ML20197J008

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Summary of 980916-17 Meeting with NEI & Others to Prepare for 980928-1001 Performance Assessment Improvement Workshop. Attached Materials Presented & Discussed.Final Versions of Matls Provided as Handouts at Workshop
ML20197J008
Person / Time
Issue date: 11/04/1998
From: Isom J
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
References
NUDOCS 9812140229
Download: ML20197J008 (33)
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Text

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November 6,1998 i

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MEMORANDUM TO: File i

, FROM: James A. Isom, Operations Engineer Inspection Program Branch Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF THE SEPTEMBER 16 AND 17,1998 MEETINGS  !

WITH THE NUCLEAR ENERGY INSTITUTE TO DISCUSS  ;

OPTIONS FOR REVISING THE REGULATORY OVERSIGHT l PROCESS i i

On September 16 and 17,1998, the NRC met with facilitators, NEl, and others, to prepare for

. the September 28 - October 1,1998 Performance Assessment improvement Workshop. The i

attached materials were presented and discussed. Final versions of the materials were provided as handouts at the workshop.

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9812140229 981104 PDR REVGP ERONUMRC PDR  !

CONTACT: James A. Isom i 301-415-1109 t _ gjg l

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I 2 l Attachments: 1. List of Attendees

2. Various Handouts for the Performance Assessment Improvement -

Workshop (September 28 - October 1,1998)  ;

1 J

i i l DISTRIBUTION:

PUBLIC .

i Central Files  !

PIPB R/F

. F. Gillespie -

I M. Johnson  ;

C. Holden  ;

A. Madison i J. Isom  !

T. Frye 3 J.Jacobson i

D. Gamberoni R. Barrett P. Baranowsky '

B. Mallet 1

4 i

DOCUMENT NAME: MTG0916. SUM To receive a copy of this docurnent, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures

  • N" = No copy

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OFFICE PIPB: DISK l PIPB: DISP l l l l NAME- JAlsopiM MRJohnsonM aV DATE 11/ 0 4 /98 / 11/ 4 /98 ' " IT OFFICIALjECORD COPY

SEPTEMBER 16 AND 17,1998, NRC/NEl/FACILITATORS MEETING ON PERFORMANCE ASSESSMENTIMPROVEMENTWORKSHOP (SEPTEMBER 28 - OCTOBER 1,1998)

SIGN-IN SHEET NAME ORGANIZATION PHONE NUMBER  !

' Ralph Andersen NEl 202-739-8111

  • Richard Barrett NRC/NRR 301-415-3183
  • Carl Berlinger NRC/NRR 301-415-3627

" Mark Cunningham NRC/RES 301-415-6189

  • Tom Essig NRC/NRR 301-4151282

" Stephen Floyd Nuclear Energy Institute 202-739-8078

" Timothy Frye NRC/NRR 301-415-1287

" David L. Gamberoni NRC/NRR 301-415-1144

  • Ellen Ginsberg NEl 202-739-8140
  1. Clare Goodman NRC/NRR 301-4151047 "Heidi Hahn LANL 505-665-4606
  • Tom Houghton NEl 202-739-8107
  1. Jeffrey Jacobson NRC/NRR 301-415-2977
  • Jack Kudrick NRC/NRR 301-415-2871
  1. Ron Lloyd NRC/AEOD 301-415-7479
    • Alan Madison NRC/NRR 301-415-0412
  • Steve Mays NRC/AEOD 301-415-7496
  • Charlie Miller NRC/NRR 301-415-1086
  1. Alan Nelson NEl 202-739-8110
  1. Peter Prescott NRC/AEOD 301-415 7591
  1. Gary Sanborn NRC/OEDO 301-415-1726
  • Mark Satorius NRC/OE 301-415-2747
  1. Peter Wilson NRC/NRR 301-415-1114
  • Attended Meeting on September 16,1998
  1. Attended Meeting on September 17,1998
    • Attended Meeting on September 16 and 17,1998 ATTACHMENT 3

1 DRAFT PERFORMANCE ASSESSMENT WORKSHOP SEPTEMBER 28 - OCTOBER 1,1998 SEPTEMBER 28,1998 - DAY 1 PURPOSE: To explore / develop a framework for assessment of facilities which takes into account a graded / threshold approach.

. TOPIC / LOCATION: TIME:

1

1. REGISTRATION 8:00 - 9:00 AM (HOTEL LOBBY)
11. WELCOMEllNTRODUCTION 9:00 - 9:30 AM L. Joseph Callan - Executive Director for Operations Conference Administration (Congressional Ballroom) lil. BACKGROUND PRESENTATION 9:30 - 10:30 AM A. Performr.nce Assessment Process Problem <

Mike Johnson - Acting Branch Chief, inspection Program Branch B. Objectives of Performance Assessment Mike Johnson - Acting Branch Chief, inspection Program Branch C. IRAP Effort Dave Gamberoni- Reactor Operations Engineer, inspection Program Branch DRAFT ATTACHMcMI 2

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DRAFT

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D. NEl White Paner Steve Floyd/ Jim Levine j (Congressional Ballroom)

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IV. BREAK 10:30-10:45 AM V. STRUCTURE OF WORKSHOP 10:45 -11:30 PM A. Construct Comerstones of Safety Anoroach l Mike Johnson - Acting Branch Chief, inspection Program Branch a  ;

B. Fundamentallasues (Attributes) Breakout Sessions Alan Madison - Acting Section Chief, inspection Program Branch l

C. Detailed Cornerstone Deveicoment Breakout Sessions -

Alan Madison - Acting Section Chief, inspection Program Branch (Congressional Ballroom)

VI. NPR AND RESEARCH OFFICE DIRECTORS' REMARKS 11:30 - 12:00PM VI. LUNCH 12:00 - 1:00 PM Vll. NRC/ INDUSTRY BREAKOUT SESSIONS 1:00 - 5:00 PM NRC and Industry will breakout into 2 groups to discuss the proposed comerstone model 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.

Are these " cornerstones of safety" sufficient (comprehensive, useful for assessment, clear)?

DRAFT

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ISSUE 2 i

Do the " cornerstones of safety" provide a risk-informed framework for the regulatory  ;

oversight process? If not, what changes should be made?

t (Congressional Ballroom) b Vill. ADJOURN 5:00 PM I i

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PERFORMANCE ASSESSMENT WORKSHOP SEPTEMBER 28 - OCTOBER 1,1998 SEPTEMBER 29,1998 - DAY 2

{

After reconvening to discuss the cornerstone approach, we will conduct issue breakout sessions for the rest of the day to explore and discuss different policy and regulatory issues.

TOPIC / LOCATION: TIME:

1. RECONVENE NRC AND INDUSTRY BREAKOUT SESSIONS TO DISCUSS THE CORNERSTONE APPROACH (cont'd from day 1) 8:00-9:00 AM (Congressional Ballroom)
11. BREAK 9:00-9:15 AM lli. NRC AND INDUSTRY BREAKOUT SESSIONS REPORT BACK TO GENERAL ASSEMBLY ON CORNERSTONE APPROACH 9:15-10:15 AM (Congressional Ballroom)

IV. ISSUE BREAKOUT SESSIONS 10:15-12:00 PM (Four issue breakout sessions (Policy; PRA; Performance Indicator; Enforcement) will be on-going at the same time.)

A. Policy Group (General Policy issues: Safety Performance Expectationst Regulatory Oversight Process)

NRC FACILITATOR: FRANK J. MIRAGLIA INDUSTRY FACILITATOR: ???

ISSUE 1 is there a threshold of licensee. safety performance above which the NRC can allow licensees to address weakness without NRC action? In other words, at what level above a *zero-defect" tolerance can licensees safely operate without NRC interaction?

ISSUE 2 DRAFT AT#cmuN r Z

DRAFT The threshold for NRC interaction (based on the response to issue 1), to what level of licensee performance does the NRC need leading indication of changes in 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?

ISSUE 3 To what extent should the NRC maintain independent regulatory oversight? How?

1 ISSUE 4 Given that the NRC will continue inspecting selected areas of licensee performance, how should NRC inspection findings be factored into the regulatory process?

("* assign room *")

B. RISK INSIGHTS IN ASSESSMENT GROUP NRC FACILITATOR: RICHARD J. BARRETT INDUSTRY FACILITATOR: ???

ISSUE 1 To what extent should the performance indicators and their associated performance >

thresholds be risk-informed? What process should be followed to select them?

ISSUE 2 I

Can a set of performance indicators be used to assess the integrated risk significance of licensee performance?

ISSUE 3 To what extent do we need to use individual site PRAs to develop risk-informed, site-specific performance indicators to complement the generic performance indicators?

(*" assign room ***)

DRAFT ,

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l DRAFT C. PERFORMANCE INDICATORS / INSPECTION RESULTS INTEGRATION GROUP NRC FACILITATOR: PATRICK W. BARANOWSKY INDUSTRY FACILITATOR: ??? l ISSUE 1 l

What is the role of performance indicators in the regulatory oversight process?

ISSUE 2 What group of performance indicators provides an adequate measure of licensee performance? What are the necessary attributes of these performance indicators?

ISSUE 3 How are performance indicators integrated with inspection results?

ISSUE 4 How can the NRC assure that performance indicator data is accurately developed, recorded, and submitted in a timely manner? Voluntary program? Rulemaking? What l controls should be placed on this process?

("* assign room ***)

D. ENFORCEMENT GROUP NRC FACILITATOR: JAMES LIEBERMAN INDUSTRY FACILITATOR: ???

ISSUE 1

. How does the enforcement process interact with the assessment process?

ISSUE 2 What NRC actions are most effective in encouraging timely licensee corrective actions?

3 ISSUE 3 What methods of communicating performance assessment results are most effective, accurate, fair, and objective?

(assign room)

DRAFT

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DRAFT V. LUNCH 12:00 - 1:00 PM VI. ISSUE BREAKOUT SESSIONS 1:00 - 3:00 PM 1

continue with issue breakouts sessions Vll. FUNDAMENTAL ISSUES BREAKOUT SESSIONS REPORT BACK TO GENERAL ASSEMBLY 3:00 - 5:00 PM

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i PERFORMANCE ASSESSMENT WORKSHOP i SEPTEMBER 28 - OCTOBER 1,1998 SEPTEMBER 30,1998 - DAY 3 .

1. RECONVENE AT CONGRESSIONAL BALLROOM 8:00-8:15 AM
11. DETAILED CORNERSTONE DEVELOPMENT BREAKOUT SESSIONS 8:15 - 12:00 PM I

Five groups - each group focuses on a single "comerstone of safety" and:

t A. Clearly defines the comerstone/ objectives B. Defines the building blocks for the cornerstone C. Determines how the measure performance for each building block (Ident;fies performance indicators and necessary inspection areas)

D. Identifies performance indicators related to overall plant performance in the cornerstone area l l

A. GROUP 1.

INITIATING EVENTS NRC FACILITATOR: RICHARD J. BARRETT INDUSTRY FACILITATOR: ???

("* assign room ***)

B. GROUP 2:

MITIGATION SYSTEMS NRC FACILITATOR: PATRICK W. BARANOWSKY INDUSTRY FACILITATOR: ???

("* assign room *") l l

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DRAFT C. GROUP 3:

CONTAINMENT SYSTEMS i

' NRC FACILITATOR: JOHN A KUDRICK ,

INDUSTRY FACILITATOR: ??? I i

("*a:isign room *")

I D. GROUP 4:

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e EMERGENCY PREPAREDNESS NRC FACILITATOR: CHARLES L. MILLER INDUSTRY FACILITATOR: ???

("* assign room *")

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RADIOLOGICAL CONTROLS j NRC FACILITATOR: THOMAS H. ESSIG INDUSTRY FACILITATOR: ??? I ll1. LUNCH 12:00 - 1:00 PM 4

IV. CONTINUE WITH CORNERSTONE DEVELOPMENT 1:00 - 3:00 PM ,

V. DETAILED CORNERSTONE DEVELOPMENT BREAKOUT SESSIONS REPORT BACK TO ,

THE GENERAL ASSEMBLY 3:00 - 5:00 PM DRAFT ArrmtmauT z.

l DRAFT PERFORMANCE ASSESSMENTWORKSHOP SEPTEMBER 28 - OCTOBER 1,1998 OCTOBER 1,1998 - DAY 4 .

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1. RECONVENE DETAILED CORNERSTONE DEVELOPMENT BREAKOUT SESSION GROUPS 8:00 - 10:30 PM Five groups - each group focuses on a single "comerstone of safety":  ;

ll. DETAILED CORNERSTONE DEVELOPMENT BREAKOUT SESSIONS REPORT BACK TO THE I GENERAL ASSEMBLY 10:30 - 12:00 PM 1

Ill. LUNCH 12:00 - 1:00 PM I IV. WRAP-UP 1:00 - 2:00 PM l

i DRAFT 1

ATT80MlstT 2. l l

DMFT Facilitators (9)

Fundamentalissues A. General Policy issues NRC - Frank Miraglia NEl -

B. Use of Risk insights in Assessment NRC - Rich Barrett NEl -

C. Use of Performance Indicators and Integration with inspection Results NRC - Pat Baranowsky NEl -

D. Role of Enforcement in Regulatory Oversight / Range of NRC Actions / Communications NRC - Jim Lieberman NEl -

Cornerstones A.' initiating Events NRC - Rich Barrett j

NEl - -

B. Mitigation Systems NRC - Pat Baranowsky NEl - I C. Containment Systems NRC -Jack Kudrick NEl -

D. Emergency Preparedness NRC - Charlie Miller NEl -

E. RadiologicalControls NRC -Tom Essig NEl -

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Facilitator Roles and Responsibilities Technical Facilitators LANL Facilitators

  • Provide context for issues Lead session
  • Answer technical questions and Ensure assigned roles are followed provide NRC/ industry positions . Manage overall discussion: keep Manage technical aspects of time, solicit participation discussion .Take notes during discussion Synthesize input
  • Present results to large group . Prepare workshop report

.NRC: Lead implementation teams . Assist with implementation work (TBD) (TBD) i 2

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Technical Facilitator Dos and Don'ts Do: Balance your participation: You're part of a facilitation team!

Do: Provide clarification whenever you feel it is necessary for common understanding of the discussion Do: Respond to all requests for clarification with an agency or industry position I

Do: Show respect for the views of others, even if you don't agree with them ,

Don't: Debate the issues with members of the breakout group or your counterpart facilitator

.j Don't: Step out of facilitator role without acknowledgement

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DRMT F5500NEETEA115 NRC's SAFETYASARESRT Overa!iSafety gFg333333 Mission g REACTOR OPERATIOR I I I Strategic EXPOSURE FROM EXPOSURE FROM RADIOLOGICAL REACTOR PLANT NON-REACTOR Performance REACT R A DENT ACCIDE I OGICAL WORKER EXPOSURE SAFEGUARDS g l l l l 5 INITIATING OPERATIONAL OVER PHYSICAL

  • MITIGATION
  • CONYAINMENT EMERGENCY f EVENTS SYSTEMS SYSTEMS PREPAREDNESS 8

(ALARA) ihh PROTECTION 0

  • PERFORMANCEINDICATOR
  • INSPECTION
  • DECISION THRESHOLDS a

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OBJEdTIVES OF CORNERSTONES EXPOSURE FROM REACTOR ACCIDENT REl5ASES INITIATING EVENTS:

Limit the frequency of those events which challenge the heat removal capability of the reactor plant, commensurate with their safety significance. These events include both operating events such as loss of main feedwater and shutdown events such as loss of reactor coolant system inventory.

MITIGATION SYSTEMS:

Ensure that the reliability and capability of those systems required to prevent  !

and/or mitigate core damage are mairitained at a level commensurate with their safety significance.

l CONTAINMENT SYSTEMS.

Ensure that the reliability and capability of those systems required to ensure containment integrity are maintained at a level commensurate with their safety significance.

EMERGENCY PREPAREDNESS:

Ensure that the capability is maintained to take adequate protective measures in the event of a radiological emergency.

EXPOSURE FROM NON-REACTOR ACCIDENT RADIOLOGICAL PLANT  ;

RELEASES OPERATIONAL (ALARA):

Maintain those radioactive releases resulting from plant operation as low as reasonably ::,ii;cvable (ALARA).

EVENTS: ,

Ensure that reieases from events do not exceed licensed and 10 CFR Part 20 limits. Included would be events such as transportation accidents, spent fuel pool accidents and lerge spills.

RADIOLOGICAL WORKER EXPOSURE OPERATIONAL (ALARA):

Maintain radiation worker exposure during plant operation ALARA.

OVER EXPOSURE INCIDENTS:

. Maintain radiation worker exposure below licensed and 10 CFR Part 20 limits.

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i REACTOR PLANT SAFEGUARDS  !

l PHYSICAL PROTECTION: l Still under development, but would include the protection of vital plant equipment and prevent the diversion of special nuclear material.

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OFlAFr*1 WORKSHOP DAY 2 FUNDAMENTAL ISSUE BREAKOUT SESSIONS:

Objective: The objective of these breakout sessions is to discuss those fundamental issues for which decisions and attributes must be agreed upon to support the continued development of a framework for a regulatory oversight process. These fundamental issues have been grouped for discussion in focused breakout sessions into the following areas:

- General Policy issues

. Use of Risk insights in Assessment Use of Performance Indicators and Integration With inspection Results

. Role of Enforcement in Regulatory Oversight I

The decisions, attributes, and criteria decided upon during these breakout sessions will then be used as the basis for the more detailed oversight framework development which will occur on day three of the workshop.

A. General Policy issues: Safety Performance Exoectations/ Regulatory Oversiaht Process issue 1. Is there a threshold of licensee safety performance above which the NRC can allow licensees to address weakness with decreased NRC action? In i other words, at what level above a "zero-defect" tolerance can licensees  !

safely operate with decreased NRC interaction?

Background:

Currently the NRC interacts with licensees at a very low threshold of performance weaknesses. Licensee procedure quality and human performance errors with little or no safety significance are reviewed by the NRC and extrapolated to make broad conclusions regarding the effectiveness of licensee programs.

Prooosed Position: There is a level of licensee performance above "zero-defect" which could warrant decreased NRC interaction if; (1) the threshold is tied to risk, (2) there is a sufficient safety margin below the threshold to account for uncertainty, (3) performance is measurable with clear criteria,4) the process is not overly reliant on a single source, and 5) the licensee has a strong corrective action program for identifying and resolving problems.

Issue 2. Given the threshold for NRC interaction (based on the response to issue 1), what type of leading indication does the NRC need to have early indication of changes 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?

Backaround: The Commission has directed the staff to consider the development of performance indicators that provide a leading or DRAFT n-

DRAFT 2

concurrent indications of plant performance, to the extent practicable.

i Tooics for Discussion: )

What are we trying to provide leading indication to:

- Prevention of plant events due to failures of SSCs?

Prevention of extended shutdowns due to performance issues?

Ensure public health and safety by minimizing risk-significant events?

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. Role of leading versus lagging indicators Prooosed Position: It should not be expected that any process can provide a leading indication to every plant event caused by the failure of an SSC or human error. However, the assessment process should be sufficiently leading so that indicators would give an early indication of problems before a threshold is crossed. These thresholds must be set at the correct level to ensure adequate safety margins.

l issue 3. How should the NRC maintain independent regulatory oversight?

Backaround: The industry has suggested that much of the NRC inspection effort duplicates licensee inspections, self-assessments and QA Audits. The industry has suggested that the NRC use more licensee generated information to make assessments, in lieu of NRC inspection.

This must be balanced against the fact that one of the principles of good regulation is that the NRC must maintain independence in regulatory oversight.  ;

Prooosed Position: The NRC can place more reliance on licensee generated assessment results. However, the NRC needs to 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 of licensee performance, how should NRC inspection findings be factored into the regulatory process?

Tooics for Discussion: Current assessment processes are based on inspection findings being used to provide a rebuttable presumption on l licensee performance, with performance indicators (Pis) used to place the inspection findings in context and to provide compelling reasons to override the inspection findings.

DRAFT

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An alternative would be that Pls would form the basis for a rebuttable presumption on licensee performance. When warranted, inspection findings would then be used to develop a compelling reason to override l the indicators. '

Prooosed Position: The NRC will continue to perform a baseline

, inspection effort. In a process which uses objective Pls to form a rebuttable presumption, this baseline inspection would:

Verify the adequacy and the accuracy of the performance

,- indicators.

Be used to assessed the risk-significant areas not adequately covered by Pls, Provide reactive inspection in response to significant plant events. l 1

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B. Use of Risk Insiahts in Assessment lssue 1. To what extent should the performance indicators (Pis) and their associated performance thresholds be risk-informed? What process and  ;

criteria should be followed to select them?

  • Tooics for Discussion:

What criteria could be used to select risk-informed, site specific 4

Pts (e.g. based on individual site PRAs, based on reactor type such as 3-loop W)?

Prooosed Position: Pls and their performance thresholds should be risk-informed to the maximum extent possible. This would involve the generation of certain site-specific Pls. Performance indicators without a direct tie to safety do not serve a very useful function for NRC safety assessments.

i Issue 2. How can a set of performa. ce indicators be used to assess the integrated risk significance of licensee performance?

l Tooics for Discussion: The value of risk assessment is in the ability to evaluate and identify higher risk-significant events through the integration

, of individual issues which may have had lower risk-significance.

Individual equipment failures, which may not individually cross PI

thresholds, may result in situations or configurations with high risk-significance.

Proposed Position: The high, but not total, independence of the cornerstones allows some conclusions to be drawn about the integrated risk significance of licensee operations without having to perform a

detailed risk calculation (like a CCDP). For example, containment l problems in conjunction with an increased frequency of initiating events
are more significant than just having containment problems.

The cornerstone approach does not address the significance of instantaneous situations. For example, event assessment techniques would be necessary to address issues such as scrams with multiple complications and to address their integrated safety significance.

Issue 3. To what extent do we need to use individual site PRAs to develop risk-informed, site-specific performance indicators to complement the generic performance indicators?

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l l . Do we need to rely on site specific or NRC PRA models?

l -  : To what quality would site specific PRAs need to be?

l-Can expert panels be used to supplement site specific PRAs?

l Proposed Position. We need to use individual site specific risk analysis to the extent necessary to develop risk-informed Pls and to set risk-informed thresholds.

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C. Use of Performance Indicatore and Inteoration with Insoection Results issue 1. What is the role of performance indicators (Pis) in the regulatory oversight process?

Procosed Posh Pls can be used to provide an objective measure which forms a rebuttable presumption about licensee performance.

Issue 2. What types of Pls (e.g. generic, site specific) provide an adequate measure of licensee performance? What are the necessary attributes of these performance indicators?

Tooics of Discussion:

- What are the roles and relatbnships of site specific Pls (e.g. SSC Availability) and generic Pls (e.g. Scrams)?

- What measures need to be taken to ensure the accuracy and adequacy of Pls?

Prooosed Position: A combination of generic and site-specific Pls would be required.

The performance indicators: 1) have to be capab!e of being measured,2)  ;

must be timely, 3) must have risk-informed thresholds,4) must have  ;

significant margin between thresholds to be adequately leading,4) must l not be prone to manipulation, and 5) must not result in adverse licensee actions.

Issue 3. How are performance indicators integrated with inspection results? i Backaround: A P! esed assessment proce:s may include up to 20 l individual Pls to ai ntei < assess licensee performance. Results from I the continuing becGne ir e action will also feed into the assessment process. This information needs to integrated in some fashion so that NRC action can be taken, based on assessment results, in a scrutable and transparent manner.

Tooics of discussion:

. What methods can be used to integrate individual Pls?

. What methods can be used to integrate inspection findings with Pis?

- Can a PI like method be developed to evaluate inspection findings?

. What is the role of subjective methods (e.g. PPR meetings and SMMs)in evaluating Pls and inspection findings?

Prooosed Position: The means must be developed so that NRC actions DRAFT m~ z_

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i can be taken in a manner which is scrutable, transparent, and predictable  !

to both the licensee and the public.  ;

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Issue 4. 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?  !

Backaround: Much of the data used in an improved assessment process could be generated and submitted by the licensees. This may include site j specific Pis, licensee self-assessments, and QA audit results.

Tooics for Discussion:

- Pros and Cons for rulemaking to control licensee information i submittal. i Pros and Cons for an industry voluntary program for licensee  ;

information submittal.

L Prooosed Position: A voluntary licensee program would require a firm  !

industry commitment.

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D. Role of Enforcement in Regulatory Oversiaht/ Range of NRC Actions / Communications issue 1. How should the enforcement process interact with the assessment process?

Background:

Currently the enforcement process acts as an input to the assessment process. It what ways should this relationship change?

Prooosed Position: The most effective role of enforcement is to encourage licensee corrective actions. Enforcement will continue to be a result and output of inspection. However, assessment results can play a strong role in determining appropriate enforcement actions.

Issue 2. What NRC actions are most effective in encouraging timely licensee corrective actions?  ;

Discussion Tooics:

What types of NRC actions are necessary outputs from an assessment process?

Which current actions, if any, would be unnecessary outputs from an improved process?

Prooosed Position: NRC actions resulting from an assessment should be  ;

regulatory based (e.g. inspection,50.54(f) letter, orders).

Issue 3. What methods of communicating performance ascessment results are ,

most effective, accurcte, fair, and objective? l Discussion Tooics:

l How should assessment results be communicated to the licensee and public (e.g. written reports, public meetings)

Prooosed Position: An assessment process must be developed which I results in clear statements of licensee performance which can be easily and effectively communicated to both the licensees and the public.

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l Workshop Day 3 j Cornerstone Development Breakout Session i Objective: The objective of this breakout session is to develop a process map which

! . identifies what information can be gathered and monitored to adequately assess licensee performance in one of the comerstone areas. A " Top-Down" approach, i similar to the one attached, shou'd be used to: ,

l l . Identify the objective and scope of the comerstone.

. Identify what's important to monitor / assess in the comerstone.

Discuss which of these areas can be adequately monitored by performance indicators.

l . Discuss the criteria for sebcting the performance entena and associated l thresholds.

Discuss what inspection (if any) is needed to supplement the j performance indicators.

METHODOLOGY l

. Discuss the objective of the comerstone and why it is important to support the 1

' associated Strategic Performance area and the overall agency mission. (This should have been completed on Day 1 of the workshop)

For example, the objective of the mitigation systems comerstone is to:

" Ensure that the reliability and capability of those systems required to prevent and/or mitigate core damage are maintained at a level commensurate with their safety i significance." l Decide what the scope of the comerstone is. Identify criteria or guidance for determining the scope. '

For example, the scope of structures, systems, and components (SSCs) for the mitigation systems comerstone would consist of those high risk significant SSCs relied l upon for core damage mitigation in PRAs. This would generally be 6-8 systems, with  !

guidance for selection contained in the Reliability Data Rule. j

. Discuss what's important to assess / monitor in the comerstone and what the inter-relationships of these items are (which ones are independent / dependent). Develop definitions for each of these areas.

For example, the following areas are most important to monitor for mitigation systems SSC Availability- SSCs available to perform their design function when demanded. )

SSC Reliability - SSCs reliably meet design functions such as service time, when demanded. l SSC Capability- SSCs capable of producing their design function such as operating pressures and system flow rates.

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5 The following areas are also important to monitor, but can be adequately monitored  !

l through SSC Availability, Reliability, and Capability.

Procedure Quality i

Human Performance Common Cause Failure i Design j Configuration Control a

j -

Determine what is important to measure in each of these areas to ensure that the

. comerstone objective is meet. {

l

For example, for Human Performance it may be important to measure
(1) licensee l j personnel ability to operate and maintain the plant in accordance with station j j procedures, and (2) licensed operator ability to respond to accident conditions.

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Discuss which of these items can be adequately measured using performance indicators  :

(Pis). Discuss and develop criteria for selecting these Pls and for setting thresholds for }

action.

l For example, configuration control, common cause failure, procedure quality, and j human performance may all be adequately monitored by an SSC availability index which j monitors the availability of the 6-8 high risk-significant SSCs. Thresholds for availability i could be set based on assumptions contained in the plants FSAR or PRA. ,

l

  • Discuss what additional inspection activities should be performed to supplement Pls.

j For example, the licensees ability to control changes to the plants design basis to j j prevent common cause failures may need to be inspected through engineering program

  • l inspections.

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