ML20211N573
| ML20211N573 | |
| Person / Time | |
|---|---|
| Issue date: | 09/07/1999 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9909130023 | |
| Download: ML20211N573 (117) | |
Text
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- IGLNAL I
UNITED STATES.OF AMERICA NUCLEAR REGULATORY COMMISSION
Title:
NRC STAFF BRIEFING ON PROBABILISTIC RISK ASSESSMENT IMPLEMENTATION PLAN l
PUBLIC MEETING Location:
Rockville, Maryland Date:-
Tuesday, September 7,1999 Pages:
1 - 84
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ANN RILEY & ASSOCIATES, LTD.
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DISCLAIMER
-This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on f
f September 7, 1999, in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general I
informational purposes..As provided by 10 CFR 9.103, it is
.not part of the formal or informal record of decision of the j
matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading-or other paper may be filed with the Commission in any. proceeding as the result of, or addressed to,_any statement or. argument contained herein, except its the Commission may authorize.
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
OFFICE OF THE SECRETARY 4
5 NRC STAFF BRIEFING ON 6
PROBABILISTIC RISK ASSESSMENT i
7 IMPLEMENTATION PLAN 8
9 PUBLIC MEETING 10 11 Nuclear Regulatory Commission 12 One White Flint North 13 Building 1, Room 1F-15 14 11555 Rockville Pike 15 Rockville, Maryland 16 Tuesday, September 7, 1999 17 The Commission met in open session, pursuant to 18 notice, at 9:17 a.m.,
the Honorable GRETA J. DICUS, Chairman i
19 of the Commission, presiding.
20 COMMISSIONERS PRESENT:
)
i 21 GRETA J. DICUS, Chairman of the Commission 22 NILS J. DIAZ, Member of the Commission 23 EDWARD McGAFFIGAN, JR.,
Member of the Commission 24 JEFFREY S. MERRIFIELD, Member of the Commission 25 ANN RILEY & ASSOCIATES, LTD.
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STAFF-AlvD PRESENTERS SEATED AT THE COMMISSION TABLE:
2 MALCOLM KNAPP, Deputy Executive Director for 3
Materials Research, & State Programs, NRC 4
ASHOK THADANI, Director of the Office of Research 5
TOM KING, Director of the Division of Risk 6
Analysis and Applications in Research 7
PAT RATHBUN, Division of Industrial and Medical 8
Nuclear Safety, NMSS 9
MARTY VIRGILIO, Deputy Director of NMSS 10 GARY HOLAHAN, Director of the Division of Systems 11 Safety and Analysis, NRR 12 SCOTT NEWBERRY, Deputy Director of the Division of 13 Regulatory Improvements, NRR 14 SAM COLLINS, Director, NRR 15 BRIAN SHERON, Associate Director, NRR 16 KAREN D.
CYR, General Counsel, NRC 17 ANNETTE VIETTI-COOK, Secretary, NRC 18 19 20 21 22 l
23 24 25 ANN RILEY & ASSOCIATES, LTD.
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1 PROCEEDINGS 2
[9:17 a.m.]
3 CHAIRMAN DICUS:
Let me apologize for starting a 4
little bit late.
It was my fault.
I was the late one this 5
morning.
I am-leaving on travel; I probably will not be 6
able to stay through the whole briefing and Commission Diaz 7
will take over and I appreciate that, but when I have got to 8
go on travel, I have got to stop in the morning and take my 9
dog to the kennel and then I get into this awful traffic and 10 I remember why it is I come in so early, staying out of 11 traffic.
1:2 Well, let us not delay any more than I have 13 already delayed us, so good morning, ladies and gentlemen.
14 I welcome all of you to the Staff's briefing of the 15 Commission on the status of our PRA Implementation Plan.
j 16 The use of this plan has been an integral part of the 17 agency's transformation into a more risk-informed regulatory 18 framework.
It contains not only specific technical 19 activities in which risk-informed initiatives are underway 20 but it also provides a comprehensive structure to evaluate 21 all the programs and processes that are necessary to support 22 a risk-informed regulatory environment.
23 Much has been accomplished but there is much more 24 to be done, as we all know from activities related to the 25 maintenance rule and review of the IPEEE evaluations to the j
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1 development of regulatory guidance and identification and 2
resolution of' policy issues involved in risk-informing 10 3
CFR Part 50.
4 The Staff has planned a rather ambitious 5
presentation for us this morning, which I think we can get 6
through hopefully in a timely fashion, so therefore do any 7
of my fellow Commissioners have any opening comments they 8
would like to'make or any clarifying statements?
9
[No response.)
10 CHAIRMAN DICUS:
Then with that I believe we are 11 ready to start, so if you would start, Mr. Knapp, we are 12 ready.
13 MR. KNAPP:
Certainly.
Good morning, Chairman, 14 Commissioners.
15 CHAIRMAN DICUS:
Good morning.
16 MR. KNAPP:
I would like to-begin by introducing 17 the Staff on this side of the table.
To my immediate right 18 is Ashok Thadani, Director of the Office of Research; to his 19-right is Tom King, Director of the Division of Risk Analysis 20 and Applications in Research;-and to his right is Pat 21 Rathbun, with the Division of Industrial and Medical Nuclear 22 Safety, NMSS; to my left, Marty Virgilio, Deputy Director of 23 NMSS; to his left Gary Holahan, Director of the Division of 24 Systems Safety and Analysis within NRR; and to his left 25' Scott Newberry, Deputy Director of the Division of ANN RILEY & ASSOCIATES, LTD.
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Regulatory Improvements within NRR.
2 The briefing that we are bringing you today will 3
focus principally on the last six months.
The last PRA 4
implementation briefing which we presented was in January of 5
1999.
The purpose is to both summarize our accomplishments 6
over the last six months and focus on the major activities 7
which are now underway.
This work underway represents a 8
fundamental reassessment of our current programs and 9
practices, not only on reactors but also on materials and on 10 nuclear waste.
11-We are building on the previous work that we have 12 done and the successes that we have had in risk-informing 13 some of our activities.
I think it is important to note 14 that as we continue this work licensees can utilize the 15 existing risk-informed approaches that we have and our work 16 will build on broader applications.
17 I will now turn the meeting over to Mr. Thadani, 18 who will carry the ball.
1 19 MR. THADANI:
Thank you, Mal.
Good morning.
May 20 I have viewgraph number two, please.
21 As you can see from the outline of the 22 presentation, we do have a number of important issues that 23 we intend to discuss at this briefing.
After a fairly brief 24 description of some of the recent accomplishments including 25 the use of risk information in the Reactor Oversight ANN RILEY & ASSOCIATES, LTD.
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1 Program, we will move on to focus on kay elements in terms 2
of what is the status and what are the key issues with 3
risk-informing Part 50 of the regulations, provide the 4-update on status of implementation of the framework for 5
materials regulation, and finally we will discuss the 6
strategy for integrating a number of interrelated issues, 7
and this was one of the concerns that was raised by 8
stakeholders.
Let's go to viewgraph number 3, please.
9 As we stated in the SECY paper itself, SECY 99-211 10 only briefly discussed work related to risk-informing 11 reactor and nonreactor requirements as well as development 12 of a strategy for risk-informed regulation.
While our 13 plant-specific activities have continued we have 14 significantly expanded our broader applications of risk 15 information both in the reactor as well as nonreactor
'16 arenas.
17 For example, between March and June of this year 18 six papers were provided to the Commission and the 19 Supplements Chart Number 1 lists the papers that were 20 provided to the Commission.
In addition to that, we have 21 also' actively moved forward in our efforts to risk inform 22 Part 50 of our regulations.
In this effort of course we are 23 very mindful of the input from the stakeholders.
1 24 Many important issues have been raised by 25 stakeholders and briefly GAO noted a need for a strategy to ANN RILEY & ASSOCIATES, LTD.
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1 integrate objectives, safety goals, activities and j
2 timeframes in a cohesive fashion.
The Center for Strategic l
3 and International Studies noted the need for a clear safety I
4 philosophy that is consistently applied, and also noted the
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5 need for some methods enhancements in risk-informing certain j
6 areas.
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Industry has provided input.
There is fairly 1
8 specific. input in terms of some of the areas that they would j
9 like for us to proceed on first.
10 Public interest groups have noted some of the j
l 11 limitations in methods and pointed out the importance of 12 having a high quality standard and detailed reviews by the 13 NRC of PRAs prior to moving forward with risk-informed 14 regulation.
15 The Advisory Committee on Reactor Safeguards has, 16 of course, supported moving forward with risk-informing 17 rules, but they have also noted the need to make 18 enhancements in certain selected areas, and they have 19 identified those in the report that they just recently 20 issued which reviewed research programs.
May I have the 21 next viewgraph, please.
22 There are a number of issues, as I said, 23 interrelated issues, and these require management attention.
24 Some of the examples of these issues are the need to develop 25 a strategy for risk-informing Part 50 and other efforts, ANN RILEY & ASSOCIATES, LTD.
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feasibility of high level safety principles -- agency-wide 2
safety principles not just reactor, revision of reactor 3
safety goal policy -- we provided a paper on that recently 4
to the Commission as well as nonreactor issues.
5 The PRA Steering Committee plays a very active 6
role in these efforts.
As you know, the committee consists 7
of Directors -- NRR, NMSS, Office of Enforcement.
Regions 8
are represented by Luis Reyes of Region II and OGC 9
participates in these meetings and I chair the meetings.
10 Our focus has really been on taking these issues 11 and trying to make sure we can see how best to fit all these 12 pieces together.
Now today's presentation is going to cover 12 a number of these issues, and next Gary Holahan will briefly 14 summarize some of.the accomplishments of the agency in the 15 last six months. Gary?
.16 MR. HOLAHAN:
Thank you.
I will be very briefly 17 summarizing accomplishment in a number of areas, two items 18 we'll on with additional presentations and those will 19 involve the Oversight Program and risk-informing Part 50.
20 The other areas that I would just like to spend a few 21 minutes on is the Reactor Licensing where we have put in 22 place Regulatory Guides and Standard Review Plans and a 23 number of pilot activities, and now we are really in an 24 implementation phase in which the Staff has been granting 25 license amendments and in some cases exemptions to
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-1 regulations I think in areas where we would not have done 2
previously without having the risk assessment tools that we 3
currently have.
4 These areas are summarized in supplemental 5
viewgraphs two, three, four and five.
Basically what they 6
are identifying is eight significant risk-informed licensing I
7 actions that have come in over the last six months,
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8 predominantly in the area of inservice inspection for 9
reactor coolant system piping, technical specifications,
.10 inservice testing for pumps and valves, and also a very 11 significant item during this period that has come in, which 12 is the South Texas Project's request for an exemption to a 13 number of regulations and that activity will serve as a 14 pilot for the risk-informing of Part 50.
j 15 A number of items have been completed over the 16 last six months in similar areas.
The emphasis has been on 17 technical specifications, ISI and IST.
We expect 18 additional -- we have a number of applications under review 19 and we are expecting additional ones on those areas, and 20 what we are seeing is both generic activities where owners 21 groups and EPRI for example are coming into the Staff as 22 well as plant-specific items.
23 I think from the numbers what we see is there's 24' some significant activity but it is still a small fraction 25 '
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with, and so we still see that there are a few active 2
licensees and a number of others tha': have yet to involve 3
themselves in these risk-informed activities.
4 But still I think it is fair to characterize these 5
as technical matters.
They is significant progress because 6
the Staff and the licensees have been engaged in issues 7
which I think we weren't previously capable of dealing with 8
in an efficient manner, and I think we have had sort of 9
proof =that these things een done and can be done reasonably 10 efficiently and we are looking for additional examples in 11 the future.
12 Supplemental Slide 7 shows a list of activities 13 which are now in Research, previously the kind of activities 14 done in AEOD where operating experience is being looked at 15 through a risk-informed perspective, an important study on 16 initiating events, Westinghouse Reactor Protection System 17 Reliability Study, and substantial progress on reliability 18
' data in cooperation with INPO.
These are all important 19 steps forward in using more risk information in the 20-regulatory process.
21 I would also like to note that 12 additional 22 IPEEEs, the Individual Plant Examination for External 23 Events, were completed, and that program is progressing.
24 An important item that supports a number of these 25 areas is the ASME, ANS and the National Fire Protection ANN RILEY & ASSOCIATES, LTD.
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Association standards for the use of probabilistic risk i
2 assessment.
3 The ASME standard is in a draft stage.
We expect 4
by the end of the year to see that come out.
The ASME 5
standard deals with at-power Level 1 issues.
ANS has just 6
started up to deal with shutdown fire and some external 7
events.
There was recently a meeting in San Francisco to 8
kick the shutdown activities off.
9 I think the Commission knows that the ASME 10 standard has been somewhat controversial.
There have been a 11 number of comments.
I think that document is undergoing 12 some review and I think over the next few months we will i
13 have a better understanding of how comfortable the Staff is 14 on how that is sorting out, but that is an important issue 15 for streamlining and for the efficiency of using risk 16 information in the licensing and inspection and oversight 17 processes.
18 Recently there has been a Commission paper, 19 99-191, on the safety goal and I think there are a couple of 20 interesting thoughts in that paper.
One is the proposal for 21 high level safety goals so that the materials and the 22 reactor activities really are being informed by the same 23 sort of high level insights.
I think that is an activity 24 that will take some time but ultimately will help in 25 uni.fying the Staff's activities.
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In the Training area we have I think a solid 2
program.
3 The staff and technical managers, those courses, 4
'the 105 and the 107 courses are in place.
They've been 5
supporting the need for training very well over the last 6
couple of years.
Those seem to be working.
7 In the inspection area there's the P-111 course.
]
8 We are on track to have all the resident inspectors and 9
senior residents through that two-week PRA training course 10 by the end of fiscal 2000, and then by the end of fiscal 11 2001, all other qualified inspectors.
So it looks like the 12 program is in place, and that's moving along well.
13 In the materials area there have been a number of 14 significant activities, framework for risk-informing NMSS 15 activities summarized in SECY-99-100 and the material 16 review, and later on in the presentation Pat Rathbun will 17 speak to past, present, and future materials programs.
So I 18 think I'll leave it at that.
19 On viewgraph 6 I'd just like to spend a few 20 minutes on one of the major activities in the reactor area, 21 and that is the b*inging of risk insights into the reactor 22 oversight program.
I think it's fair to say both, it's both 23 a risk-informed and performance-based program, because it 24 makes much stronger use of performance indicators than the 25 previous inspection program.
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What I've highlighted here is how risk information 2
is worked into that program, just to remind the Commission 3
this is what was presented back in SECY-99-007 and 99-007A.
4 So we are now in the implementation or in the pilot 5
implementation phase of using safety cornerstones based on 6
. risk principles by using risk-informed and performance-based 7
approaches with performance indicators and inspection 8
insights relating to those cornerstones to identify the 9'
safety significance of inspection findings and of 10 performance indicators.
11-The pilot program is now under way, started back 12 in June.
There are still some developments going on in 13 parallel with that, but the process is being tested with 14 respect to testing the usefulness of performance indicators.
15 The significance-determination process, which is 16 an integral part of, you know, determining how important 17
. individual findings are, that's being tested, and I think 18 that the inspection, you know, methods and guidance are out i
19 there being tested as well.
20 So the program is on course, the actual in-field 21 test is being done through November, then there's a period 22 of.considering the insights learned from that process, and 23 hopefully we'll be in position to put that program in place 24 in the spring of next year.
And if you have any specific
\\
I 25 questions on the findings to date, I think some of our staff ANN RILEY & ASSOCIATES, LTD.
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are here and can cover those.
Otherwise we're prepared to 2
go on to risk-informing Part 50.
3 CHAIRMAN DICUS:
Go on.
4 MR. HOLAHAN:
Okay.
Scott Newberry.
5 CHAIRMAN DICUS:
Although we may come back and 6
address that question, let's go on now.
7 MR. HOLAHAN:
Okay.
I 8
MR. NEWBERRY:
Moving on to risk-informing Part 9
50, I'll cover our efforts on Options 1 and 2 as defined in 10 SECY-98-300.
We received an SRM from the Commission on the
)
11 SECY, and we put together an effort that I'll describe in 12 the next viewgraphs.
13 My point on viewgraph 7 is not to go through the 14 individual rulemakings that are ongoing right now, which are 15 included in Option 1, but basically we were told in the SRM 16 to proceed on these rulemakings, and we are doing so.
The 17 main point is that we're now proceeding in a structured way, 18 coordinating between the rulemakings listed there as part of 19 Option 1 and in Option 2, making sure that we're coordinated 20 as we move out to implement Option 2, that I'll talk about 21 in a minute.
22 Let's go to viewgraph 8.
A few points on how 23 we're tackling the Option 2 aspect of risk-informing Part 24 50.
I think it's fair to say that the effort is being 25 managed and staffed as a high-priority project.
A team has ANN RILEY & ASSOCIATES, LTD.
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1 been formed from all divisions in NRR with direct ties to 2
the other offices, certainly Research, OGC, Enforcement, the 3
regions, and NMSS.
4 Management oversight is provided by the 5
risk-informed licensing panel.
This.is a panel that's been 6
in existence, has been very beneficial in dealing with all 7
risk. informed licensing matters.
It's made up of division 8
management in NRR Research and OGC, and the panel is 9
actively involved in the Option 2 activity, providing 10 oversight guidance on I would say technical, sometimes 11 legal, and even management issues associated with the 12
. effort.
13 Ashok mentioned the PRA Steering Committee 14 previously.
He chairs the. committee.
It's an office-15 director-level committee that has already met a couple times 16 on risk-informing Part 50, primarily at this point to i
17 provide leadership and coordination and priority assign.nent 18 of resources.
We'll be involving ourselves with that
{
19 committee as policy issues develop.
20 The team that's been assigned to this activity and 21 the risk-informed licensing panel members have participated 22 in several public meetings.
To date those meetings will 23 continue certainly.
Purposes are to work very hard to make 24 our efforts publicly available, and I'll talk about some of 25 the work we've done recently there, and of course to receive ANN RILEY & ASSOCIATES, LTD.
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input from our stakeholders.
To date I think it's fair to 2
say that NEI with support of four pilot licensees have 3
provided most of the comment input.
The pilots are, and 4
Gary has mentioned one, South Texas, and then Arkansas F
Nuclear I, Fermi, and San Onofre.
6 Let's go to the next viewgraph.
7 On viewgraph 9 at the start we intend to provide 8
the' Commission a rulemaking plan by the end of October, as 9
requested.
We're working hard to do that.
On this 10 viewgraph I've listed the primary tasks associated with 11 Option 2.
12
'Just to step back, Option 2, as defined in 13 SECY-98-300, is the change of scope of Part 50 to a 14 risk-informed scope rather than a design-basis-oriented 15
. scope of equipment that receives special regulatory 16 treatment.
Special regulatory treatment is talked about in 17 that paper, but really refers to the highest order of
{
18 quality looking at harsh environment or seismic 19 qualification treatments like that.
We'll be working with 20 internal and external stakeholders of course and utilize 21 pilot activities and exemptions as appropriate.
22 The rulemaking plan is now being developed.
As I 23 said, it's due by the end of October, and we're in the 24 crunch of pulling issues together and approaches in that 25 rulemaking plan.
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-I do' list on the viewgraph some of the parts of 2
the plan which are important, and I'll talk about them here 3
briefly.
4 We're looking at approaches for revising the 5
terminology in Part 50.
We suggest one in 98-300, and as 6
you dig into it, you find out there could be others that 7
might be more efficient, and certainly effective, not just 8
changing the definitions to safety-related, but perhaps
'lternate definitions to better define what we're really 9
a i
10 doing.
And then you look at how to weave that into the 11 regulations in a clear and understandable way, and new ideas 12 are coming forward.
13 Our intent would be to put them in the plan and to 14 solicit, you know, stakeholder input on those approaches, 15 you know, which rules need to be considered in the effort.
16 We suggested some in the SECY.
As we dug into it we find 17 that there are more rules that would fall within the scope, 18 and at a public meeting on the 26th of August, we put our 19 first cut at those rules out into the public so that we 20-could receive input as early as possible.
Not just the list
'21 of rules.being important, but how did we determine which 22 rules, what were our criteria.
We've identified preliminary 23 criteria for determining which rules would need to be 24 risk-informed.
I think it's important to point out that we 25 now think we need to look beyond Part 50 Part 21, Part ANN RILEY & ASSOCIATES, LTD.
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54, Part 100, and then some of the appendices to Part 50 as 2'
well.
3 The methodology for reclassifying the equipment 4
based on its safety significance is gofng to be a very key 5
aspect of the rulemaking.
We're looking at that now, and 6
two of the key issues in my view right now would be to what 7
extent can we efficiently take advantage of preliminary 8
work'.
There's been scoping and screening of equipment done 9
to date as part of other efforts.
We need to look to see if 10-we can efficiently take advantage of that work, and of 11 course the review process itself, would each licensee have 12 to, you know, submit this to the staff for review, or could 13 we create a more efficient process for implementation.
14 As I said, our plan is to get the rulemaking plan 15 to you on schedule the end of October, and we're still 16 working to that date.
17 MR. HOLAHAN:
Can I have viewgraph 10, please.
18 In SECY 98-300 there were four policy issues 19 identified.
The first three of those are being dealt with 20 in an integral manner as part of risk-informing Part 50 and 21 on the same schedule.
Policy Issue Number 4 is really being 22 dealt with separately and has a September 30th Commission 23 due date and that is the issue of clarifying the Staff's 24 authority and having guidance for applying risk-informed 25 decision-making in those cases where the licensees have not ANN RILEY & ASSOCIATES, LTD.
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asked for and have not submitted risk information.
2 The Commission was recently sent a paper on the
~3 Callaway.electrosleeving issue, which also reiterated the 4
need for clarify in the Staff guidance in this area.
5 So the cases that are of relevance to Policy Issue 6
4 are ones in which-the licensees have submitted information 7
which appears to meet the deterministic regulations but for 8
which there may be'some risk implications that the Staff 9
wisher to deal with, and the question is what guidance and 10 what Stuff authority exists to do that.
11 We are currently developing a paper for the 12 Commission, due September 30th.
A draft is currently in 13 concurrence.
It was shared with the ACRS last month.
There 14' was an ACRS meeting earlier this month on September 2nd to 15 get their input.
A proposed approach was discussed with 16 both the PRA Steering Committee and the Risk-Informed 17 Licensing Panel.
18 The general approach that is being proposed and 19 will be sent to the Commission for approval uses the concept 20 of identifying special circumstances.
There needs to be 21 some reason why the normal deterministic regulations are not 22 providing the level of safety that was expected or 23 envisioned when the regulation was first written.
24 This is part of our desire to preserve the 25 presumption that the regulations under normal circumstances ANN RILEY & ASSOCIATES, LTD.
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provide adequate protection and simply meeting the 2
regulations is a way of showing that the plant is safe 3
enough and that license amendments ought to be granted.
4 We have seen that there are unusual circumstances.
5 In fact, we probably think of them as being rare 6
circumstances, under which new methods, new materials, a 7
different approach to an issue is identified, and it is 8
different from what the Staff and I think the Commission had 9
envisioned when a regulation was written, and so there is 10 the possibility that the regulation dealt with the way the 11 Staff would normally, with its existing guidance, would not 12 provide the level of safety that was desired.
13 In those cases we would go on to first identify 14 what is special about this case, secondly to use an 15 integrated decision-making process like that included in Reg 16 Guide 1.174, which includes both risk and deterministic 17 insights, to go on and use the guidelines in 1.174 to test, 18 as a screening test of whether adequate protection ought to 19 be questioned or whether it can be assumed for a given case, 20 so this is sort of a one-sided test.
21 If an application is consistent with the Reg Guide 22 1.174 guidelines, which is about the same as saying if the 23 licensee had submitted it as a risk-informed initiative it 24 would have been approved, so at that point I think we would 25 assume that something could be approved.
But if there are ANN RILEY & ASSOCIATES, LTD.
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unusual circumstances.and it is outside the guidelines of 2
Reg Guide 1.174, it would trigger the Staff to question 3
whether adequate protection would be preserved in that 4
license amendment, and at that point we would take all the 5
existing information into consideration -- deterministic
... 4 6
engineering insights, safety margins, risk insights, the 7
defense-in-depth implications, and also look at anything 8
peculiar to that case -- how long such a condition would be 9
in place, whether there were compensatory actions, what it 10 meant for an individual plant, and we would propose to 11 develop a safety decision based on all of those insights and 12 determine whether at that point a license amendment ought to 13 be granted or not.
14 Process-wise what we have proposed is to lay this 15 general approach out for the Commission for its approval.
16 If the Commission agrees or for whatever guidance the 17 Commission gives us we would then go forward and modify 18 office procedures, Regulatory Guides, Standard Review Plans 19 to be commensurate with that, and those documents would be 20 taken through the normal stakeholder process.
They would be 21 put out for comment, probably have meetings or workshops on 22 those.
They would go through CRGR, ACRS and the rest of the 23 process.
24 For the end of September we will be presenting a 25 paper with a general approach, looking for Commission ANN RILEY & ASSOCIATES, LTD.
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guidance.
2 One of the issues'that the Staff has been 3
struggling with somewhat is if or how the concept of cost 4
and cost benefit and the backfit rule can play a role in 5
this. process.
Normally license amendments are granted 6-completely separate from backfit considerations, but it has 7
been suggested that there may be some usefulness to that 8
concept and how that would work in is still an ongoing 9
thought.
It was discussed with the ACRS and we expect to 10
-have a position to bring to the Commission by the end of the 11-month.
12 With that, I think I have said everything on the 13 Slide 11 except perhaps that in this process we have 14 reconfirmed basically what we said in 98-300, which is it 15 doesn't appear that any rulemaking is necessary.
The f
16 Commission's authority and the Staff's authority to act on
. 17 -
risk information in the licensing process exists in the 18 regulations.. What we lack.is guidance documents on exactly 19 how to do that.
20 I would like.to turn the presentation now over to 21-Tom King to discuss Option 3 of risk-informing Part 50.
22 MR. KING:
All right, thanks, Gary.
23 What I am going t-o discussion the next several 24-slides is our efforts related to risk-informing the 25 technical requirements of Part 50. including the integration ANN;RILEY & ASSOCIATES, LTD.
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and coordination with the Option 2 work on the scope and 2
some of the key issues that are being faced in this effort.
3 In SECY 98-300 Option 3 is the study of technical 4
requirements.
Our plan right now calls for two products to 5
be developed under this Option 3.
The first is our plan to 6
do the study, which we owe to the Commission the end of 7
October.of this year.
8 That plan will be more than just a schedule.
What 9
we intend to have in that plan is a summary of the approach 10 we will take in doing the study, which we will discuss when 11 we get to the next couple of slides, the criteria we plan to I
12 use for selecting candidates for change, any of the key 13 issues that need to be faced as we go through this study and 14 certainly our schedule.
15 When we talk about technical requirements we are 16 talking about more than just the regulations.
Certainly the 17 regulations have some technical requirements in it but a lot 18 of the detailed technical requirements are contained in 19 Regulatory Guides and Standard Review Plans.
They deal with 20 things like analysis methods, assumptions, acceptance 21 criteria, and so'forth.
All of those are included in the 22 study when we talk about technical requirements.
23 The second aspect of this work is the study 24 itself.
What the study will include is it will identify 25 those area that are candidates for change.
It will identify ANN RILEY & ASSOCIATES, LTD.
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the scope of the changes that we would recommend, and again 2
that would include regulations or any changes needed to the 3
supporting Reg Guides and Standard Review Plans.
4 It would provide enough description of the work 5
done to establish the feasibility of making those changes.
6 It will identify any issues that need to be dealt with in 7
implementing the changes and the recommended priority.
8 We would play to provide this in a paper to the i
9 Commission for your approval and, as requested in the SRM
{
10 that approved proceeding with this study, if there are any 11 things that come out of this study that look like they i
12 should be proceeded with on an expedited basis, we wouldn't 13 wait until the end of the study.
We would bring those 14 forward on an individual basis for Commission approval.
15 In developing the plan and the study itself, we 16 are going to get stakeholder input and discussions with 17 ACRS.
In fact, next week we have a public workshop i
18 scheduled where we are going to discuss our plan for doing 19 the study and solicit feedback.
We have a meeting with ACRS 20 schedule the week after that, where we are going to do the 21 same thing.
We would expect to schedule additional 22 workshops and ACRS meetings as we get into the study and 23 have technical results to discuss.
If I could have Slide 24 13, please.
25' One of the key things we need to pay attention to ANN RILEY & ASSOCIATES, LTD.
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in doing the Option 3 study is maintaining close integration 2
and coordination with the Option 2 work.
To do that we are 3
maintaining a consistent approach in that we are going to 4
utilize the principles of Reg Guide 1.174.
In doing the 5
Option 3 study, we'll consider defense-in-depth, we'll 6
consider safety margins.
The way we are going to bring in 7
risk is to look at small changes around the plant's current 8
risk profile.
We are not going in and trying to drive 9
plants to some new level of risk in doing this study.
We 10 think that is certainly consistent with the Commission's 11 performance goal of trying to maintain safety.
12 We plan to retain the design basis concept.
Now 13 what we would envision is this would be, when we are all 14 done, a risk-informed design basis, but we are not throwing 15 away the idea of design basis accidents and so forth.
What 16 we want to do is make them consistent with what risk l
t 17 insights tell us.
18 Whatever the Option 2 activity comes up with in 19 terms of a risk-informed scope definition, I would certainly 20 think that would apply to the technical requirements as 21 well, so we want to maintain close contact and review that 22 in terms of its applicability to the Option 3 technical j
i 23 requirements.
24 Similar to Option 2, we envision the use of pilot 25 plants to test out some of these concepts and ideas for ANN RILEY & ASSOCIATES, LTD.
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technical changes to the requirements.
Slide 14, please.
2 There'are a number of issues that we are going to 3
have to deal with in doing both Option 2 and Option 3.
What f4.
I wanted to do is just give you an early indication of what 5
some.of these are'likely to be.
There is a certainly a 6
policy issue that remains on the plate that was in 7
SECY-98-300 and discussed in your June SRM, that has to do
]
8, with selective implementation.
If you recall, the 9
Commission felt that this issue, at the time SECY-98-300 was
)
10 provided, it was premature.to deal with this issue.
I 11 We agree with that, but we still owe you for both 12 the risk-informed scope and the technical requirements.
13 Should'all-risk-informed changes be implemented as a 14 package?
Should there be some bundling within, or should 15 licensees:be able to pick and choose the ones that they want 16 to implement?
17
.So as we proceed into this and get further along 18 and identify what these change are, we still owe you a 19 recommendation on that' issue.
20 Regarding implementation itself, what we are doing 21 is we are taking an approach that is looking at existing 22 requirements and how to' risk-inform them.
We are not 23 starting with a clean sheet of paper and rewriting Part 50.
-24 And, as mentioned previously, we are retaining a design
'25 basis concept and we are using the risk-informed principles ANN RILEY & ASSOCIATES, LTD.
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in Reg. Guide 1.174.
2 Technical issues.
One of the main ones is, what 3
are the criteria we are going to use for selecting the 4
candidate rule changes and proposing modifications to Part S-50?
6 Risk-informed regulation is a two-way street, so 7
there will certainly be criteria that have to deal with 8
current requirements that have'little or no safety benefit.
9 What do we do with those?
How do we get rid of excessive 10 conservatism?
But also aware, does the risk-information say 11 safety enhancements are justified?
12 If I could have Slide 15, please.
13 That will lead us to developing a set of criteria 14 to deal with those three aspects I just mentioned, and we 15 envision the criteria will be consistent with the agency's 16 performance goals in that we-will have criteria that will 17 address maintaining safety.
That, again, will get back into 18 using the Reg. Guide 1.174 considerations.
We plan to have 19 substantial stakeholder input, which we believe will help 20 enhance public confidence in what we are doing.
As I 21 mentioned, the workshops, ACRS meetings that are planned.
22 We envision cost benefit considerations will be 23 used as well as looking at areas where there is excessive 24 conservatism.
This would be considerations in reducing 25 unnecessary burden and also improving effectiveness and ANN RILEY & ASSOCIATES, LTD.
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1 efficiency of what the technical requirements are.
And we 2
would envision.using a performance-based approach where
~3 practical in making recommended changes to the technical 4
requirements.
5 With that, I will turn it over to Pat Rathbun, who
~
6 will discuss the NMSS activities.
7 MS. RATHBUN:
Thank you.
During my presentation 8
here.today, I will be.providing you with an update on the 9
status of NMSS efforts in risk analysis.
Before I move into 10 those details, though, there are two important points that 11 we need to keep in mind when we are looking at NMSS's 12 approach to risk analysis.
The first one is that we are 13 fully participating in the overall agency strategy to bring 14 the risk-informed approach into our regulatory and licensing 15
- activities.
Conceptually, our approach is based on and 16 closely parallels the approach taken by both NRR and 17
- Research as they develop and implement the PRA program.
18-Now, having said that, though, I want to note that 19 risk analysis methodologies used by NMSS in the past have, 20 for the most part, differed from traditional PRA approach 1
21 used by the resc of the agency.
Now, this is, of course, 22 due to the heterogeneous licensee base and array of nuclear 23 materials we regulate.
With one notable exception, and I 24 will talk about it in a minute, our approach is risk 25
~ analysis.
We do, and have started working on PRA, but I ANN RILEY & ASSOCIATES, LTD.
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just want to say upfront that this may not be too possible 2
for NMSS.
3 All right.
Having said that, I do want to go back 4
now and talk just a little about the work we have done in 5
risk analysis.
Most of this has been -- I need Slide 16.
6 Most of this has been done and briefed to you, but I just 7
want to quickly revisit it.
We have extensive experience in 8
using performance assessment.
By and large, this technique 9
was developed by the NRC and works well with the risks 10 associated with geologic disposal of high and low level 11 waste, and we believe in the residual site contamination 12 after decommissioning.
13 An early effort to apply risk assessment 14 methodology to the analysis of transportation risk is known 15 as the Modal Study, and I have referenced that for you in 16 the slide.
This is a study of and response to severe 17 accident highway and railway accidents.
We are considering 18 revisiting the Modal Study and taking a long look at the 19 methodology and the way this was approached.
It appears 20 promising.
21 Another technique which has worked for us is the 22 Integrated Safety Analysis, which, of course, is the risk 23 assessment technique developed by the chemical process 24 industry after Bhopal, and it has proven to be a good way of
'25 looking at hazards for us.
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In nuclear medicine,'we actually did try real PRA.
2 We_used PRA to look at the gamma knife, which bears some 3
parallels to engineered systems.
It has a hydraulic system 4
that can fail, leaving the patient exposed to risk.
It was 5
moderately successful, and we would have to take a look at 6
that, but always in the use of PRA, you have to remember 7
that it will not model human error effectively and most of 8
ours comes about in human error.
9 The Nuclear Byproduct Material Risk Review Group 10 has published for comment two significant NUREGs that are 11 noted in Slide 1.
This would be an extension and an attempt 12 to develop risk analysis for the fields of radiography, 13 nuclear medicine.and well logging.
It is a substantial 14 document and well worth your time.
15 Now, although NMSS had worked in risk analysis, we 16 had not developed a fully integrated approach.
With the 17 publication of SECY-99-100, a framework for risk-informed 18 regulation, and the direction that you gave us in the 19 subsequent SRM, we believe we now have laid out the 20 groundwork for carrying out an integrated program of risk 21 assessment.
22 If you could give me the next slide, please.
23 We have set out a five-step process.
Also I am 24 not going to go through that with you because it is very 25 close to what Tom just discussed with you, and I have ANN RILEY & ASSOCIATES, LTD.
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provided it for you in Background Slide S-8.
2 We are now11n the process of carrying out this 3
five-step process and trying to implement a risk analysis 4
approach that will also include risk management.
We are 5
working with a joint ACRS-ACNW subcommittee, and we are 6
working now -- that would go too far -- we are beginning to 7-look at the material safety goals and are quite excited 8
about the new paper Joe Murphy sent up to you and are 9
planning to work closely with him.
10 We also are working on an enhanced participatory 11 process and right now we have people -- Don Cool and Seth 12 Copelan will be speaking at the Organization of Agreement 13 States meeting this week.
We will be also speaking to the 14 fuel cycle licensing efforts and we are planning a 15 full-scale meeting in March, which would be the first of our 16 participatory workshops.
]
l 17 I guess we'll go on.
Ours is very short because
)
18 we'are really just beginning.
I want to go on to our recent 19 accomplishments which I have already touched upon.
20 You have approved the plan.
We have met with the 21 ACRS.
Most importantly though, we have formed a task force 22 to try to bring this activity to the forefront.
We have 23 formed a short-term task force, sort of similar to the one 24 we did for the DOE oversight task force and we plan to have 25 this in effect for about six months and we hope that this ANN RILEY & ASSOCIATES, LTD.
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.1 group, which is quite senior people, many of whom have 2
worked in risk analysis in the offices,_can bring this 3
together and lay out a framework.
We are then planning a 4
permanent organization in the Division of Industrial and 5
Medical Nuclear Safety.
6 I have already touched upon the publications, and 7
the last thing I want to mention is the Part 35 rulemaking.
8 We have worked very hard to try to make this a risk-informed 9
approach.
Thank you.
That concludes our presentation.
10 MR. KING:
Okay.
If I could have Slide 19, 11 please.
12 The Commission's August,'1995 PRA policy statement 13 expressed their desire and expectations for the use of risk 14 information in regulatory matters.
As you have heard, there 15 are a number of broad scope activities underway in the 16 program offices to implement this policy.
These are also 17 being carried out consistent with the agency's Strategic 18 Plan.
19 Integration and coordination are important to the 20 success of all of these activities, and that includes both 21 internal integration and coordination as well as external.
22 Such integration and coordination will lead to consistency 23 in approaches, goals, and guidance.
It will also facilitate 24 efficiency in the development of the infrastructure needed 25 to actually implement risk-informed regulation in NRC, ANN RILEY & ASSOCIATES, LTD.
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whether it is analytical tools, data, resources -- Staff, 2
contractor, training and so forth.
I 3_
Therefore we have several activities underway that 4
are directed toward helping to ensure this coordination.
5 What I wanted to talk about was three specific ones in that j
l 6
area, if I could have Slide 20, please.
7 The first of these is what is called a strategy 8
for risk-informed regulation.
GAO did an audit last year on 9
NRC's risk-informed regulation activities, and in their 10 March, 1999 report recommended that the agency develop such 11 a strategy.
The purpose would be to describe the overall 12 agency plans and approach for risk-informed regulation, a 13 road map, if you will, for where the agency wants to go in 14 risk-informing its activities.
15 That would include criteria for deciding what do 16 we want to risk inform, goals, approach, technical needs, 17 and so forth, for how we would do the risk-informing, and 18 the priority, resources, and schedule that would be used to 19 decide when we would risk inform these activities. Certainly 20 this would support implementation of the agency's Strategic 21 Plan.
22 Former Chairman Jackson wrote back to GAO and 23 agreed with this recommendation and said we would embark 24 upon developing such a strategy.
It was discussed briefly 25 in the most recent quarterly update of the PRA ANN RILEY & ASSOCIATES, LTD.
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Implementation Plan and we are committed in there to provide 2
to the Commission in mid-September an outline of this 3
strategy document, which is currently working its way 4
through concurrence up to the Commission.
5 The second major activity is what we call high 6
level safety principles.
These were discussed in SECY 7
99-191.
The idea behind those was that when we were looking 8
at the revisions to the Reactor Safety Goal Policy it was 9
apparent that a number of things that we were looking at in 10 that context were really agency-wide issues.
They weren't 11 reactor issues -- things like adequate protection, 12 defence-in-depth, regulatory analysis guidelines, the 13 concept of how safe is safe enough, and so forth.
14 At the same time we knew NMSS was working on their 15 framework and it occurred to us that perhaps it would be 16 useful to develop these set of what we call high level 17 safety principles to deal with these issues in an 18 agency-wide fashion.
They could then be used to provide 19 overall direction and consistency to all the agency 20 activities, risk-informed activities.
They could also be 21 used in the nonrisk-informed activities as well.
22 So we took a small effort to develop the concept, 23 discussed it with ACRS.
They said it was worth proceeding, 24 at least to look at the feasibility of doing this.
We 25 proposed to the Commission in the SECY to proceed and do the ANN RILEY & ASSOCIATES, LTD.
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feasibility study and come back to the Commission in March 2
with a recommendation in this area.
3 The third major activity is the revision to the 4
Reactor Safety Goal Policy, which again was discussed in the 5
It deals with a number of issues related to 6
reactors as well as the broader issues that we talked about 7
under the high level safety principles and it has to be 8
coordinated very closely.with the high level safety 9
principles where we owe the Commission recommendations on 10 these issues again in March of next year.
I would like to 11 have Slide 21.
12 In summar}, I just wanted to emphasize the key 13 points associated with our activities in the risk-informed 14 area.
15 One, that we are trying to systematically assess 16 and risk-inform our programs.
Certainly the plant-specific 17 activities will continue the progress made to date on, for 18 example, risk-informed licensing amendments.
It is not 19 going to slow-downed or terminated because of these 20 additional efforts.
We are trying to bring stakeholder 21 concerns in in all the areas that we are working in.
We 22 will bring issues to the Commission as they are developed.
23 As Mal said in his opening remarks, the work that 24 is underway now in these broad areas is going to result in 25 fundamental changes to regulatory programs and in doing that ANN RILEY & ASSOCIATES, LTD.
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clearly the theme you heard today is that integration and 2
coordination of these activities is very important to the 3
' success.
4 That concludes ~our briefing.
5 CHAIRMAN DICUS:
Okay, thank you very much.
6 I am going to ask a couple of questions and turn 7
it over to my fellow Commissioners, and one of the questions 8
is very philosophical, _and there are any number of briefings 9
at which I could probably ask this question, but it so 10 happens that I am going to ask it in this one -- as I said, 11 it's somewhat philosophical.
12 It is something that Tom King said when he talked 13 about one of the goals that we have is to maintain safety 14 and we are being.perhaps criticized a little bit by our 15 foreign colleagues who say you shouldn't maintain safety, 16 you-should promote and enhance safety.
17 Now also the industry from time to time tells us 18 that we keep raising the bar, keep making it tougher, 19 tighter, which would imply promoting safety or enhancing 20
- safety, 21-If we had the goal 10 years ago of maintaining 22 safety, would be a different agency today than we are, and
(
23 if you look forward to 10 years, if that goal is to maintain 24 safety, what differences do you see, if any, in how we might 25 respond and where the bar might in fact be?
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It is a very philosophical question.
If you want 2
to think about it, that's fair too, and if you want to think 3
about it until the next briefing, I'll bring it up again, 4
whatever that briefing may be, but anyway, does anyone want 5
to take a stab at it?
6 COMMISSIONER MERRIFIELD:
In three sentences or 7
less.
8 (Laughter.)
9 CHAIRMAN DICUS:
Right -- three sentences or less.
10 MR. HOLAHAN:
I'll take a stab at it.
11 MR. THADANI:
Go ahead, Gary.
12 MR. HOLAHAN:
I think it is an issue for everyone i
13 to think about.
It seems to me that when you establish a 14 goal of maintaining safety there are certain assumptions 15 that you must have about the maturity of an industry, about 16 how well you understand it both in terms of data and in 17 terms of methods of analysis, how comfortable you are with 18 the overall management structure, and things like that.
19 So I think if you go back a number of years, and 20 whether it is 10 or 15 I think probably the conditions 21 didn't exist -- at least personally in my judgment -- with 22 respect to licensee performance, the stability of their 23 management structures, the clarity of all of our 24 understandings of what the safety issues are, so I would 25 think probably at that point it wouldn't have been ANN RILEY & ASSOCIATES, LTD.
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appropriate to have such a standard.
2 Now how close are we now to being comfortable with 3
licensee performance and with having a clearer picture of 4
what is safety?
I think it is a goal that makes much more 5
sense now and I think it is not a b,. dea to raise this 6
issue at this meeting, because I think probabilistic risk 7-assessment in my mind is what brings a lot of those insights 8
to the table, to say I am now comfortable in saying I 9
understand the plants well enough to have such a goal.
10 However, I think that when you say " maintaining 11 safety" at least to me that means maintaining the level of 12 safety that you think you have, right?
You may very well 13 discover that some things aren't quite what you thought they 14 were and have to have safety enhancements or corrective 15' actions or something.
It doesn't mean that if we discover 16 problems we are not going to deal with them.
It means 17 maintaining the level of safety that the industry and the 18 Commission has come to think of it.
19 MR. THADANI:
If I may add to that, I completely 20 agree with what Gary said, and I think it is fair to say 21 that there is a lot of concern out there about what we mean 22 by maintaining safety, what do we mean by risk-informing our 23 regulations, and what are some of the implications in the 24 international arena, 25 I think it is very important for us, and perhaps ANN RILEY & ASSOCIATES, LTD.
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1 we don't do it well enough ourselves, to clearly say what do 4
2
. we mean by' maintain' safety?
It does not mean that we are 3
going to terminate some of the things we do, such as looking i
4 at operational experience, whatever work we are doing in the
]
5 Office of Research, insights that we get from various 6
arenas -- that we will look at those and we will.make i
7 determinations in accordance with the backfit rule to see if 8
any additional requirements should be imposed consistent 9
with the safety benefits as well as cost considerations.
10 Tom touched upon it in his discussions.
It is a 11 two-way street and perhaps we haven't articulated this 12 aspect enough to say our intention is not just to remove an 13 unnecessary burden using these techniques but we will not 14 stop looking for potential areas for improvement, but we 15 will take costs and benefits into consideration.
.16 I think I have also been contacted by a number of 17 people from other countries.
They raise the same kind of 18 issues, but what does it mean?
Part of my sense is, part of 19 it is the articulation of the broad safety philosophy and 20 not just getting hung up on what do we mean by the term 21
" maintain safety."
I am urging internally that we have to 22 keep bringing this sort of language in when we talk about 23 maintaining safety in order to make sure that there is 24 confidence -- not just the international community but we 25 have heard from some stakeholders in this country the same 1
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concern.
2 CHAIRMAN DICUS:
Okay.
Does NMSS want to add 3
anything to that?
4-MS. RATHBUN:
No.
5
[ Laughter.]
6 MR. VIRGILIO:
Chairman, I would add something to 7
that.
8 In addition to. maintaining safety, one of our 9
draft performance goals is also to look to look at 10 efficiency --
11' CHAIRMAN DICUS:
Right.
12 MR. VIRGILIO:
-- effectiveness and realism, and 13 within that I think what we are looking at is how do we 14 sharpen our safety focus so, while on the one hand, what we 15 are doing is maintaining a level of safety we are also 16 looking what are we looking at, what are we focusing on, how 17 do we focus our attention and our licensees' attention on 18 lwhat is most important from a safety perspective, so if we 19 are being criticized on one hand for just maintaining safety 20 I.think they are missing the complete picture, where we are 2 11 looking at other activities, other initiatives that would 22 sharpen the focus.
23 MR. HOLAHAN:
Can I add one thing?
24-CHAIRMAN DICUS:
Go ahead.
25 MR. HOLAHAN:
I hope this doesn't sound ANN RILEY & ASSOCIATES, LTD.
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inconsistent -- what I think.
2 CHAIRMAN DICUS:
I hope it doesn't either.
3
[ Laughter.]
4 MR. HOLAHAN:
I think you can have expectations of 5
increased safety while you have a regulatory program focused 6
on maintaining safety, and that is because our experience 7
'with Regulatory Guides, for example, where we said, well, 8
you know, licensees can use risk insights and they are 9
allowed to make burden reductions and risk increases, in 10 fact they are not out there looking for risk increases.
11 What we see is in fact on the whole that program has 12 resulted in safety improvements and burden reductions, so my J
13 personal expectation is even while we are risk-informing the 14 regulations consistent with maintaining safety, I expect 15 actually the plants to get safer because both we and the 16 licensees will understand them better.
17 CHAIRMAN DICUS:
And I agree and I will go back to 18 the transcript and copy down notes, so that I have got 19 answers to my foreign colleagues, but I appreciate that 20 input very much, and I think I have used up more than my 21 five minutes, so Commissioner Diaz?
22 COMMISSIONER DIAZ:
This is part of your time in 23 here.
24
[ Laughter.)
25 COMMISSIONER DIAZ:
If you look at page 15, I
~
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1 think what Chairman Dicus is bringing out when it says 2
" effectiveness, efficiency and realistic decision making /
l 3
excessive conservatism" -- meaning that we are going to i
4 eliminate excessive conservatism -- you can easily put
)
5 another bullet there, " safety enhancements" -- you know, 6
with due consideration of backfit or whatever it is.
It 3
7 makes a more complete picture.
8 Now I will start with my time.
9
[ Laughter.]
)
10
~ CHAIRMAN DICUS:
I am watching.
1 11 COMMISSIONER DIAZ:
First, I think I am viewing i
12 this briefing as kind of setting a series of positions 13 because I guess the meat of the information will be coming i
14 very rapidly to the Commission.
I understand that.
That 15 will have a significant amount of specificity.
16 A quick comment.
Somebody made a comment that 17 preliminary criteria for determining which rules should be 18-risk-informed, and that is really setting the stage of how 19 these things are developed.
I'd really appreciate getting a l
20 copy of that, because sometimes the Commission sees the end 1
1 21 result and we don't see the thought processes.
22 MR. NEWBERRY:
I'll take that action and get it to l
l 23 you today -- to all of the Commissioner offices.
24 COMMISSIONER DIAZ:
Appreciate it, and now that I 25 said that I realize that cornerstones are under development.
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I contradict myself and I'll ask a couple of questions.
2 Now first, there is a statement in Slide Number 10 3
that says Guidelines for Questioning Adequate Protection.
i 4
Of all of the things that I saw here to me that is a very j
5 fundamental and very major statement, because in reality to 6
enable to do that you are going to have to set hierarchies i
7 of call it safety or risk platforms that would allow us to I
8 eventually make regulatory decisions.
9 So I am very keen in seeing how these guidelines j
l 10 for the question of adequate protection develop.
I think 11 this is the fundamental work of the agency, and it might 12 have far more bearing on risk than many of the immediate 13 things.
14 I had a question, issue, no rulemaking necessary.
15 We are talking of what part of the work?
You know, because 16 eventually there is going to be some rulemaking necessary.
17 MR. HOLAHAN:
On the specific policy issue number 18 4 is what we are saying.
19 COMMISSIONER DIAZ:
Specific policy issue and that 20 is it, okay, in other words.
21 MR. HOLAHAN:
Right.
22 COMMISSIONER DIAZ:
And that is the short-term, 23 like March of next years, something like that?
24 MR. HOLAHAN:
I think what we said is -- well, 25 actually, what we owe to the Commission by September 30th is ANN RILEY & ASSOCIATES, LTD.
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both a plan and an interim position, and so what we will be 2
asking for is an approach.
I think the schedule will run 3
out,.probably -- I don't know that we have set it in 4
concrete yet.
But for. stakeholder input, something like six 5
or nine. months would not be unusual.
But we would also be 6
asking the Commission to approve the interim use of such 7
guidance if those cases were to come up.
8 COMMISSIONER DIAZ:
Okay.
9 MR. THADANI:
May I comment?
10 CHAIRMAN DICUS:
Sure.
11 MR. THADANI:
I think, as you correctly noted, it 12 a pretty complex issue, and it is also clearly linked with 13
.the hierarchy we have been talking about in terms of the 14 safety philosophy and coming down to safety goals and their 15 relationship with adequate protection.
So there are a 16 number of interrelated-issues that would require careful 17 deliberation.
18 COMMISSIONER DIAZ:
Thank you.
On Slide 13, 19 integration and coordination of Options 2 and 3.
I might 20 just bring up the fact that we are trying to use Reg. Guide 21 1.174 as a guideline, and that deals many times with changes 22 to the risk.
There is another envelope or another issue 23 which is, you know, what is the absolute value of where 24 things have been set.
So I just want to caution there are 25 times we don't want to take a square and try to put it P.NN RILEY & ASSOCIATES, LTD.
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inside a circle.
You know, the areas are outside of the 2
_ principles in Reg. Guide 1.174, and we want to be apprised 3
of which ones are those.
I don't know whether work is going 4
on on that, but'there is a difference in how you look at 5
these things.
6 MR. THADANI:
We certainly, under Option 3, we are 7
looking at -- you are correct, first of.all, but there are 8
issues beyond what is in Reg. Guide 1.174.
The intent of 9
that Reg. Guide was to deal with license amendments, as you 10 recall.
And what we are talking about now is significantly 11 broader applications, and we have to look at the whole map.
12 We cannot just look at the parts of core damage frequency 13 and large early release frequency.
14 There are two sides, if you were to draw a curve, 15 so to speak, the early part of the curve, that is, even 16 though there may be small accidents or small releases, small 17 events, one has to carefully consider how what we are 18 talking about, that is folded in.
If you were to look at a 19 frequency consequence curve, so to speak, two parts, or the 20 very first part of that curve, how are we going to deal with 21 that?
Very small events, they happen.
What frequency?
22 At the last PSA conference, Commissioner Diaz, you 23 were there and I was there, Brookhaven raised the issue.
If 24 the leak that they had, and the consequences that they 25 suffered as a result of the event, how would that be ANN RILEY & ASSOCIATES, LTD.
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considered as we sort of restructure the regulatory 2
philobupor?
So under Part 3, the options, we are going to 3
carefully look at the whole map and see what issues and how 4
well to integrate this.
5 COMMISSIONER DIAZ:
I do agree, it is a good base, 6
but it is just a base, and sometimes doesn't fit the 7
picture.
8 In the same slide, there is new statement in here, 9
risk-informed / deterministic requirements.
Again, the issue 10 of hierarchy will come into play.
Which one comes first?
11 Okay.
And that is.a major decision-making, because unless 4
12 we establish the hierarchy, you know, there will be a
]
- 13 tendency to just abide by what was existing, because that is 14 comfortable.
I think we need to at time challenge this 15 established hierarchy to be able to really become 16 risk-informed.
17 That is a comment, and then to NMSS, and I am not 18 criticizing, but the statement was made that PRA will not 19 model human errors.
I think you can say that it does not 20 presently.
But it certainly is quite possible that it will 21 model human errors, as long as we are willing to establish 22 the right distribution.
And that is one thing that, you 23 know, probably we will see in this Commission.
But it is a 1
l 24 major issue that will have to be addressed.
25 MS. RATHBUN:
I agree.
Thank you.
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COMMISSIONER DIAZ:
We will have to address the 2.
distribution.
3-And a question to-NMSS.
What-is the difference 4
between the NMSS task force and the NRR dedicated team?
The 5
same thing or different?
6 MS, RATHBUN:
I think that ours is very new and my 7
guess would be that it will be identical as it goes on.
8 COMMISSIONER DIAZ:
Okay.
Thank you.
9 MR. HOLAHAN:
Could I follow up on something that 10 Commissioner Diaz said?
11 CHAIRMAN DICUS:
Yes.
12 MR. HOLAHAN:
The thought that -- the sort of 13 which comes first thought about the PRA or deterministic 14 issues.
I am hopeful that at some point, and it may not be 15 close, but, ultimately, that the deterministic requirements 16 are sufficiently compatible and integral with the risk 17 insights that, in fact, there is no competition between 18 them.
19 For example, if you could imagine the Chapter 15 20 Safety Analysis Report, basically dealing with accidents in 21 the context, let's say of the success criteria that are used 22 in the PRA, then, in fact, you would have an arrangement in 23 which the deterministic analysis and the risk analysis were 24 so integral that you wouldn't have to worry about, you know, 25 which is more important than the other and where should I ANN RILEY & ASSOCIATES, LTD.
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-put my priorities, they, in fact, would be fully compatible.
2 Hopefully, we can get to such a point.
3 COMMISSIONER DIAZ:
Yes, that certainly would be 4
the ideal that we would like to do, but, first, we are going
-5 to have to move the immovable object with the irresistible 6
force.
]
7 CHAIRMAN DICUS:
Commissioner McGaffigan.
8 COMMISSIONER McGAFFIGAN:
My understanding, we are 9
. going to have a couple of rounds, is that 10 CHAIRMAN DICUS:
No, as many as we need.
11 COMMISSIONER McGAFFIGAN:
Okay.
Let me just try 12 to divide the questions up into rational groups then.
On 13 Slide 10, when, Mr. Holahan, you were talking about it, you 14 were talking about giving us this approach, and unlike on 15 Options 2 and 3, where there were stakeholder workshops and 16 all that sort of thing, what you talked about was getting us i
17 to conceptually buy into something and then Reg. Guides and 18 Standard Review Plans and stakeholder comment would follow.
19 MR. HOLAHAN:
Yes.
20 COMMISSIONER McGAFFIGAN:
But with us having 21 pretty much said how it was going to turn out, and I am 22 wondering whether we need stakeholder involvement at the 23 start on this conceptual approach you are laying out, or how is it going to be so conceptual that you can 24 much meat 25 hang anything on it during the later process, or is it going ANN RILEY & ASSOCIATES, LTD.
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to -- what is it we are going to be voting on?
2 MR. HOLAHAN:
No, I think it is not so vague that 3
it could mean anything in the future.
You know, here we s
4 have the problem of not wanting to go out for public comment i
5 on something that might be very different from what the 6
Commission would be comfortable with and, frankly, also have 7
a schedule which I think is not compatible with 8
stakeholder --
9 COMMISSIONER McGAFFIGAN:
Let me just ask you a 10 question.
11 MR. HOLAHAN:
So we have broken it into a two 12 stage process.
I 13 COMMISSIONER McGAFFIGAN:
I am learning from the 14 Callaway experience with the electrosleeving.
Under this 15 approach, whose burden of proof will it be if somebody gets 16 kicked into risk-informed space, having submitted a 17 perfectly straightforward deterministic amendment that would 18 have been approved?
Who has to do all the analysis and pay 19 for it and whatever if a staffer decides, through whatever 20 this process is, that this is a special circumstance, and, 21 by God, we need a much more elaborate set of analyses to 22 approve this amendment?
23 MR. HOLAHAN:
Let me say first that we expect 24 these to be unusual and sort of hand-wringing cases.
So I 25 don't expect individual staffers to be making the decisions ANN RILEY & ASSOCIATES, LTD.
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on these cases.
They are probably management decisions and 2
maybe even, you know, licensing panel or PRA steering 3
committees.
And I imagine it going through stages in which 4
when the' staff has a concern that there might be risk 5
implications to a license amendment request, that we would 6
first go and ask'the licensee to voluntary provide 7
additional information to address the risk significance of 8
the issues.
And if the licensee'does, you know, then I 9
think we have all the information on'the table to make 10 decisions.
11 If the licensee concit
.o that, no, they feel that 12 they meet the regulations, they meet the deterministic 13 regulations, they meet what it says in the book, and they 14 don't want to provide, you know, any additional information, 15 then the burden of proof is on the staff to determine that 16-granting such an amendment would be inappropriate.
In my 17 mind, unsafe is the same as not providing adequate 18 protection.
So that burden is on the staff.
19 COMMISSIONER McGAFFIGAN:
Okay.
20 MR. HOLAHAN:
That is the advice that we have 21 gotten from OGC consistently.
I think this where we are.
22 COMMISSIONER MERRIFIELD:
Commissioner, as the 23 lawyer at the table, I know we have had staff talking about 24 burdens of proof, which is a legal term.
Perhaps we may 25 want to just clarify that with our legal counsel and make ANN RILEY & ASSOCIATES, LTD.
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sure that they are consistent with that interpretation.
2 CHAIRMAN DICUS:
That is a good point.
3 MS. CYR:
That is correct.
I mean Gary is 4
recounting the advice we have given him.
If the staff 1
5 essentially proposes to deny the request on the basis of 6
additional information, they need to demonstrate that in l
7 terms of why they are proposing to.
]
1 8
COMMISSIONER McGAFFIGAN:
Okay.
And the worst
{
9 situation we get ourselves into, a denial request by the 10 staff -- you have a right to a hearing at that point, right?
11 CHAIRMAN DICUS:
Yes.
I 12 COMMISSIONER McGAFFIGAN:
So I think it is a 13 fairly profound set of issues that are in this paper.
- And, 14 as.I say, I am little bit concerned that, unlike the other 15 two areas where you have obviously had public workshops in 16 the last month, you haven't sat down and gone through it 17 with stakeholders, how this is going to work.
18 MR. HOLAHAN:
I think the staff would be 19 comfortable doing it either way.
The question is whether 20 the Commission is comfortable with us, you know, floating 21 proposals out before the Commission has seen them.
So, we 22 are prepared.
23 MR. THADANI:
May I comment on that?
24 CHAIRMAN DICUS:
Yes.
25 MR. THADANI:
Commissioner, I think it is clearly ANN RILEY & ASSOCIATES, LTD.
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linked, this issue is clearly linked to many of the other 2
things we have been talking about.
In the long run, it
-3 seemsJto me we would have input from stakeholders, 4
particularly if we move forward, if the Commission approves I
5 us moving forward with these high level safety principles.
]
6 There has to be'some link in relationship.
It would seem to 7
me that that would-require quite a bit of stakeholder input.
I 8
So in the long run, I think that is how we would end up.
9 COMMISSIONER McGAFFIGAN:
Well, the question is, 10 we are allowing them, I would point out, on Options 2 and 3 11 to talk about things that -- and, in fact, Nils asked 12 earlier for one them -- that we haven't fully approved.
I i
13 am comfortable with that in Options 2 and 3, that they have j
14 had these workshops, they are talking about what rules to 15
' change the scope of, et cetera.
I think that is fine.
I am 16 just questioning whether this area is not another area, 17 where some of the details, you end up fleshing out the 18 issues'that we really have to decide, as opposed to, you 19 know, having the debate after we have made a decision, and 20 the decision having a half life of a nanosecond.
I 21 CHAIRMAN DICUS:
Sam.
22 MR. COLLINS:
Sam Collins, Director, NRR.
The 23 staff appreciates your pod' Clearly, we need public 24 stakeholder input into thi; process.
It is a matter that 25 pivots on the schedule that the staff is on, which clearly ANN RILEY & ASSOCIATES,.LTD.
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the Commission can wrestle with.
I think there is common 2
ground and the common ground perhaps would be that the staff 3
provides, as a proposal, a paper to the Commission with 4
their preliminary thoughts.
That would engender the 5
Commission's comments, and the Commission could ask, and the 6
staff would propose to go out for public comment, not only 7
on the staff paper, but on those issues that the Commission 8
would believe, as a result of a preliminary review of the 9
paper, also warrants specific stakeholder input.
10 That has been a very constructive way to do this 11 in the past, because not only does it steer the staff into 12 the Commission's thinking, but it also prompts specific 13 response to those thoughts from the public.
14 COMMISSIONER McJAFFIGAN:
That is what we did in 15 the oversight process, sort of with IRAP, or whatever.
16 MR. COLLINS:
That's correct.
17 CHAIRMAN DICUS:
Okay.
Thank you.
18 COMMISSIONER McGAFFIGAN:
Have I already used my 19 five minutes?
20 CHAIRMAN DICUS:
Yes.
21 COMMISSIONER McGAFFIGAN:
I probably have.
I will 22 wait till the second round because I will probably go on to 1
23 different topics.
{
24 CHAIRMAN DICUS:
Okay.
Commission Merrifield.
25 COMMISSIONER MERRIFIELD:
The first thing, I want ANN RILEY & ASSOCIATES, LTD.
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to make a comment about the Chairman's I think very 2
thoughtful question and the consideration the staff made in 3
answering ~it.
I thought that was a good interaction, one 4
that I think we will continue'to grapple with over time.
5 Going back to Commissioner McGaffigan's questions 6
on Callaway, I am curious to see what lessons -- I mean that 7
was an effort, a strong effort on the part of the staff to 8
work through that.
What were the lessons that we have 9
learned from that, using risk-information in a regulatory 10 decision-making process?
And is interim guidance simply so 11' that we handle similar submittals in a consistent manner as 12 we move forward?
13 MR. HOLAHAN:
Well, let me take the second part 14 first.
We have a proposed approach for dealing with issues j
i 15 on the interim, but, in fact, we don't have Commission l
)
16 approval for that approach.
And the way the policy issue is 17 laid out in 98-300, I think the Commission called'for 18 approving such an interim approach.
So I woald say we are 19 at the moment --
20 COMMISSIONER MERRIFIELD:
So you owe us something?
21 MR. HOLAHAN:
We owe you something.
We are sort 22 of -- obviously, if another case were to come up shortly, we 23 would use our best judgment, but I think we would also feel 24 obliged to inform the Commission since it would be an 25 unusual case.
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With' respect to what we-learned from the Callaway 2
experience,-it was clear that we spent a lot of our time and 3
energy, and some of the licensee's energy, trying to decide 4
on the process and legal questions.
What is an appropriate 5
question?
Who has the burden of proof?
If this is to be 6
approved or disapproved, on what standard should that 7
judgment be made?
8 When we get to the point of having clear guidance 9
in place, hopefully our energies will be spent more on the
'10 technical issues, how much do we know about the sequences of 11 interest and the performance of the steam generator tubes 12 and those sorts of things.
13 There are a couple of other lessons learned that 14 mean that these issues by their very nature will be very 15 difficult to deal with.
One is when the burden of proof 16 comes on the staff to make a judgment about risk 17 implications, we don't have a Calloway probabilistic 18 risk-assessment model, so we're going to make those 19
-judgments based on the closest model we have, what insights 20 we can draw from looking at the licensee's models.
So we're 21 not as fully capable in terms of data and models available 22 as when the licensee volunteers information.
So that became 23 clear in the Calloway case.
That's a lesson learned.
24 Another lesson learned I think is if you meet the 25 current regulations and there is a risk implication, it is a ANN RILEY & ASSOCIATES, LTD.
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severe-accident risk implication, it probably has to do with 2L complicated phenomena, something that is by its nature 3
somewhat uncertain, and we're going to have to make 4
. judgments in a way that's different from the way we normally 5
do,.what guidance we will put in place will be process 6
guidance.
Okay?
The guidance that's in the regulations and 7
the requirements stated in the regulations I think will be 8
necessarily clearer than that.
Okay?
So we will be dealing 9
with issues of severe accidents, containment performance, 10' steam generator tube performance, things which we have less 11 experience and less technical information than, you know, 12 than the things we normally make judgments on the license 13 amendment process.
14 So they will be difficult by their nature, even 15 when there's more guidance in place.
16 COMMISSIONER MERRIFIELD:
As you are working ahead 17 on that interim piece, I suggest that rather than wait for 18 something else.to come in the door and force us to decide at 19 that point, which may slow down ourselves and the licensee, 20 getting what you think is the right resolution to that l
21 interim piece.and getting to the Commission in a timely 22 manner so it's ready in the event, perhaps not needed, but 23 in the event it's needed, if we have a request.
24 The second question I have, and I'm very hesitant 25 about doing these kind of things, but there is a story in ANN RILEY & ASSOCIATES, LTD.
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the August 16 version of "Inside NRC" indicating that 2
risk-informing Part 50 effort is "out of sync" because one 3
of the pilot plants, South Texas Project, filed multiple 4
exemptions well ahead of the other pilot plants.
5 I was wondering if you could share with us your 6
perspective on that.
7 MR. NEWBERRY:
My personal perspective is I don't 8
agree with.the characterization "out of sync."
I think it's 9
_in line with the process discussed in 98-300, and, you know, 10 having a licensee willing to offer up an approach using the 11 exemption process we talk about in the paper and talk about 12 in the Commission's SRM is going to be very, very helpful.
13 We had a very worthwhile meeting with South Texas 14 last week.
There was a two-day working meeting with their i
15 staff, and then there was a good meeting which Gary and I i
16 attended with their management on the difficult issues we're 17
-facing as the rationale for the exemptions, which are going 18 to be helpful in the rulemaking activity.
So South Texas l
19 will be different.
l 20 They're -- I think I should point out the thought 21 we have right now is that South Texas will not be a pilot in 22 the sense that they're going to be testing a proposed rule.
23 We don't have a proposed rule right now.
I mean, the South 24 Texas PRA has received considerable review.
They've had 25 proposals in here that have received considerable staff ANN RILEY & ASSOCIATES, LTD.
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So there will be obvious questions about whether 2
the burden borne by. South Texas is appropriate for someone 3,
else coming in under the context of the rule.
'4 So I think the other three pilots will be 5
different than the concepts of the South Texas exemption 6
request.
But no, I don't agree with.the characterization, 7
and I think the South Texas effort is going to be very 8
helpful.
9 COMMISSIONER MERRIFIELD:
Yes.
10 MR. HOLAHAN:
I would just add that I don't agree 11
'with the characterization either, and I think the staff is 12 sensitive to the point that the South Texas exemptions are 13 not identical with any rulemaking activities.
14-I think it was interesting in the meetings we had 15
'just last week that Scott referred to, what was most 16 enlightening were the questions, okay?
The questions that 17 were raised with respect to, you know, making decisions 18 about the South Texas exemptions are the same questions that 19 we have to answer in dealing with risk-informing Part 50.
20 The answers are not always the same, but I think the 21 questions are the same.
22 For example, South Texas is a very low seismicity 23 site, so some of their answers having to do with well, are i
24 we really worried about se'ismic qualification of this and 25' that, the South Texas answers are not necessarily ANN RILEY & ASSOCIATES, LTD.
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everybody's answers, okay?
But the' questions are the same:
2 How do I deal with seismic issues?
How do I deal with EQ?
3-So I think, you know, I see it as a very useful part of the 4
process.
5 COMMISSIONER MERRIFIELD:
I particularly think 6
they wouldn't be similar to San Onofre's answers to the same 7
questions.
8 MR. HOLAHAN:
Yes.
9 COMMISSIONER MERRIFIELD:
I just -- I raised 10 that -- some of you may have read that article and may have 11 been.left with a particular impression.
I thought it was 12 helpful to get a staff view on where that was coming from.
'13 I'll defer to the next round.
14 CHAIRMAN DICUS:
Okay.
One quick question, and 15 then I'm going to have to run.
It really follows on on what 16 Commissioner McGaffigan and Commissioner Merrifield have 17 been discussing, just taking another little part of it.
18 It has to do when we do get an amendment request 19 that we have difficulty dealing with and how better we might 20 be able to deal with those, and I'm referring to SONGS and 21 the hydrogen recombiner.
What should have been or appeared 22 to be on the surface a fairly simple amendment request 23 became a very complicated situation that we really had I 24 think a little bit of difficulty dealing with.
Would any 25 one of you care to address that, what the issues were?
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MR. HOLAHAN:
Well, the San Onofre hydrogen 2
recombiner I think, although technically it appeared to be a
.3 simple issue --
4 CHAIRMAN DICUS:
But there was a policy issue 5
involved as well.
6 MR. HOLAHAN:
There was a policy issue, and 7
there's a set of regulations involved, and I think what 8
San Onofre basically came to us with an insight'that said 9
hydrogen recombiners don't really provide the level of 10 safety that one might imagine, okay?
For design basis 11 accidents they're really not needed, and for severe 12
-accidents,.they really don't handle all, you know, that much 13 hydrogen.
So they don't really make a lot of difference.
14 And yet we have a regulation in part of 50.34 which 15 basically treats hydrogen recombiners as being important, 16 okay?
- 17 So we have a technical issue, but we also have, 18 you know, a policy and procedural issue, and I think we also 19 have a public-confidence issue, how is it that we're now 20 going to say what we put in the regulations, thinking that 21 it was important, is now not really what we thought it was.
22 So I think the licensing and certainly parts of 23 the industry felt that perhaps we took too long and spent 24 too much time _getting into the details of these issues, and 25 that it should have been done, you know, quickly and easily.
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I guess I -- well, anything can be more efficient.
I would 2
say that.
But I think these sort of issues really, really 3
do' require us to get to the heart of the details to ask the 4'
licensee hard questions, you know, to explain in our safety 5
evaluation reports, you know, you know, why what we thought 6
was important before is not really important now, and to 7
really lay out that logic in some detail.
8 Frankly I think we're having the same experience 9
on the decommissioning discussions with the industry,.that 10 things which some people feel are rather, you know, minor 11 issues and can be dismissed easily I think the staff feels 12 that, you know, they deserve a full airing, careful 13 analysis, yes, that does stretch out the time frame 14 somewhat, but I think it's an important part of the process.
15 CHAIRMAN DICUS:
Yes.
I think we need just to be 16 sure we're always shepherding that process and don't take it 17 out unnecessarily.
I mean, I don't want us to take 18 shortcuts, either, and I appreciate the seriousness the 19 staff gives these things.
When we can look at these what 20 appear to be simple but become very complicated that we 21 always try to monitor ourselves well.
22 Thank you.
23 Commissioner Diaz?
24 COMMISSIONER DIAZ:
A second round?
25 CHAIRMAN DICUS:
You don't have any?
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COMMISSIONER DIAZ:
I did my first, second, and 2
third round.
~3
. COMMISSIONER McGAFFIGAN:
Okay.
Well, you're 4'
going to get a few more from me.
5 The. SONGS issue, I might as well just, you know, 6'
follow up, and that was one I was going to ask.
7 In the end, you know, when Senator Domenici was
.8 out there, I believe you-guys were described by the SONGS 9
staff as trying to hold onto things.
In the end, did you 10 put any conditions on, or can they just take out the 11 recombiners at this point?
At one point, you know, it was 12.
alleged that you guys were going to say yes, you don't need 13 them for 50.'34, but we're going to cook up this other reason 14 you need them, and maybe you don't have to test them as much 15 or something, but you were holding on is where you were 16 circa the spring.
17 MR. HOLAHAN:
The agreement we've come to I think 18 has -- the only holding on that you might ascribe to it is 19 the fact that the licensee has indicated their intent to 20 keep the recombiners in the plant to keep them in their 21 accident-management program, which is both of those are 22 voluntary activities the licensee maintains in their 23
. commitment management program, and the only regulatory 24 oversight of that activity is the licensee has agreed to 25 inform us if they change their mind and decide to remove the ANN RILEY & ASSOCIATES, LTD.
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'l recombiners.
They are under no regulatory requirement to 2:
maintain the recombiners in place, but they have put on j
3' their. docket their expectation to keep them there.
And so I
'4 think'this is basically consistent with the way they treat 5
other. equipment associated with severe accident management 6;
guidelines.
l 7
Remember, the Commission didn't write a 8
severe-accident rule, the industry. volunteered to have, l
9 among other things, severe accident management guidelines.
10 We've' looked at those, but that is a voluntary commitment on
.j 11 the part of the industry, and so they would maintain this
/
12 equipment as they maintain other, you know, nonsafety 13 equipment for use in their voluntary severe accident 14 management programs.
15 COMMISSIONER McGAFFIGAN:
Was their original 16 proposal to simply delete the recombiners?
17 MR. HOLAHAN:
Their original proposal was -- I 18 would categorize it as to remove it from regulatory 19 controls.
20 COMMISSIONER McGAFFIGAN:
So they succeeded --
21 MR. HOLAHAN:
They succeeded in doing that.
I 22 don't think they ever had an intention of removing the i
23
' equipment.
In-fact, it would probably cost more money to 24 remove the equipment than to leave it in place.
25 COMMISSIONER McGAFFIGAN:
I'd like to do a couple ANN RILEY & ASSOCIATES, LTD.
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quickEquestions, and then I'll get to a big one that may 2
take more time.
3 You've mentioned decommissioning a moment ago, and 4
that wasn't in the PRA plan.
5 MR. HOLAHAN:
Right.
6 COMMISSIONER McGAFFIGAN:
We are characterizing it 7
in a paper that's before the Commission at the moment as an 8
attempt at risk-informing decommissioning.
Should that be 9
part of this effort?
I mean, should it be, you know, copied 10 in the next PRA implementation plan as something you're 11 following?
12 MR. HOLAHAN:
I would think so.
It seems
-13 appropriate.
14 COMMISSIONER McGAFFIGAN:
It's just bookkeeping.
15 A second issue, last week's "Inside NRC" or 16
" Nucleonics Week" or whatever mentioned a I think it was a 17 Farley amendment.
I don't have it in front of me.
I'm 18 doing this from memory.
19 MR. HOLAHAN:
Yes.
20 COMMISSIONER McGAFFIGAN:
It had to do with 21 checking steam generators and whether they needed to do an 22 outage partway through their cycle, and it said in the 12 3 article that this was a risk-informed licensing action, and 24 that but for risk insights you wouldn't have granted it.
At 25 least I think I'm quoting the article right now.
How come ANN RILEY & ASSOCIATES, LTD.
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'that isn't listed as a risk-informed licensing action in 2
your slides at the back?
3 MR. HOLAHAN:
Probably because -- I'm not sure it 4
was a licensing action.
But I don't remember the exact 5
format of it.
And also it might have taken place since 6
August, which may just be timing.
7 COMMISSIONER McGAFFIGAN:
But it would have been 8
in process, unless they -- I mean, these things take some 9
time to make a decision like that.
10 MR. COLLINS:
It was a licensing commitment?
11 MR. HOLAHAN:
I guess it didn't raise to the level 12 of a license amendment.
It was a licensee's original 13 commitment that they wished to change.
l 14 MR. SHERON:
Brian Sheron from the staff.
The 15 licensee had a commitment to shut down for a mid-cycle 16 inspection, and so this was already scheduled.
The licensee 17 then came in and proposed this to alleviate the mid-cycle 18 inspection.
So it wasn't really a license amendment in that 19 sense, it was to get relief from a previous commitment.
20 COMMISSIONER McGAFFIGAN:
I'm going to use my five 21 minutes, Mr. Chairman --
22 COMMISSIONER DIAZ:
No problem.
23 COMMISSIONER McGAFFIGAN:
But can somebody explain 24 how the -- I still haven't got to my big issue -- anybody 25 can explain how we do the license commitment process?
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mean, you know, there's a lot of analysis that goes into 2
this, or -- and how do you -- obviously it's not a public 3
process, but how does a license commitment relief request 4
work?
Maybe the general counsel --
5 MR. HOLAHAN:
Except for the legal aspects of 6
hearing rights and stuff like that, I think the technical 7
review looks very much like a license amendment.
Same sort 8
of technical issues.
9 COMMISSIONER McGAFFIGAN:
Same sort of thing.
How 10 long did this one take?
11 MR. SHERON:
This one took a little bit longer 12 than normal because the quality of the information that the 13 licensee submitted was not up to par, basically, and we went 14 back to the licensee and asked for more information, better 15 information.
I believe they even made some mistakes in 16 their analysis, which we found, and once we got that all 17 sorted out, they gave us better information that was 18 acceptable to the staff.
19 COMMISSIONER McGAFFIGAh:
Okay.
Have I already 20 used my five minutes?
21 COMMISSIONER DIAZ:
I don't know.
It depends on 22 what clock you're using.
23 COMMISSIONER McGAFFIGAN:
Can I -- let me just try 24 one big question.
This goes back to Mr. Thadani.
You know, 25 early on in your slides you talk about the CSAS process and 1
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its, you know, desire for a safety philosophy to be 2
established.
3 You know,,I participated in that with you, and my 4
recollection of the safety chapter was that it was one of 5
the more tortured chapters in the study.
I was proud to get 6
a sentence into it that said, you know, the clear, concise 7
definition of safety they were looking for might not be 8
possible in a deterministic framework.
That was my 9
contribution to the chapter.
10 And in the end all they asked for at the end of that 11 chapter, I mean, they seize on the oversight program --
12 MR. TEADANI:
Yes.
13 COMMISSIONER McGAFFIGAN:
And say the oversight 14 program looks like finally because of the performance 15 indicators it is providing some definition of safety, and 16 let's stay the course on that.
They did not ask us to go 17 off and do big, you know, core damage frequency safety goals 18 or safety principles.
19 In fact, I'll get to that in a moment, they 20 basically came -- they're looking for clear, crisp guidance.
21 They want the licensing reviewer, you know, to always reach 22 the same judgment, you know, have a -- I think they want, 23 you know, almost a risk-based sort of thing at times, but 24 David Lochbaum's involved in this, he doesn't believe PRA, 25 as he said at the end of the PRA chapter, is up to snuff, ANN RILEY & ASSOCIATES, LTD.
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and we shouldn't be barging ahead on risk-informed 2
regulation.
But they all want a clear definition of safety.
3 The safety-goal stuff that you guys are proposing 4
in 191 is not what they're looking for.
It is more -- I 5
mean, if I'm Forrest Remick or David Lochbaum and I read the 6
appendix -- I had it out here a moment ago -- these 7
overarching safety principles, and they're going to say, you 8
know, in all frankness, this is mush, this will not help 9
somebody, you know, individual members of the public should 10 be provided a level of protection such that they bear no 11 significant additional risk to life and health.
And they 12 say well, gosh, you guys have already done better than that 13 in Part 20, you see, of 100 millirem per year public dose 14 limit.
At least I can judge something against that.
15 So, you know, this is more me making a statement 16 than asking a question, but I'd be interested in Ashok's 17 response, because he was there, I didn't sense the CSIS was 18 asking us to go off and write overarching safety principles.
19 What they're looking for is consistency in making bite-size 20 decisions, and they're seeing it in the oversight process.
21 They think an inspector at Plant X and an inspector at Plant 22 Y because of the significance determination process that's 23 built into that now that we're going to reach similar 24 findings about an inspection finding.
They think that the 25 results are going to be similarly assessed in the asaessment ANN RILEY & ASSOCIATES, LTD.
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process.
So there's some confidence there which we'll have 2
to demonstrate through the pilots and demonstrate if we go 3
ahead that that program is going to be consistent.
4 Taen when they look at licensing actions they want 5
to -- they're.looking for every licensing reviewer to look 6-at a license amendment, you know, and basically say this 7-one's good, this one's bad,~and have a framework that's 8
understandable.
And they see some hope, some of them -- I 9
mean, Remick sees hope in risk-informed regulation in giving 10 that licensing review' consistency; Lochbaum doesn't, at 11' least until-we have~very high-quality PRAs.
So what's what?
12' MR. THADANI:
Well,.I think --
13 COMMISSIONER MERRIFIELD:
In three sentences or 14L less.
15 MR. THADANI:
I think first of all --
16
[ Laughter.]
17 I think we reflected very well on the discussions 18
'and the deliberations that went on.
You might recall -- and 19 by the way, I think it's broader than just what CSIS said.
1 20 We recently at the reactor -- or in our strategic plan 21
~ stakeholder meeting the same issue came up.
There is a i
22 continuing need it seems that the Agency's safety-23
~ requirements, and let me say in terms of what's adequate l
24 protection and what's considered under cost-beneficial 25 requirements and so on, are they clearly understood by all ANN RILEY & ASSOCIATES, LTD.
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1 parties and consistently applied.
As you said, that was the 2
theme.
Do people-understand clearly what the expectation
-3 is, and the actions that are taken are consistent.
4 There's a lot of debate, as yti recall, of what 5
gets folded under so-called " adequate protection" 6-
. definition.
A number of issues, from operating experience, 7
the concern was the industry having to respond under 8
adequate protection.
This doesn't meet Rule XYZ, and you 9'
need to respond or a group of plants need.to respond.
10 There was a need in that sense what the Agency's 11 actions are going to be and how they might relate to either 12 adequate protection or beyond adequate protection in terms 13 of backfit-rule considerations.
'14 In ordec to provide some consistency, the request 15 seems to be to come up with better articulation of what we 16 mean by adequate protection.
I completely agree with you it 17 cannot.be numerical.
I personally don't think it can be 18 numerical.
That truly would be risk-based.
And there are 19 lots of issues there.
But that doesn't mean that the risk 20 information can't play a part, perhaps under subordinate 21 basis, in some better articulation of safety goals -- I 22 mean, adequate protection.
23 The group clearly was satisfied with the direction 24 of the oversight reactor, oversight program, and the 25 cornerstones, and that they provide partial so-called --
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maybe I should -- I'll use the term definition of adequate 2
protection, but that there are many other areas beyond that.
3 Reg Guide 1.174 doesn't really address the issue 4
of adequate protection.
While I don't think one can have 5
clearly defined sort of numerical guidelines, but it seems 6
to me that expanding on what is in Reg Guide 1.174, taking 7
into consideration the factors that are discussed in Reg 8
Guide 1.174, such as defense in depth, margins, and so on, 9
if we can develop what I call subsidiary criteria for those, 10 it may provide a little better consistency in the way we 11 conduct all our activities.
This is the sort of attempt --
12 perhaps the language is not clear -- that's what we were 13 talking about attempting to do under the high-level safety 14 principles.
This would be one piece of that.
15 COMMISSIONER McGAFFIGAN:
If I might defer.
16 COMMISSIONER DIAZ:
All right.
I'm just going to 17 make a comment on that.
Rather than subsidiary, which might 18 look at a series of thresholds, you probably mean a series 19 of subsets.
20 MR. TEADANI:
There are subsets.
And in fact if 21 you recall the ACRS paper on defense in depth which talked
\\
22 about rationalist and the structuralist and somewhere in 23 between, I will admit up front I'm somewhere in between 24 myself.
But the idea, the concept there was as George 25 Apostolakis certainly talks about it, that you can stay --
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you have to have some kind of hierarchical arrangement at 2
some point.
3 And I sort of agreed with what I think you said I
4 earlier.
The challenge is going to be to what extent these 5
numerical calculations would be utilized to support the 6
concepts of margins, defense in depth, and so on.
I don't i
7 know what the answer is, but I do think that we won't be 8
able to come up with a concise definition -- that's what 9
CSIS was initially looking for -- a concise definition of 10 adequate protection.
But I think.we can do better in 11 responding to some of the concerns that various stakeholders 12 have raised.
13 COMMISSIONER DIAZ:
Okay.
Thank you, Commissioner 14 Merrifield.
15 COMMISSIONER MERRIFIELD:
Although I'm relatively 16 young now, I'm certain later in my life I will appreciate
)
17 the ability to stretch five minutes as long as we did.
3 18
[ Laughter.]
19 Okay.
Two quick questions on slide 4.
The first 20 bullet on slide 4 says substantial staff and management 21 attention has gone into our risk-related work.
I guess my 22 question is do we as an agency have the sufficient expertise 23 in the area of risk to carry out the plans laid out in 24 SECY-98-300, or will we be relying substantially or to any 25 great degree on contractor support?
And if we are, are we ANN RILEY & ASSOCIATES, LTD.
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taking the steps necessary to improve our internal 2
capabilities in the area of risk?
3 MR. THADANI:
Let me give you -- I think each 4
office may want to speak to this issue, but first and 5
foremost, within the Agency we have very good capability in 6
terms of background, understanding, and knowledge of not 7
just the use of risk information but also in terms of risk 8
analysis, the conduct of analyses themselves.
Oftentimes, 4
9 if there are some unique aspects that come up, it might have 10 something to do with better understand seismic hazards, 11 probabilistic assessments, and so on, or in some cases 12 fire-risk analysis.
Oftentimes we find that we don't have 13 in-house capability to the degree that we need.
We would go 14 through contractors in those areas.
But by and large -- I 15 think NMSS may particularly want to comment on this -- but 16 by and large I think we have fairly good capability at the 17 Agency.
18 MS. RATHBUN:
We have somewhat limited capability
.19 at this time in risk analysis, and by and large we've put 20 those people together into the group.
As we move forward, 21 we will have to use contractor assistance, and fortunately 22 we know them and, you know, we're aware of that.
As we move l
23 into the longer term, I believe we will need to hire some l
24 experts, but I've also begun the training program, begun to I
25 look at it.
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I also attended some of the PRA classes and am
'2 looking specifically to how we'll modify-them for NMSS.
3
.We've tried it in the past actually over time, and it's not 4
so difficult to modify it, but you have to realize that 5
NMSS, like the-inspectors of the past, thinks 6
_-deterministically, and so this requires a large culture 7
change as well'as specific expertise.
So we're starting
-8 that right now.
9-MR. VIRGILIO:
Just to give you some more concrete 10 examples, if I think about some of our activities.with Part 11 70 and the ISA work we are doing there, we are doing that 12 mostly with our Staff in-house.
On the other hand, if I 13 think.about what'we are.doing under Part 63 with the total 14 system performance assessment, that is a mix of both l
15 in-house Staff and the Staff we have at the center that is 16 helping us do the review successfully there.
.17 It is a mix.
I think it will be a mix for some 18 period of time until we can do what Pat is talking about, 19 getting more in-house expertise.
20 MR. HOLAHAN:
Can I just add from NRR's 21 perspective, I think in the last about five years we have 22 hired a number of well-known and very experienced experts in 23
.the probabilistic risk assessment area, so I think we have i
24 addressed one piece.of the issue, which is to have at least 25 a core of very expert, actual experienced people who have, i
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you know, actually earned a living at doing probabilistic 2
risk' assessment.
3 The-other part of the challenge is the other 99 4
percent of the NRC needs to be trained, and I know that NRR 5-and Research have been putting our Staffs and the regions 6
have been putting our Staffs through training programs for 7
the Staff and management, and at'this stage it seems to me 8
that the larger challenge is training and the interest in 9
commitment of the Staff versus having a core of experts who 10 are capable of carrying the ball, so I think we have done 11 part of it.
12 The training part I think will be just a 13 continuing effort, to bring everyone up to speed.
14 MR. THADANI:
May I add to that --
15 COMMISSIONER MERRIFIELD:
I have another question.
'16 MR. THADANI:
Just quickly --
17 COMMISSIONER MERRIFIELD:
Okay.t 18 MR. THADANI:
-- that the idea of risk analysis as 19 such is qualification part, fundamental understanding, 20 transient analyses, accident analyses, thermal hydraulics, 21 and so on.
That is a key.
If one doesn't fully understand 22 how these plants behave under different conditions than in 1
23 fact one would not understand the end results.
24 At the agency we have a very large number of 25
. people, I believe, who really understand well how these ANN RILEY & ASSOCIATES, LTD.
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plants behave, and then the issue is quantification and 2
understanding what those calculations might imply and that 3
is'an importantlpart.
4 COMMISSIONER MERRIFIELD:
And that is.a very good 5
point-you add.
6-Turning to Slide 5, _it lists some risk-informed 7
licensing activities.
What mechanisms do we have in place 8
to ensure that we as an agency handle similar risk-informed 9
licensing actions in a consistent manner?
Does that fall on 10 the shoulders of the Risk Informed Licensing Panel, or is 11 formal guidance in place to ensure a level of consistency?
12 MR. HOLAHAN:
There are several pieces of the 13 answer.
14.
It is not the Risk Informed Licensing Panel.
I 15 think the Risk Informed Licensing Panel' deals with cases on 16 an exception basis.
If there is a difficulty or some 17 identified problem, then the Risk Informed Panel would be.
18 called into place.
19 As a routine activity the first level of activity l
20 for assuring consistency is that we have a Standard Review 21 Plan so the reviews are done by the Staff using the same 22 guidance document and they are trained in the same training i
23 program.
Those reviews also get at least one or two levels 24 of management attention.
Those risk-informed licensing 25 reviews normally are signed out at a Branch Chief level so ANN RILEY & ASSOCIATES, LTD.
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that they will have Section Chief and Branch Chief.'.evel of 2
review.
3 In addition to that, and I would say that is a 4-sort of normal 1 activity where you have a guidance document, 5'
Staff training, management oversight, so this is done not 6
veryl differently from what we do for other types of 7
technical-Staff reviews.
8
'In the future NRR is moving in the direction of 9
putting a work planning group into place which would also 10 help to identify similar past activities so that when work 11 first comes in, it would be identified as being similar to 12 some other piece of work.
It would be looked at by a 13 planning group to identify where it should go, what kind of 14 issue is it, what you would normally expect in terms of 15 Staff resources to be applied to such a case, and I think 16 that will probably help in our' consistency also.
17 COMMISSIONER MERRIFIELD:
That's positive.
I know 18 this Commissioner, certainly this Commissioner has commented 19 frequently on the issue of the need for consistency where 20 you have similarly situated parties and the way in which we 21 are judged by our stakeholders and others will be based on 22 our ability to act in that kind of manner so I compliment 23 the Staff for focusing on that.
I have no further 24 questions.
-25 COMMISSIONER DIAZ:
Other questions?
Commissioner ANN RILEY & ASSOCIATES, LTD.
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McGaffigan?
2 COMMISSIONER McGAFFIGAN:
Just following up on the 3
last question, the paper before us, 191, in the Safety Goal 4
Policy Statement, my fundamental question is is it worth the 5
effort?
I think I saw a Staffer in one of the trade press 6
quoted as saying it is going to be controversial, resource 7
intensive and perhaps unnecessary.
8 I question what it contributes to risk-informing 9
Part 50 or trying to get on with making consistent judgments
)
i 10 on licensing amendments or any of that given how long it j
l 11 took us to just work on the definitions -- I see Gary about 12 to answer -- and just work on the definitions paper --
{
t 13 risk-informed, performance-based regulation.
14 I can see this effort taking a very, very long 15 time, and unless it really is going to help you do something i
16 that you otherwise wouldn't be able to do, fixing Reg Guide 17 1.174 or choosing the rules to change the scope of or 18 whatever, I just question the value of the whole effort if 19 it is going to be controversial, time-consuming, and if from 20 the get-go we are saying it is perhaps unnecessary.
21 MR. KING:
Let me try and take a stab at that.
22 I think from the standpoint of the reactor 23 risk-informed licensing activities, they are out ahead of 24 other activities in the agency, risk-informed activities.
I 25 think developing the set of high level safety principles ANN RILEY & ASSOCIATES, LTD.
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79 1-will probably not have too much of an effect on the reactor 2
aspects of risk-informed regulation, but I do think that 3
they are worth at least spending a little more time to see 4 ~
what can come out of it in terms of what these things would 5
look like and how they would be useful and beneficial to the 6
-agency, and I think where they'would be useful and 7
beneficial is in providing guidance to the nonreactor I
J 8
activities, so that'there is some consistency in approaches, i
.9
-in issues, in criteria that are applied there.
l 10 Now maybe when we are all done we will end up with j
1 11 a drill in a dry hole.
I don't know, but I am not convinced 12 yet that I am willing to go that far at this point.
I 13
.MR. THADANI:
If I may also make a point.
I asked 14 Joe Murphy -- I believe he was the one who was --
15 COMMISSIONER McGAFFIGAN:
I think it might have 1
16 been him in the paper --
17 MR. THADANI:
I asked Joe Murphy and he indicated 18 to me that that is not what he said, that it wouldn't be 19 useful.
He did say it is going to be difficult, and I 20 believe it is going to be difficult, but if we are going to 21 change the structure of our regulations, then there needs to 22 be again I would say clearer and consistent understanding on 23 the part of all stakeholders as to what is it that we are 24 going to use'to change'the structure, how well have we 25 considered some of the difficult issues.
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I mean an example is in the paper -- land 2
contamination.
Is that included?
Is it to be included or 3
not?' It is clearly an important issue -- has to be i
4 considered.
Whatever the ultimate decision is, we need --
5 our view certainly was that we need to lay out these issues 6'
upfront,.get input.from various stakeholders, and then 7
proceed with some recommendations to the Commission.
8 I'think they are complex issues.
I agree -- and 9
that they'are difficult, but once that -- I think they are 10 tractable.
The ACRS for example said to us that it is a 11 very complex issue, but perhaps it is worthwhile to go study 12 these and see how far we can in fact go.
13 What we are asking in this paper is taking a look 14 and coming back to the Commission in six months, 15 basically -- six to eight months -- with some firm 16 recommendations, and that would call for, we had planned to 17 have a workshop in November, after laying out these issues, 18 getting them out to stakeholders and having a workshop, 19 seeing what various stakeholders' views were, subsequently 20 studying what we get and come back to the Commission with 21 some recommendations.
That is the level of effort.
22 COMMISSIONER McGAFFIGAN:
I will just tell you, my 23 concern is a concern of opportunity costs.
I think what you 24 have laid out in just trying to risk-inform Part 50, and 25 there's a lot of learning that can get done in NMSS without ANN RILEY & ASSOCIATES, LTD.
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this paper perhaps, just by doing some things, and as you do 2
things you set a foundation, but I am worried about the 3
opportunity costs because it is a significant effort.
4 I think if we are going to risk-inform Part 50 5
there's an awful lot of resources required there.
Again I 6
look' at how long it took us to ck) the 50.59 rulemaking, 7
which isn't finished yet because we won't have the Reg Guide 8
until next June, or the 50.65 or whatever.
We could be 9
talking years just to get these rules through and if there 10 are resources that could be dedicated to that that otherwise 11 are going to be sitting worrying about whether the core 12 damage frequency should be 10 to the minus 4 or should be a 13 safety policy goal or something and redoing all of these 14 white papers we have done over the years, which in the end 15 the policy statements don't, in my view don't count as much 16 as the rules, so that is just a concern I will throw out in 17 the open that I am having with that paper.
18 COMMISSIONER DIAZ:
It appears Commissioner 19 McGaffigan has a question on that issue.
Thank you.
20 Just a couple of quick comments.
In thinking of 21 all the things that we have said and the trade press, I am j
22 getting a little bit concerned that people are counting 23 beans again, except looking at the direction that the 24 Commission has taken, and I think it is important that we j
25 realize that we use risk information in more manners than l
l ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
I
82 1
license amendments,-that it is really an overlaying 2
philosophy that we are trying to put on issues, and I think 3
that-is a very important aspect of it, rather than again, 4
you know, we are always being criticized about counting l
5 beans.
6 I think bean counting is a good exercise, but it 7'
is not the only way in which we can frame the importance of 8
what the. Commission have decided.
9 In looking at the Staff presentation, I realize 10 that we put accomplishments.
I think it might be at times 11 appropriate to identify hurdles.
I know there are no 12 show-stoppers that have been brought out, but there are 13 hurdles or problems that the Commission can receive ahead of 14 time.
That certainly will help us in decision-making.
15 At this moment I just would like to thank the j
16 Staff for what I think has really been a very good 17 overarching meeting and we looking forward to receiving the 18 specifics.
It is very clear that there has been a lot of
\\
19 discussion and input by the dedicated members of the Staff i
20 and by stakeholders alike into the implementation and 21 development of this approach to information, risk-informed 22 regulation and the PRA implementation plan, and there really 23-much to come.
We are expecting to be looking in the next 24 few. weeks to receive that "much to come."
25 Discussion on Option 3 related to risk-informing ANN RILEY & ASSOCIATES, LTD.
Court Reporters 11025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
r 83 1
Part 50.
Joe said this is an effort that might extend for a 2
significant period of time.
I think it is important that we 3
are aware of what the developments are so these issues are 4
not made just on big issues at the last moment, but that we i
5 receive the information like what are the preliminary issues 6
that are making it risk-informed.
7 Key technical and policy issues will need to be 8
evaluated,. a viable schedule will have to be developed, 9
pilots will be important in determining what needs to be 10 conducted, and the results of those pilots evaluated for 11 lessons learned.
Training is a big issue.
I think we all 12 realize that here and by the licensees -- the issue of 13 training so people will have the knowledge of what are our 14 systems and performance and behaviors, how they can get 15 integrated with a risk-informed approach is very important.
16 It will be necessary that we be vigilant regarding 17 the capabilities of the Staff and the licensees are up to 18 par, and we need to know ahead of time and further efforts 1
19 need to be in this area.
1 20 In summary, as Chairman Dicus stated in her 21 opening remarks, obviously we have done much and are 22 expecting to be doing a lot more in the near-term.
Again, I 23 want to thank the Staff for the fine presentation.
I think l
24 it was very, very informative.
Do any of my fellow 1
25 Commissioners have any closing remarks?
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.
20036 (202) 842-0034
{
l i
I
84 1
COMMISSIONER MERRIFIELD:
No.
2 COMMISSIONER McGAFFIGAN:
No.
3
. COMMISSIONER DIAZ:
If not, the meeting is l
4 adjourned.
5
[Whereupon, at 11:23 a.m.,
the briefing was 6
concluded.]
7 8
9 10 11 12 13 14 15 16 17 18 19 20 i
21 22 23 24 25 l
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
CERTIFICATE L-This is'to certify that the attached description of a meeting of the U.S. Nuclear _ Regulatory Commission entitled:
TITLE OF MEETING:
NRC STAFF BRIEFING'ON PROBABILISTIC RISK ASSESSMENT IMPLEMENTATION PLAN PUBLIC MEETING PLACE OF MEETING:
'Rockville, Maryland DATE OF MEETING:
Tuesday,-September 7, 1999 was held as herein appears, is a true and accurate record of the meeting, and that.this is the original transcript thereof taken stenographically by me, thereafter reduced to typewriting by me or.under the' direction of the court reporting. company Transcriber: Rose Gershon Reporter:
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