ML20202D972
| ML20202D972 | |
| Person / Time | |
|---|---|
| Issue date: | 01/26/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3064, NUDOCS 9902020199 | |
| Download: ML20202D972 (200) | |
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l DISCLAIMER j UNITED STATES NUCLEAR REGULATORY COMMISSION'S
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i l ADVISORY COMMITTEE ON REACTOR SAFEGUARDS JANUARY 26, 1999 I The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory
,3 .( / Committee on Reactor Safeguards, taken on January 26, 1999, i
as reported herein, is a record of the discussions recorded ' at the meeting held on the above date. This transcript had not been reviewed, corrected and edited and it may contain inaccuracies. D)e x 1
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1
.1 UNITED STATES OF AMERICA i ';
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2' So, NUCLEAR REGULATORY COMMISSION
~3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
]
- 4. *** I 5 MEETING: PLANT OPERATIONS AND RELIABILITY AND i
6: PROBABILISTIC RISK ASSESSMENT I 7 8 *** 9 U.S. Nuclear Regulatory Commission-10 11545 Rockville Pike 11 , Room T-2B3 12' Rockville, Maryland ?-
' 13 Tuesday, January 26, 1999 l
14' The subcommittee met, pursuant to notice, at 8:30
- 15 a.m. I 16 MEMBERS PRESENT:
17 GEORGE APOSTOLAKIS, Chairman, ACRS 18- JOHN BARTON, Member, ACRS 19 MARIO FONTANA, Member, ACRS j i 20 THOMAS KRESS, Member, ACRS 21 DON MILLER, Member, ACRS
.22' DANA POWERS, Member, ACRS 23 ROBERT SEALE, Member, ACRS {
- 24. WILLIAM SHACK, Member, ACRS 25 GRAHAM WALLIS, Member, ACRS l 1
I
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ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. ~ . _ _ _. _ _ _ _. ._ ..
2 1 P R O C E E D I N C- S [^i (_ / 2 (8:30 a.m.] 3 DR. BARTON: The meeting will now come to order. 1 4 This is a joint meeting of the ACRS Subcommittee on Plant I 5 Operations and Reliability and Probabilistic Risk 6 Assessment. I am John Barton, chairman of the Subcommittee 7 on Plant Operations. Dr. George Apostolakis is chairman of 8 the Subcommittee on Reliability and PRA. i 9 ACRS Members in attendance are Mario Fontana, ! 10 Thomas Kress, Don Miller, Dana Powers, Robert Seale, William ) 11 Shack, Robert Urich, and Graham Wallis. 12 Also in attendance is Mario Bonaca, who has been 13 selected as a new Member. He is expected to be appointed to s 14 the ACRS in the near future. A/ 15 The purpose of this meeting is to continue the 16 subcommittee reviews of proposed improvements to the NRC 17 inspection and assessment programs, including initiatives 18 related to development of a risk-based inspection program 19 and performance indicators. Subcommittees will gather 20 information, analyze relevant issues and facts, and 21 formulate proposed positions and actions as appropriate for 22 deliberations by the full Committee. 23 Michael T. Markley is the cognizant ACRS staff 24 engineer for'this meeting. 25 The rules for participation in today's meeting (~ ('~')J - ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C, 20036 (202) 842-0034
3
- 7. 1 have been announced as part of the notice of this meeting i
\ 2 previously published in the Federal Register on December 21, ) 3 1998. A transcript of the meeting-is being kept and will be 4 made available as stated in the Federal Register notice. 5 It is requested that speakers first identify 6 themselves and speak with sufficient clarity and volume so 1 7 that they can be readily heard. l 8 We have received no written comments or requests l 9 for time to make oral statements from members of the public. 10 I note that we've got Bruce Mallett on video from 11 Atlanta. Bruce, can you hear us? 12 MR. MALLETT: I can hear you fine. Can you hear 13 me? l fg 14 DR. BARTON: Yes, we can. And I also understand V 15 that you have another commitment, and we lose you at what 16 time? 17 MR. MALLETT: I have to be out of here by ten 18 o' clock. 19 DR. BARTON: All right. So at this point we'll 20 proceed with the meeting, call upon Frcnk Gillespie, Mark 21 Cunningham -- Mark's not here -- who's got the lead here 22 this morning? 23 MR. JOHNSON: Frank.
'24 MR. GILLESPIE: I do.
25 DR. BARTON: All right. Do you intend, since ( \
\~ 1 ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. S e6 4
1 we' re going to lose Bruce, we're going to kind of get his /'~'% (_,) 2 inspection stuff tied in early? 3 MR. GILLESPIE: Yes. 4 DR..BARTON: Since we did meet in December, and 5 sent a letter up, the things that we were interested in that 6 you were still working on at that point I believe was the 7 work on the assessment process. So if we can spend some 8 time on that today, the transition plan, and hopefully can 9 answer some questions on the package that you're asking the 10 Commission to proceed with has got some, you know, future 11 work needed, some holes in it, how you plan to address those 12 issues. We'd be interested in that also. 13 So at this point; Frank, you've got the show.
-s 14 MR. GILLESPIE: In order to get Bruce on pretty
's l 15 quickly, and we're not going to repeat everything we said 16 the last time, we've got that fat package out, and it pretty 17 much lays out all the details. So rather than go through 18 all the viewgraphs we have here, which are kind of a subset 19 of the Commission viewgraphs we use, there is one on the 20 concepts. We're going to I think just get right into it. 21 Our one big hole we identified with the Commission 22 just to highlight it, the Commission said that they're 23 interested in, is a risk-informed screening measure for 24 dealing with inspection results that aren't really conducive 25 to quantification. And we're still working that, and Alan r"N ('~') ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
5 1 Madison's going to be here a little bit later to go over the IO 2 details of that. 3 DR. BARTON: All right. 4 MR. GILLESPIE: And that was probably the one 5 biggest policy hole that we had I think when we addressed 6 this with the Commission that they were looking forward to 7 seeing in March. And probably one'of the more -- I don't 8 want to say intellectually, academically challenging things J 9 to do is to come up with something that the inspector in the 10 field, who's basically only had a two-week risk course, can 11 apply and will get a meaningful screening process out of. 12 So Alan will come. We've made some progress on that. And 13 he'll be explaining that a little later. 14 So with that, rather than go through all of these, 15 the schedule is there, our transition plan is there, we'll 16 hit that at the end. We're on kind of a tight schedule in 17 that we're going to try to have eight pilot plants started 18 in June. 19 DR. BARTON: These are six-month pilots? 20 MR. GILLESPIE: Yes, we're going for six-month 21 pilots. We feel we need at least a half a year to just 22 exercise the system and work the bugs out of it, that just 23 doing a three-month pilot isn't going to give us a chance 24 .really to observe it. 25 DR. POWERS: I guess the question that came to my 1 ANN'RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
7 1 mind was the opposite. Why isn't it a full cycle, a
'ts_
2 full-year pilot? i 3 MR. GILLESPIE: There's a certain amount of 4 impatience on people's parts -- 5 DR. POWERS: I understand that. 6 MR. GILLESPIE: To get on with it. 7 DR. POWERS: But it seems to me you don't get 8 through the whole shooting match in one consistent pilot by 9 going with six months. You're guessing a lot. 10 MR. GILLESPIE: Probably the -- it's not guessing. 11 Six months actually gets us through the basic inspection 12 cycles, gets us through a planning cycle, and because the 13 reporting is going to be on a quarterly basis with a g 14 one-year running average, once you've reported one or two
\'-) 15 quarters' worth of material, you've basically exercised it 1
16 twice. The first time you've made a lot of mistakes, the l 17- second time hopefully you've made fewer, and now you can 18 kind of clean it up. So we would have exercised reporting l 19 through two cycles. We would have exercised inspection 20 planning. 21 What we are likely going to be missing will be l l 22 those things that might only be done once a year or once 23 every two years, like the engineering inspections, but the 24 engineering inspection is, quite honestly, because there's 25 no PIs in engineering, is fundamentally what we're doing l
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7 gs 1 today, because we're picking high-risk systems. So what \
)
2 we're not testing in the six-month period is actually the I l 3 things that might be very similar to what we're already l 4 doing, l 5 With that, I'm going to turn it over to Bruce I 6 right away, because he's got an interesting section and one i 7 that's got a lot of implementation questions still left on j 8 how we're going to actually organize it to get it done. So 9 Bruce -- 10 MR. MALLETT: Thank you, Frank. Mike, were you i 11 able to receive the two slides that I sent? 12 MR. BARANOWSKY: No, I did not yet. I'll get 13 someone to run for them. (N 14 MR. MALLETT: Mike Johnson. \ '~ 15 MR. JOHNSON: Yes, Bruce. 16 DR. BARTON: George, do you have a question at 17 this point? 18 DR. APOSTOLAKIS: Yes. 19 DR. BARTON: Bruce, can you hold a second? We've 20 got a question here at the table. 21 MR. MALLETT: All right. 22 DR. APOSTOLAKIS: Well, I want to ask, as I was 23- reading this report, the question of the objectives of the 24 whole exercise came to mind, and I'm wondering when it would 25 be a good time to raise that question. Shall we let Bruce
/-m Q)
( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
m,; I 8 l 1 1 go on first, or.--
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2 MR. GILLESPIE: No, I think that's probably a good j 3 . time, because there's a good lead-in to one of the 4- criticisms we got of the inspection section was it did not 5 ' -- and, Bruce, chime in if I get this wrong, but it did not
- 6. -clearly state the objectives we were trying to meet when you I 7 read the inspection section by itself. So, no, this is a 8 good time to ask --
9 DR. APOSTOLAKIS: Okay. Let me tell you then what 10 the concern is. On page 2 of the document it says this 11 paper presents recommendations for improving the NRC's 12 reactor oversight processes including inspection, 13 assessment, and enforcement, and includes a transition plan.
'l 14 Now it doesn't really say what the objective of '
~- 15 Lthe oversight proc ~ess is,'but then on page 3 it says, the 1
16 first full paragraph, the objective of the inspection task 17 group was to develop recommendations for a baseline 1 18 inspection program blah blah blah blah blah to determine l 19: whether plant performance is at an acceptable level. 20 Now I am not sure that this is what the objective 21 of an oversight process should be. I see this as equivalent 22 to what people call quality control-in manufacturing. You 23- .have a process which is acceptable. I mean, the plants have 24 already been licensed, right. They're operating. 25: MR. GILLESPIE: Right, ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
9 fg 1 DR. APOSTOLAKIS: It seems to me that the purpose (\ ') 2 of the oversight exercise it to make sure that what you have 3 licensed, what you think you have licensed is indeed the 4' truth. 5 So, now, then we go to Attachment H. If that 6 premise is correct, then if I look at the figures H1 through 7 6, which are pages H-18 on, these are the actual data that I 8 believe NEI supplied you or some of it is -- yes, okay. So, 9 for example, figure H1 on page H-18 is the number of 10 unplanned scrams per year for a number of units. It's not 11 all the units, right? For a number of units. And the same 12 thing, the next one is the BWR high-pressure injection 13 system unavailability and so on. This is real life. 14 In the text it says that the way to define one of f"] 15 the goals, I think it's the -- I don't remember the colors 16 now, green to -- ] 17 MR. GILLESPIE: Green to white. 18 DR. APOSTOLAKIS: Green to white. Is to consider 19 that number of unplanned scrams that about 95 percent of the l 20 plants meet or have a smaller number of scrams. And then we 21 make that part of the assessment process and say this is a i 22 threshold. l 23 It seems to me that this runs counter to the 24 notion that the purpose of the oversight process is to make ! 25 sure that what the plants have been doing, what we think
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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 l l
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i l 1 10 1 they have been doing, is indeed correct. In other words, i /'N
's_/ 2 you are forcing now this way the five percent of the plants i l
3 that are above to actually come below the threshold. In 1 l I ! 4 other words, you are regulating them instead of just I 5 overseeing them. Isn't there a difference? 6 You are telling the -- in fact, if you go to one 7 of the -- yes, for example, figure H4, BWR RHR system 8 unavailability, the threshold is set at .015, and there are l 9 1, 2, 3, 4, 5, 6, 7, 8 plants that in fact have an RHR 10 unavailability greater than .015. So aren't you sending l 11 them a message that they better make sure that their RHR
'12 unavailability comes below .015, which may be a good 1
13 message, but it's not the job of the assessment process to
,._. 14 do that. \ s' 15 In other words, the way I would do it, I would say 16 okay, Mr. Plant 70, you have an RHR system unavailability 17 .025, it's the highect, this is what you have in your IPE, 18 and your whole IPE was accepted by the staff or it was 19 reviewed by the staff, and you have a license. So all I 20 have to do now from now on is make sure that you don't 21 become worse than .025, not that you reduce it down to .015.
22 That's a separate regulation. The oversight process' job is 23 to make sure that what we have licensed and the assumptions 24 and all that is still the way we thought it was. It's 25 quality control, in other words, not regulation. l l /~N tj ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
11 _ j- 1 Which brings up now another. If that is the case, i
\ 2 that's the second point now, the first point is we are in 3 fact intervening with this process, it's not oversight' 4 anymore. The second part I think is also a conceptual 5 difficulty. Let's say you agree with me. I don't expect
- 6. you to agree with me right away, but let's say you agree 7 with me.
8 DR. SEALE: You're going to give him a little 9 time. 10 DR. APOSTOLAKIS: So you say okay, fine, so even I 11 for this plant where the RHR unavailability is kind of high, 12 they probably have other things that are much better on the 13 average, so the total core damage frequency came out to be t'N 14 some reasonable number. So now we make sure that the (- 15 oversight process will monitor the plan to make sure that I 16 the IPE -- the IPE's assumptions and the numbers and so on 17 remain the way they were submitted. 18 But the plant has not been licensed on the basis 19 of the IPE. Right? lt's the whole -- 20 MR. GILLESPIE: Right. 21 DR. APOSTOLAKIS: Deterministic. So can we really 22 do that? Can we regulate, can we have an oversight process 23 that is based on a study that is not part of the licensing 24 basis? Is that allowed? 25 Which then creates the question, should we again (3 m/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
____.c.c. _. _ , _ _ . _ . _.._..g, l 12
, 1 ago back to Part 50 and make sure we change things there . s /. 2 before we develop this?
3 MR. GILLESPIE: Two things, George. 4 DR. APOSTOLAKIS: Yes. 5 MR. GILLESPIE: Yes, we're out of sync, because 6 inspection is ahead of Part 50 -- risk-informing Part 50. 7 DR. APOSTOLAKIS: That's correct; yes. 8 MR. GILLESPIE: So that's true. The other piece 9 is we don't have the sophistication to do this plant by 10 plant by plant right away. 11 The-third piece is what's probably missing in 12 clarity, and we -- I tried to make this clear at the 13 Commission briefing -- is that this piece and the way these
~g 14 are used and the.way they're used in inspection isn't 15 intended to be a backwards ratchet. I 16 The baseline program is an indica,. ion program. -l l
17 Even the. inspection program is an indication program. It is 18 not diagnostic. It is not intended to force someone to be 19 better than.they can be. l 20 DR. APOSTOLAKIS: Aren't we de facto doing this 21 though? 22 MR. GILLESPIE: Could that happen? 23 DR. APOSTOLAKIS: Yes. [ l 24 MR. GILLESPIE: Yes, and if you set up a standard 25 and say, you know, pass this standard it means be go into ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014. Washington, D.C. 20036 (202) 842-0034 i
13
,J" 1 more of a diagnostic mode to understand why and that is the
(_) 2 real point here. That is the objective of the thresholds is l 3 if someone breaks the threshold it is to engage them to 4 ensure that we as regulators understand why you might say in l 5- this case that they are different from the expected norm. 6 DR. APOSTOLAKIS: So it becomes plant-specific at 7 that level. 8 MR. GILLESPIE: And at that point you become l 9 plant-specific and engaged doesn't mean send out a 20-man 10 team. It means first you'd probably end up asking a 11 question -- why? If there is an explanation, we understand 12 it -- then there's an explanation. We understand it, and ' 13 that is when it becomes plant-specific. fs 14 DR. APOSTOLAKIS: I understand that but again , e s i
\' 15 there is a fundamental concern here that -- and there is a 16 third point -- but first of all, I don't think it's such a 17 nonumental job to do it on a plant-specific basis, because 18 we don't have to do it. We can ask the utilities to do it.
19 We can give them guidelines how to do it but we don't have l 20 to do it on a plant by plant basis. 21 For example, if I go to Figure H-2, look at Plant 22 Number 62 on page H-19. It is a BWR. High pressure 23 injection system unavailability is the lowest of all the 24 plants that are listed here. It's less than .01 and you 25 have already set the threshold at .04, right? It's really
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14 1 low. Now that plant probably wants to get some credit for
) \
(,,) 2 it. Maybe somewhere else -- they are not named, right? -- 3 somewhere else they have an unavailability for something 4 else that is higher than the threshold, so they may come 5 back or they should come back and say, look, on balance our 6 risk is acceptable and so on and so on, but if we look at 7 each one of these individually, which is the third point I 8 wanted to make and I forgot, we are regulating -- I mean the 9 idea of the cornerstones was not really to continue to be as 10 intrusive as we have been. 11 We don't want to regulate initiating events and 12 the pressure boundary and inspect the same way we were doing 13 it before and I think that is the path that this is going .i,,,s r 14 down, because now we have thresholds for initiating events, l 15 thresholds for una'vailabilities of various systems, and so 16 on, so it will be as intrusive as the regulatory system and 17 inspection process, as it was. 18 How can we give them more flexibility, which is 19 the whole idea of performance-based regulation? Remember, 20 these plants have already been licensed. Even if the core 21 damage frequency is greater than the goal, there's nothing 22 we can do about it, unless it is 'way up there, which is it 23 not. Right? Because that was not part of the licensing 24 basis. 25 So can we relax a little bit this and instead of C ()h ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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- 1. looking'at the systems and the initiating event frequencies 2 -and so on propose a methodology perhaps that the utilities 3 can implement for them to come up with individual -- not 4 goals. Thresholds? I don't know -- using some sort of
- 5 systematic approach.
l' 6 MR. GILLESPIE2 What we have generated here is 7- kind of a. generic profile of certain operating parameters -- 8 DR.-APOSTOLAKIS: Yes. 9 but. GILLESPIE: And could you cenerate a j L I i 10- . plant-specific profile for each site, given site differences l 11 and engineering. differences? In the future the answer is l-j 12 probably yes, you could. 13 We started from the general and now we are going
. -. 14 .to the. specific.
b '15 -DR.'APOSTOLAKIS: I understand.
.16 MR. GILLESPIE: And right now we are at the 17- generic. I don't disagree as.a future goal it would be very 18 nice to have a plant-specific profile but we don't have L 19 it --
l' l 20 DR.,APOSTOLAKIS: But aren't we over-stepping the 21 bounds though of the oversight process -- telling those 5 22 percent of the plants that they better shape up. l < l23 MR. GILLESPIE: We are not saying that. L l 24 DR. BARTON: George, I don't think that is what U . -
- 25. they are trying.to do here. I think they are looking for ANN-RILEY & ASSOCIATES, LTD.
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16 l 1 trends. They are looking for plants that all of a sudden [ (~} (_) l l i 2 are above a norm -- and the industry is using one of the 3 performance indicators which looks an awful lot like_this l 4 kind of stuff so the industry is already familiar with this. l 5 I think what they are looking for is a plant that 6 is below this .04 and all of a sudden it shoots up to, you l l 7 know, .07, and you say, well, why? 8 DR. APOSTOLAKIS: If I owned a plant that already 9 has at BWR HP injection system unavailability of .07 -- 10 Plant 75 -- and the NRC as part of its oversight process 11 says the threshold is .04, what do I do? 12 MR. GILLESPIE: Could this system be abused to 13 that point? I guess the answer would have to be yes, but l g- 14 that is clearly not the intention. The intention is it's an 1 15 indication system. At that point as the regulator we would 16 want to understand why they are different and what offsets 17 it. It is not clear. 18 Now maybe if we had a detailed, plant-specific 19 profile that was completely justified, it would be clear, 20 but we don't have it and right now the industry hasn't 21 really proposed to do a plant-specific kind of profile. 22 MR. MALLETT: But Frank, let's be careful here. 23 Let's make sure we understand the process here is that we 24 have a band of operation for plants and those plants in that 25 band of operation might be, as George said, from .04 to .07 i 4 () (~% ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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l l l 17 unavailability of'that system and therefore when you look at 1 O 4
\m/ '2' them you may need nothing more than a baseline inspection 3 program if-they are in that band of performance.
4 It is only supposed to be an indicator of whether 5- owe would increase our inspection above a minimum level, so 6' the concept is every plant will get a baseline minimum 7 ' inspection and if the indicators show they are outside those 8 bands or thresholds we would increase at least a part of 9 that. They could very well operate within that band and l'0 we'll leave them alone. 1 11 DR. APOSTOLAKIS: But Bruce, you are bringing up i 12 another issue now. You are saying that what counts.is the
'13 band not the threshold, and if I didn't speak to you and 14 listen to you, I wouldn't know that.. The document does not 15 say that. In. fact, that may be a way out since I fully
- 16 appreciate, by the way, that you had to do it in a generic 17- way. Perhaps instead of a threshold give a band because 18 what you don't want to-do is introduce new requirements 19 through a document that is supposed to be an oversight and l 20 assessment document.
21 MR. GILLESPIE: Yes. This is fundamentally an I 22 internal tool for us to know when we have to do and 23 understand more. ; 24 DR. BONACA: I would like to make one comment. 25 MR. GILLESPIE: Go ahead. ANN RILEY & ASSOCIATES, LTD. Court Reporters o 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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i 18 iq 1 DR. BONACA: Simply it seems to me that, yes, I l% ,/ 2 can understand it is an internal tool but then it introduces 3 again subjectivity and one goal is go away from 4 subjectivity. l 5 One thing that concerns me, looking at these l 6 thresholds -- that is the same point that George is l 7 making -- is they may not be equally achievable for all i 8 plants at the same level, but again there is compensation I 9 from other systems that may not -- what I mean is designs of 10 plants vary very much for the BWR high pressure injection 11 system. 12 Some plants have just one train but they have 13 other things that compensate for that, and simply the
,, 14 threshold is not equally achievable for all plants, but the Ks 15 reason is there are reasons why, however, core damage 16 frequency is equally low because there are other systems and 17 so that is what I am trying to understand.
18 Is that the point you were making, George? 19 DR. APOSTOLAKIS: Yes. One of the points. 20 MR. GILLESPIE: We are not disagreeing with that. 21 DR. BONACA: But my only concern is the issue of 22 subjectivity, because the question is how is it going to be 23 interpreted and used in the field. 24 MR. GILLESPIE: Well, the intention is, just as 25 Bruce said, that at that point we have to develop a better f
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L 19 1 understanding, so'you go from an indication mode into an i 2 understanding or diagnostic mode. 3 Once we understand it, then it is a done deal. l 4 Also, this is a starting point, not an ending 5 point and here is something I am kind of cautious about and 6 one of the reasons we went from generic in that work in the 7 future to specific and that's on the other side is all those 8 people who talk about the fidelity of individual PRAs and 1 9 overdependence on them and how can you have two plants, how l 10 can you have two plants that appear to be virtually l 11 identical with two different PRA results and different sets 12 of important systems, and how do you deal with that 13 uncertainty. 14 At this starting point we were not prepared to 15 have individual plant by plant specific profiles,- so this is i i 16 our starting point. To do that in the future is a good 17 option, but I can't deal with it between now and June very i l l 1 18 well. j i 19 Is this a de facto different set of performance l 20 standards? It could be abused to that extent. I can't say 21 it couldn't. It is certainly not our intent and that is why 22 we have got it out for comment. i 23 DR. APOSTOLAKIS: Well, I appreciate the ' 24 difficulties you have. I mean don't think that I don't. L 25 On.the other hand, we have to evaluate these r~\ ,
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Court Reporters r 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 i
i 20 1 things and scrutinize them because this is the first time . 2- -that we are really doing such things in a big way. 3 First of all, I think that the document, the 4 written document, should reflect some of the thoughts that 5 .you just gave us, Frank. For example, we had a similar -- 6 not quite the same but similar discussion in the development 7 of the Regulatory Guide 1.174 whether the lines were bright 8 to different shades of gray and so on, and what Bruce said 9 about maybe the band really being more meaningful -- now I 10 don't know if you already have several bands of regulatory 11 action and now.you are making the boundaries between the 12 bands themselves -- what all that means but also maybe 13 'you should give the option to a utility to come back and 14 argue on the basis of their IPE or PRA that for them BWR
- 15. high pressure inje'ction system unavailability of .07 makes 16 . sense and they will maintain that, but they have other 17 things that compensate for that.
18 Right'now, there is no option like that here. It 19 is generic thresholds and the truth also is that very few 20 people really understand the subtleties of all this. 21 I mean you are saying there is a danger for abuse. j 22 I think the probability is pretty high that well-intentioned 23 people will abuse this because they don't understand the 24 fundamental idea of overseeing probabilistically -- not that 25 I understand'it. It_took me a while to understand this and ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
! l l l 21 l 1 make the points. I 2 MR. GILLESPIE: Well, one of the criticisms of the
'3 package was that we didn't have a clarity of purpose in 4 there, and that is something we're going to fix -- the idea 5 that this is strictly an indication process and which you 6 then go into a process of understanding when the indication 7 says more understanding is needed.
l 8 I can't fix it here today -- 9 DR. APOSTOLAKIS: I know. I am just raising the I l 10 issue. I know. 11 MR. GILLESPIE: The ideal would be plant-specific 12 profiles. 13 DR. APOSTOLAKIS: Yes. 14 MR. GILLESPIE: Because just by the nature of the 15 statistics, we are agreeing that 5 percent on any given ., 16 indicator could be outside the band and that's perfectly 17 acceptacle. 18 DR. APOSTOLAKIS: Right. 19 MR. GILLESPIE: There's tails on every j 20 distribution but being in the tail doesn't mean you are bad. 21 It means we need to understand why so we know you are not. 22 We do need to put that clarity in it. 23 How we get there from here and how fast we can do 24 it I don't know, and the other piece we need to be concerned 25 with as we'need'to part from generic and go to
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m.. _ _ . . - _.. _ . . - _ ._. _ . _. _ _ _ _ . . __ __ . _ _ . _ , _ . ._ - ,_ , I I e 22 ) g 1 plant-specific is how do we communicate that to the other i /q (j 2- stakeholders. We may understand it and the industry with a-3 PRA group at each facility may understand it, and it's kind l-4 -of a compromise in there in a somewhat more simplistic view f 5 in trying to have something enat we can also communicate to 6 the public. ! 7 There is some simplicity driven into this. 8 We also came up with another point of confusion ! 9 which we are starting to get clarified with people, and that . l 10 is that there are two very important matrices, one that Pat 11 is going to go through which apply to individual indicators i 12 and will then -- also a parallel process to apply to 13 individual inspection results. That is an individual 14 indicator. It is one out of 20 indicators. [ . ['N (
. _g/ - 15 Then there is a matrix that Mike has in the i
16 assessment process which is the matrix that covers expected 17 agency actions'or regulatory response. L 18 Initially when people thought about the concept 19 they talked about green plants. We said but there's no
- 20. green plant. There is a green indicator.
21 Also clarifying the difference between a threshold 22 and a band -- well, thresholds establish bands but the 23 context we use it in is really a l'icensee response band, 24 regulatory response band, and the terminology if you 25 eliminate the colors, the terminology in there is actually i
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1 23 j 73 1 focusing on the bands. e i
~- 2 Now the interesting point here is that the i
3 industry has -- I don't want to say -- I guess I could say 4 has tentatively agreed that the licensee response band as a 5 first cut on this is reasonable. They are not saying it is 6 perfect, but they are saying it is reasonable as a first l 7 start, that people should be able to actually have some , 8 things go wrong at a facility and they should be able to 9 correct them before they pass out of the band. 10 And that's a broad expectation of establishing the 11 width of the band, be it three scrams or the unavailability 12 numbers. What we don't want is an indicator system that 13 trips on a failure, on a single failure, or on a single r"'s 14 thing. So, 95 percent performance over the last several 15 years as in industry set, that is kind of how we picked it. 16 Then looked back and said, well, is this low risk? And the 1 17 answer to both of those was it looks achievable, in general, i l 18 recognizing there is a 5 percent tail on every indicator, 19 and it is low risk. 20 I don't know that we can do much more at this 21 point, but this is a starting point. That's the other 22 emphasis here. This is a starting point. We have got a f 23 list of about six different topics from research on 24 longer-term on how to mature this and make it better. So -- l l 25 DR. APOSTOLAKIS: I think that by putting these
,n A
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a a l 24 1 thoughts in the document and starting out by saying, you
%, ) 2 know, ideally, one would like to have a plant-specific PRA 3 base on this. If a utility wants to do it, we are open to 4 suggestions, you are very welcome. Now, we have to do it in 5 a generic way, so we have to select a way for doing it.
6 Now, one way might be to say, well, I will take 7 the highest value in every chart and go with that. Well, we 8 don't want to do that for some reason. So we want to be 9 generic. We have this requirement. We go with the 95th 10 percentile, but we will -- this will be an indication, 11 blah-blah, everything you just told us. 12 MR. GILLESPIE: Yeah. 13 DR. APOSTOLAKIS: And maybe soften the impact.
,_ 14 Now, let me tell you what really bothers me at a \/ 15 philosophical level without necessarily attacking this 16 document. We can work on a PRA space and be as prescriptive 17 as we are now in the deterministic space. If we ever 18 produce a document that will say, okay, it will be !
19 risk-informed, so now we are going to tell you what a 20 threshold, a regulatory threshold is for scrams per year, a 21 regulatory threshold is for unavailability of this system 22 and that system, I would really object to that, because now 23 we are being very prescriptive in PRA space. It is none of 24 our business. If the accident sequences have the 25 frequencies that are acceptable, why should we regulate the A k,) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
_ . - . . . _ _ . - - _ . . .-~-..- 25 p~s 1 initiating events and so on? t
\ 2 So that is what really struck me, and I am 3 bringing it up, that, perhaps unintentionally, you do some 4 of that-here by saying, look, 95 percent is what we are
'5 choosing and the other 5 percent -- now, if I am the owner 6' of a facility, what do I do? I get a signal from the NRC j 7 that my unavailability is not really good, but that is not a 8 job of the oversight process, that is somebody else's job.
9 So, now, for oversight purposes, I think it is all 10 right to look at each cornerstone, perhaps look at other 11' things below the cornerstones, because you are overseeing l 12' .now, you are making sure that what they told you remains 13- that way in the future, so that is not intrusive in my mind. g- 14 But if you demand, though, that the frequency be below a
^
15 certain level, that is regulating the frequency of ] 16 initiating events and that, I-don't think we should do. 17 MR. BARANOWSKY: There is no demand associated 18- with~these green-white thresholds. They are exactly what . 19 you said, and, that is, they are a point of oversight in 20 which we increase our oversight because we have indication 21 that we should start to look in those areas. l 22 When you get to the point of unacceptable
- l. 23 thresholds, where we talk about talk about taking actions 24 such as shutting down a plant, that is a different story.
25; Then maybe.that is the point where we are imposing some t ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 L (202) 842-0034 L I 1
26 1 regulatory action on a licensee. But this is oversight,
)_ 2 minimal oversight when you are below that line, a little 3 more oversight, which seems to make sense. Where are you 4 going to spend your resources? Well, where it seems like
- 5. " the performance is not within the norms, and a few sigma 6- outside of the norms is the point where you say, is that an
-7 outlier?
8 .DR. APOSTOLAKIS: But you see, Pat, that is 9 exactly my point. That is why I asked what is the objective 10 of this. Aren't you bringing now another element in the
, 11 regulations, namely, how does your plant perform with 12 . respect to the others? When you licensed it, did you do 13 that? No. When you licensed it, you said here is a set of
- 14. regulations, if you meet them, you get your license.
) 15 -Now, we'are saying something else. We are saying 16 but if you happen to be outside the bound of what everybody 17 else has.
18 MR. BARANOWSKY: That was just done a convenience 19 because -- I think you are right, we would like to have a 20 more plant-specific approach to this, where some plants are 21 more susceptible to high or low reliability depending on 22 system design and operating characteristics. But as a first 23 cut, we said let's just start with this more generic 24 treatment. 25 DR. APOSTOLAKIS: I think we need a good () ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Evenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
27 1 discussion up-front what the purpose is, that you are fully (_s 2 aware of the fact that there are certain risks by going this 3 way, but there are some benefits as well, because we can do 4 it is, it is generic and so on, and if somebody wants to 5 come in here with a plant-specific PRA and argue that their 6 thresholds should be different, you are willing to listen. 7 MR. JOHNSON: George, let's not forget also that 8 we do what this process is talking about trying to do, we do 9 it today. We look at the performance of plants, we le ' at 10 it in some areas that we have set up for ourselves. We make 11 decisions about events as they occur on a real time basis. 12 We. decide whether we need to engage, to do more inspection 13 based on the instincts of the inspectors. I am being a 14 little bit cavalier, but we use our judgment, based on our 15 -experience, based on our understanding of what is important 16 from a risk perspective today to make decisions about 17 whether we engage, about -- the extent to which we engage. 18 Do we send out individual inspectors? Do we send out a team 19 of inspectors? So on and so forth. 20' And what we need to keep in mind with this process 21 that-we are proposing is that we are simply trying to add a 22 structure and a framework to do that in a way that is a 7 23 hierarchial approach, as the-ACRS has pointed out, that we 24 -need to go on, we think it is a good direction to go-in. 25 That starts with this notion that, given the fact that we fA l(j . ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.. 20036 (202) 842-0034
28 1 are working towards this mission, this common mission of ,\ ( ) 2- public health and safety, and then that we have had 3 cornerstones which say, hey, given the fact that we have got 4 this robust framework, regulatory framework, and all the 5 requirements, we can't possibly look at everything. And l 6 even if we could look at everything, what would we do with ' 7 'all of that information? 8 So we have set up this series of cornerstones and 9 PIs and we have established PI thresholds and inspection l 1 10 thresholds. And the entire notion is to be able to take a l 11 look, from an objective perspective, to see when plants are 1 12 beginning to wander from what we accept as the utility l 13 response being -- and this notion that the utility can ,r 3 14 respond, and to the point where we need to begin to take ( ,I 15 some action. 16 Now, we are not going to be measuring delta CDFs, 17 we are going to be looking at numbers of scrams, we are 18 going to be looking at some very simple things. And the 19 whole reason to do that is to be able to have some objective 20 way to figure out when we ought to engage or when the 21 utility ought to engage, and the extent that we ought to 22 engage. And that is what the action matrix and all those 23 things talk about. 24 DR. APOSTOLAKIS: I understand. 25 DR. BARTON: George, I think utilities are used to ('3'~') ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p i 29 1 " working this. You look at the INPO indicator, they have got 2 scrams, they have safety system actuation, and they have got 3 goals set for each one of those, and utilities try to
'4 operate to stay within the goal. This is the same kind of 5 thing. If you get enough -- above enough of these bands, 6 you'are probably in trouble. If you don't meet a lot of the 7 INPO indicators, you get a real good look at those areas 8' when they come'in and do an evaluation as well.
9 I think it is a trust thing here. If get above a i 10 couple of these targets, is the NRC going to come in and 11- shut you down right-away? I think.that gives you some 12 nervousness of how this is. going to be used. But I -- I
- 13 don't.know, I think it is a good process, to try to figure 14' -what-is a better process than what they have laid out in
. Cy/1: 15 :looking at,1 you know, how are: plants performing. You know, 116- 'where are plants getting out of whack, so to speak, and what 17 is the reason for that? 18 If you follow maintenance rule, you have got
- 19 training, procedures and human performance, and all those i 20 kinds of things are, quote, "okay" at your plant, you are 21' probably not going ~to have your. plant above this threshold l 22 in these' areas. So all this tells me is I see that, you
~ 23 know,-what is going at that plant?. What is the maintenance ;
24 history-of that system? What is the problem with the
- 25 -maintenance rule at this plant that they are up with this
'l ANN RILEY-&' ASSOCIATES, LTD.
Court Reporters' 1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C. 20036 (202) 842-0034 4 1 1 t v w w * . , -+ + + + - - - - * * - - - + - - - - - - - -
..l l
l 30 l 1 system unavailable in the RHR system? And that is what I l I'D () 2 think you use this for, and I don't have a problem with I 1 3 that. I 4 Now, if you are going to come in here and beat me l 5 up over that and shut me down because of it, I think that is I 6 the trust issue here. 7 DR. APOSTOLAKIS: Well, no, first of all, I think I 8 this is one of the best risk-informed documents -- 9 DR. BARTON: I thought you believed that until 10 this morning. I am wondering what is going on here this 11 morning. 12 DR. APOSTOLAKIS: I do believe it. l 13 DR. BARTON: This is six months revisited or
,~. 14 something.
E i ks/ 15 DR. APOSTOLAKIS: And I want it to become better. 16 But, remember, this is -- no, really, you did a great job, 17 don't get me wrong. I am just arguing a couple of points 18 that I think -- three points that I think are very 19 important, and some of them can be remedied by writing a 20 better background and introduction. 21 But I think, John, it is different from an 22 industry -- when I have an industry organization like INPO 23 going to a particular plant and saying, hey, this is the t l 24 norm, you are near the tail or you are outside, and so on, 25 it is very different from having a regulator come and tell CN () ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
31 s 1 me the same thing. (D t u,/ 2 Let's say that I am a known recover plant, and I l 3 tell the NRC I have legal documents here that you have ' 4 granted me a license. No where in the license do I see 5 initiating event frequency and unavailability and this and I 6 that. And now you are going to inspect me on the basis and 7 make decisions? I am going to have my lawyers after you. 8 MR. BARANOWSKY: George, we do that now without 9 this objective cut. We see something happen at a plant, I 10 with our own personal cult and culture and operation, we go 11 do things. 12 DR. APOSTOLAKIS: Right. 13 DR. BARTON: They do it with the SALP process, 7- 14 which is much more subjective than this.
- 15 MR. GILLESPIE: George, one of the --
16 DR. APOSTOLAKIS: No, no , no, no. Wait, wait. 17 The fact that we are doing it now, though, let me finish the 18 thought, because Michael is already -- the fact that we are l 19 doing it now doesn't mean that it is the right thing to do, 20 and, in fact, I thought that was one of the major complaints 1 1 21 at the stakeholder meeting, was the inspection process, was l 22 it not? 23 MR. GILLESPIE: Yeah, the lack of transparency and 24 the lack of a standard. l 25 DR. APOSTOLAKIS: And too intrusive. l n ( ,) 70R7 RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l 1 ..
32 1 MR. MALLETT: This is Bruce, let me make a
/~T
(_,l 2 comment. Is that I think George is right that this is one 3 of the holes that the Commission emphasized to us that we 4 need to work on, is establishing these thresholds correctly. 5 And, also, how the inspection findings interplay with these 6 performance indicators. Let's say somebody drops, as you 7 said, George, from .04 to .07, I think you were using 8 unavailability of the HPSI system, then they -- we have to 9 look at the inspection program and what has it shown us in 10 that area as well. Bectuse it all fits together to say, do 11 we believe the objectives of cornerstone were met? That is 12 what we designed the program to do, is to determine is the 13 licensee meeting the objective of that particulsr 14 cornerstone. i ' 1
'/ 15 DR. APOSTOLAKIS: Bruce, if the four of you 16 gentlemen were doing this all the time for other plants, I 17 wouldn't have any problem. Okay. I wouldn't have any 18 problem.
19 MR. MALLETT: I want to mention a couple of other 20 points, Frank, that are different than what George was 21 raising. But it is close to his original question on what 22- was our objective. In the risk-informed baseline program, 23 we wanted to focus on risk, the planning inspections and 24 conducting inspections, and we have got that concept in the 25 process. We also wanted to make it clear why we are . ,Q ( ,j ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
33 1 inspecting something from a risk-informed perspective in p).
-%, 2 linkage to our mission. We have ga- -that in there.
3 And, last, we wanted to have risk information put
-4 into how we select our samples, which is different than 5 ~ today, and we wanted to have that in there. So when you 6 look at why we did what we did, those were some of the 7 original reasons.that we put into the program. So I 8 recognize we'have whole lot of thresholds, but we can't
'9- forget some of those objectives on why we wanted to what we 10 wanted to do.
11 DR. BONACA: -One' comment I have, if I could. I 12 don't see why this discussion should not be reflected 13' somewhere in the early portion of the document to this i 7_( 14 nation, because you are using a lot of PRA, risk-informed
;\-)
(
. 15 information coming from PRA concepts. So you have got to 16- put some kind of insight in how this is going to be used, 17 the way you are describing here. And I think that that 18 would enhance the understanding of this approach for 19 inspectors, in fact, and for everybody else. So it would 20' improve'the scrutability of the process that you are talking 21 about.
L ! 22 DR. APOSTOLAKIS: One of my real concerns here is , ;23 'that we will send a message to the rest of the NRC that when l
- j. 24 you develop risk-informed regulations, it is okay to put 25 thresholds on initiating events, on unavailability. Well,
.[g
(,) ANN RILEY & ASSOCIATES, LTD. , Court Reporters-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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34 1- it is not okay. It.is not okay at all. That is not'the j ' 2 idea:of performance-based -- risk-informed, 3 performance-b' a sed regulation, that is not the idea. And~it 4 is so easy to fall into that pitfall, because, you know, it
.is detailed, it is nice, it is something I can measure, but 5-
- 6. that-is not the intent. For oversight purposes, it is okay 7 to look at these things, but not to put, you know, 8 regulatory limits,'then you are back to a prescriptive l 9 system.
- 10. MR. GILLESPIE: Let me go back to one comment that 11 was made'here that we didn't address. And that was,.one, 12 this is an indicator process, including inspection, and part 13 'of what a utility gets, if you would, from participating 14 with the indicators, is the inspection program won't jy ,
\_/T 15 ' duplicate the information that that indicator is giving us.
16 So there is some dependence on the indicator. We 17 have a reliance that we are not going to duplicate that 18 area. We're going to do some verification inspection. So 19 there's definitely a backoff, if you would, on inspection. 20 Because the big question was what information do we need to
-21 make a reasonable assurance finding.
22 The other thing is, this is not diagnostic _or
- 23 cause~. When an indicator says you need to understand what's 24 happening, the problem is still going to have to be
.25 discussed and identified in the context of the regulations.
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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 n
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~ 1' You're right, if we went in and said you've got 2 four scrams and therefore we're going to take some action 3 based on that, no. The root cause of the problem is still 4~ going to have to have its essence and any corrective i- 5 regulatory. action taken is still going to be based in
'6 regulation and license.
'7 So when you do get engaged, you tend to fall back 8 on the traditional system of what was the cause, what's the 9 requirement,1 was a requirement violated, and if a 10 requirement wasn't violated, then we have to say we 11 understand what happened and it's okay, or it's a new 12 . phenomenon,- and we have to do something about it and issue 13 an order or a license condition or something. So it gets us
-14 back into kind of the today environment when you do become U(~s : 15 more diagnostic.
L 16 That was the intent. It's a starting point. It's 17 not a finishing point, and we recognize that. 18 The other thing'is, it.was never our intent to L19 rewrite:this document, by the way. This document goes away
- 20. .by June. This. document.is really the' description of the 21" concept that we would use as our guidance in writing I'll 22 . call it the real program documents. So this description of 23 .n'ot abusing things would actually go into whatever we would 4
- 24) replace,. Inspection Manual 2515, which has the philosophy of 25 the inspection program in it. One of the cautions I want to.
[ T < ANN RILEY & ASSOCIATES, LTD. Court Reporters
-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
4 36 1 do is I don't want'to keep rewriting a document that's 2 really'not a functional document in any sense or any system. 3 This was a descriptive document. So -- 4 DR. APOSTOLAKIS: Is this a public document, by 5 the way? 6 MR. GILLESPIE: Oh, yes, yes. It's on.the Web. 7 The Commission gave us permission to put it out before they 8 even saw it so we could get comments. Comment period has 9 s' tarted, and we'll see what comments we get. I agree that 10 -- the Commission said the same thing, the context that we 11 were talking to at the meeting was absent by way of like an 12 introduction or contextual statement in the front of it. 13 DR. APOSTOLAKIS: Let me ask you another question,- 7- 14 Frank -- or all of you. One of the particularly sensitive
?
[ 15 issues with some of us on this Committee, and I think with 16 the industry, is that PRA is perceived as being a tool for 17 adding regulations or adding burden. Is this document 18 removing any of the burden,-the existing burden?
-19 MR. GILLESPIE: Yes.
20 DR. APOSTOLAKIS: Okay. 21 MR. GILLESPIE: In fact, if you look in the 22 inspection section, there are some hours there, and we 23 didn't project it all the way forward, but I had given this
~24 information to Sam, and he used it at the Commission
-25 meeting, so now it's in a public transcript, so I feel free O
\ ,/ ANN RILEY & ASSOCIATES, LTD. Court' Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
37 1 to use it again.
> \
- (_,/ 2 This probably reflects a 15 to 20 percent 3 reduction in overall inspection.
4 DR. APOSTOLAKIS: Okay. 5 MR. GILLESPIE: In two phases. When Pat 6 ba11 parked how many sites would actually meet the entire 7 profile as being in the licensee control zone, it's in the 8 ballpark of about 50 percent of the utilities. So about 50 9 percent of the utilities that are now getting some level of I 10 reactive kind of inspection from us would no longer be 11 getting that level of reactive inspection. So I think 12 there's going to be kind of an immediate incremental benefit I 13 from being risk-informed and being focused. fs 14 And now the question would be is -- I think we ( )
'v_/ 15 need to be cautious as regulators, and we're generally 16 conservative -- is as you're fine-tuning to a plant-specific l 17 nature maybe, that as you fine-turn, you don't lose some 18 sense of checks and balances that you've tried to build into 19 the system. And if you do lose it, you know what you're l 20 losing.
21 So yes, it looks like about a 20-percent savings. 22 The immediate piece in the baseline program itself from the 23 core to this baseline looks like it's approximately 15 to 20 24 percent. So that's 15 to 20 percent of the core, which 25 represents about half the inspection program across the (. (',) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 y
l 38 1 board. And then there's about another 20 percent which is i l' i l
\ J- 2 the reactive effort, which might not take place. l J
3 Now what's going to happen, George, and you're j 4 absolutely right, is I could say the safety gain here is 5 everyone's going to strive to be in the best category. It's. ; 6 a possibility. That's a business decision. 7 DR. APOSTOLAKIS: Which is not a bad idea. 8 MR. GILLESPIE: Yes, I mean, you know, I mean, I 9 have to recognize that. I'm not living in a vacuum, because 10 utilities every day make the choice do I go along, and this 11 is one of the criticisms. So I'm not saying this as a fact, l 12 but do I go along with the inspector and just fix it, or do 13 I fight it. I mean, that's the kind of a thing you hear p 14 from the' regulatory impact survey going back ten years. t i S~ / 15 It would be a business decision that they would 16 strive to stay in the licensee control zone in all of these 17 areas. Now do I feel that we've kind of agreed if you would 18 in setting these thresholds with credible thresholds, 19 reasonable thresholds, I think we have. You know, I'd say 20 the best shot is 95 percent. 21 DR. BARTON: They are reasonable thresholds. 22 DR. APOSTOLAKIS: Yes. 23 MR. GILLESPIE: They're reasonable thresholds. 24 Now that's a business decision. It could happen. And that 25 could happen without us doing any arm-twisting. Someone ()
.f%
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R 39 1- could say you know, if there were really -- T-ks N.l. 2 DR. APOSTOLAKIS: All you have to do is'show up,
, .:, 3 Frank.
p '4 MR. GILLESPIE: Okay. Okay. All we have to do is 5 -- 6 DR. PARTON: I think we need to get on with Bruce. 7 We're going to lose him. C 8 MR. GILLESPIE;- Let's get to Bruce. Bruce only
~ has about.a half-hour.
'% 9 I think we're in violent agreement.
A '10 And the. Commission was also in agreement that we need'some l ' ll'- contextual-words-in'the front of this to put it in context. 12 I don't want to rewrite the document, because the document l 13 actually will go away within six months. ' 14 Bruce.
-\, _)- -15 MR. MALLETT: You should have in front of you -- I
[16 think the easiest way without repeating our last meeting is 17 .one slide that I. call a flow diagram that's used ---the 18- scope lof the program, planning inspections and selecting. l
- 19- Do'you.have that in front of you?
.2(F DR. APOSTOLAKIS: Yes.
L . .
'l 21' MR. MALLETT: Okay. Let me walk through that just
.22 -briefly. I don't want to bore you, but I want to highlight 23 some-of.the concepts we had previously in the program.
- 24' First, we've been talking about an oversight !
, #25 ~ framework where we: have Lperformance indicators, a baseline l
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.(202) 842-0034
.1 40 1- inspection, and an assessment process. That led us to.the 2 cornerstones of safety concept in which we'have seven 3 cornerstones. Those then defined inspectable areas and gave 4 us inspectable areas out of that. And George Apostolakis 5 asked us before to put in charts showing that linkage from 6- the inspectable areas to the mission of the Agency and to i
7 the cornerstones of safety, and, George, we did that there
)
- 8. in Appendix 2 to Attachment 3 on the document. There's a 9 chart-for each of the cornerstones that shows inspectable 10 areas and performance indicators.
11 DR. APOSTOLAKIS: I've seen that, Bruce. Yes. 12 MR. MALLETT: Okay. I just wanted to let you know 13 we do listen to you, George. p 14 We also -- 15 DR. SEALE: Never doubted it. l l 16 MR. MALLETT: The document I'm going to describe 4 17 these concepts out of for the baseline inspection program 18- are risk-informed is in Attachment-3 to the Commission ! 19 paper. There are nine sections to that. document. Each 20 section describes a particular concept of the program. For
'21 example, one-that you asked us for, Dr. Seale, you asked us 22 the last time to make sure we put in resources. We put in a 23 projection of that in section 8 of that Attachment 3.
24 Let me continue looking at this chart with you to 25 just describe a few concepts. First of all, the scope of
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41
. .1 - the program is defined by the cornerstones and these N 2 inspectable areas, but one of the goals we had up front was 3 to define why we inspect. _So we put that in something 4 called a basis document, and that's why we drew an arrow 5 from basis documents up to scope.
6 The next thing you would do in this baseline I 7 inspection program, you would plan inspections. And we
)- 8 developed something called a risk-informed matrix. We call 9 it RIM No. 1. Those are also an appendix to Attachment 3 to 10 the document. I believe it's Appendix 3. i 11 If you look at RIM No. 1, it outlines for each 12 inspectable area what the frequency of inspections are going ;
I 13 to be, how many inspections you might do,' and how many 14 samples you might select. We put ours in there as a way of 15 budgeting. One of the points of contention for the ] 16 Commission, you ought to realize, they challenged us on was 17' it's a great concept, Bruce, but for a lot of the 18 inspectable areas, you don't have much definition of the 19 sample. And they are right on that. We need their -- as we 20- go through the pilot and using this program further develop 21 what samples we'll have and how many. 22' 'The next thing where we put risk into the process 23 is in selecting the sample. Once you've planned on your 24 12-month cycle and your plant performance review in each i 25 region, you'll take RIM No. 2 then and select the system N- ANN RILEY & ASSOCIATES, LTD. Court. Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202). 842-0034 L
, , . , > =
1 l 42 1 that you might want to look at. That's generic.
,s ~
Plant k,,,) 2 specific, you'll have to modify that by using the SRAs and j 3 any plant-specific information to determine your sample. 4 And then the next thing you do in the process is 5 you inspect, and we've got the procedures concept set up as 1 6 a procedure by cornerstone to perform the inspection. And 7 I'm going to -- procedures are listed in section 4 of that 8 Attachment 3. 9 And the last thing you'll do is you'll assess 10 those findings much like today. We envision you'll have a 11 plant information matrix type summary of the finding, but we 12 envision that you'll have a risk scale, and this is another 13 hole right now, that this risk scale has to be developed to
,s 14 set what we're thinking of as maybe three areas. You'll
- 15 have a performance that we believe is not risk-important.
16 You'll have another category we believe_that's very 17 risk-important in your finding. And then one that just says l 18 it's a finding, but it's an average performance. 19 DR. APOSTOLAKIS: Would you -- 20 MR. MALLETT: We haven't developed this much -- 21 yes, George. 22 DR. APOSTOLAKIS: Would you put another arrow 23 there under findings assessment to bring up again the 24 plant-specific nature of these things? In other words, you 25 do your inspection, and then when you evaluate what you
,/~~
( ) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 l
43 1 found, you look again at the plant. Unless that's r
\' 3,)
2 understood. Maybe that's understood. 3 JMR . GILLESPIE: Yes. George, let me kind of come
; 4 out of the closet a little bit on how we're working this.
5 We actually right now kind of have a draft which has two 6 scales, two steps right now, and then there will be a third 7 step. l 8' One is a generic screening out of totally 9 risk-insignificant anyplace kind of items. Then there's ! 1 10 another step which gets you into is it risk-significant in a 11 sense at that facility. And then there's a third step that 12 says the inspector isn't in a position to make this 13 judgment, we need the SRA or we need some more analytic help
. ,, 14~ on the bottom. So it's kind of a multistep screening kl s 15 process, because we need something that an inspector can 16 quickly and rapidly use for the majority of the cases. ,
i 17 DR. APOSTOLAKIS: Okay. I 18 MR. GILLESPIE:
. So, yes --
y 19 DR. APOSTOLAKIS: That makes sense. 20' MR. GILLESPIE: We're getting to that point, 21 because it's the risk at the facility that we have to focus 22 on. 1
- 23. DR. APOSTOLAKIS: Okay.
I24 MR. MALLETT: .Okay. The last point I wanted to 25 make is that we put down a block there that says () 4 A ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 44 1 cornerstones objective met, yes or no. The idea of that is (.m ( ,); 2 to show that this is a minimum baseline program to be 3 performed at all plants. If they meet the objectives, 4 they'll continue to receive the baseline program. If they 5 don't, through as we talked earlier, through crossing some 6 threshold or from an assessment finding, meet the objective, 7 we want to increase the inspection above that for that 8 plant. 9 So, George, you asked the question of reducing 10 burden. An implication of this is that currently, you know, 11 we have set out at some sites rather than inspectors at the 12 N level per number of units, we have also in some cases set 13 at the N plus 1 level. If that plant is in the band where
,, 14 we believe they're meeting the cornerstone objectives, the
( \ (-) 15 new program will s'ay they will only receive the baseline 16 inspection program, you'll have to decide what you do with 17 that other that is there so that they don't raceive more 18 than that. So that's a big implicaticn of this change. But 19 if we carry it through, that will be certainly a reduction 20 of unnecessary burden of a licensee's facility. 21 I can mention more, but what I want to do is 22 refresh you on those concepts and then leave it to any 23 questions that you might have. 24 DR. APOSTOLAKIS: Which attachment has the 25 inspection areas? A I ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
45 1 MR. GILLESPIE: Three. \s,) 2 MR. MALLETT: That's Attachment 3, but the 3 Commission paper, the SECY paper, the main concepts are just 4 discussed or described on page 12 of the Commission paper, 5 and the implications for policy I just mentioned are on page 6 15 of the Commission paper. 7 It also listed -- I'll mention one more thing -- 8 in Attachment 3 in the beginning you'll find an executive 9 summary and in that executive summary we list the work we 10 believe still needs to be done prior to conducting a pilot 11 program. 12 DR. APOSTOLAKIS: Now the inspectable areas, 13 Bruce, like Attachment 3, I guess arabic 1, page 1, l
,s 14 program -- Part 1, inspectable areas.
? h V 15 MR. MALLETT: That's correct. 16 DR. APOSTOLAKIS: Attachment, page 1. 17 First of all, this idea of complementary and i 18 verification inspection I think is very good. You are 19 really trying to discriminate as much as you can. 20 MR. MALLETT: Now I have to give credit to Pat 21 Baranowsky and his group for that -- 22 DR. APOSTOLAKIS: He just stepped out of the room, 23 so let's hope he reads the transcript. 24 The inspectable areas by cornerstone -- how did 25 you come up with these? Was it just your group sitting 73 i < ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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- 1. around the table and.saying, well, what is it that we need
() 2- :to do here-or was there some more systematic way, because 3 this is really what'you are.actually inspecting, right? 4 MR. MALLETT: What we did was originally we sat 5 around the room or Pat Baranowsky's group sat around the 6 room and we said what all do we believe we need to inspect 7 .to meet these~ cornerstones objectives? 8 I think we had a hundred and some areas that we , l 9 came up with' originally,.and then as the framework team ! 10 ' developed the performance indicators and as we met with them 11 and discussed-them, we said where do we have a performance 12 indicator that we don't need to inspect because it already 13 covers that, and we crossed the list off for those, and then
. 14 we said -- we made another cut. What is risk important?
15 Well, we crossed a number of things'off the list that we
.16 felt were not risk-important.
17 I'll give.you an example. ..Under the Mitigating.
- 18. Systems cornerstone we originally had an inspectable area of
'19 observing maintenance activities. We said we don't need to 20 . observe maintenance activities. The key part of those from 2 11 .a' risk perspective is the post-maintenance testing, we 22 . thought, and so we left that one in but took' out observing 12 3 ' maintenance activities.
- 24 That is how we arrived at inspectable areas, but 25 one thing I'll also mention, George, in Appendix 1 to that 9"N i 1j 10-i ANN RILEY & ASSOCIATES, LTD.
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t 47 l 1 attachment in the basis documents we added something after l s) 2. we met with you all the last time. We described in there 3 why we inspect, but we also discussed performance l p 4 indicators. 5 Remember you all suggested we highlight how those 6 interplay. 7 DR. APOSTOLAKIS: Yes. In fact, let's go to 8 Attach 1, page 5, because that is where my notes are. l 9 Attachment 1, page 5 -- where you also have the inspectable 10 areas by cornerstone. 11 MR. MALLETT: Right. 12 DR. APOSTOLAKIS: For example, if I look at 13 initiating event cornerstones, maintenance rule e- 14 implementation, maintenance work prioritization and
'd 15 control -- why do I have to worry about work prioritization 16 and control if they comply with the maintenance rule?
.17 MR. MALLETT: For initiating events? l
' 18_. DR. APOSTOLAKIS: Yes.
19 MR. MALLETT: What we felt there was there are 20 some events where the maintenance caused the problem by not
- 21. deciding the right.-- I don't want to say sequence, but not 22 looking at one system they are doing maintenance on versus 23 another system, because they didn't prioritize their work to
~
.24 do it in the sequence that wouldn't cause that problem later 25= on -- like if they had an event while they were working on a
1 Why did you feel that it was unlikely that they
) .
2 would be successful?. 1 3 MR. MALLETT: I am not sure, Dana, that we thought . l
~4 it was unlikely they would be successful. We felt at this 5 point in time that there1wasn't one developed and so -- 1 i
6' DR. POWERS: I.mean that is not the criterion on 7 shutdown, so why should it be the criterion on fire? I 8 MR. MALLETT: Well, the same way in shutdown we 9 felt that there wasn't one developed yet so we would not I l 10 rely on that performance' indicator. I l 11 DR. POWERS: I understand that, but in some cases 12- you have said, well, in the future there might be, and you 13 have allowed for-that possibility that in the future there
-s 14 might be --
' 15 - MR. MALLETT: Oh, I see your point.
16 DR. POWERS: -- but in fire you apparently had 17 little faith that this could be accomplished. Now that may 18 be a very, very rational viewpoint but I just wondered why 19 you had that viewpoint. I l 20 MR. MALLETT: I don't think it was having little i 21 faith, Dana, as much as we may have had an oversight 22 inconsistency between the two writeups and we may have to 23 look at that. 24 DR. POWERS: I think you should, because if that ! 25 is a major initiative that the Staff is undertaking to vote b Q ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 l 51 t 1 with your feet on it may not give them the encouragement ( / 2 they need at this critical juncture in their work. 3 MR. BARANOWSKY: I think we identified the 4 performance indicators that we thought we might see some l 5 development and acceptance of in the next six months, and ! 1 6 our impression was that the fire program performance I 7 indicator probably was going to take longer than that to 8 develop and get operable. 9 DR. SEALE: You are less sanguine about shutdown? l 10 DR. POWERS: In six months we are going to have a l 11 shutdown performance indicator? l 12 MR. BARANOWSKY: Well, there were some proposed by 13 the way, and what we didn't have was the time to get the
/s\
14 data and look into the details of the indicator to see k/ 15 whether we thought it was a really valid indicator or not. 16 The feeling was that it probably could be developed. It was 17 a judgment call. That's all. 18 DR. POWERS: Well, it may be very sound. 19 MR. BARANOWSKY: You wouldn't be the first to say 20 that it's not going to be possible. 21 MR. GILLESPIE: It wasn't our intention to take a 22 shot at the fire people. 23 MR. MALLETT: Yes. We can take Dr. Powers' 24 comment and look at it during the pilot program and see if 25 there is some way we can factor that in better, give more i l ( ')x ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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,, 1 credit to them -- good point.
f i \_) 2 MR. GILLESPIE: I think simplistically when you 3 look at shutdown, you can ask the question how many water 4 sources are available and is there power available to pump 5 the water to where it needs to be and is the heat sink 6 available? 7 All of a sudden I have got specific things that 8 you can count at any given time at a shut down facility and 9 say yes, I have got two water sources available -- yes, I 10 have power from two different sources ready to go to the 11 pumps. It's actually something we could count, so we saw 12 some near-term achievability in shutdown. 13 We were not familiar enough -- in fire protection 14 when you look a fuel sources and other things, how would you
15 measure fuel sources? It seemed like a bigger problem, so 16 there was kind of, I think, a near-term, longer-term 17 perspective when we were doing it.
18 I literally mean "we" -- I mean just the team 19 working on it saw shutdown was a place we could make 20 progress and fire just needed a whole lot more work before 21 you had something that was countable and easy -- something 22 you would see from actually the control room. 23 DR. POWERS: You have a tension that runs 24 throughout the document between defense-in-depth and some of 25 the rest of the document, the rest of the approaches you 73 (__,) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025. Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
53 1 have.
\# 2' One area where you don't have tension, one area 3 that_everything that one would do for inspection and 4 regulation of safety is lined up with defense-in-depth is in 5 fire protection. The things that you would count are the 6 things that make up the elements of fire protection -- of 7 defense-in-depth and fire protection.
8 Do you prevent fires from occurring? Do you 9 detect'and suppress fires? Do you protect the equipment? 10 So in a counting basis I think that you will find that you 11 can count and what you count are things that are explicitly 12 defense-in-depth items. There is not a tension between 13 defense-in-depth and the things you are inspecting the way [' '% 14 there is throughout the rest of the document -- and that is
\
15 because fire protection is the one area where they have 16 explicitly-defined defense-in-depth. 17 MR. MALLETT: I guess one other comment I would 18 make on a different note than what Dr. Powers was talking 19 about was the last time we met NEI said they had two points 20- of contention about the proposed program.
- P 21 One was they had thought when we set out there 22 were going to be more performance indicators than there are l 23 now in the program, and we indicated that we opened the door ;
24 for that, but we haven't developed all those performance 25 . indicators and that is why they aren't in the program now.
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54 1 The second point of contention they were making 2 was remember when we said we wanted to do an identification 3 .and resolution of problems inspection as a two week 4 inspection once a year and they indicated they didn't know 5 we needed to do that. They thought it was repetitive. 6 We had left it in the program. We' changed it to 7 once every two years'but we thought it was important to have 8 in the program to have an independent look.at the routine
'9 inspections we're doing in the baseline by individual
'10 inspectors and to also have an across-the-board look at how 11 they are identifying and resolving problems, but I did want 12 -to point out to you that that was the point of contention on 13 their part and I believe they'still have that view even 14 though they support the concepts in the program.
15- If there aren't any more questions I am going to 16 get off the line. We have an enforcement conference we're 17 going to start. 18 MR. GILLESPIE: That is risk-informed --
- 19. MR. MALLETT: And they are using risk information.
20 All right? 21 DR. BARTON: Any other questions of Bruce before 22- he signs off? Hearing none, thank you very much, Bruce. 23 MR. MALLETT: Thank you for letting me dc it by 24 videoconference so that was'very good. Thank you. 25 DR. POWERS: Mr. Chairman, I am now fighting with ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
55 f_s 1 another windmill, to the same success most people have ws 2 fighting with windmills. 3 Have we gone into.the details of Appendix H? 4 DR. APOSTOLAKIS: Yes. Not the details, the 5 overall structure, but we spent an hour on it. If you -- 6 DR. POWERS: I guess I need to understand a little 7 bit better the quality of the tools that have been used in 8 defining things in Appendix H and better to understand the 9' benchmarking that was done in Appendix I. 10 I think I understand the approach that was adopted 11 in H, and I will confess to being confused a little bit over 12 Appendix I. . 13 Within H, I need to understand you utilized the (~g 14 Sapphire Code plus some PRAs that were suPmitted by the 15 licensees or by NEI provided them to you? 16' MR. BARANOWSKY: We used the Sapphire Code with 17 PRAs that we obtained from licensees. There were 18 approximately 13 of them that we used. 19 DR. POWERS: And these PRAs were in some sense
;20 certified for this particular application?
21 MR. BARANOWSKY: They were not certified. They 22 had been reviewed as part of the IPE process. 23 DR. POWERS': And what we know about the reviews 24 that are done in the IPE process is that they serve 25 ' adequately the objectives of the generic letter that A <b' ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C-. 20036 (202) 842-0034
, .n 56 1 initiated the IPE process, but in no sense are they what I (3
() _ 2 would call a technical review of how well the IPE or the PRA 3 reflects the plant, how good the database is, how complete 4 the scenarios considered are. 5 MR. BARANOWSKY: Yes. We weren't really trying to 6 do a plant-specific assessment. What we were trying to do 7 was get some representative models and our belief is that 8 the results from the models and the IPEs when one looks at j 9 the broad insights are reasonably correct in terms of what 10 is important and the kind of levels of core damage frequency 11 that one sees. 1 12 In fact, if we look at the results of the action 13 sequence precursor program, we see approximately the same 1
-s 14 order of magnitude core damage frequency comparability l
/ \ ! 'vs/ 15 between that progr'am and what the IPEs give us and most of 16 the important sequences are of similar characteristics but 17 details do different and there are a few different ones, so 18 our feeling was that in terms of orders of magnitude we have 19 got a spectrum of plant designs with PRAs that have at least 20 been looked over somewhat. They don't have obvious flaws in 21 them and therefore they would be reasonable models to 22 perform sensitivity analyses to understand how some of these 23 parameters' variation would affect risk calculations. 24 DR. POWERS: At least when I look at the IPE 25 insights program, I see an order-of-magnitude difference
,~
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1 57
.1 .between plants of nominally the same type. So you've got an hs,) 2 order of magnitude -- uncertainty band? I don't know what 3 you call it in this. I 4 MR. BARANOWSKY: Yes.
5 DR. POWERS: This context. Derived from a tool 6 that may or may not be qualified for this kind of job. 7 MR. BARANOWSKY: Yes. I think the reasca that 8 it's a reasonable tool is because of the way that we used 9 it. We didn't take any one plant. What we did was we ran a 10 bunch of these calculations and then we sort of enveloped 11 them. And we have no reason to believe that the IPEs 12 grossly and in a biased manner underpredict the likelihood 13 of core damage for this type of a calculation, but that in 14' 'some cases they're a little high and in some cases they're a I , d' 15 little low. And in fact most of the work that. we've done in ! l 16 AEOD taking actual operating experience and comparing it to l
\
17 'IPEs shows that about 90 to 95 percent of them have pretty 18 reasonable values when it comes to initiating event ! l 19 frequencies and system reliabilities, and that there are a
.20 few that are unexplained as to why they are higher or lower l 21 than what we would get from looking at some of the more i 22- . direct indications from the operating experience.
23 So it's our belief that taking a set of'these, 24 running the sensitivities, and more or less enveloping the 25 results probably is. conservative for this cut at setting i g'r i,
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7 58 1 thresholds. Moreover, I think the level of risk that we're
/^\
() , 2 talking about looking at is, you know, rather low. We're 3 talking about changes in core damage frequency of 10 to the 4 minus 5, 10 to the minus 6, for which there's not a 5 significant public risk associated with it, and that one 6 doesn't need to be precise in calculating these things 7 because we're not using it in that manner. We're trying to 8 get into the ballpark of what we think is an area of 9 increasing risk as we move through the different thresholds 10 and performance bands. 11 DR. POWERS: Someone might ask that given the 12 uncertainties that are associated with risk estimates, is a 13 differential of 10 to the minus 5 in core damage frequency 14- detectable? That is, maybe you're looking at just noise.
<x .^
(N -) 15 MR. BARANOWSKY: It probably realistically is the 16 noise, but it is something that one can calculate. Just j 1 17 like one can sit down and deterministically say a piece of j 18 equipment doesn't meet a certain regulatory rule, that 19 probably is well within the noise also with regard to 20 whether the plant is safe or unsafe. So I'm not sure that 21 there's any difference there. The point is that we are able l 22 to identify plant performance characteristics that seem to l 23 show increases of these small magnitudes, and it's the best 24 tool that we have available for identifying where we should i 25 be focusing our look. l r~s i
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1-59 fs 1 DR. POWERS: Can I ask you about the status of 2 what, validation verification, peer review of the Saphire 3 code? 4 MR. BARANOWSKY: Yes, I guess I'd have to ask 5 someone from the Office of Research to give you an 6 up-to-date statement on that, but my understanding is that 7 that code has been pretty well developed, reviewed, and 8 validated by the Office of Research over about 15 or so
- 9. years at least. I don't know that anyone here is familiar 10 with that. I'm looking around the audience. I don't know 11 if John is --
12 DR. POWERS: What I know is that the Office of 13 Research has in many cases subjected codes that they have g_ 14 sponsored the development of to what I think is a rigorous (/. (- 15 and outstanding peer review process, very disciplined, very 1 i 16- structured, published reports, and allowed deve' lopers of 17 those. codes to respond to the peer review comments and 18 responses from the commenters. But I am not familiar with l l 19 such a review for the Saphire code. That doesn't mean it 20 hasn't been done. I'm just not familiar with it. , 21 MR. FLOOD: This is John Flood from the Office of 22 Research. We'll have to get back to you on that, Dana, 23 DR. POWERS: I wish you would, because I think ! 24 this is crucial that'the Office of Research in developing j 25 its PRA tools has tools that the rest of the Agency can put ic t - s- - ANN RILEY & ASSOCIATES, LTD. Court Reporters L 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 L (202) 842-0034 i j .'
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60 l p_ 1 an enormous amount of confidence in. Whereas they can have
\s...) 2 their doubts and qualms about IPE PRAs, they should not have l 3 any doubts about the capabilities and limitations of their 4 in-house tools.
1 5 MR. BARANOWSKY: By the way, I would like to point 6 out that most of the doubts and questions about IPEG have 7 very little to do with the specific computer code that was ) 1 8 used. They usually have to do with the assumptions and i 9 completeness of the model and the tools generally give 1 10 pretty similar results, and that's the way a lot of them I 11 have been tested out, by benchmarking against each other. 12 DR. POWERS: If you could give me a ten-minute l 13 guide on how I should reread Appendix I to understand what's 14 been done, I would appreciate it, because I have to admit -- l .\-- g-]3 15 DR. APOSTOLAKIS: Well, let me ask, what's the 16 process here, Mr. Chairman? We seem to have demolished the 17 presentation. 18 MR. GILLESPIE: Well, no. 19 DR. BARTON: I don't think so. I was going to ask 20 Frank, where are you going from here, because we -- 21 DR APOSTOLAKIS: We will come back to -- 22 DR. BARTON: We've done some bantering back and 23 forth and trying to get Bruce's input before he to fall off. 24 I was going to ask Frank where does he see going next, we 25 take a break now, or you get into this. (. O). ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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1 l 6
'1 1 DR. APOSTOLAKIS: Because I had some comments
' h#'T bs/ 2- myself, and I don't know when to raise them, i 3 MR. GILLESPIE: No, right now what we'd like to do 4 is continue the questioning on performance indicators in the ' 5 , oversight structure, and then move on to Mike and the 6 .. assessment process.
- 7. DR. APOSTOLAKIS: Okay.
8 DR. BARTON: Why don't we finish that, and then [ 1 9 before we move on to Mike, we'll take the break. 10 MR. BARANOWSKY: Okay. Well, I mean, the 11 questions.-- i
-12 DR. BARTON: Any other questions about performance 13 indicators?. i i
14 MR. BARANOWSKY: In this area? h# L15' ' DR. BARTON: Do we have any other questions of Pat 16 at -- 17 DR. APOSTOLAKIS: I cannot.ask any questions. 18 DR. BARTON: Okay. I 19 'MR. GILLESPIE: I was thinking you were going to 20 continue on, Dana, beyond -- the. question you've asked also 21 applies, and in fact'the Commission asked -- David Lochbaum j L22 asked it -- relative to the stuff Bruce was doing. I'm
'. 2 3 sorry'we don't have Bruce in line, but we've got John Fleck 24 .here. 'And-that'was how did you pick the inspectable areas' 4 25 to be risk-informed given you had-to average across PRAs if N
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< , .. )
62 r~% 1- similar plants could come up with different analysts with (_,) 2 different results. 3 And John, there was kind of a process of averaging , 4 -- it's kind of gross, but we did this -- on two plants and 5 less than all of them for picking sequences that led to 6 areas, and could you just in a few minutes -- 7 MR. FLECK: Yes, I'm John Fleck from the Office of 8 Research. We looked across IPE the top ten sequences across 9 plants to draw insights and put those into a matrix called 10 RIM 2. Basically it was to pull out the information that 11 ' drives risk out there onto the table, so when we are 12 choosing inspectable areas we could somehow link the area to 13 those risk insights.
,ss 14 So we did that -- the insights were generated, as t
\~-) 15 Frank said, using 1PE information that we brought-in house 16 through the IPE data base by scanning across the sequence,
'17 the dominant sequences at all plants, and the insights ;
i 18 contained in NUREG-1560. And the process more or less 19 ' evolved around - -there was about five of us involved in 20 looking at the inspectable areas and weighing it with that 21 information in the IPE as well as basic information like how 22 much effort would it take even just to go look at that 23 particular area. So there's.always some minimal amount of 24: time that you'd have to spend on it. And that's where we 1 25 came down from 150-some-odd areas to something like 26 in l (h,) - ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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'i 63 1 the reactor safety area.
O 2 T%-)- Does that address the question, Frank? 3 MR. GILLESPIE: Yas. Basically what he's , 4 describing is kind of an averaging process that went across .
.5 the PWR designs, which meant if a sequence showed up in the 6 top -- ;
7 MR. FLACK: Top ten. I j 8 MR. GILLESPIE: Top ten at at least two 9' facilities. There was more detail to it. At a couple of 10 facilities, didn't have to show up anyplace, then it got to } 11 influence an inspectable area, which means the inspectable 12 areas at one plant might be from a sister plant of similar 13 design where a different analyst found something more
~g 14 important. So it's kind of a generic averaging is kind of s 15 how I put it in my lexicon.
'16 Now the next step is when you apply those insights
-17 to plant-specific, and this is a step where I'm trying to 18- develop in the next phase, is the areas are defined, there 19 will be a minimum look at these areas, now customize your 20 look to the specific sequences from that facility.
21 And it's.the kind of a process of attempting, if
-22 -you would, in a gross sense, to take the best of the average 23- and say here is the areas you need to look at, but when you 24 pick your' specific sample, you'need to look at your specific 25 plant and make sure you have hit your most significant (3
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l I l 64 l
-1 sequences at that plant.
k 2 It is not a perfect system because we didn't have 3 perfect IPEs and PRAs, but it was a way of trying to deal ) 4 with the strengths of the PRAs and the weaknesses in a 5 process way. And the research reports are in draft form. 6 They are kind of.in for final comment'right now. 7 MR. FLACK: Yeah, we have got them for out for 8 comment. We should be able to finalize, certainly, within 9 the next two weeks. l' 10 MR. GILLESPIE: But the next step is, now, how do 11 you go from the generic averaging to the specific , l 12 application and not lose your generic insights, but, yet, do 13 some successful ~ customization, as you pick your sample, to
,_ 14 the high probability sequences at that facility, or high ;
1' (/ 15' risk sequences? It is a challenge. And we are dealing in 16 gross levels. This isn't a highly -- a high fidelity system l 17 we are in. l l 18 DR. POWERS: Is this an exercise undertaken with a 19 pad and paper or undertaken with computer? 20 MR. FLACK: The exercise of gleaning out the 21 insights was done basically by -- 22 DR. POWERS: No, I am talking about the step from 23 going -- you have got these generic inspectable areas. l 24 MR. FLACK: Pad and paper. 25 DR. POWERS: And now you want to customize it. Is
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,_ 1 it -- is that reasonable to have it as a pad and paper
(/ 2 . exercise, or should there be other kinds of tools in the 3 hands of the people to do this the way you envision? 4 MR. GILLESPIE: Again, in kind of the macro sense 5 that we are dealing in, pad and. paper, given we have nailed ; 6 it down, we have kind of boiled it down to a matrix kind of : 7 approach, and then you can go to the specific facility and 8' we know to the best we know the dominant sequences at those 9 facilities. It is now a matter of saying, what systems are l 10 predominant? And if I have to look in the mechanical area 11 in a mitigation system, what is the system I want to be sure ) 12- at my facility will stop a sequence? What is -- and those i 13 risk important things are all really available for that most i f- 14 part right at the site.
# 15 So making that match in pad and paper, I am not 16 sure I would computerize it. That is a subjective match of
.17 . kind of the generic stuff that, if you would, that we have l
l 18 put together and the site-specific PRA results.
.19 Right now we are not thinking about putting any 20 kind of fancy algorithm together to try to do it other than h 21 do it. .We also have to focus on the people doing it. The 22 people doing it are likely going to be the senior resident 23 inspector and the resident staff, with some assistance from l
- l. 24 .the SRA. And you are looking at about 20 sites per region,.
25 and a lot of up-front planning to do this right. - (- ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
m.-.. . . _ . . ~ . . .. . -~. . 66 ; i
- l' So if an SRA spends -- if the senior resident
) 2 . spends about a week, and of that week, he gets a day of the 3 SRA's time.to overview his' recommendations and results, that h
~;
is.probably in the ballpark of the expertise that is likely l I 5 to be on most facilities. So that can't complicate it too j
- 6 much. It'has got to be very user-friendly.
{ 7 Again, not to say in the future we won't try to
- 8. computerize it, but to get something done this year, this is 9 the best we conceptually could approach it with.
10 DR. POWERS: i was certainly not thinking about 11 this year, I was thinking -- 12 MR. GILLESPIE: Okay. ! 13 DR. POWERS: -- ten years from now.' 14 MR. GILLESPIE: Yeah. I think, again, then you 7
~\ ;
15 are to the point of probably having site-specific profiles. 16 And the degree of sophistication ten years from now, and l 17 someone will have settled the fidelity of the PRA question, j 18 I hope, by then. We will either have an ANSI standard or f 19 someone will have a standard that these will be measured 20 against, and then we can move forward. Lacking that, this 21- is the approach we have taken to do it. 22 MR. FLACK: There is one other thing, what we have 23 raised, we have discussed -- we are discussing with Frank,
- 24 - is developing these generic matrices to make them 25 plant-specific. So, it would be a matter of going to the !
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67 1 site'and finding'out what additional sequences would have to
,O b s/ 2- be considered and trying to fold that into a matrix form for 3 each site, so each site would have its own risk set of 1
4 insights that then would be updated and used by the 5 inspector, but these are just things we are entertaining at ,
'6 this time. I i
7 DR. POWERS: I think there is no question that j l 8 that will be one of the most interesting aspects of the
.9 pilot. How do we go from a generic kind of appendix that, 10 quite frankly, I don't understand right now, but that is my j 11 fault, to the specific activity will be real entertaining. I 12 MR. GILLESPIE: Yeah, because then you are going 13 Lfrom, as Bruce said, areas that contain multiple systems to
's 3 14 specific systems that are going to be sampled. And we also 1
~
15 view that as a significant challenge, because the directions ~ 16 on how to do that right now are lacking 17 .DR. BARTON: Frank, is this the time >to take a 18 break? Till 25 after and then we will hear from Michael. 19 [ Recess.) j 20 DR. BARTON: I think we have got a quorum here, so
'i 21- we will get started. Michael,.you.are next, with the 22 assessment process. I don't know if there's any other 23 questions for Pat or not at this point, I don't think so.
24 MR. JOHNSON: Okay.
- 25. DR. BARTON: We will find out if he leaves, a
- (~'-
V ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025. Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i l 68 l :. 1- though. E g j 2 MR. JOHNSON: Okay, I just have a couple of brief l 3 slides to put up, and I don't want to -- or I hadn't i i E 4' intended to go over the entire assessment process. We did 5- that the last time we met with the ACRS. I just wanted to I
- 6- remind us that the purpose of the assessment process is to l
\ l 7 assemble the information that we get, both from the PIs that 8 we are collecting and from the inspection, the risk-informed 9 baseline inspection, plus the additional inspection that we 10 Edo, assemble that information to arrive at conclusions
- 11 regarding plant performance and then, based on those I l
12 ' conclusions,-to. identify resultant regulatory actions and 13' then communicate the results of those, those actions, and 14 -the results of the assessment to the public. 1 l($~\ \ ,ka /- 15' And then', finally, we want to provide a means of L 16 follow-up such that we look at future performance, factor 17 .that into the assessment process and make adjustments as 18 appropriate, based on whether the licensee is or is not 19 responding and addressing the problems that we see as being t-20 important.
.21 The second slide I will put up is this slide I 22' will call key concepts. I just wanted to remind us that the
- 23 process is based on thresholds. We have done a lot of g
L 24 talking this morning about thresholds for the PIs. Also,
- 25. keep in mind that we will have thresholds -- a means to i
lt )- ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I l 69 l
,_s 1 evaluate the significance of findings from the inspection
( ) '\' - 2 program and thresholds associated with that in each of the 3 cornerstone areas. And it is those thresholds that really 4 drive us, or put us in the position where we consider ; 5 additional action beyond allowing just the licensee to take 6 action based on their performance. So it is very much I 7 driven by thresholds. 8 The assessment process considers the performance 9 for a 12-month rolling window. That is not new, we have 10 been talking about that for a while. It is a rolling 11 12-month period of time that we are looking at, PIs being 12 provided each quarter, and the inspection results will come 13 in as we accomplish inspections. r^g 14 The assessment process provides a graded approach. I \
\. / I 15 One of the things that is in Attachment 4 is something I 16 called an action matrix. And in looking at that matrix 17 then, and with the PI results and the inspection results, we i 1
18 have a graded way of looking at what we communicate to the i 19 licensee baned on performance, the actions that we take, 20 whether we do inspection, so and so forth. All of our 1 1 21 actions, our management involvement are graded such that l i 22 plants who perform better get, if you will, the minimal l l 23 level of engagement by the NRC. Plants who perform -- whose l
)
24 performance crosses multiple thresholds get a greater degree 25 of involvement by the NRC. I n
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70 l I 1 The assessment process eliminates use of the watch i
, 2 list and superior performer recognition. That was one of 3 the things that even the IRAP concept proposed, and we '
4 thought it was important then, and we think it is still i 5 important that we do'away with things like superior
- 6 performer recognition and the watch list, we don't think i 7 they serve a purpose. .
8 And, finally, one of the things that we needed to l- ! 9 do with the assessment. process was look at plants that are
' 10 ' 'in an extended shutdown. Extended shutdown has an impact on i 11 the PIs,-as you are well aware, and the inspections, the l 12 additional inspections that we do, we think it is necessary
.13 to do, with this assessment process that we are proposing, ,
34 exactly what we did today, and that is to set those plants-15: aside for this assessment process. 16 And we rely on the Inspection Manual Chapter 0350 17 process that~has restart approval requirements for us in 18 terms of what we will look.at to decide whether a plant is 19 ready to restart, and we will make some logical decision 20 about when that plant should rejoin-the assessment process 21 following their restart at the end of that extended shutdown 22 period. i 23. E n Let me just put up very briefly the action matrix. 24 I mentioned this in terms of talking about the fact that the L 25 assessment process provides for sort of a graded range of ANN RILEY & ASSOCIATES, LTD. Court Reporters
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I l 71 l P 1 actions. If you will look across the top, that gives you k-s 2 the results from anything from a plant that would receive 3 --would not cross any threshold, any PI threshold, or any ) 4 inspection threshold, all the way across to plants who have 5 crossed multiple thresholds. And then if you look down the 6' left column, we talk about management meetings, the things 7' that'we do in terms of response, management meetings, 8 licensee actions, NRC inspection and regulatory actions, and 9 also the communication. And so, for example, if you look in 10 the left column, you can see that a plant that hasn't 4 11 crossed any threshold, a plant with all the indicators and 12 'all the inspections in the green band, simply receives a i 13 risk-informed baseline inspection program. And, again, as y a 14 you move to the right, the responses becomes graded in
\#' 15 significance, increasing significance. :
16 Let me mention one last thing, and I will shut up 17 and take whatever questions you have. There's -- l 18 DR. APOSTOLAKIS: Mike. I i 19 MR. JOHNSON: Yes, sir. l 20 DR. APOSTOLAKIS: Would you put that back on? 21 MR. JOHNSON: Okay. 22 DR. APOSTOLAKIS: Where can I find it here? Where 23- is it, do you remember? 24 DR. WALLIS: Twenty-five. 25 DR. APOSTOLAKIS: Twenty-five. g- g I ,- Q ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
' Washington, D.C. 20036 j (202).842-0034
_ . . _ . . _ __ . _ . _ . _ . . _ . _ _ _ _ - . _ . _ _ _ _ _ . . . - _ . , , ._ _ . . . _ . ~ _ _ _ __ 72 4 : - g g. 1 DR..WALLIS: In the handout. (_s} 2 DR. APOSTOLAKIS: No , I know. I 3 MR. JOHNSON: It's Attachment 4. i
'4 DR. BARTON: Attachment 4, George. Attachment 4, 5 page 19, I think.
l 6 DR. APOSTOLAKIS: Well, page 9 of the -- l 1
- 7. MR. JOHNSON: And page 9 of Attachment 1.
8 DR. APOSTOLAKIS: Attachment 1. Page 9 of 9 Attachment 1. I am wondering, under Roman II there, one or ) 10 two inputs white, but the cornerstone objective is fully l l 11 met. Why' don't we move the regulatory action of the j 12 commenting response and make it a licensee action, and we do
]
13 nothing? And I am not even sure that the SRI or the branch
,r- 14 chief should meet with the licensee.
-- 15 MR. JOHNSON: I think the answer to your question 16 is, when we cross a threshold, and that is what we are 17 talking.about in'that second column, we would do some 18 follow-up inspection in'that area, whether it is a PI or 19 whether it an inspectable area from the risk-informed 20 baseline inspection program.
21- And so when we talk about documenting the response 22 in the graded area and in the inspection report, what we are 23- talking about is just making sure that that inspection 24 -report captures what the inspector has found in that 25- additional' inspection that follows up in that area. We
'(_)
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1 l 73 l 1 would do that. It is sort of an obvious outcome of that S l
\_ 1 2 inspection that you have done to address that fact that you l
3 have crossed that threshold. l l 4 DR. APOSTOLAKIS: Well, yeah, I understand that, 5 but I guess what I am saying is in the name of granting 6 relief, to both them and us, why don't we start getting 7 involved when one of the cornerstones is degraded? In other 8 vords, your third column, Roman III, you have one degraded j 9 cornerstone, so now the NRC is beginning to provide 10 increased oversight, you know, that kind of thing. It is 11 really a matter of policy, but I am just asking why we can 12 -- can we not do -- 13 MR. JOHNSON: Yes.
,f - 14 MR. GILLESPIE: You're right, George, it is a '-- 15 matter of where you set the thresholds, and how much margin 16 you are going to have from you get in a more interdictive 17 mode.
18 DR. APOSTOLAKIS: Right. 19 MR. GILLESPIE: And we have basically set the 20 threshold. In fact, if you look in Reg. Guide 1.174, there i 21 is a graph in there that looks very much like the graph Pat 22 uses but it is upside down. And we are, in essence -- we ! 23 are, in essence, adapting those same thresholds. The bottom l 24 band or the least risk significant band in that Reg. Guide, 25 where things would be turned over to licensees, is very i /~N l ( ,) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 l t
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74
- 1 consistent with the description of what we have got in the t
4 ( ). 2 licensee response zone, or the green band. And so what we { 3 did was try notsto invent new policy, but adapted that l i I 4 perspective. 5 DR APOSTOLAKIS: Yes, but in that guide, though,
.6 they_are dealing with core damage frequency in there.
-7 MR. GILLESPIE: Yes. And -- l 1
8 DR. APOSTOLAKIS: Here, you are talking about not 9 even a cornerstone being degraded. { 10 MR. BARANOWSKY: But the thresholds were based on 11 risk insights that put tus into a core damage frequency level 12
- of risk comparable to that in Reg. Guide 1.174, where the NRC would provide review and approval of changes in licensee i
13 14 design and operational features, so -- ("'\ Am / 15 DR. APOSTOLAKIS: Wait a minute. I mean you can l 16 have -- 17 MR. BARANOWSKY: That is what the white zone is 18' meant to capture. 19 DR. APOSTOLAKIS: Yenh, but you mean you can have 20 one or two inputs white, when,-in fact, the cornerstone 21 objectives are fully met, and see a difference in CDF? I 22 MR. BARANOWSKY: No , the -- well, yes.
'23 DR.~APOSTOLAKIS: Really? ;
l i 24 MR. BARANOWSKY: Well, I mean you can calculate 1 l 25 the difference in CDF, it is small. I mean, for instance, j i b>\- ANN RILEY &-ASSOCIATES, LTD. Court Reporters 1025 Connecticut' Avenue, NW, Suite 1014
, -Washington, D.C. 20036 (202) 842-0034 l !
l l
l l l 75 ) ( 1 in Reg. Guide 1.174, it says the licensees can make () 2 permanent changes to their plant with a CDF change of up to l l p 3 about 10 to the minus 5. And the white band of this i 4 performance model includes core damage frequency changes up 5 to 10 to the minus 5, so it is meant to be consistent with 6 Reg. Guide 1.174, where there is regulatory oversight of 1 1 7 risk-informed applications that occur with changes up to 10 8 to the minus 5. l 9 The same thing over here, when you cross any one 10 threshold, the implications are comparable to being in that 1 11 kind of a situation with regard to changes or increases in i 1 l 12 risk. { ! 13 DR. APOSTOLAKIS: Well, I would expect that if the 14 cornerstone objectives are fully met, even if one or two l 15 inputs are white, you wouldn't see much -- 11 6 MR. BARANOWSKY: Well, you are not going to see 17 much. 18 DR. APOSTOLAKIS: Unless the plant was already one L19 of the great performers, way below the threshold, so by 20 increasing it a little bit, you know, -- 21 MR. BARANOWSKY: This isn't a regulatory hammer.
.22 -This is really just the beginning of taking a look so that
- 23. we don't have things go from everything is all right to shut 24 them'down the next day. This way the licensee sees it'
'25 coming. ;
E ; l I j"'y ANN RILEY & ASSOCIATES, LTD. .g l'j . Court Reporters i 1025. Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202).842-0034
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76 1- DR. APOSTOLAKIS: Right.
/3 k ,)
2 MR. BARANOWSKY: There is plenty of warning. The 3 NRC sees it coming. And, in theory, it is a very modest 4 regulatory engagement at that point. 5 MR. JOHNSON: Yeah, and it is very much -- it is 6 very much philosophical. The notion was if the system is 7 set up on cornerstones, you don't wait till you have got a 8 degraded cornerstone before you engdge. You engage at a 9 point where you are seeing some degradation, but not 10 degradation significant enough to take dowr. the cornerstone, 11 if you will. 12 DR. APOSTOLAKIS: Yes, but if you look at 3, it 13 says cornerstone objectives met with minimal reduction in j 14 safety margin. So'it is not that, you know, the next 'ksl: m .:U5 category is something that already is pretty bad. You are 16 still meeting the objectives even in Roman III. 17 MR. JOHNSON: Right, but we are talking about -- 18 DR. APOSTOLAKIS: What I am caying is doing 19- nothing in the first two columns except being informed and 20 then start doing things 3 and above. 1 21 MR. BARANOWSKY: Not meeting a cornerstone l 22 objective is considered pretty significant, it is not the ; 23 beginning of engagement for us. I mean that is the 1 L 24 equivalent of saying I don't have any defense-in-depth or i l-25 something like that. l h( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
77 1 DR. APOSTOLAKIS: No , but you are still meeting O ( ,) 2 it, though. Cornerstone objectives met.
'3 MR. BARANOWSKY: No, I understand that.
4 DR. BARTON: Yes. 5 MR. BARANOWSKY: But if we wait until we get to i 6- the point where things are really broken, that is one of the 7 concerns that was raised about not having leading indicators 8 in the current process in which one day the plant is 9- operating, the next day we go there and we say, oops, we 10 have to shut you down because this is really broken badly. 11' We are trying to have a process here that slowly steps into 12 a recognition of declining performance so that there is 13 plenty of opportunity to turn that around before we ever get 14 to these level 4 or 5 conditions. I mean we never want to !,_\ V '15 get there. 16 DR.'APOSTOLAKIS: I know, 4 and 5, I agree. 17 MR. GILLESPIE: Remember, this is an indication 18 system, and the severity or the pervasiveness of the root l i 19 cause to the reason the indication has tripped a threshold 20 is really the question, once you trip a threshold. And, in 21 fact, NEI's proposal, which we have spun off of here, 22 up-front said-if you meet all the PIs that are proposed, 23 that should be evidence that your corrective action problem 24 identification system is working. If you trip a threshold,
~25 there is at least some essence of evidence that your problem
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.(202) 842-0034
I l 78 1- . identification corrective action system isn't working. That I) 2L is.all we have got. We have got some evidence that problem 3 identification corrective action isn't working. Now, when
.4 we get more diagnostic,-the question is, how pervasive is it or isn't it? This is an indication where we ask that 6 question.
7 So that is kind of one of the: fundamental premises 1 8 that even the industry proposed, actually, similar levels. 9 If you remember, they proposed three scrams and we kind of 10 verified that that looked good to us on the same basis. So l 11 that is how we are coming at it. i-
)
12 Could the root cause -- are we good enough to have 13 created the perfect system? No. So'that is how the 14~ thresholds were set, and that is the intent of the O)
\- 15 indication. The primary indication is there is a problem l 16 with problem correction and identification of problems.
17 MR. JOHNSON: There is one other thought I ought l 18 to mention, too, George, and it is in Attachment 4, and it 19 mentions the fact that when we go to apply this action 4 20 matrix, one of the first things we would do is to consider 21 what the licensee has already done. 22 So, for example, if you -- let's suppose you have l 22 one or two of these areas where the' licensee has crossed the 24 threshold. The first thing you would do is to look to see 25 if the licensee had taken some actin to do some diagnostics, ig~ *NN RILEY & ASSOCIATES, LTD. A Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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l 79 1 had taken some action to address the problert, and that would O
- (_s/ 2 further_ temper what we would do in terms of the follow-up inspection that we would plan. So, we really see this l_ 4 second column as one that is really a very measured 5 response, but necessary as licensees begin to cross these 6 individual thresholds associated with PIs and inspections. P 7' DR. APOSTOLAKIS: But look at the first column.
8- All assessment inputs are green, and there is licensee
- 9. action, licensee corrective action. To correct what?
10 MR. JOHNSON: Well, that simply says if-the t l 11 licensee is in the green band, all of these indicators are 12 in the green band, where the inspection would find issues, , 13 we would simply put those issues in the licensee's 14 corrective action program and the licensee would address , :t
.\ 150 .them in'accordance with that whatever prioritization scheme ,
a 16 they set up, because the licensee has a good success at L 17 doing that. This is the routine-dealing with issues as they. l 18 arise. 19 DR. APOSTOLAKIS: So there will be issues even 20 though all assessment inputs are green? 21 DR. BARTON: Oh, yeah. L 22 MR. JOHNSON: Oh, sure. 23- DR. BARTON: The world is.not perfect, they are , 24: saying. There may be little blibets, but you are still 25 going to be green because you haven't crossed any threshold. l (_j ANN RILEY & ASSOCIATES, LTD.
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80 1 DR. APOSTOLAKIS: Like what issues? ex ,a) 2 DR. BARTON: I don't know, give us an example of 3 where it could be. 4 MR. GILLESPIE: Tag-out problems. 5 DR. BARTON: All right. Equipment tag-out. 6 MR. GILLESPIE: Equipment tag-out. 7 DR. BARTON: There you go. 8 MR. GILLESPIE: Not safety significant, didn't 9 compromise the system. Inspector sees it, it is a 10 requirement. 11 DR. APOSTOLAKIS: But that is my point, though. 12 Why should you worry about it if all the assessment inputs 13 are green? 14 MR. JOHNSON: And that is our comment is we don't (x (_,/ 15 worry about it. That is left to the licensee. 16 DR. APOSTOLAKIS: But why would you even notice? 17 Why would you even bother to look at it? 18 MR. BARANOWSKY: Because you don't know, until you
~19 get all the facts together, whether or not the facts 20 indicate there is a problem. You can't go and say there is 21 no problem so I won't look for facts. Your job is to go get 22 the facts and then see if they indicate that you should have 23 a more aggressive examination or follow-up activity. So the 24 first step is getting the information, that is all in the 25 green is about. Baseline inspection program to get baseline f)
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81 1 information. Performance indicators, inspections. (_,) 2 DR. APOSTOLAKIS: Wait a minute. All the 3 assessment inputs are green, everything. All the 4 indicators, the areas, right? 5 MR. BARANOWSKY: Right. 6 DR. APOSTOLAKIS: There is nothing to correct. 7 MR. JOHNSON: No, that's not true. 8 MR. BARANOWSKY: The NRC won't be taken a 9 corrective action. 10 DR. BARTON: But the licensee has some actions. 11 MR. BARANOWSKY: The licensee, when they find 12 tag-out problems, will be taking a corrective action. The 13 theory is if you let the little things go, they become
-s 14 bigger, and then they become bigger, and then they become kJ 15 bigger.
16 DR. SEALE: Indeed, one of the concerns is that by 17 the time they reach -- things reach the level of recognition 18 on the NRC's screen, you may already be on a slippery slope 19 that may be very difficult to turn around. It is my 20 understanding that INPO is looking at indicators at a much 21 more sensitive level, as many as a hundred per plant in some 22 cases, and that they would hope that using those indicators, 23 the licensees themselves, with INPO's help, would be able to 24 anticipate things so that you never let any -- nothing you 25 ever saw got out of the green.
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82 1 MR. BARANOWSKY: Yes. ( (m,/ 2 MR. GILLESPIE: There's actually -- there's INPO 3 -- WANO and INPO are kind of one in this -- and WANO's had a 4 lot of input into an IAEA dccument which is currently 5 circulating in draft -- I don't believe it's available for 6 the public -- which takes the next step that we've said we 7 wouldn't take. Not only is it indicators from the facility, 8 but it talks about safety culture -- 9 DR. SEALE: Yes. 10 MR. GILLESPIE: And it talks about indicators of 11 management. So there is internationally and nationally the 12 industry's themselves looking at it. The IAEA document is a 13 document for station personnel, and specifically in the 7~ 14 front of it it says this is not intended for the regulator. 15 DR. SEALE: Yes. Yes. 16 MR. GILLESPIE: So there is that activity. 17 DR. SEALE: Yes, but it does address these -- 18 MR. GILLESPIE: Yes. 19 DR. SEALE: These culture-r61cced concerns that 20 we've raised in the past in some of our discussions. 21 DR. APOSTOLAKIS: Well, again, it's okay for INPO 22 and the industry to do things like that. When we do 23 something, I mean, we have to be a bit more careful. And -- 24 let me put it in a different way. I get the impression that 25 we are changing, you know, it is risk-informed and so on, A () ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l
____m . 83 1 but we still -- we don't want to let go, in other words. We (s, i 2 still want to get involved in detail. 3 A bolder approach might be to say regulatory 4 actions, none in the first column, none in the second. Just 5 be informed of what's going on, and then start worrying 6 about it at 3. And if they have tagging problems, it's 7 their problem, you know. We don't get involved in these 8 things. 9 MR. GILLESPIE: Well, I think, you know, we've 10 kind of got -- now we're stuck in the compromise position 11 we're in. We have a set of regulations and requirements 12 currently out there. An inspector walks through the plant, 13 and while he's looking at risk-significant systems and
,-s, i
14 risk-significant spaces, and he's looking for safety ( ' \/ 15 problems, he sees that tags are mistagged and valves are 16 mislocked. It doesn't rise to being -- it doesn't negate a 17 system, doesn't negate a train, doesn't maybe rise to that 18 level. Does he walk away and ignore that and not tell 19 anybody? That's what you're suggesting, George? We can't 20 tolerate that. He has to document it. 21 Now how we dispose of it becomes the question. 22 And what we're suggesting here as the disposition is it gets 23 turned over almost as if he was a QA inspector and walking 24 through the same space, he gets integrated into the licensee 25 system. Now we're trying not to put undue pressure or undo (O) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
84 1 priority on it, and'in fact gets in their system and gets l (% ' iA__) 2' fixed in accordance with whatever priority system they're 3 using, p 4 DR. BARTON: It's level 4. 5 MR. GILLESPIE: It's like the level 4 policy 6 statement going through now. 7 DR. BARTON: Right. 8 MR. GILLESPIE: I mean, that's the approach. The 9 second column'on this, the darn senior resident lives at the 10 ' site. Him finding, asking, you know, why did you bust this 11 threshold, when he's already there, doesn't -- is kind of a 12 real measured response. I mean, I would be hard pressed to 13 have someone bust a threshold and have one of the two 14 residents we've got at the site say I'm not going to ask.
~
p-
%s 15 So it's a real measured response. It's kind of proportional 16 to the idea of busting one threshold, 17 You have your resident at his normal weekly 18 meeting and they generally, although they're at six-week 19 reports, they generally have kind of a debriefing weekly, 20 and what their findings are says hey, you know, your 21 ' quarterly report showed this. What's going on here? It 22 seems like a very measured response. Could it be none? I 23 don't know how we'd administer none and tell a resident not
'24 to ask that question.
25: DR. MILLER: These responses you judge are l I Lp y ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington,.D.C. 20036 (202) 842-0034
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i l 85 1 minimal.
; g)(, , 2- MR. GILLESPIE: Yes. Oh, yes, column 2 is very
'3 minimal. i i
l 4 DR. MILLER: I don't know how you'd define it, but j 5 -- l 1 6 MR. GILLESPIE: It is, i i 71 DR. . MILLER: They would just be routine, the 1 8 . senior residents walking around or the residents.
. 9' MR. GILLESPIE: Right.
10 DR. MILLER: And we need to document it, because 11 it does -- 12 MR. GILLESPIE: Yes. 13 DR. MILLER: Break the written rule, but it has no i 14 effect'on risk. ! ' /^'g
) 2 15- MR. GILLESPIE: Right.
- 16. DR. SEALE: You're letting the licensee know that l 17 the inspector is not brain-dead. I i
18 MR. GILLESPIE: Right'. The other thing is you're l 19 letting the public know that we're still looking. Now we've ; 20 got another audience. It isn't just us and the licensees. 21 -And, you know, one could say well, the inspectors won't 22 bother writing any inspection reports unless they found a 23 complete cornerstone completely degraded. And that's not 24 acceptable in the public nature of our business. 25 DR. MILLER: But the burden on the licensee in t
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l l 86 I 1 column 4 is probably equal if not somewhat less than it is
<^x l
, ) 2 today. Is that right or not?
3 MR. GILLESPIE: Yes. In fact, at the Commission 4 meeting -- yes, column 4 -- at the Commission meeting said 5 -- 6 DR. MILLER: Column 2; I'm sorry. l 7 MR. GILLESPIE: Oh , okay. I was going to say the 8 Commissioners actually commented on column 4 and 5. They 9 spent some time on this and said move the Commission over to l 10 column 4. That was their comment. So, yes. 1 11 DR. MILLER: But column 2 is less than it is l 12 today, or equal -- 13 MR. GILLESPIE: Oh, yes. I would expect that l
, 14 column 2 would just crossing one threshold where there's a I
[) x- 15 readily available' explanation would not be sending a 16 three-man team out to investigate it. The first thing is l l 17 the SRI, what's happening here. Do you have a reasonable l 18 explanation? If the answer is yes, he documents reasonable 19 explanation. The other nature of the public agency we are, 20 we're going to be publishing these PIs quarterly. We're 21 going to be -- it would be irresponsible to publish a PI 22 that shows a threshold crossed and have no text that said 23 here's what it was, and it appears to be okay. 24 DR. SEALE: I'm intrigued by that bottom row down 25 there where you have a differentiation or a dividing line
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'( ) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
.. 3 87 1 between regional and agency review. You've got a pilot
(/ 2 coming up. Will all of those pilots be in one region?
- 3. DR. BARTON: They could be in all regions.
4 MR. JOHNSON: No -- 5 DR. SEALE: One in each? , 6 MR. JOHNSON: Two pilot plants in eacu region. 7 DR. SEALE: Yes. Okay. Some in each region. 8 MR. JOHNSON: Eight. 9 MR. GILLESPIE: Eight pilots. 10 DR. SEALE: Some in each -- okay. It's going to 11 be very' interesting to see the degree to which unanimity of
- 12. what that means emerges from the different regions. And 13 that's going to be a job for you, I think.
14 WL GILLESPIE: Consistency -- O.l 15 DR ~. SEALE: Yes. 16 MR. GILLESPIE: Well, the starting point is we'll
-17 have something we don't have today. l 18 DR. SEALE: Sure. l 19 MR. GILLESPIE: We've at least got a first shot at 20' a scale. Now we can adjust the scale in effect. That's the 21- kind of comments we're expecting to get. But at least we 22- have a starting point to measure people against. One of the ;
i 23 major criticiums of the whole oversight assessment process
]
24 was we didn't write our criteria down up front, and so here 25 we're attempting to do that. .q
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I i 88 1 1 DR. SEALE: You may have heard that from us, too. (~< v). 2 MR. GILLESPIE: Yes. l 3 DR. APOSTOLAKIS: One of the things that still is I 4 not clear to me, Frank, and maybe you can clarify it, is i 5 okay, you go down and you do the inspection and the licensee '
-- the performance indicator on scrams is high, above the 6 ;
7 threshold. And.the licensee says-there is-nowhere in my 8 . license that says that'I.have to keep this below 3. I'm not 1 9 going to take any corrective action. It was nine from Day 10 1. Why are you asking me now to change it? What is the new 11 regulation that's forcing me to do this. And you say PRA.
-12 MR. GILLESPIE: No, we're not going to ask them to 13 change.
.14 DR. APOSTOLAKIS: Okay. You're not going to say i p .
L%) 15 PRA. > 16 MR. GILLESPIE: No. . l 17 DR. APOSTOLAKIS: What would you answer -- how f 18 would you answer? L '1 MR. GILLESPIE: 1 50 At that point we would end up l 20 doing additional inspection, since he's refused to do a l t- 21 root-cause analysis, and the inspection would likely be on 22 his root-cause analysis problem identification process,_and L 23 we would then leak that back to regulatory requirements. 24 MR. JOHNSON: Right. What caused the scrams. 25 MR. GILLESPIE: And if he's not violating any j ANN RILEY & ASSOCIATES, LTD.
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-, 1 regulatory requirements, then you're right.
\/ '2 DR. APOSTOLAKIS: That's right. That's what I'm 3_ 'saying.
4 MR. GILLESPIE: The nine scrams is an indication 5 we need to look further and tie that to what requirements 6 are either being violated or what new requirements are 7 needed. -We're not going to force him to meet the threshold. 8 But if anyone has nine scrams in a year -- 9 DR. APOSTOLAKIS: Let's say you find that no 10 regulatory. requirements are violated. 11 MR. GILLESPIE: Oh, we could find that, in a 12- difficult startup after a long shutdown. 13 DR. APOSTOLAKIS: What was the frequency of scrams ,rs 14 in the United States 15 years ago?
- 1) . 15 DR. BARTON: About nine.
i 16- MR. GILLESPIE: Yes, nine. ! 17 DR APOSTOLAKIS: Nine a year. 18 MR. GILLESPIE: Eight, nine a year, j l 19- DR. BARTON: That's in the ballpark. ! [ 20_ DR. APOSTOLAKIS: Once we're licensed, the guy 21~ says it was nine then, it's nine now. 22 _MR. BARANOWSKY: Yes, but we have both Appendix B i-4 23- and we have the maintenance rule, and both of those 24' ' regulatory; requirements force you to take corrective actions I 25- when your reliability or performance is not up to what's 1
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- 1 expected. In the maintenance rule we have some targets in
\_) 2. it for you to meet. 'And clearly this would be outside of 3- what would be called for in the maintenance rule, and 4 .certainly Appendix B has elements of quality in it that this 5 would challenge.
6 DR. APOSTOLAKIS: Are the targets of the 7 maintenance rule utility-selected?
- 8. MR.'BARANOWSKY: Yes.
9 DR. APOSTOLAKIS: Okay. 10- MR. BARANOWSKY: And I can tell you one thing, i 11' they're certainly less than nine. 12 DR. SEALE: Yes. I think there's another way to 13 look at this. Nine years -- or ten years ago we had nine g 14- scrams. Ten years ago we had the inspection system that
- 15. we're still living with today. When we don't have nine l 16- scrams a year, maybe it's time to take a look at the i
17' inspection system and bring it into more of -- well, in tune l ( 18 with what the practices are today. But you still use that ! 19- as the thing that opens the door to the kind of inspection 20- that11s more reminiscent of what you have today if somebody 21 does show up with nine scrams.
'22 DR.- APOSTOLAKIS: My fundamental problem is that 23 the basic regulations that people have to comply with are l.
24 not risk-informed. 25 DR. SEALE: True. l Q,j
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_-___.7 91 1 DR. APOSTOLAKIS: And the inspection oversight
\ 2 program is risk-informed, and nobody sees a possible !
3 conflict here?. 4 MR. GILLESPIE: No, we do. We do. In fact, we 5 highlighted that in the Commission paper as a conflict, 6 because we are right now out in front of the regulations. 7 DR. APOSTOLAKIS: Yes. 8 MR. GILLESPIE: Absolutely. 9 DR. APOSTOLAKIS: We are changing the way we 10 . oversee things. 11 MR. GILLESPIE: And -- 12 DR. APOSTOLAKIS: Without knowing why. 13 MR. GILLESPIE: No.
.fg 14 DR. APOSTOLAKIS: We have empirical knowledge --
( 3 15 DR. BARTON: So we shouldn't improve this process
- 16. --
17 MR. GILLESPIE: We know why we're changing, but -- 18 and that's the difficult part. The only step we can take 19 is, we can't enforce thresholds. Thresholds are an 20 indication as to when we go further. And then we're forced, 21 if you.would, into making a link of what is the requirement 22 that links'to the root cause. 23 MR. JOHNSON: We're forced to use the existing .. ,i.. L L -24 -regulatory -- 12 5 _ MR. .GILLESPIE: . Structure. I O _(,) - ANN RILEY & ASSOCIATES, LTD. Court Reporters L 1025 Connecticut Avenue, NW, Suite 1014-Washington, D.C. 20036 (202) 842-0034
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92 l
. 1 MR. JOHNSON: Structure to take action against the
{d = 2 licensee. 3 MR. GILLESPIE: I would love not to have to do 4 that, but that's where we are. That's our only option. 5 DR._KRESS: The link is that you're assuming that 6 you have a body of regulations there and you're assuming 7 that if a plant does meet all those regulations that are out 8 there, then it is more likely in the green zone? 1 9 MR. GILLESPIE: That's inherent in the assumption. ; 10 DR. KRESS: And so you've got indicators that you I 11 don't have.to go in and see if they meet all the 12 regulations, you just go look at these indicators. Now if 13 somebody gets out of them, your assumption is, well, more 14' than likely they don't meet some of these regulations, so 7-c-t , j 15 we'll go in and se'e. i l 16 MR. GILLESPIE: Right.
]
1 17 DR. KRESS: And you may find that they still meet 18 the regulations. 19 MR. GILLESPIE: That's true. 20 DR. KRESS: Or you may find that they don't. And I 21 your response is going to be depending on what you find by ] 22 that additional inspection. 23 DR. APOSTOLAKIS: What do you think the response 24 -- 25- DR. KRESS: So I think they're forced to go in and l l 7-( /^ ANN RILEY & ASSOCIATES, LTD. Court Reporters
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93 l 1 their response has to be well, dc they meet the regulations
/ s
(_) 2 or not? And maybe those regulations will change over time, 3 and so forth, but I think they're right in saying -- 4 DR. APOSTOLAKIS: What do you think the response 5 -- 6 DR. KRESS: That they're boxed in to saying meet 7 the regulations. I 8 DR. APOSTOLAKIS: What do you think the response 9 will be if they find that they meet the regulations but two 10 of the performance indicators are above the threshold? 11 DR. KRESS: That's a good question. That's where 12 the conflict's going to be. What do you do about that? I 13 think they have to backfit or --
,. 14 MR. GILLESPIE: No --
_-} 15 MR. BARANOWSKY: That's so highly unlikely, 16 because what we currently have today is performance that 17 would be well within the green band in which we still cite 18 licensees on Appendix B violations'. It's exactly the 19 opposite problem as the real world than you're postulating 20 right now occurring in the future. 21 DR. SEALE: There's also another response, and 22 that is-while they may be complying with what the
-23 regulations state, they're certainly not meeting the utility 24 peer group's aspirations for excellence, and the other 25 utilities are going to be all over them, because they have i [ ANN RILEY & ASSOCIATES, LTD.
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94 1 the same indicators, they're looking at them for the same r kinds of concerns, and nine is not a satisfactory way of 2 1 3 doing things in.their world where they think in terms of 1
.4 excellence and performance.
S' 'DR. MILLER: And that peer pressure by some is 6 perceived as being more of a hammer -- 7 DR. SEALE: That's right. 8 DR. MILLER: Than is the regulatory pressure. j 1 l 9 DR. APOSTOLAKIS: What kind of world are you guys 10 describing?. . Plato came again down here and I didn't realize 11 it. This is so platonic. This is the ideal world. You 12 know, you will be shamed and your peers will come and 13 correct you? Has that happened before? f 14. DR. SEALE: It's happened before. 15 MR. BARANOWSKY: Actually the PUCs are also i 16 important here. When the PUCs end up seeing something 17 happening, there's a question as to whether or not -- 18 .DR. SEALE: That's right. 19' MR. BARANOWSKY: There should'be changes in rates 20 and so forth. 21 MR. GILLESPIE: And all of that, we're still an p 22 independent regulatory agency, and we're setting our -- the 23 fact that our thresholds and our perspective is coincident 24 with some societal pressures is very nice in a system point
~25' of view, but clearly these are our thresholds in our action
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l l 95 i
-% 1 statements.
s/ 2 DR. KRESS: When you come to enforcing things, I 3 think you really are bound by the existing regulations. 4 MR. GILLESPIE: Oh, yes. 5 DR. KRESS: If you end up having this conflict, 6 George, where -- and I'm sure it can exist -- where the risk 7 performance metrics appear to be way out of line and they're 8' still meeting all the regulations, I think you've got a 9 problem with the regulations. 10 MR. GILLESPIE: The ideal piece where this would 11 be explained away -- 12 DR. KRESS: Fix the regulation.
-13 DR. BARTON: Fix the regulation. Right.
14 DR. KRESS: But that's a -- you know, that's a (~' G- 15 backfit and that's a rule and you have to make new rules. 16 But I think that's where you have to attack. If you find 17- this to be a real problem that's pervasive, I mean, I think 18 you can stand it -- 19 DR. APOSTOLAKIS: Or you can live again with an 20 unfortunate situation like after the IPEs go down we realize 21 that 19 PWR units were above the goal but they meet the 22 regulations. There's nothing we can do. Right? Is that a 4 23 happy situation for us? 24 DR. KRESS: Probably not. 25 DR. APOSTOLAKIS: Probably not. (( )- ANN RILEY & ASSOCIATES, LTD. Court Reporters
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;a 1 DR. BONACA: I just have a comment I'd like to
- 2 make.
3 DR. KRESS: The backfit rule is one of the things 4' that's got us into this box. You know, if you-can't satisfy p 5 the.backfit requirement, you can't make a new rule. And 6 that's one of the things.that have us in this box. l- 7 DR. BARTON: Mario? 8 DR. BONACA: Yes, I had a comment regarding -- one
~
9 thing that, you know, looking at these performance , 10 indicators, in fact, I don't know how many plants would not 11 meet these performance indicators quantitatively. I mean, I 12 haven't seen many plants that have more than three scrams
'13 per year, I mean, in fact.
t s 14 And the concern I have is the reverse one, which
-Q- 15 is the one that rather than being an cbjective process again 16 there'is a lot of reliance on the complementary or '
17 supplementary inspections. And so the burden becomes again 18 on the staff to show that in fact it is an objective process 19 that you are using. 2-0 Maybe the question I have is how did you get these 21 thresholds, and they seem to be in fact much more relaxed 22 than what you have from INPO.
- 23. DR. APOSTOLAKIS: In fact, they go to page H-18.
24' DR. BONACA: I know. 25 DR. APOSTOLAKIS: You will find one, two, three, i o l' Q ANN'RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut. Avenue, NW, Suite 1014 Washington, D.C.-20036 (202) 842-0034 i
97 1 four, five, six, seven, eight plants whose number of (\. )N - 2 unplanned scrams for a year is above the threshold. l 3 DR. BONACA: Yes, that's right. 4 DR. APOSTOLAKIS: By design. So what do these 5 eight plants do? 6 DR. BARTON: What they'd better do is have a 7' corrective action program to reduce the amount of scrams,
- 8. but if you're shut down, you're not going to be economically
- 9. feasible, pa da pa da pa da, down the path you go.
10 DR. APOSTOLAKIS: As a result of oversight? 11 DR. BARTON: Pardon? 12 DR. APOSTOLAKIS: As a result of oversight they
- 13 - have to do that?
.14 MR. GILLESPIE: No, there's going to be logical V 15 explanations in some cases. If you have a plant that's been i 16 shut down for two years, of which we happen to have.several, 17 and you go to start up, it is not unprecedented even in the 18 first month you would have three, four, five scrams. But
,19. you'll generally identify exactly what it was very rapidly, ;
20 and you'll correct it and move on. That's an explanation. 21 DR. APOSTOLAKIS: Incidentally -- 22 -MR. GILLESPIE: It means we have to understand and 23 explain. It doesn't mean we have to take action. And the f: 24' . licensee just has to be able to explain it and it has to l 25 .make sense and be logical.
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.~ 1 DR. APOSTOLAKIS: I don't know. I mean, that is / N Y 2 related to Dana's question earlier about not regarding the ;
3 PRA. I don't know how NEI produced these figures. Was it i 4 based on one year's performance? ; 5 MR. BARANOWSKY: No. l 6 DR. APOSTOLAKIS: Was it based on a lot of years' 7 performance? i 8 MR. BARANOWSKY: No. It was based on I believo i I 9 five years' performance and it ran from approximately 1992 l l 10 through '97. I l 11 DR'. APOSTOLAKIS: So for each plant it was the 1 12 same denominator, five years. l 13 MR. BARANOWSKY: It was on a per-year basis, but 14 they collected for that five years, and then they took the g w) ( 15 peak value for each plant in that five-year period. 16 DR. APOSTOLAKIS: Oh. 17 MR. BARANOWSKY: Now there is a couple of things-18 that are important. 1 19 One is performance has been improving over that 20 period and since that time, so there's a reasonable 21 likelihood that there would be less hits in any given year 22 than would be indicated by the 95 percent -- 23 DR. APOSTOLAKIS: Because I was wondering if you 24 have five years' worth of data for each plant, I mean the 25 codes are available now -- a two-stage Bayesian thing would
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l l 99 1 be -- V - 2 MR. BARANOWSKY: We got 'em. 3- DR. APOSTOLAKIS: You have them already? 4 MR. BARANOWSKY: We can apply a lot more 5 sophistication than we did. 6 EDR. APOSTOLAKIS: Yes. 7 MR. BARANOWSKY: But we kept it very simple for 8 this go-around. We wanted to keep the mathematical 9 eloquence to a minimum so that it could be more easily 10- understood by the everyday inspection kind of person and 11 ' licensees without going through a lot of arguments about is 12 this a good computer code, is that a good mathematical 13 method,-is the prior proper and so forth -- we wanted to get 7g_ 14 away from that for now because we just wanted to try this I i) N#> 15- out. l 16 It will evolve into something a lot more 17 sophisticated as we get more plant-specific and more 18 risk-based and we improve on the indicators, but for now, it fl9 is a very simple approach. 20- The thresholds there have' minimal risk 21 implications. We ran some calculations using those 13 122 models I told you about and for that particular threshold we 23 didn't see anything that approached the 10 to the minus'5 24 change in core damage frequency from what would be a mean 25 type of performance over that period of time, when we moved g..
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! 100 1 up to that threshold.
2 - In some cases we put all the plants' performance 3 ' at-the threshold to see if the risk was high, so it was a 4: relatively low risk associated with operating within that 5 performance band, and relatively low risk,-what I mean there l 6 is what we have today. That is low risk. 7 Increases in risk when one moves up to those J 8 limits are small enough that they wouldn't cause us to be
-9 concerned with regard to the kind of thresholds for risk 10 applications Regulatory Guide 1.174.
11 MR. JOHNSON: So let me just tell you what we'll ! 12 l see -- ' 13 DR. APOSTOLAKIS: Before we go to that though,
,-- 14 let's talk about the substance.
15 MR. JOHNSON: Which one, George? Back to the 16 matrix? 17 DR. APOSTOLAKIS: This is pages 14, 15 of the ' 18 Attachment 2 -- cross-cutting issues. 19 MR. JOHNSON: Yes. 20 DR. APOSTOLAKIS: Can we discuss those? 21 DR. BARTON: Go ahead. 22 DR. APOSTOLAKIS: You have a very nice discussion 23 of safety culture which is under the name Safety Conscious 24 Work Environment, but then you dismiss it - "No separate 25 and distinct. assessment of licensees' safety culture is s,,/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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l 101 l f-~ l' needed because it is subsumed by either the PIs or baseline 2 inspection activities." 3 Does everyone agree with that? i l 4 DR. BARTON: Well, I think they are driven to that I 5 based on -- it's the policy of the Commission is if you I 6 don't go and inspect safety culture, management 7 effectiveness and all that stuff I think you are forced into 9' this approach. l 9 DR. APOSTOLAKIS: Why don't we say that? 1-0 MR. BARANOWSKY: That's not really -- I mean that l 11 may be one reason why you get to that conclusion, but that's l 12 not why we got there when we did this work. ; 13 The real reason we got there is we're looking at
/}J' 14 outcomes that affect the objectives of the cornerstones that 15 we identified.
l 16 DR. BARTON: Okay. I 17 MR. BARANOWSKY: And our conclusion was that this 1,8 is an underlying cause to outcomes. As long as we measure 19 the outcomes, which is the performance indicators and the
. 20 inspections, and if those outcomes are acceptable we don't !
21 have to go and check into whether or not they have the right 22 . attitude at their plant. 23 DR. APOSTOLAKIS: So you are measuring human 24 performance? L 25 MR. BARANOWSKY: Sure. People make mistakes and l
- i. '
ll ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l 1 (202) 842-0034' l l . -. .
7 1 102 !
'l cause plants to trip. People make mistakes and cause j
.(~N
'ss) 2 equipment to fail.or be unavailable. To the extent that
\
3 those things don't occur, we are satisfied with the human 4 performance. 5 Now thee'are some things that we can't measure 6 with the performance indicators like how will the operator 7 respond-to a real accident. I 8 That's where we would have inspection or related 9 activities associated with the operator licensing program. 10 That is a complementary area for inspection. 11 DR. APOSTOLAKIS: Well, let's see what you are 12 saying about post-initiator operator actions. 13 You admit that they are far less frequent:--
,s 14 that's page 14 -- while initial and requalification \ '
15 . examinations provide'a predictive measure of operator 16 performance during off-normal and emergency operations, 17 follow-up inspections of risk-significant events will 18 provide a more direct indication of the adequacy of 19 post-initiator human performance. 20 In other words, you are saying that, look, we 21 really - .I-mean there is no way we can know how the guys 22 are going to perform.
- 23. MR. BARANOWSKY: Actually, what we are saying is 24 that we have had a very successful operator qualification H25 and training program and that unless we have objective X
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37 103 f.q 1 information or evidence given to us as a result of abnormal (7/ 2 events that-really challenge the operations and show that 3 they didn't handle the situation properly, we are going to 4 rely on that program to give us confidence that that is an 5 acceptable area of licensee performance. l 6 We had some incidents occur in which operators 7 have made some errors during these incidents, and those !. 8- would be the things that we would look intc to see whether i 9 or not those are an occasional human error problem or 10 whether they are indicative of deeper problems with their i 11 program. 12 DR. BARTON: I think inspectors go look at, if you put those into the corrective action program, they go look , 14 at what is going on at the site with respect to improving 15 human performance and reducing operator error. l' 16 The inspectors look at that, so that's in real 17 life.
. 18 DR. BONACA: Yes, the industry is moving, however, 7
19, in a direction where you can group elements of human iM) . performance, safety-conscious work environment, problem 21- identification in safety culture and you have'very clear
'22 indicators of it.
h .23_ 'For example, you can look at. operator challenges,- 24 temporary mods, operator work-arounds. Those are typical
;, 25 indications of poor culture if you don't correct those, or I
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M i 104
- 11. for example, corrective action programs that doesn't solve
. (^T . (,) 2 you issues or doesn't have the proper root cause. That is 3 '
an indication of that. 4 They may be worthwhile in fact at some point to 5 group this other indicator that you have inside here under 6 some heading -- because the industry is moving in that 7 direction and I think they should be encouraged to move in 8 that direction, and I think something could be done inside 9 here. 10 MR. BARANOWSKY: In fact, we would encourage them 11 to do that kind of thing because that is like an early 12 indication of an indicator, if you will. 13 DR. BONACA: That's right. . , . 14 MR. BARANOWSKY: And what they are trying to do is 15 maintain their per'formance above that threshold and so by 16 having these kinds of additional performance indication or 17 inspection activities that they perform themselves, which go 18 really beyond what the NRC does, they have the opportunity 19 of controlling their own destiny. 20- DR. BONACA: That's right. 21 MR. BARANOWSKY: That's really the idea that we 22 -are-trying to foster here is that the NRC does one to five 23 percent of all the inspections and evaluations that go on at 24 a plant. The licensee does the other 95 or 96 percent or
,25 -whatever it is, and it is their ability to do that stuff
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105 1 ~ correctly that we are trying to take sample information on C\ (m / 2 to see what the indications are. 3 MR. JOHNSON: Right. In fact, the industry was 4 very interested in looking at the things that you have just
.5 mentioned. They were also very interested in having us not 6 look at them if they don't reflect themselves in actual
'7 performance, and so that is sort of how we have come out.
8 DR. BONACA: But you do have significant 9 expectations in safety-conscious work environment and to me 10 it seems you should translate those expectations in 11 measurable things. You know, I gave you some example of 12 those because there are relationships there, so I understand 13 the interest of the industry also not having you quantify s 14 some of those, but to the degree to which you are interested N' 15 in those specific assessments, some correlation with the 16 specific metrics could be important. 17 DR. APOSTOLAKIS: When the Commission decided that 18 it's none of our business to look at safety culture, they 19 interpreted ~ safety culture the way you interpret it. 20 Let me be a little more clear. If you read
- 21 -reports from Vienna on safety culture, safety culture 22 consists of two elements they say. One is the 2
i3 organizational structure and the other is the attitudes, the 24- norms.and so on. 25 You seem to be making a distinction. You are b ( ,,/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i... m_
s l 106 1 saying safety-conscious work environment, otherwise known as q j ,) 2 safety culture, really refers to the norms and attitudes ' 3 because youfstill worry about the organizational structure' l 4 on the problem identification and corrective action 50 programs. 6t .What is not clear to me is whether the Commission l 7: also thinks about it that way. 8< DR. BARTON: That's a good point. 9 DR. SEALE: Well, didn't they really say. don't 10 look.at management -- l 11 DR. BARTON: Don't look at management
-12 effectiveness and competence.
13 DR.'APOSTOLAKIS: But what does management mean?
<14 It means your work processes and the way you manage business 15 or only the managers?
16 DR. BARTON: I think it is the former. 17 DR. APOSTOLAKIS: Well, then, how come we have a 18 full section here on problem identification that says the. I 19 scope of problem identification corrective action programs
-20 ~ includes processes for self-assessment, root cause analysis, E 21 safety-committees, operating experience, feedback-and !
i 22: corrective' action. 1 23 These are processes. They arelpartsof the 1
- 24. organization structure, so from this document I get the i- ;25 impression that this is.outside safety culture, whereas the ;
\
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107 I 1 INSEC documents'is part of the safety culture. You have to k 2 make sure you have good processes and.so on and so one, 3 which is fine with me, but now that explains the I h 4 Commission's decision because I am a little puzzled by the i 5 decision if it includes processes for self-assessment root i l 6 cause analysis and so on. h 7 I mean obviously we do care about these things -- l 1 8 DR. SEALE: It's my impression, George -- l 6 l L 9 DR. APOSTOLAKIS: -- so these are not safety ) 10' ' culture. ! \ l l 11 DR. SEALE: It is my interpretation, this personal L p 12 interpretation, that they don't -- do not want to be in the 13 position of having appeared to have told a utility, whether 7 14 it has a vice present or a -- whatever -- and exactly how ' iw~ 15 many people report'to that. person and whether their training 16 organization reports to a Nuclear Executive Vice President 17 for-the whole organization or the guy in charge of a given 18 plant, those kinds of questions. 19 DR. APOSTOLAKIS: Okay, so somehow we have to make : ( 20 a distinction. j- .21 DR. BARTON: George, I think if you look at this, 22 this is really looking at safety culture, if you are looking h 23 'at the thing that you read. I
.24 DR.-APOSTOLAKIS: Yes.
L 25- DR. BARTON: If you look in the corrective action 1 t O'c *
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- p 1 program, self-assessment, root cause analysis, safety
'Eb_sb 2 committee, you are really looking at what is the safety ; l 1 3 culture.of that organization. You really are. .I don't care l l 4 what you call it. 5 DR. APOSTOLAKIS: And that is what INSEC:said, but-6 the previous ~section here-said "a safety-conscious work 7- environment, also referred to as a safety culture" and.then 8 it concludes by saying, "In short, no separate and distinct
-9' assessment of licensees' safety-culture is ndeded.'"
10 Then there is immediately another section that 11 says, ah, but for processes that have to do with 12 identification and correctional programs, we worry about
-13 those, so I think a lot of thisuis semantics.
.g~g 14- By.the way, I don't disagree with you and that ig 115 clears up a lot of things in my mind because I think Bob is 16 right, Bob Seale,-that.the Commission did not want to appear 17 as if they were interested'in which Vice President reports 18 to the' President.
19 DR. SEALE: And the driving force behind that is 4 p :20 that there.are documentable cases in the past where certain
. :21- people who are employees-of the Commission maybe overstepped I 22 their authority and appeared at least to have interfered L23 with that sort of thing and it did raise a considerable i 24 amount'of ire and fury and heat.
l' I 25: DR. APOSTOLAKIS: Yes. ANN RILEY &. ASSOCIATES, LTD. Court Reporters-1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 !: (202) 842-0034
109
~~ 1 DR. BARTON: That came out in the Towers-Perrin
\- 2 Report.
3 DR. APOSTOLAKIS: And there are other parts of the L 4 safety culture that-I do worry about. For example, operator 5 training and so on. Yes -- in the broad definition, that is
'6 part of it, so we really are excluding here, and I think l
7 rightly so, the attitudes, goal prioritization, things that 1.' 8 you can't really see, right? 9 MR. GILLESPIE: Right. 10 DR. APOSTOLAKIS: So maybe just change the words a 11 little bit to make sure that that is what you are doing. 12' This is not really -- safety-conscious work
.13 environment, the way you describe it here, is not also l
r~s 14 ~ referred to as " safety culture." l t, 15 MR. GILLESPIE: I don't think we used the words l 16 " safety culture" but if we did we shouldn't have. l 17 DR. BARTON: Yes, you do. 18 MR. GILLESPIE: We do. 19' DR. BARTON: You have got it thrown in there a 20- couple of times. 21 DR. APOSTOLAKIS: Page 14. l L 22 MR. BARANOWSKY: That's a throw-away. I am glad l -:.
- 23 to have something the ACRS thought of something here.
24 [ Laughter.] l 25 DR. SEALE: You put it in quotes so it is -- l i l b'
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q 1 110 1 MR. BARANOWSKY: I admit it -- we made a mistake. () 2 DR. APOSTOLAKIS: I am not asking you to admit you 3 made a mistake. It's good that you did. 4 (Laughter.] 5 DR. APOSTOLAKIS: But it is a very important part 6 .though that you really worry about -- in fact, if you go to 7 a plant or your resident inspector realizes there is no 8 mechanism, there is no process for operating experience 9 feedback, he probably won't like it. Right? 10 DR. SEALE: Well, any root cause analysis that 11 doesn't address concerns having to do with human action is 12 idiocy. 4' 13 DR. APOSTOLAKIS: Which is most root cause
,. 14 analysis.
\ 15 MR, BARANOWSKY: When you cross the threshold and 16 the resident inspector goes and says why is this occurring, 17 and they see that they don't have a good root cause analysis 18 activity, then you are getting into these things, but that 19 is a cause of the problem kind of thing. That's why we are 20 saying you won't have an indicator for that by itself 21 because if you did I mean that would be fine but v don't
'22 know how to relate some of these things to the cornerstones 23 directly. There isn't a simple algorithm for doing that.
24 , DR. SEALE: The thing you detect is the 25 consequence, not the action.
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111 1 MR. BARANOWSKY: Right. 0 1
\ ,) 2 MR. GILLESPIE: And in fact independent of which 3- -cornerstone or which PI or which inspection activity might 4 cause us to engage further in doing a root cause analysis, 5 the end of the root cause analysis might find that problems 6 exist in places not first indicated, because at that point 7 you are in an analytic mode and how pervasive is it is the 8 kind of question you are asking, how limited is it, was it 9 isolated, was it not isolated, so you roughly go from one 10 kind of inspection process and procedure to a different one 11 when you get to that point.
12 DR. BARTON: I have seen you put your light out. 13 Does that mean,you are done? 14 MR. JOHNSON: That means -- N 15 MR. GILLESPIE: I think he gave up on the last 15 viewgraph. 'He's not going to put it up. 17 [ Laughter.]
'18 MR. JOHNSON: We have moved beyond the last one.
19 I can put it up but I don't see a point. 20 DR. APOSTOLAKIS: I am done with my questions, Mr. 21 Chairman. 22 DR. BARTON: You are done with your questions? 23 All right. j 24 Throughout.the document, and I think you mentioned l L 25 this morning you still have got some work to do and there's
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t 112 L ' 1 some not just shoe-strings to tie but you actually have some Y'_s\ ( /- 2 other open issues that are mentioned throughout the , l 3 document. l l 4 When do you plan to have that supplemental l 5 information ready? When can we hear? Will that be after 6 pilot programs, after this thing goes out for comment? What 7 is'the timing on when we'll hear what is missing in here? 8 MR. GILLESPIE: Let me ask Al Madison to come ; 9' up -- Alan is the Team Leader for the Transition Task 10 Force -- and ask him to address part of the schedule. 11 DR. BARTON: Is that the last slide you weren't 12 going to show? 13 MR. GILLESPIE: No. This is one that-wasn't even j- - 14 on the -- i
\ *E MR. MADISON: I am Alan Madison with NRR. We have
'16 met before. Your specific question, so I can address it?
17 DR. BARTON: You go through the document and it 18 says thee is more work to be done; we've got to do something 19 here -- throughout, all right?
-20 My question is when will you fill in those blanks 21 and when will you have that work done?
22 MR. MADISON: Well, I am glad you recognize there 23- is a lot of work to be don, a lot of work left, and we're, 24 as the paper alludes to, we are going to implement or 25 establish a-task force which we have begun to do. Because l ANN RILEY & ASSOCIATES, LTD. j Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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113 1 of the broad scope of activities that are involved there ' O)
\s, 2 will be a lot of folks involved in that task force.
3 Some of the items -- Mike,,you'll probably want to 4' list the key transition. tasks. 5 These are some of the key tasks we think are 6 involved in there and you probably noted a few others. But . 7 we have broken it out into the work remaining and developing 8 the procedures and the policy _ documents that are going to 9 need support both the inspection procedure and the 10 assessment procedures. Enforcement policies also fit into 11 there. The performance indicators, how we are going to 12 collect the performance indicators, how licensees -- the 13 format they are' going to report them in. What are we going
- s 14 to do with it? How are we going to get that cut to the \ 15 public? All that is yet to be developed, the support 16 infrastructure for those changes, as well as other changes 17- in various areas.
18 We have'got'a lot of training to do, we have got 19 development. Some of the jobs that were left to be done, 20 including -- well, it was called benchmarking, we are now 21' really calling that a feasibility study. Is the process -- 22 is it feasible that we can take the performance indicators,
-23 that we can take inspection data and compare those and come 24 up an assessment in the cornerstone areas? We plan to do 25 that during the_ transition.
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114 1 One of the biggest things, and that would be the A)
?(_ 2 next slide with the transition strategy. One of the biggest 3 things we recognized right away is there'is a lot of L 4 communication and change management issues that we need to 5 . deal with in this. And so we, as part of establishing the 6 transition task force, we'have named what we call a change 7, champion who is going to be kind'of our voice out in the l
8 industry and the agency, c.nd to the public, and that is Sam ' 9 Collins, Director of NRR. He will be our primary i 10 communicator of what we.are doing and where we are going. l l 11 To assist him, to help him out in that, and to 12 help us out, we are in the processing a change coalition, 13 which we feel are the -- we are hoping these folks are what 14 we are calling the opinion leaders in the various areas, and I 15 they may or may not be in management. We are focusing right 16 now on the regions, but we are also going to develcp some 17- folks here in headquarters that will be on that change 18 coalition. We see them as our primary source of information 19 back from the field, how the transition, how the processes 20 are being perceived by the people in the field, and changes, 21 recommended changes and improvements that we can make to the 22 ' process. 23- We are also going to try to leverage off of this a 1 24 ' group of. individuals, the senior individuals in this change ! 25 coalition, who may be able to provide some management
'(O)
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115 1 ' oversight and some management control for the process k,) m 2 . implementation that we go through. 3 We also recognize there is industry and other
- 4 external stakeholders, such as the states,-that we are going 5 to have to communicate with and bring on board. And we are l'
6: : developing some -- or we are working with some 7- opportunities, I guess, where we can take some action in ;
-8 that area.
)
9 One of the transition task force members will be
.10 -
that will be his primary job, to look after the change 11 management and the communication issues that we have. 12 Another' member of the task force will look at the training l 13 issues that we have and develop training for the staff. And ) u 14 we will probably end up developing some joint training with . !
.i i
O' 15- industry to get the plants up to speed on the performance ;
-i 16 indicators, how they are going to report them, and how we 17- are' going to -- what we are going to do in that area.
'18 Now, the schedule. There's what we see as our 19 major milestones as we go along. Now, throughout that time i
p '20 period we expect to be communicating and keeping the ACRS _ 21. informed, and we will try to schedule some opportunities 22 that we can do that. We look at having a Commission paper 6, 23 sometime in the March timeframe and receiving final 24L Commission approval on the recommendations, not on the whole $ 25 package. We are not going to have all the details filled i ANN RILEY & ASSOCIATES, LTD. Court Reporters I 1025 Connecticut Avenue, NW, Suite 1014
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116 1 in. (_) 2 We plan to start a pilot in June. Now, to support 3 the pilot, we are going to have to have a good draft of the 4 inspection procedures and the program documents that will 5 support those inspection procedures. And we are also going 6 to have to have provided some training to those selected 7 pilot plants and the NRC staff that is going to be involved 8 in that, that includes the senior resident inspectors, the 9 branch chiefs, and probably some DRS personnel, and others 10 in various areas. 11 And we are also looking at, in October, providing 12 a workshop that would be a joint industry-NRC workshop, 13 public workshop, to provide training for everybody involved. 14 Does this sort of answer some of your question?
/~'
kN) 15 DR. BARTON: That's part of it, Alan, but I was 16 under the impression that you owed the Commission some more i 17 supplemental paper, some more documents by next month i 18 sometime. 19 MR. MADISON: The March paper, I think, promised i 20 -- the March paper is -- the promised March paper has to 21 deal with completing some of the items, I think, and the 22 Office of Enforcement is to come up with a recommendation, a 23 final recommendation of where they went ahead with the 24 enforcement policy. I think we are going to come up with a 25 better draft. We didn't provide them any documentation on r~x ANN RILEY & ASSOCIATES, LTD. (' ') Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 \ a-
117 1 what we are going to do-With the inspection data to relate f*
.( )\- .it to performance indicators, and we owe them a document
~
2 3 that at least outlines the concept that we have and gives 14 some direction of where we are going with that. I am not 5 sure how-mu'ch detail we owe them on that. > l 6 DR. BARTON: Well, are we going to get to see any 7' .of this stuff? Do you need a letter from us before this 8 goes out for public comment or what? Where are we in I i 9 your kind of chain here? ! 10 MR. GILLESPIE: Let we tell you where are in the { l 11' ' cycle of things. It is out for public comment. To maintain ' 12 this aggressive schedule, it went out for public comment ! 13 before the Commission even got it, and the Commission went 1 14 on faith that the staff had a good document, which was -- I 6 ' s s 15_ appreciate that because it allowed us to move forward. l
- 16. We will be going back to the Commission, I believe 17 the meeting is tentatively scheduled for March 18th. About 18 the first week.in March, we will be going back with a 19 smaller paper -- we are not sending 400 pages back up --
20 that will deal.with.the exceptions and the comments. And t-21 that will include dealing with any comments now we get from an ACRS letter that comes to the Commission from this
~
.22 i
23 meeting in -- l i [ 24- DR. BARTON: February. ,. 25 MR. GILLESPIE: February, I forget when the date <
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118 1 is. TN
.( ) 2' DR. BARTON: Fourth, 5th, somethir3 like that?
3 MR. GILLESPIE: Fourth or something. Yeah. So 4 .the ACRs letter will be factored in to this comment' period, i s 5 DR. BARTON: We are going to really -- we are 6 really commenting on-this policy.
-7 MR. GILLESPIE: Yes.
l 8 DR. BARTON: SECY-99-007, January 8th document. 9- 'MR. GILLESPIE: Yes. Yeah. And now the hole, the
- 10. real big hole that'the. Commission focused on was this l
'11 . subjective or potentially rule-based scale that an inspector 12 could rapidly assess his results against and know whether --
13' .I just turn this over to a licensee, or does it warrant l 14 further pursuit. ) That was the significant hole that was l L \s / 15 identified. We are' going to be working on that. 16 As'a-minimum, our best insights on that will have l 17 to go in the March paper. As a maximum, maybe we will get 18 it done sooner and get it out for comment to everybody, i 19 including the ACRS for information and comment. 20 DR. SEALE: When the March paper is available, we
.21 will get a copy of that?
- 22. MR. GILLESPIE: .Yes, absolutely.
[ 23 DR. POWERS: Mr. Chairman, I think we should I ' 24- devote some time to this letter. I think we have to go p-- 25 beyond just the details and the specifics, but point out
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u 119 11 what we think are the strengths of the approach that they
) 2 have adopted in what I think is an extraordinary piece of 3 work.
,, 4 DR. BARTON: Yes. 5 DR. POWERS: And that stands as a template for a' 6 lot of other activities that the NRC is undertaking. 7 DR.' MILLER: However, you are going to -- you I 8 recommend we comment on the process of getting to this 9 document as well as.the document itself? 10- DR. POWERS: That's right. I think that - - I 11 think some of the ideas that emerged in this document are 12 strokes of genius. 13 DR. SEALE: They are worthy of emulation.
-s 14 DR. POWERS: And could be used in a lot of other \~ I 15 contexts to get over some of the rough spots of moving in 16 the direction of more risk-informed regulations.
17 DR. SEALE: I have one comment -- 18 DR. POWERS: Other than that, we ought we praise 19 the document wherever we can. 20- MR. GILLESPIE: Well, we also appreciate, because 21 this sets us up for the future. I promised research, you 22
~
have always got to give them a plug, this is the beginning,
.23 .and we know there's weaknesses in the approach that deserve 24 future consideration. So any insights'as to where, first, 25 future consideration might go would also be appreciated. 'O 'V ANN RILEY & ASSOCIATES, LTD.
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-120 1
1 Because once this.goes in place, the next step is figure cut t . ! ,, j 2 to make it better. I 3 DR. SEALE: I have one comment on the schedule or l ! 4 the outline of future action you made. I heard about task I 5' force members or team memb'ers. I heard things about I 6 piggy-backing or some term like that, some administrative or i 7 leadership, or something like that in all of this process, 8 and I never did hear any word about the regional I 9 administrators. And it seems to me that while this is going 10 to be in the pilot stage, only a small part of what is going 11 on in each region, that it is very important that the i 12 regional administrators be brought up to speed on this 13 process very early, because they can either make it or break 14- it. t ) ! \m/ 15- MR. GILLESPIE: Yes, absolutely. And that is -- I 16 hope nothing I said led you believe that we weren't going to 17 involve the regional administrators. Yes, and we are 1 j 18 wrestling with-that. And the agency right now is a 19 quandary, and the quandary is we have taken on, as an 20 institution, what the consultants tell us we probably [ 21 shouldn't have, all at once. We are reorganizing. We just i 22 went through a massive number of retirements in the 1 23 management ranks, including the regions. And at the same l 24 time, at least as far as the regions are concerned, we are l 25 maintaining a current program and we are trying to l l
.'(,
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L r L : 1 t l 121 [ . _1 completely turn it upside down. .And we are trying to do it t l,D [ - (,) . .
'i 2. all at once, i 3 DR. BARTON: Business as usual. Right. ,
4- MR. GILLESPIE: Yeah. And it has put strains on ! S the system. While we would have liked to have actually had ; 6- a regional administrator volunteer to come in and work with 1
'7 us for six months-and run this show, I would have liked the 8: relief, it wasn't in the cards, because two of the regional 9' administrators are basically.new.
10 DR. SEALE: Well, it is not in the nature of those
~
[11 1 beasts.
'12 -MR. GILLESPIE: Yeah. But we are fosteri~ng, as i
13_ part of-the change coalition, and we are trying to -- we l 1~- '14 have been brainstorming this. I will throw this out on the !? p ^~ / b 15 table. This is a concept. I won't even say I have talked
- 16. it over very much with people, at least we have touched it
- 17. with Sam, and that would be putting a senior level committee 18 together which might be deputy regional administrators,
- 19. regional administrators, o .r projects division directors, who
~20- are the guys who really have to make_this work when we get 21- it out -- one person from each region who is kind:of the 22l senior member of this concept of a change coalition -- and
'23 we wouldn'* be on it, and, actually, subject ourselves about 24 once every two to.three weeks to using themalike a murder l L2 5 - board, where we would' spend-one day briefing them, and a i
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i 122 l 1 half-a-day letting them tear us apart. And at the 2 Commission table at the end, in March, we would ask the 3 chairman of that group to come and sit at the table with us. 4 Now, that is kind of a conceptual concept that we
- 5. are looking at. We haven't really run that by the regions 6 yet, and they haven't volunteered for it. But that is kind 7 of.the degree of thinking, as we are putting the task force 8 together,.that'we are going to. So any suggestions, any --
9' that is kind of the gelling, it is as close as we have come i 10 right now, conceptually, to how we would both get critical, 11 very, very critical -- Can this be applied? Can we do it? 12 -- advice, and have them at the table to say, hey, they took 13 my criticisms and they told me why not, or they took them
.j-~ 14 into account, here's my concerns that still exist.
15 DR. SEALE: I have another question I want to ask, 16- and it goes back to -- I don't know, for some reason, I have 17 always had a picture of autonomous fiefdoms as you move from 18 one' region to the other, and I don't think that is an 19 entirely erroneous picture. In this -- in that chart you 20 had up there earlier, you talked about the dividing line 21 between regional review and Commission review. In all of 22 these mergers, acquisitions and things like that that have 23 gone on, how many cases do we now have where an operating 24 company has plants in more than one region? 25 MR. GILLESPIE: I couldn't answer. It is getting q k ,lI m ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
123 1 worse. I mean with Entergy buying Plymouth, we have got
,O \ ,). '2 Region IV to Region I, which is the maximum extent. I don't
- 3. know. We could look it up.
4 DR. SEALE: Yes. Well, it is-interesting to me 5 because it seems to me that that -- and I am not sure how 6 you get it, but it might be interesting to try to find out, 7 in the eyes of a victim, whether or not they see equal 8 treatment from the regions. 9 MR. GILLESPIE: Yeah, that's an interesting point. i 10 It has happened, by the way. 11 DR. SEALE: I am sure it has, but, you know, I
'l 12 think it is something.that the regions ought to be aware of 13 as a reasonable and perfectly correct source of performance
,_ 14 data that they have to be prepared to live with. Just a N-I 15 wild suggestion.
16 MR. GILLESPIE: Yes, and actually putting on 17 another hat. Within the same branch, we are putting 18 together a program performance group of four or five people.
'19 We used to do this about four or five years ago, got 20 strapped for resources, couldn't do it. And with the 21 demise, if you would, of the end of the A&E program, we now 22 have some people available to get back into more of a 23 routine -- How is the program going? And that is a good 24; point, because we would be visiting some utilities and 25 plants, and I hadn't necessarily, I don't think anyone has ir
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124 l- . suggested that we ask.that particular question.
]) ~.,
2 I am going to guess there is a half-a-dozen. 3 companies. L 4 DR. SEALE: .I would think so, yeah. Yeah. ! :S MR. GILLESPIE: That cross some line, some way,
.6 shape or form.
- c i
7 MR. MADISON: There is a - NEI is having a user
- 8. survey which they are' going to survey pre-implementation of L 9 this process and post-implementation, which may address that l
- 10. question. We are going to.try to utilize that survey. I 11 DR. POWERS: I want to go back to your question j ~ 12 - about the. cultural change.that you have to.make within the j
! 13' agency itself. 'You are not-'the first institution to
,% 14 undertake a're-engineering of its procedures. It has gone
~- 15 on long enough that'there is a body of management science 16 that'has been assembled on the difficulties of-these things.
17 . I, myself, am unfamiliar with that literature, but I l 18' wondered if it had anything that was of use to you. l ' 19 MR. GILLESPIE: Yes. 20 MR. MADISON: Definitely. l J l, 21 MR. GILLESPIE: In fact -- okay, go ahead, Alan.
.22- He is'the holder of the textbook, he has got the-formula.
l-l 23 MR. MADISON: Well, I don't know if I have got the ; (- l l- 24 ; formula or the answer, but.we are trying to get the answer L i L 25 now. We are. utilizing the contractor that the NRC does, ! i' i u
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1 l 125 1 1
. ~s i
1 Nick Mann, as well as his subcontractors, to give us some f- / 2 insight into where we ought to go. I 3 As I said earlier, we have one individual who is l l 4 going to be on the task force, August Specter, who has a ! 5 background in this area. He is going to be the focus for 6 this so that we have somebody who is really concentrating on l 7 this full-time. He and I are going to go to -- actually, 8 outside to the industry, to Salem, to try to get some input 9 and some insights from the changes that they have gone 10 through and the processes they have used. 11 Yeah, we are going to try to collect some of this 12 body of knowledge and use it. 13 MR. GILLESPIE: Well, no, no , no. Think about ( rw I 14 this, and it is funny, the people from Salem were very, very
J 15 open with us, and they said we have done it twice and we 16 messed it up the first time. And, so, I am not sure that 17 they might not be kind of -- when you are going for l
18 insights, and they gave us some interesting insights and , l 19 documentation already which has caused us some thinking. 20 One was people want to hear from the first-line l 21 supervisor. They don't want to hear from outsiders. Which l 22 is interesting, because the traditional way NRC does things 23 is we kind of collectively as a team would have gone out to 24 the regions and lectured the first-line people with the 25 supervisors in probably the same group.
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126 1 And you start to develop well, we've got to go 2- talk to the branch chiefs and division directors separately 3 first and make sure not that they're saying yes, we'll do 4' what you're telling us to do, but yes, we understand the 5 underlying principles and can explain it to our staff. So 6 some of the insights of what Alan's been doing are already
=7 -- it slowed us down a little bit, because we said we need 8 to think about'this. If you do it in the wrong order, you
'9 could mess it up badly.
I 10 DR. BARTON: I thought it was a surprise, j 11 DR. SEALE: There's a variation on that that the 12 INPO people use in their' plant assessments now, their I 13 visits, namely they use local peers -- f- 14 DR. BARTON: Right.
-"# 15- DR. SEALE: On their visiting team, and the
'16 presentation of the results of the. visit is made-by the 17 local peer.
18 DR. BARTON: Right.
.19 DR. SEALE: Which is kind of the same thing. The 20 guy that's telling you the finding knows your plant. He's 21 not somebody from Mars that came in and --
22 MR. GILLESPIE: Yes. And maybe we should have 23 known this right away. .We didn't. And to'me that was, if 24 nothing else, an extremely valuable insight that said slow 25 down, understand the steps, adjust who you're talking to, ';/7
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127 1 you want to talk to different people with different levels 2 at different times. i 3 And-then you have to say what are they going to do 4 with the information? And the first-line supervisor, 5 division director, do different things. So we're trying to i 6 do it right, and in fact we're looking at the literature and 7 'trying to use the right experts to give us the input. 1 8' DR. POWERS: I mean, I think'that's the answer is 9 simply not be arrogant enough to think that you know all the I 10 pitfalls to this, because I think more than one company has 11 had serious difficulties making these kinds of changes. 12 MR. GILLESPIE: Yes. 13 DR. POWERS: The other thing is, of course, to 14 recognize I think the personality of your organization and (~) (s,/ - 15 the personality of the Salem organization are about as !
.:16 orthogonal as two organizations can be. So I laud you for i 17 taking the words from them, but I caution you they may not l 18 be 100 percent transferable.
39 DR. MILLER: They say they messed it up the first i 20 time. I don't think the second time the story's been told 21 totally yet. 22 DR. POWERS: Yes. I mean, this is --
\: 23 DR. MILLER: We don't know the result in the 24 second time.
25 DR. POWERS: Right. This is a classic theory x , b) Hk_/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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128 l l 1 and theory y organization. They're just not going to mesh
.q- -Q 2 well.
3 MR. MADISON: But they do have some interesting i
' l 4 concepts that we want to find out what they -- how they 5 really made or are making them work and see if we can apply 6 them to our own case. U 7 DR. POWERS: I think you're doing the right thing, ;
8 going and collecting information from wherever you can and i 9 then use that part that's useful to you and throw away that { 10 part that's not. 11- MR. MADISON: Exactly.
.12 DR. POWERS: That's all you can do, and pray.
13 MR. MADISON: We may not have the answer yet, but i 14 we're -- this is probably the first time that in my i
) \_/ 15 recollection with'the NRC that we've made this large of an 16 attempt at managing the change rather than just making it.
17~ DR. POWERS: The other piece of wisdom that I've 18 heard frequently expressed in this area is that it takes i l 19 three years, that if you try to bring about a change in the
- 20. culture and do it in six months, and then we'll make another 21 change at the end of that six months, you make no change at 22 all.
23 MR. MADISON: Um-hum. 24 DR. POWERS: And it's -- it is so tempting for ( .t. l- '25' managers to say okay, here's the time line when we will have I b
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I 129 1 made this change, and lay it down by the calendar rather i
. -) 2 than the personality of their organization, and I think that 3 has been one of the biggest discoveries people have made is 4 that --
5 DR. MILLERS. Each organization has a different 6 personality. I'll guarantee any university will take a lot l 7 more than three years. ' 8 DR. BARTON: Three to five years -- 9 DR. MILLER: Some organizations might take less, i 10 DR. POWERS: Well, I think you have certain 11 advantages in some organizations would change and certain 12 you don't, and NRC is likely to be slow, simply because 13 conservatism has been the watchword of the way you do I
,_ 14 things, not only within this agency but in all of nuclear \) -
15 power, the whole thing is think carefully about making a
.16 step. A] ways make sure you've got your foot on firm ground 17 before you take a step forward. I mean, we tell people to l
l 18 do this all the time, and that infects the nuclear business, 19 whereas in Silicon Valley they don't -- not too concerned 20 about whether they're floating on air or not. 21 DR. MILLER: Dana, wouldn't you expect with all 22 the changes in the upper management they reflect and so 23 .forth, that could be in some cases disadvantageous, and in l 24 other cases advantageous in this culture? l 25 DR. POWERS: I think you're right that whenever A ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034
y i. l 130 1 you change a high-level boss, people anticipate change and
-(_,
p) 2 -are more open to it. On the other hand, they're always 3 suspicious. l 4 DR. MILLER: But aren't there like somebody l 1 I 5 reflected there's fiefdoms, I think Bob Seale, at the 6 different regions, which is probably true. Now you've had l 7 two regional administrators who are probably in control of 8 those fiefdoms depart. If the fiefdoms are going to change, ; 9 it's a good time to change them, if indeed that's what we're 10 going to do. 1
'11 DR. BONACA: I have one.more question regarding 12 the report. I realize that I got this report, I've seen it 13 for the first time just a few days ago, so -- and the
- /,_N 14 question I have is the report sets essentially four hmI 15- cbjectives for this change in the inspection process. One 16 is improved objectivity, scrutability, risk-informed, and 17 also a secondary goal seems to be the reduction of burden.
- 18. And clearly reading it scrutability is improved, 19 risk-informed is there, okay.
20 The only thing that I was asking was, I would have 21 liked to see some comparison of the areas of inspection that 22 we used to do before that would not be done by the new 23- process and vice versa to convince me that in fact we have 24 enhanced objectivity and also that we have reduced burden. 25 Without that it was a little bit difficult to make a t l L l ('~') ' ANN RILEY & ASSOCIATES, LTD. Court Reporters I 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
aar 131 I 1 judgment. And I wonder if you'have done that kind of
- /~'t 4 Ts/ 2 comparison, just as a minimum, you know, large pockets of i
l 3~ perspective, what we're not going to look at anymore that we 4 .used to look at before, and vice versa, what is new that we 5 were not.looking at before. C MR. GILLESPIE: Yes, .let me -- we actually kind of i 7- -- I wish I could give a flat yes or no -- we actually did a 8 check going the other way, and the question was would this 9 program as proposed in the areas of inspections catch the l i 10 things that we've seen at plants in the past which are not i i i 11 covered by PIs. And therefore you still see a large -- 12 almost the same emphasis as we have today on engineering., 13 So the engineering area didn't change very much.
, -q 14 For the other areas, we did it, but didn't write r 1 l 15 it in, and there's a' chart in there that talks about the l 16' risk-informed baseline and section, it comes up to like 1850 17 hours. We actually have a table that's in the inspection 18 manual today that we check each year to see that we're kind
- 19. of in the ballpark on the current core inspection procedure, 20 which is kind of the equivalent. And'for a two-unit site, 21- that comes out to be about 2200 hours. The best estimate on 22 if you did the sampling process and looked at the things 23 that are in here was about 1850. So we are anticipating 241 that it will be as a first estimate about 20 percent less.
25 But we didn't write that down as a formal report. !,q f ( )\< ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
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132 1 But it's really comparing this table to the table that's in h(~M ' 2 >there'. And that was done. 3 DR. BONACA: The main concern I had was that, you 4 know, I'see a' lot of restructuring. The question is, are we 5 really changing what we're going to look at? And if we are, 6 what are we going to lose in the process to gain in that 7 . process? 8 MR. GILLESPIE: Yes. If there was a major area of 9 . loss, and this may sound counterintuitive, but I think in 10' the whole set of inspectable areas, the major reduction is 11 .in operational areas. .I'll give you an example relative to 12 maintenance. The current procedures would cause maintenance 13 procedures to be observed on some periodic basis, and'I 14 think it's once every two months or something~now.
\- 15 Well, what's the point of that?
4 What's the safety 16 significance of it? I mean, those kind of questions are 17 asked. I think you'll find in the inspectable areas that 18 the. focus is on observing the postmaintenance testing to 19 assure that the proper characteristics will work, which 20 doesn't mean sitting there eight hours and watching a 21 maintenance procedure. But it does mean watching the test 22 -procedure, which will be much truncated.
- 23 The PIs tended to be very operational PIs, numbers 24 of scrams, and risk-insights that Research came up with 25 focuses that -- John, help me out -- some what percentage of C $s,) ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 { i V 1 9
133
-sy .it ~t he risk actually looks like in real experience came from 4 ? }~ ') 2 maintenance, wasn't it? You used to have a pie chart you 3 showed --
4' MR. FLACK: Yes, that was a -- and actually that l 5 was the big discrepancy. A lot of the events, the i 6 risk-significant events-that we were observing through the S i 7 program was coming from maintenance and not so much from 8 operations. 9 MR. GILLESPIE: Operations. I 10 MR. FLACK: And I think that's where you're seeing { 11 the change, the tradeoff now is they*re going to be looking l 12 more at maintenance and less on operations. 13 HMR . GILLESPIE: Yes, and the way we look at
. maintenance in this process becomes different, hopefully
-14 I
4
-15 more intelligent way of looking at it rather than just the 16 gross approach of we're going to watch this guy do
-17 maintenance on a valve from beginning to end. And you know j 18 when we watched him do the maintenance we didn't hang around 19 -to see the postmaintenance test? Because that wasn't in the 20 procedure.
l 21 DR. POWERS: You have to advertise this. I mean,
- 22. you just really have to advertise that you've taken l- 23 advantage of these insights that you've been getting out of 12 4 your past inspection program. .I mean --
- 25 MR. GILLESPIE: And some of this is practical i.~O h ANN RILEY & ASSOCIATES, LTD.
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134 1 insights, n. Ig, ). 2 , DR. BONACA: I'm saying that as you go forward in 3 a transition, I think it would be helpful to have somewhere 4 a brief discussion of this, because you are leaving behind i 5 issues or_ reviews that may be significant, and the question ' 6- is you have a burden of proof that this transition in fact
]
7 is effective -- r 8 MR. GILLESPIE: Yes, i 9 DR. BONACA: And also you have a burden of proof 10- of closing on these objectives that you set in your, you 11 know -- 12 MR. GILLESPIE: Right.
- 13 . DR. BONACA: And the other thing is that it would
- 14 be certainly useful to the industry and certainly to me to O
i
-(/ 15 understand the dif-ferences there and to really -- it would 16 give me much more comfort that in fact the objectivity is 17- truly improved in the process. )
18 MR. GILLESPIE: Let me -- I'm only hesitant l 19 because this is an opportunity lost, you might say. If this ) 20 was a research project, literally doing a kind of a more 21 academic research project, an experiment that doesn't work 22 still is a successful experiment, and it tells your 23 hypothesis was an incorrect hypothesis. And some of us only
-24 look at -- only if it proves _a hypothesis is it successful.
25 And when Bruce was putting together the program, i
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9 1 135 I 1 he went through a process of identifying over 100
,y
()_,, 2 inspectable areas which basically encompassed the program as ; 1 3 his group who were actually inspectors, sorry, today. And j i 4 so they basically took today's program and cut it up into l 5 all these pieces, and we ended up with about 40 areas when
]
1 6 you implied all the insights. What we lost was they didn't i 7 write down the results of the brainstorming sessions which 8 necessarily caused them to filter those things out. l l 9 And I don't know how recoverable that is, but I 10 don't mind going back and asking the question, and going 11 back through some early drafts. Steve Stein was on the 12 group, and I talked to Steve, and I said, Steve, did you l l 13 save the file folders to show the traceability of, l l
, _s 14 basically, how do you go from everything we look at now to I 'a k/ -
15 what you look at here, and why? 16 DR. BONACA: As a minimum, if you had written that 17 here, I would have been more comfortable. 18 MR. GILLESPIE: Yes, and that was a reaction a 19 number of us had when we started reading, and we said, oh, 20 no, we left off the negatives. We left off the reasons why 21 we left things off. 22 We will look at the file folder and see if it is 23 recoverable. I don't want to promise it, that it is. 24 MR. FLACK: Just to clarify, they are not really 25 lost. I mean for the baseline inspection, it does a certain A () ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
.- .. .. . .. . -. ~
136 1 level of inspections, but, again, you revisit these .f') l s_/ 2 depending on your performance indicators and findings. So 3 it is not totally lost, it is just that you will get into it 4 after something else leads you there. 5 MR. GILLESPIE: Yes, but what is lost is -- What 6 did we trade off? What.would we be inspecting today that we 7 .are not going to inspect a year from now because we have 8 this performance indicator? 9 MR. FLACK: As part of the baseline. 10 MR. GILLESPIE: As part of the baseline. And 11 that, I am afraid, is lost. 12 MR. JOHNSON: But I almost think a better way to 13 do it, or at least as good a way to do it, and one that we es 14 had anticipated, was that we will go look -- we have talked 15 allot about success-criteria, and one of the success 16 criteria is do we meet the objectives. And I think it is 17 going to be important that we go back a year from now, and 18 we look in terms of what it is we are actually inspecting. 19 And what did the old core provide? What are we looking at 20 now? Do we have a sense that we are more objective? Do we 21 have a sense -- I mean have we hit our targets in terms of 22 burden reduction? Have we hit those things that we outlined
-23 for ourselves? And we have promised to do that all along, 24 and the Commission is holding our feet to the fire on that.
25 DR. BONACA: The other thing is that I would
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.. m 137 1 expect some of your resident inspectors would want to know p_ )\-) 2 why-I am not going to inspect this anymore, I think is i
3 important-. 4 MR. GILLESPIE: And that is going to have to be 5 factored into the training. And I will give you one las,t 6 bit of insight that is hidden in this paper, :Un Pat's 7 write-up some place, and it goes -- of a thousand LERs that 8 came in about a year, only 1 percent, or 10, were 9 significant enough to be screened at a 10 to the minus 6 or 10 greater risk number, which is significant in that -- 11 DR. POWERS: It is not hidden, it is highlighted 12 in there. 13- MR. GILLESPIE: Yeah. I'll tell you the truth, I ys. 14 have talked to a lot of people who said they read the paper
\- 15 and they missed this sentence, and I remembered it, because 16 it stuck.
17 DR. POWERS: It stands right out.
'18 MR. GILLESPIE: If that is in any way reflective 19 of also the kind of things that an inspector sees as he is 20 walking around a plant, then that is going to be the most 21 significant cultural change that we will have, that 99 22 ~ percent of what we have been observing in the facilities is 23 likely not risk significant.
24 Now, I don't know that I can take that and 25, directly make that conclusion, but, certainly, it says that r.
~' ~
( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
m 138 , 1 p_ 1 many of the things that we see going on day to day, even
- \
\_ / 2 though they are viewed as incorrect or not right, may cat i 3 necessarily have a risk significance. That is the one most l 4 significant cultural change that is going -- that we are 5 challenged with right down to the lower levels, because we 1 6 have trained ourselves, we have trained the industry, that 7 this is a problem, regulatory significance, procedural 8 compliance. l 9 DR. BARTON: Verbatim compliance with regulations, 1
10 it is not quite that bad, but it is almost there. 11 MR. GILLESPIE: So I don't know the answer, but 12 this is the change process. It is not just changing how you 13 inspect and what you inspect, but it is the fundamental
,e 3 14 understanding of why I am just turning this over to a \ '-} 15 licensee, when only a year ago, this might have been a level j 16 4, level 1 violation.
I 17 DR. SEALE: It is interesting. l l 18 DR. APOSTOLAKIS: We are not requiring verbatim l 19 compliance anymore? j 20 DR. BARTON: I hope not. 21 DR. APOSTOLAKIS: If you read the nuclear safe 1 22 culture thing, we do. We do. We do. l 23 MR. BARANOWSKY: They might be NCVs, non-citable 24 violations. l l 25 DR. BARTON: That is how to handle it. r (T 1 (,/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 i 1
L ! 139 1 MR. GILLESPIE: Anyway, it is that kind of data d 2. that needs to be put together in an understandable -- that 3 is going to be'a challenging-training-course, if you would, 4 or adjustment to the P-111 course that we currently have. 5 To get this kind of information, and the context, that also 6- fits with what people feel they are intuitively seeing at 7 the facilities is going to be difficult. 8 Even Sam Collins gave me an incident, it was a
; 9 morning report that came into the EDO. A BWR flange had a 10 steam leak on it, it was going up in power. A 10 percent l
L 11 power tech spec says check your high pressure injection , L 12 turbine-driven pump. They let steam in. Steam flange 13 wasn't tightened. Steam leak. They turned off the steam,
/N 14 .they tightened the flange, it continued up in power. The i U l . 15.
system got very exercised. 1[t happened to be the most
- 16. important thing that happened that day in the morning 17 report.
I 18- It was not risk significant. So everyone got 19 exercised all the way up through the EDO, you might say, in
- 20. a' communications sense, for something that was not -- the 21 system worked. The tech spec said test, they tested. Yes, l' 22 they have to go back and find out why weren't the bolts l
! 23 tightened the first time around. And Sam looked at me when p 24 I said, this isn't risk significant. He said I can't p l i 25 believe you, go get a risk guy. So I took it down to the
. ;g V
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, - , , ~.
l 140 p 1 risk guy and I said --
/ %
(_,/ 2 DR .' BARTON: Well, it is going to take years to 3 change that mindset. 4 MR. GILLESPIE: Is this significant? And the risk 5 guys says, you know that is not significant. I said, yeah, 6 but you have to write it down for me. So he wrote it down, 7 he pu*. his name on the bottom. I went back in to Sam, and 8 said, see, Sam, it is still not risk significant. And he 9 just looked at me and said, we are really going to have to 10 change the way we think around here. 11 DR. BARTON: You are darn right you are. It is 12 also not only risk, it is also you are afraid that you are 13 going to be accused of not knowing what is going on out j, 14 there. 8
'~l 15 MR. GILLESPIE: Well, and that is -- yeah, and 16 that is the other sense.
17 DR. BARTON: That is their part, whether it is 18 risk or not. 19 MR. GILLESPIE: When you start stepping back, if 20 you do less inspection, you have less information. 21 DR. BARTON: Right. 22 MR. GILLESPIE: When you are less intrusive, you 23 have less knowledge on a day to day basis. 24 DR. BARTON: Yeah. 25 MR. GILLESPIE: It is a different approach. And
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9 l l l 141 r'N 1 it is going.to be a challenge to get this into the culture ; (_)c '2 -of this. organization. 1 3 DR. BARTON: Oh, yeah. 4 DR. SEALE: Somehow you have to bring into the 5 attributes of this system the idea that you are inspecting 6 smarter. l 7 MR. GILLESPIE: Yes. 8 DR. SEALE: And maybe that 1 percent example is a 9 good lead-in to that line, to that point. 10 DR. MILLER: The same number of hours in 11 inspection on the 1 percent rather than on the 99, is that? l i E12 DR. SEALE: Well, -- 13 MR. GILLESPIE: That is really the focus of a
-s 14 ' risk-informed ~ inspection program is you are inspecting
-15 somewhat.less, but you are actually inspecting the risk 16 important things more.
17 DR. MILLER: That's_the whole objective. 18 DR. POWERS: I think it is important to consider a 19 human element of the inspector's life, it is what I call my
'20 proof-reading ~ theory of facility inspection. I sometimes 21; get'to inspect facilities. If I don't -- if I have people 22 working for me developing a facility and they don't make a 23 certain number of errors, my inspection becomes very poor.
24 As soon as they cross a threshold of a certain number of i g 25 errors, then'I get them all. And.so it seems to me that I g) (~ ANN.RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
g . _ _ _ _ _ . . _ _ . _ - . l I I l 142 ! 1 p ,_ . 1 would tend to portray this as -- it is true, 99 percent of ; \ ( . i
-\%...
2 .these things are not risk significant, but they may well I
'3- portend a degradation, and you need to bring them still to I 4 the licensee's attention, it is just that we don't do L -5 anything-about them.
6 MR. GILLESPIE: That was our earlier discussion.
. 7. DR. POWERS: Yeah, I think we had this earlier l
8 discussion. l 9 MR. GILLESPIE: Exactly. j l 10 DR. POWERS: That what you don't want is l l 11- inspectors being bored. l 12' MR. GILLESPIE: Yeah, you don't want the inspector 13 stepping aside, because what you are going to have.-- you
.I 14 are going to miss something you should have picked up. And I ' \-
15 'that is actually the challenge to the screening process, 16 which is the big IOU to the Commission of inspection 17 results. Having some false positives when you screen is 18 probably okay, In other words, some things that you do a 19: little more work on, you might not have had bo do a little 20 more work on, because I feel comfortable we are talking
, l 21 about fairly small numbers of things. But having a false i
22 negative is totally unacceptable. l 23 So the challenge in setting up -- it has got to an 24 asymmetrical uncertainty in the screening process, and Alan 25 -has taken this challenge on, so now, officially, he is ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 t 1
~.,
_. _ _ _ _ _ _ _ _ _ . . . _ . .. .. _ __ ._ __ n .y ._ . - .- _ . . . - . . . . _ . _ . _ . L i l: t i 143 : L I l' hooked. So -- and that is why it might end up being kind of kss '2 a multi-stepped thing, a rule-based thing that is looking at [ 3 certain ques'tions. 'Is it a train, is it a system? If it is 4 a program-failure, it is. kind of like asking a question -- 5 Are:there enough program failures that the coincident effect *
'6 'at any given point'in time is risk significant? That is-a j 7; realLtough. question to answer, and that starts getting at- ,
8 the sense of regulatory significance or not, because it is. i 9 not -- Was'it wrong and fixed, wrong and fixed, wrong and 10- fixed? If'it is wrong and fixedi and things don't happen l
-11 coincident to degrade several' systems or several trains, 12 then it won't. hit a safety threshold, yet, you-have to give 13 it to the licensee because you don't want all those things .g 14 ' happening.
( 15 So that, to me, is the one major, major, major 16 intellectual-challenge in this whole system that.we have 17 ahead, is.doing-that.for the inspection findings. Because
'18- 'what I said doesn't depend.on numbers of findings, it
' 19 ~ depends on the severity of the finding. So, in inspection 12 0 _ space,Twe may be dealing with the safety significance of the 21 . finding,- not the number'of findings. And, again, that is a I 22 'different approach. If.you have a lot, it has to be safety- )
j 23 significant, right, that is the intuitive feel. It may not 24 .be. And it is going to be very difficult, because now we 25- are counter-intuitive with our inspection force, and that is L Y L s
- ll~'\
i
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T T -- . .- .-- .. - .--.- - .- .
1 144 1 going to be -- that is going to be real hard. /~x
)
('_,/ 2 DR. MILLER: So an inspector who found one very 3 risk significant situation would get more credit, so to 4 speak, that somebody who found a hundred insignificant ones, 5 is that the thing you are alluding to here? l 6 MR. GILLESPIE: No , it is a matter of -- the 7 general sense is, gee, I found eight things wrong in 8 procedural compliance, and the typical enforcement letter l 9 that would go out, signed by a division director, would 10 declare it a programmatic failure, and it would be a big 11 deal in today's environment. I don't know what it would be 12 in tomorrow's environment, because if those eight procedural 13 items happen disconnected in time and never actually l
,s 1
14 affected a piece of equipment, and we are trying to develop l 1 N/ 15 a safety outcome score, or goal, or judgment, it puts it in 16 a different perspective. And it is not the way we have been 17 trained. 18 DR. POWERS: I have a question about public 19 perception. If I am a member of the public sitting next to 20 this -- living next to a plant, and I see less stringency on 21 the part of the NRC, the number of level 4 violations has 22 gone to zero, lots of things that on the face of it would 23 have been violations today are not tomorrow, and I, as a 24 reasonable person, come to you and I say, how come? Anc you 25 say, oh, they weren't risk significant.
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145 p_ 1 And I respond, gee, how would I know that? And / ) (/ 2 you say, well, it is real simple, you run the sapphire code 3 with the right kinds of inputs and outputs, and you take the 4 things and you do a risk assessment worth on this, and you 5 look at your 95 percent confidence level on a T-scale with 5 6 degrees of freedom and utility comes this number. 7 Do you think you have really persuaded me that you 8 are not -- 9 DR. MILLER: Have you persuaded anybody on this 10 Committee even? 11 DR. POWERS: You're not relieving a burden upon 12 your. licensee at the expense of increased risk on my part? 13 And by risk in that context, I mean my qualitative 73 14 perception of the risk. (* ') 15 MR. GILLESPIE: Actually, we are working very 16 closely with public affairs on trying to answer that 17 question. But there's some flaws in your basic assumption, 18 they are different than our basic assumptions. One, we 19 expect the inspector will write down when he sees something 20' wrong. Now, what we have to talk about is what do we call 21 it. The current enforcement policy change, as yet 22 unapproved,.but I understand the vote sheets are in, would 23 take all these level 4s and call them non-cited violations, 24 would not have us follow up on every single one of them, but 25 would have us audit, on an audit basis, to follow up on i
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l. l 146 them.
~
1 We would expect -- l (, p/. 2- DR. POWERS: If I am a member of the public who 3 knows a little bit about your processes, what I see is 4 violations used to be cited, now they are not. Violations l 5 used to be followed up, now they are not. And when I -- as , 6 a reasonable question, I mean I don't think it is an l 7 outrageous question, before I make any accusation, is I ask 8 you why, and you give me'this claptrap about risk analyses 9 and things like that. 10 MR. GILLESPIE: Like I said -- 11 DR. POWERS: What other conclusion can I arrive 12 at? 13 MR. GILLESPIE: Well, I think, first, the intent 14 is that we are not going to ignore the items. Now, what we
.hb/
' 15 are doing is calli ~ng them something different, and that 16 gives us, you might say, a public perception challenge to 17 deal with, because we are calling them something different, 18 and we will not be'following up on every single one we used 19 to follow up on. So we are going to have to very articulate 20 in saying why. We haven't been there yet.
21 In fact, one of the criticisms of this whole 22 ~ report, that they opened up the meeting with, was a member 23 of the public would have a very difficult time reading this 24 report. It'is not user-friendly.
-25 But let me go back and say why this is better than 10
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i 1 147 l 1 what we have,.and that is kind of where we are at right now. f'~ - ( 2- What we have right now in judging overall safety of the l 3 facility is the SALP process. The SALP process is actually i l 4. v e ry, very, very subjective, there is no doubt about it. In L 5 fact, the insights we would have from this program that we 6 have kind of run so far would be that a lot of facilities, 7 or a large group of facilities, are run so safely that it is 8 almost' impossible to discern between-them, yet SALP was 9 trying to-force itself to discern between several very well 10 run facilities because we were obligated to write a report. 11 This will allow us now to have more information
)
12 out.to the public directly related.to their operations and ) 1 13 more frequently, and that is the plus. The minus from the 14 system is we are not going to follow up on every one of the ' f A 15 items. The plus to the system is, by publishing the 16 performance indicators, and an interpretation of what they 17 mean on a quarterly basis, and something bigger on an ennual 18 . basis, we will be displaying to the public more and current 19- information on the safety of the facility. So we are 20 substituting one process for another process. 21 How'we put that together is going to be a real l 22 challenge, and how we communicate that to the public is 23 . going to be another real challenge. In fact, public affairs 24 . offered that maybe we could go talk to the League of Women 25 Voters and a whole bunch of other people to try to deal with i 1 i ANN RILEY & ASSOCIATES, LTD. I Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
a 148 1 the concerns. d J )) 2 DR. POWERS: I think the important thing, I mean I 3 hate to be so complimentary, and I will try to avoid that -- 4 MR. GILLESPIE: Oh, no, but this is a hard one. 5 .You'know, it is easy to deal with the darn technical issues. 6 It is very difficult to deal with the translation of what 7 you think.is a good judgment into you are backing off, you
- 8. are not doing as much.
9 DR. POWERS: One thing I liked about the draft 10 response you articulated here, you went for about two 11 minuten without ever once bringing up the word " risk" in 12 that, and I think that is the start of formulating a good 13 response, is bring up the risk after you have said all those 14 things you did, more information, better information, better s.) 15 interpretations and things like that. 16 Get to the results of going in this direction and 17 then if someone wants to ask you why.do you have all this 18 good insight, then you can bring up risk. Rather than 19 saying, oh, well, we have used these analyses that it is 20' impossible for me to reproduce, or even understand, to focus 21 1my efforts so that I get the most bang for the buck. You 22 know, that just leaves me cold as a response, whereas, when 23 -you tell me -- ah, you are getting much more, you are really 24 getting much more out of this, and much -- using much the
-.25 words you did and don't bring up this arcane technology that ANN RILEY & ASSOCIATES, LTD.
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149 _ -. 1 requires a degree in statistics to understand. N/s 2 DR. SEALE: A little confession may be good for 3 the soul here, too. I have heard that it is, at least in
.4 some circles, although it is not too popular these days.
5 DR. POWERS: But in both the states that you and I 6 live in -- 7 DR. SEALE: Very definitely. And the confession 8 may be, and it may take a little bit of homework to verify 9 it, but the confession may be that, of all those violations 10 that you had previously cited, the ones that you are no 11- longer publicizing -- or going into the record with, and so 12 on, were ones that had no impact on -- when you finally get 13 around to the point of public risk. 14 DR. POWERS: But I don't think I would try to
.O 15- bring that story to the public --
16' DR. SEALE: Not up front. 17 -DR. POWERS: -- because he didn't think -- he 18 didn't know whether they did or not. All he knew was that 19 they were being stringent and now they are not. I think -- 20 I really like this idea of no, no, no, it is not less, you 21 are getting way more. I really.like that approach. 22 DR. SEALE: Well, we are looking at the things 23 that count. 24 DR. POWERS: I wouldn't even go that far. I would 25 say we are looking -- b ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
150 1 DR. MILLER: 'You are getting more. () s 21 DR. POWERS: Tha have always looked at the things 3 that count, and we are continuing to look at the things that 4 count, and we are giving you far, far more than you ever got 5 before, because you used to get these funny looking SALP 6 scores that meant absolutely nothing to anyone on the face 7- of the planet, not even those in the NRC. Now, you are 8 .getting.all this other wonderful stuff. I think that is the 9 germ of a public -- of risk communication that may actually 10 work. 11 MR. GILLESPIE: It's funny, that's where Bill 12 Beecher came, in a lengthy meeting we had with him 13 yesterday, trying to brainstorm. It was tell them what you 14 are giving them, don't --
,/~T k-) 15 DR. POWERS: That's exactly right.
16 DR. MILLER: Tell them the glass water is getting 17 fuller not empty. 18 MR. GILLESPIE: It is getting fuller, not emptier, 19 yeah. l 20 DR. BARTON: I think we need to wrap this up, and l- 21 figuring out what do we want to talk about at the full 22 . Committee meeting, I guess next week. 23 DR. APOSTOLAKIS: We are all here. 24 DR. BARTON: Pardon? l L 25 DR. APOSTOLAKIS: We are all here. ((N
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_ - .- - . . _ . .. ~.- - . - , . . . . 151 1 DR. BARTON: Yes, we are all here. What else? (d 2 What -- 3 DR.-APOSTOLAKIS: Let's take the time to write a 4 letter. Well, I don't think we need a presentation, we are 5 all here. 6 DR. SEALE: Well, the only thing I can think of is 7 if we ask them if they could, at that point, tell us what L 8 additional information you are liable to be able to put in L 9 the Commission letter. 10 DR BARTON: The supplemental information. 11 MR. MADISON: I think at this time it is l 12 premature. We have got a draft concept that we are refining 13 and I really want to put it through a lot more exerciser.
N 14 before we make it -- bring it here.
i
) 15 DR. SEALE: Okay.
16- DR.'BARTON: What about the policy issues that 17 remain that you mention in this document, evaluating 18- interface of Part-50, revisiting event response evaluation, 19 revisiting N-plus-one, organizational impact. Is that 20 something that you are prepared, that we could talk about,
-21 that we could address in our letter? Since the Commission p 22' -has to make decisici. on those policy issues?
23 MR. MADISON: No, the Commission -- those four 24- ' policy issues.were a heads-up to the Commission. And we 25' actually had a fair amount-of discussion on. These are not ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036
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152 1: today's decis' ions. I 2' DR. BARTON: Okay. 3- MR._ MADISON: _They are next year's decisions. In 4 somc' cases, they:are six months away. But the basic j '5 ' question was, _if you do go.down this path, and there is less 6 . inspection,-but you keep N-plus-one; residents tend to be 7f generalists, not specialists. EL DR. BARTON: Right. , 9 MR. MADISON: -If,you need engineering specialists 10- and what you have got is generalists living at the plants, 11' that gives you an organizational problem and causes you to
-12 need, if you go down this path very far, to step back and 13 say, I have got an institutional problem I have to address, 14 not a technical problem. '
, /y 1/ : 15 - The reco'nciliation or harmonization with Part 50,
-16 that was our number one issue on the list.
17 DR. BARTON: Right. Right. i 18 MR. MADISON: It is just highlighting to them, we ' 19 are'getting out in front and if Part 50 changes their scale, j i 20 'then'we are going to have to have feedback from that, and 21 :they are going to have to be cognizant of Commission 22- decisions made. If the Commission approves our basic scale 12 3 of_where our bands are, then it is going to be hard-pressed 24 for the Commission to necessarily change their mind without 25 some justification later. So approving what we are doing L(Q-; j -ANN RILEY & ASSOCIATES, LTD. L Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036-
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i 153 1 actually has future implications that-says hey, the bands j ) 2 .are set. Here's the licensee response zone for whatever it 3 is. I 4 So, no, those four issues were a heads-up. I 5 think'they need to.bie dealt with in the course of probably . I 6 the_next 12 months. They can't be ignored, particularly if 7 we are' successful -- I 8' DR. BARTON: That's true. Right. ' 9 MR. MADISON: -- with the pilot program, but not 10 in the next three months. 11 DR. BARTON: Okay. What else do we want to hear? 1:2 George, I think the problem we've got is it's already in the 13 Federal Register, right? _s 14 DR. APOSTOLAKIS: Y'ou can take that time to write l 15 a letter. 16- DR. POWERS: Or at least a summary from the 17 Commission Chairman in order to -- or from the Subcommittee 18 Chairman at the very least. I don't think it would be a bad 19 idea to bring up these policy issues even though they are 20 'six months down the line, because that is about our time 21 schedule for thinking about'the subject. 22- DR. BARTON: Okay. 23 DR. POWERS: And it would be opportune for putting
;24 -it-on our agenda so that when you come in here, we are not 25 having to spin up from zero -- that and a summary from the O ANN RILEY'& ASSOCIATES, LTD.
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_._.~_9__. 154 l' Subcommittee Chairman would fulfill our obligations.
. 2 DR. BARTON: At the full Committee meeting.
3 DR.. POWERS: At the full Committee meeting. 4 DR. BARTON: Okay. 5 DR. APOSTOLAKIS: How much time do we have? 6 DR. BARTON: I don't know. 7 MR. MARKLEY: 10:30 on Wednesday. 8 DR. MILLER: One of the policy issues -- it may 9 not be a policy issue -- we raised a concern about the fact 10 that the inspection assessment process is leading the 11 regulatory situation. Is that an issue you want to raise? 12 DR. POWERS: Yes. I think that's a -- 13 DR. MILLER: I am beginning to think that maybe
,_ 14 one could look at the advantages of this leading the
\' l 15 regulatory process -- if we want to look at the half a glass 16 of water fuller.
17 DR. POWERS: And I will remind you -- 18 DR. MILLER: It might lead them in the right < i 19: way -- l 20 DR. POWERS: I would still like to know about your i 21 validation of your tools for your Appendix H and Appendix I l 22 analyses. 23 MR. GILLESPIE: That's an IOU we'll take away and l 24 get back on Sapphire Code and what happened to that. l-25 DR. WALLIS: Well, I took a vow of silence when I l. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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l l '. l 155 l 1 came in this morning. ' n).
$_- 2 DR. POWERS: Why?
3 DR. MILLER: It's about those hundred Senators i 4 being quiet. 5 DR. WALLIS: But Dana woke me up when he said how t' 6 would the public perceive this, and I think it is not just a l 7 question of public perception but too many of these changes, 8 which I think you have done very well, appear to be l 9 motivated by what is good for the utility or what is good 10 for the administrators in the NRC, and it would be good if 11 somehow it could be put in perspective to give a really fair l 12 measure of what has the effect of all this been on nuclear 13 safety. 14 I don't know how you would do that but really that C)
\~ 15 is a measurement I would like to see or get some better feel j 16 -for. I'like what you are doing, but how do I tell if it's 17 been good for nuclear safety or are we backing off or what?
18 Maybe we back off but it's still better for 19 nuclear safety,-but how do I know? 20 MR. GILLESPIE: Yes, that's -- let me explore that 21 a little, because this is kind of a key point underlying the 22 paper. 23 In the paper it talks about this is a process to
-:24 ensure that safety is maintained so'we are clearly not 25 putting something in place, and from the way Pat described D
--Q - ANN RILEY & ASSOCIATES, LTD.
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156 l 1 his statistical and the way the first threshold was set, we [8 lNs,) 2 are clearly trying to maintain what we believe is an 3 acceptable level of safety. We are not forcing it to be 4 better. l 5 .QuiteLhonestly, I don't think we could force less 6 than the .8 scrams on the average per plant that exists f 7 today, so how is this good not.to do that? That is a public 8 perception problem. You mean the NRC is not forcing it to l l 9 be better and better and better and better? 10 .I don't have a good answer for that because we 11 haven't digested it. We understand it but that is kind of 12 one of those things that is hidden in the paper. 13 DR. KRESS: Well, let me take a stab at that at
. e- 14 the risk of breaking my vow of silence.
1
's / 15 DR. POWERS: What is this vow of silence?
16 DR. KRESS: This process tW3 are going through 17 could lead up to this bit of a problem that George pointed 18 out that you will find some plants for example that may get 19 outside your inspection lines but then you go in and look at 20 it more closely and find that they still comply with all the 21' regulations, and what you will have done there is perhaps 22 this particular plant while it still complies with the
- 23 regulations as a. specific plant has -- let me put it this 24 way -- not quite as good a desired risk status.
25' MR. GILLESPIE: Yes, that's -- ; i O) ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
I 157 l 1 DR. KRESS: And it is because your regulations t (s\ y ,/ 2 have allowed that. Now this allows you to focus on the 3 problem of risk, which is really your regulatory mission, 4 and you can say, well, have our rules done the job or not { l 5 ,and which part of the rules are keeping us from doing our 6 job and it will allow you to go back and say now do we need 7 to change the rules some way and in what manner do we need 8 to change them in order that we can get plants within a risk 9 status that we would better desire. 10 Now of course that raises questions of backfits or 11 substantial improvements in regulatory analysis, but I mean 12 you're stuck with that, but it will allow you to focus your 13 attention on the rules and whether they are doing the job
, 14 correctly or not, and I think it is worthwhile.
i )
%/ 15 I mean that is a public benefit that is going to 16 come from it'in my mind.
17 MR. GILLESPIE: I'm going to say it kind of 18 harshly. I don't mean it -- I don't know how else to say 19 it, but if the industry disagrees with the basic premise 20 that we have tried to pick thresholds that in fact they 21 could fairly operate within and in normal circumstances at a 22 reasonably well-run plant, not a perfect plant, it can
-23 operate within those thresholds. If that basic premise is 24 incorrect, the industry has to stand up and be counted and 25 say that. ,/ m !. ) ANN RILEY & ASSOCIATES, LTD.
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158 1 DR. KRESS: That may be the way -- your hands may (~ '
~ (j - 2 be tied --
1 3 MR. GILLESPIE: I can only take on so much burden i 4 and this team in developing an approach that has to be 5 somewhat generic, and it has to give the public the ability j 1 6 quite honestly to compare one plant to another, but in 7 comparing one plant to another when you get structured like 8 this, it's there and, yes, one plant could have, if it 9 continually violated a threshold but was in compliance with 10 all the rules, it could have a less desirable public image, I 11 and that is kind of -- you know, the comment on SALP l 12 today -- a similar comment. 1 13 I hope it will be less of a problem than the I 14 system today gives us in that same arena but we will likely 15
~
have not fixed it perfectly, so the industry now has to 16 speak up and that is why this thing is out for comment. I 17- DR. BONACA: Your point is a concern I had before 18 when I talked about the fact that most units meet those 19 kinds of quantitative criteria that we have here. From past I
'20- experience I can remember exact cases where units met those
- 21. criteria that were provided by INPO and so on and so forth 22 entirely, and yet their performance was very negative 23 because of other issues which are tied to inspection.
24 Now to the degree to which you have a much more 25 scrutable process here, it's going to be very hard to deal ANN RlLEY & ASSOCIATES, LTD. 3 Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
159 1 with that kind of situation. 2 I.am trying to understand, you know, because I do
- l. 3 believe that the inspections bring about a lot of insights 4 that tell you whether or not a plant is doing well. l 1
5 What I am trying to say is that the numerics may 6 force you to disregard a lot of these other insights from j l 7 inspections if consistently they give you all greens. J 8 See what my concern is now? i 9 MR. GILLESPIE: Yes, and this is the crux of a i 10 past criticism we have gotten from GAO in past years. Let ! l 11 me take what you have just said, if I could, to the extreme, ] 12 .and that is when we go in and shut a plant down because all 13 of a sudden -- Cook. 14 We did an A&E inspection, raised questions about 15 ~ engineering, went in and looked at engineering even more. 16 They went in and looked at their engineering even more. The l 17 ice columns became -- it just -- it kind of, you might say,- 18 expanded to the point where'the facility has been shut down 19 for an extended period now to get the design process 20 . straightened out. 21 One of the things we were being pressed several 22 years ago was to always identify a problem to allow a 123 . licensee to correct it before it got to the point where you
~
~24 had to shut down to correct it. I believe -- and I am not 25' ' going to commit to the team, unless they want to chime in,
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L 160 1 that these indicators plus the inspection -- and I can't (. y ,/ 2 take my eye that there's still substantial inspection being { 3 done in very focused areas, particularly engineering, will ! 1 4 still give us an early enough indication that I think we can 5 beat that goal. . l l 6 'Now we looked back-retrospectively and Cook was 7 one of the ones that Bruce Mallett looked back on and said j 8 there is no indicator for this problem they had in L 9 engineering -- are we still looking at engineering? And 10 Bruce said yes, we are still looking at engineering, and we 1-11 would have had an opportunity to pick that up. 12 Cook still would have been shut down, because you l 13 would have found a problem in engineering, they would have 14 pursued it more, the problem would have gotten bigger, and 15' they'd be shut down. The Cook shutdown by this new process I 16 likely would not have been avoided. 17 DR. MILLER: '
't it might have been shorter.
18 MR. GILLESPI'*i It might have been shortened 19 because we would havr. a different perspective on it possibly 20 but I don't think the shutdown itself would have been 21 avoided, so for Cook we wouldn't have made this goal that 22 was set up for us. 23 ' Inspection insights are still going to be there. 24 I~ hope they are the insights in the right area. We have 25 .tried'to focus them that way. l
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161
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1 I would like to bring up one other thing that is i K/ 2 in the paper and no one here touched upon. It's something t 3 that Mike is going to grimace when I say it, and it's the -- 4 what do we call it? -- the executive exemption? No -- 5 MR. JOHNSON: Executive override. l-i 6 MR. GILLESPIE: Executive override. We are 7 allowing a five percent executive override and I regret the l 8 terminology but I am pleased with the concept. 9 In fact, if there are significant insights that 10 cause us in a very limited number of cases to question the l 11 performance indicators, we do need to go in and examine 12 those cases and if we find the indicators are correct, fine. ! 13 That reinforces where we're at. If we find they were wrong, t gs 14 the executive override concept has great value in program iN 15 evaluation space relevant to being kind of like a proof 16 test. l 17 One of the things that we are going to be kind of 18 committed to is kind of looking at the terminology and the 19- basis we had in there for that. [ 20 David Lochbaum, UCS, says I don't like these 21 executive overrides at the Commission meeting -- there
- 22 should be zero executive overrides -- because it had a l 23 negative connotation, but actually having an occasional 24 question to test the system is probably a positive move, so t
l 25 we are going to need to go back and re-look at how we have l!
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m 162 1 termed that in there to take care of that concern, not f')\ y, s-2' everyplace but I think as a programmatic group in l 3 Headquarters we have to be conscious that we need to test ' l L 4 our assumptions somehow, and the only way to do that is from j 5 the outside looking in. You can't necessarily do it always
- from the inside looking out.
t 7 DR. SEALE: Are you familiar with the term "the 8' halo effect" -- l l 9 MR. GILLESPIE: Yes. I 1 10 DR. SEALE: The halo effect was on the basis of I 111 personalities. The executive override that you are talking l 12 about is on the basis of specific physical observables. I 13 think that is a reasonable trade, and not have the 14 personalities which have been a problem in the past. O\ss/ 15- MR. GILLESPIE: So that is one aspect in there. 16 There was some discussion on that. You know, if that is a 17 piece -- you know -- those are the kinds of pieces and kinds 18 of comments that we're searching for that will help us hone 19 the system down or in, get it in tune, and move forward with ! 20 it. I 21 I think the concept was right, the move was right, i L 22 .it's the right thing to do, but we worded it wrong. 23' DR. SEALE: Yes. ; 24 MR. GILLESPIE: And that just comes as time 25 evolves and you say, well, why did we say it that way? Why
.Ir)'
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163 1 do we really think this is the right thing to do? g k, ,) 2 That is kind of an evolving nature, which is why s 3 we are not committed to rewriting this entire 400 pages, but 4 now taking-the comments, adding them to these 400 pages, and I 5 then moving forward and writing the actual program j 6 documentation. 7 With that, I am worn out. j 8 DR. BARTON: Well, one thing. I know you said you 9 didn't want to rewrite the document but there's areas -- the I 10 document could probably be streamlined and a lot thinner i 11 because there's a lot of redundancy. 1 12 Also, I don't remember whether there is a master 13 table of acronyms in there, but you use ERO in two different ,, 14 sections, Emergency Response and then Effluent something and K- 15 Radiological Emergency. You may want to either put a master 16 acronym thing in here or else change one of the two because 17 you use it in.two separate -- 18 MR. GILLESPIE: You can tell we had multiple 19 authors putting this -- 20 DR. BARTON: Yes, and that is probably the result 21 and why it got that way, but you want to look at that so you 22 don't end up with confusion down the road or at least put a 23 master -- 24 MR. GILLESPIE: Pat's comment was more than 25 multiple. In fact, there was about 24 authors who wrote ,~ () . ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
'164 11 different sections.
fy_,o 2 DR. MILLER: There.is strength in the weakness. 3- DR. BARTON: Anything else we want to talk about ) 4 next week or:here that we haven't heard before? If not, ) ' I
- 5. then --
6~ DR. SEALE: I'have an entirely different matter to 7 ask the people. 8- DR. BARTON: While these guys are here? I 9 DR. SEALE: No , no. Just don't.you guys leave, 10 that's all I am saying, the members. 11 DR. BARTON: And we are done and we will break for 12 lunch. 13 Thank you for all the hard work and coming in here l 3r. - 14 and putting it up again. I guess we are adjourned. !
^t 15 [Whereup'on, at 12:31 p.m., the meeting was 16 concluded.]
17
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-19 20 1
21 22-24. 25 lr'N f h,,) , ANN RILEY & ASSOCIATES, LTD. j Court Reporters 1025_ Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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REPORTER'S CERTIFICATE This is to certify that the attached proceedings
} before the United States Nuclear Regulatory Commission in l the matter'of:
l i. l NAME OF PROCEEDING: MEETING: PLANT OPERATIONS AND t RELIABILITY AND PROBABILISTIC RISK. ASSESSMENT l' DOCKET NUMBER: PLACE OF PROCEEDING: Rockville, MD were held as herein appears, and that this is the original () transcript thereof for the file of the United States Nuclear Regulatory Commission taken.by me and thereafter reduced to typewriting by me or under.the direction of the court reporting company, and that the transcript is a true and c
~
accurate record of the foregoing proceedings. (I b 'D% j Mark Mahoney Official Reporter Ann Riley & Associates, Ltd. l
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l i INTRODUCTORY STATEMENT BY THE CHAIRMEN OF THE O JOINT SUBCOMMITTEES ON PLANT OPERATIONS AND RELIABILITY AND PRA 11545 ROCKVILLE PIKE, ROOM T-2B3 i ROCKVILLE, MARYLAND ' JANUARY 26,1999 I The meeting will now come to order, This is a joint meeting of the ACRS Subcommittees on Plant Operations and on Reliability and Probabilistic Risk Assessment. I am John l Barton, Chairman of the Subcommittee on P%nt Operations. Dr. George Apostolakis is l Chairman of the Subcommittee on Reliability and PRA. ACn3 Members in attendance are: Mario Fontana, Thomas Kress, Don Miller, Dana Powers, Robert Seale, William Shack,' Robert Uhrig, and Graham Wallis. Also in attendance is Mario Bonaca who has been selected as a new Member. He is l expected to be appointed to the ACRS in the near future. ' The purpose of this meeting is to continue the Subcommittees review of proposed improvements to the NRC inspection and assessment programs, including initiatives related to development of a risk based inspection program and performance indicators. The Subcommittees will gather information, analyze relevant issues 'and facts, and formulate proposed positions and actions, as appropriate, for deliberation by the full h Committee. Michael T. Markley is the Cognizant ACRS Staff Engineer for this meeting. The rules for participation in today's meeting have been announced as part of the notice of this meeting previously published in the FederalRegisteron December 21,1998. A transcript of the meeting is being kept and will be made available as stated in the Federal Register Notice, it is requested that speakers first identify themselves and speak with i' sufficient clarity and volume so that they can be readily heard. We have received no written comments or requests for time to make oral staternents from ! members of the public. ) i (Chairman's Comments if any) We will proceed with the meeting and I call upon Messrs. Frank Gillespie, NRR, and Mark l
.Cunningham, RES, to begin.
l l l l O i
.. - - -- . _ . . . . . - - - . . . . . . . - . - . ~ . . . - . . . . ... - . - . - _ _ - - . .
i s i i REVISED 1/21/99 l%
'( ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l
MEETING OF THE JOINT SUBCOMMITTEES ON RELIABILITY AND PROBABILISTIC RISK ASSESSMENT AND ON PLANT OPERATIONS ROOM T-2B3,11545 ROCKVILLE PIKE, ROCKVILLE, MD JANUARY 26,1999
)
-PROPOSED SCHEDULE-TOPIC PRESENTER IIME ;
I)- Introdmetion 8:30-8:40 am o Review goals and objectives J.Barton, ACRS for this meeting e Review previous deliberations and J.Barton, ACRS issues identified in ACRS interim report G. Apostolakis, ACRS dated December 16,1998 l
- 2) NRC Presentation 8:40-10:15 am o Introductory remarks F. Gillespie,NRR M. Cunningham, RES e Recommendations for reactor oversight M. Johnson, NRR process improvements (SECY-99-007) B. Mallett, RII P. Baranowsky, RES Brief overview of framework, inspection and enforcement Assessment program including integration ofrisk insights Transition Plan Reconciliation ofpublic comments Response to issues in Staff Require-ments Memoranda
*
- BREAK *
- 10:15-10:30 am
- 3) NRC Presentation - continued 10
- 30-12:00 noon e Recommendations for reactor oversight M. Johnson, NRR process improvements (SECY-99-007) B. M allett, Ril
' including items noted above P. Baranowsky, RES
.. . . . - . . . - - . - _ . . . . - . - - . .. . . . . - . - . . - . . _ - - - - . - . ~ . . . . . ~ . . _ -
?
- 4) General Discussion and Adjournment 12:00-12:30 pm
- General discussion and comments J.Barton, ACRS !
by Members of the Subcommittee, G. Apostolakis, ACRS l items for discussion by the full ACRS NOTE: Presentation time should not exceed 50% of the total time allocated for a specific item. Number of copies of presentation materials to be provided to the ACRS -35.
Contact:
M. Markley l 1 l l 1 1 O e i I O.
. O ._ . O .
O . k l FAX TRANSMITTAL s e=v==
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l " nk n%db "'"OL&T ' ~' l "..."'~' MP A -- l _ _,,,, ,. ,,,, .,,, - - - - t RISK-INFORMED BASELINE INSPECTION PROGRAM
-i 3
PROJECT METHODOLOGY 5 a e Used framework output as guideline ' e Developed program as replacement for current core program g e Benchmarked some other agency programs 5 e Solicited stakeholder issues and comments on y program e B - E 5 s
i .q - 3 (O RISK INFORMED BASELINE INSPECTION PROGRAM a' l I
, Oversight Framework ,
Performance Indicators Baseline Inspection i Assessment Process j i Cornerstones v l Inspectable Areas v
> Scope E Plan Inspections Select
-- - Sample s-Basis Documents RIM No. 1 A
~
q Plant V Specific Mod. RIM No. 2 Increase' Inspection . A . no ___ yes_ Cornerstone 's Findings >' Inspect < Objectives Assessment j Met _ J , l i Risk l Scale l l X. ' u 50/50 3Dttd IId OdNSO 646PE95 POP EE:LO 6661/93/10
o O O' ' ACRS PRESENTATION REACTOR OVERSIGHT PROCESS IMPROVEMENTS JANUARY 26,1999 FRANK P. GILLESPIE PATRICK W. BARANOWSKY BRUCE S. MALLETT MICHAEL R. JOHNSON
,i
i I BRIEFING OUTLINE
- Overview
- Framework l
- Risk-informed Baseline inspection Program i
- Assessment o Transition :
l, P o e ...l
O O O BACKGROUND ; e Commission briefed (11/2/98) on regulatory oversight framework
- concept & plan
}
e Commission directed staff to finalize development of conceptual changes e Interactions with stakeholders (14 meetings during 1998) e Groups (framework, inspection, & assessment) completed development of concept ,
- inter-office participation (Regions, AEOD, NRR, OE, RES) 3 r
COMMISSION PAPER
- Seeks approval of CONCEPT, SCOPE, and TRANSITION PLAN (pilot)
- Comments on the details of the proposal are being sought in parallel from public, industry, and internal stakeholders
- Details will be finalized through accomplishment of activities in the transition plan
- Final Commission approval requested by March 1999
- e --
e.
o O O~ 'l CONCEPTS t e Regulatory oversight: performance results will be evaluated to determine when enhanced NRC diagnosis of licensee performance is warranted. A baseline inspection program will be performed for all sites. e Framework: performance indicators and risk-informed inspection results will be used to measure licensee safety performance. Results will be evaluated using equivalent risk- ' informed scales. (thresholds) e inspection: inspections will be risk-informed. Inspection i results will be evaluated for their risk significance using a rules-based (examples) scale. l, e Assessment: a streamlined, structured review process will be 6 used. An action matrix will provide consistency in making ! response decisions. e Enforcement: consistency with assessment results will be i sought. Several options are being evaluated. ,! 5 I
. . _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ . _ _ . _ . _ _ _ . . _ _ __._______.___ _ _ _ _ ______.m - -___ _ _ _ _ ___ __-__._ _____ _ _ _ _ _ _ _ _ _ _ _ _ _ _
POLICY ISSUES ,
- Interface with 10 CFR Part 50
- Event response and evaluation processes
- N+1 policy for resident inspector staffing r
- Organizational impact i i
[ 7 k l h .
o O O " SCHEDULE / RESOURCES e 6 Month Pilot Program
- coordinated with industry /NEl
- Pl data collection
- baseline inspection program
- pilot assessment and enforcement approaches e Resource savings
- Factored into FY2000 budget 7
! TECHNICAL FRAMEWORK
- Cornerstones of safety and key performance attributes o Relationship of performance indicators to risk-informed inspections 1
- Performance indicators and performance thresholds
- Conceptual model for licensee performance evaluation
- Benchmarking performance indicators 1
8 8 9 e .
O O O - ' REGULATORY OVERSIGHT FRAMEWORK , i 1 NRC's PUBLIC HEALTH AND SAFETY ! Overait AS A RESULT OF CIVILIAN " Satety NUCLEAR REACTOR M,ssion i OPERATION s I Strategic REACTOR RADIATION
- Performance SAFETY SAFETY SAFEGUARDS Areas
\
\
Cornerstones "m" * $7' > k"y PUBLE OCCUPJmONAL i
. . . . . . . . . . . . . HUMAN " " " " " ~ ~ ~ ~ ~ SAFETY CONSClOUS WORK ~ ~ ~ ~ ~ ~ ~ ~ ~ " " ' PROBLEM ~ ~ " * " " "
PERFORMANCE ENVIRONMENT IDENTIFICAT10N AND RESOLUTION
- PERFORMANCE INDICATOR
= INSPECTION
- OTHER INFORMATION SOURCES
- DECISION THRESHOLDS 9
i t PERFORMANCE INDICATORS (PIS) AND RISK-INFORMED INSPECTION 1 e Pls and risk-informed inspection activities cover a broad sample of risk significant areas-e Pls used to the extent practical as the performance measurement index ; e Risk-informed baseline inspection program provides:
- complementary inspections in risk important areas not covered by Pls :
- supplemental inspections to cover PI limitations t
- verification inspections of PI accuracy e Reactive inspections address:
- declining performance (cause, corrective action evaluation)
- significant event and generic issue follow-up 10 h .!
/~~N o
. i v
O ' t i MITIGATING SYSTEMS CORNERSTONE DETAILS l l MITIGATING SYSTEMS i CONFIGURATION CONTROL EQUIPMENT LINEUP EQUIPMENT LINEUP (AT POWER) (SHUTDOWN) Pi = SSPI Ril MRV i SSPI = Safety System Performance Indicator MR = Maintenance Rule Ril = Risk informed Inspections V = Verification and Validation ; 11 i
TABLE 1 - PERFORMANCE INDICATORS Cornerstone Indicator Thresholds increased Regulatory Required Regulatory Unacceptable Rasponse Band Response Band Performance Band Unplanned scrams per 7000 critical hours >3 >6 >25 initiating Events (automatic and manual scrams) Risk-significant scrams per 3 years >4 >10 >20 Transients per 7000 critical hours >8 N/A N/A Safety System HPCI and RCIC >0.04 >0.12 >0.5 Mitigating Systems Performance Indicator HPCS >0.015 >0.04 >0.2 Unavailability Emergency Power >0.025 >0.05 (>2EDG >0.1) >G.1 (>2EDG >0.2) RHR >0.015 >0.05 TBD AFW >0.02 >0.06 >0.12 HPSI >0.015 >0.05 TBD Safety System Failures >5 - prior 4 qtrs N/A N/A Reactor coolant system (RCS) >50% of TS limit >100% of TS limit N/A Barriers
- Fuel Cladding specific activity RCS leak rate >50% of TS limit >100% of TS limit N/A
- Reactor Coolant System
- Containment Containment leakage >100% L, N/A N/A Emergency Emergency Response Organization <75% - prior 6 <55% - prior 6 N/A (ERO) drili/ exercise performance months; months; Preparedness
<90% - prior 2 <70% - prior 2 years years ERO readiness (percentage of ERO <80% - prior 2 <60% - prior 2 N/A shift crews that have participated in a years; years; drill or exercise in the past 24 months) <90% - prior 3 <70% - prior 3 years years 12 0 9 6 -
f'8 R 0 [) TABLE 1 - PERFORMANCE INDICATORS Cornerstone Indicator Thresholds increased Regulatory Required Regulatory (Jnacceptable Response Band Response Band Performance Band Alert and Notification System performance <94% per year <90% per year N/A (percentage of availability time) Occupational Occupational exposure control 6 or more 12 or more N/A Radiation Safety effectiveness (the number of non- occurrences in 3 occurrences in 3 compliances with 10 CFR 20 Requirements years (rolling years (rolling for (1) high (greater than 1000 mrem / hour) average); average); and (2) very high radiation areas, and 3 or more 6 or more uncontrolled personnel exposures in 1 year in 1 year exceeding 2% of the stochastic or 10% of the non-stochastic limits) Public Radiation Offsite release performance (number of 7 or more events 14 or more events N/A Safety effluent events that are reportable per in 3 years (rolling in 3 years (rolling 10 CFR 20.10 CFR 50 Appendix I, Offsite average); average); Dose Calculation Manual, or Technical 4 or more events 8 or more events Specifications) in 1 year in 1 year Physical Protection Protected Area security equipment <95% per year <85% per year N/A performance (availability of systems to perform their intended functions) Vital Area security equipment performance <95% per year <85% per year N/A (availability of systems to perform their intended functions) Personnel screening process performance 3-5 reportable 6 or more N/A (acceptable implementation of the access events reportable events authorization program) Personnel reliability program performance 3-5 reportable 6 or more N/A (acceptable implementation of the fitness- events reportable events for-duty & behavior observation programs) 13
^ - - -
~
CONCEPTUAL MODEL FOR EVALUATING LICENSEE PERFORMANCE INDICATIONS
- GREEN -
(ACCEPTABLE PERFORMANCE - Licensee Response Band)
- Cornerstone objectives fully met
- Nominal Risk / Nominal Deviation From Expected Performance
- WHITE -
(ACCEPTABLE PERFORMANCE -Increased Regulatory Response Band)
- Cornerstone objectives met with minimal reduction in safety margin
- Outside bounds of nominal performance
- Within Technical Specification Limits
- Changes in performance consistent with ACDF<E-5 (aLERF(E-6).
- YELLOW -
(ACCEPTABLE PERFORMANCE - Required Regulatory Response Band)
- Cornerstone objectives met with significant reduction in safety margin
- Technical Specification limits reached or exceeded
- Changes in performance consistent with ACDF(E-4 (ALERF<E-5)
-RED-(UNACCEPTABLE PERFORMANCE - Plants not normally permitted to operate within this band)
- Plant performance significantly outside design basis
- Loss of confidence in ability of plant to provide assurance of public health and safety with continued operation
- Unacceptable margin to safety j
l
-UNSAFE PERFORMANCE -
14 h . .
O O O BENCHMARKING THE PERFORMANCE INDICATORS e Benchmarking was against plants with histories of poor, declining (trending to poof haverage, and superior performance per current NRC assessment processes; ASP results were also considered
- Observations:
- vast majority of plants with indications of declining performance had Pls in the increased regulatory response band; a few Pls were in the required regulatory response band; no Pls were in the unacceptable performance band
- Pls differentiate between watchlist plants and superior plants
- transients and safety system failures are the best differentiators
- Pls show some ability to lead watchlist plant performance declines
- several cases where watchlist plant performance issues do not correlate with Pls, the performance issues were more suitable to inspection
- In most cases, Pls do not lead ASP events 15 i
i RISK-INFORMED BASELINE INSPECTION i PROGRAM PROJECT METHODOLOGY e Used framework output as guideline e Developed program as replacement for current core program e Benchmarked some other agency programs e Solicited stakeholder issues and comments on program 16
o O O ~
~i
~
PRODUCT PRODUCED
- Document entitled, "NRC Nuclear Power Reactor Baseline inspection Program"
- Risk-informed matrices
- Estimated resources needed for implementation
- Preliminary analysis of how proposed program would lead inspector to areas where there have been past problems in plant performance i
17 i t
I i KEY CONCEPTS IN PROPOSED PROGRAM j e Minimum level of effort at all power reactor licensees
- Licensees performing better than established thresholds receive baseline i
e increases above baseline will be termed reactive or initiative as in current program
- Scope of program defined by inspectable areas
- linked to cornerstones of safety ,
- inclusion in program based on risk significance and need I j
to monitor a cornerstone attribute
- Basis documents for inspectable areas
- scope within area defined
- why inspect defined j
- how inspection relates to performance indicator !
18 f f I
-w------- _ _ _ - - - - _ - -- _- --- -- __-- - - - -_ - - - _ _ . -
RISK-INFORMED BASELINE INSPECTION PROGRAM
- Process for planning inspections
- - based on 12 month cycle i
- guided by risk informed matrices and plant specific data
- objective of assessing performance relative to cornerstone objectives
- Verification of performance indicators
- only required inspection in areas where performance indicators are all-inclusive
- Review of licensee programs for problem identification and resolution
- with other inspection of inspectable areas
- focused effort on biannual basis
- Inspection findings
; - guidance for categorizing findings based on significance l 19
I i ! t i e [ f L REACTOR PERFORMANCE ASSESSMENT ! PROCESS l
- Key concepts l
t
- Assessment activities !
- Action matrix !
I e Process evaluation i 1 e i i 20
O O O ~t PURPOSE i e Assemble and integrate performance indicator and inspection results within each of the cornerstones e Arrive at objective conclusions regarding plant performance 1 i e identify resultant regulatory actions based on the conclusions
- Communicate assessment results and actions to the public e Verify the actions taken are effective 21
b KEY CONCEPTS l
- Process is based on use of thresholds l
l
- Considers performance for a 12-month rolling window l (some Pls have a 3-year window) e Provides a graded approach e Eliminates watchlist and superior performer recognition ,
- Plants in extended shutdown covered under other NRC oversight processes (IMC 0350)
I l 22 I l : O $ .f
i ASSESSMENT ACTIVITIES
- Organizing and compiling data
- Comparing data to a standard
- Deciding on actions
- Implementing actions l
- Provide process feedback to ensure actions have been effective I
t I i 23 i
i REVIEW SYSTEM Level of Frequency / Participants Desired Communication Review Timing (* indicates lead) Outcome Continuous Continuous SRl*, RI, regional Performance None required inspectors, analysts awareness Quarterly Once per quarter / DRP: BC*, PE, Input / verify Pl/PIM Updated data set Two weeks after SRI, RI data, detect end of quarter early trends Mid-Cycle At mid-cycle / Divisions of Reactor Detect trends, Six month Three weeks Safety (DRS) or DRP plan inspection inspection after end of DD*, DRP and DRS for six months look ahead letter second quader BCs End-of-Cycle At end-of-cycle / DRS or DRP DD*, Assessment Assessment letter Four weeks R As, NRR of plant and six month after end of representative, BCs, performance, inspection look assessment principalinspectors, approvel ahead letter cycle OE,01, other HQ coordinate offices as appropriate regional actions Agency Annually / DIR NRR*, ras, Approvel Commission Action Two weeks DRS/DRP DDs, coordinate briefing, followed Review after end-of- AEOD, DISP, OE, 01, agency by public meetings cycle review other HQ offices as actions with individual appropriate licensees to discuss assessment results Acronyms SRI Senior Resident inspector DD Division Director RI Resident inspector RA Regional Administrator BC Branch Chief DIR Director PE Project Engineer DISF Division of intpection and Support Programs DRP Division of Reactor Projects 01 Office of Investigations 24 8 9 e
<m es C
n ( % J_
) (/)
s ACTION MATR X LICENSEE PERFORMANCE INCREASING SAFETY SIGNIFICANCE >
- t. All Assessment inputs it. One or Two inputs lit. One Degraded IV. Repetitive Degraded V. Overall Red (PIs and Comerstone Wtute (in different Cornerstone (2 inputs Cornerstone Multiple (Unacceptable)
Inspection Areas) cornerstones); ' White or 1 Input Ye4cw) Degraded Cornerstones, Performance; Plants Not 3 Green; Cornerstone Cornerstone Ohlectives or any 3 White Inputs; or Multiple YeNow Normany Pemutte1 to en Othectives Futty Met Fully Met inputs; Comerstone Operate Within this Band, Cornerstone Ot4ectives ' E Met with Minimal Otdectives Met with Unacceptable Margin to Reduction in Safety Signincant Reduction in Safety Margen Safety Margin Management Routine Resident SRVBC Meet with DDIRA Meet with EDO Meet with Senior Commission meeting with Meebng Inspector Interaction Ucensee Ucensee Management Ucensee Management Senior Ucansee Management Ucensee Ucensee Corrective Ucensee Corrective Licensee Sett Ucensee Performance ! Action Action Action with NRC Assessment with improvement Plan with
$ Oversight NRC Oversight NRC Oversight Z
O
- a. NRC Risk-informed Inspection FoNow4sp Inspection Focused on Team inspection
$ inspection Baseline Inspection Cause of Degradation Focused on Cause of Ec Program Overall Degradation Regulatory None Document Response to Docket Response to -10 CFR 50.54(f) Letter Order to Modify. Suspend.
Degrading Area in Act6ons Degrading Condation - CAtJOrder or Revoke Ucensed ' inspection Report (Consider N+ f (Consider N+ f Activttles Mspectron for 2 Inspection for 2 Consecutive Cycter in Consecutive Cycats in This Range) 11ris Rangej Assessment DD rev6ew/ sign DO review / sign RA review / sign
$ Report assessment report assessment report (w/
RA review! sign RA review' sign p assessment report (w/ assessment report (w/ assessment report (w/ 4 (w/ inspection plan) inspection plan) inspection plan) inspection plan) inspection plan) 2 3 Public SRI or Branch Chief SRt or Branch Chief RA Discuss EDO Discuss Commission Meeting with i 3 Assessment Meet with Ucensee Meet with Ucensee Performance with Performance with Sen6er Senior Ucensee h Meeting Ucensee Ucensee Management Management to Discuss O Ucensee Performance
< Regional Review 1 Agency Review >
25 l t
+ PROCESS EVALUATION
- Initial benchmarking
- Ongoing evaluation i
i i 26 I
'
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_ _ _ _ _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ = _ _ m e_ _ _ _ _ _ _ _ _ -_ _ _ - _ _ _ _ - _ _ _ - _____
O ~~! O O TRANSITION
- Key transition tasks
- public comment
- final Commission approval
- 6 month pilot
- joint NRC/ industry workshop
- training
- implementation
- Staff work remaining
. - procedure and policy development
- PI format and reporting protocols
- support infrastructure changes
- related key policy issues
- development of training materials
- incorporation of lessons learned from pilot 27
i i TRANSITION STRATEGY
- Transition Task Force i
e Change Champion e Change Coalition '
- Industry and External Stakeholders i I
28
- e . . .
O O O ~^i i i TRANSITION SCHEDULE i
- Requested final Commission approval (March 1999)
- Senior Management Meeting (April 1999)
- Start pilot (June 1999)
- Implementation workshop (October 1999)
- Complete pilot (November 1999)
- Implement new process for all plants (January 2000)
- Last Senior Management Meeting (April 2000)
- First annual review results under new process (April 2001)
- Complete evaluation of effectiveness (June 2001) 29
O o 01 BASELINE REACTOR INSPECTION PROGRAM t . Key Concepts in Proposed Program
- Planning process for what to inspect on 12 month basis Process Tools Step 1: List inspectable areas & Table 1 by cornerstone -
Step 2: A. Select no. of risk & RIM No.1 significant activities to inspect B. Select type of & RIM No. 2
- activities to match (1st cut) level of effort in 2A.
Site Specific (Modified Cut) i Step 3: Schedule inspections to match total hours by cornerstone Back Up-1
l l l l l MITIGATING SYSTEM CORNERSTONE DETAILS t ( MITIGATING SYSTEMS , , I CONFIGURATION CONTROL I , r i l EQUIPMENT LINEUP EQUIPMENT LihEUP (AT POWER) (SHUTDOWN) Pi = SSPI Ril MRV VERIFY Pt INSPECTABLE AREAS: INSPECTABLE AREAS: l&RP f&RP EQUIPMENT ALIGNMENT MAINT. WORK PRIORITIZATION EQUIPMENT ALIGNMENT MAINT. WORK PRIORITIZATION TEMPORARY PLANT MODS. REFUELING ACTTVITIES EMERGENT WORK I MR IMPLEMENTATION TEMPORARY PLANT MODS. EMERGENT WORK . I 1&RP = identification & Resolution of Problems MR = Maintenance Rule SSPI = Safety System Performance Indicator V = Verification and Validation Ril = Risk infonned Inspection Back Up-2 ;
*
- e.
n qj '
/. -
(v) r) z v Table 1, Risk Information Matrix No.1 (continued) PEnromm<r H URsFOR CoRNERSTord prSPECTABLE AREA FREOuENcY 24MT SITE PER Tom LEVEL OF ErroRT Bases YEAR REACTOR SAFETY CORNERSTONES (l=lnetiating Events; M=Midgating Systems; B=Bamer. X or a number andcates the inspectable Area is mapped to that Comerstone; When a number is present in a column,11 represents the approximate percentage of the total hours of inspection to be performed for that Comerstone) 1 M B Adverse Weather None As conditions 12 to 18 h@ar Select 1 non4ailure tolerant SSCs. supplemented by 1 site- Conditions leading to loss of Offsite 20 80 Preparations require specdic high nsk SSCs. The non-failure tolerant SSCs (i e.. Power, freezing temperatures, high hegtWy restable RWST). whose faltures may contnbute a sma8 winds, flooding dominate risk. amount to the total CDF, but create a large CCDP, could result in Conditions can lead to common fadures of other SSCs due to instrument kne freezing or other cause failure of trubgation CCF tailuras. equipment and to initiattating events. Use plant history,IPE,IPEEE to desarmme vulnerabthty eM assign final hours, Base'me inspection to tA performed petor to seasonal suscepttbliities. Hours include 6 hrs for lderetration and Resolution of Problemsassues. I M D Changes to License None Annual 32 hry Review licensee evalua' ions made per 10CFR50 59 Changes can be made without prtor 80 20 Conditions and Safety requirements. If the initial screening indcates that the issues NRC approval only 5 they do not Analysts Report patentialty increase risk, select the issue for review. Select a increase risk. Adequate itcencee mwumum of 5 sigrwficant evaluations for indepth review. Incknes performance while evaluating 8 hrs of kjentifcation and Resolubon of Problem!! sues impact of changes prevents changes that increase nsk from being made. Success criteria for PRA muld change N ucense basts changes. I M D Emergent Work None Barnonthly 60 hrs /yr Selection of risk sigruficant activities should be made using Troubleshooting while trying to 40 60 l'censMs mnfiguration specific risk assessment or from a determine cause of emergent ranking of system importance. RIM 2 should be used if plant equipment problems can lead to specific information has not yet been developed. Select 2 inadvertent risk significant initiating actnrities per monm. events. Hours estimate assumes 3 hrs / month of observatkm and 2 In addition. high rtsk conngurations hrtmonth of Identifcation and Resolution of Problems /tssues. with mul'iple outef-service SSCs may occur during volung on-line maintenance due to emergent work. I M B Equipment Angnment None Semlannual 76 hrstyr One system walkdown every 6 rnonths. If avadable system High risk configurations may occur 30 60 10 and success crnena from me sHe specNic rtsk shsdy, and the system dustng normaloperabons and N as required by design basis should be reviewed to focus the inspection. RIM 2 line maintenance activities due to maintenance should be used for system selection if plant specific information multiple out-of-service SSCs. and has not yet been developed. sucts configurations can lead to high Core Damage Probability. In conjunchon with mantenance on higher risk systems, validate entical features on lineup of the train or system providing the backup functiort Hours based on 8 brs semiannually for a complete nsk important system walkdown; 4 hrs / month in walkdowns to support venfication of operable system tram because otner train is OOS, and I hr/ month for identifcation and Resoluhon of ProblemsMssues. I l BACK-UP 3
Table 2, Risk Information Matrix No. 2: BWRs (continued) BWR Systems that Were Risk Important at Atost Plants and Reasons for importance Not prioritized within this portion of the Table Cornerstones Important Systems Reasons for importance Initiating Mitigatina From IPEs Events Systems a* Systems selected based on CDF contribution from NUREG-1560 HPCI Used to provide injection and remove Decay Heat (DH) from the core on an SBO. Availability and Redundancy of High Pressure injection Systems (HPCI & RCIC) 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 X system redundancy can be impacted by harsh environments in containment (before cont. failure). On a transient with loss of DHR, resulting in con'ainment failure, Mitigating system redundancy (for Systems Located Outside of Containment and Rx B!dg) can be impact 3d as a result of harsh environments in adjacent structures (after cont. failure). RCIC Used to provide injection and remove Decay Heat (DH) from the core on an SBO. Availability and Redundancy of High Pressure injection Systems (HPCI & RCIC) 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 X system redundancy can be impacted by harsh environments in containment (before cont. failure). On a transient with loss of Decay Heat removal (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 containment failure). PACK-tJP 4 8 9 e.
J RISK INFORMED BASELINE INSPECTION PROGRAM Oversight Framework Performance Indicators Baseline Inspection Assessment Process-a Cornerstones V Inspectable Areas v
> Scope >~ Plan Inspections Select Sample Basis Documents RIM No. 1 A Plant Specific Mod.
RIM No. 2 Increase Inspection A
' ~
no ~ ves Cornerstone 4 Findings < Inspect g Objectives Assessment Met u Risk ,.. Scale
, k,/ -
- E0/20 -f 39tfd ', ,
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