ML20202H059
| ML20202H059 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/1997 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3018, NUDOCS 9712100193 | |
| Download: ML20202H059 (172) | |
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H 3 \\ A ACRST-3MS OFFICIAL TRANSCRIPT OF PROCEEDINGS f].;
4 NUCLEAR REGULATORY. COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS:
Title:
447TII ADVISORY COMMITTEE ON J
REACTOR SAFEGUARDS TR;4 ACRS fen ~n.N ORIS NAL T: B "4H I TE M5 T-2E26 4;5-7130 TH1dE5 '
.c Docket No.:
Work Order No.:
ASB-300-64
' ACTS Offce Cc5Neh $)
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Rockville, Maryland DATE:
- Wed6eesday, December 3,1997 PAGES: 1 - 109 ANN RILEY & ASSOCIATES, LTD.
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T DISCLAIMER UNITED: STATES-NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
DECEMBER-3', -- 1997 The contents.of this transcript of-the proceeding
~
of the United States-Nuclear Regulatory Commission Advisory O
Q Committee on-Reactor Safeguards, taken on' December 3,
- 1997, as reported herein, is a record of the discussions recorded o.
at the meeting held on the above..date.
- This-transcript had not been reviewed, corrected l:
t and-edited and'it may contain inaccuracies.
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-1 UNITED: STATES NUCLEAR-REGULATORY COMMISSION 2
- ADVISORY-COMMITTEE ~0N REACTOR ~ SAFEGUARDS 3.--
4.
447TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5-6 7-U-S. Nuclear: Regulatory Commission 8
'Two White Flint North 9 --
11545 Rockville Pike 10-Rockville, Maryland 20852-2738 11
-12 Wednesday, December 3, 1997 13 14~
-The Subcommittee met pursuant to notice at 1:00-15 p.m.
16
-17 MEMBERS PRESENT:
18-ROBERT L. SEALE, Chairman, ACRS 19 DANA A POWERS, Vice-Chairman ACRS 20 WILLIAM J.
SHACK, Member, ACRS 21' DONALD W. MILLER, Member,-ACRS 22 MARIO H. FONTANA, Member, ACRS 23-THOMAS-S.;KRESS, Member, ACRS'
- 24 ROBERT Ei UHRIG, Member, ACRS I25-
-(
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1 PROCEEDINGS
,~
i 2
(1:00 p.m.)
3 CHAIRF9M SEALE:
The meeting will now come to 4
order.
This is the first day of the 44'th meeting of the 5
Advisory Committee on Reactor Safeguards.
I am told that 6
this is also the fortieth anniversary of this committee.
?
I'm sure there are all kinds of homilies that have been 8
ex, tressed by people in the past about any committee whose 9
tenure would cover a span of 40 years.
I think we all take 10 heart in the fact that none of those homilies or comments 11 are relevant in this particular case.
12 During today's meeting the committee will consider 13 the following.
The emergency core cooling system strainer 14 blockage, assurance of sufficient net positive suction head O(_/
15 for emergency core cooling and containment heat removal 16 pumps, NRC performance plan, ACRS report to Congress on the 17 NRC safety research program, proposed ACRS reports, 18 This meeting is being conducted in accordance with 19 the provisions of the Federal Advisory Committee Act.
20 Dr. John T. Larkins is tha designated federal official for 21 the initial portion of today's meeting.
22 We received no written comments or requests for 23 time to make oral statements from members of the public 24 regarding today's sessions.
25 A transcript of portions of the meeting is being
[)
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a l'
kept and it is requested-that the speakers use one of the j
2 microphones, identify themselves and speak with sufficient
()
E 3
clarity and_ volume so that they can be readily heard.
- 4 I have a few announcements to mako.
Some items of 5
-current _ interest and a brief review of our expected letter 1
6
-writing chore for this session that I would like to remind 7-
- overyone of -before we get started with tlue first topic.
8 First of all, I would like to remind the members 9
-of the committee and announce to others that Dr. Gail Marcus 10
~is acting Deputy Executive Director for a three-month i
11 period.
Dick S.svio and-Sander Aswami are on developmental i
12 rotational assignments for this three-month period.
13-We are going to have a Christmas session party, if 14 you will, tomorrow from 11:30 to 1:00 p.m.
We expect 15 Commissioners Dicus and McGaffigan to visit with us at that 16' time.
And in fact after that, immediately following that 17 little nosh, we will hear from Commissioner Dieus for about 18 an hour or so.-
She will have several topics she would like 1
19 to talk with us about and I believe the members have 20 received a letter dated the 2nd which lists the-items for 21 discussion that have been identified in cooperation with her 22 staff.-
' 23 We have some meetings with the other commissioners 24; coming up over the next month-or so, so we will want to. keep 25 watch on that.-
I think. in February, Chairman ' Jackson will ANN RILEY & ASSOCIATES, LTD, Court Reporters 1250=I' Street, N.W., Suite 300 Washington, D.C.:20005
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meet with the committee and so on.
()
2 In line with some of the concerns that have been 3
expressed recently regarding the question of waivers or 4
special evaluations of potential conflict-of-interest issues 5
that members of the committee might have, I should mention 6
that Commissioner Jackson has recently released a letter 7
regarding waiver on a couple of affiliations I have with Los 8
Alamos and Sandia and I would expect that similar 9
determinationr: which won't have to be signed by the Chairman 10 will be forthcoming on some of the other members pending 11 completion of discussions with the OGC people who are always 12 in the loop on those kinds of concerns.
13 DR. UHRIG:
Do we need to take any action on that?
14 CHAIRMAN SEALE:
That comes up as a result of your 15 filing of your interests and affiliations.
16 There is a rather thick, pink cover sheet file of 17 items of interest and I must say that all 69 pages contain 18 material that are of interest to some of us and a good bit 19 of it to all of us.
There are three speeches by 20 commissioners, Cbsirman Jackson a couple of speeches and 21 then one by Commissioner Dia: at the ANS meeting in 22 Albuquerque last week.
23 There are two enforcement activities, one at 50K 24 and one at 100K that are mentioned there that involve very 25 specific violation activities or responses and then there ANN RILEY & ASSOCIATES, 11rD.
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1 are several misce 31aneous items which are -- have some
()
2 potential effect on the Connittee.
One is the MOU between 3
DOE and the NRC establishing a pilot program on external f
4 regulation of DOE nuclear facilities.
There is a resume, if 5
you will, or an updating of the status of Westinghouse's
[
6 sale of various business units, their nuclear energy 7
business is a part-of it.-
I am intrigued by the idea of l
8 separating nuclear energy _from Dan Rather but that's another 9
-que. ion. -
10 There is also a speech by_ Senator Pete Domenici of l
11 New Mexico that was made at the Albuquerque ANS meeting-that 12 is enclosed here which I think-you will find very 13 interesting and then a short summary of a conference to 14 discuss cancer risk from radiation exposure.
So I would
()
15 urge you to take a look at that if you get a -- or when you 16
-get a chance, not if.
17 As far as letters are concerned, there are eight
+
18 of them on here, on the list that has been prepared.
I 19 think perhaps one of them we have decided may not be I
12 0 necessary but they include the use of uncertainty versus 21 point values in PRA decisionmaking process, revisions to 10 22 CFR_50.59, proposed final SRP Chapter 19 and Reg Guide 23-DG-1061.
The annual ACRS report to Congress on the safety 24-program.
Assurance of net positive -- of sufficient net 25
-positive suction head.
Revision to NUREG 1022, the i
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emergency core cooling system strainer blockage, we may not
()
2 need a letter on that, I-think. as a result of what we will 3
talk about later.
And then~the capability and application 4
of the check works code.
That's tentative also.
5 I noted that there is a good bit of grade I
6 inflation that has taken place here because there are none 7
of them that look to be really pressing that don't have 8
either an A or an A-plus grade associated with them.
I 9
wonder'about those things.
10 Yes?
11 DR. POWERS:
If we have doubts about these 12 rankings, we ought to change them.
Because I think we want 13 to move toward the chance -- we have a chance to reflect 14 over letters.
15 CHAIRMAN SEALE:
That's right.
And I mentioned it 16 for that reason.
I think we ought to ask ourselves whether 17 or not those ratings that are being put on there now really 18 encourage where it's possible the kind of deliberation that i
19 we ought to try to have before we stick our necks out on 20 some of these issues.
1 21 I'll ask are there any other announcements that we 22 need to make before we get into the main?-
23 DR. LARKINS:
I don't know if you want to announce l
24 it-but you have a potential new member sitting in later 25 today and tomorrow.
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CHAIRMAN SEALE:
Yes, that is correct.
We
()
2 understand that Professor Graham Wallace has been okayed, if 3
you will, I guess that's the word, by the commissioners, 4
subject to the usual vetting by the powers that be that have 5
to do with conflicts of interest and so on but we expect no 6
problem there.
We are looking forward to having a new 7
colleague with us there.
8 Any other comments or suggestions?
Any members of 9
the committee have anything they would like to add?
10 (No response.)
11 CHAIRMAN SEALE:
Well, having taken care of those 12 things, the first topic is the emergency core cooling system 13 strainer blockage and our most recent member, Bob Uhrig, is 14 acting chairman of this subcommittee in place of John 15 Larkins.
16 John won't be with us at the meeting this week, by 17 the way.
18 Bob, it's your subcommittee so I will ask you to 19 take over.
20 DR. UHRIG:
We had an all-day meeting yesterday in 21 which we had a number of presentations by the staff.
It 22 dealt not only with the issue of the potential strainer 23 blockage by debris but also with the net positive suction i
24 head.
These two issues are intimately tied together and, as 25 Gary Holahan said, the solution of these will basically take l
l()
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place simultaneously.
f
()
2 So with that as an introduction, I will call upon 3
the staff.
Yes.
Rob, we will let you hold forth.
4 MR. ELLIOTT:
Thank you, sir.
5 My name in Rob Elliott, for those who I didn't get G
to meet yesterday.
I am with the Containment Systemc Branch 7
in NRR and I have the lead review responsibilities for NRC 1
8 Dulletin 96-03, which deals with the BWR strainer blockage 9-issue.
10 What I would like to do today is just give you a 11 little update on where we've gone with the bulletin since we 12
-last briefed the Committee.
We came to you all back in I 13 believe it was February of last year and briefed you on the 14 bulletin that we were proposing to-issue at that time.
It 25 actually got issued on the 6th of May 1996 and it offered 16 three prospective resolution options to the utilities for 17 resolving the strainer blockage issue.
l 18 The options were to put in large, passive 19 strainers -- either large, passive strainers, self-cleaning 20 strainer designs or backflush systems to ensure that the 21 ECCS could perform its safety function during an accident.
22 To date, we have received all the required responses from 23 the licensees and all have indicated that their intention is 24 to use option one to install the large passive strainer 25 designs.
()
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However, because of the timing of-the bulletin,
()
2 the bulletin actually requested utilities to implement their 5
3 resolution to the strainer issue by the first refueling.
4 outage commencing after January 1, 1997.
The timing of-the I
5-bulletin, though, left inadequate lead time for.the plants 6
having spring outages this year to be able to procure the i
7 strainers that they needed in a timely fashion and to t
8 install them during the outage.
9_
In addition to that,. the industry had prepared a 10 utility resolution guidance document which provided to the 11 various utilities guidance on how to analyze your plant and 12 determine an adequate strainei' size to install.
The need-13 for the NRC to review that document and give the feedback to 14 the industry relative to any concerns that we had with the
()
15
- strainer si=ing criteria combined with the inadequate lead 16 time led to the staff granting deferrals to the plants 17-having spring outages of this year.
_ 18 However, having said that, four utilities still 19 managed to obtain their strainers and get them installed 20 before they started up from their spring outage.
We added 21 an additional plant that was down over the summertime also 12 2-install and.since then the plants with fall outages have 23.
proceeded with installation with only one problem arising.
24 We gave one deferral ~to a plant that had trouble obtaining
'25 the structural' materials they needed for their strainers in 1
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time to install during the outage.
()
2 They did install one strainer on the one RHR 3
system but they were unable to get the structural materials 4
in time to install all of the strainers.
So we granted one 5
deferral to the fall outages.
6 In order to keep the fall outages on pace to 7-install in time, we did do plant-specific reviews over the 8
summer to support their outages.
This was because the 9
utility resolution guidance document which I believe we have 1
10 given a copy to the committee was very, very detailed and a 11 very large document to review and it required a large amount 12 of effort for the staff to complete its review on that and 13 so in the taeantime to keep the fall outages moving, we 14 performed plant-specific reviews for the licensees that felt
()
15 they needed to get staff approval before they proceeded.
16 DR. UHRIG:
How many of those were actually 17 reviewed in CFR 50.59?
18 MR. ELLIOTT:
Well, what they did is they were 19 still using 10 CFF.59.59, but they came in with submittals 20 detailing what they were doing in the way of sizing their 21 strainers, and they asked for Staff approval of their sizing 22 criteria.
So even though they said we don't need Staff
-23 approval to do this, they still wanted to know that the 24 Staff didn't identify any concerns with their sizing 25 criteria.
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We reviewed all of the ones that were submitted to
()
2 us and actually issued safety evaluations on I believe four.
3 DR. UHRIG:
Thank you.
4 MR. ELLIOTT:
So, what has been accomplished so 5
far, as we've seen plants installing larger strainers in 6
their suppression pools that have led to strainer surface 7
areas between 750 square feet and 2,000 square feet, this 8
represents (n1 the order of a 1,500-percent increase in 9
strainer area for some of the smaller plants, and much 10 larger percentages of strainer increase for the plants 11 having the larger strainer areas.
12 The differences in the strainer areas is directly 13 attributable to the plant-specific variables such as the 14 type of insulation that they have in their plants and some 15 of the design assumptions that they make in sizing their 16 strainers, and examples of the types of things that they 17 might use as design assumptions are the frequency that they 18 intend to clean their pool.
If they're going to clean it 19 say every other cycle then that may -- that leads them to 20 increase the amount of particulates and sludge that would 21 collect in the pool during ncrmal operation.
And so 22 depending upon how they select these variables, they can end-23 up needing larger or smaller strainers, but in all cases the 24 strainers have been substantially increased from the 25 original design.
(
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12 1
As I said earlier, all the licensees -- well, most
()
2 licensees have concluded after doing their 50.59 evaluation 3
that they didn't have an unreviewed safety question, and 4
therefore the installation of the larger strainers did not 5
require prior Staff approval.
However, as I indicated, we 6
did review some of the -- some plant-specific submittals 7
because licensees were concerned about the need for Staff 8
approval of the sizing criteria that they were using.
9 So since we weren't getting detailed 10 plant-specific submittals from most plants, the Staff 11 conceived or prepared a closure plan for evaluating licensee 12 implementation in 96-03.
And basically what that entails is 13 we will conduct some plant inspections on the order of six 14 to eight plants beginning in the spring of 1998.
If 15 significant issues are identified when we evaluate licensee 16 resolutions at those plants we will probably expand the 17 number of inspections until we're sure that we have good 18 confidence that there are no safety issues with the 19 resolutions that licensees are implementing.
Part of those t
20 inspections will also include an evaluation or review of the 21 50.59 evaluations performed by the licensees.
22 Basically there are three areas that we would 23 focus our attention on in the inspections and/or in the 24 closure of this issue.
The first area is of course in the 25 strainer sizing, and the way we're evaluating how licensees l
! ()
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are sizing their strainers is first the staff safety
[
()
2 evaluation of the utility resolution guidance document which p
3 licensees are using to size their strainers, and then l
4 through the -- we'll inspect the application of that 5
guidance by conducting the plant inspections.
6 The second area is hydrodynamic loads, and 7
basically the original strainer designs were very small, and 8
not significant when evaluating the amount of loads caused 9
by hydrodynamic loads or evaluating the load on the 10 structure caused by hydrodynamic loads during an accident.
11 So they were just treated as solid cylindrical objects.
The 12 drag on a solid cylinder the size of the strainer that they 13 had was not very significant, and it didn't create 14 structural problems for.them supporting the penetration.
()
However, when you put in the new strainetr, very 15 16 often these strainers are 44, 48 inches in diameter.
They 17 are anywhere from 8 to 12 feet long.
If you treat that as a 18 solid cylindrical object when you start calculating the load 19 on the penetration, you're going to calculate very, very 20 large loads.
But the fact of the matter is the strainers 21
_are parforated.
They're not solid cylinders very often.
22
.Their geometry has. corrugations in it which would allow 23 fluid to pass freely also.
And so licensees are 24 reevaluating their hydrodynamic
" ads on the strainers and-25 taking credit for the-fact that the strainer is not a: solid
~
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cylinder.
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- 2 Staff has pointed out to the industry that the 3
original basis for acceptance of hydrot tamic loads such as 4
treating them as solid cylinders had the basis in test data, 5
so test data was used to confirm that the drag coefficients
.6 used in the calculation of hydtodynamic loads was accurate.
7 However, it's not been demonstrated that you can calculate 8.
these drag coefficients with any kind of accuracy, and so 9
the staff believes that test data is needed to demonstrate
- 10 the drag coefficients on the new strainer-designs that are
-11 being installed.
j 12 To date there's been four approaches used for 13-hydrodynamic loads, each one corresponding to a different 14 strainer vendor.
General Electric and Performance 15 Contracting both offer what's called a stacked-disk strainer 16 design, and they have conducted testing to show what the 17 drag on their strainer designs would be.
The Mark IIIs have i
18 created their own strainer design, and they are presently 19 evaluating test facilities to conduct testing for their 20 design as well.
And the fourth vendor is ABB, and in their 21 case for the one utility that they've been working for they 22 are treating the strainer as a solid cylindrical object ano 23 maintaining the original licensing basis for the strainer 24 and providing sufficient structural support to support that 25
' strainer -
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But when we go out to the plants on the
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2 inspections we will also at that time evaluate the 3
hydrodynamic load calculations and see if we identify any 4
concerns there.
But we have made very clear to the industry 5
and to the various vendors our feeling that the methods they 6
use to calculate hydrodynamic loads needs to be based in 7
test data.
8 The final item-that we need to evaluate to reach a 9
closure on this issue is in the area of net positive auction 10
-head, and that's because net positive suction head is the 11 ultimate criteria by which we judge success in this issue.
12 As you know, we've issued Generic Letter 97-04, and we will 13 review those responses, and ' luring our inspections we'll 14 review the calculations at the sites and try and determine
()
15 whether or not we have any concerns about the way NPSH 16 evaluations are being conducted.
17 DR. SHACK How much is the increase in surface 18 area for these strainere typically?
19 MR. ELLIOTT:
It's -- well, the one plant that I 20 said was 750 square feet, that represented a 1,500-percent 21 increase, so that was going from about 50 square feet total 22 to 750 square feet.
The plants that are putting in 2,000 23 square feet -- I mean, it's probably more on the order of 24 three times that or 4,500-percent increase in strainer area.
25 It is -- they are putting very, very substantial
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increases in strainer sizes.
In general licensees are
()
2 choosing the more conservative methods of evaluating the 3
plant in the URG.
So -- of the plants that we've seen.
Now 4
of course there are some plants that have not given us 5
detailed information, and as suen they've probably become 6
tl.e more likely plants that we'll go out to and inspect.
7 I'd just like to touch briefly on the status of 8
our review of the utility resolution guidance document, and 9
then just touch briefly on the open items that we have in 10 the SER right now.
11 We have prepared a draft safety evaluation report 12 which we have shared with the committee, and in that SER we 13 have identified several open issues.
However, we have tried 14 in the SER tc point the way to resolution on each issue, how 15 the Staff perceives the issue could be resolved, such that a 16 utility could take our SER, take the ORG, and address the 17 Staff concerns and proceed with their installation right 18 away 19 But because we have identified these open issues, 20 we believe that it's prudent to send the draf t to the owners 21 group and allow them the opportunity to respond to our open 22 issues.
They may be able to bring more information, more 23 test data, more analysitt to provide to the staf f and be able 24 to give us additional information which we might not have 25 considered in our initial evaluation.
So we'll send that to I()
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17 1-the' owners group.
We haven't determined what an appropriate
()
2 comment period is, but probably:something on the order of 30 3
j 3
to 60 days, and following evaluation of the owners group 4
response to those open issues we will issue the SFR in its l
l 5
final form.
6 Okay.
I just want to briefly touch on this.
This l
i 7
looks like a lot, but I think much of it is not deeply i
8 complicated.
Each bullet represents an area where we've 9
identifiad an open item in the analysis methods that are
- 10 provided in the URG, with the exception of this last bullet,-
11 which is more on general guidance that the URG gives.
In 12 the area of selection of breaks, basically the URG 13 references a standard review plan section 3.6.2 and a branch-14' technical position MEB 3-1 for determining what breaks
[
15 should be selected when you're evaluating.your plant.
16 That section of the SRP was prepared by the Staff 17 for evaluating compliance with general design criterion No.
18 4, which is for evaluating what' break locations you might
[
19 need to put pipe restraints on, what equipment you might 20 need to shield from jet impingement.
It has nothing to do 21 with functional design of the ECCS.
Staff believes it's 22 inappropriate for use for demonstrating compliance with 10 23 CFR 50.46 and that the rule itself is very specific about 24 the number of breaks that need to be considered.
4 25 The rule states that you must consider enough
()
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breaks of different sizes and properties to ensure that the
()
2 worst-case scenario has been calculated.
And so 3.6.2 and 3
MEB 3-1 limit the scope of breaks that licensees would
{
4 choose from, and in fact one licensee when we evaluated 5
their sizing criteria we sent them back that comment that we 6
think they needed to expand the scope beyond that SRP l
7 section, and sure enough they found a more bounding break.
8
-The second issue in the selection of breaks deals 9
with a comment that the owners group states in there that 10 deals with a general statement about the alternate strainer 11 designs that they tested not being susceptible to what's 12 called thin-bed effects.
And basically what the Perry 13 events and again at Limerick what it was seen that you could 14 get very high head losses with very thin beds of fiber
()
15 combined with high concentrations of corrosion products in 16 the pool.
And while we agree that the designs they tested 17 are not susceptible to thin-bed effects, and therefore i
18 medium-break LOCAB don't become as important to analyze when 19 sizing your strainer, we believe that licensees should 20 verify or should ensure that the experimental data is 21 consistent with the amounts of debris that they would have 22 for a medium break for their plant, and therefore to ensure 23 that the strainer design they're choosing is not susceptible 24 to thin-bed effects before they eliminate medium-break LOCAs 25 from their analysis.
()
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In the area of calculation of zone of influence we
()
2 identified two-issues there also.
I'll drop down to the 3
second bullet real quick, because that's quick and easy.
4 One of the ways they said you could determine the zone in 5
which debris would be created, what we call the zone of 6
influence, they said you could run a CFD code to determine 7
what that zone is, how far out the zone instruction would 8
occur.
9 There was insufficient guidance for the Staff to R1!0 really evaluate how effective that method would be.
They 11 didn't provide us any information on the code or how it 12 would be validated or anything at all other than just kind 13 of a general one paragraph on that.
So lacking sufficient 14 guidance we're unable to provide any detailed evaluation on
()
15 that at this time.
However a plant wanted to use that 16 method, we suggest that they provide us a plant-specific 17 submittal with more detail.
18 The first bullet gets into how the owners group 19 scaled their debris-generation tests to determine the zone 20 of influence.
They conducted a series of tests to find out 21 at what pressure destruction would occur for various 22 insulation material types, and it's basically an air jet 23 which you aimed at a target, they backed it out until no 24 mcre generation occurred.
Then they calculated what the jet 25 centerline pressure is.
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1 Staff has taken exception to the use of jet
()
2 centerline to determine at what point pressure damage occurs 3
to the insulation.
The reason why we disagree with that is 4
that the typical failure mechanium that was identified in
?
5 the owners group testing was failure of the latches that 6
hold the sheathing or the insulation covers on, and those 7
are not always located at the center line of the jet.
It 8
was felt by the Staff that what was causing debris 9
generation is the force on the blanket itself, the total 10 f)rce, and so we recommend a use of an average pressure, 11 tatget average pressure for determining the point at which 12 destruction occure.
13 We have an issue that was raised by Dr. Powers 14 yesterday about whether the Staff's opinion is necessarily
()
15 accurate, and we are going to seek to resolve that with the 16 owners group as we go through this comment period.
17 MR. ELLIOTT:
In the area of other drywell debris 18 sources, they give some values for, generic values for other 19 types of debris such as rust, dirt, dust, qualified 20 coatings.
The only Staff comment there is you should 21 evaluate the applicability and the basis for those values to 22 your plant.
23 The values are very similar to what was used in 24 NUREG 6224, which was the Staff's analysis of a MARK I 25 plant, a BWR-4, and the concern is that plants with larger
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containments may end up with larger values of dirt, dust,
()
- 2
. and rust and those t*, pes of materials.
3 In addition, that same section mentioned i
4 unqualified and indeterminate coatinga but didn't provide 5
any significant guidance on how to-treat those coatings.
In 6
the SER the Staff recommends, to avoid future potential V
7 concerns regarding.the operability of the ECCS, to assume 8
100 percent of those coatings fail and reach the strainer 9
surface.
- 10 However, if licensees can come up with a technical ull basis on which to use -- to treat them differently in their 12-analysis, we would be open to hearing the basis for that.
i 13 In the area of drywell debris transport, the 14 Owners Group came up with --
(
15 DR. POWERS:
Let me interrupt you just a second, 16 I think it is important that you explain to the committee 17
. all-the things that have to be taken into consideration 18 about getting this additional material down into the 19 strainers, that it is not just the flight of loosened and 20.
suspended debris going through the downcomers and eventually 21 ending up in the pool, that they may-well be stopped in that 22 flight prior to getting into the downcomers, but then 23-
- subsequently,they may be washed down by flowing water.
24 MR. ELLIOTT:
By falling water either from the
- 25 break, such as in the case of a recirculation line break O-i ANN RILEY &JASSOCIATES, LTD.
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with unthrottled ECCS ficw or through the use of containment
()
2 sprays -- so it is not -- there's a number of issues when 3
you are trying to evaluate the transport of coatings that-4 come into play, not only will they fail but when will they i
5-fail.
6 If it is not likely that they are going to fail 1
7 until many, many hours out into the accident then the amount 8
of transport mechanirms available to get those down into the I
9 suppression pool would be relatively few.
You're prebably l
3 10 not using containment sprays anymore.
You have probably 11 throttled back ECCS flow.
You basically have gravitational
-12 settling, and that is probably not going to get you through 13 the downcomers and down into the suppression pool.
I 14 However, if those coscings were to fail early, 15 then during the blowdown phases then the Staff feels that 16 they could certainly be entrained in the steam flow and if 17 not blown directly down into the suppression pool deposited 18 in areas where water flow could then wash them down into the 19
'suppressicn pool 20 When you lump unqua? fled and indeterminate 21 coatings together you have got-a lot of different problems 22 being kind of lumped under two words, 23 Unqualified coatings cometimes coatings that you
~
24 would normally consider to be qualified.
It's just that the q
25 pedigree is not there -- the QA paperwork,-the-documentation
()
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supporting calling it a qualified coating is not there.
2 This is not untypical for, say, reactor coolant 3
pumps, taotor housings, to be covered with those types of l
4 coatings.
I 5
The other category is a qualified coating that has 6.
not been properly applied.
These are the types of problems 7
that we are seeing now in the_ plants where supposedly 5
8 qualified coatings are peeling or bubbling, and in that 9
particular case-I think the argument to say *: bat the i
10 coatings would not fail till later in the accident becomes a 11 very difficult argument to make, because if you already have 12 failure of the coating, then I think the air velocity and j
13_
the turbulence in the drywell following_a pipe break is
'14 going to be sufficient to strip those coatings off of their 15 surfaces.
16 So, yes, and there is a lot of plant-specific 17
. analysis that.would have to be'done to evaluate that, but 18 the concern that we have is that URG guidance is not very 4
19 detailed in that area, and we are concerned that as we 20_
evaluate the issue of coatings here that we may end up with 21
-licensees now coming back and saying that they didn't account for that=and now they are into operability problems
=23'
-as a result of it.
- 24' Did that answer your question, Dr. Powers?
25.
DF POWERC:
Okay.
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MR. ELLIOTT:
In the area of drywell debris
()
2 transport, the Owners Group conducted some limited testing 3
of just the downcomer or vent geometries for a MARK I and a 4
MARK II, small scale, to see what transport fractions they 5
would get that could get through just that geometry.
6 However, when they were preparing the tests we 7
identified some scaling concerns relative to the bulk fluid 8
velocities in the facility itself and in the downcomers 9
being substantially lower than what we were calculating for 10 a full-size, large break LOCA on the order of 22 to 26 pipe 11 diameter.
12 The fluid velocities they were getting were more 13 on the order of -- depended upon whether you were scaling 14 the facility itself, the drum, or the vent were more on the
()
15 order of 12 to 17 inch pipe breaks, so we believe that that 16 could possibly have affected the results they got.
17 Basically the result the got was for a MARK I they got 100 18 percent transport of fine debris, but for a MARK II they got 19 half that.
20 When we did our confirmatory testing, we did not 21 find the MARK II to have anywhere near that kind of holdup 22 just in the vent.
We got on the order of 15 percent 23 capture, which did not in our mind when you take the 24 potential for washdown following that didn't justify the use 25 of a 50 percent transport fraction.
.(
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1 So we have suggested that they use 100 percent for
()
2 the MARK II, just as they are using for the MARK I and MARK 3
III.
4 We did communicate that concern to them.
That is 5
a very important concern and that was communicated to them 6
very early on in our review of th9 URG.
7 The other area that we took exception to is large 8
debris, what they characterized as large debris -- I would 9
say on the order of the size of your hand -- that is 10 generated below the lowest grating in the drywell.
3 11 They assumed a 70 percent transport fraction.
.ie 12 Staff felt based on our confirmatory research that the 13 potential for that material to wash down was very great 14 because of the location where it was generated and its
()
15 proximity to the downcomers and felt that 100 percent of 16 that debris was a more appropriate transport fraction.
17 In the strainer head loss area the Owners Group 18 developed a head loss correlation.
Unfortunately, when we 19 tried to use it, compare it to their own test data, we found 20 it to be very unreliable.
As such, we recommended that 21 utilities use vendor test data to support the head loss that 22 they assume for their plant.
23 Each of the vendors has done a substantial amount 24 of testing of various debris combinations and amounts for 25 their strainer design and we felt that that was probably a O
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1 more appropriate way to go.
2 The second concern we had in the area of strainer 3.
head loss dealt with the treatment of what we call combined i
4 debris bed.
5 Some plants have not only fibrous insulation but 6
also reflective metallic m
, eion and then they all have 7
corrosion products in '.h>. r m.peression pool or particular 4
8 type-of-debris such-as dirc and rust.
9 The Owners Group said that when you have that kind 10 of debris bed you don't need to consider the contribution of 11' the RMI,'that the head loss of. the combined debris bed would i
12 be bounded by the head loss of just the fibrous and the 13 particulate materials only.
14 When we looked at the test data that both the 15 Owners Group had and from our own confirmatory testing which 16 we conducted up at Alden, we concluded that while in most 7
17 cases that appeared to be true, there were at least three 18-datapoints in the Owners Group test data and a couple in our 19 own test data where that did not hold true.
20 As such, we concluded that the head loss is 21 actually bounded by the addition or summing of the RMI head 22 loss only with the head loss by the fibrous and particulate 23-materials and so we have stated that in the SER, that that
+
24
-is the way we believe it should be-treated.
- 2 5. -
In the area of-NPSH, we didn't have significant
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concerns in the guidance that was given in there.
We took
()
2 exception to one note that said that utilities should 3
consider NPSH for a range of fluid temperatures which l
i
'4 essentially!is saying a time-based analysis, the temperature j
5 of the pool changing over time to make sure that they are 6
calculating the bounding case relative to NPSH.
t 7
Basically what happens, when the temperature goes j
8.
up, the head loss across the etrainer and the debris bed 9
goes-down, but for other reasons generally NPSH ends up f
10 being -- the limiting condition still ends up being when the
-11 max water temperature occurs.
12 However, the recommendation is still that you 13 should consider a range of fluid temperatures.
14 The only thing is the Owners Group in their
()
15 guidance excluded plants that had a specific temperature 16 cited in their licensing basis, saying that they didn't need 17 to evaluate a range of temperatures and the Staff just took i
18 exception to that, saying if it is good enough for the is plants that don't have a specific temperature cited, then it 20 should be good enough for all the plants -- that it is 21 probably good guidance for everybody to follow.
22 The last two iten.s -- the first one, treatment of 23 foreign material, basically dealt with the statement in the 24-URG that said if you assumed enough foreign material reached
- 25 the strainer, you could reduce or eliminate the need to
~ ()
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conduct inspections of the strainers and the suppression
()
2 pool.
3 The Staff took exception to that.
Basically, we 4
feel it is prudent to assume that there is some foreign 1
5 material in your suppression pool.
It is very diff.s. cult to 6
keep those things completely clean and free of various t
7 littla things that get dropped in there, so in order to 8
avoid operability concerns it is prudent to assume that 9
there is some amount of foreign material present in the 10 suppression pool and in the drywell which can transport to 11 the strainers.
22 However, we don't feel that if you do that, that 13 thnt relieves you of any responsibility in foreign material 14 exclusion controls, or in the inspections of the strainers,
()
15 cleaning of the suppression pcol.
You still have your 16 responsibility to ensure operability of the ECCS.
17 We also note that if you assume too little foreign 18 material then you can get into operability concerns every 19 time you find small amounts of material in your containment.
20 The second thing on the last bullet, the use of 21 banding, there is a section in the URG which states that one 22 of the options to assist in the resolution that utilities 23 could take would be to install jacketing on their 24 insulation.
25 Yet if you go to the test report on debris
()
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generation,-the test report specifically states that L(
)
2 jacketing by itself had negligible effect on reducing debris 3-generation unless the addition of banding was used, and in i
4_
the front section of the URG they did say_that the banding 5
was very important.
l 6
However, there was no guidance on what type of
?
-banding to use -- you know, how many bands to use on each 8
section of insulation; l
9-There was-very little guidance at all or-
)
10 information provided on the construction or anything like 11
-that as far as the banding goes, so the Staff identified 12 cautions in that area because (a) it gave the impression 4
13 that way the URG was written that jacketing by itself was 14 sufficient to reduce debris generation and that is not true,
()
15 and second of all, not all bands had the benefit of raducing 16 debris generation.
There are only certain types of cands, 17 certain construction types in particular -- those that were 18
-welded versus those that were riveted -- that made a i
19 substantial difference on debris generation, so s a wanted to 20 make sure that that was clearly identified to the atilities.
21 Now with that,.just to summarize where we are at 22 to date, overall we believe that licensees are proceeding 23 and making good progress towards the implementation of 24 96-03. ;We had-a little bit of-problem getting started out 25 of the block but things seem to be proceeding very smoothly O
r
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right now.
r's 2
The URG is anxiously being awaited by the industry (v) 3 and we are about to get the SER to them now so that they can 4
be making use of that.
5 We have a plan developed to close the issue 6
consisting of not only the URG review and 7
post-implementation inspection but also Generic Letter 97-04 8
reviews to evaluate the NPSH.
9 In general, we believe the URG provides good 10 guidance to the utilities that we consider to be acceptable.
11 We have identified concerns and we believe that licensees 12 can address those concerns the way the SER and URG -- with 13 the SER and URG information already provided.
14 DR. POWERS:
I think you undersell yourself a O( )
15 little there.
I think it is impcrtant that the committee 16 understand that not only have you identified concerns, you 17 have identified a path forward to get around that concern at 18 the same time.
e 19 MR. ELLIOTT:
Yes, sir.
20 DR. POWERS:
It may be a fairly conservative path 21 forward but you are not just saying -- in your SER you don't 22 just say this is a concern and let it go at that.
You say 23 here is how to take care of it and we will happy wr:h it.
24 MR. ELLIOTT:
We tried very hard to make sure that 25 there was a path to resolution available to the utility with l(A/
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the SER because we recognize the fact that when we send this
)
2 to the Owners Group there may be time involved with trying 3
to resolve those open items, and in the meantime the spring 4
outages are working furiously right now to be prepared to 5
install in the spring, and we felt that we needed to give 6
them a e to 1s path from the get-go.
7 DR. POWERS:
I think you have done a good job.
8 MR. ELLIOTT:
Thank you.
9 We also note that there's portions of the URG 10 which I didn't go into much detail here where the owners 11 group would cite the potential option that a utility could 12 make use Of.
13 An example was the banding, where there was not 14 sufficient detailed guidance for the staff to evaluate that
)
option as to what kind of effect it would have and how 15 16 beneficial it would be.
17 So, we said so in the SER, there was insufficient 18 information, we can't evaluate this portion at this time.
19 However, that doesn't stop a licensee -- and we've 20 stated that up front and in the conclusion, I believe, of 21 the SER -- if there is a portion of the URG that the staff 22 is unable to draw a conclusion on and a licensee wants to 23 use that, then they should provide us with a plant-specific 24 submittal addressing how that particular option would be 25 used.
[
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.And-as I:said earlier, since we-have identified-()
1! -
severalistaff concerns, the draft SER will be,sent to'the 3-
-owners. group and theJc,,portunity provided for them to 4
respond to the' concerns cited.
5 And with that, are there any-questions?
6-DR. UHRIG:
Any' comments of the committee members?
7 CHAIRMAN SEALE:
Well, I think it might be-8-
worthwhile.to indicate -- maybe I lost track of things, but 9
-when do you expect complete closure on:all-of this? MR. ELLIOTT; Well', complete closure -- are you E11
-talking'about 96-03 complete closure?
12 I mean 97-04 will be running in parallel, but 13 basically, implementation should be completed by the middle 14 of'1999, because we've granted: deferrals to a couple of-()
15 spring outages which have two-year operating cycles, and 1 61 even though we gave them till the end of'1998, they'll
'17 probably'come in and say can we have until early 1999, 18 becauseiwe're going down in early 1999 anyway, and we gave a 19-deferral:to one fall plant that wouldn't be going-down again 20-until the spring of-1999.
21' Sc6 based on the deferrals that-we have. I believe 22 that everybody should be implemented by the first half of 23:
1999.:
e I believe that we have not heard from any:-spring-
'24 25-
-plantsihaving-problems.
I-believe, when we get the-SER on
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the street, we should be able to-resolve any plant-specific (L
2 issues that'arise in sufficientJtime for those plants to-3 implement their resolution on time.
4 Vendors are geared up.
They've had a' lot of 5
practice at doing this now.
We probably have on the order 6'
of 10 plants'already installing, or maybe a few more than 7
that,~even.
I don't have the exact count.
8-
-So, I think there shouldn't be any problem with 9'
the actual strainer installation'taking place, at the 10 latest, by.the beginning or the middle of 1999.
1 11 CHAIRMAN SEALE:
What's the total number of plants 12 involved in this category?
13 MR. ELLIOTT:
Thirty-six. _If you discount Brown's 14 Ferry 1, 35, and' Big Rock Point was excluded from the k
15 bulletin because they-have a dry containment.
16 CHAIRMAN SEALE:
I have one other question.
There 17 is a corollary concern for PWRs that was addressed several 18 years ago on-strainers.
19-MR. ELLIOTT:
On sumps.-
20-CHAIRMAN SEALE:
On. sumps, yes.
21 MR. ELLIOTT:
Yes, sir.
22 CHAIRMAN SEALE:
Is there some sort of wrap-up, if 23 you will, or reconciliation of the PWR versus the-BWR 24:
approach?
-25 MR. ELLIOTT:
Yes, sir.
We are presently in the O
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process of gathering up more detailed information on the PWR
,-m
.( )
2 sump designs, and we are going to conduct an evaluation of 3
what we've learned since the original resolution of US-A43 4
and determine whether or not there is a need for further 5
action with the PWRs based on the types of things that we've 6
learned with the B's and also whether or not we just happen 7
to identify different issues today that weren't considered 8
before.
9 DR. UHRIG:
Any other comments?
10 (No response.]
11 DR UHRIG:
I would simply say that I was very 12 impressed with the amount of work done by the staff and its 13 contractor, as well as the utility, in preparing the 14 guidance documents.
I think this issue is well on the way
()
15 to resolution.
16 MR. ELLIOTT:
Thank you, sir.
17 DR. UHRIG:
I think that's it as far as this topic 18 is concerned, unless there are other concerns.
19 CHAIRMAN SEALE:
Okay.
Any other concerns by 20 anyone?
21
(;No response.]
22 CHAIRMAN SEALE:
Is there anyone from the industry 23 here that would like to make a comment on this issue?
24
[No response.]
25 CHAIRMAN SEALE:
Anyone else?
g
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[No response.)
()
2 CHAIRMAN SEALE:
Okay.
I guess we can go on to 3
the next one.
I think most of the players are already here 4
for that.
The next issue is the assurance of sufficient net 5
positive suction head for emergency core cooling and 6
containment heat removal pumps.
7 By the way, thank you very much.
8 DR. UHRIG:
Just one thing.
We do not anticipate 9
wilting a letter on this at this time.
There may be a 10 letter after we get the comments from the utilities, but at 11 this point there is not.
12 CHAIRMAN SEALE:
Okay.
13 Tom, you're the chairman on this.
14 DR. KRESS:
Thank you, Mr. Chairman.
)
15 I remind the committee that we had earlier had a 16 discussion on this issue and written a letter to the 17 Commission in which we stated a position that we thought 18 that it was inappropriate to use containment over-pressure 19 as a fix to a lack of sufficient net positive suction head 20 if such is found by the information that the staff is 21 receiving from -- I guess it's Generic Letter 97-04 that 22 they sent out to solicit information on how the various 23 licensees are determining their compliance with the reg 24' guides and the regulation on net positive suction head, and 25 so, since then, we received a letter from the EDO saying O,-
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- 1_
that -- I think it said1that they still intended to use some
()
2-over-pressure allowances,- and we suggested we have an 3
additional hearing.from the staff to increase our 4'
understanding of this issue and to see if we still feel like 5
our_ earlier position is the right one to take or not.
6 So, with that introduction, I'll turn it over to_
7 Jack Kudrick, who will enlighten us on this iesue a little 8
- further, 9
MR. KUDRICK:
Okay.
10 My name is Jack Kudrick.
I work within the 11 Containment and Severe Accident Branch within DSSA of NRR, 12 As Dr. Kress has correctly identified, we had a 13 meeting with the ACRS back in June of '97 on the Generic 14
, Letter 97-04, and we got a letter back with some areas that 15 they thought needed further development by the staff, and 16 those included a pathway associated with corrective actions, 17 total reliance _on over-pressure by itself did not appear to 18 be a success path, and that there ought to be some level of 19 evaluation when back-pressure cannot be guaranteed or 20 assumed-within the credible modes of operation, and two 21 examples that were pointed out within the. letter was 22 shut-down period as well as containment bypass, and what I 23 hope to do is address those particular issues and give 4
24.
somewhat of a better explanation than we had in the previous g
-25 meeting as to what we were doing and why.
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Let me start first with the area of periods when
()
2?
-back-pressure cannot be relied upon.
The two most notables 3
were shutdown and containment bypass.
-4 Well,.for shutdown, we're-essentially guaranteed 5
not to have back-pressure, but the. fortunate' thing is that 6
back-pressure is never-credited during that mode of-7 operation,!primarily because they do not need it.
8 When you don't have containment -- and for 9
example, in a BWR, the boiling, steaming off the reactor 10 will go directly to the outside, at least the secondary ~
~11 containment, bypassing t'ne pool, and that's important, 12 because the pool temperature will remain cold, and 13 therefore, we don't have the degree of NPSH concern that we 14 would if all the energy was dumped into the pool.
(I 15 DR. KRESS:
It might be of interest to the 16 committee that the primary _ reason that we have insufficient 17 net positive suction head is the pool temperature actually, 18 because the hotter it is, several' things happen, the less 19 dense it in and the earlier you reach the cavitation point, 20 so that it's the pool.Lemperature that tends to drive this f
21 issue.
22 MR. KUDRICK:
The other area is containment 23 bypass, and now, we define containment bypass as either 24 bypassing the containment or bypassing the suppression pool.
25-Now, bypassing the containment means that you're O
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basically.not containing within the containment, it is a
()
2L
-reddction in the amount'ofLenergy that would be associated-3 with the pools, whether it be a suppression pool or a sump.
'4 The other area is-bypassing of the suppression 5
pool but still being contained within the containment.
6
'Now, for DBA conditions, all boilers have a tech 7
spec associated with them to perform 4 testing of that u
8 particular bypass leakage area, and the acceptance criteria 9
is 10 percent of the allowable, and what we mean by 10.
allowable is that break area or bypass area that will not 11-exceed the design pressure of the containment, and it varies 12 depending upon what design we're talking about.
13 We think that, through that testing program and 14 through the minimization of the acceptance or allowable
()
-15 leakage-area, we have a good understanding of the bypass 16 characteristics of the containment, at least on the onset of 17 the LOCA, 18 Where we think that there is more of concern of 19 bypass is beyond DBA conditions, because now we're going 20 into areas where we have potentially much larger bypass 21 areas and, therefore, the effect is more significant.
~22 Now, what happens relative to that bypass area?
23-Well, it's going to tend to over-pressurize a BWR 24' containment design, because it's not passing through the 25 pool.
((
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.1:
There are.two mechanisms that-we-see:that can
()
2 control-that pressure.
3 One is the initiation of sprays,.and all of the 4
containments, BWRs, have sprays.
Mark I's and II's have 5
both dry well sprays and wet well sprays, and they will. tend 6
to minimize the-impact of the bypass.
is not a success path, there's 7-
-If that doesn't 1
8 also venting capability, which basically means just that.
.9 We would vent the atmosphere of the containment to protect-10.
the containment in the long run.
In other words, we would 111 vent and close the vent path.
12 All of these are not going to be negative-relative 13 to NPSH.
14 The one n2gative part of the challenge would-be if
()
15 we got containment failure, and containment failure means 16 loss of back-pressure, so that if we had bypass and we had 17 containment failure, we've lost the containment and possibly a,
18 even losing of the suppression pool,- because-we could-not
~19 comment on where it was going.to fail.
+
'20 The only_ impact on any of1the analyses that we 21~
would do for NPSH with-back-pressure or-containment failure 224 would be if the. suppression-pool was above 212 degrees 23-Fahrenheit, and then the pool would simply flash down to 212 24-and-maintain that.
25
-DR.
KRESS:
Jack, what-do you suppose-would' happen ANN RILEY & ASSOCIATES, LTD.
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in an ATWS event?
That flashing is going to be pretty (g4 2
vigorous, because the temperature of the pool might be G
3 pretty high in an ATWS.
4 MR. KUDRICK:
As a matter of fact,- something in 5
the neighborhood of 240 degrees F, I think, have been 6
calculated for ATWS condition.
7 DR. KRESS:
It may take some time for it get down 8
to 212.
9 MR. KUDRICK:
We have looked at the rate of 10 depressurization with various size holes, if you will, in 11 containment.
12 Primarily, we looked at the impact, 24-inch 13 diameter, 42-inch diameter.
Even in the very large areas, 14 because of the flashing of the pool, the depressurization is ts
()
15 very slow.
16 So, we would not anticipate a very vigorous 17 flashing, you know, where you just drop the pressure 18 immediately down.
It would be a very slow decrease in 19 pressure, even with large failure paths.
20 DR. KRESS:
Is that an event for which you need 21 net positive suction heFC that is not going to be there?
22 MR. KUDRICK:
Do we need --
23 DR. KRESS:
I mean, is that where you lose net 24 positive suction head and it is not going to be there for 25 that event?
[
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MR. KUDRICK:
No, no, no.
You have to take the rh
_(
i 2
next step now.
%J 3
We haven't, even with the ATWAS, exceeded 4
containment design capability.
So --
5 DR. KRESS:
So you are saying the pressure will be 6
there?
7 MR. KUDRICK:
The pressure will be there.
It is 8
only when you take the next failure.
And that is, assume 9
failure of the containment, that you would be in a situation 10 of loss of back pressure.
11-DR. KRESS:
So the question is, how 12 risk-significant is that particular thing?
13 MR. HOLAHAN:
This is Gary Holahan from the staff 14 also.
You have to also remember _what is going on in an
((_,/
15 ATWAS is that there is no reason to think that -- in many of 16 the cases you would have main feedwater and so you are not 17 using any injection mode.
In fact, to control the ATWAS, la you are usually minimizing water level in a vessel and the 19 water addition rates would be small and you are probably not 20 running any of these large pumps at full flow that you are 21 concerned about from an NPSH point of view.
22 In other words, certainly you are not using ECCS 23 in a full flow injection mode.
It is just something that 24 doesn't come about in the ATWAS case.
25 DR. POWERS:
But as yor go on and recover?
rs
', -}-
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MR. HOLAHAN:
As you go on and recover, all you
[V 2
are really doing is putting enough water back in the vessel
-3 to cover decay heat.
And that's probably more on the order 4
of a few hundred GPM rather than thousands of GPM and I 5
don't think there are NPSH concerns under those 6
circurastances.
And in fact, probably, most of those cases, 7
except if the ATWAS happened to be a loss of feedwater, you 8
are probably adding water either with a normal feedwater 9
system or from a condensate storage tank so you are probably 10 not actually in those cases using suppression pool for 11 injection.
12 MR. KUDRICK:
That kind of completes what I had to 13 say relative to consideration without backpressure.
Now I 14 would like to begin talking about what we look for when we f~
15 begin to consider backpressure as part of the NPSH 16 alculation.
For the starting point.
17 In that considerution is a good minimum 18 backpressure analysis.
Now, what does that mean?
We 19 generally associate containment response with a peak 20 calculated pressure condition.
Now we are looking at the 21 other extreme and that is what is the minimum pressure that t
'22 we could credit to the containment for purposes of NPSH.
So 23 we look to a series of conservative assumptions that would 24 not normally be applied when we are talking about peak 25 calculated pressure.
()
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A major effect is the consideration of containment r~N (J
sprays that are'on and the reason that's so important is
)
2-3 because it thermally disconnects the pool from the 4
atmosphere.
Now the pool temperature is not affecting the 5
atmosphere.
There is not an intimate contact.
6 What is controlling pressure of the, let's say, 7
wet well is the inlet spray temperature and that is ruled by 8
the RHR heat exchangers.
So we are now looking at a 9
different connect.
And it is much colder so therefore the 10 pressures are going to come down.
11 Generally, we look to a conservative decay heat 12 model that would maximize the energy that is going-into the 13 suppression pool and that is a combination of decay heat and 14 initial power level of the reactor.
Generally, we are j
15 looking -- we see conservatisms in the five to ten range of 16 the type analyses that we have seen so far.
17 The inclusion of containment leakage, and that's 18 associated with Appendix G type leakage, is a small effect 19 as long as you are in that vicinity, even for long periods 20 of time.
It is introduced because-it is a realistic 21 assumption but as far as the impact on the calculations, it 22 is relatively small.
23 Consideration of only one RHR, I would say, is 24 more consistent with single failure.
Max service water 25 temperature is generally the area that will give the worst
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condition because it will tend to minimize the reduction
()
2-
_ capability and therefore maximize the time period that the 3
suppression pool is up to temperature.
4 These are the inputs and basically what we are 5
looking at then is a computer analysis that will give us an 6
adequate profile of the pressure as a function of time and 7
temperature and, as Dr. Kress correctly indicated, generally 8
the worst point is with the maximum temperature.
But 9
because of the pressure profile, sometimes the delta between 10 the needed NPSH and the available as seen through the 11 calculation may be smaller earlier on in the transient or 12 later on when the temperature reverses.
13 Let me -- now that we have established basically 14 what we believe the minimum backpressure available to the
()
15 containment is through these conservative assumptions, we 16 now look at the needs based on the NPSH calculations.
17 Because there are multiple sequences and multiple points, 18 multiple pumps that would be involved in various sequences, 19 there are various needs of those pumps as far as NPSH.
We 20 generally only refer to the worst case or the most critical 21 case and so when we refer to a power plant needing 2 psi 22 backpressure to satisfy NPSH, that's only for one accident 23 sequence.
There are several other sequences.
24 Of the plants that we have looked at, the next 25_
most limiting case would generally only need about half the ANN RILEY & ASSOCIATES, LTD.
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1 backpressure as-the most limiting case.
And then if you go i
()
2i into the other cases, they generally will not need any 3
backpressure.
So.it is not.like all' sequences need that 4
pressure, tis the point that I am trying to make.
5 Now, I would like to address the issue of 6-corrective action.
When we -- we envision that the 7
responses to the Generic Letter 97-04 will be used to 8-identify the need for any corrective action.
And let me 9
just note that the scope of 97-04, unlike Generic Letter
-10 96-03, which is restricted to boilers, the generic letter 11' encompasses all plants, both PWRs as1well as boilers, 12 Let me also just indicate a scnedule on Generic 13 Letter 97-04.
For the most part, we've gotten the -- well, 14 first, the generic letter has been issued and we've gotten 15 the 30-day response which basica.ly indicated how they had 16 planned to respond to our generic letter.
We gave a 90-day 17-
'overall response which.means that on January 4 we respect
-18 all the responses to be in house.from industry if they 19-adhere to these schedules, 20 Now, we have gotten several plants where they
.:21 originally proposed much longer schedules.
We think after a 22 better_ understanding of t: hat we wanted, I think they are in 23 agreement with-our letter request and basically 24-fundamentally, what we are asking for is-what you have.cn1 25 the record today relative to the NPSH calculations.
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- We don't want-you_or them to recalculate what they 2
think we want.
We-want to understand what is Un the record 3
today.
And so we see-this as going into the~ files and 4
pulling out information and sending it to us.
5 We_also feel fairly strongly that the -- it is the 6
responsibility of the licensee when-they identify that they 7
~are operating outside their licensing basis, it-is their 8
responsibility to propose corrective action and as we heard 9
yesterday, obviously we hope that the corrective action is 10 to get back in.conformance to the licensing basis of the 11 plant.
12 The last item is just for completeness.
As we 13 start looking at the incoming, that there may be some 14 enforcement actions that may be necessary or there may be 15 some licensing amendments that may be part of resolution of 16 the issue.. That's really all I had to say on the subject.
17 DR. KRESS:
Do we have any comments or questions 18 from the members?
19 DR. UHRIG:
Could you describe the kinds of 20 actions that the utilities-might have to take to meet this 21 requirement?-
22 MR. KUDRICK:
It would strictly be a guess and I
.3 am not sure that's worthy for'the-record at this point in 2
24
-time.
So I would prefer to wait to see what is the incoming 25 on this particular area.
r b
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There is one area that I failed to mention and
()
2 during our meeting yesterday there was a good question that 3
came up and that is that we went back and looked at all of 4
the assumptions that would make the calculation conservative 5
for minimum back pressure and we thought we had essentially 6
considered all of the conservative assumptions possible but 7
there was one that -- well --
8 DR. KRESS:
It had to do with solubility of gases?
9 MR. KUDRICK:
- Yes, And it had to do with is it 10
-possible that a suppression pool, for example, could absorb 11 enough nitrogen as to basically bring the nitrogen, the gas 12 form, into solution into the suppression pool.
13 So I got out several handbocks on chemistry and 14 physics, including my old yellow one --
15 DR. KRESS:
How old is it?
16 MR. KUDRICK:
Well, I was just a baby when I 17 bought it.
18
[ Laughter.)
19 MR. KUDRICK:
But they more or less were in 20 agreement as to the solubility factors and there are two 21 parameters associating solubility.
Temperature of the 22 suppression pool and pressure.
Well, the temperature, 23 the -- as I increase temperature, my solubility goes down so 24 in effect I would be evolving nitrogen or air into the 25 atmosphereLif that was the only effect.
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The_other-effect, however, is more dramatic and
()
2 that is pressure.
Basically, it is a Henry's-Law abides in 3
this particular-area and what it says is that the amount of 4
absorbed gases is proportional to the pressure.
If I double 5
.the pressure, I double the amount-of' gas that's within the 4
6 solut. ion,_if you will.
7-Ek) if I -- and_I think that is the range of 8
pressures that we are talking-about here, a doubling of the-9-
pressure.
So.from one bar to two bar would be-more or less 10 encompassing on most plants.
i 11 The net effect for a typical boiler is.05 psi.
12 DR. KRESS:
It's not big.
P 13 MR. KUDRICK:
So, there's an effect, but we've 14 concluded now, after looking at it, that it's still a 15 negligible effect and still can be neglected.
16 MR. BOHNERT:
Was that.05?
17 MR. KUDRICK:
.05, 18 DR. KRESS:
That, of course, assumes saturation,
^
19 which is --
20 MR, KUDRICK:
Right.
is going to take some time to 21 DR. KRESS:
22 achieve.
23 MR. KUDRICK:
That's true.
24 MR. POWERS:
No, I think it would be saturated 25 anyway, at all times.
()
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DR. KRESS:
At start, but during the transient,
(
.)
2 you're increasing the pressure --
3 MR. POWERS:
And the pressure moves up.
4 DR. KRESS:
-- and I think it may take a while for 5
that gas to saturate the full plume.
I don't know how long 6
it would take, but I would suspect it would take a while.
7 MR. POWERS:
Well, it will saturate quite quickly 8
if you're sparging.
If you're not sparging, it will take 9
forever.
10 DR. KRESS:
If you're sparging.
11 MR. POWERS:
I mean it would really be slow.
12 DR. KRESS:
In the top surface is what I'd be 13 assuming, but I don't know if it's true or not.
14 Well, thank you, Jack.
A'\\,)
15 MR. KUDRICK:
Okay.
16 DR. KRESS:
We probably will have a letter on 17 this, because we are already on record as --
18 MR. POWERS:
We've looked at a range of dba's, and 19 it's really kind of design basis space that I'm thinking of 20 here.
21 I think that's what we were thinking of when we 22 wrote the original letter, was really design basis space, 23 maybe with a tinge of beyond-design-basis space, but 24 primarily design basis space, and what we have here is an 25 argument that says, okay, when I don't have pressure, I have ANN RILEY & ASSOCIATES, LTD.
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o 50 1-a-cool pool and-I don't need'the pressure, and when I have a "r'1; Ithave pressure,,and those look like -- I mean I
2
. hot-pool,
.%)
3 those are two good limits.-
4 DR. KRESS:
-I have pressure more than the 5
saturation.
6:
MR. KUDRICK:
I mentioned it yesterday but I 7
didn't mention it this afternoon, and that is we also 8
explore-the potential of a loss of back-pressure when you 9-
'need the back-pressure, and we do it on the basis of what-if 11 01 scenario.
11 We're not suggesting that it is unreliable or
-12 anything like that, but we feel that, to give that overall 13 assurance, we'd like to understand from the operating 14 utility exactly what actions or what effects those_ pumps 15 would have if they suddenly lost those pressures, and that's 16 an important point, because it basically points another
~
17
_ point in between'the two extremes.
18 MR. POWERS:
And what do they tell you? MR. KUDRICK:
Well, we've gotten different 20 answers.
1 21 One answer was that their pumps-were tested at 22 full cavitation for one hour.
Then the pumps were-23 disassembled-and there was no evidence of any damage, and 24 they were reassembled, and supposedly they were put back-25
'into service.
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The other possibility is what type of actions (sv) 2 could one take to remove themselves from cavitation, and so,
(
3 what is the level of cavitation and the perception of the 4
ability to survive a loss of back-pressure and, the other 5
one, what are the type of operator actions that are possible 6
to remove you from cavitation source, and I alluded to 7
several of them while we were talking, the fact that only 8
one sequence actually gives you this more serious event and 9
so on and so on.
10 But the only time that that's meaningful is when 11 we're talking on a case-by-case basis.
12 DR. KRESS:
Once you're in cavitation, there's not 13 much you can do.
14 MR. POWERS:
Oh, yes.
(O,)
15 MR. KUDRICK:
Oh, yes, there is, 16 MR. POWERS:
Pump down.
17 DR. KRESS:
Except a back-flow or something.
18 MR. KUDRICK:
Let me just add one point, that when 19 they were testing that pump under full cavitation, that they 20 were still getting above the necessary flow from an ECCS 21 function point of view.
22 MR, BERLINGER:
Jack, let me add one other 23 thought.
24 My name is Carl Berlinger.
25 That thought is that the amount of containment
/ h
(
\\
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52 1-back-pressure that'sLbeen granted!on a plant-specific basis-i 2.
has beeniquite limited:to somewhere -- well,Lup to about,-I x) 3 31
- think,E5; psi for the maximum case.
L41 MR. KUDRICK:
That'sfa very good point.
The-fact-5:
- that we,have afminimum back-pressure analysis curve doesn't 6:
mean'that we would give approval;for that.
7 We tried to minimize the approved back-pressure in 8
.both duration and magnitude.
So,_many times-it's just a-L
- 9
'small fraction.ofLthe minimum back-pressure curve.
- 10 DR..KRESS:
You don't have a criteria that says 11 this minimum for-this amount of time integrated with --
121 MR.:KUDRICK:
Well,.whenever we go to 13_
case-by-case, we_do'not have specific criteria, and I don't-14 think, in this case, because of r a' the variables, that it - would make the most appropriate direction.
16 MR. HOLAHAN:
In my experience, the more credit 17_
they give, the more management attention the decision gets.
18 DR. KRESS:
That's your shaded area.
7 19 MR. HOLAMAN:
That's a shaded area.
4 20 DR. KRESS:. Is there further questions or 21' discussions?-
22"
(:No response.)
H23 DR. KRESS:
Well, thank-you,. Jack.
It's been very 24
_ enlightening,.and we appreciate the' presentations.
25 CHAIRMAN SEALE..You propose to write a letter?-
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- DR'.'KRESS - Yes, we have to.; We're:on record:as
()
2 saying'something,_and this is to close the issue --
'3-CHAIRMAN SEALE:
Very-good..
4 DR. KRESS: ' -- supposedly.
f
-5~
-So, we'll have some kind of letter.
I'm not r"re 6-what_it will say.yet.
s7 CHAIRMAN SEALE:
Okay.
Do you want to discuss 8
that a bit?
We do have a little bit of time on our hands.
9.
Just in general?
'10 DR. KRESS:
I might get a feel of the committee.
- 11 LWe have.two optionu.
We can say yes, this is an acceptable
-12 procedure, or we can say no, we stand by our original
_ position.
13 14 Our original position said taking over-pressure
()
15.
was not appropriate, was based on the concept that 16 partially a defense-in-depth concept, which is -- which says 117-that~a design basis accident has these prescriptive L
18 !
requirements in it, and they're there because wa can't 19-really calculate the risk,. we don't have risk acceptance 20
-criteria, so we develop these design basis servants for all r
t 21' the accident sequences and make the leap of faith that-if 20!
you fitiall these-requirements, then you have acceptable 23 margin and~ acceptable defense-in-depth, and if you start 24 eroding away these prescriptive requirements and allowing.
25 more'and more deviation from them, then you're. eroding 1
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54 1-defense-in-depth and you're eroding margins and you don't-m (Gl-2 really know how much, because you cannot very easily 3
correlate the design basis accident space with risk space.
4
.There's a definition connection, but there's no real firm 5
correlat?">n there.
6-So, that was kind of the basis of our original 7
recommendation.
8 Now what we've heard is they've made a sort of 9
judgmental PRA in the sense that they've looked at sequences 10 where they think it might be important, looked at it from 11 the standpoint of a qualitative evaluation.
12 I would call this a very limited qualitative PRA 13 of type in which they have demonstrated to some extent that 14 they think the risk implications of allowing some limited O
(,/
15 case-by-case allowance of over-pressure is probably not very 16 risk-significant.
17 MR. POWERS:
I'd call it more like a failure modes 18 and effects analysis.
19 DR. KRESS:
Yes, more like that, you're right.
20 MR. POWERS:
They've said, okay, if I fail in this 21 circumstance, I don't need the pressure.
22 DR. KRESS:
Yes, that's exactly right.
23 MR. POWERS:
But then, in this other circumstance, 24 I'm guaranteed to have the pressure.
25 DR. KRESS:
Yes, but you can translate that into
~
(s' -)
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saying what effect it might have, a judgement on PRA, to
)
2 some extent, and so, the question is now, do we still want 3
to stand by our original position, or do we think this is an 4
acceptable approach, and I'm open to suggestions and 5
comments from the members and look for guidance on what you 6
think.
7 CHAIRMAN SEALE:
Any comment?
8 DR. SHACK:
I found the case fairly persuasive.
I 9
have no problems with eating crow, 10 CHAIRMAN SEALE:
Feathers and all.
11 MR. HOLAHAN:
Could I suggest that there are a 12 couple of alternatives besides the crow /no-crow 13 alternatives?
14 The committee might not be comfortable with the 15 concept in general, but you could, for example, look at the 16 specific cases that we have recently approv 1 and sort of 17 take it out of the philosophical range and see whether you 18
-- even though you may not be comfortable with the concept, 19 that in fact -- I mean we didn't present the specific cases, 20 but we could -- if the committee wanted to pursue this 21 issue, we could present, you know, the specific cases and 22 why we made the decisions and how much credit we gave for 23 the last one, two, or three such cases.
24 DR. KRESS:
Personally, I really like that 25 suggestion.
()
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-l-MR.'HOLAHAN:
The~other' suggestion is-the
()
l2 committee aidn't.necessarily_have~to take an all-or-nothing -approach.to this.
1 4
You could make'a-recommendation that says, well,
{
5 normally, you don't give credit, and if you do, you ought to 6
have a'PRA or a failure. modes and effects analysis or 7
something.
8' So, I think, you know, we started'out with sort of 9
one. recommendation, but-I think.you could construct sort of 110 a more complicated recommendation.
~11 DR. KRESS:
They're smiling because they've 12 already written a letter.
F 13 Well, we certainly appreciate that, I think those 14 are excellent suggestions, and with that as guidance, we can 15 come up with some sort of a draft and discuss it later.
16 MR. POW AS:
I guess it's really the bounding or:
17 the' limiting nature of the argument that continues to cause 18 pause.here.
-Is there no interpolation between the extremes 19 that get you in trouble?
-20 Taking extremes of, when I don't have pressure I 21l l don't have temperature, when I do have. temperature I'm 22
' guaranteed to:have pressure, is there any interpolation
-23 between those that gets me into~ trouble?
24
'DR. KRESS: :That's the' thing that gives me pause, 25
'and'I think you need a full PRA.
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MR. POWERS:
I continue to come back to DBA space,
(~%
- v!
2 and I said I ought to be able to do this without a PRA, 3
because I'm working in DBA space, and what I'm asking is 4
what are the bounding -- this is a defense-in-depth 5
argument.
6 We accept that nearly all the easy accidents that 7
you come up with need the additional head and that, even if 8
they do run into cavitccion problems, you can back off in 9
'the pumps, and even if you don't back off in the pumps, 10 these are pumps that are not particularly susceptible to 11 cavitation failures.
12 CHAIRMAN SEALE:
Well, I think we want to be very 13 careful in how large we decide we want to imagine our plate 14 is in terms of asking for more complicated analyses, more
/
(_ l 15 detailed analyses when it does appear that the consequences 16 are not that adverse -- that is, cavitation is not a 17
' catastrophic problem, response to that is straightforward 18 and appears to be adequate to the needs of the problem.
19 MR. POWERS:
Well, it's just a huge change in 20 degradation of your safety strategy to come in and say, 21 first of all, I would depend on a consequence of the 22 accident to get me out of the accident or to say, second of 23 all, that I will run my equipment that I spent huge amounts 24 of money assuring stringent operability requirements, but 25 now I'm going to count on it being able to operate in a
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regime it was never intended to operate in.
()
2 Yes, if you were to go into a PRA with a 3
risk-based set of regime, this might be acceptable, you 4
might convince yourself it's acceptable, but when you stand 5
a defense-in-depth DBA kind of regime, you're really getting 6
into a place where you can be accused of schizophrenia if 7
nothing else.
8 CHAIRMAN SEALE:
Well, I think we'll have to 9
discuss our mental health in a little bit more detail as we 10 go along here.
11 Well, you did a job so well and I guess you 12 mane.ged to get through the subject matter so much faster 13 than we had originally allowed you to or scheduled you to, 14 and our next item on the agenda is the presentation on the
.O
\\,/
15 NRC performance plan by Mr. Funches and someone from the m
16 EDO's office, and I don't think we can speed those people up 17 any at all.
18 I am afraid that what we'll have to do is just 19 socialize together, and I don't know there's anything else 20 we can do at this point.
21 Does anyone have any suggestions?
22 DR. SHACK:
I think the reconciliation people 23 aren't 24 CHAIRMAN SEALE:
We haven't gotten anything to 25 reconcile yet, unfortunately,
(/,)
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i DR. SHACK:
But the subcommittee chairmen for some
()
2 of those things aren't here yet, j
i 3
CHAIRMAN SEALE:
That's what I mean.
So, we i
4 really can't attack those issues, which are usually a i
f 5
- filler, 6
- So, I'm afraid what we're going to do is. recess 7
until-3:30.
1 8
DR. ZRESS:
That gives me time to work on the 4
9 letter.
10 CHAIRMAN SEALE:
Okay.
Yes, I would urge you, if i
11 you don't have your letters, let's get on them.
12 (Recess.)
r 13-CHAIRMAN SEALE:
We are back in session.
14 This afternoon, we are going to hear about the
()
15 NRC's planning and performance management Jystem.
We have 16 Jesse Funches, who is the chief financial officer, and Jim 17 Blaha, who is the executive secretary of the Executive
- 18 Council nere to tell us all about it.
19 Then.there's a'little bird sitting on the rail 20-back here in the corner,. I guess, who is going to check and 21 make sure everything is -- or find out_what it is he is suppcaed co be doing, too.
I know we are all interested to
. 22-23 -
know whac we are supposed to be doing. - We keep hearing 24 words like strategic assessment, rebaselining and issue l
25 papers, production of a1 strategic plan and implementation.
l O
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1 And now we also have this big, thick -- or relatively thick
()
2 performance plan for 1999 and these gentlemen have offered 3
to tell us a little bit more about that process and try to 4
respond to any questions we have so it's all youra.
5 MR. FUNCHES:
What I would like to do, I think l
6 what we will do is I would like to give you a broad 7
framework of where we are trying to go and the system that 8
we are implementing and then Jim will talk to you about some 9
very specific as it relates to the -- the implementation l'/
part of that system.
11 Just to take a few minutes to go back into why we 12 are doing this, there are a couple things, a couple of 13 reasons why we are looking to make these changen.
One is 14 that the citizens are basically demanding more
()
15 accountability for improved results and outcome.
That has 16 Jed to something, a law that was passed by Congress called 17 the Government Performance and Results Act.
Some people 18 call that GPRA.
Congress likes to refer to it as the 19 Results Act.
And the system that we will be putting in 20 place will respond to that.
We will talk about the specific 21 pieces as we go through that system.
22 I think the other thing is we es an agency want to 23 improve how we manage our program and our resources.
We 24 want to be in a position that we look at managing the agency 25 more like a business.
We want to look at both effectiveness l
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which we always have.
We would also want to increase the
()
2 emphasis on the efficiency side or the cost side.
So that's 3
what'a pushing us towards change.
i 4
The Chairman implemented, initiated something r
5 called the Strategic A9sessment Rebaselining.
That 6
has -- that effort itself is concluded.
It concluded with 7
the issuance of a strategic plan and a copy of the strategic 8
plan has been provided to all the employees and a copy is 9
there.
And we want to make that a living document.
It is 10
-going to be part of the management of the Agency.
11 If you go to the -- what I will do is summarize 12 the systems that ce are implementing and talk about the 13 component parte and then, as I mentioned earlier, Jim will 14 talk about some of the dethil.
15 If you go to the first chart, what I would liks to 16 do is talk about what are the goals that we have set for 17 ourselves in this planning and performance management 18 system.
Let me just emphasize it is not a computer systein 19 per set it is more of a process that we are looking at.
20 One of the things that we wanted to do was we 21 wanted to make sure that we precede the budget decision with 22 strategic and policy and planning decisions and that is we 23-want our budget to be policy driven and we want the budget 24 to be results oriented.
So we want to establish what our 25 expectations are and then build a budget to support that.
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t i
I think in the long term,-there'is a lot of
()
2 benefit to us also in that we will have a more efficient o
1 3
process-and especially a more efficient process in producing
~
t 4
a budget.
Because we will know what the planning direction 5
we are going in and the budget then will just follow that' 6
- ~ become a pricing exercist.
7 Another design criteria that we have was that'we 8
wanted to be a learning organization.
That is, we wanted to 9
use the results-from assessments to inform our planning and 10 budget decision.
We want to learn from implementation of 11 our programs.
We also want to learn as to the environment 12 change.
And as I mentioned earlier, we wanted to be dynamic 13 in planning rather than static.
I 14-A third objective that we have basically gets down
()
15 to we want to invest in those things that add value.
16 Therefore, what we want to do is identify and sunset the 17 activities that don't no longer add value or have limited-18 value and I don't -- you know, some people might look at 19 tuat as we want to cut the budget but what we want to do is 20 to allocate our resources to the things that have the best 21 payoff to us as an agency, given our mission.
22 And, lastly, we want to build a monitoring 23-component so we can look at the progress of how we are 24 moving toward achieving our goal and want to monitor it 25 throughout the year.and basically that's good management.
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What I am going to do in the next several charts,
()
2 I ' r. going to build this system in a circle and I'm going to 3
talk about each of the components.
4 The first component or the first phase is to set 5
the strategic direction.
And we do that through a couple of 6
documents.
We have a strategic plan.
That strategic plan 7
currently is being updated to reflect what we have learned 8
this year from building the plan, from consulting with 9-Congress and OMB and also from program reviews that we have 10 ongoing as part of the operating plan.
Jim will talk about 11 those more in detail later, 12 We also have as part of that, setting the 13 strategic direction, the performance plan.
And I think the 14 document you have there, if you concentrate on the first
(
15 part of that plan which talks about these are our 16 performance goals, these are the metrics we plan to use and 17 these are the targets we would hope to achieve, both the 18 performance plan and the stratrgic plans are documents that 19 are required by the Government Performance and Results Act.
20
. Congress was heavily involved in the strategic plan 21 development.
We have to consult with them.
We expect them 22 to continue to be invo2ved in that.
23 In terms of the performance plan, we produced our 24 first performance plan.
That plan went to OMB along with 25 our proposed biaget to OMB.
We have to produce a final plan h
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that will-be sent to Congress in early February as
()
2 part ---it will go at the same time that the budget goes to 3
Congress.
lt Another piece that we are developing, and this is 5
again to bring more discipline into our planning and i
6 budgeting proc 9ss, is program guidance.- What we are trying
.7-to do there is *.o get early view on what the programs were-l i
8_
we want te pursue to implement the strategies and goals that 9
are in the perfornance plan and the strategic plan.
10 The major input to these output documents as the i
i 11 cycle works will be from program reviews and completed l
12 assessment.
This is what we will call bottom-up reviews.
13 We will also be doing top-down reviews where we look at the 14 external environment, see if there are major changes out
()
15 there that cause us to want us to change our strategies.
L 16 One of PSe major challenges we have now, and we 17
-have a grour of pe -
' working on as we speak is to create a 18 better link between che outcome goals and strategies and the 19 activities that we are performing.
We did some work this 20 year in parallel.
We are taking the next step now to try to 21 bridge that gap to make sure we've got a seamless-linkage 22-between our-goals and the activities that we are performing.
I 23 We can move to the next chart.
24 The second piece of the planning and performance 25 management system is determining what resources and planned i.
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accomplishment that we want to achieve or what activity we
()
2 want to pursue and what output from those activities we 3
expect.
Once we have developed a broad strategy, strategic 4
directive and program guidance, we can then begin the phase 5
of allocating the resources that are achieved, the results 6
that we would have defined and th' performance plan, the f
7 strategic plan and carrying out the programs that we would 8
have defined in the program guidance.
9 To accomplish this, we will be doing several 10 things.
First, we will establish planning assumptions and 11 fiscal guidance for budget development.
What do we mean?-
12 What we mean there, what we want to do is define and agree 13 on those significant external factors that affect our work, 14 That is, what's going to happen to the reactor industry, do O
(,,/
15 we expect that industry to grow, decline substantially or 16 stay about the same.
17 We also want to specify scenarios so that_we have 18 continuously built into our budget so that we can respond to 19 changes by Congress, OMB and also to help us make the 20 priority decision in allocation of resources.
Next, we 21 would develop budget proposals.
We always did for the 22 Commission and we are looking this year to have a more 23 streamlined process rather than debate programs or policy.
24 We will be looking at just how to cost and how to allocate 25 the delivery of the resources.
[
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1 The last, obviously, is the budget to OMB and
()
2 then, ultinately, to Congress and we will go through that 3
process.
I don't know if you've heard, we just recently got 4
our OMB decision this year on the fiscal year 1999 budget 5
and actually we got a very good decision from them.
The 6
reductions were minor, relatively speaking and we did not 7
recover those reductions.
8 Next chart.
9 The third -- the third piece of the process is 10 what we call measuring monitoring performance.
Basically it 11 is implementation.
I am not going to spend a lot of time on 12 this because Jim will be talking in a lot of detail about 13 where we are and what we are doing there.
And basically 14 what that involves is an operating plan where we communicate
)
15 expectation, you know, from the top all the way down to the 16 bottom.
We link organization goals with agency goals and 17 strategies and then periodically we have reports and see 18 where we are going.
19 Another piece that is required by the Govertiment 20 Performance and Results Act is a performance report that 21 goes outside the agency.
That performance report will be 22 going to Congress and to OMB'and that performance report 23 will report on the -- how we e:cecuted the performance plan.
24 That first performance report will cover fiscal year 1999, 25 which begins next September and the report will be issued in ANN RILEY & ASSOCIATES, LTD.
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1 March of the year 2000 which will be six months after the
()
2 end of fiscal year 1999.
3 What we are looking to do this year is to do some 4
pilot work on that report, looking at the data sources, s
5 There is a new law now that proposes that the IG audit the 6
data sources, audit the performance report.
We are working 7
with the IG and we would be working internally, just look at 8
the data sources to make sure they have the right controls 9
and they can withstand scrutiny.
10 Next chart.
11 The last component and probably one of the most 12 critical components is the assessment phase.
Without doing 13 some type of assessment, we have a tendency to become 14 static, we say we've got it in place, let it run.
(~(,)/
15 What we want to do is we want to identify how 16 we're proceeding, whether we're achieving the results, and 17 if we're not achieving the resultr, why not, and what 18 changes we need to make to our programs, our strategies, our 19 goals.
20 We also want to assess the cost, can we achieve 21 things less costly, again coming back to trying to operate 22 like a business.
23 There are several ways that we are planning to do 24 assessment.
-25 Thera are p;ngram reviews, which is tied in very
\\').
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closely with the operating pisu that we will be doing
()
2 annually.
There are self-assessments that are ongoing that 3
we expect each organization to perform, and there are what 4
we call program evaluations.
5 These program evaluations are integrated very 6
closely with the regulatory excellence concept.
What we 7
Want to do there is we want to have quantitative looks at 8
how well our p., grams are working and whether or not they 9
need to be chan'
- c..
10 We have a lot of activity, for example, now 11 looking at how we -- looking at the inspection program, all
-12 of the components of that, to make sure that the inspection 13 programs we have now are achieving what we want it to 14 achieve, and the second question is are we achieving what we
(
15 r'.t to achieve at the least cost.
16 I think, overall, what this tells us, when you 17 complete the system, is what we're trying to do -- we're 18 trying to plan what we want to do, and then we're trying to 19 implement that plan, and then we're trying to apply some 20 very good management concepts to do that.
21 I think it will require the agency to make some 22 shifts in how it operates, and we think we are making steps 23 to do that.
We have a ways to go, but we believe that, in 24 the long term, what we will have is we'll be able to achieve 25 more safety with the resources that we have.
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That's the ultimate outcome that we are trying to l
()
2 achieve.
3 The last chart again just shows the four 4
components, and the executive council, which we've got 5
.two-thirds of-it here today,-definitely supports this 6
concept, the Commission supports it, and the staff is 7
Lworking very hard to implement it.
8
.Again, just in summary, what we want to do, we-9 want to set ene strategic direction through our strategic-10 performance plan and program guidance using inputs from the I
-11 monitoring assessment activities.
12 We want to determine the resource, have an early 13 plan-and guidance, just pricing out what we need to do, and l
14 we want to allocate the resources to achieve the results f
()
15 that we have determined.
16 We then want to monitor implementation, and then l
l 17 we want to assess how well we're doing and feed that back l
18 into the system.
19-What are the next steps?
l 20
. We are implementing the system for fiscal year 21 2000, which.is the upcoming budgeting cycle.
We are trying.
. 22 to implement all phases of the process.
As we implement, we l
23 obviously will learn, we'll feed that back, and then we'll 24'
.make modifications as we go.
25 We expect to learn a lot as we go.
We want to
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follow the same ideas that we have for the agency in
_2
-. implementing this.
3 That is, we want to assess how well we're doing, 4
_ eliminate those components that don't add value, and then make tbs modifications and then implement the second year.
5 I'think we are making good progress, and I think,
?
_in the long term,'we're going to have something that's going 8-to be very good 'for the agency and put us in a very good 9
position to get the resources that we want. DR. KRESS:
What parts of this process wasn't done 111 before?
When you go through a planning and budget cycle, 12-you generally do these things, but I guess it wasn't 13 formalized or centralized?
14 MR. FUNCHES:
I think the agency has gone through
)
15, different cycles, also.
We-went through a cycle way back on E16 PPPS, and I-think a lot of them have different-components of 17 this.
- 18 I think what was happening was we were trying to 19' do, in some cases, a lot of things at the same time, trying 20-
-to do programming and budgeting at the same time, and you 121 just can't do.that in a very short period of time.
22 DR.-KRESS:
This makes it a living, continuous-23 thing.
24 MR. FUNCHES:
Right.
More of a sequential 25
' process.
()
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1 DR. KRESS:
Sequential.
( s-
)
2 MR. FUNCHES:
I think the other key thing that's 3
very different is I think there's a lot of emphasis on 4
achieving results as opposed to outputs, as opposed to 5
saying I did so many inspections, as opposed to I prevented 6
so many SCRAMS or whatever.
7 DR. KRESS:
Could you come up with an example 8
performance measure that you might have?
What would be a 9
typical performance measure you would be looking for?-
10 MR. FUNCHES:
At the top here -- and these are in 11 the strategic plan -- at the top, for example, we said what 12 our outcome is and how we want to define safety in a reactor 13 is that we don't want any death and illness in the operation 14 of a power reactor.
That's the ultimate outcome. -That's
(
15 the general goal.
16 DR. KRESS:
Yes.
17 MR. FUNCHES:
Underneath that 18 DR. KRESS:
You work downwards from that.
19 MR. FUNCHES:
Underneath that, what we say is we 20 want 21 DR. KRESS:
What page are you looking at?
22 MR. FUNCHES:
Page four.
23 DR. KRESS:
Four.
Okay.
24 MR. FUNCHES:
Underneath that, we say we want zero 25 severe nuclear reactor accident, and we define what that I
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means, and then, underneath-that, we say the goal is we want
/3 2
to maintain a low frequency of events which could lead to a i
j 3
severe accident.
4 DR. KRESS:
Okay.
5 MR. FUNCHES:
So, that's the outcome we want.
6 DR. KRESS:
That's what an AEOD actually measures.
7 MR. FUNCHES:
Right.
And then you see down here 8
how we're going to measure those, and then over here you'll 9
see we want zero significant radiation exposure due to 10 reactors.
11 Now, we've got a different goal when you get to 12 material, because -- our goal is not zero there, because 13 it's slightly different.
14 And again, what we're going to measure -- the data
()
15 we're going to use that is going to be data from the 16 abnormal occurrence system that we have, and that's how 17 we'll define that particular measure.
18 One of the things we found, say, compared to some 19 other agency is because we have a -- some agencies, for 20 example, for a traffic accident, means reducing the number 21 of traffic deaths.
22 DR. KRESS:
They can't reduce it to zero.
23 MR. FUNCHES:
So, we have some absolute there 24 that's -- we spent a lot of time on that.
25.
The program manager, Joe, himself, we had a i-
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facilitator, and we went through and -- probably about two
()
2 days -- coming up with, really, what are the outcomes we're 3
trying to achieve, and I think we've come up with a good ~
i 4
set.
?
51 One of the things we're looking to see if the next
}
G level down, like maintain low frequency, do we need 7
something a little bit more to make sure we match it to the 8.
activities.
j 9
CHAIRMAN SEALE:
You know, we have been struggling 10 with the problem of performance indicators for risk -- in t
11-the context of safety and so on, and one of the ideas you 12 come up with is that performance is something you ought to 13 be able to measure, and the measuring of the performance 14 should not involve things which catastrophically affect the
()
15
- process, 1G In other words, to say we have no reactor 17 accidents is not a good performance indicator, because the
-18 horse'has left the barn by the time you it the indicator.
19-I mean if that's how far you go to go before you measure L
20 something changing, you're in trouble.
21 MR. FUNCHES:
That's exactly why we built down.
l 22 CHAIRMAN SEALE:
Yes.
So, we really need to think L
r H
23
' in' terms of subcategories, if you will, to more carefully 24-articulate what it is -- the first measurements or the first i
25 sensations that.our antennae feel, t
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MR. FUNCHES:
The way we kind of look at this is
()
2 exactly what you said, is this is the ultimate goal.
3 CHAIRMAN SEALE:
Sure.
It's a goal.
It's not 4
really a measure in that sense.
5 MR. FUNCHES:
Right.
And what we are trying to i
6 say is the way you don't get there, you keep the risk low, 7
and what are the things that give us the indication that we i
8 are getting too close or increasing the risk too much to 9
that goal.
10 That's somewhat the philosophy behind a lot of 11 these goals and the intermediate goals, which are the ones 12 that we will be measuring against, not the general goal.
13 MR. BLAHA:
I think I can give you an example of 14 what we're toward, at least, as it relates to achieving the O
(,/
15 goals.
16 The strategic plan has the higher-level goals and 17 it has strategies and it has sub-strategies.
18 I think what we are trying to do is have everyone 19 understand how they are contributing to those strategies and 20 sub-strategies with day-to-day activities that they do, and 21 in the operating plans, we've asked them to look at those 22 sub-strategies and say what are you doing to support those.
23 So, one of the back-up documents you have in your 24 package is the state programs assessment that we did, and 25 their operating plant is here.
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I 75 j 'One ofithe sub-strategies, for example,-in the I
()
2 strategic plan -- and this is on page 12 of the state f
3 programs operating plan, which is the last part of that i
4 package that looks like this -- it's probably easier if I 5
just explain it.
6 The strategy says we will be alert to the changing 17 environment in the electrical utility industry and t1mely 8
adjust our regulatory programs to maintain safety.
9-So, what state programs is doing to support that
~10_
sub-strategy 11s they are going to support Commission 11 representation at NARUC in three NARUC national meetings.
12 So, that's an example of how something that state 13
. programs is doing is contributing toward that sub-strategy.
14 Now, where we have to evolve to is how effective 15-were they?
Did it produce the results that we were looking 16 for?
So, this is an evolving process.
17 The first step is to say how do your activities 18 link to these strategies?
The next step, what we have to 19 evolve-to, is did they work?
Is it producing the results we 20 want?
21 MR. FUNCHES:
You know, trying to make a leap from
' 22 this activity'to some type of function that, you know, this
- 23 activity contributes at the rate of 1 over X or whatever, X
' 24 squared, is not very easy, and I don't think we're going to 25 get -- you know, you-can get to that and say one inspection O
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-2 I don't think we can get there.
3 I-think what-we can do and what we're trying to do 4
now is whatfJim is saying, is if I follow this strategy, it 5
will help me achieve this goal because of A,-B, C, and D.
I 6
I will implement this strategy with -- and I think 7.
for example I'm just picking inspection.
If I.incpect it r
8 will implement the strategy because it will allow me to do 9
A,1 B, C, and D, and finally use the strategies and 10 sub-strategies as the link between the outcome goals what'we 11 want and the activities that we perform 12 DR.-KRESS:
Most of-these things seem to address 13 effectiveness.
How do you deal with the efficiency part of' 14 this?
()
15 MR. FUNCHES:
We have one goal in the strategic 16 plan called regulatory excellence, and that is'the goal that 17 gets at the efficiency part, and I think that's -- and again 18 this is one of the -- we had a lot of discussion of this 19 with the program managers at the group that was coming up
~20 with these goals and there's two places I would point you 21 to'.
22 DR. KRESS:
Page 22?
23 MR. FUNCHES:- Right. -That's one page, where=we-24 talk about regulatory excellence and what regulatory 25 excellence is about in terms of trying to make things more ANN RILEY & ASSOCIATESi LTD, Court--Reporters 1250 I Street,1N.W., Suite'300 Washington, D.C.
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1L efficient.
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2 Again, this goal is overarching and it covers j
3 everything we do.
You know, you could have put it in each 4
other piece.
1 i
.5 I think the other thing we talked about was the j
6' fact that you want an efficient regulatory program also from 4
7 the utility' operating's point of view.
You don't want to I
8
.have regulation for regulation's sake.
You want to have a 9
very efficient regulatory program from that perspective T
-10 also, but that is where we address the efficiency, and this 111' is, even.though we have identified it as a separate arena, r
12 it really is an overarching goal and it probably should be 13 one of the things that we want to some kind of way make sure 14 it is clear'that it is overarching.
()
15 There have been several papers.
I think you all 16
'might have been briefed on regulatory excellence.
3 17 DR. KRESS:
Yes.
18 CHAIRMAN SEALE:
Yes.
19-MR. FUNCHES:
On that concept -- and there's two-20 pieces to that concept -- efficiency and effectiveness.
21 MR. BLAHA:
We also are addressing efficiency as 22 part of the program review process.
23 CHAIRMAN SEALE:
Yes.
l
-24 MR. BLAHA:
There are about a dozen questions that
. 25; we -
that the program managers have to ask themselves, a-
. O
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these questions, and answer them for us for the program
()
2 review process.
3 One of those questions is are there efficiencies 4
that can be achieved in your program, and we don't treat 5
that lightly.
That usually is a point of discussion at 6
every meeting we have, every program review.
7 Ideally you measure every output -- I like to 8
think of it in five metrics -- of quantity, quality, 9
effectiveness, efficiency, and timeliness.
10 We are not measuring all those metrics yet, and in 11 some cases you can't measure all of them, but that is the 12 kind of thinking that we are trying to impose.
13 DR. KRESS:
Is all of this centered in the 14 financial office?
()
15 MR. BLAllA :
That's a good segue maybe.
16 MR. FUNCHES:
And I think that's a very good 17 question.
18 What we are -- I guesu we are just kind of the 19 steward of the system or the process, but I think and 20 throughout this for us to be effective as an agency, it 21 can't be the financial office going off and doing the 22 strategic plan, the performance plan, and other things.
I ',
23 has.to be integrated throughout the organization.
24 MR. BLAHA:
Yes, sir.
25 MR. FUNCHES:
And certain components that have i
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1 been led by the EDO's office.
The other thing is that -- I
't
()
2 mentioned this earlier -- that the Executive Council is 3
really very involved in this and it's from the overall 4
agency's perspective because again it is not a kind of a 5
CFOs thing.
We have I guess accountability to try to make l
i 6
sure there is a system in place that can allow us to do the 7
planning, the budgets, and the monitoring and the 8
assessment,-but a lot of the work to make this work, it has 9
to be agency-wide.
- 10 Let me just make one other point.
I think one of 11 the reasons, and we've got pretty good marks on this on 12 organization and strategic plan.
One of the reasono I think l
i 13 we were as successful as we were in developing this is there I
i 14
-was heavy involvement of the business people, the program
()
15-people, and because again, you know, I could go off and 16 write good words but if it's not what the program people
[
17 believe and are ready to implement, it's not very effective.
18 DR. KRESS:
It doesn't work.
~
119 MR. FUNCHES:
Right.
That's correct.
?
20 MR. BLAHA:
Okay.
If there are no other 21 questions, why don't I start.
22 CHAIRMAN SEALE:
Go ahead.
23
-MR._BLAHA:
My role in this process is really from 2 4 --
two different perspectives.
One, as secretary to the 25 Executive Council I assist the Executive Council in the O
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general oversight of the planning process.
()
2 The CFO has direct responsibility for implementing 3
this planning process but the Executive Council has broad 4
oversight of the process and, as Jesse says, has been very 5
involved.
6 Also as Assistant to the EDO, most of the 7
activities, the program activities, fall under his purview 8
and for years the EDOs had program reviews but they now have 9
taken on a very different focus and complexion and in that 10 role I am helping the EDO and the Deputy EDOs implement that 11 process.
12 But I think the one message that I hope you carry 13 away from Jesse and my discussion is that we are 14 fundamentally committed to changing the way we manage in the
()
15 agency, to focus on achieving strategic goals and 16 objectives, measuring effectiveness, measuring efficiency, 17 and having a process to monitor and provide feedback on that 18 process.
19 For example, Jesse and I attended this morning a 20 pilot training session that will be given to all supervisors 21 and managers on program and resource management.
It is 22 intended to give staff and managers the tools they need to 23 actually make this happen in a realistic way.
24 A lot of our people have grown up as technical 25 staff people and aren't very strong in this area of resource ANN RILEY & ASSOCIATES, LTD.
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management, program direction, and so on, so it is our
()
2 understanding that they-need the tools and make sure they 3
get what they need to make that happen.
4 DR. KRESS:
Are these computer software cools that 5
-you are talking about?
6 MR. BLAHA:
No, it's more management tools in how 7-to measure effectiveness, how to budget, how to plan, how 8
the budgeting process works, how the planning process works.
j 9
MR. FUNCHES:
Forecasts.
10 MR. BLAHA:
How forecasts work -- things like.
f
~ 11 that.
It's the ef ficient side of nanagement again, t
12 DR. FONTANA:
You know, there is another sida of 13 that too, as you are well aware, is that the planning and 14 forecasting could be very well done but then implementation
()
15 is crucial -- that it be implemented.
16.
Here is where all your lower level managers have 17 to buy into the procesa.
~
18 Now do you have an implementation plan that goes
.19 along with the high level plan -- like you mentioned of 20 course that you are getting to the managers and the staff, 21-giving them the tools on which they can do resource 22 management.
- 23 Is the -- I am searching for-the right word -- you 24-
- could say they have got to buy into the process -- and also 25 there is the measurement and how well they are doing it, and O
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1 the question that I have is are all those elements in place?
()
2 MR. BLAHA:
I think you will see that we have a 3
plan in mind for those elements when I talk a little bit-4 more about the operating plan and the program review l
l 5
process.
6 I think we understand the elements, yet we are not
-7 there by a long shot, but I think as I get into this a 8-little-more I'think you will see those features.
- l 9'
MR. FUNCHES Let me say one thing.
One of the 10 things we have said earlier on is what we want to do in 11
- these earlier phases is to have a lot of coaching of the 12 managers to try to coach them and move them along.
13 We are taking that approach to -- at least early-14 on to try to -- and then as we mentioned earlier we are 15 going to stop and have feedback, continued feedback, into 16 the system -- what we need to do next.
17
- I think the pieces are there.
We are going to :ry 18 to execute all of the pieces by fiscal year 2000, that 19 cycle, recognizing that we won't be 100 percent s
20 efficiency -- operating at 100 percent efficiency or 21 effectiveness but hopefully we will make a giant step, and 22 then we'll make some changes and we will be improved the 23 next year.
,24 MR. BLAHA:
I'll be speaking from this handout 25 here.
Really, that diagram on the cover page gets at the O-ANN RILEY & ASSOCIATES, LTD.
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heart of what we have been about for the past six months.
()
2 There was almost a two year effort put into the 3
planning aspect of it, and of course va did the budget last 4
spring, but the Chairman challenged the Executive Council 5
and the CFO with how are you going to make this actually 6
happen?
How are you going to have an integrated, seamless 7
process that allows this to be implemented, and then you can 8
assess whether or not you are effective, so the process that 9
Jesse described and that I will get into is intended to 10 integrate and to show how we are linking day-to-day 11 activities to those st...egic goals, those performance 12 output measures, and so on.
13 We also want to have a logical, well understood 14 management process which will allow us to measure progress
()
15 towards those goals and to improve effectiveness sand 16 efficiency.
17 That is really what we are all about here with the 18 operating plans and the program assessment piece of this.
19 We also recognized early on that this was not l
20 going to be a quick, easy thing to implement.
It was going 21 to take time and we fully expect it to take as much as two 22 to three years.
i 23 We had a consultant early on the process who 24 suggested we were going too fast and the Chairman said we l
25 were going too slow.
l l
{
()
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1
[Lauchter. )
()
2 We are trying to strike a balance, but it can't 3
happen overnight.
But we're trying to push forward as fast 4
as we can.
But what I'm going to focus on today in this 5
cycle of planning, budgeting, execution, and assessment is 6
the execution, which is really the operating-plan concept, 7
and also the assessment, which is our program-review 8
concept.
9 Moving on to the second page, clearly the 10 strategic plan and the performance plan have to drive the 11 process.
That is a statement of agencywide high-level goals 12 and objectives.
And that should drive our budget, and it 13 should drive our day-to-day activities, which is captured by 14 our operating plan.
)
15 Now the challenge for us is to make these all 16 consistent, and right now, as Jesse said, the budget isn't 17 necessarily consistent with the strategic plan.
But we have 18 to make it that way.
And his challenge betueen now and 19 February when we send the budget to Congress is to repackage 20 what we sent to OMB in a way that it will explain to 21 Congress how that budget supports the strategic plan that 22 they will also get.
And then obviously we need to have our 23 operating plan also logically support that process, both the 24 budget and the strategic plans.
25 The opetating plan essentially provides the
(
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detailed milestones, outputs, and deliverables that support
)
()
2 achieving the goals and strategies in the strategic plan.
3 The offices were asked to -- this past summer -- to produce 4
these operating plans.
They did that by the early part of 5
October.
The EDO sent out some instructions on how to do 6
operating plans.
On August 26 you all received a copy of 7
that I believe, but I have some additional copies I'd be 8
glad to leave.
And it explains what our objective was in 9
-the offices in building the operating plans.
I'll talk a
-10 little bit more about that later.
11 But the next key element is once you have an 12 operating plan in place, the question is, is it achie ing 13 what you want.it to achieve.
Now since this is our first 14 year, we couldn't really measure what we did in '97 because
(
15 we didn't have operating plans in '97, we didn't have goals 16 and objectives that were measurable.
So this year's program 17 review is very prospective in nature.
In the future program 18-reviews will both look at what we achieved in the previous 19 year based on what we told Congress we were going to 20 achieve, but they'll also look at the plans we have for the 21 future to implement the -- to further advance the goals and 22 objectives.
23 But the program-review process is conducted by 24 what we call the Program Review Committee.
The Program 25 Review Committee censists of the three Deputy EDOs, the i
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Deputy CIO, the Deputy CFO, and Jackie Silber from the (n-)
2 Chairman's staff.
They used to be known as the Budget A/
3 Review Group, but they've been recast in a broader context 4
because it's not just budget anymore, it's really program 5
direction, it's strategic direction, and they are now the 6
Program Review Committee.
7 And starting in late October they started program 4
8 reviews of each of the approximately 45 programs that we 9
have in the performance plan.
One thing you'll see in the 10 performance plan is that we characterize work as in the 11 area -- as programs, not by office, and that's a concept 12 that we're trying to implement with the operating plans, is 13 that the operating plan is an agency operating plan, not an 14 office operating plan.
It's for a program that crosses
('
(_)T 15 office lines.
16 Now I'll be the first to say we have a long way to 17 go to really to do that in a robust way, but the concept, 18 our objective, is to have program managers who look and 19 manage the programs from an agency perspective and including 20 all of the other offices that contribute, not just from 21 their own office perspective.
22 The program reviews are intended to produce three 23 outputs.
As you see from this chart here, the program 24 reviews produce program guidance and budget guidance.
That 25 refreshes the strategic planning process, and in fact as an U
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example, Jesse has a group, a steering committee looking at
()
2 revising the strategic plan.
The results from our program 3
reviews this fall are feeding in directly to that group.
4 From the program reviews we're looking at assumptions and 5
issues that will affect the year 2000 budget.
We're 6
capturing that, and that's going to feed right into the 7
budget process.
8 And the last element.a we are addressing program 9
issues, just like for the past 10 or 15 years the EDO's 10 office has dealt with program issues, we're dealing with 11 that in this process too to make sure the programs are 12 achieving what we want and we're resolving issues and 13 problems.
So that's a broad overview of the process.
14 To further amplify a little bit on operating plans r
\\
is) 2.5 on Chart 3, first of all the operating plans are intended to 16 be multiyear.
The operating plans today include FY '98 and 17 FY '99, because we have a '99 budget that's ready to go to 18 Congress.
We will add the year 2000 this spring as the 19 offices build the FY 2000 budget.
So it will for some 20 period there be a three-year operating plan.
And at the end 21 of FY '98 we will monitor what we achieved in '98 and then 22 look forward to '99 and the year 2000 on the plans.
23 CHAIRMAN SEALE:
One of the things that struck me 24 as I envisioned the ring you constructed in your earlier 25 discuseion is that it's really going to be moving in Ii ANN RILEY & ASSOCIATES, LTD.
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regulatory space over the next few years as we go more and
(~h
( )
2 more to risk-informed regulation.
Do the details of these 3
plans and expactations that are under these multiyear 4
operating plans reflect elements that address the question 5
of m. -
oward risk-based regulation?
6 BLAHA:
They sure do.
7 PHI
}Udi SEALE:
Or risk-infortaed, I should say.
8 4F LAHA:
Yes.
You'll see in the strategic plan 9
under the r sar-safety gohl that there's a substrategy 10 that says under -- on page 6 we will incrementally implement 11 risk-informed and where appropriate performance-based 22 regulatory approaches for power reactors.
Now each of the 13 offices -- each of the programs in building their operating 4
plans are supposed to tell us what they're doing to support iO
()
15 that strategy, and they have quite a bit going on, in fact.
16 CHAIRMAN SEALE:
Yes.
We've already expressed t
17 some interest in finding out what's going to happen to the 18 inspection plan.
19 MR. BLAHA:
Um-hum.
20 CHAIRMAN SEALE:
As you go to a risk-informed 21 regulatory process.
22 MR. BLAHA:
Right.
23 CHAIRMAN SEALE:
Because clearly your inspectors 24 do slightly different things.
25 MR. BLAHA:
Right.
[
T ANN RILEY & ASSOCIATES, LTD.
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CHAIRMAN SEALE:
Yes.
/m
\\
2 (d
MR. BLAHA:
From site to site.
3 CHAIRMAN SEALE:
Yes.
Well, and relative to what 4
they do now at a given site, 5
MR. BLAHA:
Right.
Right.
Um-hum.
6 CHAIRMAN SEALE:
Yes.
7 KR. BLAHA:
So the answer is yes.
8 CHAIRMAN SEALE:
Okay.
g 9
MR. BLAHA:
It's clearly identified in the 10 strategic plan.
11 CRAIRMAN SEALE:
Yes.
12 MR. BLAHA:
The operating plans are supposed to 13 capture commitments.
What the offices are supposed to be 14 producing, what their plans are to achieve some of these (O,)
15 things, the milestones, the dates, and what the outputs are 16 going to be, how many licensing actions, how many 17 inspections, and so on.
It's a vehicle for communicating 18 expectations up and down the line.
It's really a contract.
19 It says here's what I'm going to produce for the resources 20 that have been given.
And it is supposed to be a vehicle
/
21 for every staff member to understand how what they do 22 provides linkages to our strategic plan, our goals and 23 strategies.
And so that's really some of the key aspects of 24_
the operating plan.
25 I have a few other items on Chart 4.
As we talked
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)
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earlier, it's the link, the logical progression from the
- iwj 2
planning and budgeting process.
As I mentioned, we're x
3 organizing by program, not office.
Three-year cycle.
1 4 4
I might mention a little bit about the specific 5
components of the operhting plan.
Each of these was 6
intended to focus on -- each of the subchapters in the 7
operating plan is intended to focus on things of special 8
interest to management.
For example, the first subchapter 9
in the operating plan deals with budget planned 10 accomplishments.
Here's what we are saying in our budget 11 what we're going to achieve.
The next one -- the next 12 subchapter describes what they're doing to implement 13 strategies and substrategies.
14 Now if we put our money where our mouth is, in the O)
(,
15 future those two will merge, because what we have in the 16 budget should track to what we say we want to achieve.
17 Today they don't.
But that's why you have two separate 18 subchapters now.
What we're trying to do is look and see 19 what their plans are to implement the substrategies and to 20 see if they're adequate, to see if really they're going to 21 achieve what we want.
22 We have a subchapter in monitoring the output 23 measures.
As you see in the performance plan, we have 24 specific output measures.
This asks them to articulate what 25 they're going to do to achieve that, and in many cases
(\\ ')
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provide quarterly milestones or quarterly measures.
If NRR
()
2 is going to do 1,500 licensing actions, what is their 3
quarterly target, so that we can monitor their progress in 4
implementing that.
5 You may or may not be familiar with the fact the 6
chairman has a special priority tracking list.
We've 7
captured that in the operating plan.
You're probably 8
familiar with the directional setting issues concept that 9
came out of our strategic planning process where we're 10 looking at what each program is doing to implement those.
11 Significant staff requirements memos.
The regulatory 12 effectiveness initiatives.
Information technology 13 initiatives.
And then we have a chapter dealing with 14 organizational management issues like supervisory ratios, n(_,)
15 average grade level, EEO goals, things like that.
16 And theli we would expect we'll get quarterly 17 updates on how well the offices are achieving their 18 commitments.
19 On chart five, we talk a little bit about the 20 program review process.
It is intended to assess how well 21 we are achieving what we said we were going to achieve.
22 As I said, this year it's been prospective in 23 nature, because we didn't have plans in the past.
24 Next year's program review cycle will look at what 25 we achieved in '98 based on what we said we were going to
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achieve, and we also want to see whether the program are
( s) 2 producing not just the outputs but the cutcomes, whether we v
3
'are effective in achieving our goals and also the efficiency 4
aspect of it.
5 As I mentioned earlier, that program review 6
process refieshes both program direction, the budgeting, and 7
the strategic planning process.
8 On chart six, the process starts with the offices 9
doing their own self-assessment of their operating plan.
10 We've told them to build their operating plan, and then we 11 said ask these 12 questions, and as I mentioned earlier, one 12 was on efficiency.
13 But the first question is, do the planned 14 accomplishments and the program activities in your operating
((.
15 plan adequately support the strategies and sub-strategies, 16 and are those linkages clear?
And by and large, the answer, 17 more often than not, has been no.
18 Right now, we don't describe very well why 19 producing 1,500 licensing actions is going to reduce the 20 number of severe accidents or the risk of severe accidents.
21 So, we have to provide better links and 22 descriptions of why inspections or licensing or whatever we 23 do helps to achieve those desired outcomes.
24 The scope of the program reviews covers a variety 25 of things.
It covers the strategic planning and performance (m'~)
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planning issues.
It covers budgetary issues like what would t
i 2
you do if you had to take a reduction, what are your G
3 priorities, how can you be more efficient?
We get into 4
things like the information technology initiativer.
5 There's a memo that the EDO sent to the offices on 6
September 12th that describes how to do a self-assessment, 7
and as I mentioned earlier, you have an example here of the 8
state programs area, and what you see in here is the 9
self-assessment by the program manager and comments by a 10 support team.
11 For each of the program areas, we've defined a 12 support team of usually three or four people who have more 13 or less challenged the program manager in each of the areas
.4 of program review, and they've written their own independent
/^T (m,)
25 assessment.
16 That is a resource for the program review 17 committee to get a different insight and different 18 perspective on how well that program is being implemented, 19 and that's proved very effective, and you will see in here 20 the analytical support team findings for what the program 21 managers' own self-assessment reflects.
22 So, at the program review -- with the program 23 review committee, the program manager is there to review his 24 or her self-assessment, then a local support team is there 25 to provide input and comment, and usually as a result of
-~,
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that, there is some direction given to the program manager
[)
2 to go back and strengthen or revise or build in a number of
(
3 different areas.
4 Kind of to summarize or wrap up, I think we have 5
recognized early on that this is going to be a longer-term 6
process, we're not joing to do it overnight.
We are 7
learning a lot in the process, and we expect it to take two 8
or three years.
9 Some programs have done a better job than others, 10 and we'll be working with those that are having a harder 11 time in the weeks and months ahead, but we are identifying 12 some good issues, and I think it's going to produce a better 13 strategic planning process, it will feed a better budget 14 review process, and we're also addressing the program issues (O) 15 that need to be addressed in the process, 16 I'll be glad to answer any questions.
17 DR. KRESS:
This process is on a yearly cycle with 18 a three-year planning horizon?
19 hR. BLAHA:
Right.
20 DR. KRESS:
It's not a five-year planning horizon.
21 MR. BLAHA:
It's three.
22 MR. FUNCHES:
The strategic plan is basically five 23 years, out to the year 2000.
It covc s
'97, but actually 24 it's kind of a quirk in the law.
It covers last year, but 25 it really can't cover the last year, because it's due on
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Septembe:
he 30th, that year '97 shows up, so it's really x
(
2 covering
')
to the year 200, which is basically four years.
(
3 DR KRESS:
I guess because of the Federal budget 4
cycle being one year, you're forced into a one-year cycle, 5
Is there ever any hope of that changing?
6 MR. FUNCHES:
They've had discussion about 7
two-year -- incorporation of two-year authorization.
I 8
guess, technically, if we had an authorization bill, it 9
could be a two-year authorization bill, but I don't see any 10 hope for it.
11 DR. KRESS:
It would be nice, though.
12 MR. FUNCHES:
It would be, because what it does in 13 it's going to give you the stability.
You don't have to 14 worry about -- as you plan out, you know -- and I think, for
(~h
()
15 us, you know, two to three years, you know -- we look at 16 five years, planning horizon, two to three.
17 Most of the things really are in the 18 two-to-three-year planning horizon.
You know, we have long 19 procurements like they do in the military and places.
But I 20 think, in the strategic plan, we do want to project 21 ourselves forward, but the operating and the budgets, you 22 know, beyond two to three years, really gets to be a little 23 24 DR. KRESS:
-- a little iffy.
25 MR. FUNCHES:
Right.
,rx I
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DR. MILLER:
It seems like your goals actually are (gv) 2 independent of time, though, wouldn't you say?
I mean 3
looking through the goals you establish, they're goals you 4
would have tomorrow and goals you'd have 30 years from now.
5 MR. FUNCHES:
You are absolutely correct for us.
6 I was mentioning earlier, the concept behind the 7
Government Performance Act is that the performance plans 8
really do cover one year, and for example, this performance 9
plan technically is supposed to cover fiscal year 19f9, and 10 the idea behind it is, you know, for example, if you -- and 11 this is a plan I'm very familiar with, the National Highway 12 Transportation Safety Administration.
13 They wanted to reduce highway death, and they 14 said, okay, we're going to reduce it by 10 percent in this
)
15 year, this operating year, you know, next year it might be 16 another 10 percent.
So, it's more of a progression.
17 But right now, the goals that we have are -- we 18 don't see those intermediate goals changing from year to 19 year.
There could be some.
20 We had some discussion in the materials area with 21 the Commission.
22 They raised a concern, you know, kind of the 23 budget was put together, do we really want to say we're 24 going to maintain the same number of radiation exposure in 25 the material area as we have today, and you know, even I
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though it's a very low number, you know, you could see some (G
i 2
changes to something like that, but I think, by and large, j
3 they are multi-year goals, multi-year goal in the sense that 4
they'd be the same for each year.
5 CHAIRMAN SEALE:
Any other comments or questions?
6 MR. FUNCHES:
I think Mr. Kress had asPed one 7
question about where do we talk about efficiency.
There's 8
one other place in there I do want to point out to you in 9
terms of where we talk about efficiency.
10 If you go to page two in the strategic plan -- and 11 we put that there for a specific reason, again, introducing 12 the goals -- it's just before you get to the bulletized 13 goals on page two, and it talks about the efficient 14 regulatory program, not only do we want an effective O
tw,/
15 regulatory program, we want an efficient regulatory program, 16 end that gets at the regulatory program itself, as opposed 17 to our operations.
18 DR. FONTANA:
I guess Tom's question basically is 19 how difficult it is to measure efficiency.
20 MR. FUNCHES:
You're right, that is very 21 difficult.
22 DR. MILLER:
If you could measure it, then you 23 could set a goal and say, okay, we're 90-percent or 24 80-percent efficient now and, by year 2003, we're going to 25 be 95-percent.
fm
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MR. FUNCHES:
You're *.bsolutely correct.
I think,
/
( s) 2 at best, you can have knowledge that is kind of a subjective s
3 thing that you're trying to use as a guiding principle.
4 DR. MILLER:
Now, the Commission has recently put 5
out a document diccussing the issue of safety and 6
compliance, and I don't know how these goals were set.
I 7
was surprised that maybe there wasn't a goal that reflected 8
upon bringing safety and compliance more into it as a goal.
9 I wasn't involved in setting the goals, and I 10 don't know who was, but if the Commission had that document, 11 I'm surprised that 12 MR. BLAHA:
I think the thrust is that there is --
13 they're completely compatible.
There isn't really one 14 versus another or how do we bring them in alignment.
They P)
(_
15 should, by definition, be in alignment.
16 Joe?
17 MR. CALLAHAN:
I'm Joe Callahan, the Executive 18 Director for Operations and a member of the Executive 19 Council, and I have a morbid interest in this discussion 20 here.
21 The safety and compliance -- you said it right, by 22 the way.
You didn't say safety versus compliance, you said 23 safety and compliance.
24 DR. MILLER:
I definitely didn't say "versus."
25 MR. CALLAHAN.
You passed that test.
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This would not be a goal in the context of the
[)
2 planning process, the performance planning process.
It's a V
3 challenge, but it's not a goal.
4 As the paper clearly says, there is no 5
incompatibility between the two concepts, but as the paper 6
also says, we have to strive to continuously look for areas 7
where our regulations are not congruent with our safety 8
mission, and it's a challenge to both the NRC staff as well 9
as to the regulated industry to constantly highlight, 10 identify, and correct areas that are not congruent.
11 You raise an interesting point.
I suppose that as 12 Jesse discussed, as we cascade these goals down to the 13 section level and individual employee level which, I mean, 14 the operating plans will do, that's part of the cascading O\\
(_)
15 process and there are major gaps in that cascade, we 16 recognize.
And the gaps typically relate to areas where we 17 go from zero deaths and no illnesses to minimizing backlogs 18 on licensing options.
How do you go from that to no deaths?
19 Well, we have to flesh that out and that's doable 20 and that's the challenge.
But as we go through that 21 process, I think we probably need to look for opportunities.
22 We need to look for opportunities to highlight this 23 challenge.
I think, clearly, we do.
I think that's a 24 Commission imperative and I wasn't really focused on that 25 but that's something we need to do, clearly.
,m
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DR. MILLER:
It seems like that could be at least
([
)
2 one measure of efficiency.
Ideally, every compliance
-3 requirement would certainly reflect on safety and we all 4
know that is not necessarily true.
5 We also ideally will never reach the ideal.
But 6
it seems like some measure of efficiency would be the 7
compliance issues and safety issues would become congruent.
8 MR. CALLAHAN:
I think that is a very worthwhile 9
input.
I think that may help us actually with this.
10 We have a lot of work ahead to do this, to make il sure that there is that continuity, that fidelity from --
12 what our consultant called a nose cone, the nose cone goals 13 of this rocket down all the way down.
And this will help.
14 This will help a lot.
15 CHAIRMAN SEALE:
Good.
Any other?
16 DR. POWERS:
One of the offices that struggles 17 with this planning as this one, what would you suggest to 18 us?
19 MR. FUNCHES:
I think ask questions, keep at it.
20 I think, which I assume the office has the support and I 21 think it is very important to look at what you're doing and 22 kind of ask the question of why and how does it -- we used 23 to be too mild if you come down and said, I'm doing this 24 because, you know, I want to achieve this goal.
Then you 25 ask how, how, how until you get down to what you want to do.
p)
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Likewise, you can start and say, I perform this (qj 2
function and you say why do I perform this function and keep v
3 asking why, eventually you are going to say I perform this 4
function because to do an outcome.
And I think, you know, 5
to keep asking those questions.
6 I think the key is to take that first step to put 7
together an operating plan or where you're trying to go and 8
what you want to focus on.
And I would assume for ACRS it 9
would be similar to an office.
Where do I get the biggest 10 payoff in terms of what I do, you know, and help the agency 11 achieve safety as defined by these gcals.
12 But I think it's a learning process but I think, 13 you know, the biggest thing would be the management and the 14 leadership of the ACRS to support the concept.
And I think (3
(_)
15 it helps you get the support and the help you need to 16 implement it.
I guess that's the easier part.
17 DR. POWERS:
One of our responses to this 18 initiative was to say, okay, we've got a problem with the 19 first year of the program just because of the way it gets 20 started and things like that but we know certainly in the 21 next year somebody is going to come through and do an 22 assessment on us so maybe we ought to practice and do a 23 self-assessment on our own and we anticipate doing that at 24 the end of January at one of our subcommittee meetings.
Do 25 you have any advice for doing self-assessments?
,~.
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l 102 1
I mean, I've heard about your 12 questions.
I'm (m) 2 not sure I've seen those 12 questions.
ms 3
MR. BLAHA:
I would be glad to leave them with 4
you.
But it asks the fundamental questions.
5 For example, a very near-term issue will be the 6
revision of the strategic plan and if there aren't the right 7
strategies and substrategies that explain why you are here 8
and why you do what you do, then that needs to be fixed.
So 9
one of the questions we have asked all our program managers 10 is, do the strategies and substrategies need to be changed, 11 revised or so on to better describe the linkages between 12 what you do and how we are -- what we are trying to achieve.
13 So that's one thing to look at.
14 CHAIRMAN SEALE:
I'd like to have a copy of your A's,)
15 12-question self-assessment.
s 16 DR. SHACK:
They are in the packet here?
17 CHAIRMAN SEALE:
They are in the packet?
- Okay, 18 fine.
19 DR. SHACK:
You can see a sample and some answers.
20 CHAIRMAN SEALE:
Okay, fine.
21 MR. FUNCHES:
I think that is a good idea on the 22 self-asFessment.
23 DR. POWERS:
One of the activities we carry out at 24 the behest of both Congress and now the Commission is to 25 review the research program and to -- we are involved in
'l
')
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that right now and we have conducted some preliminary
()
2 discussions on a subcommittee level with the research 3
program and we find a substantial difficulty in the concept 4
of mission need as opposed to what historically te have 5
done.
I guees that's what you are trying to change here, is 6
to go to a mission need kind of structure rather than here's 7
what we've done.
8 MR. FUNCHES:
Absolutely.
9 DR. POWERS:
So that difficulty, when we -- we 10 know there is some help for us to change that problem that 11 we've run into.
12 CHAIRMAN SEALE:
There is even interest.
13 DR. POWERS:
What we also encounter is we also ask 14 the question of the research program, what is it that you O
(m,/
15 are not doing that you think you ought to be doing but you 16 can't do because you don't have the resources?
And we found 17 people could not answer that.
The programs were being 18 resourced -- resources were dictating the range of thinking.
19 Is that something that you are encountering?
20 MR. FUNCHES:
I think -- and I have to go back to 21 this previous budget process.
I think there are a couple of 22 things we encounter in resources.
23 I think there were two kinds of fundamental things 24 we were dealing with.
One was -- and the strategic plan 25 talks to that, that we want to maintain some core
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104 is 11 capabilities such that we got those core capabilities inLany 2
regulatory program that-we have and several papers-have been
-3 written on that.
So that was one concept that-we-finally:
4 deal with to make sure-that:those core' capabilities were' 5
there..
6 I think the other issue you talk'about was a 7
= mission-related issues.
There was some issues in-terms of 8
-priorities across the agency and whether it's sort of research would' fit vithin those priorities and the r
l10 Commission ultimately made some decision on what those 11 priorities were.
12 I think -- I'm not sure in terms of overall big 13-scheme or resource constraint, that was an issue except for l
14 in the sense of the priority and the agency budget has to
()
15 come down and we did get a $7-1/2 million reduction as a 16 result of-congressional action.
We used those priorities to 17-implement that reduction and part of the reductica-was in l
18 research.
19 I think, the kind ~of answer to your question in l
l 20-shorthand was there was two issues.
One was maintaining 21 this core capability, which the strategic plan talks to.
l 22; And then other one was really just-kind of a priority issue.
L 23 I--don't recall---
24' LDR.. POWERS:
Well, there are a couple of
- 25 activities'that the strategic plan calls out.
One of them ANN RILEY &. ASSOCIATES,-LTD.
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is to respond to the line needs for information and the
[
)
2 other one is the core capabilities.
So you clearly have
\\_/
3 some sort of a tradeoff here and you have limited resources.
4 So when you are sitting down and saying, I've got to do 5
tradeoffs, I don't have enough money to do everything, I've 6
got to do some prioritization and balancing.
7 What we encountered was they didn't know all the 8
line needs because the line would only ask them up to the 9
limits of their budget.
As soon as they ran out of budget, 10 they stopped asking.
11 So, I mean, you don't know how big that iceberg 12 is.
And when we ask them about core capabilities, they say, 13 well, we maintain these core capabilities because that's 14 what we can afford to maintain.
There was not the -- here
)
15 are the core capabilities we think we are going to need and 16 here's what we can afford, therefore we're not doing these 17 because they are lower priority or for whatever reason.
18 MR. BLAHA:
A comment, last year's budget cycle 19 did not put a constraint on the resource levels that they 20 asked for.
So in that respect, they could ask for 21 everything they thought they needed.
22 From a practical sense, there was a lot of 23 frustration because they put a lot of tension saying, here 24 are all the things we need and the reality was that wasn't 25 affordable.
So I think we are trying to be more realistic
(
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in what is a more realistic target.
But I think doing the n
(
j 2
budget cycle there will always be a question to the program v
3 office directors and managers, what aren't you doing that 4
you really need to do.
5 Those questions will be asked.
6 MR. FUNCHES:
Right.
I think -- I'm not sure 7
there is a competition between, you know, office needs and 8
core capabilities.
One of the concepts embedded in core 9
capability is that the mission needs come down so low or are 10 driven down so low, if you are not careful you would 11 eliminate core capabilities that you need to undergird any 12 regulatory program.
So I am not sure there is a competition 13 for resources between maintaining core capability and, in 14 fact, the concept tends to imply that you ought to -- maybe, p)g
(_
15 you know, you need to add a little bit of resources above 16 those that you need to respond to requests to maintain that 17 core.
So I wouldn't say there is a competition there.
18 I think there is, you know, probably like in most 19 areas, there's always room to do a little bit more if there 20 is resources available.
21 CHAIRMAN SEALE:
Well, hopefully ve will have some 22 more specific things to say about the research needs and so 23 on as we get these letters put together and so forth.
But 24 there is a serious problem.
I mean the shock of the kinds 25 of draconian cuts that have occurred over the last four
,m
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- years:in research is such"that those people;have been in the H
()
E 2
2
= moat pouring oilidown,--hopefully some still-~left=that will 13 catch' fire to keep the Philistines out. and --
4
[ Laughter.]
i
'5-They're under siege, really, and it's been very 6
difficult to begin to think out of the box, and clearly that
. s i
(7 is exactlyLwhat's called for in.this situation.
-8 Are there'any other -- yes.
9 MR. LARKINS:
Can I raise a question?. When we
- 10 submitted our operating ~ plan, we reviewed the I think it was
-11 54 program areas, and we noticed that the ACRS had not --
12 --
and the ACNW-had not-been-mentioned in a support role for 13 any of those. LSo dn our-submission we identified a number
- 14 of program areas-that we thought the Committee should be
- 15
- cited as being in a support mode.
I don't know whether
-t ere's; een any-discussion on'following up on our h
b 16 17 recommendation.
18 MR. BLAHA:
I think that probably would be 19 input --
20
.MR.
FUNCHES:
Right.
- 21 MR. BLAHA:
Into the strategic --
22-
-MR.
FUNCHES:
Right.
I think -- what we're doing
-23
. is--- and agcin what we did was we took the -- I think what 24 you were'saying is for ProgramLX there were-a program
- 25
- manager and there were support officers, and you're saying Il ANN RILEY:&-ASSOCIATES, LTD.
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- 1-that ACRS probably inLseveral areas should be listed as_a 4
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2 support office.
And.I-don't see a-problem with dealing with 3
that,cbecause that's one of the things we obviously_want to 4
-flush out to make sure we pick up all the-support 5
CHAIRMAN SEALE:
And ACNW where appropriate.
6 MR. FUNCHES:
Right.
And ACNW.
My guess we might 7
have picked up ACNW because I, you know, my understanding, 8
-you probably cover many safety areas, and that might be --
9.
but I don't see a problem with that, John.
I have not 10 looked at it personally per se, but I would, you know, I
=11 think we're obviously trying to cover the waterfront.
12 MR. LARKINS:
Well, we provided some suggestions 13 as to those areas where we thought it was appropriate, 14-MR. FUNCHES:
Okay.
Because what we want to do is 15 ery_to get an integrated piece when you look at, as Jim said 11 6 early on, when you look at a program and how the program 17 manager -- all the pieces that feed in that program.
18 CHAIRMAN SEALE:
Any other comments or questions?
-19_
I want to-thank you very much for coming and i
20 spending this time with us.
I think we ran beyond the 21 witching hour, as it were, but at the same time I think the 22-questions were appropriate, and it'll help us with our i
23 thinking, and hopefully we've reminded-you of some of_our-24 concerns and all, and we look forward to hearing from you 25 some more, &nd perhaps at some point down the road there may l
l:
l:
l H
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be an issue or two where we might be able to give you some
[v) 2 help, and if there is, why come see us.
3 MR. FUNCHES:
I appreciate that.
4 CHAIRMAN SEALE:
We appreciate it.
And thank you 5
for coming too.
We appreciate any time you can ever spend.
6 Okay.
I'm going to say that we will recess for 10 7
minutes, and then we're going to come back and talk about 8
the research letter.
9
[Whereupon, at 4:47 p.m.,
the meeting was 10 recessed, to reconvene at 8:30 a.m.,
Thursday, December 4, 11 1997.)
12 13 14
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15 16 17 18 19 20 21 22 23 24 25 4
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' REPORTER'S CERTIFICATE This is to certify that the attached proceedings
[1l before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING:
447TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 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 O
'(,,/
accurate record of the foregoing proceedings, Om %d Ion Hilndley Official Reporter Ann Riley & Associates, Ltd.
(^~')
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9 I
I y-O.
O O
PRESENTATION TO THE ACRS ON THE STATUS OF NPSH ISSUES og g
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DECEMBER 3,1997 PRESENTED BY:
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O PAST DISCUSSIONS WITH ACRS ON NPSH o
STAFF MET WITH ACRS DURING THE 442nd MEETING DATE: JUNE 11-14,1997 e
ACRS LETTER DATED JUNE 17,1997 SUPPORTED ISSUANCE OF GL-97-04 HOWEVER, INDICATED SEVERAL CONSIDERATIONS FOR THE STAFF STAFF NEEDS TO DEFINE ACCEPTABLE CORRECTIVE ACTION TOTAL RELIANCE OF OVERPRESSURE IS UNACCEPTABLE EVALUATE PERIODS WHEN BACKPRESSURE IS UNAVAILABLE 1-SHUTDOWN 2-CONTAINMENT BYPASS ACCIDENTS 2
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PERIODS WHEN BACKPRESSURE MAY BE UNAVAILABLE I
e SHUTDOWN BACKPRESSURE WILL NOT BE AVAILABLE FOR BWRs, BACKPRESSURE IS NEVER CREDITED BLOWDOWN BYPASSES THE SUPPRESSION POOL RESULTING IN A COLD POOL (NON-BOUNDING CONDITION).
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e CONTAINMENT BYPASS FOR DBA CONDITIONS BYPASS AREA TESTED EVERY REFUELING OUTAGE 1-ACCEPTANCE VALUE IS 10% OF ALLOWABLE FOR BEYOND DBA CONDITIONS 1.
CONTAINMENT PRESSURE WILL EXCEED ANALYSIS 2-CONTAINMENT SPRAYS WILL SUPPRESS AFFECT 3-CONTAINMENT VENTING POSSIBLE 4-CONTAINMENT FAILURE WORST POSSIBLE EVENT i
FOR CONTAINMENT FAILURE EVENTS 1-POOL WILL SURFACE FLASH
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2-POOL TEMPERATURE WILL FALL TO 212 "F i
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RELIANCE ON CONTAINMENT BACKPRESSURE BASED ON MINIMUM CONTAINMENT PRESSURE ANALYSIS
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CONSIDERATION OF CONTAINMENT SPRAYS CONSERVATIVE DECAY HEAT MODEL t
INCLUDES CONTAINMENT LEAKAGE CONSIDERATION OF ONLY ONE RHR HEAT EXCHANGER MAX SERVICE WATER TEMPERATURE CALCULATE NPSH REQUIRI:D VS. POOL TEMPERATURE (TIME) e
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NORMALLY CORE SPRAY OR LOOP SELECT GENERALLY MUCH LESS THAN MINIMUM CALCULATED i
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e ALL OTHER SEQUENCES WILL NOT REQUIRE BACK PRESSURE e
BASED ON THREE PLANT STUDIES l
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GL-97-04 RESPONSES WILL BE USED TO IDENTIFY THE NEED FOR CORRECTIVE l
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STAFF MAY TAKE ENFORCEMENT ACTIONS AND MAY CONSIDER LICENSE AMENDMENTS AS PART OF ISSUE RESOLUTION i
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NUCLEAR REGULATORY COMMISSION J' *g *... f g
WASHINGTON, D.C. 20 % 6 4 001 November 13, 1997 MEMORANDUM TO: Hugh L. Thomoson, Jr., Deputy Executive Director for Regulatory Programs Ashok C. Thadanl, Acting Deputy Executive Director for Regulatory Effectiveness Patricia G. Norry, Deputy Executive Director for Management Services Peter J. Rabideau, Deputy Chief Financial Officer Jacqueline E. Silber, Deputy Director for Corporate Planning and Management, Office of the Chairman Francine F. Goldberg, Director Division of Planning and Program Support, OClO James L. Blaha, Eggeret FROM:
Executive Council
SUBJECT:
ANALYTICAL SUPPORT TEAM REPORT - STATE PROGRAMS On November 13,1997, the Program Review Committee (PRC) analytical support team Q
completed its review of the State Programs program. Attachment 1 provides the analytical V
support team's findings. The document is formatted such that the program review question is
- provided in the left column, the Program Manager's program review assessment is provided in the right column, and the analytical suppon team's findings follow the Program Manager's assessment. If you have any questions regarding the analytical support team's fir dings, please contact George Pangburn, the analytical support team leader, at (610) 337 5283.
l On November 21,1997, the PRC will meet to discuss the analytical support team's findings and l
other recommended toples of discussion. To facilitate the discuscion at this PRC meeting, I l
have developed a meeting agenda with proposed dl3cussion topics. This agenda is provided as Attachment 2. If you have any questions or comments regarding the agenda, please let Elise Heumann ((301) 415-2281) know by COB Monday, November 17,1997 so that a revised agenda can be provided to the Program Manager in a timely manner.
Attachments:
- 1. Memo from G. Pangburn to J. Blaha dated 11/13/97
- 2. Agenda ccw/ attachments:
R. Bangart, OSP l
P. Lohaus, OSP G. Pengburn, RI J. Surmeier, NMSS
-U D. Cool, NMSS E. Heumann, OEDO (2)
K. Cyr, OGC (2) y--r---.m-,
Attechment 1 paa q ot UNITED STATES
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NUCLEAR REGULATORY COMMISSION 0'*%'****/
2 WAsHINoToN, D.C. 30MH001 November 13, 1997 MEMORANDUM TO:
James L. Blaha Executive Secretary of the Executive Council FROM:
George Pangbum, Team Lead
[N Analytical Support Team
SUBJECT:
TRANSMITTAL OF THE PROGRA REVIEW COMMITTEE ANALYTICAL SUPPORT TEAM COMMENTS ON THE STATE PROGRAMS PROGRAM REVIEW ASSESSMENT The Program Review Committee (PRC) Analytical Support Team (AST) has completed its review of the State Programs Program Review Assessment, including the program Operating Plan and the assessment submitted to you by Paul Lohaus on November 6,1997l The AST censisted of Elise Heumann, OEDO; Rita Albright, OCFO; and myself. Our comments are attached in the form of additions to the Program Review Assessment, g
in addition to the above-mentioned documents subrpitted by Mr. Lohaus, we reviewed g
relevant portions of the Strategic Plan, Performance Plan, several Commission papers and Commission Staff Requirements Memoranda, and the report of the NRC/ Agreement State Working Group Recommendations for Agreement State Traini,1g Programs. We also provided a draft of the AST report to involved OSP staff and management to review, and discussed the report with them.
The review process worked well considering the somewhat complex set of linkages among the Strategic Plan, Perfonnance Plan, Operating Plan, and the budget. We were assisted in no small measure by the comprehenaive assessment put together by Mr. Lohaus, which served to simplify some of these linkages. Based on the program self-assessment and our independent review, we have concluded that SP has appropriate plans and controls in place to assure that its single output measure in the Performance Plan-completion of reports under the Integrated Materials Performance Evaluation Program (IMPEP)-will be realized.
Tne Program Manager identified several issues for discussion by the Program Review Committee. The team has independently reviewed those issues and concurs in their inclusion in the PRC agenda. In addition, the team recommends the following issues for discussion during the PRC meeting:
1.
The Commicsion has indicated its concem regarding timeliness of IMPEP reports and SP is preparing a Commission paper to address this concem. The team also be!! eves that timely communication of Agreement State and RegionalIMPEP reviews is an important component of the IMPEP process and recommends that the output measure
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The team believes that the importance of close monitoring of schedules for the potential new Agreement States of PA, OH and OK cannot be overstated. Any slippage in projected dates needs to be promptly reported and considered in development of the Agency's budget.
3.
While not necessarily an issue of efficiency or effectiveness, the Commission is currently considering issues related to recovery of budgeted costs of Agreement State activities. Specifically, the issue addressed in SECY-97-249 is-Should the budgeted costs of f?P activities related to Agreement State oversight, along whn other programs, be removed from the fee base and funded through a separate appropriation? The team agrees with the recommendation of SECY-97 249 to pursue rernoving these activities from the fee base, but recognizes that this action could result in a greater level of Congressional scrutiny through the appropriations process and could ultimately have impacts on the scope and size of the program.
The Analytical Support Team is available to discuss any questions that individual members of the PRC may have on the comments provided or the process used during this review.
Attachment:
As stated O
2 qO 2.
The team believes that the importance of close monitoring of schedules for the potential new Agreement States of PA, OH and OK cannot be overstated. Any~
slippage in projected dates needs to be promptly reported and considered in j
development of the Agency's budget.
3.
While not necessarily an issue of efficiency or effectiveness, the Commission is currently considering issues related to recovery of budgeted costs of Agreement State activities. Specifically, the issue addressed in SECY-97-249 is-Should the budgeted costs of SP activities related to Agreement State oversight, along with other programs, be removed from the fea base and funded through a separate apprcpriation? The team agrees with the recommendation of SECY 97 249 to pursue removing these activities from the fee base, but recognizes that this action could result in greater level of Congressional scrutiny through the appropriations process and could ultimately have impacts on the scope and size of the program.
The Analytical Support Team le available to discuss any questions that individual members of the PRC may have c,n the comments provided or the process used during this review.
Attachment:
As stated Distribull20:
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- 1. Do the planned accomplishments and program Yes, the p!anned accomplishments (PA) and program actmtes activities in the consolidated Operating Plan adequately support the Strategic Plan subGeigies (SS) that adequately support the SP substrategies that they they are linked to. Some of the planned accomplishments, are linked to? If not, what program however, given that they relateio specific Agreement S" ate guidance / redirection is warranted or how should program activities, may only be linked indirectly. One example is those substrategies be modified? Secondly, is planned accomplishment OSP 6 (A), which addresses there a need for additional substrategies? If so, Agre.emant State staff attendance at NRC training courses, and explain.
its linkage to substrategy 7.1.4: "we will provide training and development to our staff to enable us tc achieve excellence in i
our organizational and individual performance." Although this l
does not explicitly address Agreement State staff attendance at NRC training courses, we believe the linkage is sufficiently clear i
i and no change is suggested.
Also, NMSS 1 for Regional IMPEP reviews under Support Office Activities is linked to substrategy 6.1.1 wtwreas the planned t
accomplishment OSP 4(C) for the same activity " support for Regional IMPEP reviews" is linked to substrategy 6.1.2. They
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substrategy 6.1.2: " measuring and reporting on the performance l
ofNRC..."
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Analytical Support Team Findings:
The team agrees with the Program Manager's conclusion that the planned accomplishinesi, support the sutmhetegies.
The self assessment references 18 different substrategies which is indicative of the broad range of achvites covered by this program.
In the transmittal memo sending forth the program review assesr'ent, the Program Manager idenhfied for discussion purposes, the concept of a new substrategy on " National Materials Program Development " which would address the collective efforts of the NRC and the Agreement States in working coopetetively to develop new rules, guidance and policies for the materials program. The team agrees with this concept and notes that it is rer.ective of efforts of OSP, NMSS, RES, AEOD, Regions and the Agreement States over the past several years to jointly address issues in the materials area.
e With respect to the issue raised in the second paragraph on the appropriate substrategy to be linked to Regional l
IMPEP reviews, the team does not have a recommendation and suggests that the Program Manager work with the Program Manager for the Nuclear Materials Users Ucensing and Inspechon Program to identify the most appropriate linkage.
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- 2. Is +.here a clear link between the program's There is a clear, although, indirect link. A single output measure has output measures / targets in the Performance Plan been established for the Program: Completion of integrated Materials and the related SP/PP goals (outcomes)? If not, Performance Evaluation Program (IMPEP), Reviews of Agreement where are the linkages weak? What changes are State Programs." This output measure is linked to the SP/PP g !s/ outcomes, based on the premise that an adequate and warranted?
compatible Agreement State program should assure an equivalent level of protection of public health and safety as that achieved through NRC's materials program. This, in tum, should lead to an acceptable level of performanca in Agreement State licensee operations and help achieve SP/PP goats...
Other program activities also support specific SD/PP goais. For example, Agreement State reporting to NRC of incidents and events occurring at Agreenient State licensed facilities is linked to goals established for " Nuclear Materia!s Safety
- relatmg to lost sources and misadministrations.
Analytical Support Team Findings:
As noted by the Program Manager, IMPEP is the singular output measure for the program. The team agrees that the linkage between the Performanu olan output measure (completion of IMPEP reports) and relevant goals in the SP/PP, is a clear, although indirect, one. hQ quality reviews of Agreement State and Regional programs completed in a timely manner will help assure that most of the goals referenced in the Operating Plan are achieved E.nd should provide for an equivalent level of protection of public health and safety nationwide. Because timeliness of IMPEP reports is an issue that the Commission has directed the staff to address and because the team believes this is an important component of the IMPEP process, the team recommends that the output measure contained in the Performance Plan be revised to include a specific timeliness goal for issuing reports.
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- 3. Are the plans outlined in the programs's consolidated Yes, The program's consordated Opeiein.g plan contains sufficient Operating Plan adequate for achieving Performance information and plans to achieve Performance Plan Output targets.
Plan output targets? If not, what changes to the program are warranted?
Analytical Support Team Findings:
Based on the five reviews that are in progress (TX NM, NH, NV, and a fol',ow up rewew in NE), and that will be completed dunng FY 1998, and the nine Agreement State reviews and two Regional reviews scheduled for complebon during FY 1998, the team believes that there is adequate information to support a conclusion that the Performance Plan output targets will be met.
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- 4. Are tiiere any apparent opportunities fcr Yes, there are opportunities for increased ef5ciency.
accomplishing this program more efficiently either within an office or across offices?
(a) Agreement State program activities within OSP could be integrated with the NMSS materials program with an estimated resource savings of 3 FTE as a result of increased efficiency. A paper responding to Commission direction to examine the integration of the OSP Agreement State program with the NMSS materials program has been comp!eted.
(b) in addition, under Commission direction, since the beginning of FY 1994. OSP has devoted many of its resources to improving the effectiveness, efficiency, and responsiveness of the Agreement State program. The sum of these improvements has been the equivalent of a program reengineering. Most major revisions have either been completed, or are nearing completion. A summary of the revisions is attached.
Analytical Support Team Findings:
The team agrees that the opportunities identified by the Progfam Planager have the potential for increased efficiency. The reengineering conducted over the past several years in terms of providing operationst def.nitions of adequacy and compatibihty and providing an umbre% policy for the conduct of the program has been substantial arrd stand to improve overall efficiency.
(See last two pages of this report for a complete description of activities undertaker; by GT in this regard.) in addition, the team agrees that the potential integration of OSP into NMSS has merit and is reflective of trends within the program to establish a national materials program.
The team believes that there are other opportunities for increased efficiency in the program. For example, the transfer of rclemaking functions from RES to NMSS, combined with the proposed OSP/NMSS consolidation could help streamline the rulemaking process and assure early and substantive Agreement State involvement in that process. Continued use of working groups involving Agreement State personnel, such as those employed in addressing sealed source and device issues as well as training issues, is also an effective way to leverage scarce OSP resources. Lastly, the reexamination and reissuance of OSP internal procedures should improve efficiency.
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- 5. Are the planned program activities associated with Yes. There are two Chairman Tracking List items relating to GSI 4:
the accomplishment of each Chairman Tracking List "NRC's Relationship With Agreement States."
item adequate for meeting the related milestones? If not, what changes are warranted?
(a) Provide report to the Commission on anernatives and recommendations for cost effective NRC training and technical assistance.
(b) Prepare guidance for assistance to Agreement States to identify and clarify State training needs.
Both (a) and (b) are being addressed in a single Commission papcc.
The 10/14/97 due date set out in the Operating Plan v as extended to November 4th to provide additional time needed to address feasibility issues relating to use of attemative technologes for NRC training courses. The paper was provided to the EDO on November 4,1997.
Analytical Support Team Findings:
The team agrees.
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- 6. Are the planned program activities and related Yes. DSI 4 items a and b are addressed in response to question 5.
milestones associated with meeting DSI commitments With respect to DSI 4 item c, the s'aff has prepared and provided the adequate? If not, what changes are warranted?
Commission with final criteria for staff use in evaluabon and approval of funding for Agreement State training and assocated travel in hardship cases. (SECY-97-183, dated Aufast 7,1997).
Analytical Support Team Findings:
The team agrees.
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- 7. Are the F eivM program actmbes associated with Yes, the p;iew.ed accomplishments are adequate and sufficent to meet A
the accomplishment of the significant SRMs identified in direction provided by the Commissaon in the follownng two skjiJc nl the consolidated Opciating Plan adequate for meeting SFMs:
the related milestones? If not, what changes are
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warranted?
a) SRM dated 2/21/97 regaidig SECY-96-234: Status Report on Imp;ernenti/Jon of the Integrated Materials Performance Evaluabon Prwi.in.
Staff has completed a final Management Directwe 5.6
- Integrated Matenais Performance Evaluabon Program" wtwch inwipciete; i
gtidance for all non-common perferini c ' dcators and which u
reflects the expenence and comments from NRC and Ayec.T.ent State i
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staff. Staff has also focused addibonal attenbon on ensunng the i
1:rneliness in issuance of IMPEP reports to meet the goal of issuance l
wthin 104 days of complebon of the guy.in review. Staff wi!! report to the Commission on the effectmeness of these efforts by 1/30/98, as directed in the SRM.
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b) SRM-dated 03/19/97 reg.id;.g SECY-96-054: NRC's Relabonship
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with AvioeTent States (OSI 4).
1 Staff has provided the Commission with final cntena for funding A,greement State train' s, travel and tedidca: assistance in hardship c
cases (SECY-97-183, dated August 7,1997). Follounng Commission approval, staff will inform States of the final entena and be prepared to i
j respcmd to requests on a M-case basis.
I Staff has gep ied a Commission paper to examine cost effectueness snd attematives for ti.iniig, and to prcmde guidance for offenng assistance to States, on a case-by-case basis, to help identify and l
clarify training needs to.ppivpi;.tw State authonties. It was provided l
to the EDO on November 4,1997.
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Analytical Support Team Findings:
The team agrees with the Program Manager's assessment. However, as mentioned in the team's commed on Question 2. we think that the timeliness goal for issuance of IMPEP reports should be added to the Performance Plan.
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- 8. Are the planned activities associated with regulatory Yes. OSP has two planned actmties in this area.
excellence initiatives and assessments adequate for meeting milestones? If not, what changes are 1 (a) The first is a re-examination and reissuance of OSP intemal warranted?
j procedures, many of which have not been updated since the late
' 1970's and early 1980's.
(b) The second is a self-assessment of the distnbution of documents to Agreement States. Some Agreement States have continued to express concems about the distribution ofinformation having little relevance to the Agreement State program, multiple mailings of the same document to the same addressee, and incorrect addressee names and titles. The self-assessment is planned to begin on January 1,1998 and conclude on March 31,1048.
Additional planned activities will have to be developed if NRC's developing program for regulatory excellence is broadened to address regulatory exce!!ence in Agreement States.
Analytical Support Team Findings:
The team agrees with the Program Manager's assessment. Wo would add, however, that OSP is playing a substantial role in Initiative 4 " Improve the medical regulatory program by modifying 10 CFR Part 35 to be more risk-informed and performance-based." of SECY 97-225," Enhancing NRC Effectiveness and Efficiency.'
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- 9. Are there new policy or program changes anticipated There are no new policy or program chages yet identified for program which could affect resource requirements for FY 2000?
implementation which could affect resource requirements. The Are there aspects of the program which should be schedule and workload associated with new agreements for OH, OK considered for sunsetting? If so, explain.
and PA are significant and should be closely followed to assure adequate resources have been bodgeted. They are current!y projected to become Agreement States in FY 1999-2000. A significant slip in their schedu!es will affect budget planning assumptions for these fiscal years. If NRC rece<ves additional letters of intent fram States to become Agreement S'.ates, additional resources in this area may be needed in the FY 1999/2000/2001 budgets.
Future Agreement State Program issucs will relate not only to operational issues relating to program implementation of the new policies and procedures described in the response to question 4, but also to the development of additional policies and program initiatives in order to further enhance program effectiveness and efficiency as changes extemal to NRC occur. Anticipated issues that will need to be considered, and wi!! likely require additional reicurces, are:
I. How do we continue to mahtain and in rease Agreement State involvement and sharing of the rest urce costs for development of regulations and guidance a support the national materials program, particularly as more States become Agreement States?
ii. What changes will be needed in the materials program as more States become Agreement States?
iii. Defining NRC's oversight role, if any, of Agreement States (or non-Agreement States) in possible regulation of Department of Energy activities.
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Question 9 - Continued Question 9 - Continued
- 9. Are there new policy cr program changes anticipated which could affect resource requirements for FY 2000?
iv. The scope of NRC's role in the "nabonal* materials Are there aspects of the program which should be regulatory program, and NRC's role in assunng safe use of considered for sunsetting? If so, explain.
naturally occurring radioactive material wi5 be an issue which i
NRC will likely need to address as part of deliberation on NRC j
regulatory oversight of DOE.
- v. Should NRC's developing program of regulatory exce!!ence be broadened to address regulatory excellence in Agreement States?
Analytical Support Team Findings:
The team agrees that the Program Manager has adequately and accurate *y addressed the possible extemal changes in the answer. In addition, the team notes that the potential consolidation of OSP into NMSS mentioned in Queshon 4 above could have resource implications in this time frame. The team also believes that the importance of close monitonng of schedules for the potential new Agreement States of PA, OH and OK cannot be overstated. Any slippage in projected dates needs to be promptly reported and considered in development of the agency's overall budget.
The team notes that the Comnision is currently considering issues related to recovery of budgeted costs for Agreement State activities. Specifically, the issue addressed in SECY-97-249 is: Should the budgeted costs of SP activities related to Agreernent l
State oversight, along with other programs, be removed from the fee base and funded through a separate appropriation? The team agrees with the recommendation of SECY-97-243 to pursue removing these activities from the fee base, but recognizes that it could result in a greater level of Congressional scrutiny through the appropriations process and could ultimately have impacts on 7
the size and scope of the program.
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- 10. If program resources were reduced in the range of High priority actmbes in the Picpen include: review of State p w.m 10-20%, what lead office program actuities wot.ld most under the In19.ted Materials Performance Evaluabon Propeii likely be reduced, modified, or eliminated because they (IMPEP); review of requests for new ajveinsits, gucessing are of the lowest poonty in supporting the agency's allegabons in Agreemer" 3tates; tedc.ical assistance and exchange strategic goals? Include any related insights asscciated of informaton (e.g. irete-i.is licensee events that occur in Agreement with the support offices J possible.
States) and the Federal / State Liaison gep.ni actmties.
Activities that would be candidates for reduchon, modificatkn or elimination, if program resources were reduced, include: OSP staff involvement in NRC/OliS working groups (reduce level of effort);
reissuance of OSP intental p vcedures (extend s';hedule); support to other offices on regulabon and guidance develepr=nt actmbes l
(reduce level of effort); and interachon with the Conference of Radiation Control Program Directors (reduce NRC effort in support of CRCPD Committm and reduce NRC funding of CRCPD).
i Analytical Support Team Findings:
t This characterization appears to be appropriate. The team notes, however, that the Federal liaison function is no longer a part of the budget for OSP in FY 1,999.
I 12
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- PROGRAM REVIEWrASSESSMENTS3 -
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- 12. Are plans for ongoing IT projects that fall under the OSP has no current or planned IT picic-cts that would be included agency's Capital Planning and Investment Control under the CPIC process.
(CPIClprocess adequate? Are any problems affecting the timing or budget of the IT project anticipated? What changes to the IT project and/or the program are warranted as a result?
Analytical Support Team Findings:
The team agrees.
e k
(
e 14
O S
9 PROGRAM REVIEW ASSESSMENTS (.
.-n-c
- 0;r 8 RECENTLY COMPLETED OR ONGOING AGREEMENT STATE PROGRAM IMPROVEMENT INITIATIVES Issuance in final on September 3,1997 of a new policy statement entitled " Statement of Principles and Policy for the 1.
Agreement State Program" which set out the basic operating philosophy and framework for the program. It identifies, for l
example, specific NRC actions which will be taken in the event of unsatisfactory performance in an Agreement State l
program. Several implementing procedures were prepared and issued in concert with this Policy statement including procedures for suspensior., emergency suspension and termination of an agreement procedures for placing an Agreement State program on probation, and management directive establishing new standard section 274b agreement. In connection with development of the standard agreement, staff conducted an analysis of existing agreements to determine whether existing agreements needed to be modified or re-affirmed based on the new policies and standard agreement. (SECY 145).
Issuance in final on September 3,1997 of a new policy entitled " Policy Statement on Adequacy and Compatibility of 2.
Agreement State Programs" which establishes the basis and framework for NRC decisions regarding adequacy and compatibility determinations for Agreement State programs. Two major implementing procedures were completed rela +ing to this policy to provide guidance to staff in use of the policy, one a management directive and hbndbook on implementation of the pclicy and a second, an intemal OSP procedure which establishes a compatibility or adequacy level for each section of NRC materials rules and major program elements.
Pilot, interim and now finalimplementation of the Integrated Materials Performance Evaluation Program (IMPEP). IMPEP is 3.
a performance based program for review of both Agreement State and NRC Regional materials programs against common performance indicators. IMPEP includes team reviews of State and Regional programs against known common and non-common performance indicators, participation of Agreement State staff on review teams, use of a seniorlevel Management deview Board (MRB) for program findings, and opportunity for Agreement State or Regicnal manager from the program being reviewed to discuss program findings with the MRB. Management Directive 5.6 and its associated handbook providing final implementing procedures have been completed. Staff has also comp leted procedures for annual meetings with Agreement State in intervening years between IMPEP reviews.
Review of Agreement State Regulations: In accordance with the Commission approved Policy Statement on Adequacy and 4.
Compatibility of Agreement State Programs, impiementing procedures are being finalized for ese by staff in the compatibility reviews of Agreement State regulations.
S.
Funding Agreement State iraining and Associated Travel: SECY-97-183, Criteria for Funding Agreement State Training, l
i 15
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_/
- PROG' RAM REVIEWiSSESSMENTSj
~
jJM a
Travel and Technical Assistance, was issued for Commission appro/af on August 7,1997.
)
Draft guidance for reporting of Agreement State licensee events to NRC has been Agreement State Reporting of Events:
l 6.
distributed to Agreement States for use. That guidance is scheduled to be published in final form by December 31,1997.
Commission direction in the June 30,1997 SRM provides that reporting of events to NRC is mandatory for an Agreement f
State. The Nuclear Materials Event Database is operational and establishes a national database for all materids events.
MD 8.8 was revised, and an intemal OSP procedure was developed, to address a!!egations of Agreement State Allegations:
7.
improper actions by Agreement State licensees as well as allegations of poor performance by Agreement States and allegations of wrongdoing by Agreement State employees. OSP has designated a staff member to serve as Office Allega*Jon Coordinator. Further activities are being examined relating to ethics and integrity issues in Agreement States (SECY-97-156)
MD 6.3 now includes Agreement State early and substantive involvement in the rulemaking process by requesting comments 8.
on certain draft rulemaking p!ans. Early and substantive involvement by Agreement States on major materials program policy and programmatic issues now occurs through the use of NRC/ Agreement State Joint Working Groups. There are currently six active Joint Working Groups. A procedure for the formulation of Joint Working Groups is nearing completion.
Consistent, Coherent Regulation of Materials Licensees Through the Collective Efforts of NRC and the Agreement States:
9.
The improvements noted above are creating a national program approach to regulation endorsed by both NRC and the Agreement States. The national program concept and goal is reflected in the Statement of Principles and Policy for 'J1e Agreement State program.
i 4
16 b
O O
O FY 1998 - 1999 OPERATING PLAN OFFICE OF STATE PROGRAMS Smrember 2S,1997 PROGRAM MANAGER: PaulIL Lohaus PROGRAMi STATE PROGRAMS 1.
BUDGET PLANNED ACCOMPLISIIMENTS FAf Pinnned Accomplishnsent States Intending Or IInviig An Expressed Interest In Becoming Agreement States OSP1 (A) During FY 1998 - 2001 State Programs will continue working with those States, that have submitted a letter of intent to become an Agreement State (Ohio, Oklahoma, and Pennsylvania), to develop their Radiation Control Programs in anticipation of their becoming Agreement States. Ohio is expected to become an Agreement State sometime in FY 1999. Oklahoma and Pennsylvaaia are expected to become Agreement States during 1999-2000. (B) Continue to work with other States (e.g., Connecticut, Wisconsin, New Jersey, Delaware, Wyoming, Missoun) expressing interest in becoming Agreement States.
(A)
(B) l l
Output Measure:
N/A N/A Goal:
N/A N/A Strategy:
2.3.3 2.3.3 DSI:
4 4
SRM:
N/A N/A Chairman Tracking:
N/A N/A I
I State 1>ograms Subchajter1: Radget11annedetecomplishments l' age i
h
-l O
O O
FY 1998 - 1999 OPERATING PLAN OFFICE OF STATE PROGRAMS SmraLv 25,1997 SUPPORT OFFICE ACTIVITIES OGC will provide legal assistance to the Offic: of State Programs on allissues relating to the OGCSI implementation of the Commission's Agreement State Program. This 'mcludes advice on the implementation of the Commission's Agreement State compatibility policy, including the review of specific state regulations on the use of radioactive materials; advice on the rap
- uuents for the approval of new Agreement State Programs; advice on issues related to the extent ofstate authority under an Agreement State program.
(
Output Measure:
N/A l
Goal:
N/A l
l Strategy:
N/A DSI:
N/A SRM:
N/A Chairman Tracking:
N/A l
(
State 1%g w; Subchapter 1: Budget 11annedAccomplishments Page2
O O
O FY1998-1999 OPERATING PIstN OMer o(State Mgrams September 25,199?
OSP Policy and Procedure (A) During FY 1998 - 2001 OSP will continue h implement a policy statement that is intended to draw a clear OSP2 distinction betwe a what is required for the " adequacy" and " compatibility" of an Agreement State program The policy,
establishes a balance between the extent of uniformity of an Agreement State's program with NRCs program to be required and the extent of flexibility allowed to an Agreement State in tailoring its program to the individual circumstances within the State. (B) Continue development ofother Agreement State program improvements and procedures that will lead to greater stability in the Agreement State program. Follow-on revision of the guidance for entering into an Agreement will be completed in 1998. (C) Review OSP procedures to improve the way we do work.
(D) Develop, revise, and implement OSP policies and procedures to make the ofIice more effective and efficient.
(A)
(B)
(C)
(D)
Output Measure:
N/A N/A N/A N/A Goal:
N/A N/A VII.A VII.A Strategy.
2.3.3 2.3.3 7.1.1 7.I.2 DSI:
N/A 4
N/A N/A SRM:
N/A N/A N/A N/A Chairman Tracking:
N/A N/A N/A N/A 1
l l
l
[
I I
State P,+ ms Subchapter 1: Budget 1%nnedAnomplishments Page 3
O O
O FY1998-1999 OPERATING PLAN
\\
ofwe crSme nra.s sepiaaern.1997 Regulatory Development (A) Partidpate in the NRC development ofpolicies and procedures for NRC/ Agreement State regulation of DOE OSP3 facilities. Work with those States that are already regulating portions of DOE facilities to learn from their experience.
Tue resources for this activity are being coordinated through NMSS until Congressional action has been taken.
(B) Participate in the review and comment on unnecessary regulatory requirements and streamlining the licensing process. (C) Participate in the activities that address the risks involved in the use of radioactive materials.
(A)
(B)
(CJ Output Measure:
N/A N/A N/A Goal:
N/A N/A N/A Strategy:
2.4.1 7.1.5 2.2.2, 2.3.1 DSI:
2 N/A N/A SRM:
N/A N/A N/A Chairman Tracking N/A N/A N/A
)
State D.,ie.a =
Page4 Subcharter1: Budget 11anudAccomplishments
~
O O
O FY1998-1999 OPERATINGPIAN oraceerstateMrmms September 25,1997 Integrated Materials Performance Evaluation Program (IMPEP)
(A) During FY 1998 - 2001, OSP will implement a IWanagement Directis e that guides a common process by which OSP4 OSP will assess the performance of the 30 Agreement States. OSP, with support from NMSS and the Regional offices, will conduct ten reviews for Agreement States. Reviews are conducted at least once every 4 years. (B) OSP, with support from Regional oflices, will conduct management meetings with Agreement States during the years between IMPEP reviews. (C) OSP will support NMSS in the conduct ofIMPEP program reviews ofNRC Regional offices.
Reviews are conducted at least once every other year (two Regions each year). (D) Conduct compatibility reviews of proposed new or revised and final State statutes and regulations for existing Agreement States.
(A)
(B)
(C)
(D)
Output Measure:
NMS 10 N/A NMS 10 N/A Goal:
N/A N/A II N/A Strategy:
2.3.2 2.3.2 6.1.2 2.3.2 l
N/A N/A N/A N/A DSI:
SRM:
N/A N/A N/A N/A Chairman Tracking:
N/A N/A N/A N/A SUPPORT OFFICE ACTIVITIES NMSS S1 Continue the Integrated Materials Performance Evaluation Program (IMPEP) to assess the performance ofNRC regional materials program. This program evaluates and determines a unifonn and consistent level of health and safety regulations, technical adequacy, and quality of the inspection program.
Continue to share the results and performance with others. (secondary strategy 6.1.2)
Output Measure:
NMS 10 Goal:
II.A.1 & II.A.2 I
Strategy:
6.1.1 DSI:
4 SRM:
SECY-96-234 Chairman Tracking:
N/A I
State r,,.
Subchapter 1: Budget Planned Accomplishments Page5
O O
O FY1998-1999 OPERATINGPLAN 07ce ofS'*** Fes i
serteneer 2s,1997 Continue the Integrated Materials Performance Evaluation Program to assess the performance of NMSS S3 Agreement States. This program evaluates and determines a uniform and consistent level of health and safety regulations, technical adequacy, and quality of the inspection r regram..
Output Measure:
NMS 10 Goal:
II.A.1 & II.A.2 Strategy:
2.3.2 DSI:
4 l
SRM:
SECY-96-054 Chairman Tracking:
N/A Advice on issues related to the extent of state authority under an Agreement State program; and advice OGC S2 on the implementation of the Integrated Materials Performance Evaluation program. The General Counsel serves as a permanent member of the IMPEP Management Review Board.
Output Measure:
NMS 10 j
Goal:
N/A Strategy:
N/A DSI:
N/A SRM:
N/A Chainnan Tracking:
N/A i
(
i StateIvegrana Subchapter 1: BudgetPlannedAccomplishmenn Page 6 9
pJ.
C)
_)
G FY1998-1999 OPERATINGPLAN oraorstatewg September 3, H97 Conference of Radiation Control Program Directors (CRCPD) and Organization of Agreement States (OAS)
(A) OSP Program Support for CRCPD takes the form of a S110,000 interagency agreement with FDA annually for a OSPS joint Federal cooperative agreement administered by FDA. CRCPD Task Groups assist NRC on issues of topical interest such as low-level radioactive waste and radioactive scrap steel. CRCPD also develops and maintains the suggested State regulations which are used as models for development of compatible State regulations. We will have increased focus on development of Suggested State Regulations (SSRs) and parallel development ofNRC and SSR rules to help ensure compatibility of Agreement State rules. (B) Continue to maintain program interface with the Organization of Agreement States (OAS) executive board and support forjoint NRC/OAS working groups to address issues ofcommon regulatory need and interest. Participate in an annual meeting ofNIC and Agreement States.
(D) Ensure opportunity for early and substantive input to NRC rules, guidance, and policy development which affect the material program and Agreement State activities. This includes participation in NRC/OASjoint working groups and l
coordination of Agreement State participation.
(A)
(B)
(C)
Ouf put Measure:
N/A N/A N/A Goal:
N/A N/A N/A i
Strategy:
2.3.1 23.1 2.3.1 DSI:
N/A 4
4 SRM:
N/A N/A N/A Chairman Tracking:
N/A N/A N/A SUPPORTOFFICE ACTIVITIES OGC S3 OGC will provide legal assistance to the staff working with agreement states to assure consistent protection of public health and safety nation wide, including assisting the staffin reviewing the adequacy l
l and compatibility of each Agreement States Radiation Control Program.
Output Measure:
N/A Goal:
N/A Strategy:
N/A DSI:
N/A SRM:
N/A Chairman Tracking:
N/A 1
State T..,w - e.;
Subchapter 1: Budget Planned Acwmplishments Page 7
u O
(J v(%
wJ FY1998-1999 OPERATING PLAN ora ersrawrnvams Srreember 25.1997 Training and Technical Assistance (A) Coordinate training activities for Agreement State staff attendance at NRC training courses. This includes OSP 6 implementation of the criteria for evaluation of NRC funding of Agreement State travel and tr'aining expenses.
(B) Provide assistance, via OSP staff and Agreement State staff, in teaching NRC training courses. (C) Provide technical assistance to Agreement States in the interpretation ofNRC programs, regulations, guidance and policies.
Requests may be in the form of telephone calls, e-mails, or letters. (D) Maintain the OSP Home Page by continuin add the ongoing information generated by the office and add enhancements as necessary.
(A)
(B)
(C)
(D)
Output Measure:
N/A N/A N/A N/A Goal:
VII.A VII.A N/A VI.A Strategy:
7.1.4 7.1.4 N/A 63.1 DSI:
4 N/A 4
N/A SRM:
N/A N/A N/A N/A Chairman Tracking:
N/A N/A N/A N/A SUPPORT OITICE ACTIVITIES Continue to evaluate technical licensing and inspection issues from Agreement States including sealed NMSS S2 source and device technicalissues.
I Output Measure:
N/A Goal:
N/A l
Strategy:
N/A DSI:
4 SRM:
N/A Chairman Tracking:
N/A l
k State Programs Page8 Subchapter 1: BudgetstannedAcconylishments
O O
O-FY1998-1999 CPERATING PIAN ontcaasuste nr-g se emsern. nn r
l Incidents and Allegations (A) Gather, compile, report and analyze materials licensee events and abnormal occurrences that occur in OSP 7 Agreement States. (B) Address allegations about Agreement State licensees, Agreement State programs, and Agreement State officials.
(A)
(B)
Output Measure:
N/A N/A Goal:
VIII.A.2 N/A Strategy:
6.1.2 N/A DSI:
N/A N/A SIGI:
N/A N/A Chairman Tracking:
N/A N/A l
l I
{
I State Pr,,-,,
Subcharter 1: Budget 11onned Accowlishments Page9
O O
O FY1998-1999 OPERATINGPIAN Ofter e(State Pwsmms Smtember 25,1997 Federal and State Liaison Program (A) Provide the Commission and senior NRC management with advice and information on the programs of othe OSP8 agencies. Represent NRC and its policies to other Federal agencies and serves on interagency committees. Review pertinent rulemaking, correspondence and legislation that affect NRC's relations with other Federal agencies. As appropriate, address policy issues related to NRC interaction with Indian Tribes. Coordinate with other Federal a f
as required by law or Executive Order, the NRC activities in the CEQ, environmentaljustig and Historic Preservat:o j
areas. (For FY 1998 only)
(B) Implement the State Liaison Officer (SLO) program whereby each Governor appoints a State official to be the liaison to NRC for all nuclear-related activities in that State. The Regional State Liaison Officer functions as lead NRC contact for governor-appointed SLOs and other State officials, raaintains liaison with other Regional Federal ofIices, and maintains awareness of all relevant State activities involving NRC matters.
(C) Conduct periodic meetings with SLOs in the Regions. Plan, coordinate and conduct a National SLO Meeting in the Washington, DC, area every three years. This meeting brings together all of the SLOs from each of the 50 States to discuss issues and exchange information of current interest. A national meeting will be held in early FY 2000.
(D) Revise or develop OSP policies for the Federal and State Liaison functicn as directed by management.
(E) Implement the Commission's policy on cooperation with host and adjacent States which allows States to observe and particip te in NRC mspections at reactors. Address policy issues reted to inspection ofother NRC licensees by Agreement State-Negotiate and coordinste Memoranda of Understanding (MOU) with States as provided for in the Commission's policy statement on cooperation with the States.
(F) Attend periodic emergency response training provided by OfIice for Analysis and Evaluation ofOperational Data and participate in the NRC Operations Center's planned drills and exercises.
(G) Maintain contacts with representatives of State Public Utility Commissions, National Association of Regulatory Utility Commissioners (NARUC) including monitoring electric utdity restructuring and sersing on NARUC staff subcommittee on Nuclear Issues / Waste Disposal. Follow activitie; ofnational organizations such l
i as National Governor's Association and the National Conference of American Indians.
Statehowwe Page10 Subchapter 1: Budget 11annedAccompfhhments
O O
O FY1998-1999 OPERATINGPL.AN Ofee o(State Promsm3 Sm:w.ber 25,1997 (H) As required in 10 CFR Parts 71 and 73, maintain list of Governors' designees to receive advance notification of high-level radioactive waste (HLW) shipments.
(I) Maintain an tavareness of the State's progress in the low-level waste disposal facility site selection process through its liaison activities and be prepared to discuss the regulatory process with State ofIicials and the public.
(J) Coordinates Systematic Assessment of Licensing Performance (SALP) meetings with State and Local officials, provides State officials with event notification and follow-up, monitors performance incentive programs, and assists in other PUC activities. Provides lead for allinteraction with State and Local officials, monitors legislative activities and plans Regional SLO meetings.
(K) Testifies at State Legislative hearings and rep.sents the NRC before State intergovernmental groups and at State meetings at which NRC activities are discussed.
(A)
(B)
(C)
(D)
(E)
Output Measure:
N/A N/A N/A N/A N/A Goal:
N/A VI.A VI.A VI.A
'/I.A Strategy:
N/A 6.2.1 6.2.1 6.2.2 6.2.I DSI:
N/A N/A N/A N/A N/A SRM:
N/A N/A N/A N/A N/A Chairman Tracking:
N/A N/A N/A N/A N/A (F)
(G)
(II)
(I)
(J)
(K)
Output Measure:
N/A N/A N/A N/A N/A N/A Goal:
I I
III.B N/A Vr.A VI.A Straiegy:
1.1.8 1.1.5 3.1.3 N/A 1.6.2, 6.2.1 6.2.1 DSI:
N/A N/A N/A N/A N/A N/A SRM:
N/A N/A N/A N/A N/A N/A Chairman Tracking:
N/A N/A N/A N/A N/A N/A I
State l>egrams Subchapter 1: Budget Planned Accomplishments l' age 11
i od o
o v
FY1998-1999 OPERATINGPL4N Omcr ofState Memms Sepire ber 25.1997 2.
STRATEGIC PLAN SUBSTRATEGIES No.
Sub-Strategies:
We will be alert to the changing environment in the electric utility industry and timely adjust our regulatory program to 1.1.5 maintain safety.
I (G) Maintain contacts with representatives of State Public Utility Commissions, National Association of Regulatory OSP8 Utility Conunissioners (NARUC) including monitoring electric utility restructuring and serving on NARUC staff subcommittee on Nuclear IssuesAVaste Disposal.
Support Commission representative to NARUC participation in three NARUC national meetings Maintain contact with NARUC staff and stafrof Nuclear IssuesAVaste Disposal Subcommittee threugh participation in bi-weeldy conference calls and participation at perio:iic meetings held concurrently with national NARUC meetings.
We will maintain and exercise an ia:ident response capability to ensure that licensees and the NRC are prepared to 1.1.8 respond to radiological emergencies.
(F) Attend periodic emergency response training prcvided by OfIice for Analysis and Evaluation of0peraticmal Data and OSP8 participate in the NRC Operations Center's planned drills and exercises.
Participate in emergency exercises when requested.
We will develop improved methods oforganizing and displaying performance informatioriin order to enhance the 1.6.2 assessment of plant performance and communicate the basis for NRC decisions to the industry and the public.
(J) Coordinates Systematic Assessment of Licensing Performance (SALP) meetings with State and Local officials, OSP8 provides State officials with event notification and follow-up, monitors performance incentive programs, and assists in other PUC activities.
I Inform States of results of each Senior Management Meeting.
State Programs Page12 Subchapter 2: Strategic Plan Substrategies
O O
O v
FY1998-1999 OPERATINGPLAN Ofsce ofState Programs September 23,1997 We will assess our regulations and processes to identify those that are now or can be made risk 'nformed, performance 2.2.2 based or risk-informed, less prescriptive.
(C) Participate in the activities that address the risks involved in the use of radioactive materials.
OSP 3 Review and comment on work products in this area, as requested.
We will provide for early and substantive involvement of the Agreement States in rulemaking and regulatory processes, 2.3.1 including the transition to risk-informed, performance-based regulation er a risk-informed, less prescriptive approach.
(A) Fund interagency agreement between NRC and FDA to support FDA Cooperative Agreement with the CRCPD.
OSP5 Provide NRC resource staff to CRCPD Task Groups addressing issues of topicalinterest to NRC such as radioactive scrap steel. Increase focus on development of Suggested State Regulations (SSRs) and parallel development of NRC and SSR rules to help ensure compatibility of Agreement State rules.
DATE TBD Complete funds transfer to FDA.
10/30/97 Update / identify resource representatives for CRCP,D Committees.
10/23-28/97 Participate in 2 CRCPD Board meetings.
TBD Coordinate NRC participation in Annual CRCPD Meeting.
TDD Provide NRC support to CRCPD in parallel development of SSR equivalent to new Part 35.
(B) Continue to maintain program interface with the Organization of Agreement States (OAS) executive board.
Participate in an annual meeting of NRC and Agreement States.
10/16-18/97 Participate in Annual OAS meeting Conduct monthly conference calls with OAS Executive Board.
(D) Ensure opportunity for early and substantive input to NRC rules, guidance, and policy development which affect the material program and Agreement State activities. This includes, formation and participation in NRC/OASjoint working I
groups to address issues of common regulatory need and coordination of Agreement State participation.
i I
State T w w.,mi Page13 Subchapter 2: Strategic Plan Substrategies
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FY1998-1999 OPERATING PLAN osersurews sertember 2s. n91 Transmit, or assure transmittal, of draft Rulemaking Plans, guidance documents, and program development initiatives to Agreement States for review and comment.
Form joint NRC/ Agreement State Working Groups (WG) and provide support through the OSP representative.
Provide funding for Agreement State representative travet.
We will review the adequacy and compatibility of each Agreement State Radiation Control Program and discuss the 23.2 results of this performance review with the Agreemmt States.
(A) With support from NMSS, OGC, and the Regional OfIices, conduct ten reviews of Agreement State programs for OSP4 continued adequacy and compatibility in accordance with Management Directive 5.6 " Integrated Materials PerfGrmance Evaluation Program (IMPEP).
Meet quarterly quota and schedule for conduct ofIMPEP reviews.
Issue final IMPEP reports within 104 days of review completion.
Conduct annual training for IMPEP review teams.
(B) With support from Regional OfIices, conduct annual management meetings with each Agreement State during intervening years between afPEP reviews.
i Meet quarterly quota and conduct Management Meetings in accordance with OSP Internal Procedure D.24, Annual Meetings with Agreement States Between Reviews.
Issue management meeting reports within 30 days.
(D) With support from the ReF onal Offices, NMSS, and OGC, conduct reviews ofproposed and final State regulations i
1 for compatibility with NRC regulations.
Complete reviews of State regulations on schedule to meet State needs in accordance with OSP Internal Procedure D.7, Procedure for Reviewing State Regulations.
I State & grams Subchapter 2: StrategicPlanSubstrategies Pag
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O FY1998-1999 OPERATINGPLAN Ofuv cfSsateherams September 25,1997 SUPPORT OFFICE ACTIVITIES NMSS S3 Continue the Integrated Materials Performance Evaluation Program to assess the performance of Agreement States. This program evaluates and determines a uniform and consistent level of health and l
l safety regulations, technical adequacy, and quality of the inspection progrant Current Date Provide NMSS support to OSP Agreement State IMPEP reviews Ongoing FY 98 State schedule 11/97 Arizona 01/98 Massachusetts 03/98 Arkansas 03/9s New York 04/98 l
Alabama 06/98 Kansas 07/98 Maine
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08/98 Rhode Island 08/93 Oregon i
i TBD FY 99 State schedule' l
' Performance Measure for IMPEP review of Agreement States and NRC Regional Offices - the goal is to complete 2 regional and 10 IMPEP reviews in FY 99.
State nograms Subchapter 2: Strategic 1%n Substrategies Page 15 t
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Oc oU FY1998-1999 OPERATINGPLAN omerstaresw ms r
September 25.1997 (A) Gather, compile, report and analyze materials licensee events and abnormal occurrences that occur in Agreement OSP7 States.
DATE 12/31/97 Issue final Agreement State Event Reporting IIandbook.
Evaluate Agreement States event reporting to assure NMED database is complete.
Address Agreement State events during monthly NMSS event and evaluation follow-up meetings.
Obtain and review Agreement State reports of Abnormal Occurrences.
(B) Address al!egations about Agreement State licensees, Agreement State programs, and Agreement State omcials.
DATE Forward to the appropriate Regional Office all allegations about Agreement State performance or Agreement State licensees.
During IMPEP reviews, evaluate Agreement State resolution of allegations received from NRC.
TBD Complete revisions to OSP Allegation IIandling procedures.
Conduct Allegation Review Board meetings for all allegations of wrongdoing by Agreement State staff.
We will continue to respond to requests from individual States that express interest in pursuing Agreement State status l
2.3.3 and work with each State to achieve this goal;we will also encourage retention ofexisting Agreement States primarily through non-monetary incentives.
(A) With support from NMSS, Regional omces, OGC, RES and AEOD, continue working with Ohio, Oklahoma, and OSP1 Pennsylvania to become an Agreement State. (Ohio is expected to become an Agreement State sometime in FY 1999.
Oklahoma and Peimsylvania are expected to become Agreement States during 1999-2000.)
DATE Complete review of Pennsylvania proposed regulations for full Agreement in accordance TBD with date requested by PA or r negotiated date.
State Programs Subchapter 2: Strategic 11an.iubstrategies Page16 J
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O FY199b-1999 OPERATLVGPLAN o r a erst-ta w s secremser n,1997 10/30/97 Respond to Oklahr,ma request for guidance on scope of Agreement.
DATE Complete review of Ohio Agreement Application in acordance TBD with OSP Internal Procedure C.!, Processing of New Agreement in accordance with negotiated schedule.
(B) Continue to work with other States (e.g., Connecticut, Wisconsin, New Jersey, Delaware, Wyoming, Missouri) expressing interest in becoming Agreement States.
No defined activities at this time l
(B) With support of NMSS, RES, OGC, AEOD and.he Regional Oflices, continue development ofother Agreement OSP2 Etate program improvements and procedures that will lead to greater stability in the Agreement State program. Revi e guidance for entering into an Agreement.
Complete revision of OSP procedure C.t " Processing of New Agreements"in sufTicient time for use in processing the new Ohio agreement.
(C) Provide technica' assistance to Agreement States i[1 the interpretation of NRC programs, regulations, guidance and OSP6 policies. Requests may be in the form of telephone calls, e-mails, or Ictters.
Issue All Agreement State Letters, as required.
Provide response to technical assistance requests from Agreement States in accordance with requested, or negotiatea due da!es.
We will identify and resolve significant legal, procedural and technical issues prior to accepting oversight responsibilities 2.4.1 of DOE nuclear facilities.
(A) Participate in the NRC development of policies and procedures for NRC/ Agreement State regulation of DOE OSP3 facilities. Coordinate with those States that currently provide oversight ofportions of DOE facilities to learn from their experience.
No defined activities at this time I
State 1%i=.;ms Subcharter 2: Strategic Plan Substrategies Page 17
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v FY1998-1999 OPERATING PIAV 0@u ofState Phsw Smrember25,1997 We will maintain the regulatory framework and the capability necessary to regulate transportation and storage of spent 3.13 fuel.
(H) As required in 10 CFR Parts 71 and 73, maintain list of Governors' designees to receive advance notification of hi OSP8 level radioactive waste (HLW) sifsments.
Update and publish list of Governor's designees annually in the Federal Recister.
We will establish and clearly communicate our annual performance goals and measures.
6.1.I SUPPORT OFFICE ACTIVITIES NMSS SI Continue the Integrated Materials Performance Evaluation Program (IMPEP) to assess the performance of NRC regional materials program. This program evaluates and determines a uniform and consistent level of health and safety regulations, technical adequacy, and quality of the inspection program.
Continue to share the results and performance with others. (secondary strategy 6.I.2)
Current Date 2
IMPEP 12/97 Conduct training ofIMPEP teams 01/98 Conduct RI IMPEP review 02/98 Conduct RII IMPEP review 06/98 Issue 1998 regional reports FY 1999 IMPEP reviews TBD Conduct RIII IMPEP review TBD Conduct RIV IMPEP review l
l Performance Measurr,s for FY 99 Integrated Materials Performance Evaluation Program (IMPEP) reviews of Agreement 2
States and NRC Regional Offices - the goal is to complete 2 regional IMPEP reviews and 10 State reviews. State reviews are tracked under budget planned accompEshment NMSS/SP 3.
State 1%g..ms Subchapter 2: Strategic 11an Substrategies l' age 18 a
FY1998-1999 OPERATINGPLAN sapremser25. Im operofsameru ma n
6.1.2 We will measure and report the perfor tance of both NRC and its compliers and share this perivmance 'mfor nation in a focused way with interested stakeholders.
OSP4 (C) $upport NMSS in the conduct ofIMPEP reviews of two NRC Regional Office licensing and inspection programs by providing staff to help complete the reviews.
6.2.1 For each of the various types ofissues, we will develop a specific approach for responding to public interests and concerns, ensuring that our approaches to public interaction employ open processes that provide opportunities for.
meaningful participation, candid communication, and exchange ofviews among the participants.
OSP8 (B) Implement the State Liaison Officer (SLO) Program.
(C) Conduct meetings with the SLOs.
(E) Implement Policy on cooperation with host and adjacent States to observe and participate in inspections and negotiation ofimplementing MOUs. Address policy issues related to inspection ofNRC licensees by Agreement States.
t (K) Testify at State Legislative hearings and represent NRC before State intergovernmental groups.
Conduct Regional SLO meetings.
Notify new Governor of NRC State Liaison Progrant and request identification of State Liaison Ofruer.
6.2 2 We will ensure that the approaches developed are consistently practiced agency-wide by using centralized planning and coordination, and decentralized implementation, primarily by the program offices and Regions.
OSP8 (D) Revise RSLO program guidance DATE Complete revision to Os State Liaison Program Guidance 1/1/98 a
I Subchapter 2: Strategic 11an Substrategies l' age H StateI%grenn
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FY1998-1999 OPERATING PL4N oraersure nerms september 2s, nn We will capitalize on information technology for improving information access, information distribution, and public 63.1 interaction, being careful not to eliminate paper in favor of electronic communication without full consideration of the public's ability to access information electronically.
OSP 6 (D) Maintain the OSP Home Page by continuing to add the ongoing ~.rmation generated by the office and add enhancements as necessary.
Manage ORNL OSP home page contract We will proactively examine our programs and performance in order to improve the way we do our work through a 7.1.1 comprehensive, systematic, agency-wide approach to program assessment and improvement.
DATE OSP 2 (C) Review OSP internal procedures.
Complete review of OSP internal procedures using a schedule that will allow ORNL to complete Statement of Work.
With assistance from NMSS and IRM compte self-assessment of the 4/1/98 process followed in distribution of documt :s to States.
We will implement changes to improve the effectiveness and efliciency of our regulatory programs and our management 7 1.2 and support activities. (Lead Office: RES)
(D) Develop and revise OSP procedures to make the ofIice more effective and eflicient.
OSP2 DATE 9/30/99 ORNL to complete revision of OSP internal procedures; one-half of procedure revisions to be completed in FY 1998.
We will provide training and development that will enable us to achieve excellence in our organizational and individual 7.1.4 performance.
(A) Coordinate training activities for Agreement State staff attendance at NRC training courses. This includes OSP6 implementation of the criteria for evaluation ofNRC funding of Agreement State travel and training expenses.
(B) Provide assistance in teaching NRC training courses, both OSP staff and Agreement State staff.
I State rigi.ms Page20 Subchapter 2: Strategic Fran Substrategies
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O FY1998-1999 OPERATINGPLAN ornserss sePro1~*~r sept & 2s.1991 DATE l
10/1457 Provide report to Commission on alternatives and recommendations for cost effective NRC training and technical assistance.
l Prepare guidance for assistance to Agreement States to identify and 1N1457 l
clarify State training needs.
. Prepare and implement final criteria for funding Agreement State j
travel, training, and technical assistance within 60 days of l
Commission approval l
We will eliminate unnecessary regulatory requirements and policy statements, and streamline our processes, including l
7.1.5 l
using information technology to help improve efliciency.
1 (B) Participate in the review and comment on unnecessary regulatory requirements and streamlining the licensing OSP3 process.
Review and comment on work products, as requested.
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Subchapter 2: Strategic Plan Substrategies rage 21 v
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FY1998-1999 OPERATING PIAV septer,4er n, nn Oraerstauws 3.
PERFORMANCE PLAN OUTPUTMEASURES Number ofIntegrated Materials Performance Evaluation Program (IMPEP) reviews of Agreement States Measure:
and Regional Offices Completed.
FY 1999 Target:
Complete 10 Agreement State and 2 NRC Regional office IMPEP reviews.
Quarterly Milestones:
FY 98 FY 99 Is' vet
- Actual Target
- Actual 1st 4(1) 4(1) 2nd 7(2) 7(2) 3rd 10(2) 10(2) 4th 12(2) 12(2)
Remarks:
- NRC Regional office reviews shown in ( ).
State n vi, ems Subchapter 3: Performancertan outputMeasures Page22
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O' FY1998-1999 OPERATINGPL4N orcaersuwws sm ersern nn e
4.
CHAIRMAN TRACKING LIST h
Description l
IV.D.1 DSI 4: NRC's relationship with Agreement States DATE 10/14/97 Provide report to Commission ou alternatives and recommendations for a.
cost effective NRC training and technical assistance.
b.
Prepare guidance for assistance to Agreement States to identify and clarify 10/14/97 State training needs L
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O-l FY1998-1999 OPERATING PLAN or.ceasusanr r s.ra-aer:s,1n1 5.
DIRECTION SETTING ISSUF3 (DSIs)
Eg, Titic/ Scope DSI 4 NRC's Relationship with Agreement States DATE 10/1457 Provide report to Commission on alternatives and recommendations for a.
cost effective NRC training and technical assistance.
f 10/1457 Prepare guidance for assistance to Agreement States to identify and clarif b.
State training needs.
Prepare and implement final criteria for funding Agreement State c.
training and associated travel within 60 days after Commission
- final approval.
SUPPORT OFFICE ACTIVITIES l
conduct Integrated Materials Performance Evaluation Program during this planning period.
d.
1, StateI>egrams rage 24 Subchepter 5: Direction Serring hsues
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O FY1998-1999 OPERATINGPIAV Ofee ofStasr Nrrams September 25,1997 6.
STAFF REQUIREMENTS MEMORANDA (SRM)
SRM dated XX/XX/XX regarding SECY-96-234 - (N5Edlilife)
SRM dated 03/19/97 regarding COMSECY-96-054 - NRC's Relationship with Agreement States (DSI 4).
SIGNIFICANT REGULATORY EFFECTIVENESS / EXCELLENCE INITIATIVES 7.
DATE 3/30/98 Self assessment ofinformation transmitted to Agreement States.
8.
SIGNIFICANT INFORMATION TECIINOLOGY INITIATIVES No initiatives at this time.
9.
OTIIER MAJOR PROGRAM ACTIVITIES No activities at this time.
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StatePrograms Subchapter 6: StafRequirements Memoranda rage 25
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l AGEEDA STATE PROGRAMS NOVEMBEIL211997 9:15 A.M.
O-3B4 1.
Introduction (Thompson) 9:15-9:20 2.
Program Overview (Bangart/Lohaus) 9:20-9:30 Historical perspective of Agreement State Program 3.
Significant program issues (Lohaus) 9:30-10:30 Need new National Materials Program Development substrategy (see response to Question #1)
Need to revise.'utput measure to add timeliness goalin issuing IMPEP reports (see memo and response to Question #2)
Monitor schedules for potential new Agreement States (See memo and response to Question #9)
FY 2000 policy and program changes (see response to Question #9):
o Need to share costs with Agreement States for administration of national f
materials program (regulation and guidance devalopment) o NRC's oversight role,if any,in Agreement State regulation of DOE activities o
Possible issue of NRC regulation of naturally occurring radioactive material as part of NRC oversight ol DOE activities o
NRC's role, if any, in regulatory excellence in the Agreement States o
Need to closely monitor schedules for new Agreement States (OK, OH, PA) for any changes Reduction Scenarios (see response to Question #10)
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