ML20196H519

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Presents Status of Activities for PRA Implementation Plan, Including Development of risk-informed Stds & Guidance
ML20196H519
Person / Time
Issue date: 07/22/1997
From: Callan L
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-97-158, SECY-97-158-R, NUDOCS 9707280179
Download: ML20196H519 (23)


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July 22.1997 SECY-97-158 EQB:

The Commissioners FROM.

L. Joseph Callan Executive Director for Operations

SUBJECT:

QUARTERLY STATUS FOR THE PROBABILISTIC RISK ASSESSMENT IMPLEMENTATION PLAN PURPOSF.:

This quarterly report (Attachment 1) presents the status of activities for the Probat:llistic Risk Assessment (PRA) Implementation Plan, including the development of risk-informed standards and guidance.

BACKGROUND:

In a memorandum, dated January 3,1996, from the Executive Director for Operations to Chairman Jackson, the staff committed to submitting quarterly reports on the status ofits development of risk-informed standards and guidance. Previous quarteily reports were sent to the Comm:ssion on March 26, June 20, and October 11,1996, and on January 13 and April 3, 1997.

CONTACT:

A. Thadani, RES 415-6641 0'

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SECY NOTE:

TO BE MADE PUBLICLY AVAILABLE IN 5 WORKING DAYS FROM THE DATE OF THIS PAPER T

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r The Commissioners 2-DISCUSSION Significant achievements in the past quarter include the following:

4' Publication of a Federal Register Notice (FRN), "Use of PRA in Plant Specific Reactor e-i Regulatory Activities: Proposed Regulatory Guides, Standard Review Plan Sections, and Supporting NUREG,' announcing the availability of four draft Regulatory Guides (RG), three draft Standard Review Plan (SRF) Sections, and a draft NUREG series report for public comment. These draft documents are:

General Guidance (DG-1061 and SRP) i Inservice Testing (DG-1062 and SRP) j' Graded Quality Assurance (DG-1064)

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Technical Specifications (DG-1065 and SRP), and

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Reference Information on Expected Attributes of PRA Analysis (NUREG-1602) i j

Copies of these draft documents can be viewed at the NRC Public Document Room or accessed electronically via the NRC Electronic Bullet:n Board on FedWorld, or the NRC's accessed Website.

To facilitate solicitation of public comments, the staff will conduct a workshop during the e

j comment period to explain the draft documents and answer questions. The staff is preparing an FRN to announce that the workshop will be held on August 11-13,1997, at the Doubletree Hotel in Rockville, Maryland. A workshop agenda will be included in the F_ N.-

R The draft RG and SRP section for risk-informed inservice inspection (RI-ISI) were completed and copies were sent to the ACRS for review and comment. An overview of the documents was presented to the ACRS full committee on June 11,1997. Initial and detailed presentations to CRGR are scheduled for June 1997 and July 1997, respectively. Presentations of the ISI RG and SRP section to the ACRS subcommittee and full committee are scheduled for July 1997.

The staff anticipates receiving three pilot plant applications to implement RI-ISI i

programs by the end of September 1997. The staff and the industry continue to develop methods and complete analyses.

With regard to the pilot program for RI technical specifications (TS), the staff completed the safety evaluation, which provides the basis for granting amendments -

for TS allowed outage times (AOTs) for the safety injection tanks and low pressure safety injection system at the lead plant, Arkansas Nuclear One, Unit 2 (ANO-2). The safety evaluation was forwarded to the Commission in SECY-97-095, "Probabilistic i

Risk Assessment implementation Plan Pilot Application for Risk-Informed Technical 3

Specifications," on Apiil 30,1997. On May 28,1997, the Commission issued a staff i-requirements memorandum (SRM) which stated that the Commission had not i

objected to the issuance of an amendment to the ANO-2 TS as described in the safety j

evaluation attached to SECY-97-095. The SRM also stated that the Commission noted the staffs intention to issue similar amendments for the remaining Combustion i

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l The Commissioners Engineering plants in cases for whic6the results are comparable to those for ANO-2.

The staff completed five more maintenance rule baseline inspections, which included inspection of licensee methods for using PRA in maintenance programs and in inspection of safety assessments performed by licensees when removing equipment from service for maintenance in accordance with Paragraph (a)(3) of the maintenance i

rule. As of June 7,1977, the staff has completed 26 inspactions.

On June 13,1997, the Commission approved the staff's recommendation to accept l

the industry's proposed voluntary alternative to the Reliability Data Rule. The staff will (1) continue to work with industry to improve the content of the voluntary data, (2) periodically update the Commission on these efforts, and (3) advise the Commission on whether the voluntary approach remains a viable method of meeting regulatory needs.

COORDINATION:

j The Office of the General Counsel has reviewed this paper and has no legal objections to its issuance.

L. Joteph Callan Executive Director l

for Operations Attachments:

As stated l

DISTRIBUTION:

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ATTACHMENT 1 l

QUARTERLY STATUS UPDATE OF THE AGENCY-WIDE IMPLEMENTATION PLAN FOR PROBABILISTIC RISK ASSESSMENT (PRA)

(from March 31,1997 to June 30,1997)

SUMMARY

OF SIGNIFICANT PROGRESS (1)

Reaulatorv Guide (RG) and Standard Review Plan (SRP) Develooment (Tasks 1.1 and 2S On Aprii 8,1997, the staff sent to the Commission SECY-97-077, " Draft Regulatory Guides, Standard Review Plans and NUREG Document in Support of Risk-Informed Regulation for Power Reactors." SECY-97-077 requested Commission approval to publish for comment four draft Regulatory Guides (RGs), three draft Standard Review Plan (SRP) sections, and one drait

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NUREG series report that support implementation of risk-informed regulation for power

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reactors. By staff requirement memorandun (SRM), dated June 5,1997, the Commission j

approved publication of the draft documents. A notice was placed in the Federal Register i

announcing availability of the documents and requesting public comment on them.

To facilitate solicitation of public comments, the staff will hold a workshop during the comment period to explain the draft documents and answer questions. The staff is preparing a Federal Register Notice to announce the exact date and location of the workshop. A workshop agenda will be included in the FRN.

The staff is also finalizing a draft RG and SRP for risk-informed inservice inspection programs (RI-ISI) for piping. The staff is scheduled to meet with the ACRS subcommittee on July 8, 1997, to discuss the RI-ISI documents. These documents are scheduled to be sent to the Commission on July 31,1997. The draft RG and SRP section have been completed and copies have been sent to the ACRS for review and comment. The presentation of the ISI RG and SRP section to the ACRS sub-committee and full committee is scheduled for July 1997.

Presentations to the CRGR are also scheduled for July 1997.

1 (2)

Pilot Acolications (Task 1.2)

The staff has actively engaged with South Texas Project (STP) personnel to evaluate their i

proposed approach for implementing graded quality assurance (QA). In response to staff questions, the licensee submitted on January 21,1997, a revised operational QA program (OQAP). A management meeting was held on March 31,1997, to discuss issues associated with the graded QA initiative. On the basis of the staff review that identified further questions and concerns on the graded QA description in the OQAP, another request for additional information (RAI) was issued to the licensee on April 14,1997. In a meeting with STP on April 21,1997, the staff discussed the RAI and preliminary STP responses to the staff questions. On May 5 through 8,1997, the staff visited STP to review in greater detail the STP implementation procedures, planned OQAP revisions to address staff concerns, corrective action processes, l

and details related to equipment categorization. STP subsequently submitted for staff review another OQAP revision and revised procedures for implementing facets of the graded QA A1-i 1

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l OQAP'that should address all issues raised by the staff. The staff has been preparing a safety evaluation (SE) for graded QA based on the reviews performed.

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Regarding the pilot program for RI technical specifications (TS), the staff completed the SE that provides the basis for granting amendments for TS allowed outage times (AOTs) for the safety injection tanks and low pressure safety injection system at the lead plant, Arkansas

- Nuclear One, Unit 2 (ANO-2). The safety evaluation was sent to the Commission in SECY-97-095, "Probabilistic Risk Assessment implementation Plan Pilot Application for Risk-Informed Technical Specifications," on April 30,1997. On May 28,1997, the

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Commission issued an SRM which stated that the Commission had not objected to the issuance of an amendment to the ANO-2 TS as described in the safety evaluation attached

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to SECY-97-095. The SRM also stated that the Commission noted the stafs intention to issue similar amendments for the remaining Combustion Engineering plants in cases for j

which the results are comparable to those for ANO-2.

As discussed in SECY-97-095, in approving the proposed ANO-2 TS changes, the staff is

- relying on a commitment made by the licensee with respect to using a RI configuration j

control technique to assess the risk associated with the removal of equipment from service during the proposed AOT. The staff stated that because this is a new commitment specific to RI TS changes, the staff will ensure that the commitment is incorporated into the ANO-2

- operating license. The staff and the Combustion Engineering Owners Group (CEOG) have

. generally agreed that the preferred method for incorporating this commitment into the license i

is through the addition of an administrative control TS. However, the staff and the CEOG have not yet reached agreement on the content of such a TS. The CEOG has indicated that it would be prepared to meet in late July or early August to discuss the resolution of this issue. Once this issue is resolved with the CEOG, ANO-2 will need to submit a supplemental l

amendment request to add the new administrative control TS. Once the supplement is received and reviewed, the ANO-2 amendments can be issued and the review of the remaining Combustion Engineering plants completed. The staff expects this process to be completed by the end of 1997, as indicated in the revised PRA implementation Plan.

As indicated in the last Quarterly Status Report for the PRA implementation Plan (SECY 076), dated April 3,1997, the staff expected to be able to issue SEs for implementation of RI-IST at Comanche Peak and Palo Verde by June 30,1997. The staff has been interacting with the pilot licensees and developing SEs on their proposed RI-IST programs. The June 30,1997, completion schedule was contingent upon timely receipt of the two pilot plantc' responses to staff RAls. This includes responses to second-round RAls issued in March 1997, which addressed several key areas of review as containd in the draft RI-RGs and SRP sections, as well as responses to final RAls aimed at eliciting, in detail, how the pilot licensees comport with the draft RI-IST and general RGs. The staff has maintained

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interaction with the pilot licensees, and representatives from the pilots have attended some of j

the meetings between the staff and ACRS during the development of the RGs and SRP sections. Shortly after the March 1997 RAls were issued, the staff discussed the questions with the pilot licensees and clarified them via teleconference.

The stafs RI-IST team is currently working on the first drafts of SEs for Comanche Peak and Palo Verde. These drafts will be based on the licensees' proposed RI-IST program submittals in response to the staFs first-round RAI (Palo Verde has only partially responded to the stafs March 1996 RAI). However, open items in the draft SEs can only be resolved A1-il j

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after the staff receives documentation from the licensees describing how their proposed RI-

-lST program comports with the drsft RI-IST RG or their rationale for any differences. In late May 1997, the Comanche Peak licensee, Texas Utilities (TU) Electric, indicated that they

' would try to respond to both the second-and final-round RAls within 60 days of receipt of the draft RI RGs and SRPs. The staff plans to meet with TU Electric several weeks after the licensee receives the draft RI RGs and SRPs to obtain interim responses to the RAls so that progress can continue towards completing the staff's SE. The final RAls related to the RI-IST program for both Comanche Peak and Palo Verde were sent to the licensees on June 9, 1997. It is expected that issuance of the Safety Evaluation on the Comanche Peak RI-IST program will be in October,1997.

Significant PP.A-related technical support has been provided for the agency's maintenance rule (MR) baseline inspection. The goal of the MR baseline program was to conduct a full team inspection at each reactor facility in the first two years following the implementation date of the rule (July 10,1996). As of June 7,1997, the staff has performed 26 fullinspections.

These inspections were performed with the support of experienced staff and contractor personnel trained in the use of PRA, using an inspection procedure that focuses on the inspection and assessment of the relevant PRA-related technical aspects of the NRC-approved industry guideline for implementing the rule (i.e., NUMARC 93-01).

Regarding RI-ISI pilot review, the staff is currently reviewing the Westinghouse Owners

. Group (WOG) responses to staff RAls. The staff completed its review of the Electric Power Research Institute (EPRI) methodology and issued its RAI to the industry. The staff has not l

yet received any of the three pilot plant submittals from the industry. These submittals to l

NRC are currently scheduled for September 1997. The staff continues to have working l

meetings with the industry on the WOG and EPRI methods and with Virginia Power on the 1-Surry pilot.

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Trainina for inspectors (Task 13) j i

The first Senior Reactor Analyst (SRA) training class has been completed. Eight SRAs have i

taken the training and qualification program, and managers are reviewing their certification packages.' Employees are being selected for the remaining two SRA positions in Region 111.

I (4)

Individual Plant Examination flPE) and IPE of Extemally Initiated Events (IPEEE)

Reviews (Task 2.5)

IPE 1.

All 75 IPE submittals have been reviewed (Browns Ferry Unit-3, not included). Staff evaluation reports (SERS) have been issued for all except five, two of which are in i

' progress (Susquehanna and St. Lucie). The other three submittals have been redone by the licensees to account for either staff concems brought out during the IPE review process (Byron and Braidwood) or plant changes that resulted in the j

original IPE submittal being obselete (Ginna). SERS are scheduled to be issued for j

these IPEs by the end of July 1997.

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RES is evaluating the applicabi'ity of the TVA multi-unit PRA, (which is a PRA of Unit

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2 given operation of Units 1 and 3) as an IPE of Brown's Ferry, Unit 3. RAls were

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prepared and transmitted to TVA to support this evaluation.

3.

Draft NUREG-1560, ' Individual Plant Examination Program: Perspectives on Reactor Safety and Plant Performance," was published in draft form in October (Vol. 1) and November (Vol. 2) 1996. Perspectives are presented on four major objectives as follows:

The impact on reactor safety; i

The significant reactor design, containment performance and operational features relative to core damage, containment failure, and radionuclide releases; The different methods and models developed and quantified in performing the IPEs; and The implication of the IPE results relative to the Commission's Safety Goals i

and the Station Blackout Rule.

A workshop was held in Austin, Texas, on April 7-9,1997, to present the insights l

discussed in draft NUREG-1560. Approximately 100 participtents attended from U.S.

power utilities, reactor vendor owners' groups, industry consultants, and other Federal and State agencies. Based on written comments, and comments received at the workshop, a final version of NUREG-1560 will be issued by September 30,1997.

4.

The IPE database has been completed and is available to the public (can be i

downloaded from the NRC Web page). In addition, the user's manual for the IPE 4

database, draft NUREG-1603 has been published.

i IPEEE Of 74 expected IPEEE submittals, the staff received 61 that were complete and 3 that were partially-complete. Currently,41 submittals are under various stages of review. Eleven additional submittals are expected to be received by the end of December 1997, one by June 1998, and the submittal date of one IPEEE has yet to be determined.

A preliminary IPEEE insights report has been developed that summarizes the information presented in the first 24 submittals reviewed by the staff. This preliminary report will be sent to the Commission in September 1997. In September 1998, a final report summarizing all IPEEE reviews will be sent to the Commission.

i (5)

Risk-Based Trends and Pattems Analysis Task (3.1)

As part of Task 3.1 (Rrisk-Based Trends and Pattems Analysis Task), a final report on the reactor core isolation cooling (RCIC) system study was issued in June 1997. In additiion, the fire events study report was also issued in June 1997.

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Accident Seouence Precursor (ASP) (Task 3.2)

The 1995 ASP report was published as NUREG/CR-4674, Volume 23. The ASP analyses for 1982 and 1983 were completed and are documented in NUREG/CR-4674, Volume 24. The l

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1996 event analyses are nearing completion and analysis of 1997 events was begun.

(7)

Reliability Data Rule (Task 3.5) l The staff completed its evaluation of industry's proposed voluntary attemative to the rule on schedule. (The proposal was revised in March 1997 to resolve the staff's technical concems.) in May 1997, the staff sent a Commission paper describing its evaluation of the voluntary approach and various options for proceeding. In an SRM, dated June 13,1997, the Commission approved the staff's recommendation to accept the industry's proposed voluntary attemative to the rule. The staff will (1) continue to work with the industry to improve the l

content of the voluntary data, (2) periodically inform the Commission of the status of this l

work,' and (3) advise the Commission on whether the voluntary approach remains a viable method of meeting regulatory needs.

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Staff Trainina (Task 3.6) l The new PRA for Technical Managers course was added to the curriculum. This course is designed to provide alllevels of staff managers with a basic understanding of PRA methods, I

strengths, and limitations needed to implement risk-informed, performance-based regulations.

Current plans are to present this course three time a year in headquarters.

l The first presentation of the new PRA Level 2 course, Accident Progression Analysis, was l

held February 25,26, and 27,1997. This three-day course addresses accident phenomenology under post-core damage conditions and development of PRA models for this severe-accident regime. Based on feedback for the first presentation of the course, the course is undergoing significant modification. The next offering of the course will be in August 1997. Current plans are to present this course and the Level 3 course twice a year.

The new course on external events has been completed. This three-day course will address extemal events (such as fires, floods, earthquakes, high winds, and transportation accidents) and the development of external-event PRA models such as those used in the IPEEEs. The pilot presentation of course is scheduled for June 1997. The course is scheduled for its first regular presentation in August 1997.

The new PRA Technology and Regulatory Perspectives course is under development and scheduled for presentation in October 1997. Four of the 13 course modules have been reviewed to date. The course will replace the PRA Basics for Regulatory Application course and the insights into IPEs course for some basic level users.

REVISIONS TO THE EXISTING PRA IMPLEMENTATION PLAN Task 1.2 of the PRA plan states that the target schedule for completing the graded QA l

initiative is June 1997. The staff has focused on the South Texas Project (STP) as that is the j

only graded QA volunteer plant that submitted a revised graded QA program for staff review I

and approval. The staff is working on a draft safety evaluation for the STP program that will be transmitted to the Commission in July 1997. Staff monitoring of activities at all three volunteer plants will continue beyond the June target date to observe the results of equipment categorization for additional systems, and the results of the application of graded 4

QA controls and to assess the integrity of the corrective action and operational performance j

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f fee:lback programs. This monitoring effort is expected to continue for an extended period (several years) to provide the staff with lessons leamed.

The staff intends by working with the graded quality assurance (GQA) volunteer plants to learn from their implementation strategies, to evaluate their methodologies in relationship to staff prepared guidance documents, and to approve associated QA program changes where necessary. For the purposes of the PRA implementation Plan, this phase of volunteer plant interactions will be considered complete when the GQA RG and inspection procedure (IP) are issued in final form. In the future, the staff will continue to monitor the volunteer plant GQA implementation, gain feedback to revise the RG and IP as warranted, and evaluate GQA implementation strategies for other licensees who choose to pursue GQA. Issuance of the SER for the STP GQA program is expected by July 1997. The completion date for the GQA pilot applicat;on has been revised to March 1998 to reflect the expected schedule for issuance of the final GQA inspection procedure.

In June 1997, the staff informed the Commission of a delay in the expected issuance of SEs for implementation of RI-iST at Comanche Peak and Palo Verde. The staff expects issuance of the SE on the Comanche Peak RI-IST program in October 1997. The schedule assumes i

that TU Electric adequately responds to both the second-and final-round RAls within 60

days, the staff completes its SE within 4 weeks of receiving the licensee's written responses, e

and managers will review and the Commission will approve the SEs for issuance within 6 weeks of the staff's completion of the SE.

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The schedule for issuance of the SE on the Palo Verde Rl-IST program remains uncertain until further commitrnents from the Palo Verde licensee are obtained.

The schedule for issuance of Inspection Manual Chapters 9900 and 2515 (Task 1.3) has been extended to allow time for additional technical review based upon the guidance i

contained in the RI SRPs and RGs.

Regarding core inspection procedures (Task 1.3), an additional item to complete revision to proposed core inspection procedures has been added to the PRA implementation Plan. The expected completion date for this item is December 1997.

The first SRA training class has been completed (Task 1.3). Eight SRAs have taken the training and qualification program, and managers are reviewing their certification packages.

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Employees are being selected for the remaining two SRA positions in Region Ill. This activity has been placed in an ongoing status to indicate the continuing need to train new SRAs as current positions become vacant owing to attrition or transfers.

In case of Task 1.9, a brief overview of Accident Management (A/M) treatment in IPE studies

-is covered in NUREG-1560. Since A/M guidelines are generic in nature, both the generic and plant-specific IPE insights are useful to support evaluations of A/M programs, and future staff audits ofimplementation of these programs. A more efficient use of the staff resources

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can be achieved when A/M information is evaluated in concert with other IPE follow-up l

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current positions become vacant owing to attrition or transfers.

In case of Task 1.9, a brief overview of Accident Management (A/M) treatment in IPE studies is covered in NUREG-1560. Since A/M guidelines are generic in nature, both the generic and plant-specific IPE insights are useful to support evaluations of A/M programs, and future staff audits of implementation of these programs. A more efficient use of the staff resources can be i

achieved when A/M information is evaluated in concert with other IPE follow-up activities in

. Task 1.10. A detailed description of a plan for IPE follow-up activities is currently under 1

development by the staff. Disposition of IPE insights to support staff A/M activities will be addressed under Task 1.10.

The work for developing PRA methods (Task 4.1) for use in evaluating medical devices I

containing nuclear material has been interrupted, because of the loss oi key staff and staff

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assigned to other, higher priority, PRA support activities.

Development of methods for incorporating aging effects in PRA has been delayed because of

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the loss of the contractor's principalinvestigator.

The demonstration analysis portion of the human reliability work in Task 2.4 is being delayed because the cooperating licensee had to allocate needed resources to other, higher priority, issues at the site.

Work on the development of PRA methods for use on industrial devices containing nuclear j

x material (Task 4.4) has begun using NRC staff and limited contractor support, and is I

proceeding more slowly than expected. The schedule for completing this work has been delayed from June 1997 to the end of FY 1998 in order to assign resources on higher priority PRA activities. Options to accelerate this effort are currently being assessed.

The dates for the component study (Task 3.1) and the initiating event study (Task 3.1) changed due to technical issues that are being resolved and to allow for adequate peer review. The date for determining the need to revise the LER rule (Task 3.5) was changed to coordinate efforts with an update of NUREG-1022.

P REVISED TASK TABLES Attachment A2 provides updated to reflect the progress and revisions to the PRA Implementation Plan from April 3, to June 30,1997.

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ATTACHMENT-2 REVISED PRA IMPLEMENTATION FIAN TASK TABLE (June 1997) 1.0 REACTOR REGULATION Regulatory Activity Objectives Methods Target Lead Schedule Office (s) 1.1 DEVELOP STANDARD Standard review plans for NRC staff to use in risk.

  • Evaluate available industry guidance.

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REVIEW PLAN 3 FOR informed regulatory decision-making.

RISK-INFORMED

  • Devclop a broad scope standard revicw plan (SRP) chapters REGULATION and a series of application specific standard review plan chapters that correspond to m&stry initiatives.
  • These SRPs mill be consistent with the Regulatory Guides developed for the imbastry.
  • Draft SRPs transmitted to Commission to issue for public comment General -

IST 4M7C' 151 4N7C TS 7N7 487C

  • Issue final SRP General IST 12M7 ISI 12N7 TS 2N8 6

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l Regulatory Activity Objectives Met'mds Target Lead Schedule OfTwe(s)

I.2 PIIET APPLICATION

  • Evaluate the PRA methodology and desclop staff
  • Interface with industry groups.

NRR FOR RISK-INFORMED positions on emergin6, rid-informed imustives, REGUlf. TORY mcluding those associated with:

  • Evaluation of appropriate documentation (e.g, INITIATIVES
1. Motor operated valves.

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2. IST res;uirements.

10 CFR, SRP, Reg Guides, inspection procedures, and 2.I087

3. ISI requirements.

industry codes) to identify elements critical to achieving the

3. 4S8 (Surry).

intent of existing requirements.

I2M8 (Others)

4. Graded quality assurance.
4. 7N7:(STP)
5. Maintenance Rule.
  • Evaluation ofindustry proposals.
5. 965C(others) 3M8
6. Technical specifications.

6a. Commisson Approval

  • Evaluation ofindustry pilot program implementation.

6b. Pilot Amendments issued 6a. $N7C

7. Other applicatkms to be identified later.
  • As appropriate, complete pilot reviews and issue staff 6b.12M7 findings on regulatcry requests.

1.3 INSPECTIONS

  • Provide, guidance on the use of plant-specific and
  • Develop IC 9900 technical guidance or. the use of PRAs in 6S7 NRR generic mformation from IPEs and other plant-the power reactor inspection program.

specific PRAs.

  • Revise IC 2515 Appendix C on the use of PRAs in the 7N7 power reactor inspection program.
  • Pro. pose guidance options for inspectics procedures related 10N7 to Su.59 cvaluations and regular maintenance observations.
  • Review core inspection procedures and propose PRA guidance where needed.

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  • Complete revision to proposed core inspection procedures 12 S 7
  • Issue draft Graded QA Inspection Procedure %r public comment 987

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SER Generation for South Texas Project only.

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a Regulatory Activity Objectwes Methods Target Lead Schedule OfTice(s)

  • Provide PRA training for inyctors.
  • Identify inspector functions which should utilde PRA 7M6C NRR methods, as input to AEOD/ITD for their desclopment and refinement of PRA training for inspectors.

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  • Develop consolidated' comprehensive 2-3 week PRA for 10M7 NRR/

regulatory applications training course.

AEOD

  • Conduct training for Maintenance Rule baseline 8M6C NRR inspections
  • Conduct training courses according to SRA training Ongoing NRR/RES Programs
  • Provide FRA training for Senior Reactor Analysts (SRA)
  • Rotational assignments for SRAs to gain working Ongoing expenence
  • Continue to proviJe expertise in risk assessment to
  • Monitor the use of risk in inspectbn reports.

Ongoing NRR support regional inspection activities and to comrriunicate inspection prograr's guidance and

  • Develop new methodologies and communicate examp ofits implementation.

appropriate uses of risk insights to regional ofYires.

  • Update inspection procedures as needed.
  • Assist regional offices as netded.
  • Conduct Maintenance Rule baseline inspections 7N8 1 A OPERATOR LICENSING Moniu insights from IIRAs and PRAs (including
  • Revise the Knowledge and Abilities (K/A)Cs:alogs BS5C NRR IPEs and IPEEEr) arid operating experience to (NUREGs I122 and 1123) to incorporate operating id nify possible enhancements for inclusion in experience and risk insights.

p; Nd revisions to guidance for operator licensing act vites (initial and requalification)

  • Revise the Examiner Standards (NUREG-102I), as needed, 3M7C NRR i

to reflect PRA insights.

I.5 EVENT ASSESSMENT

  • Continue te conduct quantitative event essessments
  • Continue to evaluate 50.72 events using ASP models.

Ongoing NRR of reactor evnts uhile at-power and during low power and shutdown conditions.

  • Assess the desirability and feasibility of conducting
  • Define the current use of risk analysis methods and insights ED NRR quantitative risk assessments on non-power reactor in current event assessments.

events.

  • Assess the feesibility of denloping appropriate risk assessmer.t models.
  • Develop recommendations on the feasib!!ity and desirabdity of conducting quantitative risk assessments A2-iii

Regulatory Activity Objectives Methods Target trad Schedule Otricefs) 1.6 EVALUATE USE OF PRA

  • Audit the adequacy oflicensee analyses in IPEs and
  • Identify generic safety issues to be audited.

NRR IN RESOLUTION OF IPEEEs to identify plant-specific applicability of

  • Select plants to be audited for each issue.

GENERIC ISSUES generic issues closed out based on WE and Il EEE

  • Describe and discuss licensecs' analyses supporting issue 5

programs.

resolution.

  • Evaluate results to determine regulatory response;i.e., no TBD action, additional audits, or regulatory action.

1.7 REGULATORY

  • Assess the effectiveness of major safety issue C Develop process / guidance for assetsing regulatory NRR &

l EFFECT1VENESS resolution efliwts for reducing risk to public health etTectiveness.

RES EVAI UATION and safety.

  • Apply method to assess reduction in risk.
  • Evaluate result, etTectiveness of rules
  • Propose modifications to resolution aIproaches, as needed.
  • Identify other issues for assessment i appropriate.

TBD 1.8 ADVANCED REACTOR

  • Continue stafTresiews of PRAs for design
  • Continue to apply current staff review process.

Ongoing NRR REVIEWS certification applications.

  • Develop SRP to support resiew of PRAs for design
  • Develop draft SRP to tech staff for resiew and concurrence.

688 NRR certification reviews of evolutionary reactors

tADWR and System 80+).

12/99

  • Des dop independent technical analyses and criteria
  • Reevaluate risk-based aspects of the technical bases for EP 12/96C NRR &

for evaluating industry initiatives and petitions (NUREG-0396) using insights from NUREG-1150. the RES regarding simplification of Emergency Preparedness new source term information from NUREG-1465, and (EP) regulations.

availGle plant design and PRA information for the pr.ssive rj evolutionary reactor designs.

l.9 ACCIDENT

  • Develop generic and plant specific risk insights to
  • Develop plant-specific A/M insights /~mformation for TBD NRR &

MANAGEMENT support staff audits of utility accidents management selected plants to serve as a basis for assessing RES

( A/M) programs at selected plants.

completeness of utility A/M program elements (e.g., severe accident training) f A2-iv

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4 Regulatory Activity Objectives Methods Target Irad Schedule Office (s) 1.10 EVALUATING IPE

  • Use insights from the stafTreview ofIPEs to
  • Rev ew the report"lPE Program: Perspives on.

9/97 NRR &

INSIGIITS TO edentify potential safety, policy, and technical Reactor Safety and Plant Performance and identify the RES.

DETERMINE issues, to determine an appropriate course of initial list of required s'afTand industry actions (if any).

NECESSARY FOLLOW-action to resolve these potental issues, and to including insights on A/M.

UP ACflVITIES identify po<.sible safe *y enhancements.

- 12N7 Finafire list of required staff and industry actions.

TBD NRR

  • Audit licensec improvements that were credited in the
  • Determine appropriate approach for tracking the IPEs to determine efTectiveness oflicensee actions to regulatory uses ofIPE/IPLEE results.

reduce risk.

12/97

  • Define use for information, clarify " regulatory use", and assees the most efTective methods for data collection.

12M8

  • If appropriate, desclop approach for linking IPCAPEEE data bases.

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2.0 REACTOR SAFETY RESEARCll 7 -

Regulatory Activity Objectives Methods Target Schedule Lead Office (s) 2.1 DEVELOP REGULATORY Regulatt,ry Guides for industry to use in risk-informed

  • Draft PRA Regulatory Guides transmitted to Commission for RES GUIDES regulation.

approval to issue for public comment.

General C

IST C

ISI 787 GQA C

TS C

  • Issue final PRA Regulatory Guides.

s General 12 S 7 IST 12 S 7 ISI 2S8 GQA 1287 E

1287 2.2 TECIINICAL SUPPORT

  • Proside technical suppoit to agency users of risk
  • Continue to provide ad hoe technical support to agency PRA Continuing RES assessment in the form of support for risk-based use s.

regulation activities, technical reviews, issue ri.k

  • Expand the database of PRA models available for staff use, Co6.tinuing RES l

nssessments, statistical analyses, and develop expand the scope of available models to include external guidance for agency uses of risk assessment.

event and low power and shutdown accidents, and refine the tools needed to use these models, and continue msNenance and user support for SAPilIRE and MACCS conmats codes.

t

  • Suppo.1 agency cfTorts in reactor safety improvements in Continuing RES former Soviet Union countries.

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I Regulatory Activity Objectives Methods Target Lead 1

Schedule Office (s) j 2.3 SUPPORT FOR NRR

  • Modify 10 CFR 52 and develop guidance on the use of
  • Develop draft guidance and rule.

5/98 RES STANDARD REACf0RPRA updated PRAs beyond design certification (as described

  • Solicit public comment.

IIM8 RES REVIEWS in SECY 93-087).

  • Finalire staff guidance and rule.

12 S 9 RES

}

l 2.4 METilODS DEVELOPMENT

  • Develop, demonstrate, maintain, and ensure the quality
  • Develop and demonstrate methods for including aging effects TBD RES e

AND DEMONSTRAllON of methods for performing, reviewing, and using PRAs in PRAs.

and related techniques for existing reactor designs.

  • Develop and demonstrale methods for including human errors 9M7 RES of commission in PRAs.
  • Develop and demonstrate methods to kw A 987 RES f

organizational performance into PRAs.

  • Develop and demonstrate methods for fire risk analysis TBD RES t
  • Develop and demonstrate methods for atsessing rehablity/ risk TBD of digital systems RES 2.5 IPE AND IPEEE REVIEWS
  • To evaluate IPE/IPEE submittals to obtain reasonable
  • Complete reviews ofIPE submittals.

987' -

RES

. [

assurance that the licemce has adequately analyzed the

  • Complete reviews ofIPEEE submittals.

3M9 RES

[

plant design and operations to discover vulnerabihties;

  • Contmue regional IPE presentations.

Ongoing RES r

and to document the significant safety insights resulting -

  • Issue IPE insights report for public comment.

1066C RES from IPE/IPEEEs.

  • Fina! IPE insights report 9M7 RES
  • Issue preliminary IPEEE insights r@ ort 9M7 RES I
  • Issue draft final IPEEE insights report 12 S 8 RES l

2.6 GENERICISSUES PROGRAM

  • To conduct generic safety issue management activities.
  • Continue to prioritize and resolve generic issues.

Continuing RI3 l

including pnoritization, resolution, and documentation, for issues relating to currently operating reactors, for p

advanced reactors as app..roprsate, and for development or revision of associated regulatory and standards instrurnents.

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3.0 ANALYSIS AND EVALUATION OF OPERATING EXPERIENCE, AND TRAINING Regulatory Objectives

' Methods Target Lead Activity Schedule Office h

3.! RISK-BASED

  • Use reactor operstmg experience data to assess
  • Trer.d performance of risk-important components.

1287 AEOD TRENDS AND the trends and patterns knquipment, systems, 9N8 PATTERNS initiating cvents, human performance, and important

  • Trend performance of risk-important systems.

ANALYSIS accident sequence.

12N7

TBD

  • Trend human perfonnance for reliability characteristics.
  • Evaluate the effectiveness oflicensee actions taken to
  • Trend reactor operating expcience associated with specific safety As Needed AEOD resoive risk significant safety issues.

issues and assess risk imphcatiorts as a measure of safety performance.

  • Develop trending methods and special databases for use in
  • Develop standard trending and statistical analysis procedures for C

AEOD AEOD trending activPics imd for PRA applications in identified creas for reliability and statistical applications.

ether NRC offices.

i

  • Deselop special software and dr$ abases (e g. common cause CCF-C i

failure) for trse in trending ana'yses and PRA studies.

Periodic updates 3.2 ACCIDENT

  • Ideniity and rank risk significance ofoperational events.
  • Screen and analyre LERs, AITs, lils, and events identified from Ongoing AEOD SEQUENLE other sources to obtain ASP events.

PRECURSOR (ASP)

PROGRAM

  • Perform independent review ofeach ASP analyses. Licensees and Annual NRC stafT peer review of each analysis.
report, AEOD Ongoing
  • Complete quality assurance of Rev. 2 simplified plant specific 3M7C RES r

models.

  • Complete feasibility study for low power and shutdown models.

IIS6C RES j

  • Complete initial containment performance and consequence C

RES t

  • Provide supplemental information on plant specific
  • Share ASP analyses and insights with other NRC offices and Annual rpt AEOD performance.

Regions.

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Regulatory Activity Objectives Methods Ttget Lead SdMule Office t

33 INDUSTRY RISK

  • Frovide a measure ofindustry risk that is as complete as
  • Develop program plan which integrates NRR, RES, and AEOD C

AEOD TRENDS possible to determine whether risk is increasmg.

actisities wfuch use design and rperating experience to assess the decreasing, or remaining constant over time.

implied level of risk and how it is changmg.

  • Implement program plan elements u hich will include plant-9/98

+

specific rnodels and msights from IPEs, component and system reliability data, and other risk-important design and operational data in an integrated frame work to periodically evaluate industry trends.

3.4 RISK-11ASED

  • Establish a comprehensive set of performance indicators
  • Identify new or improved risk-based Pls which use component and C

AEOD PERFORMANCE and supplementary performance measures uhich are more system reliability models & numan and organizstional performance INDICATORS closely related to risk and provide both early indication evaluation methods.

and confirmrtion of plant performance problems.

  • Develop and test candidate Pis/ performance measures.

3S9

  • Implement risk-based Pts with Commission approval.

989 3.5 COMPILE

  • Compile operating experience information in database
  • Marnge and maintain SCSS and the PI data base, provide oversight Ongoing AEOD OPERATING systems suitable for quantitative reliabili and risk and access to NPRDS, obtain INPO's SSPI, compile iPE failure EXPERIENCE DATA analysis appliptions. Information shout be scrutable to data, collect plant-specific reliability and availability data.

l the source at the event level to the extent practical and be

  • Develop, manage, and maintain agency databases for sufficient for estimating reliability and availability reliabihts/ availability data (equipment performance,inithiing Ongoing

{

parameters for NRC applications.

events, CCF, ASP, and human performance data).

I l

  • Revise reporting rules to better capture equipment reliability information.

10/97

  • Evaluation of voluntary approach for collecting reliability data i
  • Final reliabihty data rule ( if necessary) t 6 mo. After h

Decision on Vol.

Approach.

t

  • Determine need to revise LER rule to eliminate unnecessary and less safety-sigothcant reporting.

6/98

  • Determir e need to revise reporting rules and to better capture ASP, CCF, and human performance events.

6/98 r

A2-ix

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Regulatory Activity Objectives Methods Target Lead Schedule Offre(s) 3.6 STAFF TRAINING

  • Present PRA curriculum as preseritty scheduled for FY
  • Continue current contracts to present courses as scheduled.

Ongoing AEOD 1996

  • Maintain current reactor technology courses that include PRA Ongoing insights and applications.
  • Improve courses via feedback.

Ongoing

  • Review current PRA course material to ensure consistency with Complete Appendix C.
  • Develop and present Appendix C training courses.
  • Pmpare course material based on Appendix C.

C RES and

  • Present courses on Appendix C.

C AEOD

  • Determine staff requirements for training. including
  • Review JTAs performed to date.

C AEOD anatysis of knowledge ar'd skills, needed by the NRC

  • Perform representative JTAs for staff positions (JTA Pilot C

staff.

Program).

C

  • Evaluate staff training requirements as identrfied in the PRA Implementation Plan and the Technical Training Needs Survey (Phase 2) and incorporate them into the training requirements Ongoing analysis.
  • Anatyre the results of the JTA Pilot Program and determine Ongoing requirements for additional JTAs.

Ongoing

  • Complete JTAs for other staff positions as needed.

Ongoing

  • Solicit a review of the proposed training requirements.
  • Finalize the requirernents.
  • Revise current PRA curriculum and develop new training
  • Prepare new courses to meet identified needs.

12/97 AEOD program to fulfill identified staff needs.

  • Revise current PRA courses to meet identified needs.

12/97

  • Revise current reactor technology courses as necessary to C

include additional PRA insights and applications.

3/96

  • Present revised PRA training curriculum.
  • Establish contracts for presentation of new PRA curriculum.

Ongoing AEOD

  • Present revised reactor technology courses.

Ongoing

  • Improve courses based on feedback.

Ongoing k

A2-x k

e 4.0 NUCLEAR MATERIALS AND LOW-LEVELWASTE SAFETY AND SAFEGUARDS REGULATION Regulatory Activity Objectives Methods Target Lead Schedule Office (s) 4.1 Validate risk analysis

  • Validate risk analysis rnethodology
  • Hold a workshop consisting of experts in PRA and 8/94 NMSS methodology developed to developed to assess the relative profile of HRA to examine existing work and to provide C

assess most likely failure most likely contributors to misadministratsons recommendations for further methodological modes and human for the gamma stereotache device (gamma development.

performance in the use of knife).

9/95 industrial and medical

  • Examine the use of Monte Carlo simulation and its C

radiation devices.

application to relative risk profiling.

9/95

  • Examine the use of expert judgement in developing C

error rates and consequence measures.

  • Continue the development of the relative risk
  • Develop furictionally based generic event trees.

TBD RES/

methodology, with the addition of event tree NMSS modeling of the brachytherapy remote afterloader.

  • Extend the application of the methodology
  • Develop generic risk approaches.

TBD RES/

and itsfurther development into additional NMSS devices, including teletherapy and the pulsed high dose rate afterioader.

4.2 Continue use of risk

  • Develop decision criteria to support
  • Conduct enhanced participatory rulemaking to B/94 PR RES &

assessment of allowab'e regulatory decision making that establish radio ical critena for decommissioning C

NMSS radiction releases and doses incorporates both deterministic and risk-nuclear sites; t nical support for rutemaking Final Rule associated with low-level based engineering judgement.

including comprehensive nsk based assessrnent of Published radioactive waste and residual contamination.

5/97 residual activity.

  • Work with DOE atid EPA to the extent practicable to Ongoing develop common approaches, assumptions, and models for evaluating nsks and attemative remediation methodologies. (Risk harmonization).

I 4.3 Develop guidance for the

  • Develop a Branch Technical Position on
  • Solicit public comments 5/97 C.

NMSS &

revew of nsk associated with conducting a Performance Assessment of a

  • Publish final Branch Technical Position
TBD, RES waste repositories.

LLW disposal facility.

Dependent on Resources l

A2-xi

l l

Regulatory Activity Olvetives Methods Target Lead.

Schedule Office (s) l 4.4 Risk assessment of Material

  • Develop and demonst. ate a risk assessment
  • Develop and demonstrate methods for determming 7/98 l

uses.

for industrial gauges containing cesium-137 the risk associated vnth industrial gauges containing i

and cobalt-60 using PRA and other related cesium-137 and cobat-60.

techniques.

  • Final report as NUREG 10/98
  • The assessment should allow for modification based on changes in regulatory requirements.
  • Use empirical data as much as practicable f
  • Develop and demonstrate risk assessment methods for apphcation to medical and industriallicensee activities.

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t7 5.0 HIGH-LEVEL NUCLEAR WASTE REGULATION Regulatory Activity Objecthes Methods Target Lead Schedule Ofree(s) 5.1 REGULATION OF HIGH-

  • Develop guidance for the NRC and CNWRA
  • Assist the staff in pre-liceMing activities and in Ongoing NMSS LEVEL NUCLEAR WASTE staffs in the use of PA to evaluate the safety of license application reviews HLW programs.
  • Develop a technical assessment capability in total-system and subsystem PA for use in Icensing and pre bcensing reviews.
  • Combine specia!ized technical discip!inet (esih sciences and engineenng) with those of sy.in modelers to improve methodctogy.
  • Identify significant events processes, and
  • Perform sensitivity studies cikey technicalissws Ongoing NMSS parameters affecting total system performance.

using iterative performance assessment (IPA).

  • Use PA and PSA methods, results and insights to
  • Assist the staff to maintain and 'o refine the Ongoing NMSS evaluate proposed changes to regulations regulatory structure in 10 CFR Put 60 that pertains goveming the potential repository at Yucca to PA.

Mountairt.

  • Apply IPA analyses to advise EPA in its development of a Yucca Mountain regulation
  • Continue PA activities during interactions with
  • Provide guidance to the DOE on site Ongoing NMSS DOE during the pre-licensing phase of repository characterization requirements, ongoing design work, development, site charactenzation, and repository and licensing issues irnportant to tne DOE's design.

development of a complete and high-quality license application.

  • Compare resutts of NRC's iterative performance assessment to DOE's TSPA-95 to dentify major differences / issues.

5.2 APPLY PRA TO SPENT FUEL

  • Demonstr9e methods for PRA of spent fuel
  • Prepare user needs letter to RES 4/97C RES/NMSS STORAGE FACILITIES sicrage facraies.
  • Conduct PRA of dry cask stomge 9/99 5.3 CONTINUE USE OF RISK
  • Use PRA methods, results, and insiahts to
  • Update the database on transportation of radioactive End of FY NMSS ASSESSMENT IN SUPPORT evaluate regulations goveming the fransportation materials for fW2 applications 99 OF RADIOACTIVE MATERIAL of radioactive material.
  • Revalidete the results of NUREG-0170 for spent fuel TRANSPORTATION shipment risk es: mates i

G/99 A2-xi;i

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