ML20211K182
| ML20211K182 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/1999 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-99-211, SECY-99-211-R, NUDOCS 9909070119 | |
| Download: ML20211K182 (38) | |
Text
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PO L ICY ISSUE August 18, 1999 gggg SECY-99-211 REISSUED FOR: The Commissioners FROM: William D. Travers Executive Director for Operations
SUBJECT:
STATUS REPORT ON THE PROBABILISTIC RISK ASSES $ MENT IMPLEMENTATION PLAN PURPOSE:
To report the status of the Probabilistic Risk Assessment (PRA) Implementation Plan (PIP) for the period January 1 to June 30,1999. I BACKGROUND:
In a memorandum dated January 3,1996, from the Executive Director for Operations to the Chairman, the staff committed to submitting quarterly reports on the status of its development of risk-informed standards and guidance. Previous progress reports were sent to the Commission quarterly beginning on March 26,1996, with most recent update provided as SECY-99-082, dated Mqrch 18,1999, covering the period July 1 to Decernber 30,1998.
- Because of the need to meet high priority staff commitments to actions identified in the Chairman's tasking memorandum, this update covers the period from January 1,1999 to June 30,1999. This update also reflects recent staff reorganizations, including the assimilation of AEOD work into RES, NRR and HR.
DISCUSSION:
During the reporting period, substantial progress has been made on the items listed in the PIP.
Attachment 1 provides a discussion of the key highlights of staff work accomplished during the reporting period.
/
l Most notable among these accomplishments are (1) initiation of work in response to the SRMs on SECY 98-300 and SECY 99-100 directed towards risk-informing reactor and non-reactor f\ ,
regulations, (2) initiation of the pilot test of the risk-informed plant oversight process,
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Ashok C. Thadani, RES FIlf ,} S J .'
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The Commissioners 2 1
- (3) completion of twelve IPEEE reviews, (4) initiation of Phase 2 of the PRA Standard development, (5) initiation of work to develop risk-based performance indicators and (6) modification of the. enforcement policy to be more risk-informed.
Additional detail on specific milestones and schedules is provided in the Tables (Attachment 2).
Over the reporting period, these have been interactions with ACRS on the above topics and also on research work related to PRA and risk-informed regulation. ACRS, in the recently issued l NUREG-1635, Vol. 2, " Review and Evaluation of the Nuclear Regulatory Commission Safety ,
l Research Program," provided several recommendations related to the research work. The staff
' l will be reviewing these recommendations and responding to ACRS in the near future.
During the reporting period, the General Accounting Office (GAO) issued a report on NRC's risk-informed regulation efforts (GAO/RCED-99-95). In the March 1999 report, the GAO made ;
the following recommendation:
4 To help ensure the safe operation of plants and the continued protection of
- public health and safety in a competitive environment, we recommend that the Commissioners of NRC direct the staff to develop a comprehensive strategy that includes but is not limited to objectives, goals, activities, and time frames for the -
transition to risk-informed regulation; specifies how the Commission expects to define the scope and implementation of risk-informed regulation; and identifies the manner in which it expects to continue the free exchange of operational l information necessary to improve the quality and reliability of risk assessments.
The Chairman responded to this recommendation in a June 18,1999, letter to Senator Fred .
Thompson and others indicating that the staff is developing, for Commission approval, a-I document describing the agency's strategy for risk-informed regulation that will specify the scope and approach for implementation. Consistent with the Chairman's response, the staff intends to pursue this recommendation and, if the Commission agrees, plans to revise the PIP to include a strategy for risk-informing our approach to regulation. This strategy will provided a clear link to the strategic goals, performance goals, and strategies of NRC's overall strategic plan. The intent is to have the strategy provide a vision and a road map as to wherc 'he agency is planning to go in risk-informing its requirements and activities, including how it ir decided whether or not to risk-inform an activity. An outline of this strategy is being developed and will be provided to the Commission for review in mid-September. Also, due to the longer term nature of many of the activities which will be addressed in the PIP, the staff intends to change the frequency of update of the PIP from quarterly to semiannually unless the Commission directs otherwise. Therefore, the next PIP will cover the period of July 1999 through December l 1999.
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l ThI Commi2sion:rs 3 The staff's work to risk-inform the reactor and non-reactor regulations and to develop a strategy for risk-informed regulation is evolving at a rapid pace. While these topics are discussed only briefly in this paper, the staff expects that the presentations at the planned PIP Commission l briefing will be more substantive and will include a discussion of the approaches being taken, '
work done to date, and potential policy, implementation and technical issues.
COORDINATION The Office of the General Counsel has reviewed this paper and has no legal objections.
^ -
I William D. dvers
/ Executive Director
\ for Operations Attachments: As stated DISTRIBUTION:
Commissioners OGC OCAA OIG OPA OCA ACRS CIO CFO EDO REGIONS SECY u_
Att.1-1 ATTACHMENT 1 SIGNIFICANT STAFF ACCOMPLISHMENTS Section 1: Reactor Reaulation 1.1 Standard Review Plans for Risk-Informed Regulation The staff's annual review of Regulatory Guide (RG) 1.174 and Standard Review Plan (SRP)
Chapter 19 was completed and provided to the Commission by memorandum dated June 30, 1999. As discussed in the memorandum, the RG and SRP chapter should be updated beginning in early CY2000, and is expected to include revisions to endorse the ASME standard on PRA quality, expand the guidance for shutdown conditions and discuss the use of seismic margins methods.
The first annual reviews of the application-specific RGs and SRPs for in-service testing, technical specifications, and graded quality assurance are currently underway. These are scheduled to be provided to the Commission in August 1999.
1.2 Pilot Applications for Risk-informed Regulatory initiatives Inservice Testina The staff recently completed its review of a limited-scope risk-informed inservice testing (RI-lST) relief request from the South Texas Project licensee. That review was begun in December 1998. The licensee proposed to extend the test intervals for twelve containment isolation check valves in each unit's component cooling water and safety injection system from the current 18-month interval to an Appendix J Option B test interval (i.e., not to exceed 5 years). The staff completed its safety evaluation of this risk-informed proposal in July 1999.
The staff is continuing its review of a full-scope RI-IST Program for the San Onofre Nuclear Generating Station (SONGS). That review was started in January 1999. This proposal is similar to the approved Comanche Peak RI-IST pilot plant program and involves test interval extensions for up to 6 years for safety-related pumps and valves of low safety significance. A request for ariditional information was sent to the SONGS licensee on April 20,1999. The staff received a ruponse from the licensee on June 17,1999. The staff expects to complete its evaluation of the San Onofre RI-IST Program by October 1999.
Inservice insoections A request from ANO 1 for a risk-informed inservice inspection (RI-ISI) program change is currently under review and scheduled to be completed by the end of August 1999.
Browns Ferry Unit 2 submitted an application in October 1998 which would combine the intergranular stress corrosion cracking augmented program inspections with the ASME Section XI inspection. In conjunction with this application, the staff is working together with industry to determine how, and if, the augmented programs can be included within the risk-informed program. However, the Tennessee Valley Authority (TVA) recently submitted an application for the Browns Ferry Unit 3 RI-ISI program and requested that the NRC shift its focus from the Unit
Att.1-2 2 RI-ISI program submittal to the Unit 3 program submittal. In light of this request, the staff has suspended its review of the Unit 2 submittal and initiated review of the Unit 3 submittal. The
. Unit 3 review is scheduled to be completed by December 31,1999.
l A topical report describing the Electric Power Research Institute (EPRI) methodology for RI-ISI l was submitted to the staff on April 5,1999. On May 5,1999, EPRI and the staff discussed the
- methodology with the ACRS. The staff is currently working on the safety evaluation report which is scheduled to be completed by. October 31,1999.
, .On September 28,1998, the staff completed its review and issued its safety evaluation report regarding the ANO, units 1&2 request for relief from the staff position in NUREG-0737 for ;
hydrogen monitoring. This request had been made as a part of " Task Zero" of the Risk-Informed, Performance-Based Pilot Program ("Whole Plant Study") proposed by NEl. In ;
regards to that request, the staff is continuing its review of the San Onofre request to remove l hydrogen recombiners from the scope of the regulations. The staff expects to complete this review by the end of July 1999.
1 1.3 Inspections and Assessments The staff is coritinuing its work reported to the Commission in SECY-99-007 and SECY l 007A to develop and pilot test a risk-informed licensee oversight process, including inspection, j performance assessment, and enforcement. The staff continues to work toward a November 1- 1999 target date for the completion of the pilot process and an April 2000 target date for full implementation of the revised process at all plants.
The last two of the ten Senior Reactor Analysts have completed their training and rotational assignments and have submitted their certification requests for permanent appointment to their positions.
The staff met with the Committee for Review of Generic Requirements (CRGR) on December 8,1998 to discuss the proposed inspection procedure (IP) for risk-informed graded quality assurance (RI-GQA) programs. The CRGR identified several concems with the proposed IP, and ultimately concluded that as proposed it should not.be used. On the basis of ,
CRGR's feedback, the staff revised the IP and forwarded it to CRGR for final approval on June 25,1999. The staff expects to issue the IP by the end of July.
1.10 IPE Follow-up Activities On June 8,1999, the Commission issued a Staff Requirements Memorandum (SRM) regarding risk-informed revisions to 10 CFR Part 50. In the SRM, the Commission approved staff's recommended coursa of action for making Part 50 more risk-informed. The staff believes the goals and objectives of IPE follow-up activities are closely related to the Part 50 work.
Consequently, the staff is currently working with the industry groups to develop IPE follow-up activities that are complementary with the risk-informed Part 50 process. Details of these activities will be incorporated in the PIP when they are finalized.
1.11 Risk-Informing Part 50 On June 8,1999, the Commission issued a SRM on SECY-98-300 regarding risk-informed revisions to 10 CFR Part 50. In the SRM, the Commission approved staff's recommended course of action for making Part 50 more risk-informed, including, (1) establishing risk-informed 6
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4 Att.1-3 definitions for " safety-related" and "important to safety" systems, structures and components .
. (SSCs) and using the definitions to modify the scope of SSCs for those sections of Part 50 requiring special treatment, (2) changing the existing scope of the Maintenance Rule (50.65) to conform to new risk-informed definitions for " safety-related" and "important to safety" SSCs, and (3) performing a study to determine how best to proceed with risk-informing the remaining 1 sections of Part 50 to be performed by RES. The staff is currently preparing plans and ,
schedules to implement these recommendations, including a rulemaking plan for items 1 and 2 !
listed above. These plans include public meetings with our stakeholders. These plans and )
schedules will be transmitted to the Commission in October 1999. :
Section 2: Reactor Safety Research 2.1 Regulatory Guides
]
As stated in Section 1.1, the staffs annual review of Regulatory Guide (RG) 1.174 and Standard Review Plan (SRP) Chapter 19 was completed and provided to the Commission by memorandum dated June 30,1999.
The first annual' reviews of the application-specific RGs and SRPs for in-service testing, technical specifications, and graded quality assurance are currently underway. These are scheduled to be provided to the Commission in August 1999.
2.4 Methods Development and Demonstration Work continued on. developing improved fire risk assessment methods, tools, and data. These improvements will support more robust assessments in an area of large uncertainty and will support NRC's efforts to make increased use of risk insights in fire protection applications. The topics addressed include circuit failure analysis, fire modeling, model uncertainties, historical event analysis, and turbine building fire analysis. Data obtained from NRC-sponsored fire experiments were processed and published in CD/ ROM form; the CD/ ROMS were distributed in June 1999. A plan for the overall NRC fire risk research program was developed, consistent with the material presented to the ACRS Subcommittee on Fire Protection in January 1999.
The plan was widely distributed in June 1999; numerous presentations of the plan were also made in a variety of forums, e.g., an industry sponsored conference, the NRC Regulatory information Conference, a meeting with EPRI concoming cooperation in fire research, an intemational workshop on fire risk assessment, and meetings with intemational members of the NRC-led Intemational Cooperative PRA Research Program - COOPRA. The staff's plan has been well received to date. Further interactions with stakeholders are planned to ensure proper direction to the program, including a November 1999 briefing of ACRS. The Commission will be informed of the results of these interactions in the next PIP update.
2.5 IPE and IPEEE Reviews The staff completed its review of an additional 12 IPEEE submittals (bringing the total to 22) and issued the SERs for these plants. The staff concluded that all these submittals met the intent of Supplement 4 to GL 88-20. The staff completed an assessment of the impact of Appendix R fire protection exemptions on fire risk. Nine plants were selected for review based on the relatively high core damage frequencies reported in the licensees' IPEEE fire analyses.
The results of this limited scope study, which were provided to Commission, showed that a large majority (about 85 percent) of the 169 Appendix R exemptions that were examined had a small or very small impact on plant risk. The risk significance of 22 of the 169 issues was not
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Att.1-4 able to be determined, given current fire risk insights and methods. As a follow-up to this study, the staff will examine the analysis in more detail for the 3 plants where exemptions appear to be risk-significant including modeling assumptions and supporting data. If initial results of the risk significance of exemptions in these plants are confirmed, the staff will determine if a plant-specific backfit is justified. To reduce the potential for similar circumstances in the future, the staff intends to encourage licensees to consider the risk significance of potential exemption requests before submittal to NRC.
In addition, the staff reviewed industry's responses to the staff's generic questions on EPRI's Fire PRA implementation Guide (FPRAIG) and concluded that the generic responses are
. acceptable. Based on this effort, EPRI will issue supplemental guidance to the FPRAIG and will provide recommendations to licensees that they can use to prepare plant-specific responses to requests for additional information (RAls) on their fire IPEEEs. Having acceptable industry responses to the generic RAls is a significant milestone leading to completion of the IPEEE program. Previously reported delays in completing the generic response had significantly delayed completion of the IPEEE program.
The iPE review program has been completed; the final SER, on the Browns Ferry 3 IPE, was issued to the licensee in May of 1999.
2.6 Reactor Generic lasues Program During this period, Generic issues B-61 (Allowable ECCS Equipment Outage Periods) and GI-165 (Spring Actuated Safety and Relief Valves) were resolved with no new requirements identified. Generic issue 107 (Main Transformer Failure) was re-prioritized and dropped from the list of outstanding safety issues based on staff reexamination of its risk significance.
2.8 Standards Development ASME received numerous comments from the public on their draft " Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications." ASME is currently, evaluating the comments and updating the draft based on these comments and plans on issuing a final revision for consensus review in December 1999. Based on the work done to date, the staff is concemed that this schedule may not be met; however, the staff is continuing to work closely with the ASME in the timely development of this standard and in the resolution of outstanding technicalissues. This ASME standard is Phase 1 which only covers intemal events (excluding fire) at full power and a Level 1 and limited Level 2 PRA. ANS has initiated Phase 2 which will include low power shutdown and seismic.
2.9 Low Power and Shutdown in early calendar year 1999, the staff initiated work to evaluate the current state-of-technology of low power and shutdown (LPSD) risk assessment and to formulate the need for supplementing or updating RG 1,174 which supports risk-informed regulatory decision making.
The program involves the review of lessons leamed from previous NRC studies and from domestic and intemational work on LPSD risk; the insights will be summarized in a
" perspectives" report. On the basis of these insights the staff will develop a program plan for the continuation of this program consistent with Commission guidance. The plan will focus on ,
methods and tools needed to provide the technical basis for supplementing or updating ]
RG 1.174, and for developing a consensus standard for risk-informed regulatory applications related to LPSD operations. The staff will issue its perspectives report in December 1999.
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Att.1-5
( 2.10 - Safety Goal The staff is continuing to study possible modifications to the Safety Goal Policy Statement. As part of this process, in SECY-99-191, the staff has summarized the status of its assessment of the eleven possible safety goal modifications and has requested authorization to proceed with a study of the feasibility of developing a safety policy that would set forth those broad safety principles that apply to all agency safety activities. Because of the complexity of the issues involved, (i.e., the need to ensure consistency between the broad' principles, the Safety Goal Policy Statement, activities ongoing in the PRA implementation Plan, and the need for extensive ACRS/ACNW and stakeholder involvement), the completion date has been changed to March 2000.
2.11 Regulatory Effectiveness The staff has uridertaken an evaluation of the effectiveness of the station blackout rule. The preliminary report of this evaluation will be provided to the Commission by the end of FY99. 1 The approach being used is to compare actual operating experience (risk and performance parameters) with staff estimates of costs and risk reduction developed at the time the rule was initially prepared. The effectiveness of two other rules will be assessed in FY 2000 and the methods employed will be documented as a process or guidance document in FY2001, 2.12 Review of Agency Programs and Processes ;
As discussed in Section 1.11, the Commission issued an SRM on SECY-98-300, regarding risk-informed modifications for 10CFR 50. The SRM directed the RES staff to perform (as recommended), a study (Option 3) to identify specific reactor regulations which merit modification to make them more risk-informed. The plan for this study will be transmitted to the Commission in October 1999.
The PRA Steering Committee met on 3 occasions between January 1,1999, and June 30, 1999. Guidance to the staff was provided on items such as the following:
- Approach for responding to the SRM on SECY-98-300 e Framework for risk-informing NMSS regulatory process
- Development of an overall strategy for risk-informed regulation 2.13 Rick-Based Trenos and Pattems Analysis The results, findings, conclusions, and information contained in the studies noted below are intended to support several risk-informed regulatory activities. These reports can provide information on relevant operating experience that can be used to enhance plant inspections of risk-important systems. In addition, this information can be used to support staff technical reviews of proposed license amendments, including risk-informed applications. This work will also be used in the development of risk-based performance indicators.
l The report " Rates of initiating Events at U.S. Nuclear Power Plants: 1987-1995" (NUREG/CR- !
5750) was issued in February 1999. This is the first major analysis and update of initiating i
. Att.1-6 event frequency estimates since 1985. Also, this report is the first significant effort to update LOCA pipe break frequencies since 1975 when WASH-1400, " Reactor Safety Study / was issued.
The reports " Reliability Study: Westinghouse Reactor Protection System,1984-1995" (NUREG/CR-5500, Vol. 2) and " Reliability Study: General Electric Reactor Protection System, 1984-1995" (NUREG/CR-5500, Vol. 3) were issued in April 1999 and May 1999 respectively.
These were the first systematic evaluations of reactor protection system (RPS) performance since the ATWS rulemaking in 1986. -
An assessment of the risk associated with the licensing issues identified at D. C Cook Units 1 and 2 was started. The issues are being analyzed using the accident sequence precursor (ASP) program methods. Information contained in inspection reports, LERs, and the licensee's self assessment reports is being used to identify issues that affect core damage frequency (CDF) and containment performance. The assessment is being coordinated with NRR and Region 111. Interim findings will be presented to the licensee in August 1999, and a final report will be published in April 2000.
The report " Development and Findings of the Performance Trending Methodology" (NUREG/CR-6618) was issued in April 1999. It summarizes the work that was done to develop a performance trend methodology that was used as one factor to identify plants as subjects for Senior Management Meeting (SMM) discussions.
2.14 Accident Sequence Precursor (ASP) Program Preliminary analysis of 1998 events is continuing. Four 1998 events were identified asi potential severe accident precursors and preliminary staff analyses were transmitted to the respective licensees for review and comment. These events were: (a) the tornado-caused loss of offsite power at Davis-Besse in June 1998, (b) an inoperable sump recirculation valve at San Onofre in February 1998, (c) the long-term unavailability of an EDG at Byron in September 1998, and (d) problems with the RWST and containment emergency sump level instrumentation at Oconee in February 1998.
As a result of implementation of the new reactor oversight process, questions raised by some regions about the QA review of the Level 1 Revision 3 models, and the completion of six PWR and two BWR prototype LERF models, the staff is reassessing the direction of the ASP model development (SPAR) effort. Reassessment of the SPAR model development program (including Level 1 Revision 3 LERF, SD/LP, and extemal events) will be carried out over the next 2 months to ensure that this program will adequately support the reactor oversight process, regional needs, and the ASP program in an efficient and practical manner.
2.16 Risk-Based Performance Indicators RES has a program underway to develop (in FY2000) risk-based performance indicators in support of the reactor plant oversight process. A presentation on the RBPI program was made to the full ACRS on June 2,1999. The presentation included discussion of the need for RBPIs in the new regulatory oversight process and the candidate indicators proposed for trail application. Comments were received in the ACRS letter of June 10,1999, and are being reviewed by staff.
Att.1-7 *
- 2.17 - Operating Experience Data The Reliability and Availability Data System (RADS) database system prototype was reviewed in January 1999 and the first data upload from the industry's Equipment Perfonnance and
- Information Exchange (EPIX) database was successfully performed in May 1999. EPIX is an ,
industry database which contains information on the demands, operating hours, and failures of I components in nuclear power plants. . Staff access to the industry's EPIX database was l obtained in accordance with the SRM directions regarding the voluntary attemative to the, Reliability and Availability Data rule. ;
A Subcommittee of the EPIX Ad Hoc Working Group at an April 1999 meeting recommended that the EPIX vision should be to make EPIX the industry's single, common reporting system for all performance indicators (including availability and reliability data) and equipment failure information. This recommendation was endorsed by a meeting of the full EPIX Ad Hoc Group on May 27,1999, and approved by INPC 8 Industry Review Group on June 2,1999. At the April and May meetings, NRC recommended that EPIX include additional data on demands and planned unavailability. These improvements were discussed at a meeting with industry in July 1999. Recommendations from that meeting will be addressed at the EPIX Ad Hoc Group subcommittee meeting in October. The staff will continue to pursue any other issues per the SRM direction to " work with industry to address shortfalls and limitations in the data."
Section 3: Staff Trainina The 2-week PRA Technology and Regulatory Perspectives course (P-111) continues to be presented each quarter. In FY 1999, courses have been held in Regions I, ll and ill and a course is planned for Region IV in October. FY 2000 course presentations will be at the Technical Training Center. Sufficient cou ses are planned to meet NRR's goal of having all resident inspectors and senior resident inspectors complete the course by the end of FY 2000 and to have all qualified reactor operations inspectors complete the course by the end of FY 2001.
The 4-day PRA Basics for Regulatory Applications course (P-105) and the 3-day PRA for Technical Managers course (P-107) have continued to be offered as necessary to meet staff needs. The P-105 course has beer. presented 7 times, and the P-107 course 3 times.
Advanced user courses such as Probability and Statistics for PRA, SAPHIRE Basics and Advanced SAPHIRE have been presented as needed. I The PRA course contractor, INEEL, will soon start development of a new PRA course manual that will provide a reference document for courses such as PRA Basics for Regulatory Applications, PRA for Technical Managers, and PRA Technology and Regulatory Perspectives.
Completion of the manualis planned for early 2000.
The PRA Training Focus Group (PTFG) has completed the work for which it was established. 1 It provided excellent advice as new courses were developed and provided in support of the PRA implementation Plan. User groups were identified and courses developed to provide the staff with the tools necessary to support the agency's commitment to risk-informed regulation. Since the PRA curriculum has matured, future revisions to the PRA curriculum will be coordinated directly with the program offices and specific users.
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Sufficient PRA courses will continue to be scheduled to meet identified needs for Senior l Reactor Analysts training, other advanced users, and general staff.
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Section 4: Nuclear Materials. Low Level Waste Safety and Safeauards Reaulation 4.4 Risk Assessment of Material Uses in March,1999, the staff informed the Commission of the methodology that had been developed under NRC sponsorship for assessing the risk associated with the many industrial and medical uses of nuclear material that are regulated by NRC and its Agreement States (SECY-99-062). A draft report was issued for technical peer review and public comment in July,1999.
4.5 Use of PRA in Regulating Nuclear Materials in March,1999, the staff completed the scoping effort for developing a framework for risk-informed regulation in NMSS. In SECY-99-100, the staff reported the results of this effort and also proposed both a framework and an approach for its implementation to the Commission. The Commission approved the framework and the staff's proposed implementation approach in its SRM of June 28,1999. As proposed in SECY-99-100, the staff will track progress toward implementation of the framework in the PRA implementation Pian. Thus, the staff will develop milestones for implementation (based on Attachment 4 to SECY-99-100) to be included in the next update.
4.6 Risk-informed Regulation of Fuel Cycle Facilities Significant progress has been accomplished to develop a risk-informed, performance-based proposed revision to 10 CFR Part 70 in an effort to improve the safety at fuel j cycle facilities while concurrently optimizing the regulatory burden on both the NRC and '
its licensees. The Commission approved the proposed revisions in July 1999, which 9
' culminated a substantial staff effort and outreach program that included extensive coordination with interested stakeholders. The proposed changes to the regulation require a systematic and integrated review of potetial accidents while allowing flexibility in terms of specific preventative and mitigative measures. Staff continues to work with industry and other stakeholders to resolve comments conceming the associated Standard Review Plan (SRP). Staff intends to issue a draft version of the SRP, incorporating a!! resolved comments up to that point, when the proposed rule is published for public comment.
4.7 Risk-Based Fuel Cycle Safety inspection Program Revision Staff has initiated a revision of the fuel cycle safety inspection program to optimize the
- regulatory burden while ensuring safe operations. The staff's initiative is further described in SECY 99-188," Evaluation and Proposed Revision of the Nuclear Fuel Cycle Facility Safety inspection Program," which was issued in July. A task force was established to develop performance indicators, and identify available risk insights, to assess facility performance. A public meeting with stakeholders is scheduled for September 1999.
Att.1-9 4.8 Pilot Applications for Risk-informed Regulatory initiatives for Fuel Cycle Facilities Staff initiated the development of a pilot program for altemate disposition of Severity 4 Level IV safety violations at the two Gaseous Diffusion Plants and other fuel cycle facility licensees with NRC approved corrective action programs. This program will allow lower risk issues to be dispositioned by the licensees through the corrective action programs.
Section 5: Hich-Level Nuclear Waste Reaulation 5.1 Proposed regulations for disposal of high-level radioactive wastes in a proposed geological repository at Yucca Mountain, Nevada were issued for comment in February 1999 and the comment period closed on June 30,1999. The staff continued utilizing its performance assessment to identify and address technical !ssues and develop review guidance, in response to a request from the Commission, the staff developed SECY 99-186, outlining its plans for reassessing its regulatory approach toward defining and ensuring a defense-in-depth philosophy is applied to the repository review. In finalizing the regulatory requirements (Part 63) and review guidance the staff will incorporate the Commission's defense-in-depth philosophy as described in the White Paper on Risk-informed and Performance Based Regulation dated March 1,1999.
Section 6: Enforcement The Office of Enforcement (OE) held a number of meetings with the various stakeholders that discussed the utilization of risk insights in the enforcement process. In addition, OE continues to participate in development of the new power reactor oversight process. The result of these activities was a recommendation to the Commission in SECY-99-087 that the enforcement policy be made more explicitly risk-informed by specifically stating that risk information might be used to increase or decrease the severity level of a violation. The staff also recommended that the efforts to risk-inform the enforcement policy supplements be discontinued in view of the efforts to risk-inform the enforcement process as part of the integrated reactor oversight effort.
These recommendations were approved in the Commission's June 15,1999, SRM.
The staff has revised the enforcement manual to state that risk considerations can be used to raise or lower the severity level of violations. The enforcement policy has been revised to incorporate a more risk informed approach to the treatment of severity level IV violations. The Commission approved SECY-99-087 enforcement policy changes will be completed during
' August 1999.
ATTACHMENT 2 PRA IMPLEMENTATION PLAN ACTMTY TABLE (July 1999) 1.0 REACTOR REGULATION Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 9.1 STANDARD REVIEW Develop standard review
- Evaluate available industry NRR PLANS FOR RISK- plans S to be used in guxiance /RES INFORMED REGULATION nak-in regulatory decisionmaking.
, apters tha correspond to industry initiatrves
- Transmit draft SRPs to the Commission for approval to issue for public comment-General 4/97 Ca IST 4/97 C ISI 8/97 C TS 447C
- Transmit final SRPs to the Commission for approval:
General 1/98 C IST 3/98 C ISI 12/99 TS 3/98 C Update and revise SRPs: ,
General 6/99 Note 1.1 i IST 8/99 GQA 8/99 TS 8/99 ISI 12/00 (Section 1 is continued on the next page.)
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' See Abbreviations Table at the end of this report 8 C = Task previousty completed
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- Regulatory Activity Objectives Methods ~ Taiget LCEd Status (this
. Schedule . Othee(s) quarter) 1.2 PILOT APPLICATIONS Evaluate the PRA
- Interface with industry NRR/RES FOR RISK-INFORMED m and develop groups REGULATORY staff s on emerging, INITIATIVES - nok-i ormed initiatives,
- Evaluqe appropriate including those associated documentatx>n (e.g.,10 with: CFR, SRP, RGs, inspection ures, and industry
- 1. Motor operated valves to identify elements 1. 2/96 C to actwoving the intent
- 2. IST requirements of existing requirements 2a. Comanche Peak 2a. 8/98 C 2b. Palo Verde
- Evaluate industry proposals 2b. withdrawn
- 3. ISI requirements
- Evaluateindustrypilot 3. 1aD9 Note 1.2a program implementation, includino completion of 4. 1/98 C
- 4. Graded quality ' vendor /EPRI topical reports.
assurance (GQA)
- As appropriate, complete pilot reviews and issue staff S. 9/95 C l S. Maintenance Rule findings on regulatory requests 6a. 5/97 C
- 6. Technical specdications 6a. Commission approval 6b.10/98 C l '
6b. Pilot amendments i lasued
- 7. Other applications to be identified later (e.g ,
applications related to diesel generator start times and hydrogen control) 7a. 9/98 C 7a. ANO request for relief from the staff pcsstion in NUREG4737 for hydrogen moratoring, on the basis of Task Zero" of the Risk-Informed. Performance-
- Based Pilot P hole Plant 7b. 8/99 Note 1.2b 7b. San Onofre request to remove hydrogen recombiners ;
(Section 1 is continued on the next page.)
Att. 2 -2
Regulatory Activity Obtectives Methods Target Lead Status (this
. Schedute Office (s) quarter) 9.3 INSPECTIONS AND Provide guidance on the use
- Develop IMC 9900 technical 6/97 C NRR ASSESSMENT of plant-specific and generic outdance on the use of information from individual PRAs in the power reactor plant examinations (IPEs) and inspection program other plant- specife PRAs
- Propose guidance options 10/97 C for inspection procedures (IPs) related to 50.59 evaluabons and regular maintenance observations .
- Review core IPs and 10/97 C propose PRA guidance where needed
- Complete revision to 6/98 C fMren%* 10i**"""
- Issue final GOA IP 7/30/99 NRR Chanced Note L3a
- Develop. Test & Implement 4/00 NRR Note 1.3b C?pn"s '"*s" sten!p"1 program tNat are linked with nsk-informed improvements in Licensee Performance Assessment and Enforcement in accordance with revised Oversight Process described in SECY-99-007 and 99-007A.
- RevmwIPEEE insights 12/00 NRR report and extract guidance for inspectors
- Identifyinspectorfunctions 7/96 C NRR that should utilize PRA D/ tid f the r development and refinement of PRA training for inspectors
- Develop consolidated and 10/97 C NRR/HR comprehensive 2-3 week PRA for regulatory appications training course
- Conduct training for 8/96 C NRR Maintenance Rule baseline inspections
(Section 1 is continued on the next page.)
l Att. 2 -3 L
j
p.
I l
Regulatory Activity Obpctives Methods Target Lead Status (this i Schedule Office (s) quarter)
)
! i 1.3 INSPECTIONS AND
- Refine SDP process based 4/00 l ASSESSMENT (cont) on findings i 10/99 Develop risk-informed approach to event- following' achvities 1.4 OPERATOR Monitor insights from human
- Revise the Knowledoe and 8/95 C NRR LICENSING reliabihty anal es (HRAs) of Abilities Catalogs (NUREGs-PRAs (includi IPEs and 1122 and 1123) to l Individual examinations. incorporate operating i extemal events ( IPEEEs)) exponence and risk insights ;
and ratino exponence to I identi possible
- Pe*,e, N Examiner 3/97 C l enhancements for inclusion ir. St 1dards planned revisions to guidanca as needed I'NUREG-1021),
o reflect PRA for operator licensing activities insights (initial and requahficatirw1). ,
1 l
1.5 EVENT ASSESSMENT Continue to conduct Continue to evaluate 50.72 Ongoing NRR quantitative event events using accident assessments of reactor sequence precursor (ASP) events while at power and models during low- power and shutdown Conditions.
Assess the desirabihty and Define the current use of risk TBD feasibihty of conducting analysis methods and quantitafive risk assessments insights in current event on non-power reactor events, assessments Assess the feasibility of developing appropriate risk-assessment models Develop recommendations on the feasibihty and desirabihtyof conducting quantitative risk assessments 1.6 USE OF PRA IN Audit the of NRR/RES Now tracked RESOLUTION OF licensee ana IPEs and as part of GENERIC SAFETY IPEEEs to - item 1.10 ISSUES specific of generic safety issues clos out based on IPE and IPEEE programs.
1.7 REGULATORY Assess the effectiveness of RES/NRR lt is tracked EFFECTIVENESS maior safety issue resolution now as item EVALUATION efforts for reducing risk to 2.11 pubhc health and safety.
(Section 1 is continued on the next page.)
l Att. 2 -4
Regulatory Actmty Objectives Methods Tuget Lead Status (this Schedule Office (s) quarter) 1.8 ADVANCED Conhnue staff reviews of
- Continue to apply current 9/98 C NRR REACTOR REVIEWS PRAs for desigrx:ortfication staff reviewprocess iJRR/RES Develop i
- Reevaluate risk-based 12/96 C techrucal and criteria aspects of the technical for evaluonng NUREG-0396 initiatives and petrDons bases for EP (from NUREG-)
using insights regar$ng simpirhcanon of 1100, the new source term emergency preparedness informabon from NUREG-(EP) regulanons 1465, and availab6e plant desegn and PRA information for the passive and evolubonary reactor designs 1.9 ACCIDENT Develop genene and plant. plant-specific A/M TBD NRR/RES MANAGEMENT specific nok i ' ts to i nformanon for support staff a ' of util plants to serve as a accadent mana t )
programs at ed . basis completenessfor assessi of A/M program elements e.g.,
. severe-acodont tra(erung) 1.10 IPE FOLLOW-UP Evaluate specific
- Evaluate analyses of issues 5/99 RES Changed ACTIVITIES improvements erd analyses requested in Genenc Letter Note 1.10 proposed as basis for 88-20 resolubon of generic safety issues at specific plants
- Evaluate unscheited 12/99 NRR analyses of selected voluntary genenc issues
[GS_l23) submrtted by
. m.,_____
- Recommendabons to deferred NRR/
Commission regar$ng follow regions up on accident management Use results from the staff programs and licensee-review of IPEs to identfy stated actons potenbal safety issues and determine an appropriate
- Define use for information. 5/98 C course of action to address clanfy
- regulatory use.' end NRR/
these potennalissues. assess the mosteffaceve regions methods for data collecton.
1.11 RISK INFORMED implement Opbon 2 to SECY- Develop a preliminary plan to 10/99 NRR New REVISIONS TO 98-300 as directed by the implement nsk informed Note 1.11 PART 50 Commission's SRM. modificabons to 10 CFR PART 50 related to s treatment of SCCs. pecial (Section 1 is continued on the next page.)
Att. 2 -5
Notes for Scotion 1 Noee Number Note 9.1 Memo of 6/30/99 from EDO to Cw. . 'idescribes process for RG and SRP updates.
1.23 Comp 6 ebon date revised to renect EPRI Topical as final ISI Pilot activtty.
. 1.2b SER issued 6/30/99 Emmpeon to be issued 8/99.
1.3a The Inspection Plan has been revised follow 6ng CRGR guidance and has been resubmitted for foal CRGR consideratxm.
1.3b implementabon date for revised oversight process changed per SRM 98-007A.
1.10 Work on IPE follow up'hos been delened in order to refine the program's obtechvos and approach. The staff is c options for IPE insights tonow up with industry that will be complementary wth the Part 50 nok informed process.
eM of trus the approach will be factored into the PIP when finalized.
1.11 Responds to SRM on SECY 98-300.
Att. 2 -6 A
i - . . . . . . . . ,
2.0 REACTON SAFETY RESEARCH Regulatory Activity Oblectives Methods Target Lead Status (this Schedule Office (s) quarter) 2.1 REGULATORY GUIDES Develop RGs to
- Transmit draft PRA RGs to the RES/NRR provide a basis for Commission for approval to issue for the industry to use in public comment:
risk-informed General C regulabon. IST C ISI C GQA C TS C Transmit final PRA RGs to the !
Commission for approval i
, General 1/98 C IST. 3/98 C ISI 12/99 GQA 3/98 C TS 3/98 C 1 Update and revise PRA RGs:
! General 6/99 Completed IST 8/99 GQA 8/99 TS 8/99 ISI 12/00 l 2.2 TECHNICAL SUPPORT Provide technical
- Continue to provide ad hoc technical Continuing RES l support to NRC staff support to agency PRA users l usmg nsk
, assessment in risk-
- Expand the use of PRA models Continuing based regulation available; expand the of I actmbes and available models to inct extemal,
> technical reviews, low-power, and shutdown events; issue nsk refine the tools needed to use these assessments and models; and conbnue maintenance stabshcal analyses; and user support for SAPHIRE and and develop MACCS computer codes guidance for agency l uses of risk
- Support agency efforts in reactor Continuing I assessment. safety improvements in former Soviet Urwon countries
- Load plant-specific PRAs in Ongoing SAPHIRE to support vanous risk-appl esol of nonc,ssues.and = nionanc.
Rule inspecbons.
l l 2.3 SUPPORT FOR NRR Subsumed by ;
STANDARD REACTOR Sechon 1.8 l PRA REVIEW 1 "A.dvanced R actor Revi.we ,
1 (Secton 2 is continued on the next page.)
1 Att. 2 -7
. 1 Regulatory Activity Objectives Methods Ttrg t Lcid Stitus (this Schedule Office (s) quarter) 2.4 METHODS Develop,
- Final report on development and 9/99 RES See Note 2.4.
DEVELOPMENT AND demonstrate, demonstration of methods for DEMONSTRATION maintain, and ensure incorporating aging effects into PRAs.
the quality of methods for
- Develop and demonstrate 9/98 C performing, methods for incorporatino human reviewing, and using errors of commission in PRAs.
PRAs and related techniques for
- Conduct application of ATHENA for 7/99 Completed e4st-1 reactor fire risk assessment desigris.
Develop improved methods and data 9/00 for assessing performance of fire detection and suppression
- Develop improved methods and data 9/99 for assessing likelihood of fire 4nduced circuit failures
- Identify and prioritize key areas to 9/98 C Lnprove fire nsk analysis
- Develop and demonstrate methods for 9/00 assessing reliability /nsk of digital systems
' Develo integrated framework for 11/99 addressing model and parametnc uncertainty
' Develop and present fire risk 6/99 Completed assessment research program plan 2.5 IPE AND IPEEE Evaluate iPE/IPEEE
reasonable Susquehanna 6/98 C assurance that the Crystal River 6/98 C licensees have SER for Browns Ferry 3 6/98 C adequately analyzed plant design and
- Revised SER for Browns Ferry 3 5/99 Completed operations to discover
- Continue regionalIPE presentations. 12/97 C vulnerabilities; and document significant
- lssue IPE insights report for public 10/96 C safe insights comment.
resul IPE/IP Es.
- lssue finalIPE insights report 12/97 C
- lssue preliminary IPEEE insights 1/98 C report
- Initiate review of eight additional 698 C IPEEE submittals
- Complete contractor evaluations of 6/98 C twelve IPEEE submittals.
- Complete reviews of IPEEE 4/00 submittals.
- Issue draft IPEEE insights report for 7/00 comment
- lssue final IPEEE insights report 1/01 (Section 2 is continued on the next page.) {
Att. 2 -8
i Regulatory Actvity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 2.6 GENERIC SAFETY Conduct generic
- Continue to priontize and resolve Continuing RES See Note 2.6 ISSUES PROGRAM safety issue genene safety issues management activities including pnoritization, resolution, and documentation, for issues relatng to current!y operatng reactors, for advanced reactors as appropnate, and for oevelopment or revision of associated regulatory and standards instruments.
2.7 NEl INITIATIVE TO Review NElinitiative
- Agree on ground rules for study TBD RES/NRR Note 2.7 CONDUCT "WHOLE to conduct three pilot l PLANT
- RISK STUDY *whole plant
- risk-
- Complete study TBD l informed studies of !
requirarnents vs. risk and cust.
2.8 PRA STANDARDS Work with industry to Initate Phase 1 activity (ASME) 9/97 C RES DEVELOPMENT develop national consensus standard Issue inital ASME draft standard 7/98 C for PRA scope and quality. lssue ASME draft standard for 1/99 C ;
select public comment Finalize Phase 1 standard (ASME) 12/99 Note 2.8a Initiate Phase 2 effort (ANS) S/99 C Completed lssue initial ANS draft standard TBD Note 2.8b
- LPSD
- Seismic 2.9 LOW POWER AND Collect studies of
- Collect and review existing LPSD risk 12/99 RES Note 2.9 SHUTDOWN (LPSD) LPSD risk as a information (domestic and foreign) to BENCHMARK RISK benchmark for develop perspectives with respect to STUDY assessing the need the need for revising of RG 1.174 and for further staff performing additonal work activities.
- Initiate additional work, as necessary, 1/00 based on developed plan 2.10 SAFETY GOAL Assess need to Initiate discussion with ACRS 2/98 C RES REVISION revise Commission's
- Safety Goal to make Make recommendation to 4/98 C core damage Commission frequency a
- fundamental goal Provide information paper 7/99 Completed and make other
- changes. Provide final recommendations 3/00 Note 2.10 (Secton 2 is continued on the next page.)
Att. 2 -9
Regulatory Activity Obtectives Methods TCrget Lead Siatus (this
, Schedule Office (s) quarter) 8.11 REGULATORY Assess the Evaluate the effectiveness of 9/99 RES/NRR EFFECTIVENESS offectveness of staton blackout rule and 6ssue a i EVALUATION mapr safety issue prehminary report I
reso6ubon efforts for
- reducmg nok to Evaluate resulting effectiveness of 9/00 RES .
l put*c health and ATWS rule and resolubon of USI A.
salsty. 45 Use lessons loamed to develop 9/01 process / guidance on assessing the effectiveness of mator rules l
2.12 REVIEW OF AGENCY Perform a broad Identify oobons for 12/98C RES/NRR PROGRAMS AND reviewof the 50 to be sak-informed ~bPart 98 PROCESSES agency's process to 300) search for these a vtties 'n o the SNS9 more risk informed
- process Provide recommendabons on 10/99 New item- Note l Part 50 nsk modificebon study plan 2.12
! (Option 3)
PRA Steering Committee Ongoing 2.13 RISK-BASED TRENDS Use reactor Trsnd performance of risk-important 3/00 RES AND PATTERNS operating experience components ANALYSIS data to assess the trends.and pattoms
- Trend performance of risk-important 5/00 in equipment, systems systems,initating
- events. human Trend frequency of risk-important 7/98 C performance. and irwhatng events important accident sequence.
- Trend human performance for TBD rehability charactensbcs Evaluate the Trend reactor operating 'ence As needed effectveness of associated with specific hcensee actions issues and assess nsk im taken to resolve as a measure of safety nsk significant safety performance issues.
Develop trending methods and specal
- Develop standard and C databases for use in statstcal analysis uros for AEOD trending identifed areas for hty and activibes and for statishcal apphcahons PRA appiscations in other NRC offices.
Develop special software and C databases (e.g., commorH:ause (Periodic failure or use in trending analyses updates) and P studies (Sec6on 2 is continued on the next page.)
Att. 2 -10
r
. Regulatory Actmty Ot W ves Methods T uget Lead St .tus (ttis
. Schedule Office quarter) 2.14 ACCIDENT Identify and rank risk
- Screen and analyze LERs. Ongoing RES SEQUENCE significance of operational AITs,IITs and events PRECURSOR (ASP) events. identified from other PROGRAM sources to obtain ASP events
- Completequality C RES assurance of Revision 2 of -
the simplified plant-specific models
- Complete feasibility study C RES for low-power and shutdown models
- Completeinitial C RES containment performance and consequerce models.
!
- Complete extemal event TBD RES l models for fire and earthquake
- Share ASP analyses and Annual RES information on plant-specife insights with other NRC report performance. offices and regions (Secton 2 is continued on the next page.)
l l
Att. 2 -11 i
Regulatory Activity Otnectives Methods Torget Lead Status (this
, Schedule Office gusrter) 2.15 INDUSTRY RISK Provide a measure of industry
- Develop p ram plan to C RES TRENDS risk that is as complete as integrate N ,RES,and possible to determine whether AEOD activities using nsk is increasing, decreasing, design and operating or remarning constant over exponence to assess the time. implied level of risk and how it is changing
- Implement program plan 1/01 elemer.ts to include plant-specific models and insights from IPEs.
component and system reltaoility data. and other fisk-emportant design and operational data in an integrated framework to penodically evaluate industry trends 2.56 RISK BASED Establish a comprehens.se set
- Identify new or improved C RES PERFORMANCE of performance indicators and nsk-based Pls which use INDICATORS supplementary performance component and system measures which are more reliability models and closely related to risk and human and organizabonal provide both earty indication performance evaluation and confirmabon of plant methods performance problems.
- Brief ACRS and 2/00 Note 2.16 Commission. Publish candidate RBPIs for NRC and public comment ,
- Brief ACRS and 10/00 Commission on RBPts and request implementation approval (Section 2 is continued on the next page.)
i l
Att. 2 -12 i
7 Regulatory Activtty Objectives Methods Trfget Lead Status (this
. Schedule Office quarter) 2.17 OPERATING Compile operating experience
- Manage and maintain Ongoing RES EXPERIENCE DATA informaton in database SCSS and the Pi data systems suitable for titative base, provide oversight rehability and nsk a ~s and access to apohcations. Informa on NPRDS/ EPIX, obtain should be scrutable to the INPO's SSPI, compile IPE source at the event level to the failure data, collect plant-extent practical and be specific rehabihty and l l sufficient for estimating availability data l l
' reliabihty and availability !
parameters for NRC
- Develop, manage, and Ongoing applications. I maintain agency ;
I databases for reliabihty/ availability data (equipment performance, initiating events, CCF, ASP, and human performance data)
- Determine need to revise 6/98 C LER rule to ehminate unnecessary and less
, safety-significant reporting
- Determine need to revise 6/98 C reporting rules and to better capture ASP, CCF, and human performance events
- Publish revised LER rule 2/00 <
- Develop database to 4/00 collect rehabihty(andavailability data RADS)
Notes for Section 2 Not)
Number Note 2.4 Draft report has been completed and is intemal staff review.
2.6 During'this period. Genene issues B-61 (Allowable ECCS Equipmsnt Outage Periods and GI-165 (Spn'ng Actuated Safety and Reliet Valves were resolved with no new requirements identified. Genenc Issue 107 n Transformer Failure) was re-pnoritized and dropped l rom the list of outstanding safety issues based on staff re-examination its risk significance 2.7 The staff has subsumed its interactions with NEl on the *whole plant study"into the recommended approach to risk-inform 10 CFR 50 as discussed in SECY-98 300 2.8a ASME standard (Phase 1) covers intemal events only (excluding fire) at full-power, a level 1 and a limited Level 2 PRA.
2.8b ANS has Phase 2 which includes a PRA for low power shutdown conditions and seismic events.
2.9 Work delayed due to higher pnonty work as described in the staff's response to the Chairman's Tasking Memorandum (CTM) 2.10 This task has been delayed because of the need to ensure that any proposed rnodifications to the Safety Goal Policy statement will be consistent with Commission directives on nsk-informirq10 CFR 50 (SECY 98-300), on-going activities related to the oversight program and to provide for extensive coordination with AGRS/ACNW and other stakeholders.
2.12 Responds to SRM on SECY 98-300.
2.16 Deadlines have been extended due to the determination during the initial development phase that identification of appropriate indicators and threshold was more complicated than onginally planned. The final target schedule will not be affsted.
l Att. 2 -13
3.0 STAFF TRAINING Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office quarter) 3.0 STAFF TRAINING Present PRA curriculum as
- Continue current contracts Ongoing HR esently scheduled for FY t esen coursesas
- Maintain current reactor Ongoing technol courses that include insights and apphcations courses via Ongoing
- Review current PRA C course matenal to ensure consistency with Appendix C (Section 3 is continued on the next page.)
Att. 2 -14
1 I
Regulatory Activity Objectives Methods Tcrget Lead St3us (this 4 Schedule Office quarter)
J 3.0 STAFF TRAINING Develop and present Prepare course material C HR j (continued) Appendix C training courses. based on Appendix C 4 Present courses on C Appendix C Determine staff requirements
- Review JTAs performed to C HR including date i for training, analysis of knowledge and I skills, needed by the NRC
- Perform representative C i staff. JTAs for sta'f positions l (JTA Pilot Program) j Evaluate staff trainino C requirements as idenTrfied in the PRA implementation Plan and the Technical Training Needs Survey (Phase 2) and incorporate them into the training requirements analysis Analyze the results of the C ,
JTA Pilot Program and !
determine requirements for additional JTAs
- I Complete JTAs for other C statt positions as needed Solicit a review of the C proposed training requirements Finalize the requirements C HR Revise current PRA curriculum Prepare new courses to Ongoing and develop new training meet identified needs i program to fulfill identified staff
- i needs. Revise current PRA Ongoing i courses to meet identified needs l Revise current and new 9/97 C PRA course to include RG and SRP information Revise current reactor ongoing technology courses as necessa. toinclude add PRA insights and applications Present revised PRA training
- Establish contracts for ongoing HR cuniculum. presentatKin of new PRA CumCuium Present revised reactor Ongoing tMieegy courses Improve courses based on Ongoing feedback Att. 2 -15
f
(
4.0 NUCLEAR MATERIALS AND LOW-LEVEL WASTE SAFETY AND SAFEGUARDS REGULATION
- Regulatory Activity Objectives Methods Target Lead Status (this
, Scredule Office (s) auarter) l l 4.1 VAllDATE RISK Validate risk analysis
- Hold a workshop 8/94 C NMSS ANALYSIS methodology developed to consisung of experts in METHODOLOGY assess the relabve profile of PRA and HRA to examine DEVELOPED TO most likely contributors to exisbng work and to make ASSESS MOST misadministrabon for the recommendations for LIKELY FAILURE gamma stereotactic device further methodological MODES AND HUMAN (gamma knife). devolepment PERFORMANCE IN THE USE OF
- Examine the use of Monte 9/95 C INDUSTRIAL AND Cario simulabon and its MEDICAL RADIATION application to relatve risk DEVICES profiling
- Examine the use of expert 9/95 C judgement in developing error rates and consequence measures Continue the development of the
- Developfunctionallybased TBD RES/
relative risk methodology, with genenc event trees NMSS the addition of event tree modeling of the brachytherapy remote after loader.
Extend the application of the
- Develop generic risk TBD RES/
methodology and its further approaches NMSS development into additional devices, including teletherapy and the pulsed high dose rate after loader.
4.2 CONTINUE USE OF Develop decision criteria to Conduct enhar.ced 8/94 C RES/NMSS RISK ASSESSMENT support regulatory decision- parterpatory rulemakina Final rule OF ALLOWABLE making that incorporates both to establish radiologica'l ublished RADIATION deterministic and risk-based critena for p/97 7 C RELEASES AND engineering judgment. decommissionino DOSES ASSOCIATED nuclear sites; technical WITH LOW-LEVEL support for rulemaking, RADIOACTIVE WASTE including comprehensive AND RESIDUAL risk based assessment ACTIVITY. of residual Contamination 3/98 C Develop guidance for IcNnt nafor hcense terminavon Work with DOE and EPA Ongoing to the extent practcable to developcommon approaches, assumptions, and l models for evaluating j nsks and altomatve remediation methodol (risk
- 4.3 Develop a branch technical Solicit public comments 5/97 C NMSS/RES !
l DEVELOP GUIDANCE posebon on conducting a !
SK ASS WITH WASTE A D $ s lYa$ty
- Publish final Branch Technical Position 9/00 l REPOSITORIES.
l I
(Seebon 4 is continued on the next page.)
Att. 2 -16
Reguistory Activsty Objectives Methods Target Load Status (this
, Scheduie Ofhce(s) quarter) l 4 4 ASSESS RISK Develop and demonstrate a nsk
- Develop and 9/98 C RES ASSESSMENT OF assessment for industnal demonstrate methods MATERIAL USES. gauges containing cesium-137 for determmm and cobalt 40 usmg PRA and associated wa'g n the nsk other related techniques. industnal gauges contaming cessum-137 The assessment should allow and cobaR40 for modshcahon based on
- changes in regulatory lasue final report as a 9/99 Changed requirements. NUREG (Note 4.4a)
N mpi data as much as I
Develop and demonstrate risk
- Through wortung group 3/99 NMSS Completed J assessment methods for with contractor (Note 4.4b) apphos.tnon to medcol and assistance, identify and incustnallicensee activities document a techncal I bass for a risk-informed approach to the ,
regulabon of nuclear i b uct matenal, and ns for a g approach to ;
nuclear byproduct '
matenal regulation based on nok information i 1
Note 4.4c
. Publish draft risk report 7/99 and assocated documents for comment.
Note 4.4c
. Provide final report to 1/00 the Commesion i
4.5 USE OF PRA IN Develop and implement a Provide plan for 6/98 C NMSS REGULATING NUCLEAR framework for applyng PRA to developmg framework MATERIALS nuclear material uses, similar to the one developed for reactor
- Complete scopmg effort 3,99 Note 4.Sa ,
regulabon (SECY-95-280), i where appropnote . Complete framework 3/99 C i
. Estabhsh milestones for 9/99 Note 4.5b fra G6 RISK-INFORMED Revise 10 CFR Part 70 to be . Revise current regulation 6/99 NMSS Note 4.6 REGULATION OF FUEL nsk-informed and performance- to place emphase on Complete CYCLE FACILITIES based major accidents and on I en mtegrated safety .
- "t,* arm 42 a
. De broad-scope 6/99 SRP C rs Complete u
deciphne areas
. Estabish an outreach Ongoing
!intekinto tookto ee with industry and interested stakeholders
- 6/99
. Transmit draft rule and Complete SRP to the Commesion for approvalto issue for pubhc comment 5/00
. Transmit final rule and SRP to the Commission for approval (Section 4 m continued on the next page.)
Att. 2 -17
Regulatory Activity Objectives Methods Ts/get Leid Status (this Schedule Office (s) quarter) 4.7 FUEL CYCLE SAFETY Optimize regulatory burden on Establish a management 4/99 NMSS & Note 4.7 INSPECTION PROGRAM both the NRC and its licensees task force to develop the Regions Complete REVISION wth respect to safety inspecton framework for a safety activities while ensunng safe inspection program operations optimizing on plant performance indicators, risk insights, and third party inspections
. Establish a procedure 9/99 wnting task force to revise current inspection procedures 'niing the new indicr.crs
. Establish an outreach 8/99 program to interface with industry and interestod stakeholders -
. Develop a new set of 1/00 1 NRC Inspection Manual l
Chapters j
. Develop and complete 4/00 inspector training
. Implement pilot program 3"' OTR~
for revised fuel cycle FYOO safety inspecton program
. Incorporate 10 CFR Part 9/01 70 nsk insights when available and revise program as necessary 4.8 PILOT REGULATORY Evaluate opportunities for Develop a pilot program for 8/99 NMSS & OE Note 4.8 INITIATIVES FOR FUEL reducing regulatory burden while altemate dispositon of SLIV CYCLE FACILITIES ensunng equivalent safety violatons at the GDPs and fuel cycle facilities with approved correctve acton programs
. Train inspectors to the new initiatve and 10/99 implement actvity
. Evaluate effectiveness of pilot program 8/01 4.9 PILOT REGULATORY Eval 6 ate opportunities for Develop a pilot program wth 8/99 NMSS/OE Note 4.9 (NITIATIVES FOR reducing regulatory burden while performance indicators MEDICAL LICENSEES ensunng equivalent safety focused on safety-related outcomes
. Train inspectors on 10/99 initatve
. Evaluate effectiveness 12/00 of pilot program (Section 4 is continued on the next page.)
I L
Att. 2 -18
l .
l l Notes for Section 4
- Noto
! Number Note l 4.Q3 NMSS completed review of the draft NUREG in January 1999. Comment resolution has been more resource intensive than was j onginally anticipated; scheduled publication is now September,1999.
4.4b SECY-99-062 transmitted the draft working group report to the Cc, mission on March 1,1999. The schedule for SECY-99-062 was extended to allow coordination with SECY-99-100 which was prepared as part of Regulatory Activity 4.5.
4.4c New item. I 1
4.5a in March,1999, the staff completed its scoping effort. In SECY 99-100, the staff reported the results of this effort and proposed a framework and an approach for its implementation to the Commission. The Commission approved the framework and the staff's proposed implementation approach in its SRM of June 28,1999.
. 4.5b in SECY-99-100, the staff proposed to track progress toward implementation of the framework in the PRA implementation Plan. l l Under this new item, the staff will develop milestones for implementation (based on Attachment 4 to SECY 99-100) to be included in
- the next quarterly update.
1 4.6 New item. l l
4.7 New item.
I I
- 4.8 - New item 4.9 New item.
i l
l Att. 2 -19
5.0 HIGH-LEVEL NUCLEAR WASTE REGULATION Regulatory Actuty Objectives Methods Target Lead Status (this Schedule Office (s) , quarter) 5.1 REGULATION OF HIGH- Develoo ouglance for the NRC
- Assist the sta# in pre. Ongoing NMSS LEVEL WASTE and CNWRA staffs in the use of licensing actmties and in performance assessment (PA license applicatKm to evaluate the safety of HLW) reviews Develop a technical assessment capability in total- system and subsystem PA for use in licensing and pre-licenssng reviews Combine specialized techrucal disciplines (earth sciences and engineenng) with those of system modelers to improve methodology identity sigruficant events.
- Perform sensitivity Ongoing NMSS processes, and parameters studies of key tech. ru' cal' affechng total system issues using storative PA perforfrance. (IPA)
Use PA and PSA methods. Assist the staff in Ongoing NMSS Note 5.1(a) results, and insights to evaluate maintmening and refirdng ed changes to the regulatory strtcture r goveming the in HLW disposal repositorya Yucca gulations that pertain to adv A deve6opment of a Yucca Mountain regulabon IPA analysos to
'nEntam set Continue PA ac6vities during
- Provide guidance to the Ongoing NMSS Note 5.1(b')
interaccons with DOE during DOE on srte the pre-licensi phase of characterization repository dev ent, site requirements, charactenzaton, and repository desagn work, and 'ng'ng DOE a fice"nse We2W"'"'"
- Compare results of NRC's iteranve performance assessment to DOE's V ' Assessment (VA) to ' major differences / issues 5.2 PRA APPUCATION TO Demonstrate methods for PRA
- Prepare user needs letter 4/97 C RES/NMSS SPENT FUEL STORAGE of spent fuel storage facilities. to RES FACluTIES
- Conduct ISA of VSC-24 7/99 C Note 5.2a dry-cask storage system usmg proabilisec methods
. Conduct PRA for dry cask Ongoing Note 5.2b storage (Secton 5 is continued on the next page.)
Att. 2 -20
I Regulatory Activity Objecbves Methods Target Lead Status (this i
Schedule Office (s) quarter) 3.3 CONTINUAL USE OF Use PRA methods, resuhs, and
- Update the database on 6/01 NMSS RISK ASSESSMENTIN insights to evaluate regulations transportation of SUPPORT OF goverrung the transportabon of radioactive materials for RADIOACTIVE tadioachve materiai. future applications MATERIAL TRANSPORTATION
- Revalidate the results of 12/99 NUREG-0170 for spent fuel shipment risk eshmates
. Update NUREG/CR-4824 12/04 Note 5.3 (Modal Study) l l
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Notes for Section 5 Note Number Note 5.1a Proposed regulations for deep geolo pubhc outreach meetings in Nevada.gic disposal At the close at Yucca of the comrnent Mountain penod on June were issued 30,1999,91 for comment comrr.entors in February,1999. The sta had provided approximately 1,000 comments.
5.1b DOE provided the viability assessment for NRC .eview in 12/98. The staff completed its review and reported its findings to the Commission in SECY 99-074 on March t1,1999.
5.20 The ISA of the VSC-24 dry cask storage system has been forwarded to RES to be used as background information in the development of the dry cask storage PRA.
5.2b in July,1999 RES initiated a PRA and will use the Holtec Hi-Storm cask design as the basis for the analysis. RES will perform the analysis with in-house staff in coordination with NMSS/SFPO.
5.3 New item.
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Att. 2 -21
6.0 REACTOR ENFORCEMENT Regulatory ActMty W .x Methods Target Lead Status (this quarter)
Schedule Othee(s) 6.1 CONSIDERATION OF Ensure the consistent *P re an enforcement 6/ 97 C OE l RISK IN THE canon of the Erdorcement memorandum j
' ENFORCEMENT in the Area of Rak GM)
PROCESS I Erdorcement Actions
- U to the Enforcement 8/98 C OE ual to reflect the tuidance GM developed in the
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)
6.2 RISK INSIGHTS Ensure risk-informed docsions
- Include senior Ongomg OE DURING WEEKLY are made in developmg reactor evaluation ENFORCEMENT enforcement actons on paneled PANELS cases when warranted 6.3 CHANGE THE Provide the staff with more
- Interface with NRR (SPSB) deleted per OE ENFORCEMENT useful guidance for-!-- to consider additional SRM POLICY the Severtty Level of VM..aa - examples for the poicy 6/15/99 SUPPLEMENTS supplements TOINCLUDE ADDITIONAL EXAMPLES OF HOW RISK SHOULD INFLUENCE SEVERITY LEVEL i
Att. 2 -22
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'S ABBREVIATIONS 3 ABWR advanced W - - reactor AEOD . Othee for Analysis and Evaluanon of Operatonal Data ACRS Advisory Committee on Reactor Safeguards
-AFW aujoleary feedwater AIT augmented inspecton team ANO Arkansas Nucieer One AOT allowed outage time
~AM accident management APS Arizona Public Serwce ASME Amencan Society of Mechanical Engineers ASP accident sequence precursor ATWS anecipated transient without scram BF3 Browns Ferry Unit 3 C compieied COL comtuned construcuan and operenne beense CCF commo.H:ause failures -
CFR- Code of FederalRepulseions CRGR Committee to Rewsw Generic Requirements CY . calendar year CNWRA Center for Nuclear Waste Regulatory Acevites DOE Department of Energy EDG emergency diesel generator EGM Enforcement Guidance Memorandum EP emergency preparedness EPA Environmental Protecton Agency t EPIX Equipment Performance and Information Exchange FY fiscal year HLW high4evel weste l HRA human rehabdity analysis j GSI generic safetyissus j GOA graded quauty assurance JTA job task analysis IE initiating event
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- lMC ire manuel chapter
! INPO Insttute of Nuclear Power Opershons l lP inspecton procedure l lPA . iterative performance assessment l lPE indrvidual plant examinsbon
! lPEEE indiwdued plant examinsbon, extemel events IIT incident ir=f* team IST inserwce leseng ISI inservice inspection
. .LAN local area network l LER licensee event report LOSP loss of offsite power LLW low levelweste LP&S iow power and shutdown MACCS MELCOR Accident Consequence Code System MR Memtenance Rule NEl ' Nuclear Energy instituto NOED notice of enforcement discrebon l NPRDS nucieer plant reliststy data system ,
! NRR' Othee of Nuclear Reactor Regulation l NMSS OfRce of Nucieer Motorial Safety and Safeguards OClO Office of the Chief Irdormabon OfEcor
. OE OfRce of Enforcement OGC Ottooof theGeneralCounsel PA performance assessment PI performance indicator
- PIP PRA implementaton Plan PIPS inspecton Program Branch NRR PM propect manager PRA prm flok assessment RAI request for additonalinformation
'RCP reactor cooient pump RES Omos of Nuclear Reguistory Research RG regulatory guide SAMG severe-acciJont management guidance SAPHIRE Systems Analysis Programs for Hands -on integrated Reliabihty Evaluations SBO stauon bisekout
.SECY Othee of Secretary of the Cww M SER safety evaluation report Att. 2 -23
e i
'SGTR steem generator tuber rupture SONGS San Onofre Nuclear Genorsung Station
,- SPSB Probabihetic Safety Assessment Branch
' SCidi sequence codng and search system SRP standard soview plan SRA senior reactor analysts SRM staff requirements memorandum SSPl- Safety System Performance Indicator TBD to be determined TTD TechrucalTraining Divisen l TS technmal specificanons TU Texas Utihees FY Fiscal Year j VA viabibly assessment l
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Att. 2 -24