagram, the first four boxes from the left and then the 1,P~Q u l radiation safety issues, ( ): 2; .m/ the radiation protection issues L3 tri~ed to combine those. And part of the' outcome of that '4 breakout" session.was.the changes that you saw in the 5; cornerstone diagram. We asked them to answer questions, and 4 6 "you'.11 see'those as' basically objectives at the top of this L7 1 slide / was'to identify the. objective..and the scope of_that ~ 8 cornerstone, basically to find-that corncrstone and. identify 9-Ethe objective and the scope; identify what desired results .10 and then the' attributes that may affect or have impact on r11 .those results. And we; talked.about some of those' earlier, 12 the' human performance attributes and so on that may have-J 13 ' impact. AndL then identify what should-be measured f.o make. 14-sureithat the desired results~for that cornerstone are O)f (,. -15 -achieved. And then discuss other areas Lthat.could be 16 monitorediand other information sources 1that m'.ght be used 17 -to: determine what performance is in that area. '18 And basically the reason we did is we wished to 19 _- develop a construct for each of.the cornerstones that would
- 20 look something.like this.
This is not -- you know,-this is .21 notTthe final product that came out of the workshop. This 22; is something we developed l prior to the workshop to give the 23; ' participants an idea of where we thought we were headed. 1 24 And the' idea'being that you start:off with a cornerstone, 25; for; example, the mitigation systems here, and then determine 'N].. . ANN RILEY & ASSOCIATES, LTD. -'x Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) '842-0034
'-'--'---'-----'---'"-'-'-"----------"--N' 7--- ---r'---r-- .401 '1: whatuarefyou concerned about?. What aspect of that are the /p y L L 2-Ldesired\\results'that you have? And this -- our,particular A_/. .j 3 group 1came up with three aspects that we would be concerned 4 aboute availability, reliability, and capability of the !F
- mitigation' systems.
And then, what attributes of.those 6; would-you be~concernedfabout? We're concerned'about 7 common-cause failure, the human performance aspecP.s -- '8 ..DR. APOSTOLAKIS: And that's-where my earlier 9-question becomes. relevant now. How far down do you go? 110' MR. MADISON: Right. How far down'do.you go? 11 Well, I think_you'll see that we' don't necessarily 12 have to -- we~have to consider down, but we' don't 13. necessarily have to observe or intrude all the way down into .14 the' diagram, but we do have to look and consider what is (D (_). 15. important, what things do we need to measure then to assure 16 ourselves that performance in this area is acceptable. 17 DR. APOSTOLAKIS: Now, a related question which is 18 .related also to one of the alignments you showed earlier. 19' Is there'a dynamic element-here with respect.to the 20; definition of the performance indicators? In other words, 21-you are observing a plant for a number of years, they're 22 doing great. Are you going to then say, well, gee, maybe I 23. shouldn't be looking at 19 PIs anymore, maybe I should be 24 looking at 14 for a.while because those guys know what '25 they're doing. Is there an element of that anywhere here? .b ?%# ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
402 11 MR. MAD' SON:.Not nec'essarily in the PIs, but-I rs: 7 1 ~2? we've talked about.this. And'this was not necessarily a V l3 .subjectTof this1 workshop. I think~it's something that we'll. .s 4 'probably explore'in depth in the next steps. It.was more 5' the idea _of' frequency'of interaction..If we find-in an area '61 !thatutheiriperformance'is acceptable and in the green band L7 'continuouslp and we have an inspection procedure-thatcgoes 8
- out;touverify'and val'idate that, but it never finds a 9
.; problem, then;werneed to change --'maybe expand oreincrease '10 'our frequency'of going out there by.. changing our frequency ~ 11 .so that-we don't-.out there as often. Is that -- 12 DR.'APOSTOLAKIS: That's also --
- 1 31.
MR. MADISON: Were looking at that in -- 414-MR. BERTON: 'Similar to'the QA inspection programs 15L DR. APOSTOLAKIS: Sure.
- .16 MR. MADISON:
Exactly. 1 17 DR.~APOSTOLAKIS: In.other words, the dynamics i i 18 should be both ways. If you find something wrong, then you 19L look -- j
- 20>
MR. MADISON: More frequently and more in depth. l 21 HDR. APOSTOLAKIS: :That's what I'm saying.
- Now, 122' what-it'the' other way of more deeply?
You go up. f 123; MR. MADISON: 943 are going to determine a baseline
- 20
- inspection = program.
And basically the baseline inspection J25 ? program I think is our' basement level. That's where we -ANN RILEY &. ASSOC'ATES, LTD. 7_h-Court Reporters 1025 Connecticut' Avenue, NW, Suite 1014 Washington, D.C. 20036- '(202) '842-0034 L-if
403: l 1 ' don't. drop below that'. [^Y 2- ^ DR. APOSTOLAKIS: Anyway, that's a: detail for the. 1 . kJ. 3 Jfuture. I'mean,..weLare, running out of time. 4 MR.; MADISON: And I'm'sorryffor taking up a -- 5. DR. KRESS: I was going to say,oI_wouldn't want to 6 support: George's ' changing the looking' at the number of ' 7 . indicators,1because what'you're doing is.looking at.part of '8 'the problem and then - you want to keep the whole problem, 9 but change the. frequency -- ) R10 MR.~ MADISON:.Our goal is to find that minimum 11 number of indicators that gives us the complete picture of 12 the performance to the plant. 13 DR. KRESS: And you don't want to mess with that?- 14 MR. MADISON: No. We don't want to look at t/~% 4) 15L unnecessary numbers,-but -- 16. DR. APOSTOLAKIS: Well, you could work around it. 17: But that's a detail for the future, I think. Because, you 18 know, in the hierarchy you go one step up. You still have 19 completeness, but now it's not the same thing -- well,
- 2'O anyway, I don't think that's something --
21 CHAIRMAN-SEALE: It's like PRA completeness is a 22 detail -- 23 [ Laughter.] l24 MR. MADISON: The point of this diagram was -- 25 DR. APOSTOLAKIS: Why do you say such a thing? [~'I ANN RILEY & ASSOCIATES, LTD. l ?% / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
,~. I k k 404 o. 1'i -MR'.' MADISON: Wi need to be.. complete to at least'
- :, 3
' :( J 21 . start out, AJ 3 . CHAIRMAN SEALE: Yes. L <4 MR. MADISON: We.need to start out and look
- 51
- completely at everything that.we should be concerned ~about,-
6- 'everything that we should: measure to get-confidence of that 7' farea, of~that-cornerstone..The next. step was to identify 'i L -8
- performance indicators.that may give an indication of (9l (performance in that' area.
And the' diagram here shows how a ~ -10
- performance indicator may touch on.more than one: area.
For 111' ' example,Jin the' mitigation-systems' area, ifLwe-use -- I
- 12
'think we're_using. availability information here - may tell p ~13' 'youlorLgive youL some indication not just of:howfthe
- 14 Lmaintenance system is working,;but how the humans who
- M M,)
- 151
- operat'e that-maintenance' system are working. : So"you get-i y;
.16 ; more than one11evel of indication with'one performance s -171 indicator. f L 18' 'What'you-then need to identify is where the holes o
- 19 are?. Where'doesn't the performance' indicator give'you'an.
' 20' . indication of performance, and'is that area critical? For
- - 21 example, human performance during accident -.during events.
. 22. .Th'e' availability indicator doesn't.tell you how they're C23 going to react during an event. So maybe you need to.look
- 24 fat'.-an1 inspection activity'that look at requal exams or-25" (qualification exams"or' qualification-testing of'an operator 4
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- 1025 Connecticut Avenue,'NW, Suite 1014 Washington, D.C.
20036 1(202).842-0034 y i
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- 1; g
ii - 2. CHAIRMAN SEALE: -Simulator. 4 x..sf 3-MR.IMADISON: ' --Eto give~you'the simulator' exams. '4 ~ to make;sure that'you have:that comfort level, f .5 And finally,: the inspection program as we defined' 6' in theLfirst break outisessi'on should verify and validate 7i .this-performance indicator. This will help us then lay out 8o Lwhat we're going'to look at,.and then the next step that 9 1these groups we're trying to define was to give usLsome idea 1 10-Lof'where these' thresholds in here might be for our action .I .11; ' levels. And as NEI's? proposal for the' green to white, and-U 12 white to red bands, we use something.similar like that, 13 where would those thresholds be, what criteria would we look '14-at to select.those thresholds? And then somewhat of, what f) - () 15: is the interaction then.of-how would you combine performance ] 1 16 indicators, inspection, other information sources such as-17 'LERs, because we're not going to stop receiving LERs; how 18 are we going to combine that information? And the -19: discussions then got into that type of work. j -20 Again, we don't have a nice picture of what that I 21' output looks like right now, but that -- we're collecting 22-that data. We're going to establish some working groups and
- 23 Mike is' going to talk to you about what our next steps are.
24 Any questions on this? 25 DR. APOSTOLAKIS: By the way, what is the ultimate - (A.L ANN RILEY & ASSOCIATES, LTD. \\- Court' Reporters 1025 Connecticut' Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 I'
406 l' decision here? ' ;jg.; 2 MR. MADISON: Ultimate decision? %/ : 3-DR. APOSTOLAKIS: Yeah. You've done all this? 4 The top; box says,." protect public health and safety". 5 MR. MADISON: Uh-huh 6; DR. APOSTOLAKIS: So you declare yes, that we are 7~ protecting.it? Or you're going to have a watch list again 8 or what?. 9 MR. MADISON: That's yet to be determined. 10 'MR. JOHNSON: Well, ultimately what happens is you 11 take.the work that comes out of the diagram that Alan has 12 just put up. And, again, you can figure out what the 13 inspection program looks like, " inspection" meaning the H 14 scope, you know, looking across all these areas, the depth, l' (,L 15 the frequency, and what resources you're going to put on it, 16 and that defines your baseline. And then the assessment i 17 process piece of that is then to take -- with the 18' established thresholds it's to say, now, here for a 19 particular plant is what that's plant's performance is with 20 respect to objective indicators that established a rebuttal 21 presumption, and the other information, and what that tells 22' you, if you apply those against that threshold and say, now, 23 a plant.is in the green. Then that tells you if the plant 24 .is green, then that' tells you from our perspective that in 25 fact that plant is doing okay with respect to that -{ g~s,j' ANN RILEY & ASSOCIATES, LTD. -/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
~..., l '407 11 cornerstone, so.weLhave.a high degree of confidence with' ,y;d{. 1 i - i)S srespect to-our overall,public health'and safety mission that ,21 Q '3 that1 plant-is protecting.-- adequately' protecting public + L ' l4 > health and!safetyr ~ 5~ DR./APOSTOLAKIS: Well, presumably all of them do s - 6" Ithat. T .MR.1 JOHNSON: Right. Right. 8 DR.' APOSTOLAKIS: Protect the~public health and E9-safety adequately. .Th't'sfthe. topic. 1 10 MR. MADISON: a 1L1 -DR.'APOSTOLAKIS: But.then you also go --- ) ,12. MR. JOHNSON: Yeah,Lbut you.could_have a plant ) n13 -thatTforfexample would be a' rad where you-would have -- i 14-DR. APOSTOLAKIS: Okay. LI. MR. JOHNSON: 'Right. !16 ,bGl. MADISON: Right. And I think your question 17~
- really gets into;the decision ~ tree --
18 DR..APOSTOLAKIS: 'Yes, , 19 : MR.-MADISON: the action tree for what the 20 output.for the green or white and red means as far as what 21 action does'the-NRC take-. 22. =DR. APOSTOLAKIS: Right. c23 But. JOHNSON: Let'me just --'I'm going to talk for 241 Lanother minute and then, Frank, I know you said you wanted }25-to:say_something, and then.I guess we'll be done. t l 'hk ANN RILEY & ASSOCIATES, LTD. ~ N~M Court Reporters H. 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
~ 408 ll! The deliverable for;the' Commission is by January .I T 2 ito have recommendations ~for the assessment process. And we \\J '3 need recommendations.for changes to the inspection program. L4' I think, again, we've talked about how those flow out of 5 this philosophical approach and the detailed work that you '6 Edo. And so we're going to provide that. We have a lot of; 7-
- work to do between now and January obviously.
In getting '8. there we have a couple of showings or a couple of meetings ,9 Ewith the ACRS between now and then to tell you where we are 1Q, 'and to get your input. i 'll We'have a' Commission briefing on the 2nd of 12 November to'give the Commission the status of our-activities 13-and to get'their feedback and guidance, of course. 14 DR. APOSTOLAKIS: Excuse me. Before January '99 ,m. ( f 15' then we will'have:a chance to read your recommendation and L16 meet with you? 17: MR. JOHNSON: Absolutely, j 18 MR. GILLESPIE: Yeah, we've got that scheduled for 19 December to-try to' meet in December. So if you felt
- 201 warranted to write a letter --
21 .MR. BARTON: That's alroady in our future 22-activities,.that meeting. .23 DR. APOSTOLAKIS: So the December meeting -- ~. 2 4 'MR. BARTON: December meeting. .25. DR. APOSTOLAKIS: -- we are writing a letter? j i i l ANN RILEY & ASSOCIATES, LTD. \\_/ ' Court Reporters i. ~1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 .i
1 5 ) 409 j . 1. MR. BARTON: Yeah,Lwe probably will. 2 DRE APOSTOLAKIS: 'We won't? Af 31 MR. BARTON: Yeah, 'we probably will. ~ 4
- !G1. GILLESPIE:
We also have a subcommittee ~ set'up 5 sfor-November 20th. a '6 DR. APOSTOLAKIS: That's the:one. Okay. 7- .MR. JOHNSON: Okay. So-we recognize we have a lot i 8 of work to.do. We are going to be' working with all of'the '!r stakeholders. We've got a lot of. work to do internally. 'We 1 H 10-are also anticipating' working with NEI closely on[the-philosophical approach-and how youfdrive-down.in each of i 12 these areas'as'we.did before-the, workshop to make sure that ] ? 13-when we walk into the recommendation at the final 14.' presentation to the' Commission in January that we really .r's - ,~ , [( ) 15 have scoped out folks' : views 'and incorporated them' into this ] 16 Loversight process including inspection recommendations and' 17-asnessment recommendations. That's where we see ourselves l 18 goin!;r, 19 MR. GILLESPIE: I want to say just a little bit 20
- about the obvious that's now coming to not be obvious.
And 21 what Ger:ge pointed out, he says, well,. risk-informed. l 22 That's obvious, how could anyone argue with that? But, when H 23; .you hit the real world you get problems you hadn't i- [ .241 anticipated. Everyone'can agree with the philosophy but the 25 ' implementation is a real-bear, i .[ ANN RILEY & ASSOCIATES, LTD. %/ Court Reporters .1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 4
- 410, 1'
-I met with some risk people yesterday. And just ,m. r( ~ 2 . asian example,'we talkedLover the scram indicator that NEI -s a 3 =had proposed. And the risk people said, well, ten scrams a -4 year is not necessarily risk significant.,And in a .5 calculational sense,cthey're probably totally right. 'And 6
- they say,.well,JitLdepends on the scrams,.da-da-da, ten E7"
-random scrams aLyear. And I said, "Yeahj but any plant that ' 8' J has ten. scrams a year is operating in such a. sloppy manner ,9-that I canbelieve.the risk profile was a decade.of ten-110 c Jhigher. And I said, that's risk informed. ' 11 MR, BARTON: Right. 12 MR. GILLESPIE:.We have a challenge in bringing -13 the technology together with the real world. It is not 14 . clear that the technologist in risk-based are informed about fy (f '15" operations or that the. people-in operation-base arezinformed 16: about risk. 17- 'MR. BARTON: That's a good point., 18
- MR. GILLESPIE: 'And this is going _to be -- and 19
'this came to light, and this was only yesterday, and it -- I ^20; Lwalked:away from that meeting saying, oh, no-and we're 21-supposed to have a perspective on this by January. It's 22-Ljust the sense that the devil in this is.really going to be 23 'in the details because risk-informed is very subjective. '241 DRl POWERS: If you got the empirical information, L 25 ~. somebody said a plant has ten scrams a year, you would be a b t.. h b ANN RILEY & ASSOCIATES, LTD. ^'- Court Reporters. l -1025 Connecticut Avenue, Mi, Suite 1014 L Washington,.D.C. 20036 l (202) 842-0034 1 ^ L -.m.--. .-yy,
s; 411- -[ lil'tadagitated.- E[ l-21 MR. GILLESPIE: Yeah. '"^ But yo'ur. risk' buddy;right now says.he-3- DR.. POWERS: (4' 'didn'tcheiwhether to be agitated or'not. i
- S MR. GILLESPIE:.Right.
6; DR'.. POWERS: 1That's what it says. 7 MR. GILLESPIE: Yeah. 1 1 8; DR ~.. POWERS: But there's a good deal'more I j 9' information that.you would'have' You would know a lot more J10
- about.those ten' scrams?
111:
- MR.'GILLESPIE:
Exactly. And'that's what I'm 12' Esaying. You'd have that much more insight on - -you have to
- 13 bring in/some-judgment on how were they linked, what were
'14 the :causes,. and it's' not just the mathematicc. .I'm just-q gf 15; ,sayingf-- 116l .DR. POWERS: But I'm saying that the' risk guy has E 17. ' Levery -- aszthe opportunity.to-decide whether he should.be 118 agitated'or not?- 19' MR..GILLESPIE: In a real world instance, that's 20 absolutely true. But-when you're trying to get people to '21 focus on how do you set a threshold which now what you're L22 taking is real world history and try to apply it to a 23 threshold that will be superimposed on future actions. And 24 -that was the context that this discussion was taking place. .25' MR. JOHNSON) Or really, how'do'you -- what should i
- [
ANN RILEY &' ASSOCIATES, LTD. \\~ Court Reporters 1025 Connecticut Avenue,LNW, Suite 1014 Washington, D.C. 20036 L (202) 842-0034 j..
~ I 4 412 1 youluse~as an'objectise indicator, for example. Right?' [] c2 'It.s a point?-- N- ~ 3 .ER. POWERS: I,want.to' pursue this.a little ~4 further. :Okay. We have established then that both of you SL can decide after the' fact whether to be agitated or not. '6 I .MR. GILLESPIE: After the fact is'much easier, 7 Lyes. 3 8 RDR. POWERS: But the fact is that these things 9 unfold not.as boom, today I inform you that yesterday I had 10 ten' scrams. i '11 -MR. GILLESPIE: Right. Right. H 12 DR. POWERS: You'in fact you get these'one at a 13' time. When youfhave one scram, you don't know whether to be 141 -agitated or not, ~ but your risk buddy knows whether to be c (~% : l ); 15 agitated?or.not? 16-MR. GILLESPIE: He thinks.he knows anyway. 17 CRAIRMAN SEALE: Once he looks at the character, 18 Ithe-nature..of the scram, he gets his level of agitation? 19-MP. GILLESPIE: Yes. Are there complications? 20 There's other. questions you.have to ask. And'all I'm saying 21 is that this is not going to be cui easy task and the devil 22 is in the details because people are trying to take these . 23 ' ' indicators.as individual indicators, not as a collective 24 set. l25-DR.. POWERS: I guess I'm a little bit puzzled. (9 -ANN-RILEY & ASSOCIATES, LTD. 'b_ ' Court Reporters 1025 Connecticut-Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
~. i: P 413 0 1 With the information ~-- with just the information of ten J [Q[ 12) scrams, you know't'o be agitated, your risk buddy does not. 3' With1the additional information he can'tell you, yeah,.you 4' should be'really~ agitated or you should not. 5' MR. GILLESPIE: Yes.- ~ i 6 IMt. POWERS:.But since you don't get them that, ] 71 you get them'one at a time, when you get one, you-don't know 8 whether to be agitated or not, but your risk' buddy can tell 9-you'whether to be agitated or not? Because he says, this '10 scram is' indicative of a very low reliability on this high-11- ' raw device, et cetera, et cetera, et cetera, and he says, "12 boy.you better get agitated and go do something.about this 131 because'you're. going to get nine more scrams. Okay. 14 Whereas.you didn't know that. I mean,.because the risk [. 15 buddy has a-quantitative threshold in mind, he can respond 16 to one scram-and you' can' t. I mean,oit.seems to me that -17 .you're concern about.the:real world is placed in the wrong 18 place. The risk: guy.seems to be better positioned to deal 19-with the real world than the empiricist. 20 MR. GILLESPIE: I think there's a compromise and both have to be there. 22I CHAIRMAN SEALE: But to put it anther way -- 23L MR. GILLESPIE: Oh, I understand what you're 24 saying. But in setting these threshold as we you're looking 25-at them, if the licensee reflects on what the cause of that l t ANN RILEY & ASSOCIATES, LTD. l li A s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)- 842-0034 I
.. ~ -.. ~... -. ~ 414 L
- 1 Lone scram-wasEand corrects it, then in fact the regulator
} Q[ 3 2-need not be. intrusive. 3 1DR. KRESS: I.think I agree with you, Frank,- L 4-
- because the' risk guy has as his tool the PRA.
Not all your 5' -performance indicators are going to be directly related to 6 'the PRA. I'm sure of that, and that's where you're going to 7 have to rely on the' empiricist because the risk guy will 8 'look.at that and say, I don't know what to do with that. p :, L. '9 DR. POWERS: But, Tom, there.may well be counter' i 11 0 examples, but the one that's been selected is not a good 11; ' counter example, 12; DR. KRESS: That's right. The one he's selected 13E is'.not'a problem.
- 14.
DR. POWBRS: Indeed, I've often,said that:there 'D)1 ( 15
- will never be another TMI accident because there will never j
'16 ' be another accidentzthatuis exactly like any accident. I 17 ~ mean, we'go take care of things, owe correct the things. But E 18 what happens, or at least.in my world, is we tend to correct 19_ .the things that are obvious from the event that' occurred, '201 whereas the risk guy, the.PIU4 guy can tell you, now this -- ~21' there's more here:to do. Yes, he corrected the valve that 22'
- caused the problem,'but in fact all of his valves have a 23:
1 common mode' failure problem and he doesn't. recognize that. .24- .I mean,;again, I keep coming back saying the risk guy seems 25L to.be better positioned to deal with the real world than the 7[' h ANN RILEY & ASSOCIATES, LTD. \\/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C.'20036 (202) 842-0034
C+ 4 e- -A,a . 44. 4 -.4p 4.- b -415 1, empiricist here. .,...,f [2 MR. GILLESPIE: I agree with you again, in (v 3 ' principle, yeah. And the problem-I'm.trying to address:here 4 is not reflectington a' set ~of facts you know, but setting a ~ 5' threshold for what'you don't know. And that's become -- '6 .it's not.necessarily just a' mathematic algorithm. 17-CHAIRMAN SEALE: Well, maybe what Dana suggesting ) 8 though is, that in making the decision as to whether or not l ~ 9 you' cross that threshold, you need not only the result of 10 'your inspection, but the result of-the assessment of that 11 event by a risk-informed person. ] 12 MR. GILLESPIE: Oh, yeah, I totally agree with 13 that. And one of the outlying-situations that we have yet ~ '14 to deal with it, and we talked about it in the workshop but /-'s (_) - 15.- didn't deal with it, was, i* you have-a' scram -- a scram 16 -isn't just-a scram. So on the individual case doing the 17-individual analysis of a real scram and a real incident at a 18 real plant, absolutely I totally agree. It's in how we're 19 applying this mix of empirical information and-risk insights 2 0 '. in setting threshclds to go forward. And both things have 21 their place. ~22 I'm just saying it was interesting when we were 23 ' talking about a specific threshold that -- the same data was 24 looked at -- two different people just different ways. And '25 we need to. digest both of those in this whole concept of il' [# 1-ANN RILEY & ASSOCIATES, LTD. \\~- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
M 416 1 = set' ting thresholds ~across a set of' indicators which are ,em. i 2~ trying to be an-integral cet. J( O ~. 3 DR. KRESS: That'goes back to George's obvious 4 conclusion slide about making your performance indicators as l 5, risk-informed as_possible. The more risk-informed those 6 are, the better you're going to be positioned to deal with ] 7 that issue ~you just talked about. i 8 MR. GILLESPIE: I'm just saying, it's: turning out '9 to not be.an' easy' thing. ) 10 IHl. KRESS: Yeah, that's right. And that's the -11: problem. The less risk-informed-you are, the harder it's. 12 going to be doing these things, but you're. going to be faced L13 - with it, because you -- '14~ CHAIRMAN SEALE: But in' resolving these issues, j . ?'50 i l! )) 15" .theLather; thing that stands out is that you and the industry ss_ J 16 both get a lot further along.when you talk to eachc other 17 ratherlthan at each other, i
- 18 MR. GILLESPIE:
Oh, yeah, And I think this is a i 19 problem that we both recognize, because this whole setting 20 of thresholds is going to be a real, real to'gh one. 21 DR. KRESS: Sometimes it gets down to you'just 22? 'have to use judgment. 23. CHAIRMAN SEALE: Yeah. i l 24. MR. GILLESPIE: Yeah. 25 DR. FONTANA: You're going to try this across.the [b ANN RILEY & ASSOCIATES, LTD. ^s /- Court Reporters 1025. Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 (202) 842-0034 i
417 1 board? Or:you're going.to try with a'few maybe pilot plants j 1 [1 2. to-start' with?J ) 3,- } 3 MR..GILLESPIE: I'm goi guess, we're going to a 4 try with - if we're successful-by naving' identified at 5 least what the indicators are and what some potential 1 15 thresholds : are lar January or February when we have the. 7 1 Commission paper that we then think about -- even before we 1 8 . restructure'the1whole inspection program -- collecting that l .9= specific indicator information at some sample' plants in each 10 region to, kind of baseline ourselves and have some overlap. l 11-~ DR.- FONTANA:.You can use retroactive information.
- 12' MR. GILLESPIE:
And.we're also going to be looking 13 .atisome retroactive information. SEI is. going to share.some 14 -- they've said,'some retroactive information. -Because they
- r N
- (
s 15 ,did -.they looked at. good plants, medium plants, and poor v ~16 plants and they would like to remove the names,.but we could 17 get some sense of the scatter of the data and how does it 18 ~ work. We need to get some insights into~how does a 19 threshold work?- -20 DR. KRESS: I have one other comment to make. I 21 give this workshop a SALP rating of one. You guys did a . good job. 22 23 MR. BARTON: You can't use that anymore. It's 24 been suspended. 25 DR. KRESS: Oh, sorry. ,"/3) ANN RILEY & ASSOCIATES, LTD. Court Reporters '-w ,1025 Connecticut Avenue, NW, Suite 1014 Washington,. D.C. 20036 (202)'842-0034 i
418
- 1
[ Laughter. ] 'j -2 DR. APOSTOLAKIS: Actually -- J 3 MR. BARTON: Go ahead George. 4 DR. APOSTOLAKIS: I have been critical in the past 5 over what -- 6 MR.2BARTON: We hadn't noted that. 7 [ Laughter. ] 8 DR. APOSTOLAKIS: That's why I'm reminding you. I 4 9 had-been critical, and I must say today I'm really happy 10-with what I've seen. I think you guys did a hell of a job. 11 CHAIRMAN SEALE: Yes, very good. 12 MR. BARTON: Any other questions for the staff 13 before NEI?. 14 DR. APOSTOLAKIS: Before it becomes a love fest. ,t,vl 15 [ Laughter.] 16 MR. BARTON: I think Steve Floyd of NEI would like 17. to make some comments. Thank you. 18 CHAIRMAN SEALE: Thanks a lot..Look forward to 19 seeing you in November. 20 MR. GILLESPIE: And December. 21 CHAIRMAN SEALE: And December. 22 [ Laughter.] 23 MR. FLOYD: Good morning. I have just a few '24 remarks to make. First of all we would like to congratulate 25 .the staff-also on both the workshop and on the progress that f~'\\ ANN RILEY & ASSOCIATES, LTD. \\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.- 20036 (202) 842-0034
.g.~ _.. '11 419 -1L
- they've'made
- in'the assessment area to. improve its s
L['T-C2 objectivity and it's safety focus. We think.the tops-down: a i v s 13-1 approach (thatLis now reflected,in the framework where~it's emphasia.i'ng.what is1important to-public. health and safety is .4 ? 5;
- a tremendous; improvement over whatlthe past assessment;
'6: ' approaches havelbeen. -And we'think-that they did'a very. 7
- good
- job,'at least from_.our-perspective on taking what we
~ ~ 8- . thought were some of the best. points of..the' process'that we 9 laid out'and some'of their own thinking.and melding?it 10' ltogether. 11.' If.you think back, the. white' paper that wethad 12-focused. predominant y[just'on the reactor safety area and we '13; thinkiit=is-.a big improvement and a nice rounding'out'of the 14,
- issues by' adding.the other areas that are;important.
? -15 LOverall wefthink the' workshop was a great success from the 1 65 . industry's perspective. We thought there-was an excellent -17 sharing of industry,"NRC, and public views.
- 18
- And I know my boss atLone point made the comment
- 15F to me, and he made it in the wrap up as well, that standing 20.
in the back of the room it was often difficult to determine, 21 without looking at name tags who was speaking from the 22: industry, from the public, or from the NRC. The views were ,23 -- I mean, just so well expressed and everybody was really 24. trying to focus on what.they thought was important to look 25' Lat. ' And'that was veryLencouraging to think that when you i I ((i ANN RILEY & ASSOCIATES, LTD. Os-Court Reporters 1025-Connecticut Avenue, NW, Suite 1014 Washington,-D.C. 20036 (202) 842-0034 3lc' i
- y.
- w w
l-410 ci step back and think that there was a,tood consensus about i .y., [, %r[. i 2 what was important to be looking at from all the parties 3-Jthere at the : workshop. 4~ I think we did reach a great deal of consensus on 'Sc -the overall framework.and philosophy and I would encourage T6 ---I forget which member of the ACRS just said it a minute 7-ago, but we do need to talk -- continue to talk to each Lil other instead of at each other. And I know we're trying to 9' work through and figure out how do we go from here on that. We think there's a lot more to do though. And I ill =think you heard that echoed from the. staff as well. We need 112 good definitions on these objective indicators, they've got i '13-to be clear, they've got to be concise, they've got.to be 14. understandable to all parties, they've got to be measurable, n. q( ) .15. We've.got to have good consistency of the data. We've got 16' .to work out how the data is going to be collected and .17: reporte'. And then we get.to the thresholds and we think-U d '18 .there's an awful lot of work to do in setting the '19 performance thresholds. But I think we're encouraged with 20 the framework that was laid out at the workshop and the .21 discussions 1that we got, I think we have a basis for moving
- 22
' forward to resolve all of these issues. 23 In our view, the biggest thing that needs to be 24-done after you get past the easy part of setting the l25 objective performance indicators and the thresholds, perhaps I ANN RILEY'& ASSOCIATES, LTD. I N-d Court Reporters '1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
a .t w y 421- . /li
- the[ toughest:part:is;howlto meld together the objective W.
<l h
- 2-iperformance.in'dicator datalinsights7that you get-with the is /; ".
l 30 .inspectioniinsights.that/we'll' have toi eal-with, d f L4 ' LWe really think the,keysthere-is to make sure that ' 5 l.
- theEinspection' process is' focused on what are.the risk l
16 fimportant areas-at.the= plant,'and then~once you do'that, '7 obviously'you'reigoing to;get'a set of' findings out of that-
- EU inspection l process.
Not allithe finding even though'they're M 91 .infareas that are'important'to risk, not all ofLthe findings ~ 11 0 themselves will beuimportantLfrom a safety perspective, so' 11; there has-to-be a second sort,Lwe think, on the. findings to-12. .make sure that they.are' relevant to.what's important in that 13:- area. ~ .14 ~ Andi I think if we'can work on'a framework that 15 addressesJthose two, points, then I think that we'will have j m 16 .greatisuccess,;Iithink, in trying to meld the two processes 117 together. s. E18 - .The other area that we didn't spend much time, we 1 19;
- had a'little session,'I guess it was, on Tuesday on this, L20 but that's.the enforcement process.
And we do need to
- 21 ensure'that thefenforcement process is.also made more 2 21 risk-informed consistent with the efforts that are ongoing 23-in the assessment and inspection areas.
And I know the L staff working on this, but it really wasn't a focus of the L-24 [o [25: latter part of the workshop. i L + [)L 4 ANN RILEY & ASSOCIATES, LTD. f Court Reporters 10251 Connecticut Avenue, NW, Suite 1014 I- -Washington, D.C. 20036 (202) 842-0034 o y
t ' ' ' 422 i 1 I guess, you know, going back to the bi me". j f( q. w;' Jissue,-~and that is how toimeld the inspection results with 2
- 3 Dwhat I
- would call:the.more objective performance indicator 4E aresults',.the realLchallenge here -- and I know that some of h'
~ 5' the concerns expressed by people in'the industry to.be 6E .. sensitive lto, although they're hopeful-that it won't happen ~ 7
- -is-to make'sure'that the performance indicators don't just 1
i8 'become another layer over what'is"the current assessment H 19. . process, and we still use a-lot of' insights from.the: current 10~ inspection' process to override what the objective PIs are 111 telling.us. 12. .I think. people.are very optimistic after the 1 13-l workshop that that's not' going to happen. But I'think it's ,14' something that'everybody will be-looking hard at'to make l 9/%. r
- 15 sure.,that it.doesn't happen.
16~ 'I guess in summary.we would also.like to-just l y 17: reinforce our congratulations lto the staff. This was an 11 8 exceptionally well-planned and well-run workshop, very 19 professional and we think they did an outstanding job at it. L -20' And if there are any, questions, I would be happy to answer 2 11 them. 22; MR. BARTON: ~Any questions anybody? i-23' Jo response.-)- E24 MR. BARTON: Thank you, Stevc; 25 CHAIRMAN SEALE: Thank you. -( ANN.RILEY & ASSOCIATES, LTD. N /- Court Reporters 1025; Connecticut. Avenue, NW, Suite 1014 . Washington, D.C. 20036 o l (202) 842-0034 lI
423 1 MR. FLOYD: Thanks. 1 2-CHAIRMAN SEALE: Thank you. Well, I would like to wJ '3 thank if you're -- 4 MR. BARTON: You go right ahead. 15 CHAIRMAN SEALE: Okay. On behalf of the Committee 6 I would like to thank both the staff and the NEI people for 1 7' their words. The staff's presentation and a timely comment 8 from NEI on that process are very helpful for us in checking 9 to see where we are in this whole thing. We look forward to 10 hearing from you again pretty soon and so we'll let you go 11 now if -- I'm sure you've got other things to do. Thanks a-12 lot. 13 Let's see, where am I? 14 DR. KRESS: Reconciliation is -- l 15 CHAIRMAN SEALE: Before I take the break -- s s 16 DR. KRESS: Reconciliation ought to go about five 17 minutes. 18 CHAIRMAN SEALE: Okay. Let's do reconciliation 19 right now. You're on Tom. 20 DR. KRESS: Okay. We had reconciliation letters 21 consist of two. You have a handout 15. And the two have to 22 do with.the two power uprate reviews we did, the Hatch and 23 Monticello. And let's look at the Hatch one first. It's 24 the second one on the list. To me as pointed out by L 25 somebody yesterday, I don't remember who, but this is a fine [) ANN RILEY & ASSOCIATES, LTD. x/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
W 424 m s 1 . example of. a letter: that should have been put in the c ) 12 category of "we don't need a reply _". <v- '3-DR.IFONTANA: 'We don't need what? 'I .4-DR. KRESS: A reply. U '5 .DR, FONTANA: Oh; 6 DR. KRESS: We got'one'that.said.thank you very 7 much and that's what we' expected. And so, you'know,'if you 1 8 want to :look1 at-it, that's'one that should have been in that I 9 list and of course we have no problem with it. 10 The first one, however, on Monticello,.we made d 11 some comments in there, made some suggestions on how to j .i '12 review -- how to review power uprate requests. It went from 113: 'the. view point of 1.174 an'd in so'doing, what.we said was, 14 well, one of the things we said was they oughtLto.give us /~Nr iv!. ^15: some. idea of what their risk status is -- all other one i 16 under 1 174'. I want to know what your CDF and your LERF is ,17 ' over~all sori know where to enter into the. decision chart. '18 .They just misinterpreted that altogether. We told 19-Lthem what they needed to do was give us an estimate of the 20 -effect of shutdown, give us an estimate of the effect of E21 fire, give us -- or either it's so insignificant you can do 22 without it in some way, and. seismic. They interpreted our 23 letter to say, what is the effect of the change in those 24 areas? And that's all we meant. You have to do that also, ,25 'but you can'do that almost qualitatively. l. ,m l [ . ANN RILEY & ASSOCIATES, LTD. \\~/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202), 842-0034 _.=
~ - ~. .-~ % i 425 W
- 12 fWhat:ILwanted'was a real complete CDF and LERF.and
$x A[ ~ 1 2 'their answers reflected just, wall,.we've looked at the
- 3; Leffectiof thetchange on.these~ things and it's insignificant k
14; soy--Lyou know,'so1they missed the point. And it-may-be the SL -wayLwe' worded'the letter, I; don't know,.but they missed the m g6; spoint. 'So;the point lstill~ stands that.I would like to see .i71 Lthemigiveus anoverall? risk status of the-plant before I .&"i 81 D ecide'on uprates. 'And-:that overalll risk status needsLto d ~ 1 L!L include these other things..And most of.the IPEs and.IPEEEs - 10' Edon'tigive you a' full risk numbe and therefore we want some g. -lit Jway.to; guess what.those. missing ~ parts will do,to you.
- And, 112 you know, I've got no indication from the. reply as to a
jl31 ' whether they would intend to do that or not.
- 14j CHAIRMAN SEALE
- -Okay.
So'what are"our options j ,f' \\ js,)y 015 4 here,; Tom?'.What:do you propose to do?1 ~16f DR...KRESS: I'd write another letter to?the --'
- 17
' CHAIRMAN SEALE:.Can we ask you to craft a' letter l n. 18. 'for us to look at, at the next meeting that would -- , c 19 DR. KRESS: All right. That.would -- L 120 CHAIRMAN SEALE: -- indicate to them that they 2 11 zmisinterpreted our first letter and so on? 22= MR. BARTON: Do you want to give Rich Barrett a (heads up that we're going to do that, too? '231 f24: CHAIRMAN SEALE:
- Yeah,
- 25 DR. KRESS:
I don't care. J l-I i.. ANN RILEY & ASSOCIATES, LTD. l-j Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 ' ~ Washington, D.C. 20036 (202) 842-0034
426 1L DR. LARKINS: I think also since we're going to 1 i-2 .use the status report to signal where we don't need a letter %J 3 or a reply, we can also use the status report to signal 4' - where the response was not adequate. -5 CHAIRMAN SEALE: You're going to try to explain _6 .our position a~little-bit more clearly for you? 7L ~DR. LARKINS: Yes. 8' DR.'KRESS: That's a good idea, John. 9 . CHAIRMAN SEALE: That sounds reasonable, yeah. 10 That way not only Rich, but the rest of the 11 hierarchy including Jocelyn will find out. Well, but I 12 mean,-you'll have something formal you can use to convey our 13 position. 14 Okay. So with that, will those two resolve the - l'~b. (,! - 15 reconciliation? 16 DIL KRESS: Yes.
- 17' CHAIRMAN SEALE:
Fine. So let's take a 15-minute 18-break and then we'll come back and start on preparation of =19 ACRS reports. 20 [Whereupon, at 10:10 a.m., the transcribed portion 21 of the meeting was concluded.] 22: 23 24 - ,m. l ' -) ( ANN.RILEY &' ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)'842-0034
c P, s ! REPORTER'S CERTIFICATE! 1 p, g. 1 i ? LThis is to. certify that;the~ attached proceedings-m, y 'il6,s)' .beforelthe~ United States.-NuclearJRegulatory Commission.in'. /theimatterfof: 9, -NAMEiOF PROCEEDING: " MEETING: 456TH ADVISORY-m ' COMMITTEE ON REACTOR SAFEGUARDS-v Z CASE NUMBER: PLACE'OFLPROCEEDING': 'Rockville, MD-1 4 s l F were held.as;herein appears,. and'that.this=is the' original' transcript 1thereof for.the' file-of'-the United States' Nuclear f%. js,,) -Regulatory Commission taken by me'and thereafter reduced to
- typewriting by me or under the direction of the court:
reporting' company,.and-that-the.transcriptiis a true.andt c
- accurate record of'the. foregoing proceedings.
9, v Cindy Thomas Officia1' Reporter Ann Riley & Associates, Ltd. I N 1 1 l tl/\\
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2,:' :o. 0; 0: (/"" %oW) ACRS PRESENTATION ON THE PERFORMANCE ASSESSME*'T IMPROVEMENT WORKSHOP RESi 4 TS MICHAEL JOHNSON ALAN MADISON OCTOBER 2,1998-
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.l i . WORKSHOP OBJECTIVES-i GENERAL AGREEMENT ON A FRAMEWORK FOR A REGULATORY OVERSIGHT PROCESS l i 5 GENERAL AGREEMENT ON THE ATTRIBUTES AND DEFINING .I i PRINCIPLES FOR AN IMPROVED PROCESS i IDENTIFY THOSE AREAS OF DISAGREEMENT FOR FURTHER i EVALUATION l PROGRESS IN IDENTIFYING THE MEANS AND DEVELOPING THE METHODS FOR MEASURING LICENSEE PERFORMANCE-t 1 1
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t 3 F t h r . PHILOSOPHICAL APPROAL,ri i't . FUNDAMENTAL ISSUES r I t i l . DETAILED CORNERSTONE DEVELOPMENT I t i ? 6 b I i 6 i 4 b
1.:O O O: i Philosophical Approach to Regulatory Oversight \\ Must: 3 Be Hierarchial 1 Preserve Core Values 4 Reflect recognition of overall success l of Industry Retain the ability to provide strong i focus on licensees with significant performance problems i t - O! s , 3 Jl
l. O O O remueunusAus SAFETYASARESON NRC's OverallSafety gFglggggg Mission NU M R REACTOR OPERATION l-I I I ~: EXPOSURE FROM Strateg c EXPOSURE FROM i NON-REACTOR RADIOLOGICAL REACTOR PLANT Performance REACTOR ACCIDENT ACCIDENTRADIOLOGICAL WORKER EXPOSURE SAFEGUARDS Areas RELEASES RELEASES l l t I I I I 1 5 INITIATING MITIGATION CONTAINMENT EMERGENCY OPERATIONAL OVER PHYSICAL SYSTEMS SYSTEMS PREPAREDNESS (ALARA) kClDENT EVENTS
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O. O O REGULATORY OVERSIGHT FRAMEWORK ISSUES - ISSUE _1 The NRC is developing a regulatory framework with "comerstones of safety" that could be used to structure inspection, enforcement, and assessment with the overall goal of protecting public health and safety. l 1 i Are these comerstones of safety sufficient (comprehensive, useful for assessment, clear)? ) ISSUE 2 i i Do the comerstones of safety provide a risk-informed framework i for the regulatory oversight process? If not, what changes should l be made? 1 i 7 l
" O O 10 PUBLIC HEALTH AND SAFETY. NRC's Overall AS A RESULT OF CIVILIAN Safety NUCLEAR REACTOR Mission OPERATION RADIATION Strategic REACTOR Performance SAFETY SAFETY Areas j i INITIATING MITIGATION BARRIER EMERGENCY PHYSICAL PUBLIC OCCUPATIONAL 4 INTEGRITY PREPAREDNESS PROTECTION Cornerstones EVENTS 4 SYSTEMS i HUMAN
SAFETY CONSCIOUS WORK --------------- PROBLEM ----- ----
PERFORMANCE ENVIRONMENT IDENTIFICATION AND i RESOLUTION l i PERFORMANCE INDICATOR INSPECTION OTIIER INFORMATION SOURCES DECISION THRESIIOLDS
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4, 'l O O. O i OBJECTIVES OF CORNERSTONES [ REACTOR SAFETY INITIATING EVENTS: . Limit the frequency of events which upset plant equilibrium and challenge. critical safety functions. l t MITIGATION SYSTEMS: i Ensure that those systems required to prevent and/or mitigate core damage perform at a level commensurate with their safety j significance both at power and during shutdown. l t i l I 1 9
~ O O O i t i OBJECTIVES OF CORNERSTONES j BEACTOR SAFETY (continued) l BARRIER INTEGRITY: t Assure that the physical design barriers (fuel, RCS, containment) i protect the public from radionuclide releases due to accidents or j events. l l EMERGENCY PREPAREDNESS: Ensure that the licensee capability is maintained to take adequate i protective measures in the event of a radiological emergency. l t l l t i I i i 10 l 5
~ O LO O i OBJECTIVES OF CORNERSTONES RADIATION SAFETY 1 PUBLIC EXPOSURE: I Assure. adequate protection of public health and safety from l radiation exposure. i I OCCUPATIONAL EXPOSURE j Assure adequate protection of worker health and safety from radiation exposure. { t 11 m.um.mM __m.-m -w =.-id---me.--s-on_ =vm-- -s- --T-' -,.h
!O .O O i i I 1 1 4 OBJECTIVES OF CORNERSTONES b SAFEGUARDS E PHYSICAL PROTECTION: Still under development, but would include the diversion of special l nuclear material. 4 t t I i I l l l l I i 12 i ~ i i
. FUNDAMENTAL ISSUE BREAKOUT SESSIONS I i -I i OBJECTIVE:: Discuss Fundamental issues to Support Development of a Framework for a : Regulatory Oversight Process. l t f i e Defining Principles for Subsequent Breakout Sessions l e Four Breakout Areas: General Policy issues j Use of Risk in Assessment ~ Use of Performance Indicators and Integration with inspection Results l 1 Role of Enforcement / Range of NRC Actions / Communications Professional Facilitation Supported by NRC & Industry Technical Experts j e t Process Supported by Background Information and Proposed Position e E i i
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PERFORMANCE ASSESSMENT WORKSHOP. SEPTEMBER 28 - OCTOBER 1,1998 j i RESULTS OF FUNCTIONAL ISSUE BREAKOUT SESSIONS A. General Policy Issues: Safety Performance Expectations / Reenlatory Oversieht Process I i Issue 1 Is there a threshold oflicensee safety performance above which the NRC can allow licensees to address weaknesses with decreased NRC action? In other words, at what level above a "zero-defect" tolerance can licensees safely operate with decreased NRC interaction? t Proposed Position: There is a level oflicensee safety performance, which could warrant decreased NRC interaction. I 14 i L
~ .o o; o A. General Policy Issues: Safety Performance Expectation's/ Regulatory Oversight Process - j -Issue 2 Given the threshold for NRC interaction (based on the response to issue 1), what type ofleading indication does the NRC need to have in order to provide an early indication ofchanges in licensee performance trends? Do additional performance criteria need to be monitored to provide a leading - indication of declining performance to ensure timely and complete corrective actions by licensees? Proposed Position: 1 The assessment process should establish thresholds that would trigger early interventions to arrest declining performance prior to becoming unacceptable. [ i I L 1 V [ + 4 15 i
G ~ LO; D - A. General Pol cy Issues: Sa ety Performance Expectations / Regulatory Oversight Process' i f Issue 3 Can the NRC place more emphasis on licensee generated information to perform assessments and-still maintain its required independent regulatory oversight function? Proposed Position: The NRC can place reliance on licensee generated assessment results. However, the NRC need s to 4 ensure adequate means of validating the data used in its regulatory and decision making process. Issue 4 Given that the NRC will continue inspecting selected areas oflicensee performance, how should i NRC inspection findings be factored into the regulatory oversight process? Proposed Position: ~ Validate the accuracy of the performance data to be used to assess the risk significant areas not - adequately covered by PIs. 16 =
{f ]- Q~ B. Use of Risk Insights in AssessmentL i Issue l 4 To what extent should the performance indicators and their associated performance thresholds be ~ risk-informed? What is the role of deterministicly-based indicators in an oversight process? What' -} processes and criteria should be followed to' select these information s. urces? : j o Proposed Position: j PIs and other measures and their thresholds should be risk-informed to the maximum extent. j practicable. \\ \\ \\ Iskue 2 \\ How\\y.an a set of performance indicators be used to assess'the integrated risk s -perfonhance? \\ Proposedfosition-Conclusions should be drawn from a broad set ofindicators of need to perform more in-depth I I inspections ivithout performing risk-calculations in all cases. i i i 17 l f i
0 Q l [ ~ B. Use of Risk Insights in Assessraen_t 1 a Issue 3 ~ To'what extent do we need to use in'dividual site PRAs to develop risk-informed, site-specific-performance indicators to complement the generic performance mdicators?L 7 Proposed Position: Individual site-specific risk analysis should be used to the extent necesshry to develop risk-informed q peer-group PIs and risk-informed site-specific thresholds. i [ f
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O o co C. Use of Performance Indicators and Integration with Inspection'Results in' Assessing Licensee Performance I: 9 Issue 1 What is the role of performance indicators in assessing licensee performance? Proposed Position: The rebuttable presumption about licensee performance is formed from_them, and requires a preponderance of other data in order to be overridden. k b i e 19 f f
Q Q (} C. Use of Performance Indicators and Integration with Inspection Results in Assessing _ Licensee Performance - Issue 2 What are the characteristics of performance indicators (e.g. generic, site specific) that would provide a reasonable measure oflicensee performance? Proposed Position: i The PIs may be generic across the industry but have plant-specific thresholds.
- Objectively measured
- Timely
. Risk-informed thresholds
- Identify trends
- Reasonable sample of overall performance
- Validated and verifiable
- Result in appropriate licensee and NRC actions l
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O h h C.. Use of Performance Indicators and Integration with Inspection Results in Assessing Licensee Performance Issue 3 What are the characteristics of a risk-informed inspection program to monitor licensee performance in light of the proposed performance indicator characteristics? Proposed Position: The baseline inspection program should cover risk-important attributes of the safety functions, programs, and processes not covered directly by PIs. Issue 4 How should performance indicator results be integrated with inspection results and other sources of information (e.g. event reports, FEMA reports) to assess licensee performance? i Proposed Position: . PIs will be the primary indicator of acceptable performance an approach will be developed to integrate e i 21
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C. Use of Performance Indicators and Integration with Inspection Results in Assessing Licensee Performance Issue 5 - How can the NRC assure that performance indicator data is accurately developed, recorded, and submitted in a timely manner? Voluntary program? Rulemaking? What controls'should be placed on this process? Proposed Position: A voluntary industry initiative to develop, maintain, and submit PI data is preferable to rule-making. i t t
- O G Q D. Role of Enforcement in Regulatorv' Oversight / Range of NRC Actions / Communications Issue 1 LWhat should the role ofenforcement be in the overall regulatory oversight process? - Proposed Position: . - The role of escalated enforcement is to address safety significant violations j
- Because the situations that give rise to' enforcement also feed assessment measures, no specific PIs are needed for enforcement.
t i ( Issue 2- -t What NRC actions are most effective'in encouraging timely licensee corrective actions? j l P_rpposed Position:- f There should be a graded approach to the assessment outputs, with outputs being directly related to overall assessment grade. 7 I .l 1 I 1
O O O. D. Role of Enforcement in Reenlatory Oversight / Range of NRC Actions / Communications i Issue 3 What methods of communicating performance assessment results and enforcement actions are most effective, accurate, fair, and objective? . Proposed Position: Communication of assessment results must provide a clear assessment and must be meaningful to all audiences. . Written assessment reports
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o o o j DETAILED CORNERSTONE DEVELOPMENT . OBJECTIVES: Identify the Objective & Scope identify the Desired Results and important Attributes identify What Should be Measured Discuss Areas to be Monitored by Performance Indicators Discuss Other Sources of Information Discuss Criteria and Thresholds Determine Phased Approach Five Groups: 1. Initiating Events j e 2. Mitigation Systems 3.. Containment Systems 4. Emergency Preparedness j 5. Radiological Controls t Professional Facilitation Supported by NRC & Industry Technical Experts i e l I L Outcome of Breakout Sessions Supports Development of Logical Construct l e l i t I l f 25 i 2
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gr~ n 5 High Risk 3 SSC E- . Availability. Common. Configuration Procedure . Human f,su * . Quality Performance j
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\\ Adequate ' Adequate Controls Controls Maint / Surv . Operating Personnel Personnel. 8 ure proce ure - Maintain Performance Procegty_ ty o to Maintain - to Maintain . Qua Plant IAW During. System Config. Plant Design Station Process Accidents inspection - Performance ind 3 inspection Hi h RiskSSC l Licensed Operator Design Program e Requal Program . Avalabilityindex b a i
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+70 o o ( 3 SCHEDULE i e October-November 1998: Complete development of proposal for assessment process improvements I e January 1999: Present recommendation for assessment process to Commission I e March 1999: Commission approval to implement recommended changes e June 1999: Start phase-in of the revised assessment process e June 2000: Complete phase-in of the revised assessment process e June 2001: Complete evaluation of the effectiveness of the revised assessment process -}}