ML20197J347

Summary of 981202 Meeting with NEI to Continue Exchange of Info & Views in Developing Improvements to NRC Process for Overseeing Performance of Operating Reactors.Meeting Agenda & Written Info Exchanged Encl

ML20197J347
Person / Time
Issue date:	12/04/1998
From:	Isom J NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
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ML20197J353	List: ML20197J347 ML20197J419
References
NUDOCS 9812150046
Download: ML20197J347 (38)

Text

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December 4, 1998 MEMORANDUM TO: File

, / /

FROM: James A. Isom, Operations Engineer /Y'#

inspection Program Branch [

Office of Nuclear Reactor Regulation 4

SUMMARY

OF THE DECEMBER 2,1998 MEETINGS WITH THE NUCLEAR ENERGY INSTITUTE TG DISCUSS OPTIONS FOR REVISING THE REGUL ATORY OVERSIGHT PROCESS On December 2,1998, a public meeting was conducted between NRC and NEl to continue exchange of information and views in developing improvements to NRC processes for overseeing performance of operating reactors. The meeting agenda and written information exchanged are attached.

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[N2 CONTACT: James A. Isom 301-415-1109 9812150046 981204 PDR REVGP ERONUMRC [{._.~[ t (_}

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[ 2 l Attachments: 1. Agenda

2. List of Attendees

3. Performance Indicator Table for Selected Plants

4. Risk information Matrix Number 1 l

5. Risk Information Matrix No. 2

6. Action Matrix

7. NEl Proposed NRC Inspection Findings Evaluation Matrix l 8. Table 5 Summary of Thresholds l 9. Conceptual Model - Overall Licensee Performance / Action

10. Revised Regulatory Oversight Process - Transition Plan

11. Results of the NPgO's Assessment Team Task Group Working Sessions l 12. NRC Nuclear Pc4ver Reactor Baseline inspection Program

13. Appendix 1 Basis Document for inspectable Areas

14. Appendix ll Comerstone Charts l

15. CDF Sensitivity Results for Selected Plants l

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l DISTRIBUTION:  !

! PUBLIC Central Files l PIPB R/F F. Gillespie M. Johnson C. Holden A. Madison J. Isom T. Frye

J.Jacobson l D. Gamberoni R. Barrett P. Baranowsky B. Mallet l

DOCUMENT NAME: MTG122. SUM To receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures

• N" = No copy OFFICE PIPB: DISP PIPB: DISP 1p l l l  ;

NAME JAlsom-63 MRJohnsonW\ _ l DATE 12/e3 /98 / 12/ 't /98 [h  !

OFFICIAtJtECORD COPY l l

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, December 2,1998 ,

3 NRC/NEl PUBLIC MEETING Agenda 8:00am Welcomelintroduction Alan Madison 8:15am Assessment Development Team Michael Johnson l Transition Planning Industry Survey 10:00am Break 10:15am Assessment Development Team Michael Johnson l

Definition / Significance of Inspection Findings 11:15am inspection Rebaselining Team Bruce Mallett 1

12:00 noon Lunch l

1:00pm inspection Rebaselining Team Bruce Mallett inspectable Areas 2:45pm Break L  !

I 3:00pm Framework Development Team Patrick Baranowsky Thresholds i l

4:45pm Future Interactions Alan Madison l 5:00pm Adjourn l

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l Attachment 1 L

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DECEMBER 2,1998, NRCINEl MEETING ON PERFORMANCE ASSESSMENT PROCESS IMPROVEMENTS SIGN-IN SHEET NAME ORGANIZATION PHONE NUMBER Donna Alexander Carolina Power and Light 919-546-6901 l P. W. Baranowsky NRC/AEOD 301-415-1111 i Scott Rauer APS 602-393-5978 Robert W. Boyce PECO 610-640-5620 Jim Chase OPPD 402-571-9906 Stephen D. Floyd NEl 202-739-8078 David Garchow PSEG 609-339-3250 Don Hickman NRC 301-415-6829 Tom Houghton NEl 202-739-8107 Michael Johnson NRC/NRR 301-415-1241 W. D. Johnson NRC/R-IV 301-415-1325 Marcia Lesniak COMED 630-663-6484 Jim Levine APS 602-393-5300 Steve Lockfort NYPA 914-681-6868 Alan Madison NRC/NRR 301-415-6412 Bruce Mallet NRC/R-Il 301-415-1425 Jim McCarthy Virginia Power 804-273-2699 Kevin Neitmann BG&E 410-495-4491 G. W. Parry NRC/NRR 301-415-1464 Steve Stein NRC/NRR 301-415-1296 P. R. Wilson NRC/NRR 301-415-1114 l

Attachment 2  ;

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hr wwhCC b o a IW bbk h b b kt* 1 (h b

-- Indicaser(Umoveilsbehty) I RC5 Safety Sefety psefety Sysesdre %

Perforunnece Pleet Coelant RCS Coatoament U, 2 Syseems Syseess Treesween Chareescrianties Act6vity 8 Isokege ' tsskage 8 Screensu Act eiens Failures * > 29% * / # High Press RHR' Meehed of i k . 2.-AC

• N. Injeceise ' AFW ' (WWRs) Idemencesise Encellens (NEI) Summer G G N Data G(1) G(1) Gil) [ [ Cd2) e'G (0. ell)J N G(0 012) G[007) NA l p s /  % + f e Twtey Pt 3 G G G G(1) G(1) G(3)R [ G(7) 4 G (0.097),v i G(0.009) , h_ 0(0 018) NA Tekey Pt 4 O G G G(2) G(1) G(2h'  % W([ G (0.007) [G(0.915)/ O (0 013) NA SePerser(NPC) Callaway W(lQ) G No Data G (3) G(0) G(3)k (d(5) G(0 021) G 12) G (0.013) NA t Vogtle i No Data No Data No Das G(2) G(2) G(3)M -NGO) A G(0 006) G(0 004) G (0.002) NA Vogtle 2 No Data Nc Data No Data G(2) G(1) G ('2) d(3) [ O (0 006) G (0.003) G(0 006) NA Average Calvert C l G G W(lQ) G(3) G(3) M(3b G(6)\  ; W (90'27) G(0.013) G(0 012) NA (NEI) '

Calvert C 2 G G W(1O) W(4) G(3)d AG(2) ~ \ W(9) Vd/ (0027) G(0 008) W (0.024) NA

,i ,, m Average Davis-Besse No Data No Data No Data G(I) _ G(0) ,.Q(2) < . G (5)i,l, G (0.004) G (0.008) G (0.005) NA (NRC) , , .,

Pt Beach t No Dura No Deta No Data G(2) [j G(I) f hfW(12) M(N Y (0.051) G (0.003) G (0.013) NA Inspechem Pt Beach 2 No Data No Dura No Data G(I)[ f G(2) [ W(10) / G(3) Y(0 051) G (0.003) G (0.Oll) NA laspection TMII G G No Data G([)[ G(ib G(2)Y G(4) G (0.021) W(0 018) G (0 004) NA D C Cook i No Daa No Dasa No Data bG(2) Q'(1)) W(5h G(2) G (0.014) G(0 007) G (0.010) NA Inspechon D C Cook 2 No Data No Duna [ No Dat[ ' ~ W (4) , Gkh W (6) G(1) G (0.014) G (0.006) G (0.008) NA Inspecuom Nf -hG

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Declining St Lecie 1 G Nh W(5) ? W(4) G(3) W(14) G (0.016) W (0.027) G ( 0.010) NA laspecace (NEI)

St Lacie 2 G W(lQk G\ DC)" SO(l) G(l) W(22) G ( 0.016) G (0.0l0) G (0.019) NA Inspechen Ft Calhoun W(5Q) W(lQ)/ t W lQ)' - G h (3)\-- G(2) G(5) G(4) G ( 0.012) G (0.001) G (0.003) NA

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Dechaung Cooper No Data / No Data No Dart . G(1) G(I) W(II) G(2) G (0.0ll) G(0 029) NA G(0 014) Inspechos (SRC) , ,

licre Creek No Data .I , No Data No Data V#W(5) G(2) W (7) G(7) G (0.018) W (0 042) NA G (0 006) Inspecnon/PIs

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Perferoamee g ,,g,,,e g,,g,,,s $,,,,, sa 3 y,ig,,,, e > 20% 8 *[ High Pm RHR' W af Cha. ;.. _ _ ActMey a k AC*;/ lasweens' AfW ' (BWRs) MemeAcassee A

Watch tJet Dresden 2 W data G No dena G(1) G(2) W(9) / M(t) kO(0.019) G (0.015) y W(0017)

Dresden ) No dsta G N dmin W(4) G(2) W(9)/ G(7) y [GN9)i -['G(0.018) NA G (0.0ll) Lv;-

$ G(0.0[ ! (0.009)G NA la4;?ls Salem i G G Bad plot? W(5) G(3) W(Ih A W(N G(0.014h Mh3) G(0.014) G(0 005) NA L@.?ls Salem 2 O G BM ples? G(2) G(2) W(ll\ k NA L,  ;-

G(0.006)

Quad Cines 1 G W(lQ) W dera G(I) G(0) W(3) [W(13k W(0 026) W(0.071)

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Quad Cines 2 G G  % data W (5) G(1) W(1 Wild)i  % W (0026) G t0 037) NA G(0 001)

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G(@ I G(0.42) G (0.021) NA G (0.009)

LaSallet G G No data G(3) G(3) ,Wtak .

l U W(4) O NA G (0 008) law;-

N data W (4) G(3) / G(4) UO[0012) G (0.029)

LASalle 2 G G f w la,d-.?ls Waerhilst W(14):,, G (0.003) G (0.006) NA No data W data N data G(2) G(2) *31 W(9) 2 W (0.026)

(NRC) Iruhan Pt 3 NA InW-Crystal R 3  % dura No date & dans G(1) k(2) (9) G(3) G (0 009) G (0.012) G(0 007)

,n.m ihose r ons a ind.ca.e4 i Pe4o, mar.ce assessed esm. eshoids ,re,osed i, Nu whme .uor w entered whiife red .. ace,e surrd,m o, ~

2 Values reported is 0 are the maximum number of events occumns within a calender year over ihe period tegg so 1997; perf<minance assessed usmg a threshold cf 3 3

Values repersed in 0 are the maxnaam number er events occumns withm a calendarpeer edthe perwd '" 1 3 to 1997; perfasnance assessed eses a threshold of a d Performance assessed usmg thresholds of 0.025 and 0 050 [;

.s Performance assessed usmg a threshold of 0 015 for PWits and 0.04 for BWits

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6 Performance assessed usms a threshold of 0 02 7 Performance assessed vsms a threshold of 0.015 % ,.N.3a eyear over thel p1997; performance assessed usmg a threshuld of 5 8 Values reported in () are the mamanum number afeveers occurrms .

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DRAFT RISK INFORMATION MATRIX NUMBER 1 INSPECTABLE AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE INDICATOR UNIT SITE PER YEAR Access Authorization SEC Number of Annual Expert judgement basis. PI reduces the inspection effort, andcovers a!!

Program Reportable areas except Behavioral Observation Program process and Pl Access verification.

Authorization Events Failure of program compromises ability to protect against the insider threat of radiological sabotage. Risk consequence to radiological sabotage can be high if program fails.

Access Control SEC None Annual Expert judgement basis.

16 hrs per year to perform Access Control Testing 8 hrs per year to perform Problem identification and Resolution Failure of program compromises security barriers in place to protect high risk plant equipment and activities. Risk consequence to radiological sabotage is moderate.

Access Control to OE High Radiation Annual The hours are based on the current core program as modified by Radiologically Area (for >1000 inspection experience. The total hours include C hours of Problem Significant Areas mR/hr orily) Identification and Resolution to review licensee incidents involving the l

Events, Very loss of one or more barriers 'o an HRA, VHRA or airbome area; and 4 High Radiation hours of walkdown to observe radiologically significant work not Events, addressed by the Pi and to verify that HRAs <L 1000 mrem'hr are .

Significant controlled as required by the applicable TS. Totalinspection hours Exposure required were reduced becuase of the availability of a Pl.

Events Adverse Weather IE None As Use plant history, IPE, IPEEE to determine vulnerability and assign final Preparations MIT conditions hours. Baseline inspection to be performed prict to seasonal require susceptibilities. Freezing temperatures, high winds, flooding dominate.

Leads to common cause failure of mitigation equipment and to initiatiating events.

Select 1 non-failure tolerant SSCs, supplemented by 1 site-specific high risk SSCs. The non-failure tolerant SSCs (i.e., highly reliable RWST),

whose failures may contribute a small amount to the total CDF, but create a large CCDP, could result in failures of other SSCs due to instrument line freezing or other CCF failures .

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DRAFT, RISK INFORMATION MATRIX NUMBER 1 INSPECTABLE AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE IND!CATOR UNIT SITE PER YEAR ALARA Planning and OE None Annual Centrols The hours are based on the current core program as modified by inspection experience. The total hours include 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of Problem Identification and Resolution to review licensee assessments of the Al. ARA program and applicable events; 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to review the planning for selected radiologically significant jobs; and 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to observe those activities selected. It is expected that this inspection will be performed prior to (i.e., observe planning) and during (i.e., observe implementation) an outage. However, if no outage is scheduleil for that site for the year, then this effort should only require about 40 total hours (i.e.,20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> for job review and 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for walkdown).

Alert and Notification EP Alert and Biennial System Availabihty Expert judgement basis. After initial program verification (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />).

Notification Problem Identification and Resolution review, and review system and System program changes every 2 years. Totalinspection hours required were Availability reduced by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> / 2 years because of the availabihty of a Pl.

Total public exposure could be impacted by degradation in the ANS in the event of an accident.

Changes to License MIT None Annual Review licensee submittals made per 10CFR50.59 and 50.54 Condrtions and Safety Ana!ysis Report requirements. If the initial screening indicates that the issues potentially increase risk , select the issue for review.

SEC As required Security plan reviews Drill and Exercise EP Drill and Biennial Expert judgement basis. Pl in this area eliminates the need for Inspection Exercise additional inspectors to monitor the exercise (about 96 additional hours).

Critiques Hours include observation of Biennial exercise by EP Specialist (32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> every 2 years for observation, and 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> for Problem identification and Resolution); and Resident and Operator Licensing Quarterly inspectors periodic observation of Operator performance with respect to Emergency Plan during simulator observaSon (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> I year; one 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> observation per quarter )

Emergency Action EP None As required Level Changes Expert judgement basis. Assumes modest EAL program change every by program 2 yrs. Extensive plan changes may require higher level of effort.

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RISK INFORMATION MATRIX NUMBER 1 INSPECTABLE AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE INDICATOR UNIT SITE PER YEAR Emergency Plan EP DEP Biennial This inspection area is adequately covered by the Pls.

Training ERO Emergency Response EP None Biennial Expert judgement basis. Problem Identification and Resolution review Organization based on licensee self assessments.

Augmentation Emergent Work IE None Bimonthly Assumes i hrs / month of obssrvation and 1 hr / month of Problem Identification and Resolution.

High risk configurations with multiple out-of-service SSCs may occur during ro!!ing on-line maintenance due to emergent work. Selection of activities should be made using licensee's configuntion specific risk assessment or from a ranking of system importance. RIM 2 may be used if plant specific information has not yet been developed.

Equipment Alignment IE None Semiannual Hours based on 8 hrs semiannually for a complete risk important MIT and system walkdown; 4 hrs I month in walkdowns to support verification of ,

as required operable system train because other train is COS, and 1 hr / month for by Problem Identification and Resolution. RIM 2 may be used for system maintenance selection if plant specific information has not yet been developed.

High risk configurations may occur during normal operations and on-line maintenance activities due to multiple out-of-service SSCs, and such configurations can lead to high Core Damage Probability.

Event Followup ALL Unplanned Post Event Hours based on 1 SCRAM and 10 LERs per year.  !

Scrams Depending on the risk importance of each event, the depth and scope of inspection effort should be determined. Risk impact due to events may vary depending on the nature and progression of the events.

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i RISK INFORMATION MATRIX NUMBER 1 DRAFT, INSPECTABLE AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE INDICATOR UNIT SITE PER YEAR Fire Protection IE None Triennial Hours are based on a regional based Program implementation Review, MIT and Problem identification and Review. Estimated fire risk is comparable to many intemal initiating events. If potential fire initiators, aids to propagation, or fire barrier breaches exist, safe shutdown of the plant may not be possible due to the failures of the inspectable features and areas. Selection of areas inspected should consider insights from i the plant specific fire risk analysis.

Flood Protection IE None Annual Intemal and Extemal flood protection barriers and actions review.

Measures MIT At some sites floeding can be a significant contributor to risk. Select from both the extemal and intemal flooding areas, perform walkdown of areas, being sensitive to insights from the plant specific flood risk studies.

Fuel Barrier BAR Reactor Coolant Quarterly Total inspection hours required were reduced becuase of the availability Performance Activity review of PI of a Pl. Verification of PI may be required perioriscally. With review of PI, also check for reportable event involving exceeding core thermal limits or margins.

Fuel cladding is the first barrier.

Gaseous and Liquid PE Reportable Biennial Totalinspection hours required were reduced becuase of the availability Effluent Treatment Release Events of a Pl. The hours are based on the current core program as modified Systems by inspection experience. The total hours include 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of Problem identification and Resolution to review the licensee assessments, events and annual effluent and environmental reports; 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to walkdown the gaseous and liquid systems (including monitors) to observe the equipment material condition and ongoing activities; and 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to review effluent and metoriogical monitor calibrations, monitor alarm setpoints, maintenance records and system modifications.

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j RISK INFORMATION MATRIX NUMBER 1 INSPECTABLE AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE INDICATOR UNIT SITE PER YEAR Heat Exchanger MIT None Semiannual For risk important heat exchangers, observe periodic performance Performance testing. Two activities per yr for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> each; Two hrs of Problem identification and Resolution.

Heat exchangers are required to remove decay heat, and provide cooling water support for operating equipment. Degradation in -

perfomiance can result in failure to meet system success criteria, and lead to increased risk. Exchanger selection should be made focusing on high risk functions on exchangers that have low margin to their design point, or have potential for high fouling.

Identification and ALL Safety System Biennial Region based inspection every two years using 240 hrs. 390 hrs / yr Resolution of Performance from daily review by inspectors.

Problems / Issues Indicators Uncorrected root causes to problems could lead to increasing common Daily cause and human event rates, and to breakdowns in multiple Comerstone areas. Selection should not necessarify be based on individual system importance, but should look at the potential impact of the root cause o' the plant as a whole. Many of the issues will cross multiple Comerstones.

Inservice inspection BAR RCS Leak Rate Annual Totalinspection hours required were reduced becuase of the availability Activities of a Pl. Regional based specialist to perform. Activity may be performed on a refueling cyc!e basis to observe activities.

ASME Class 1,2, & 3 components are relatively high reliability components with relatively low failure probabilities. However, they are non-failure tolerant SSCs and their failures could result in a high Conditional Core Damage Probability and consequences.

Inservice Testing - IE None Bimonthly Hours assumes observation of 24 tests on high risk components with Section XI MIT associated Problem identification and Resolution time.

Inservice testing provides indication of equipment availability and  ;

reliability. Improper testing could result in undisclosed problems that last until the next required testing, unless discovered through failure while in service earlier, creating long periods of unknown equipment inoperability. RIM 2 may be med for component selection if plant

, specific information has not yet 1,Nn developed.

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RISK INFORMATION MATRIX NUMBER 1 l INSPECTABLE AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE INDICATOR UNIT SITE PER YEAR erge Containment BAR Containment Status- Totalinspection hours required were reduced becuase of the availability iso-ation Valve Leak Penetration monthly of a i s. Problem Identification and Resolution and configuration control Rate and Status Leakage on large containment valves that are frequently cycled.

Verification Leakage-refueling large containment valves that are cycled during plant operation increase the liklihood of failure of the containment barrier. Frequent operation and aging of seals in the valves can lead to excessive leakage rates.

Licensed Operator MIT None Annual Expert judgement basis. Assumes 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> onsite by a regional based Requalification BAR specialist, and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of simulator activities sampled once per quarter EP by the Resident inspectors. Does not include in office review of tests Quarterly performed by the regional specialists.

Human errors and failure to recover from accident events increase the significance of important events: Examples include failure to manually depressurize and failure to recover offsite power for BWRs and failure to switch from RWST to containment sump for PWRs. Select from the high risk operator actions from the site risk study.

Maintenance Rule MIT None Annual includes 16 hrs I month of resident inspector activities; a 40 hr annual implementation review by a region based specialist, and 2 hrs / month of Problem identification and Resolution. Inspection should focus on categorization of failures used in tracking condition of important systems, and goal setting and get well program for risk significant A1 Systems.

Weekly Tracking and documenting system availabi!ity and reliability for the plant's risk important systems is performed under the Maintenarh ? Rule.

These estimates impact the plant risk model, in addition to actual 7. ant risk.

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RISK INFORMATION MATRIX NUMBER 1 INSPECTABLE AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE INDICATOR UNIT SITE PER YEAR Maintenance Work MIT None Monthly Control of plant risk and configurations through appropriate planning Prioritization and BAR and control of maintenance activities minimizes the plant's aggregate Control risk.

Sample times when multiple component outages were planned simultaneously. Sample times when planning decisions were made for expediting equipment retum to service because of component failures, especia!!y on the backshift when normal planning was unavailable.

rim 2 may not provide adequate guidance in this area when multiple components are out of service at the same time.

Off-Normal Piant MIT None As Required Hours based on six occurrences per year of risk significant off normal Operations operation and 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of inspection per occurrence.

Human Errors, particularly recovery actions from event initiations, are the major contributors f plant risk. Performance during non-routine Operations can be used as an indicator of plant personnel performance during emergencies than their performance during normal operations. In addition, plant upset events are more iMiy during non-routine operations.

Operability Evaluations MIT None Monthly Hours based on 2 activities per month of 2 hrs each.

Unrealized inoperability of components can result in high risk configurations becuase the tools being used to evaluate risk in daily planning will have invalid compromised on equipment availability. RIM 2 may be used for selection if plant specific information has not yet been developed.

Operator Work- MIT None Monthly Based on 2 activities per month of 1 hr each.

Arounds Operator workarounds can impact human performance during event response, due to increasing complexity of tasks and more limiting time

' to perform required actions. Select those items which can impact l operator response during critical events.

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RISK INFORMATION MATRIX NUMBER 1 ORAFT INSPECTABLE AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE IND!CATOR UNIT SITE PER YEAR Permanen' Plant MiT None Annuatty Hours are based on 5 modifications at 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of review per Modifications BAR modification by a Regional specialist. Includes review of post modification testing. On site inspection by either the resident or regional based inspector for coi.T.guration and post mod test review of ongoing modifications will require an additional 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.

At time of occurrence, Plant modifications will impact plant risk, by either increasing or if high risk decreasing the baseline risk after the modification. The risk changes are and expected to be small, however the concem is an increase in risk and/or performed consequence during the modification, if performed on line, on line Review plant-specific configuration risk for pre- and post-modification, and potential unreviewed safety questions. Select those rnodifications with the greatest impact on risk. Regionalinspectors should use the SRA to input into the selection of modifications to be reviewed.

Resident inspectors can use the RIM 2 if plant specific information has not yet been developed.

Physical Protection SEC Availability and Quarterly Totalinspection hours required were reduced becuase of the availability Syste n (Barriers, capability of review of PI of a Pl. Regional desktop review of reports. 2 hrs / quarter per facility.

Intrusion Detection security System, and Alarm equipment Risk significance is based on an exploitable vulnerability by a person (s)

Assessment) with the intent and capability in commit radiological sabotage. The risk consequences of such an ev* it would be moderate to high.

Piping System IE None Refueling 16 hrs / refueling review / observation; 2 hrs / refueling Problem Erosion / Corrosion 4 Identification and Resolution.

High energy and high risk piping system are relatively low risk but their failures may result in significant events, or high Conditional Core Damage Probabilities.

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9 O e

RISK INFORMATION MATRIX NUMBER 1 I

.NSPECTABLE AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE INDICATOR UNIT SITE PER YEAR Radioactive Material PE None Annual The hours are based on the current core program as modified by Processing and inspection experience. These hours include 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of Problem Shipping identification and Resolution to review Ucensee assessments and events; 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to observe radiologically significant processing ano shipping activities (such as RWCU resin dewatering. Type A or B shipments), and radioactive material work and storage areas; and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> te review associated records including 10 CFR Part 61 sample collection and analysis results. Credit shall be taken for any of these activities observed / reviewed while performing another inspectable area.

Radiological PE None Biennial The hours are based on the current core program as modified by Environmental inspection experience. These hours include 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for Problem Monitoring Program Identification and Resolution to review licensee assessments and (REMP) identified problems; 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to walkdown the sampling stations and observe environmental sample collection and processing; and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to review counting room instrumentation and environmental sampfer

• calibration and maintenance records. No time is allotted for review of the annual environmental report or metoriogical instrumentation as this was included in the Gaseous and Liquid Treatment Systems inspection area.

Refueling and Outage MIT None Refueling Performed on outage basis, not annual. Includes review of mid-loop ops Related Activities BAR for PWRs. Licensee's outage risk assessment to guide inspectors to risk significant activities.

Shutdown risk will be high if vital SSCs are not available. Due to potentially high numbers of out-of-service SSCs during the refueling period, configuration risk can be high. Times of reduced inventory are the most critical.

Response to SEC None Biennial Expert judgement basis. Conduct and Evaluate Security Exercise.

Contingency Events Three inspectors. Includes onsite inspection of Physical Protection as (Protective Strategy part of exercise.

and Implementation of Protective Strategy) This is a high risk-significant system necessary to protect against the design basis threat of radiological sabotage. The risk consequence to radiological sabotage if a successful attack did occur is high.

k b- A

o 4 RISK INFORMATION MATRIX NUMBER 1 ,

bk j-INSPECTABt E AREA CORNER PERFORMANCE FREQUENCY HOURS FOR TWO BASIS STONE INDICATOR UNIT SITE PER YEAR Safety System Design MIT None Biennial Region based biennial risk important system design review. 240 hrs I and Performance activity. System selection with input from regional SRA.

Capability Functionality of high risk significant SSCs are verined, including design basis, support functions, installation, testing, normat/ emergency functions. Factors contnbuting to risk reduction / increase are verified through validation of the success enteria.

Technical Specification MIT Safety System Monthly Totalinspection hours required were reduced becuase of the availability Surveillance Testing Performance of a Pl. Risk important systems surveillance. Assumes 2 risk Indicators significant activities per month of 4 hrs each.

Provides indication of cystem operability. Plant configuration and system restoration are important.

Temporary Plant MIT None As Required Screen for temporary modifications with relatively high risk Modifications configurations. RIM 2 may be used if plant specific information has not yet been developed.

The modifications may result in a departure from the design basis and system success criteria, and can result in a configuration that may be an unreviewed safety concem. Temporary or unrecognized risk changes due to the m Alfication may evolve into high risk configurations b

DRAFT

~

RISK. INFORMATION MATRIX- NO. 2:

BWR Systems that Were Risk /mportant at Most Plants and Reasons for importance No1 '

orioritized!

Cornerstones important i Systems Reasons forimportance From IE Mit. Bar IPEs s Sys .

Systems selected based on CDF contribution from NUREG-1560 HPCI Used to provide injection and remove DH from the core on an SBO. X Availability and Redundancy of High Pressure injection Systems is important to Transients with Loss of injection Sequences On a transient with loss of DHR, two issues are: NPSH Problems with ECCS in the Suppression Pool; and the Capability of the ECCS to Pump Saturated Water. Mitigating system redundancy can be impacted by harsh environments in containment (before cont. failure).

On a transient with loss of DHR, resulting in containment failure, Mitigating system redundancy (for Systems Located Outside of Containment and Rx Bldg) can be impacted as a result of harsh environments in adjacent structures (after coni. failure).  ;

RCIC Used to provide injection and remove DH from the core on an SBO. X Availability and Redundancy of High Pressure injection Systems is important to Transients with Loss of injection Sequences On a transient with loss of DHR, two issues are NPSH Problems with ECCS in the Suppression Pool; and the Capability of the ECCS to Pump Saturated Water. Mitigating system redundancy can be impacted by harsh environments in containment (before cont. failure).

On a transient with loss of DHR, resulting in containment failure, Mitigating system redundancy (for Systems Located Outside of Containment and Rx Bldg) can be impacted as a result of harsh environments in adjacent structures (after cont. failure).

HVAC for Loss of HVAC on SBO may cause common mode failure of HPCI & X HPCI& RCIC.

RCIC Diesel- Used to provide injection and remove DH from the core on an SBO. X Driven Use of firewater requires significant planning and training, but is Firewater credited in several plants.

ORAFT w~~as

)

DRAFT l

l Cornerstones i important I Systems Reasons forimportance From IE Mit. Bar IPEs s Sys l

Isolation Used to remove DH from the core on an SBO. A larger IC capacity X l Condense provides more time before makeup to IC is required and allows more  !

r (IC) time for operators to recover AC power. The ability of the IC to remove )

DH is defeated if an RV sticks open.

DC DC power is required for operaticn of the AC independent systems X Batteries (e.g.,IC, HPCI, RCIC, and ADS or SRVs). Battery depletion times typically range from 2 to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. Load shedding is imartant to extend depletion time. This provides more time for recovery of AC power.

Failures of support equipment, such as DC power can fail the EDGs. l DC Buses Important transient IEs are LOOP, LOFW, and MSIV closure, and logi X of DC buses.

l Offsite AC AC system design and maintenance contribute to the overall reliability X X power of the system (including both offsite and onsite AC power). Features important include: # of offsite lines, cross-tie capability, availability and I reliability of equipment. Also important is the capabilrty to recover AC power once lost.

Important transient IEs are LOOP, LOFW, and MSIV closure, and loss of DC buses.

Onsite AC system design and maintenance contribute to the overall reliability X Emergene of the system (including both offsite and onsite AC power). Features yAC important include: # of EDGs, availability and reliability of equipment.

power Also important is the capability to recover AC power once lost.

Service Failures of support equipment, such as SW can fail the EDGs. X Water Failure of EDGs due to loss of SW is an important contributor to SBO.

SW design is very unit specific.

ADS /RVs The ability o' e IC to remove DH (e.g., on an SBO)is defeated if a RV X sticks open.

Failure to Depressurize is important on Transients with Loss of injection Sequences. Many plant procedures direct operators to inhibit ADS on transients. When high pressure injection fails, operators must manually depressurize with ADS.

On selected sequences such as SBO, depressurization is required after failure of high pressure injection systems to allow for injection with low pressure systems. A complicating factor is that some procedures initially direct the operator to inhibit ADS. In some PRAs this appears in cutsets up to 45 % of CDF.

Excessive SRV discharge to a hot suppression pool is found to lead to late containment failure.

DRAFT

l .

• DRAFT Cornerstones I

important Systems Reasons forimportance From IE Mit. Bar IPEs s Sys l

Important transient IEs are LOOP, LOFW, and MSIV closure, and loss X Feedwate of DC buses.

r Availability and Redundancy of High Pressure injection Systems is i

1 important to Transients with Loss of injection Sequences y

MSIVs important transient IEs are LOOP, LOFW, and MSIV closure. and loss X i of DC buses.

Common injection System and DHR system dependencies on Support Systems X support Defeats Redundancy. Support system (cooling water, Inst. Air, and AC systems or DC power) failures can impact multiple mitigating systems.

for injection AND DHR systems Decay An important class of sequences is Transients with Loss of DHR. In X X Heat these sequences, coolant injection succeeds but DHR fails and RVs Removal open, sending steam to SP. Many licensees made Mods to DHR systems and improvements to ensure continued system operation under harsh environment conditions.

Some PRAs had Limited Analysis to Support DHR Success Criteria; No Credit was taken in Some Plants for Alternate DHR Systems (e.g.,

Venting). Some plants had higher contribution from these transients due to not crediting all attemate DHR systems. Also, not all plants treated the results of harsh environments the same.

On a transient with loss of DHR, two issues are NPSH Problems with ECCS in the Suppression Pool; and the Capability of the ECCS to Pump Saturated Water. Mrtigating system redundancy can be impacted by harsh environments in containment (before cont. failure).

On a transient with loss of DHR, resulting in containment failure, Mitigating system redundancy (for Systems Located Outside of Containment and Rx Bldg) can be impacted as a result of harso environments in adjacent structures (after cont. failure).

Containm Failure of CHR systems is important to Transients with Loss of DHR X X ent Heat sequences.

Removal (CHP) Less Restrictive Drywell Spray initiation Criteria are important since systen.s/ high pressure loads at time of core debris melt- through of RV & FCI Drywell are important contributors to early cont. failure.

Spray DRAFT l

~

~

DRAFT Cornerstones important Systems Reasons forimportance i From IE Mit. Bar l l pes s Sys . j Containm Operator Training on Depressurization of Containment is important X X ent since high pressure loads at time of core debris melt- through of RV & 1 Venting FCI are important contributors to early cont. failure. l Venting is found to be an effective means of avoiding uncontrolled containment failure for Mark ! and til containments in core damage events.

Suppressi On a transient or LOCA sequence, with failure of the PCS and the X X j on Pool SRVs open, containment temperature and pressure increase and mus_t Cooling be controlled. This can be dme by containment or suppression pool cooling or containment venting. Actions are required to remove DH before adverse conditions are reached (e.g., hi SP temperature leading to loss of ECCS pumps).

I Alternative Ensuring the Drywell Floor is Flooded in Core Damage Event is X '

Water important to prevent late containtrent failure since High pressure and Sources temperature loads caused by CCI are an important failure mode.

for Flooding of Drywell j Floor Combusti Hydrogen burns are important in contributor to early containment X ble Gas failures Mark tilIPEs.

Control /lg niters in Combustible gas burns are important in Mark llis to prevent late Containm containment failure.

ent of Mark Ill BWRs Additional Systems -Important based on high RAW (note 3).

RPS/CRD High RAW. If system fails, risk increases substantially. X Ms 4160 V Failure of buses appears related to LOOP, but also creates mitigation X X switchgea problems r

NOTES

1. See report, Development of Risk-informed Baseline inspection program, for a more complete discussion of Table.

2. Contains all systems from NUREG-1560, listed as: important for most BWRs in Table 3.2; or related to those containment performance perspectives of Table 4.2 listed as having significant probability for most i BWRs.

DRAFT

i * ,

DRAFT '

3. Contains those systems generically determined to have high Risk Achievement Worth (RAW > 10), that were not contained in the first part of this Table, i

4. Table developed to provide generic BWR risk insights for use in the development of a generic l Risk-informed baseline inspection program.

l

5. A plant-specific adaptation of this list may'also eventually serve as one component of a more detailed process for the selection of items to inspect at the site, i

l l

L i

)

DRAFT

1 0

DRAFT l l l RISK INFORMATION MATRIX NO. 2:

PWR Systems that Were Risk /mportant at Most P/ ants and Reasons for importance - No.t nrioritized!

l Cornerstones important Systems Reasons forimportance From lE Mit. Bar IPEs s Sys .

Systems selected based on CDF contribution from NUREG-1560 Offsite LOSP is an important IE for SBO sequences X Power Emergen Loss of and recovery of Emergency AC is important in SBO X cy AC sequences RCP in the event of an SBO the failure of RCP seals constitutes a X X seals LOCA and leads to core damage. Also important initiator for and loss of all seal cooling scenarios. Maintaining or quickly related recovering cooling to the seals is important.

cooling water DC DC load shedding is important to extend battery depletion time. X Batteries This provides more time for recovery of AC power in an SBO sequence.

Low LPI systems are important in LOCA sequences due initial failure X Pressure and also failure of operators to properly to switch to the recirc injection mode.

(LPI)

PORVs important for feed & bleed mode on LOCA and transient X sequences.

SGs SG ADVs are important as attemative means to depressurize X X X RCS during small LOCA with loss of HPl.

During transients, the ability to depressurize the SGs and the use of the condensate system for heat removalis also important.

SGTR is an important containment bypass mode for most PWRs.

RWST important for LOCA mitigation X Cross- Cross-ties between systems and units is important to increase X l ties. redundancy.

DRAFT

l ,

L)t4AF (

i i

Cornerstones important Systems Reasons forimportance From IE Mit. Bar IPEs s Sys l CCW Dependency of plant systems o'n Component Cooling Water X X (CCW)is important Service Dapendency of plant systems on SW is important X X Water l AFW/EF important for decay heat removal on transient sequences. l W Source of water for AFW is also important.

Containm Containment isolation failures are important at many plants X X l ent (e.g., large dry and sub-atmospheric containments) i isolation 1 Failure of high/ low pressure interface valves is an important containment bypass mode and can also act as a LOCA IE.

I 1

HPl/HPR HPl/HPR system could be used as mitigating system for LOCAs and as a means of cooling through feed and bleed during transients Ability to CE plants without PORV therefore no capability for feed and X depressu bleed could take credit for this means of heat removal rize SGs and use condens ate for '

heat remcval Containm Loss of CHR leading to overpressurization is an important late X ent Heat containment failure mode.

Removal (CHR)

Feed and When steam generator heat removal is lost, feed ana bleed X Bleed capability is relied on as a means of heat removal. Operation of Capabilit HPI and PORV is considered therefore to be important.

y RPS Reactor protection system for preventing ATWS. X Ability to The normalinventory in the condensate storage tank is typically supply not sufficient for some scenarios of accidents and use of other long-term sources such as fire water may be required.

water for AFW/EF l W paAPT

DRAFT Cornerstones important Systems Reasons forimportance From IE Mit. Bar IPEs s Sys .

Interfacin Failure of the isolation valves between large differential X X g Valves pressure between primary and secondary could result in core damage and containment bypass HVAC Loss of HVAC system in some areas such as Switch gear room X X System could cause loss of AC power CCW/ES Loss of CCW and ESW have shown to be quite important in X X W several PWRs since it impacts several mitigating systems and could cause LOCA as a result of RCP sealleakage Containm They were found to cause early containment releases in some X ent PWRs with large dry and sub-atmospheric containments.

Isolation Containm in some PWRs failure of Containment Spray and heat removal X ent Spray could result in containment failure prior to core damage.

and Availability of containment spray system would also be required

_CHRS for recirculation phase of ECCS.

Additional Systems -Important based on high RAW (note 3)

RPS Reactor protection system for preventing ATWS (in sorne plants X identified by RAW and some by FV)

Primary The failure of primary pipes including vessel integrity is a low X X system probability event with a high consequence.

Integrity

1. See report. Development of Risk-Informed Baseline inspection program, for a more complete discussinn of Table.

2. Contains all systems from NUREG-1560, listed as: important for most PWRs in Table 3.9; or related to those containment performance perspectives of Table 4.9 listed as having significant probability for most BWRs.

3. Contains those systems generically determined to have high Risk Achievement Worth (RAW > 10), that were not contained in the first part of this Table.

4. Table developed to provide generic PWR risk insights for use in the development of a generic Risk-informed baseline inspection program.

5. A- plant-specific adaptation of this list may also eventually serve as one component of a more detailed process for the selection of items to inspect at the site.

DRAFT

DRAFT ACTION MATRIX PERFORMANCE

_ INCREASING SAFETY SIGNIFICANCE >

u) ,

All Assessment - Any individual White One Degraded . Repetitive Degraded Overall Red .

b Inputs (Pis and . Pls.or Inspection. Comerstone (2-3 : Comerstone, (Unacceptable)

] inspection Areas) Areas l Assessment inputs Multiple Degraded ,. Performancef ,

w Green White or 1 Comerstones, or, Assessment input i Multiple Yellow - ,

'i Yellow), i Assessment inputs ' -

Management Routine Resident SRl/BC Meet with DD/RA Meet with EDO Meet with Senior Commissior. meeting Meeting Inspector Licensee Licensee Licensee with Senior Licensee Interaction Management Management Management Licensee - . Licensee Licensee Corrective Licensee Self Licensee Performance A'etion - Corrective Action Action with NRC Assessment with NRC Improvement Plan y Oversight Oversight with NRC Oversight Z

O NRC. Risk-Informed RegionalInitiative inspection Focused on Team Inspection Inspection - Baseline Inspection Inspection Cause of Degradation Focused on Cause of

$ Program Overall Degradation w

[

Regulatory None -Document Response -Docket Response to -10 CFR 50.54(f) Order to Modify, Actions ; '

(Consider N+1 to Degrading Area in Degrading Condition Letter Suspend, or Revoke Exemption for 2 Inspection Report - CAL / Order Licensed Activities Consecutive -Remove Performance Cycles in This Mitigating Factorfrom Ranon) Enforcement Assessment; DD review / sign DD review / sign RA review / sign RA review / sign RA review / sign z

o Report . assessment report assessment report (w/ assessment report (w/ assessment report (w/ assessment report (w/

~~ '

Q -

(w/ inspection plan) inspection plan) inspection plan) inspection plan) inspection plan) o a 5

3 Public SRI or Branch SRI or Branch Chief RA Discuss EDO Discuss Commission Meeting Chief Meet with Meet with Licensee Performance with Performance with with Senior Licensee 8 Assessment :.

Licensee Licensee Senior Licensee Management to Discuss Meeting l Manaaement licensee Performance

< Reaional Review Only I Headquarters Review >

DRAFT -r c.

l l

?f$

i NEI Proposed l NRC Inspection Finding Evaluation. Matrix  ;

DRAFT 11/23/98 R2 i

Purpose:

1 The purpose of this matrix is to provide basis for determining the risk-informed l significance of NRC inspection findings and to provide criteria / thresholds for increased l regulatory attention or required regulatory action consistent with the performance I indicators for the same cornerstone related to the inspection module.

l l

Assumptions:

i l e Programmatic and human performance issues asociated with implementing NRC l requirements are identified and corrected in the licensee corrective action program required by 10CFR50 Appendix B. Timeliness of corrective actions are consistent with the safety significance of the identified non-conformance.

i e Prompt operability determinations are made following identification of non-conformances in accordance with NRC Generic Letter 91-18RI This requires that prompt evaluation / action in accordance with facility operating license (Technical Specifications) occurs. Technical Specifications require plant shutdowns when non-conformances affect multiple trains and components of required safety equipment.

. Inspections for licensee programs (ISI, IST, Operator Training, Emergency Planning,

, Security, Radwaste shipping, etc) have identified risk informed criteria related to the l ability of the cornerstone objective to be met. Findings need to be based on concrete examples that demonstrate the criteria are not met.

Definitions:

i e An Inspection Discrepancy is defined as NRC identified non-conformance with )

NRC requirements that have little or no safety significance that does not affect the '

l ability of the comerstone to be met. Licensees are allowed to capture discrepancy in l the licensee corrective action program and restore conformance in a time frame l consistent with safety significance.

l

• An Inspection Finding is defined as NRC or licensee identified non-conformance(s) that if uncorrected, would compromise the ability to meet the objective of the comerstone linked to the inspection module. Comerstone objectives can still be met

! pending completion of corrective actions with implementation of compensatory measures.

• A Risk Significant Finding is defined as NRC or licensee identified non-conformance(s) that if uncorrected significantly challenge the ability to meet the cornerstone objectives relative to public safety. Non-conformances exist in multiple attributes such that comerstone objectives can not be assured without completion of significant corrective actions

• Increased Regulatory Oversight describes the assessment region in which licensee

! performance in a specific comerstone as measured by PI's and Inspection Findings cM

. .. .- -- - - . - - - ~ . . - - . ~ . . - . - - . - - _ . - -

l l P *'

l- demonstrates cornerstone objectives are compromised. Licensees are required to evaluate the extent of condition. NRC monitoring / inspection to ensure effectiveness and timeliness oflicensee corrective actions.

. Required Regulatory Action describes the assessment region in which licensee l performance in a specific cornerstone as measured by PI's and Inspection Findings demonstrates that a cornerstone objective is not met. The NRC is required to perform an assessment of the extent of condition and acceptability of proposed corrective  ;

actions. The licensee is required to formally conunit to corrective actions necessary l to meet the cornerstone objective. The NRC utilizes Confirmatory Action Letters to i ensure licensee conformance. i I

Inspection Non-Conformance Evaluation Matrix '

Attribute Discrepancy Finding Risk Sig.

Finding l'

l No impact to ability of single SSCs to perform X Safety function related to the cornerstone

, impact to I train of SSCs ability to perform X

! safety function for period of time in excess of Technical Specifications AOTs impact to all trains of SSC such that ability to X meet a cornerstone objective is lost Single example inspection criteria not X met in a cornerstone area with cornerstone objective met based on redundant attributes and'or compensatory action Multiple examples of inspection criteria not X l met in a cornerstone area with cornerstone I objective assured due to multiple attributes and/or compensatory action Multiple examples ofinspection criteria not X met in a cornerstone area with cornerstone l objective not met l

L.

Table 5 Summary othnesholds'D Performance Green-White White-Yellow Yellow-Red Indicator threshold threshold threshold Number of 3 6 >25

) Unplanned Scrams per 7000 critical hours Number of Risk- 4 TBD TBD Significant Scrams per three year period SSPI BWR HPCI .04 .12 .5 unavailability (also used for RCIC)

SSPI BWR HPCS .015 (based on .04 .2 unavailability RHR/HPSI)

SSPI EDG .025 .05 .1 (2 EDGs) unavailability .2 (>2 EDGs)

SSPI BWR RHR .015 .05 TBD unavailability SSPI PWR AFW .02 .06 .12 .

unavailability SSPI PWR HPSI .015 TBD TBD gnavailability n r rx ave n i- g i . _ . . . ... . .

CONCEPTUAL MODEL - OVERALL LICENSEE PERFORMANCEIACTION 1

1

-GREEN- l

(Licensee Response Band) l

- Nominal Risk

/ Nominal Performance I

- WHITE -

(Increased Regulatory Response Band) l l - Outside bounds of nominal performance

- Within Technical Specification Limits

-- Changes in performance l consistent with aCDF<E-5 (6LERF<E-6).

l l

- YELLOW -

(Required Regulatory Response Band) l - Technical Specification limits reached or exceeded

- Changes in performance consistent with aCDF<E-4 (6LERF<E-6)

-RED-

(UNACCEPTABLE - Plants not normally permitted to operate within this band)

- Plant performance significantly outside design

! basis 4

- Loss of confidence in l i ability of plant to provide l assurance of public health l

and safety with continued

. operation I

- UNSAFE PERFORMANCE -

l arwauur 9  ;

l l

1

..v l

DRAFT Revised Regulatory Oversight Process

- Transition Plan -

D te Plan / Process- Training ' Implementation Communication Phase in whh Development Existing Processes Nov Process 98 Development Dec 12/28- 12/1l'-Identify 12/1 - Brief 98 Benchmark Change Champion Regional DRS Selected Plants. and Change ' Directors -

to New Process' Coalition (CCL) 12/17 - Brief :

12/18 -. 12/20-Transition Regional DRP.

Transition Task Task Force * (TTF) Directors Force Identified Named :

(Pilot 12/3 - Brief ACRS Implementation; Phase in; 12/14 (week of)-

Interface Issues) Meeting Conducted with CCL ~

12/24-Comm. (roles / expectations /

Paper to EDO buyin) 12/22 - Meet with NEI to Discuss Pilot Plan Jan 1/1- Commission 1/25 - TTF in place 1/11 (week of) -

99 Paper to OCM Commission 1/22 - 30 day public Briefing on Process 1/11 - Pilot comment period Recommendations Plants named begins 1/19 - Press 1/14 - FRN Release to Issued to begin Announce 30 Day Public Comment Comment Period Period 1/26 - BriefNRR Managers l

l l

12/01/98 bTTAT& w r* lC

DRAFT Revised Regulatory Oversight Process

- Transition Plan -

DateM Plan / Process Training i , ,

L Insplementation ? ':; Communication ; ,

iPhassin~withi ' '

@ Development

~

' r '

mE s !E xistingProcesses:

Feb 2/1 -IP 2/1 (week of)- PPRs Conducted 99 Development Meeting ofCCL Using Existing Begins PIMs 2/23 -Public 2/23 - Develop Comment Period Commission Ends Paper to Provide Results ofPublic Regional Meetings Comment (coincident with PPRs to describe new process)

y : x ,- .

. y w n; . > -

Mar: ,3/191: ,

3/3-5 F=ntearyl SMM Screening 4 99' Commission- <

Information Meeting  ;

~

Paper .

Conferencef - ,-

Forwarded to ,

- , ,,.i . .. ..

i ^

ths Commission:( 3/26 - DraftIP'and?

IMC 0610 & PIMi

~

3/26 -1 .

Guidance forPilotL - m:e r Development off 1 3., g - ', '

UseIssued for) ~

L 4

Draft Procedures  % -" ,  ? , Comment (made -

^ -

?

1 Completed ( ' '

s? , , 'available to thet ,

'i 7 . ,. .' m1m, mi...

"._~; 'publis):0..

..x <m m .. m . - ._ _ L m. . ...._.~,.-..,,.,e.;

m , ,

Apr 4/9 - PI Data 4/14 Joint 4/15 - Public 4/21 SMM 99 Format Utility /NRC/NEI Symposium Established meeting for Pilot (Describe New (draft) Plant Training Process)

(NRC/NEI) (Mgr/BC/PE/ SRI)

12/01/98 4

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1 ..

DRAFT Revised Regulatory Oversight Process

- Transition Plan -

Date JPlan/ Process];*1 'a'~ ,

iTraining; ,

. Implementation ', ; Communication 1 i 1.Phaseinwith:,

" Development 1

~

Existing Processes:

- o >

May 5/14 - PI 5/12 - Joint BriefCommission 99 Reporting NRC/NEI Meeting on SMM results Format Finalized to Resolve Issues (NRC/NEI) Prior to Pilot 5/21 -

IProcedures Finalized for Pilot Use 5/17-Issue Letter to Pilot Plants to Initiate Pilot i

Process e.. .

.. _ o .

n ., , > ,

Judi: 6/1 -Issuej -

6/15 - Provide . 6/1.- Begin Pilot L 6/15 -LIssue Press? -

99l Revised ( - Training to the? Process (RIBLI, PI( Rilease on? , M. 4 > ,

Enforcement - Regions on[ collection)(previous: Enforcement Guidance Enforcement two years; monthly; Revisionst x,

sl data); .w_a m

-,1 _. , , - ..m. m , , ~ , so ,

Jul 7/30 - Check-in ' 7 /15 - First PI 7/15-30 Conduct 99 with Pilot Data Submitted Regional Meetings Utilities and with States on Regional irs Issued details of new Implementors process (NRC/NEI)

, 23 , m ., . . - m ,,,s . m Aug gp , > [m v 8/15 - PI Data ? #* ~

,y 991  ; ?.

e Submit,ted - u,

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. .Q r ,...:  :/ ,:. . ' n r  ;,n ;.;

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g/27 -IMel2e e . . . .

T

%, m Review donducted s > 4 12/01/98

L

.s l DMW I Revised Regulatory Oversight Process

! - Transition Plan -

DatesPlan/Processi ' ; Trainingi  ; '

f  ; .l Implementation.: Communication:i t !Phaseinwith :

,. ' 3 Development? M ' '

~ l' ! ' '

'^

4 M < WExisting Processesl Sep 9/10 - Review of 9/15 - PI Data BriefCommission 99 Pilot (NRC/NEI) Submitted Tas on Progress

- consistency i

- data quality irs Issued l -insp. results

- enforcement 9/24 - Develop Revisions to IProcedures based on Pilot Lessons

.; ,_y_ ,,,,

__3. 7-

= - -

77_ .

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g-

, Oct :10/4 -IPs and ' 10/11-25 '- Conduct' 10/1- PI Datal ;10/11-25iConducti PPRs' Conducted r 99: ' Reporting - [. training'of alli Submittedi >

Industry Workshop: UsingExisting '

Format Finalized ;

Reactor Pr6 gram _ . _

(NRC/NEI); Inspection: '

Staffon New(. irs issued:

' 'N

~f Program / Process Pr6 cess (coincident

_c, .1 ._ with PPRs)}

,g _

yym g . , y f ,y ,

Nov 11/15 - PI Data 99 Submitted irs issued 11/30 Level 3 Review Conducted (Using 12 month PI Data,6 Month Inspection Results) l

! 12/01/98 f-

l DRAFT

, Revised Regulatory Oversight Process

- Transition Plan -

Date Plan / Process Training : ' Implementation ~ Communication.  ; Phase in with' Deselopment - Existing Processes-Dec 12/15 -Final BriefCommission 99 Review of Pilot TAs (NRC/NEI)

- consistency

- data quality

-insp. results

- enforcement 7J Jan' 1/1 -IMC [ 'i-1/l'- Risk Informed '

1/1SALP l 1/154Pressf l 00 Changes Baseline Inspection : ReleaseIssued1 Discontinued . 1 i Implementing .. ,

Programi .

-Announcing Full' .

I RIBLI Become : Implemented for'alli Process I

Effective Plants Implementation and SALP Deletion 1/1 - MD on ' N. 1/1 - PIData?

SALP Deleted 1 Reporting Begins 1, for AllPlants

! Feb PPR Conducted 00 Mar r CobductI el2~

00' ,

Reviewi

, , 4 e 1 l Apr Conduct Last 00 SMM May 00L 12/01/98

_. _ . _ _ _ . _ _ _ _ _ _ . _ _l i i

\

DRAFT Revised Regulatory Oversight Process Transition Plan -

Date c; Plan / Process  :

[Trainingi 1 '

ilmplementationi ,

'(Communication: y . Phasein'with1 ,

whopment t - *

'R ,

< F stig Processes

..i Jun 6/15 -Issue . Conduct Level 2 00 MDs on new Resiew I

process 6/30 - Review Process Implementation (NRC/NEI) 1 rg wmg - n . nm ; ,,i. p+ 2 4 g ,, , ,- , 7 mim ~ , , - m, , a ., w r,m, l Jul" i >

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Aug i 00 i

, ~ ,, , .= .. - . . , - - , ,, , - .

Sepi

( ,

'CAnduct' Level'3 L ', '

j l 00.: . .1, Review'(Mid.c, ycle)m. ,._s....... ,

m ..- m. .u ,

.m.._ _. _ ..

- m _ .. .m . ~ . m.. ... . .- _

j Oct l 00

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m. .=

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, 1 m .s:m ,. 1 . , _ ~ . .. , aa., m , :A , .,= as Dec Conduct Level 2 00 Review

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Feb 01 12/01/98

. - - _. - - - ~ _ . ,

I r

L ..

DRAFT Revised Regulatory Oversight Process

- Transition Plan -

Date? Plan /Proce'ss/ , .nTraining .-

Vtl l; Implementation] >  ;

Communication ( . Phasein Withi

" Developmed" - , .

^ ' '

S 'T L Existing Processes' l Mar L 01 l

I

.3 1

.! 11 vs 13-' '%+ -r t W >nr -m tt p-It I 3, 1:t j  % _- t9qsr - ., .g jg ,g u t{t+* p ' .

Ce' 7 -t. g; -1 t' <.; g- t

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• t. 3 t F: 4j 't 'W

, . s . i . i i re . ....a

! Apr ' Conduct Level 36 fe' l 01 T , ,

Review (End of y,

=

.7 4 -

Cycle)l:[ ~

l Conduct evel49 ,

aeo

+ " ' '

i .

Review (Edd of[ ,

.a em w

Cyclip f , ,

y _ ,

May Commission 01 Briefed on Assessment Results Press Release Issued

.m. ,. . g ,, c , . g =. . - --

Juni 6/25 - Conducta "

L 6/7-End of Cycle ' i 01- Process Rsviewi Letters senti  : , - 1 Idsntify Lessonsi '

,. . . . .yj -,- ,- , _

l

.g Learned. ' 6/30 -Implementi

7 DevelopL ' ' '

Le'ssons Learned *

';' i 4 '-

A+- Appr'opriatei , From Ae=*mant 3.. j t M ygg . .,

• TRANSITION TASK FORCE TASKS I

4

! 12/01/98 i

. _ . _ _ , . ~ . . _ _ - _ _. -

DRAFT Revised Regulatory Oversight Process

- Transition Plan -

Process Development / Implementation O Review and incorporate public comments, revise processes as appropriate (Moderate)

D Develop individual RIBL inspection procedures for pilot use. (10-15 IPs) (Substantial)

O Finalize guidelines for establishing significance ofinspection findings (Moderate)

D Develop modifications to IMC 2515 - revised program guidance (Moderate)

O Develop modifications to IMC 0610 - report writing (Moderate )

D Develop replacement to the PPR IMC, including PIM guidance and inspection planning (Moderate)

D Develop a new assessment process Management Directive (Substantial)

O Identify computer infrastructure needs (Moderate)

O Establish data (PI) format needs and definitions (Slight) i O Benchmark process against prior plants (Clinton, Millstone, etc.)

O Oversee pilot implementation (Moderate)

O Identify necessary changes to draft documents above (Moderate) 12/01/98

DRAFT j Revised Regulatory Oversight Process

- Transition Plan -

TASK FORCE TASKS (Continued) l l

Training / Communication l O Conduct training for all inspectors (Moderate)

O Conduct pilot utility workshop (Small) l O Conduct public symposium (Small)

O Conduct regional meeting with stakeholders (Modera.<>

l

0. Conduct industry pre-implementation workshop (Moderate)

I i

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12/01/98 l

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