ML20206S646
| ML20206S646 | |
| Person / Time | |
|---|---|
| Issue date: | 02/17/1999 |
| From: | Apostolakis G Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-3135, NUDOCS 9905210188 | |
| Download: ML20206S646 (8) | |
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Date issued: 2/17/99 CERTIFIED BY:
George Apostolakis -2/22/99 i
i ADVISORY COMMITTEE ON REACTOR SAFEGUARDS JOINT MEETING OF THE SUBCOMMITTEES ON RELIABILITY AND PROBABILISTIC RISK ASSESSMENT, PLANT OPERATIONS, AND ON REGULATORY POLICIES AND PRACTICES MEETING MINUTES - NOVEMBER 19-20,1998 ROCKVILLE, MARYLAND INTRODUCTION l
The ACRS Subcommittees on Reliability and Probabilistic Risk Assessment, Plant Operations, and on Regulatory Policies and Practices met on November 19-20,1998, at 11545 Rockville Pike, Rockville, MD, in Room T-2B3. The purpose of this meeting was to continue the Subcommittees' discussion of proposed options to make 10 CFR Part 50 and 10 CFR 50.59 (Changes, Tests and Experiments) risk-informed. The Subcommittees also reviewed proposed changes to the NRC assessment programs, including integrated review of assessment processes, Senior Management Meeting process, as well as risk-informed baseline inspection case studies and associated proposed changes to the inspection program, and other related initiatives.
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 5:00 p.m. on November 19, and adjoumed at 2:35 p.m. on November 20,1998.
ATTENDEES ACRS Members G. Apostolakis, Chairman R. Seale, Member J. Barton, Co-chairman W. Shack, Member T. Kress, Co-chairman G. Wallis, Member D. Miller, Member M. Markley, ACRS Staff Princioal NRC Seeakers P. Baranowsky, AEOD*
J. Flack, RES R. Barrett, NRR*
M. Johnson, NRR M. Caruso, NRR T. King, RES M. Cunningham, RES*
B. Mallett, Rll*
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M. Drouin, RES S. Mays, AEOD F. Gillespie, NRR
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RPRNPO/ Reg. Pol. & Proc. 11/19-20/98 I
Joint Subcts. Minutes PrincloalIndustry Sc6akers B. Bradley, NEl*
S. Floyd, NEl B. Christie, Performance Technology, Inc.
NRR Office of Nuclear Reactor Regulation RES Omco of Nuclear Regulatory Research AEOD Omco for Analysis and Evaluation of Operational Data i
Ril NRC Region ll-I NEl Nuclear Energy Institute There were approximately 7 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.
November 19.1998 OPENING REMARKS BY THE SUBCOMMITTEE CHAIRMAN Dr. Apostolskis convened the meeting at 8:30 a.m. He introduced Mr. Barton as Chairman of the Plant Operations Subcommittee and Dr. Kress as Chairman of the Regulatory Policies and Practices Subcommittee. He also introduced ACRS Members in attendance and stated that purpose of this meeting was to continue the Subcommittees' discussion of proposed options to make 10 CFR Part 50 and 10 CFR 50.59 (Changes, Tests and Experiments) risk-informed. He noted that the Subcommittees would also review proposed changes to the NRC assessment programs, including integrated review of assessment processes, Senior Management Meeting process, as well as risk-informed baseline inspection case studies and associated proposed changes to the inspection program, and other related initiatives.
Dr. Apostolakis stated that the Subcommittee had received no written comments or requests for time to make oral statements from members of the public.
DISCUSSION OF AGENDA ITEMS 10 CFR Part 50 NRC Presen181190 Messrs. Thomas King, RES, and Richard Barrett, NRR, led the discussions for the NRC staff.
Mr. Mark Cunningham, RES, provided supporting discussion. Messrs. Mark Rubin and Mark Caruso, NRR, also participated. They discussed the public workshop held in October 1998, objectives and elements of the proposed modification, options, policy and implementation
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Issues, and the role of the Nuclear Energy institute (NEl) Whole Plant Study. Significant points made during the presentation include:
e Broad areas of agreement among participants at the public workshop include: the objectives of proposed changes, preference for a phased approach with feedback of lessons-leamed at each phase, early emphasis on scope issues with later emphasis on specific rule modifications, and use of the Maintenance Rule as a pilot application.
o Objectives of the modification include: enhanced safety decisions, a framework for the NRC to use risk information, and increased licensee flexibility in licensing and operational areas.
e A major problem with making Part 50 risk-informed is the definition and requirements associated with the term " safety-related." Many components classified as safety-related are not risk significant and some risk-significant items are not safety-related.
o Potential areas for revising Part 50 include: the definition of safety-related, the l
maintenance rule, quality assurance requirements in Appendix B of 10 CFR 50, and 10 CFR 50.59. Additional changes should be considered in license amendments, enforcement, and performance assessment.
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- Policy issues include: mandatory versus voluntary changes; exemptions for pilot plants, and resultant changes to 10 CFR 50.12 (Specific exemptions) to better allow for the use of riskinformation, implementation issues include: selection of risk-metrics and acceptance guidelines, e
PRA quality, inclusion of requirements for non-safety-related SSCs; documentation related to FSARs and PRAs; and the need for revised guidance in SRP/RGs, inspection, enforcement, and performance assessment.
Preliminary staff conclusions on the NEl Whole Plant Study include: implementing a phased-approach to modifying Part 50 (change to process rules, definition and scope, and authority), use of pilots, and detailed direction later after Commission decision on the policy issues.
Industry Discussion Mr. Biff Bradley of the Nuclear Energy Institute (NEI) did not make a formal presentation but offered comments on the staff presentation. Mr. Bob Christie of Performance Technology, Inc.
also offered comments.
NEl suggested that the Maintenance Rule be used as a pilot for making 10 CFR Part 50 e
risk-informed. He also suggested that this approach could be implemented by the industry in a mandatory fashion. He stated that the current Maintenance rulemaking should be reissued for public comment to consider this approach.
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Mr. Christie stated that the industry is encouraged by the risk-informed pilot applications but noted that many licensees were discouraged by the slow progress of these pilots.
10 CFR 80.59 NRC Staff Presentation Messrs. Thomas King, Jack Guttmann, and Ms. Mary Drouin, RES, led the discussions for the NRC staff regarding options to make 10 CFR 50.5g risk-informed. Ms. Eileen McKenna, NRR, provided supporting discussion. The staff discussed the status of assessing options, a test case involving the South Texas Project essential cooling water (ECW) booster pump and associated evaluation of risk significance for the proposed change including comparison with existing 10 -
- CFR 50.5g requirements and possible treatment under a risk-informed 10 CFR 50.5g process.
Significant points made during the presentation include:
The draft options paper from RES is a work-in-progress for NRR to consider in going forward with proposed changes to 10 CFR 50.5g. The paper requires significant revision but is intended to highlight methods for integrating risk insights into regulatory decisionmaking for 10 CFR 50.5g.
Key areas for possible change include: the scope (related to FSAR and Technical e-Specifications) and parameters (related to determination of unrev'ewed safety questions). Ophons for modification include: no change, scope change only, parameter change only, and scope and parameter changes, o
Scope options may include: risk-significant structures, systems, and components (SSCs) within the facility or throughout the facility.
Parameter options may include: minimal increase in current 10 CFR 50.5g parameters, or possiDie replacement of current 10 CFR 50.5g parameters with risk measures (e.g.,
iRAW,4CDF, RAW /CDF per Maintenance Rule, ALERF, or Farmer Curves).
Removal of the South Texas Project ECW booster pump from safety-related status
' e would have no impact on risk for intamal events and would have negligible impact for extemal events. It would, however, constitate significant cost savings for the licensee as a nonsafety-related component.
November 20.1998 OPENING REMARKS BY THE SUBCOMMITTEE CHAIRMAN Mr. Barton convened the meeting at 8:30 a.m. He introduced Dr. Apostolakis as Chairman of the Reliability and Probabilistic Risk Assessment Subcommittee and Dr. Kress as Chairman of the Regulatory Policies and Practices Subcommittee. He also introduced ACRS Members in attendance and stated that purpose of this meeting was to review proposed changes to the NRC assessment programs, including integrated review of assessment processes, Senior c-e-e14
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Joint Subete. Minutes M'anagernent Meeting process, as well as risk-informed baseline inspection case studies and
- associated proposed changes to the inspection program, and other related initiatives.
Mr. Barton stated that the Subcommittee had received no written comments or requests for time to make oral statements from members of the public.
lnspection and Assessment Programs NRC Presentation Mr. Frank Gillespie, NRR, led the discussions for the NRC staff. Mr. Pat Baranowsky, AEOD, discussed the Framework and performance indicators (Pis) for the reactor oversight process.
Mr. Bruce Mallett, NRC Region ll, discussed the proposed improvements to the inspection Program. Dr. John Flack, RES, discussed efforts to make the baseline inspection risk-informed.
Mr. Michael Johnson, NRR, discussed the Assessment Program. Mr. Steve Mays, AEOD, discussed risk-based Pls, and Mr. Alan Madison, NRR, discussed the Transition Plan.
Significant points made during the presentation include:
The objectives of the proposed Framework is to develop a more objective (scrutable),
e risk-informed, performance-based approach to licensee performance assessment and related bases for inspection actions. Key tasks include: Framework development, Pl development with associated thresholds for action, inspection Program development including documentation of bases, and Assessment Program development.
e Task Groups were established to develop the Framework document, inspection and Assessment Programs. Each Task Group includes participation of both headquarters
- and regional NRC personnel.
The NRC has incorporated feedback from the industry and public through meetings with e
NEl and from the public workshop held on September 284ctober 1,1998.
The proposed inspection and assessment programs will rely heavily on Pis. However, there are limitations in what Pls can do in providing insights regarding licensee / plant performance. Inspection will be used to supplement evaluation in areas where Pls are incomplete (e.g., design, corrective action, etc.).
The proposed approach to risk-informed plant inspections includes development of plant-specific insights on risk, comparison with Individual Plan Examination (IPE) risk insights (NUREG-1560), identification of the top 10 risk sequences, development of a
. generic Prisk matrix," identification of attributes that drive contributors to risk, and development of justification to support the need for an inspection activity.
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' The Transition Plan requires a " change manager" in each regional office to assure effective implementation of the proposed regulatory approach.
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-J Joint Subete. Minutes SUBCOMMITTEE COMMENTS. CONCERNS. AND RECOMMENDATIONS 10 CFR Part 60 Dr. Apostolakis questioned the objectives for revising 10 CFR Part 50. The staff offered a list of attributes for consideration by the Subcommittee. After reviewing the subject list, Dr.
Apostolakis stated that defense-in-depth is a tool and not an objective. He noted an example might be to prevent initiating events. The staff agreed to consider clarifying the objectives.
Dr. Kress questioned the staffs approach to defining safety significance. Dr. Apostolakis noted that "important to safety" was not well defined. The staff stated that the key term is " adequate protection" and noted that NEl believes that there would be a significant benefit in redefining
' safety-related." The staff stated that they may not want to get into that level of detail in the proposed Commission paper. Dr. Apostolakis disagreed and reiterated the importance of defining the objectives. He noted that the proposed improvements to the inspection and assessment programs developed a hierarchy that was useful in defining objectives, j
comerstones of safety, etc. Dr. Apostolakis suggested the staff consider such an approach for proposed revision to 10 CFR Part 50. The staff stated that the intent of the Commission paper was to be a high-level " direction paper" rather than design or implementing paper.
Dr. Wallis questioned whether proposed changes to 10 CFR Part 50 could be voluntary. In particular, he questioned whether a deterministic population of licensees could continue to coexist with a new risk-informed population. He suggested that distinction may be diffuse and fuzzy if the NRC solicits risk insights in its requests for additionalinformation (RAls). Dr. Wallis suggested that the process be better defined to clarify how a voluntary approach might work, in practice.
The Subcommittees discussed NEl's recommendation that the Maintenance Rule be used as a pilot for making 10 CFR Part 50 risk-informed. Dr. Apostolakis questioned whether this idea was supported by most utilities. NEl representatives stated that the industry task force supports this proposal. NEl suggested that this could also be pursued in a mandatory fashion. The staff reiterated agreement that the Maintenance Rule could serve as a pilot for making Part 50 risk-informed. However, the staff acknowledged that the current approach to revising the Maintenance Rule does not incorporate the NEl proposal regarding this matter.
10 CFR 60.69 Dr. Apostolakis questioned whether 10 CFR 50.5g was intended to address Severe Accidents.
The staff confirmed that it was not. Dr. Apostolakis suggested that this presents a problem because core damage frequency (CDF) is likely to dominate all other risk measures. Drs.
Apostolakis and Kress suggested that frequency-consequence curves may provide a better approach to risk-informed decisionmaking related to 10 CFR 50.5g. Dr. Apostolskis also suggested that the staff drop its proposed use of risk achievement worth (delta RAW). The staff agreed to consider these suggestions.
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-7 11/19 20/98 Joint Subete. Minutes Related to the staffs example of the South Texas Project (STP) essential cooling water (ECW) booster pump, Dr. Wallis questioned where the enhanced safety decision lies for the proposed scenario. Dr. Wallis suggested that the licensee's analysis may not be sufficient for intermediate floods and associated debris generation. The Subcommittee suggested that this example may be better suited as an example of making Part 50 risk-informed than 10 CFR 50.5g. The staff agreed but noted that it was realized as a result of a 10 CFR 50.59 safety evaluation associated with graded quality assurance.
Insnection and Assessment Programs Dr. Apostolakis questioned the basis for items considered for measures as performance indicators (Pis). In particular, he questioned whether the proposed items were selected based on an evaluation (i.e., risk / safety studies) or merely based on the availability of information. The staff stated that the current set of indicators were based largely on the experience of participants on the Task Force but noted that a research contract with the Idaho National Engineering and Environmental Laboratory to evaluate the development of risk-based Pls had been initiated.
Dr. Apostolakis questioned the planned use of PI thresholds for regulatory decision / action and asked when the current risk status of the plant was considered. Dr. Apostolakis suggested that core damage frequency (CDF) was not the right measure because it is insensitive to small changes and tends to dominate the risk analysis. The staff reiterated expectations regarding the INEEL contract providing insights on how to property integrate risk. The staff acknowledged that CDF cou!d be problematic.
Mr. Barton and Dr. Seale questioned the Transition Plan for implementing the staffs proposed approach. The staN stated that the PIS, proposed thresholds for decisionmaking, and integration of risk insights wouW require a certain level of verification and validation. The staN stated that they were working closely with the NEl to perform correlation studies to assess the approach and associated measures.
STAFF AND INDUSTRY COMMITMENTS Dr. Apostolakis suggested that the staff replace the use of " Farmer Curves" with
- frequency-consequence curves." The staff agreed to adopt this suggestion.
' Dr. Seale questioned whether the staff plans to conduct pilote to qualify / validate the proposed inspection and assessment processes. The staff agreed to consider this suggestion and noted plans to conduct bench marking stuoies both within the nuclear power industry and in other regulated areas (e.g., Federal Aviation Administration, Environmental Protection Agency, etc.).
SUBCOMMITTEE DECISIONS Because the staff does not expect to provide the proposed Commission paper on the proposed improvements to t' e NRC inspection and assessment processes until late December 1998, a n
Subcommittee meeting was tentatively scheduled for January 26,1998, with full ACRS review at
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the February 4-6,1999 meeting. However, the Subcommittee decided to recommend that the Committee prepara en interim report to the Commission during the December 3-6,1998 ACRS meeting.
FOLLOW-UP ACTIONS.
The Subcommittee requested a copy of NEl's latest Pis. NEl subsequently informed the ACRS staff that it had stopped work on developing Pls pending a Commission decision on the proposed improvements to the NRC inspection and assessment programs. NEl stated that they were in agreement with the Pls proposed by the 6taff.
BACKGROUND MATERIALS PROVIDED TO THE SUBCOMMITTEE PRIOR TO TlilS plEETING 1.
Subcommittee agenda.
2.
Subcommittee status report.
3.
Memorandum dated November 16,1998, from Noel Dudley, ACRS Staff, to ACRS Members,
Subject:
Meeting of the Committee to Review Generic Requirements (CRGR)
Concoming Options for Modifying 10 CFR Part 50 to be Risk-informed.
4.
' Staff Requirements Memorandum dated September 25,1998, from John C. Hoyle, Secretary, NRC, to L. Joseph Callan, EDO,
Subject:
5.
Report dated July 16,1998, from R. L. Seale, Chairman, ACRS, to Shirley Ann Jackson, Chairman, NRC,
Subject:
Proposed Revisions to 10 CFR 50.59 (Changes, Tests and Experiments).
6.
Staff Requirements Memorandum dated June 30,1998, from John C. Hoyle, Secretary, NRC, to L. Joseph Callan, EDO,
Subject:
Status of the integrated Review of the NRC Assessment Process for Operating Commercial Nuclear Reactors.
7.
Report dated March 13,1998, from R.L. Seale, Chairman, ACRS, to Shirley Ann Jackson, Chairman, NRC,
Subject:
Proposed improvements to the Senior Management Meeting Process.
- 8. -
Handouts and transcript for November 2,1998 Commission briefing, on Reactor Oversight Process improvements: Inspection Assessment, and Enforcement 9.
Inspection Manual Chapter 2515, Operating Reactors, Appendix C, Use of insights Derived from Probabilistic Risk Assessment (PRA), including Attachments 1 and 2.
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Ngta Additional details of this meeting can be obtained from a transcript of this meeting I
available in the NRC Public Document Room,2120 L Street, N.W. Washington, D.C.
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20009, (202) 634-3274, or can be purchased from Ann Riley & Associates, Ltd., (Court 2
Reporters and Transcribers) 1250 l Street, NW, Suite 300, Washington, D.C. Rhode l
Island Avenue, N.W. Washington, D.C. 20005 (202) 842-0034.
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