ML20206S280
| ML20206S280 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/1998 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-3096, NUDOCS 9905210087 | |
| Download: ML20206S280 (13) | |
Text
f CERTIFIED BY:
Date Issaed: 4/30/98
- G:orge'Apostolakis - 5/6/98.
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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MEETING OF THE SUBCOMMITTEE ON RELIABILITY AND PROBABILISTIC RISK ASSESSMENT MEETING MINUTES - FEBRUARY 19-20,1998 ROCKVILLE, MARYLAND INTRODUCTION The ACRS Subcommittee on Reliability and Probabilistic Risk Assessment (RPRA) met on February 19-20,1998, at 11545 Rockville Pike, Rockville, MD, in Room T-2B3. The purpose of this meeting was to continue the Subcommittee's review of proposed final Standard Review Plan (SRP) Sections and Regulatory Guides for risk-informed, performance-based regulation including individual applications for inservice testing, technical specifications, and graded quality assurance. The Subcommittee reviewed matters included in the Staff Requirements Memorandum dated October 16,1997, regarding elevation of core damage frequency (CDF) and possible revision to the 1
' Commission's Safety Goal Policy Statement. The Subcommittee also reviewed industry-initiated risk-informed pilots related to the development of full-scope probabilistic risk assessments (PRAs) and the use of quantitative health objectives (QHOs). The Subcommittee also considered staff and industry activities in the area of performance-based regulation.
~ The entire meeting was open to public attendance. Mr. Michael T. Markley was the cognizant ACRS staff engineer for this meeting. The meeting was convened at 8:30 a.m. each day and recessed at 4:50 p.m. on February 19 and adjoumed at 2:40 p.m. on February 20,1998.
ATTENDEES ACRS Members t
G. Apostolakis, Chairman D. Powers, Member J. Barton, Member R. Seale, Member M. Fontana, Member W. Shack, Member (2/19 only)
T. Kress, Member R. Sherry, ACRS Fellow D. Miller, Member M. Markley, ACRS Staff Principal NRC Speakers
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M. Cheok, NRR*
T. King, RES*
CAgyO S. Dinsmore, NRR J. Murphy, RES D. Fischer, NRR G. Parry, NRR i
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N. Gilles, NRR M. Wohl, NRR R. Gramm, NRR R. Woods, RES G. Holahan, NRR.
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m 9905210087 990430 PDR ACRS 3096 PDR Certined By R
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Religbility &,PRA Subcommittee 2
2/19-20/98 3
Minutes :
PrincipalIndustry Speakers B. Bradley, NEl*.
S. Knauf, APS*
' B. Christie, PTl*
B. Mays, TU*
T. ' Hook, SCE*
S. Rosen, HPL*
NRR Office of Nuclear Reactor Regulation RES Office of Nuclear Regulatory Research NEl Nuclear Energy Institute PTl Performance Technology, Inc.
SCE Southem Califomia Edison APS Arizonia Power Supply TU Texas Utilities HPL Houston Power and Light Company There were approximately 13 members of the public in attendance at this meeting. A complete list of attendees is in the ACRS Office File, and will be made available upon request. The presentation slides and handouts used during the meeting are attached to the office copy of these minutes.
FEBRUARY 19.1998 OPENING REMARKS BY THE SUBCOMMITTEE CHAIRMAN Dr. Apostolakis convened the meeting at 8:30 a.m. He stated that the purpose of this meeting was to continue the Subcommittee's review of proposed final Standard Review Plan (SRP) Sections and Regulatory Guides for risk-informed, performance-based regulation including individual applications for inservice testing, technical specifications, and graded quality assurance. He stated that the Subcommittee would review matters included in the Staff Requirements Memorandum dated October 16,1997, regarding elevation of core damage frequency (CDF) and possible revision to the Commission's Safety Goal Policy Statement. He stated that the Subcommittee would also review industry-initiated risk-informed pilots related to the development of full-scope probabilistic risk assessments (PRAs) and the use of quantitative health objectives (QHOs). Dr. Apostolakis stated that the Subcommittee may also consider staff and industry activities in the area of performance-based regulation.
Dr.' Apostolakis stated that the Subcommittee had received no written comments or requests for time to make oral statements from members of the public.
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DISCUSSION OF AGENDA ITEMS NRC Staff Presentation Messrs. Thomas King, RES, and Gary Holahan, NRR led the discussions for the NRC staff. Messrs. Brad Hardin, RES, and David Fischer and Michael Cheok, NRR, presented risk-informed inservice testing (IST). Mr. Roy Woods, RES, and Ms. Nanette Gilles and Millard Wohl, NRR, presented risk-informed technical specifications (TS).
Messrs. Roy Woods, RES, and Robert Gramm and Steven Dinsmore, NRR, presented risk-informed graded quality assurance (GQA). Mr. Joseph Murphy, RES, presented 4
performance-based tegulation.
Messrs. King and Holahan provided an overview of the staffs planned presentation.
They stated that all the subject documents were revised to be consistent with proposed final SRP Chapter 19 and Regulatory Guide 1.174 (formerly DG-1061) general
)
guidance. They also summarized the key issues for the final application-specific SRP Sections and Regulatory Guides including:
Possible credit for the Maintenance Rule in terms of monitoring and corrective action.
Consideration of partial scope application submittals.
Scope of allowed changes (e.g., test' interval, location, type, etc.)
Consideration of what is an acceptable PRA.
Guidance for performance monitoring, trending, and corrective action for low safety significant components.
Documentation requirements.
NRC endorsement of industry Standards and Code Cases.
Inservice Testing Messrs. Hardin and Fischer provided a brief discussion of the major public comments and proposed changes to SRP Section 3.9.7 and Regulatory Guide 1.175 (formerly DG-1062) for IST. Significant points raised during the discussion include:
Major changes resulting from public comments include:
Performance monitoring for high safety significant components (HSSCs) and low safety significant components (LSSCs) was clarified.
The relationship to the Maintenance Rule was clanfied.
The scope of the IST program was clarified (i.e., shutdown).
Guidance on corrective action was revised to be less prescriptive.
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Major changes resulting from the pilot plant reviews include:
. Guidelines for scope, level of detail, and quality of PRA for IST were reduced.
Language stating " changes to test interval (only)" was deleted as a separate option.
Guidance was revised to allow for changes in test interval as per American Society of Mechanical Engineers (ASME) Code Cases.
Guidance was clarified to state that previously reviewad requests need not be reevaluated by NRC again once approved.
Technical Specifications Mr.' Woods and Ms. Gilles provided a brief ' iscussion of the major public comments on d
and proposed changes to SRP Section 16.1 and Regulatory Guide 1.177 (formerly DG-1065) for TS. Major changes resulting from public comment and the pilots include:
Acknowledgment that the allowed outage times (AOTs) and system testing intervals (STis) will be considered on their own merit as provided in the principles stated in Regulatory Guide 1.174.
i Guidance was added to provide for a discussion of the benefits associated with the proposed change.
The discussion of PRA qualiiy and scope was revised to provided flexibility for cases where PRA modeling is not available.
Tier 3 was modified to incorporate pilot experience for administrative control of the configuration risk management program.
Graded Quality Assurance Messrs. Woods and Gramm provided a brief discussion of the major public comments on and proposed changes to Regulatory Guide 1.176 (formerly DG-1064) for GQA.
Major changes resulting from public comment and the pilots include:
Guidance was modified to allow for screening of low safety significant component (LSSC) failures in lieu of root cause analysis.
Guidance was revised to state that the documentation necessary to be included in a GQA submittal.
Guidance was revised to clarify that PRA quality should be sufficient to support the need for a regulatory decision.
Greater credit for monitoring via the Maintenance Rule is allowed.
Guidance for high safety significant components (HSSCs) was clarified.
Reliability & PRA Subcommittee 5
2/19-20/98 Minutes The staff safety evaluation report (SER) for the South Texas Project GQA application was approved by the Commission.
industry Presentation i
Mr. Biff Bradley of the Nuclear Energy Institute (NE1) introduced the industry participants. Mr. Ben Mays, Texas Utilities (TU), and Ms.' Saragrace Knauf, Arizonia Power Supply (APS), presented pilot plant perspectives for IST. Mr. Thomas Hook, Southem Califomia Edison (SCE), presented pilot plant perspectives for TS. Mr.
Steven Rosen, Houston Power and Light Company (HP&L), presented the pilot plant perspectives for GQA.
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inservice Testing Mr. Mays discussed the initial goal to reduce the burden of inservice testing at Comanche Peak by focusing on those components important to safety. He discussed the initial approach using the Individual Plant Examination (IPE) and expert panel similar to that of the Maintenance Rule. He stated that components are categorized and tested according to high and low safety significance. Mr. Mays summarized the industry participation in this initiative and associated costs. He summarized the benefits in terms of risk insights and discussed the potential for new projects as more experience is gained.
Ms. Knauf discussed the initial pilot plant expectations and experience at the Palo Verde Nuclear Generating Station. She stated that initial expectations included using PRA as input for scoping, optimizing test intervals, and evaluating test effectiveness.
She stated that some of the issues associated with the Palo Verde pilot include PRA limitations, model updates, and reconciliation of issues associated with safety functions.
She stated that concerns associated with the SRP 3.9.7 and Regulatory Guide 1.175 include:
Additions of scope with no reduction in requirements.
Limited relaxation or burden reduction for LSSC test intervals.
Limited focus on HSSC for enhanced testing and corrective actions based on safety significance.
Technical Specifications Mr. Hook discussed the technical specification pilot application from the perspective of the Combustion Engineering Owners' Group (CEOG) and the San Onofre Nuclear Generating Station (SONGS). He discussed the mission of the PSA Working Group, the background and history of CEOG risk initiatives, support activities in PSA
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2/19 20/98 Minutes certification, standards development, and issue resolution. Mr. Hook stated that the pilot application process had been slow and that none of the requests for allowed outage time (AOT) extension had been approved. He addcd that the effort and review fees had also been greater than expected. Mr. Hook concluded that the CEOG Joint application is consistent with the proposed SRP Section and associated Regulatory Guide.
Graded Quality Assurance Mr Rosen reviewed the status of the GQA program at South Texas Project (STP). He noted that the staff had issued a safety evaluation report (SER) approving the pilot application on November 6,1997. He stated that the licensee was still evaluating the subject SER to consider procedural changes that may be necessary. He also discussed the projected staffing and structure to implement GQA.
i Mr. Rosen stated that a key feature in STP's program has been a major revision to the master equipment database which is nearing completion. Included in this database is a coding system for quality grade, GQA risk rank, and PSA risk rank.
l SUBCOMMITTEE COMMENTS. CONCERNS. AND RECOMMENDATIONS Dr. Apostolakis questioned why certain things were not modeled. He asked if they were not considered and what to do about it. The staff stated that the key word was
" screened out" rather than left out. Dr. Apostolakis suggested and the staff agreed to modify the guidance to clarify what is screened out and what is not modeled.
I Dr. Seale questioned why the staff had not endorsed industry guidance in the area of IST. The staff stated that some of the industry guidance was still under development and noted that only the risk categorization Code Cases had been approved by ASME.
The staff stated that the Code Cases were complete but had not been published.
Therefore, they cannot be formally endorsed.
Dr. Apostolakis questioned whether the PRAs would be upgraded, how PRA quality
. was being considered, and how licensees plan to treat uncertainty. Industry representatives stated that they intended to use the existing IPEs without significant revision, that the Owners' Groups were pursuing PSA certification, and that ASME was developing a standard for PRA quality.
The Subcommittee, staff, and industry representatives extensively discussed enhanced testing and performance monitoring for LSSCs. Dr. Seale questioned whether or not the staff expectations were onerous. Industry representatives stated that the level of i
Reliability &,PRA Subcommittee 7
2/19-20/98 Minutes testing and monitoring requested by the NRC was excessive for LSSCs. The staff stated that they had revised the guidance to clarify this issue but also noted that they expected licensees to conduct smarter testing through use of the guidance.
In the area of TS, Dr. Powers stated that there was a need to consider shutdown risk in the staffs guidance. Dr. Apostolakis agreed and stated that the guidance documents were too detailed. He suggested that examples be used. The staff agreed to consider providing examples and offered to reference additional guidance documents, as appropriate.
Dr. Apostolakis questioned why the regulatory guide on GQA focuses on safety functions rather than components. He stated that it would be desirable to perform analysis at the component level and provide importance measures. The staff stated that a large number of components under the QA program are not modeled in PRA.
The staff also stated that GQA is a support activity rather than a design process and noted that GQA should not add new requirements. Industry representatives stated that the expert panel would provide valuable decisionmaking input for judging matters in this area.
Dr. Kress suggested that a research project may be needed to relate quality and reliability for GQA. Dr. Powers commended the staff for the improvements made to Regulatory Guide 1.177 considering the difficuNy in quantifying GQA.
February 20.1998 OPENING REMARKS BY THE SUBCOMMITTEE CHAIRMAN Dr. Apostolakis convened the meeting at 8:30 a.m. He stated that the purpose of this meeting was to continue the Subcommittee's review the matters included in the Staff Requirements Memorandum dated October 16,1997, regarding elevation of core
. damage frequency (CDF) and possible revision to the Commission's Safety Goal Policy Statement. He stated that the Subcommittee would also review industry-initiated risk-informed pilots related to the development of full-scope probabilistic risk assessments (PRAs) and the use of quantitative health objectives (QHOs). Dr. Apostolakis stated that the Subcommittee may also consider staff and industry activities in the area of performance-based regulation.
Dr. Apostolakis stated that the Subcommittee had received no written comments or requests for time to make oral statements from members of the public.
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DISCUSSION OF AGENDA ITEMS NRC Staff Presentation Messrs. Thomas King, RES, and Gary Holahan, NRR discussed potential modifications to the Commission's Safety Goal Policy Statement. Mr Joseph Murphy, RES, discussed preliminary plans for an agency-wide program on performance-based approaches to regulation.
Safety Goal Policy Statement Messrs. ' King and Holahan discussed the staffs schedule and plan for revising the Safety Goal. Policy Statement including elevation of CDF to a fundamental safety goal, possible use of goals to define " adequate protection," and consideration of a policy statement on defense-in-depth. The staff summarized the pros and cons of elevating CDF in its Commission paper (SECY-97-208) dated September 12,1997. The staff also discussed the mission, vision, and goals for risk-informed regulation in the NRC Strategic Plan issued in September 1997. Significant points made during the discussion include:
Issues identified in the staffs risk-informed regulatory guidance development include: use of goals in plant-specific activities, possible definition of LERF
- (large, early release frequency), and the development of a methodology that gives consideration of uncertainties in risk-informed decisionmaking.
Concems noted since publication of the Policy Statement in 1986 include:
Neither of the present QHOs provides a quantitative measure of risk, Goals and QHOs are described in terms of health risks. However, no goal is established for land contamination.
QHOs are expressed in terms of average annual frequencies. There is, however, a question whether a specific goal on risk should be applied for temporary plant configurations.
The relationship between defense-in-depth, adequate protection, use of PRA, and Safety Goals need better definition.
Modification of the Policy Statement would be useful to provide a clear foundation for staff practices and to explain the relationship between high-level Safety Goals and other measures in practice (e.g., defense-in-depth, CDF, LERF, adequate protection, etc.).
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~ Possible drawbacks to revising the Policy Statement include the reallocation of valuable staff resources which could otherwise be spent reviewing risk-informed changes to the current licensing basis; a revised Policy Statement is not needed to resolve current safety issues at the plants; and a revised Policy Statement have possible unintended effects (i.e., increased regulatory burden) not yet anticipated.
The staff expects to submit its plan and approach to the Commission by March 31,1998. In this paper, the staff plans to inform the Commission that there is no urgency to revising the Policy Statement and to request approval for issuance to solicit public comment before recommending action to the Commission.
Performance-Based Regulation Mr. Murphy discussed the staff's draft Commission paper regarding plans to increase performance-based approaches in regulatory activities. Significant points made during the discussion include:
l The staff is proposing this to be an agency-wide initiative which considers reactors, waste, and materials program and licensing areas. Elements of the plan include: stakeholder input, data collection and analysis of information, screening of regulatory activities, and follow-up activities leading up to and
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including final resolution.
Performance-based regulation should focus on evaluating the acceptability of outcomes or results. Desired outcomes include: improved health and safety, cost effectiveness, efficiency, and increased confidence with non-prescriptive methods.
Examples of performance-based regulation include 10 CFR 20 (Standards for Protection Against Radiation),10 CFR Part 61 (for the high-level waste repository), Appendix J to 10 CFR 50 (for primary containment leakage testing),
and 10 CFR 55 (Operator' Licenses).
Industry Presentation Mr. Biff Bradley of the Nuclear Energy Institute provided an overview of the industry-initiated pilots and efforts related to PSA quality. Mr. Bob Christie of Performance Technology, Inc., provided detailed discussion of the risk-informed pilots (Task Zero) related to the development of full-scope probabilistic risk assessments (PRAs) and the use of QHOs. Mr. Steve Rosen, HP&L, discussed the STP pilot project in support of Task Zero.
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- Overview Mr. Bradley stated that the Boiling Water Reactor Owners' Group (BWROG) and other Owners' groups were pursing initiatives to certify the quality of PSAs. He added that the American Society of Mechanical Engineers (ASME) and American Nuclear Society were pursuing efforts to develop a Standard for PRA quality. He also noted that the -
industry and NRC staff were planning to conduct a workshop in April 1998 to discus PSA quality and related matters. Mr. Bradley stated that NEl was supporting the Task Zero effort and introduced Messrs. Christie and Rosen.
Task Zero Mr.' Christie discussed the pilot programs for hydrogen monitoring at Arkansas Nuclear One (ANO) and for hydrogen control at San Onofre. Significant points made during the discussion include:
Post-accident hydrogen sampling is a requirement of the TMl Action Plan per NUREG-0737.
The proposed change for hydrogen monitoring at ANO would allow for the delay of containment hydrogen sampling from 30 minutes to 90 minutes. This change is intended to limit the impact on operators during critical action time.
The proposed change for San Onofre would eliminate the Technical Specification requirement for hydrogen recombiners. This is a site-specific change for large, dry containments.
The pilot program approach is intended to identify regulations where there is no safety benefit and to sponsor change of those regulations. It is also intended to demonstrate the relative importance of equipment and human actions with respect to the QHOs using PRA.
.f Mr. Christie stated that the plants must push hard for change and that the NRC will not self-identify changes that can be made. He added that the NRC practice of regulating to the least common denominator burdens the industry and that the NRC believes it is necessary to regulate beyond adequate protection.
Mr. Christie concluded that the best requirements are those that define the criteria to be met but do not specify how to meet the criteria. He added that the utilities will commit resources to risk-informed regulation if Task Zero initiatives are approved by the NRC.
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Mr. Rosen discussed the Task Zero effort at STP for 10 second emergency diesel
. generator (EDG) start tests. Significant points made during the discussion include:
10 second start criteria places unnecessary stress on EDGs. Therefore, STP proposes to extend the start time requirement to'60 seconds.
The proposed change is based, in part, on the assumption that a design-basis loss of coolant accident concurrent loss of offsite power is an extremely rare and high consequence event (i.e., extremely unlikely).
SUBCOMMITTEE COMMENTS. CONCERNS. AND RECOMMENDATIONS The Committee, staff, and industry representetives extensively discussed the benefits and drawbacks of elevating CDF. Dr. Apostolakis expressed the view that preventing core damage was a fundamental goal because core damage was unacceptable even if there was no offsite release affecting the public. However, he noted that elevating the numerical value of CDF may not be the best approach because of possible misconceptions about the safety of plants. The staff stated that all plants exceeding the Commission's Safety Goals meet adequate protection in that they are in compliance with regulatory requirements. The staff also stated that the NRC has never quantitatively defined adequate protection. Dr. Apostolakis suggested that 1E-3 CDF/ reactor year appears to be a good numerical value.
The Committee and staff extensively discussed the benefits and drawbacks of revising the Policy Statement. The staff reiterated that there was no urgency to revising the Policy Statement but noted that there would be some benefit in establishing a revised statement to provide consistency and continuity to the risk-informed regulatory process.
Dr. Apostolakis questioned the issue of land contamination and how it fit into the Policy Statement. He suggested that it may be a mistake to be too ambitious in revise the Policy Statement to consider issues such as land contamination.
Drs. Kress and Fontana questioned why the Task Zero effort did not use the approach described in DG-1061 (now Regulatory Guide 1.174) general guidance for risk-informed regulation. Dr. Kress added that the industry-initiated approach appears to be in conflict with Regulatory Guide 1.174. Mr. Christie stated that they pursuing a more revolutionary approach and did not plan to use the subject Regulatory Guide. The staff stated that they were encouraging applicants to use Regulatory Guide 1.174 and Indicated that the reviews may prove to be resolved in a more timely manner if they are consistent with the guidance in Regulatory Guide 1.174.
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Drs. Powers and Apostolakis questioned the practicality of regulating to the QHOs. Mr.
Christie stated that the NRC was not seeking improvement in its regulations. The staff stated that the highest levels of NRC management are interested in the Performance Technology /NEl approach. However, they acknowledged that there may be some disagreement in the steps proposed by Mr. Christie in accomplishing proposed
. improvements.
The Subcommittee and staff extensively discussed the definition of performance-based regulation. Dr. Apostolakis stated that the Maintenance Rule (10 CFR 50.65) was not a performance-based regulation. The staff took exception with this view and offered clarification on how it might be considered performance-based.
STAFF AND INDUSTRY COMMITMENTS
~ Dr. Apostolakis offered a number of line-item improvements to the SRP Sections Regulatory Guides for IST, TS, and GQA. The staff agreed to make most changes suggested by Dr. Apostolakis and offered to consider others. Dr. Apostolakis requested and the staff agreed to provide updated versions of the SPR Sections and Regulatory Guides, incorporating the agreed upon changes, prior to the March 2-4,1998 ACRS meeting.
SUBCOMMITTEE DECISIONS The Subcommittee requested the staff to provide an overview discussion of the SRP Sections and associated Regulatory Guides during the. March 2-4,1998 ACRS meeting. The Subcommittee also requested the staff to discuss the priority and timing of a possible revision to the Commission's Safety Goal Policy Statement at the March 1998 meeting.
The Subcommittee recomroended that the full ACRS review the staffs draft Commission paper on performance-based regulation without additional review by the Subcommittee when the subject document is available.
FOLLOW-UP ACTIONS None.
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.p-Reliability &.PRA Subcommittee 13 2/19-20/98 Minutes -
SACKGRO.UND MATERIALS PROVIDED TO THE SUBCOMMITTEEi PRIOR TO THIS MEETING 1.
Subcommittee agenda.
- 2.
Subcommittee status report.
3.
ACRS letter report dated March 17,1997.
4.
EDO letter dated April 25,1997.
5.
ACRS report dated December 11,1997.
6.
EDO letter dated January 13,1998.
7.
Staff Requirements Memorandum dated May 28,1997.
8.
SECY-97-095, for risk-informed Technical Specifications 9.
Staff Requirements Memorandum dated October 30,1997.
10.
SECY-97-229, for risk-informed graded QA.
11.
Staff Requirements Memorandum dated October 16,1997.
12.
SECY-97-208, regarding elevation of CDF.
13.
Memorandum dated October 8,1997, from Commissioner Diaz, to John Larkins, regarding " Safety Goal" 14.
Memorandum dated July 2,1997, from S. Jackson, NRC Chairman to L Joseph Callan, EDO, regarding elevation of Core Damage Frequency of 10E-4 as a Fundamental Commission Goal Nota: Additional details of this meeting can be obtained from a transcript of this meeting available in the NRC Public Document Room,2120 L Street, N.W.
Washington, D.C. 20006, (202) 634-3274, or can be purchased from Ann Riley &
Associates, Ltd., (Court Reporters and Transcribers) 1250 l Street, NW, Suite 300, Washington, D.C. Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 842-0034.