ML20212H345
| ML20212H345 | |
| Person / Time | |
|---|---|
| Issue date: | 09/23/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3091, NUDOCS 9910010040 | |
| Download: ML20212H345 (140) | |
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OFFICIAL TRANSCRIPT OF PROCEEDINGS V
- NUCLEAR REGULATORY COMMISSION
{
l
. ADVISORY COMMITTEE ON REACTOR SAFEGOARDS i
1
Title:
MEETING: - RELIABILITY AND PROBABILISTIC RISK ASSESSMENT AND REGULATORYPOLICIES AND PRACTICES TRO4 :ACRS; REUrdi ORIGIN TC BJWHITE N
- f^).
. Docket No.: -
5/ST-2E26[ed}r 415-7: 3 0 g.i v.y L/
THMiKS !
I Work Order No.:
ASB-300-928 I
o LOCATION:
Rockville, MD
~ dATE:
Thursday, September 23,1999 PAGES: 1 - 106 991001004e 9cca PD6 ACR(,
T-3093 y99
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DISCLAIMER i
UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SEPTEMBER 23, 1999 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory
,m
-v) committee on Reactor Safeguards, taken on September 23, t
1999, as reported herein, is a record of the discussions j
recorded at the meeting held on the above date.
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
v l
L
~
1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION
.3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 MEETING:
RELIABILITY AND PROBABILISTIC RISK 6
ASSESSMENT AND REGULATORY POLICIES AND PRACTICES 7
8 Room T-2B3 9
11545 Rockville Pike 10 Rockville, Maryland 11 Thursday, September 23, 1999 12 The subcommittees met, pursuant to notice, at 1:00 13 p.m.
14 MEMBERS PRESENT:
15 GEORGE APOSTOLAKIS, Chairman, Subcommittee on 16 Reliability and Probabilistic Risk Assessment 17 THOMAS S.
KRESS, Chairman, Subcommittee on 18 Regulatory Policies and Practices 19 WILLIAM J.
SHACK, ACRS Member 20 MARIO V. BONACA, ACRS ember 21 JOHN J.
BARTON, ACRS Member 22 ROBERT E. UHRIG, ACRS Member 23 JOHN D.
SIEBER, ACRS Member 24 25 b'
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1 P R O'C E E:D.I N G S
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2 (1: 01 p.m. ]
3 DR. APOSTOLAKIS:
The meeting will now come to 4
7rder.
This is the first day of the joint meeting of the 5
ACRS Subcommittees on Reliability and Probabilistic Risk 6
Assessment and on Regulatory Policies and Practices.
7-I am George Apostolakis, Chairman of the 8
Eubcommittee on Reliability and PRA.
Dr. Kress is the 9
Chairman of the Subcommittee on Regulatory Policies and
'10
. Practices.
11 ACRS members in attendance are John Barton, Mario 12 Bonaca, William Shack, Jack Sieber, and Robert Uhrig.
13 The purpose of this meeting is to review proposed 14 revisions to the NRC PRA plan.
Tomorrow, September 24, the f
15 subcommittees will review the proposal-making plan and study 16 for development of risk-informed revisions to 10 CFR Part 17 50, domestic licensing of production and utilization 18 facilities.
19 The subcommittees will gather information, analyze 20 relevant issues and facts, and formulate proposed positions 21 and actions, as appropriate, for deliberation by the full 22 committee.
23 Michael T. Markley is the cognizant ACRS staff engineer for 24 this meeting.
25 The rules for participation in today's meeting s
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have been announced as the notice of this meeting previously l
I) 2 published in the Federal Register on September 3, 1999.
\\_/
3 A transcript of the meeting is being kept and will 4
be made available as stated in the Federal Register notice.
I 5
It is requested that speakers first identify themselves and
(
6 speak with sufficient clarity and volume so that they can be 7
readily heard.
l 8
We have received no written comments or requests 9
for time to make oral statements from members of the public.
10 The key document for today's meeting is 11 SECY-99-211, status report on the PRA implementation plan, 12 issued August 18, 1999.
The staff has made substantial 13 revisions to this update, in part, to address comments in l
14 the General Accounting Office report, dated March 19, 1999.
/D
(,/
15 The staff also briefed the Commission on the 16 SECY-99-211 on September 7, 1999.
17 We will now proceed with the meeting and I call 18 upon Mr. Barrett, Mr. King, and Ms. Drouin to begin.
19 MR. KING:
For the record, I'm Tom King, from the 20 Office of Research.
With me is Mary Drouin, also from the 21 Office of Research, and Rich Barrett, from NRR.
22 The agenda today had two topics, basically; a 23 status report on the quarterly update of the PRA 24 implementation plan and then what are we doing in response 25 to the GAO recommendation to develop a strategy.
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What i thought we'd do in the presentation is
()
2 we've picked a few key items from the PRA implementation 3
plan and we wanted to update you on the status on those 4
items.
I think those are some of the more visible items 5.
that maybe.you naven't heard abdut in a while.
Then the 6
second half of the presentation to talk about what are we 7
doing-in response to GAO recommendation.
8 So you will see on slide two is the list of things 9
that we've picked out to talk specifically about.
There are 10 seven of them.
There are some other things that we could 11 have discussed, but we know there are separate briefings 12
' coming up at the subcommittee, like the ATHENA project, so 13 we're rot going to talk about that today.
14 The first one on the list is the PRA standard.
l(
)
15 That's the ASME effort, the ANS effort, and the NFPA effort, 16 and with that, I'm going to let Mary and Rich talk a little 17 bit about where we stand on those projects.
l 18 DR. APOSTOLAKIS:
Wouldn't it be better to start 19 with the safety goal revision or the standard is sort of a l
20 stand-alone issue?
21 MR. KING:
I think the standard is a stand-alone 22 issue.
I 23 DR. APOSTOLAKIS:
Let's go with it.
24 MS. DROUIN':
Mary Drouin, with Office of Research.
25 As.you're aware ASME is developing the PRA standard for l
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level one full power' internal events, excluding fire, and a
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2 partial level, and what I mean by a partial level two, 3
they're only'looking at large early release frequency, just 4
that part of the level two.
5 They issued a draft standard in February of this 6
year.
They went out for a 90-day public comment and review 7
period.
They received, I believe, comments from around 40 8
organizations.
9 So currently they are work g on the next i
10 revision.
That was revision -- what they call revision ten.
11 That went out in February and so they are now working on 12' revision 11 and it is my understanding that they plan to, in 13 the January timeframe, and it's a tentative date, to go out I
14 for public review and comment again.
()
15 We do have some concerns here that going from Rev.
16 10 to Rev. 11, that they have so dramatically restructured 17 the standard, that it's going to probably, in my opinion, 18 add probably another nine months to a year to the schedule, j
19 and it may not include the detail that we would like to see 20 in the standard.
-21 DR. APOSTOLAKIS:
Is it time well spent, you 22 think?
Are they revising it for the better?
I 23 MS. DROUIN:
I think that in terms of the 24 technical stuff that's in there, some of it is being watered l
25 down.
They're making the requirements more high level, I
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1 which adds more: room for interpretation.
In my opinion, I h'
2-don't think Rev. 10 was prescriptive-at all.
It tended to V
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say what~should be.in a PRA.
It did not go into detail how 4
you should do it.
~
5 But even the little bit of detail, which I don't 6
remember very much in, I.think some of that is being 7
. removed.
8-DR. APOSTOLAKIS:
So revision 11 will be 9
substantially different from what we saw which was ten.
10
'MS, DROUIN:
It's going to be very different.
11 DR. APOSTOLAKIS:
Is the ACRS going to review it
- 12'
.again?
l 13 EMS..DROUIN:
That's between you and ASME.
14 MR. BARTON:
It sounds like we should.
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15 MR. MARKLEY:
It's currently on tN3 December i
16 schedule, but I'm waiting for a call back from ASME.
17 DR. APOSTOLAKIS:
But we should, I think.
I 18 MR. BARTON: Yes.
It sounds like it's the new 19 document.
l 20:
DR. APOSTOLAKIS:
It's a new document, yes.
21-MR. MARKLEY:
You recall, the industry -- maybe 22 not the industry, but some selected participants wanted to 23
-- instead of have a standard that focused in on one level 24 of scope and detail of quality of PRA, they wanted to break 25 it up to say, well, if you're having a PRA that's just going l
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to be-used.for risk categorization or. risk ranking, here is A
'2'.
the_ standard, if you want one,Ifor risk'-informed submittals, 3
'here is the standard if you want one for risk-based 4
submittals,- here is.the standard.
5 So they sort of have a three-column format now on 6-the standard and I think there has'been some -- it's not 7-coming out as straightforward as we had hoped.
8 In concept, it sounded like a good idea, but in 9
practice, it may not be.
So that's another issue.
10 DR. APOSTOLAKIS:
See, that's my concern, because 11 I hear, also,-through the grapevine, that there are drastic 12 changes and some people are unhappy.
So I think we should 13
'have an opportunity to review it.
In fact, starting with 14 the subcommittee meeting, if it's a really new document,
()
15 where we can go into more detail and then, of course, give 16 our opinion to the full committee.
17 So now, Mike, you say that in December, we may --
-18 in other words, we may review it before they issue it for j
19 public comment or at the same time?
j 20 MR. MARKLEY:
Well, the last time I discussed it 21 with them, we were talking about it being a pre-consensus
'22.
voting process.
Now, the public comment issuance is a new 23 issue, to my knowledge, and I haven't had a chance to 24 discuss that.
I was not aware of it from talking to Jerry 25 Eisenberg, but he did, in his phone message he left me, say O
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l' there is a possibility of the schedule sliding.
So that's
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confirmed basically by what-Mary is saying here.
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MS. DROUIN:
As I said, ASME is just looking at j
4 the level one and the level two for full power internal.
5 Also, ANS is involved in this in that they are developing l
6 the PRA standard for low power shutdown and for seismic.
7 Rich sits on that.
You might want to --
8 MR. BARRETT:
Yes.
We had the first meeting of 9
what's referred to by ANS as the risk-informed standards 10 committee.
This is a consensus committee that's been formed 11 by the American Nuclear Society for the purpose of 12 developing these two consensus standards, one for external 13 events or external hazards and the other one for low power 14 and shutdown.
(h4 Q
15 But the concept is that this standards committee l
16 might be involved in future efforts, as well, and there is 17 some preliminary thinking about that.
18 The standards committee is a large group, 19 approximately 30 people, representing a wide variety of 20 organizations, government, industry, vendors, academic j
21 community, and, in addition, they have put together panels; 22 one for the -- I guess you would call it the working group 23 or the writing group for external hazards, and one for low 24 power and shutdown.
I 25' Both groups have started preliminary work.
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DR. KRESS:
Do you know wh cher or not the focus p)
(
2 on low power shutdown is the type of PRA that's used for
\\_/
3 configuration control during shutdown events or is it one 4
that's addressing a broader need than that?
5 MS. DROUIN:
Let me, because I sit on the writing 6
group for the low power shutdown, and we had our meeting.
7 Right now, there are three approaches that we're -- I 8
shouldn't say three.
There's really basically two 9
approaches; one that actually looks at, for the PRA, how 10 you're going to quantify the risk.
11 Another one --
12 DR. KRESS:
Over the full lifetime of a plant.
13 MS, DROUIN:
Yes.
14 DR. KRESS:
Not just instantaneous, g.s
(_j' 15 MS, DROUIN:
Yes.
Full lifetime of the plant.
1 16 But they're also looking at configuration control in writing 17 that, because that's more from a utility desire, where it's 18 looking for something.
So we are considering writing 19 something in that area, too.
20 DR. KRESS:
Thank you.
That answers it.
21 MR. BARRETT:
The only thing I'd like to add is 22 that there is a sense that developing a standard for 23 external hazards is going to be a simpler task than for low 24 power and shutdown and that's primarily because, for one 25 thing, the external hazards does not include fire.
Fire is
(' '
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1 being handled separately by the NFPA.
So it's primarily a
,a (v) seismic issue and seismic PRAs, the sense is that we have a 2
3 lot of experience with them.
4 It's a relatively well developed methodology, with 5
a lot of consensus built around it, and that a standard would be simpler to deal with than the lower power and 7
shutdown, which has so many facets to it.
8 MR. KING:
Nilesh Chokshi is the staff person on 9
the seismic writing group.
10 DR. KRESS:
Who?
11 MR. KING:
I 12 MR. BARRETT:
Mark Cunningham and I are both on j
13 the standards committee.
14 MR. KING:
And as Mary said, she's on the low
?h 6
( )
15 power shutdown writing group.
16 DR. APOSTOLAKIS:
Okay.
17 MR. KING:
All right.
Safety goals.
Back'in 18 July, there was a paper that went to the Commission -- in 19 fact, we discussed it with the committee before it went --
l 20 that talked about two things.
One was the status report on 21 the 11 safety goal issues that had been identified last year 22 and the second was a recommendation to the Commission to let 23 us go forward and do a feasibility study on what we called l
24 high level safety principles.
l l
25 We haven't received an SRM yet from the Commission f
l
/
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'l on the high level safety principles piece.
The safety goal lT
'2 piece was just a status report, so we're not waiting for any V
3 Commission input at this point.
4 So we have not actually done anything on the i
5 feasibility studyLof the high level safety principles, but I 6
thought it might be worthwhile just bringing you up-to-date 7
on our current thinking on some of the more key safety goal 8
issues, because we have continued to think about that, had 9
some discussions.
We haven't reached consensus on the real 10 key ones, the real tough ones yet.
11 Some of the things that we recommended were pretty 12 straightforward, cleanup items, and those are -- we're not 13 going to talk about those today, but I did want to talk 14 about the things that are more controversial and are going
()
15 to be tougher to deal with.
16 So let me go to the next slide.
17 We start off with elevation of CDF as a
-18 fundamental goal, which the committee recommended a couple 19 of years ago.
We've had a lot of discussions on this and 20 our current thinking is that we ought to add some 21 qualitative high level words in about accident prevention, 22 just like there are qualitative words in right now that deal 23 with individual and societal protection.
We think accident 24 prevention deserves similar stature in the qualitative 25 sense.
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.1 The safety goal --
()
I DR. APOSTOLAKIS: -Let me understand the meaning of 3
the words accident prevention.
If you have a CDF subsidiary 4~
goal and a LERF goal, aren't you preventing accidents?
5 MR. KING:
Yes.
6 DR. APOSTOLAKIS:
Why do you need an additional 7
statement?
8 MR. KING.:
You recall what we have now is th t we 9
have qualitative statements on protecting individuals and 10 protecting society, and below that we have QHOs, which 11 define what do we mean by protection.
12 DR. APOSTOLAKIS:
I see.
So you're referring to 13 the qualitative part.
14 MR. KING:
Right.
()
15 DR. APOSTOLAKIS:
So there will'still be a 16 qualitative statement.
17 MR. KING:
Yes.
Because I think it's important 18 not just to say protect the public and let people decide how 19 much of that they want to do by mitigation versus 20 prevention.
I think we ought to emphasize prevention.
I 21 think that's an important statement for the Commission to 22 make.
23 What we're thinking about now is then going in and 24 adding the subsidiary CDF and LERF objectives into the 25 policy statement as subsidiary objectives, but will provide O-ANN RILEY & ASSOCIATES, LTD.
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some guidelines as to what do we mean by this balance
.2 between prevention _and mitigation.
l~
3 DR. APOSTOLAKIS:
So would then a statement on how I
4 important' accident prevention la result in a reduction in 5
funding severe accident research?
l 6
MR. KING:
No, I don't think so.
I think we still 7
have the mitigation piece, which is severe accidents.
8 DR. APOSTOLAKIS:
Bt '- it seems to me that one can l
9 make a reasonable argument that if the emphasis of the 10 Commission is on prevention, let's see how much money you're 11 spending on level two phenomena versus what you're spending j
12 on level one.
13 And if the difference is the other way, I think i
14 it's a legitimate question, why are you doing it this way.
15 MR. KING:
I think if there were a big difference, 16 it might be a legitimate question, but that's not the case 17 today.
18 DR. APOSTOLAKIS:
I understand that, but, I mean, 19 the reason why I'm asking is because the industry, as you 20 know, for years now, has been very cool to any research that 21 goes beyond core damage and they are claiming that what 22 really matters is level one, because that's where we see the 23 return, we understand what's going on, it's something we can 24 put our hands on.
25 So I think this would give them further ammunition O
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l 14 1-along these lines.
2 Is that an -- I don't know, what's the word.
l 3
DR. KRESS:
George, if this is the right thing to l
4 do, I don't think we ought to worry about that.
This is the 5
right thing from a regulatory objective to do.
6 DR. APOSTOLAKIS:
But before we put forth 7
revisions of such important documents, I think we should 8
understand all the possible consequences.
I'm not arguing 9
against it, because I think it's okay.
10' DR. KRESS:
I'm sorry.
I thought you were arguing 11 against it.
12 DR. APOSTOLAKIS:
It would be a very dull 13 afternoon if we just didn't say anything, so I have to say 14 something.
()
15 DR. KRESS:
I see.
I understand.
It's worthwhile 16 understanding the ramifications, and I agree with you, that 17 is a likely ramification.
18 DR APOSTOLAKIS:
Clearly we are emphasizing 19 prevention even now, if you look at the numbers we're using.
20 DR. KRESS:
Sure.
21 DR. APOSTOLAKIS:
Okay.
22 DR. SHACK:
On that, the safety goal already has 23 qualitative statements that preventing core damage is E
24 important.
25 MR. KING:
I think the words prevention of core h
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damage show up in there,-but they don't show up as
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prominently as the other qualitative statements.
They're G
3 just sort of thrown in the discussion somewhere.
4 DR. KRESS:
Would the subsidiary goals on CDF and 5
LERF, would they have equal status to what we have out for 6
the quantitative health objectives now or would they be --
7 MR. KING:
My view is they would not.
They'd be 8
the next level down.
i 9
DR. KRESS:
Next level down.
10 MR. KING:
The QHOs really try to put some number 11 on what do we mean by protecting the public and then the 12 next level down, the CDF and LERF would be some actual 13 practical guidelines that you can use in running and 14 designing your plant to try and implement that.
()
15 The next item is definition of adequate 16 protection.
There was, at one time, a recommendation from 17 the committee to try and use the safety goal policy to come 18 up with some quantitative definition of adequate protection.
19 There's also been a lot of discussion from external 1
20 stakeholders about what do we mean by external or adequate l
21 protection.
22 The Commission nor the staff neither one has, at 23 this point, decided, yes, we want to go define adequate l
l 24 protection.
We're wrestling with that question in the 25 context of the safety goal policy, but really it's a broader O
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^
. question, because the concept of adequate protection applies 1
)
2 not just to reactors, it applies to every licensed activity 3
that we regulate.
4 So one of the things we had thought about with 5
these high level safety principles was going in and trying 6
to qualitatively lay out what does the agency mean when it 7
says adequate protection and then maybe you could, for 8
reactors, come up with something a little more specific to 9
reactors to implement that.
10 Whether that's going to happen or not I dov t 11 know.
But I think we've. clearly decided you can't 12 quantitatively. define adequate protection.
It's not a 13 -
number.
It's not a group of numbers.
14-Some people think it's a process, that you go
()
15 through the process of good engineering and QA and 16 corrective actions and inspection and all of that stuff, you 17 end up with something called adequate protection.
Other 4
18 people think it's more -- it could be defined in more 19 engineering terms or lines of defense terms without maybe i
20 putting a number on it, but it's not a process.
It's a 21 physical attribute or some defined attributes that you've 22 got to have.
l 23 DR. APOSTOLAKIS:
Would it be easier to talk about 1
j 24 adequate protection without necessarily defining it 25 quantitatively?
If the new safety goal statement clearly ANN RILEY & ASSOCIATES, LTD.
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17 I
1 identified the objectives of regulation by this agency, the
/~%.
2 ACRS has wr.ltten at least two letters, that I can think of,
()
3 where we keep coming back to it and saying -- well, the last 4
one, I read it yesterday, was in the package you sent me on 5
Part 50, revising Part 50, where we came back to it and said l
6 if you had developed this, a set of objectives, stated 7
explicitly, then the revision of Part 50 would be easier.
8 Is this a time to think about that perhaps?
That 9
in addition to the health objectives and so on -- now I 1
10 remember.
In that letter, we also said that in the draft 11 document we saw, I think Mary was here and made the 12 presentation some time ago on revisions to Part 50 a long i
l 13 time ago, the letter was from last December.
14 MS. DROUIN:
50.59.
()
15 DR. APOSTOLAKIS:
Okay, 50.59.
Anyway, we said 16 there are terms like defense-in-depth and adequate 17 protection, safety-related or something, safety-significant, 18 that were not defined anywhere and yet they were used in l
19 sort of a routine way and on page 26, at the bottom, you 20 might say, well, but this is not a good option because of 21 such and such, and this such and such had never been defined 22 up front as being one of the objectives of the agency.
23 I think what we saw there is the result or a 24 reflection of the culture that has evolved within the agency 1
25 as to what's important and what's not important.
So two O%
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18 1-people from.NRR, when they speak to each other, they more or
.( s) 2 less agree,.yes, this is important, this is.
%-)
3 And I guess what the committee is saying is that 4
it might'make all these efforts easier if somebody took the 5
time to put these things up front and discuss them with us 6
and other stakeholders and say this what we really want to 7
do.
8 MR. KING:
That's, in effect, what we had in mind 9
when we proposed these high level safety principles, to try 10 and lay that out; bhatisitwe'retryingtoachievewith 11 all these regulatory programs, what level of protection.
12 DR. APOSTOLAKIS:
And that has not started yet 13 because you don't have an SRM.
14 MR. KING:
Right.
And I agree, I mean I 7-personally agree with you that if we had such a statement of 15 l
16 objectives, it would make defining adequate protection i
17 easier, it would probably make some of these other decisions 18 easier, what do we mean by safety-related and that kind of j
l 19 stuff.
20 DR. APOSTOLAKIS:
Now, when you say consider a l
1 21 zone, what exactly do you mean?
A zone where, on the risk l
22 lane?
23 MR. KING:
Well, this was a concept that our legal 24 folks gave us to think about and as I understand it, instead i
25 of defining adequate protection in some fashion, what you i
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would do is.you'd say, okay,: I'm not sure exactly where L{ )
2 aiequate protection is, but I know if I'm in this range up 3
here, that I've got adequate protection and they call this a 4
zone.
5 DR. APOSTOLAKIS:
But up here where?
Are you 6-talking about numbers?
7 MR. KING:
I think they would be more comfortable I
8 if you put' numbers on defining such a zone.
Like, for J
9 example, Reg Guide 1174, we have numbers in there.
10 Everybody says if you meet those, if you come in with a 3
11 change that meets those numbers, there is not an adequate 12_
protection concern.
So that's a zone that we're comfortable l
13 in and we don't have an adequate protection concern as long 14 as we're in that zone.
()
15 What we had talked about was recognizing that that 16 zone is pretty -- only deals with small changes, it's 17
= obvious you're not going to worry about adequate protection, 18 when you're dealing with small and very small changes, isn't l
19 there really some region below that you can'also not worry 20 about adequate protection and could we define that 21 presumptive zone so that if people come in and they're 22 beyond the 1174 guidelines, we can at least know whether l
23 there is an adequate protection concern or not.
l 24 So that when_you have to make decisions on l
25 backfit, for example, you know you're allowed to backfit on l
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1 an adequate protection determination and if you're above 2
adequate protection, then you have to use cost-benefit.
'3 Well, this presumptive zone would help you figure j
4 out where you are in backfit space.
l 5
So they're not comfortable with defining adequate 6
. protection in some precise fashion,.but they are comfortable 7
with.saying, well, if you're up here in this zone, then 8
you've got adequate protection.
9 DR. APOSTOLAKIS:
Is it easier to define where you 10 don't have it?
11 MR. KING:
I'm not sure.
12 MR. BARRETT:
That's an interesting question, 13 because if you define it as a point, then you have to be 14 right there at the point.
If you define it very sharply and 15 the licensee is to the correct side of that point, then they 16 have adequate protection and that's -- and if they're to the 17 wrong side of that point, they don't have adequate 18 protection.
19 If they're to the wrong side and they don't have 20 adequate protection, they can't operate.
If they're to the 21 right, to the correct side of that point, then they have 22 adequate protection and the regulatory really has no 23 business dealing with that issue anymore.
24 I don't think we want to be in either one of those 25 places.
One of the proposals --
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21 l'
DR. SHACK:
If you have George's three-zone model,
[)
2 Lwhere you have a place where you're clearly in trouble,.a 3
place.where'you're clearly safe,-and then --
4 MR. BARTON:
A fuzzy place.
5 DR ~. SHACK:
-- a fuzzy place.
-6 MR. BARRETT:
One of the proposals is to have a 7
combination of criteria and processes, to think of it that 8
way.
For instance --
j 9
DR. KRESS:
Or more than just two dimensions.
1 10 MR. BARRETT:
In dimensions.
For instance,.you've 11 got a bunch of parameters that are controlled by the license l
12 amendment process.
These are your safety limits, DNBR 1.2, i
13 and PSH, all'of these detailed engineering criteria, plant 14 design basis criteria, and they are controlled by 50.59 and (s) t 15 50.90 and 50.92, the licensing process.
i 16 We've got some risk parameters that we've 17 developed over some past several years and you could say 18 that in some sense, they're controlled also by the same 19 process, but through Reg Guide 1.174, and some of the other
-20 guidance that we've developed, along with some of the 21 guidance we talked to you last month about.
22 So if you have a combination of some criteria or i
23 guidelines like that, in dimensions, and each one has 24 associated with it a process to control it, not necessarily 25 to control it at exactly that point, but to at least make 1
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l 22 1
reasoned judgments about whether it's in the right range.
[)
2 And then if you combine that with a process to V
l 3
take remedial actions, if it's in an unacceptable area, then 4
all of that combined will give you adequate protection.
And 5
another example would be if you suddenly found out that 6
there was some new piece of operational experience that took 7
you outside where you thought you should be.
8 You have 51.09, which is a process to control that 9
and to bring it back into balance.
So that's a view of 10 adequate protection in the compliance process with numerical 11 values.
12 MR. KING:
Another way to look at it, too, is, in 13 effect, the new plant oversight process has defined this 14 zone, used this zone concept where they have the green all r(h) 15 the way down to the red zone.
Down in the red zone, they 16 don't say the red zone is adequate protection, but what they 17 do is say is, hey, we're getting close enough to whatever 18 adequate protection is that we don't want the plant to 19 operate anymore.
20 That's another way to look at it, another example 21 of applying that zone concept.
22 DR. APOSTOLAKIS:
So you are now working on these 23 issues?
24 MR. KING:
We are now, from time to time, 25 discussing these issues, trying to settle in on what is it j
I
[)
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1 we.want.to recommend to the Commission.
One of the things 1
2 we'are going to do very shortly is issue a Federal Register i
3 notice'and have a workshop on November 9 to get stakeholder 4
input-on these issues, all the ones we're talking about 5
here.
6 DR. KRESS:
If you went with a green to a red type 7
system, would that be defining adequate protection in terms 8
of performance indicators, or you just use the concept and 9
use something besides those that are in the oversight?
10 MR. KING:
Remember, the plant oversight process 11 is a combination of indicators and inspection findings.
So 12 it's not just numerical values.
13 DR. APOSTOLAKIS:
I think, though, that the
-14 factor, again, and we do have an idea of where we are, if
()
15 the core damage frequency, as estimated today, the average 16 long-term core damage frequency, if the approach is 17 ten-to-the-minus-three per year, it seems to me that the 18 staff is concerned about adequate protection, and something 19 happens.
20 Now, that something may include a number of 21 things.
The licensee may decide to try to put down, the 22 staff may look at it and say, as Rich said, that there are 23 other measures, other protective measures that compensate 24 for this high value and so on, but I don't think that even a 25
. licensee who finds an accident sequence with frequency more O'
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than ten-to-the-minus-three, that that licensee would do O( J-2 nothing.
3 MR. BARRETT:
We've had examples where licensees l
4 have calculated total core damage frequencies in excess of 1
5 ten-to-the-minus-three and have implemented corrective 1
6 action programs to gradually bring it into more reasonable l
7 ranges.
Yes.
8 DR. APOSTOLAKIS:
So I think we have an idea of 9
where the zone is, but I guess that doesn't help very much 10 when you actually have to put on paper where the zone l
11 begins, right?
The numerical definition is a problem.
12 MR. KING:
People can get uncomfortable at 13 ten-to-the-minus-three CDF, but if your containment wasn't 14 operable, you'd probably be uncomfortable, too, even if your O
(s,/
15 CDF was ten-to-the-minus-four or ten-to-the-minus five.
16 If you were finding programmatic breakdowns in 17 your plant, even though an accident hadn't occurred yet, 18 you'd probably get uncomfortable, too.
People are not 19 qualified, they were on drugs, whatever, you wouldn't be too 20 comfortable.
21 So there's a lot of things you've got to consider.
l 22 DR. APOSTOLAKIS:
Is people taking drugs part of 23 the safety culture of the plant?
24 MR. KING:
Well, I would think so.
25 MR. BARRETT:
Hopefully, it's an aberration.
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7 25 1
DR. APOSTOLAKIS:
Okay.
'(q 2
MR. KING:
The second item on that page is j
3 defense-in-depth.
It's. mentioned in the safety goal policy L
4 that exists today, but it's not defined, it's not described 5
how we use it.
What it means, we took a stab at that in Reg l
6 Guide 1.174.
We thought since it is such an important 7
concept, the safety goal policy ought to say more about it.
8 We also recognize these high level safety 9
principles.
It's a. concept that applies across the agency, 10 as well.
Should we step back and, from an agency 31 perspective, talk about defense-in-depth?
12 To me, this is a fairly key item.
To me, this is 13 more key than the adequate protection.
I think we can 14 risk-inform Part 50 without having a good definition of 15 adequate protection.
I don't'think we can do it without 16 thinking hard about defense-in-depth and what do we mean by 17 it.
18 So if you had to prioritize the two, I'd put my 19 effort on defense-in-depth in the near term to try and i
20 settle out what we mean by that.
1 21 Again, you know, we read the paper that was 22 provided attached to a committee letter about the 23 structuralist and the rationalist approach.
We had a 24 workshop last week on risk-informing Part 50, the option 25 three piece, and there was a guy from the UK there that l
(t'%)
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talked about their definition of defense-in-depth.
It was
(}
2 an interesting concept.
3 So we're gathering some information.
4 DR. KRESS:
Is there a paper on that or anything 5
we could look at?
6 MR. KING:
They have those documents, tolerability 7
of risk, and there is another one that came out recently, 8
but I don't know if that talks defense-in-depth.
He did not 9
hand out a paper.
10 DR. APOSTOLAKIS:
So what did he say?
11 MR. KING:
He basically said what they do is 12 define lines of defense and what they want -- for accident 13 prevention, core damage, they want two what they call strong 14 lines of defense and the strong line of defense is a
( )'
15 capability to terminate the accident that also can withstand 16 a single failure.
So they want two of those 17 Then they want a weak line of defense for 18 mitigation, assuming the accident has occurred, the core 19 damage has occurred, and they want a weak line of defense.
20 And then they combine that with probabilistic goals on core 21 damage and'LERF, essentially, and that makes up there 22 ensemble of high level requirements for what they want to 23 achieve in terms of safety.
24 I thought it was interesting.
But what he said 25 was even if this plant calculates a good CDF, they still O
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want those lines of defense, regardless of what your CDF
()
2 says.
3 DR. SHACK:
Sounds good to me, George.
4 DR. APOSTOLAKIS:
Yeah, right.
So now we start 5
agonizing over what is a strong line and what is a weak line 6
and all that stuff.
That's why PRA was invented, to give f
7 you numbers for these things.
8 So I'm unimpressed.
9 MR. KING:
You don't think there should be some 10 floor on features that you want in the plant, regardless of 11 what your numbers say.
12 DR. APOSTOLAKIS:
That's a very different 13 question.
14 MR. KING:
It's the same question, to me
-(
15 DR. APOSTOLAKIS:
I'm unimpressed by what you've 16 described.
I thought the other way.
I don't think -- I 17 think defense-in-depth -- defense-in-depth is insurance.
18 Isn't it insurance?
19 MR. KING:
Assurance or insurance?
20 DR. APOSTOLAKIS:
Insurance.
21 DR. KRESS:
Insurance.
22 MR. KING:
I'd rather call it assurance.
23 DR. APOSTOLAKIS:
I think it's really very similar 24 to the idea of insurance.
When all is said and done, I'd 25 really feel better if you put that thing there.
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28 1
DR. KRESS:
We really do think it's intimately (A) 2 related to the uncertainties.
3 DR. APOSTOLAKIS:
Sure.
4 DR. KRESS:
In your CDF and LERF, for example.
5 And in that sense, it's insurance.
Somehow the definition, 6
in my mind, has to draw in that relationship to the 7
uncertainties some way.
8 MR. KING:
But if you had this floor of things, L
9.
you say I'm going to have these, and then beyond that, where 10 you've got uncertainties, maybe you want to add more for 11 defense-in-depth purposes.
That sounds like a reasonable 12 approach, to me.
13 DR, APOSTOLAKIS:
Which is what we proposed in the 14 combination.
The floor there is the high level l( )
15 structuralist approach.
But no matter what, you must have a 16 containment, you must -- it's not a floor.
It's a ceiling.
17 And then you go -- and by the way, there's a lot of people 18 who are unhappy with that and I'm -- they're developing this 19 pebble bed reactor.
Now they're talking about there is no 20 need -- about not needing a containment.
21
/CMR. KING:
They proposed that ten years ago.
22 DR. APOSTOLAKIS:
I thank God this is an MIT 23 project, so I have a conflict of interest.
24 MR. KING:
What they say is the little fuel 25 particles are --
l t( )
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29 1-DR. APOSTOLAKIS:
I'll let you guys resolve it.
()
2 DR. KRESS:
There has been one member of the 3
committe? who has said that it is rational to think about a 4
system, a design that doesn't:need a containment.
5 DR. APOSTOLAKIS:
Rational?
6 DR. KRESS:
Right.
7 MR. BARRETT:
In Reg Guide 1.174, we talk-about i
8 defense-in-depth and margin separately.
It could very well 9
be that for the pebble bed, the two might be related in 10 terms of the thermal inertia and --
l 11 DR. APOSTOLAKIS:
But it's a separate issue.
12 MR. KING:
The pebble bed said they had a trillion 13 containment, so these little fuel particles in there.
l 14 Triple-coated, can withstand high_ temperatures.
()
15 DR. APOSTOLAKIS:
That's where my idea of 16 insurance comes in, because I think we're probably going to i
l 17 have a very hard time agreeing that you don't need a j
l 18 containment, but that's my first reaction.
19 DR. KRESS:
And it depends on the uncertainties i
20 and how well those things function.
21 DR. APOSTOLAKIS:
That's right.
.22 DR. KRESS:
Then the insurance inertia definitely 23 is a good term for that.
24 DR. APOSTOLAKIS:
Anyway, we agree that the 25 British approach.is not impressive.
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DR. KRESS:
At least on first glance.
()
2 DR. APOSTOLAKIS:
Yes.
As conveyed to us by Mr.
i 3
King.
Insurance, insurance of a different kind.
4 MR. KING:
I'll get a call from my colleagues in l
5 the UK.
6 DR. KRESS:
Who was the British guy on this?
7 MR. KING:
Nigel -- what was his last name?
8 DR. KRESS:
Buttery?
9 MR. BARRETT:
Holloway.
L DR. APOSTOLAKIS:
Holloway, Nigel Holloway.
11 MR. KING:
The other --
12 DR. APOSTOLAKIS:
I thought he was in weapons 13 right now.
14 MR. KING:
Yes.
He's working on weapons now, but r
(
15 he's sort of like a --
16 DR. BONACA:
Trying to design a weapon to see if 17 he can defeat defense-in-depth.
18 MR. KING:
It sounded sort of like an ombudsman 19 for that program over there, that when people disagree on do 20 we provide adequate protection or not, he comes in and 21 listens to the arguments and tries to sort out what the j
22 right answer is.
23 DR. APOSTOLAKIS:
Anyway.
24 MR. KING:
Societal risk and land contamination, 25 those were the other two big issues, o,en issues in the i
l l
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safety goal policy list.
()
2 DR. APOSTOLAKIS:
Yes.
And we've -- sorry, go 3
ahead.
4~
MR. KING:
We've talked about the societal risk 5
when it had to do with the way we calculate the current 6
QHOs.
They're both calculated, whether it's early or latent 7
fata*ities, they're calculated on an individual risk basis.
8 We have reg analysis guidelines that calculate a person rem 9
o society and makes decisions based upon that.
10 They also have different distances out to which 11 you make those calculations.
So the amount of society 12 that's affected is different in those cases.
13 And then we don't have anything that protects the 14 environment, so we talked about should there be some lane
,f 15 contamination, but we haven't settled anything on either one J
(
16 of these issues.
I think we are exploring two things now.
17 One, we're looking at maybe it would be -- make 18 mo.re sense to deal with both of these issues by looking at 19 should we have a goal cn the amount of material released 20 from a reactor.
21 DR. KRESS:
FC curves.
Frequency.
22 MR. KING:
Not the large.early release that was in 23 the original safety goal policy at ten-to-the-minus-six, but 24 some --
25 DR. KRESS:
Some say release of any given --
('
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V..
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MR. KING:
Right, right.
l f~s I
J-2 DR. APOSTOLAKIS:
Which are being produced by 1150 l
l 3
and other studies.
l f
4 MR. KING:
Yes.
But that would cover --
l-5-
DR. APOSTOLAKIS:
Which the Swiss are using, by 6
the way.
7 MR. KING:
Yes.
But that would cover both of 8
these issues.
-It would protect society, it would protect 9
land, and be irregardless of how many people are around the 10 site that --
11 DR. KRESS:
It also implicitly incorporates LERF 12 and explicitly incorporates CDF.
13 MR. KING:
Yes.
So we're looking at that now.
I 14 don't know what the answer is going to be.
O( j) 15 DR. APOSTOLAKIS:
The penalty is that you will I
16 probably need more than one set of curves to satisfy Dr.
j 17 Powers.
i 18 MR. KING:
The other thing we're doing is looking 19 at make the distance -- the evaluation distance.the same.
l 20 Safety goals is ten miles, reg analysis guidelines is 50 21 miles; shouldn't the population at risk be the same, how did 22 we decide ten miles, how did we decide 50 miles, why 23 shouldn't they be the same.
l 24 I don't know, again, I'm not sure what the answer i
25
.is going to be, but those are the two things we're focusing 1
[I
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in on now in dealing with these issues.
()
2 I suspect the ten miles is because that was where 3
the evacuation distance is today that's specified in the 4
regulations, which is based upon risk analysis that was done 5
a long time ago that shows that beyond ten miles, you don't 6
really get exposures to people that cause acute health 7
effects.
8 DR. KRESS:
But one of your goals ought to include 9
something other than acute health effects.
10 MR. KING:
Excuse me.
Say that again.
11 DR. KRESS:
It seems to me like one of your 12 regulatory objectives are to prevent releases even though 13 they're not big enough to cause acute health effects.
14 So you probably -- that calls for looking at the
)
15 full range of transport out to 50, 100 miles or whatever, it 16 seems to me, because although you don't have acute effects, 17 you have other types of effects that you -- I think rightly 18 so, you have a regulatory objective to prevent those.
19 I think you could deal with those all in FC curve 20 space, frequency consequence of release of given amounts.
21 So that 22 DR. APOSTOLAKIS:
Is anybody looking into FC 23 curves seriously?
24 DR. KRESS:
That's why we sort of advocated those 25 a little bit in the first place, because they seemed to ANN RILEY & ASSOCIATES, LTD.
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-s 34 1
encompass, to some extent, all of your objectives in one
()
2' set.
3 MR. KING:
Joe Murphy has got the lead for this.
4 He's looking at them.
He's pulled some out and we've gone 5
through them.
6 DR. APOSTOLAKIS:
So full circle, back to what 7-Ridge Farmer said in '67, that's interesting, if we do.
8 MR. KING:
If we do this.
9 DR. APOSTOLAKIS:
Now, this workshop on the ninth, 10 what day is the ninth, does anybody know?
11 MR. KING:
I think it's a Tuesday.
The workshop 12 is going to be at 13-MR. BARTON:
November 9 is a Tuesday.
14-MR. KING:
It's going to be up the street here at
/"~'i
. ( j/
15 the Double Tree.
16 DR. KRESS:
Is that the week we're here?
I 17 MR. MARKLEY:
No, the week before.
l 18 MR. KING:
But what we want to do in this Federal 19 Register notice --
i 20 DR. APOSTOLAKIS:
Oh, I know what I'm doing, yes.
21 Okay.
I'm up in the air, so I can't come.
]
22 MR. KING:
We want to lay out the options, the 1
23 pros and cons, some questions, so that people have something 24 to chew on before they come to the workshop.
25 DR. APOSTOLAKIS:
So this is only on the safety b
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goal revision.
()
2 MR. KING:
Only on the safety goal revision and 3
it's going to focus on these issues we just talked about.
4 DR. KRESS:
Do we have to have a special 5
invitation to come?
6 DR. APOSTOLAKIS:
No.
It's NRC.
7 DR. KRESS:
It's here?
8 MR. KING:
It's up the street at the Double Tree 9
Hotel.
10 DR. APOSTOLAKIS:
So these overarching principals, 11 the objectives that we keep asking in our letters, you are i
12 not working on that right now, because for that you want to 13 have a separate SRM.
14 MR. KING:
We asked Commission permission to do
,("'\\
(,/
15 the feasibility study.
We have not gotten permission yet.
16 We're not doing anything on those.
17 DR. APOSTOLAKIS:
So Murphy working on this is not 18 actually thinking about the'overarching principals, also, 19 because you are waiting for --
i 20 MR. KING:
He may be thinking about them, but he's 21 not writing anything down.
22 DR. APOSTOLAKIS:
But that's an important point, 23 though, because I think having those objectives is really --
24 in fact, if I can read one sentence from the letter dated 25 December 14 to Dr. Travers, articulation of the regulatory i
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1 objectives should be a restatement of the NRC's mission l (
2 related to what it may consider to be the complete
\\)
l 3
definition of safety,-as contrasted to risk.
l 4
So clearly this committee feels this is extremely-L 5
important and that seems to be left out of the writing.
I 6
don't know what else we can do.
The Commission is obviously 7
thinking about it.
8 Wasn't it a question by Commissioner McGaffigan at 9
the last meeting regarding cost of doing all this stuff?
10 MR. BARTON:
Yes.
11 DR. KRESS:
He didn't think it was --
12 MR. BARTON:
He didn'c think it was worth it and 13 it would be too long and too costly or something, is the 14 comment he made.
It's in the writing there someplace.
)
15 DR. APOSTOLAKIS:
So who would be addressing this
'16 concern, the staff?
17 MR. BARTON:
I guess so.
18 DR. APOSTOLAKIS:
Or should we do something, if we 19' feel --
20.
DR. KRESS:
That might be part of our meeting with 21 the Commission.
22 DR. APOSTOLAKIS:
That's a good idea.
Maybe we 23 should do that.
24 MR. BARTON:
This item is on the Commission 25 briefing.
L l
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DR. APOSTOLAKIS:
It is?
)
'2 MR. BARTON:
I think so, risk-informed Part 50.
3 DR. APOSTOLAKIS:
Okay.
So we can raise it 4
ourselves.
5 MR. BARTON:
You can raise it at that time.
6 DR. APOSTOLAKIS:
That's not the same thing, 7
though.
8 DR. KRESS:
I don't think the policy, the safety 9
goal policy.
10 DR. APOSTOLAKIS:
No, it was not.
11 MR. MARKLEY:
I think that discussion is more 12 focused on the Part 50 rather than necessarily the goals.
13 DR. APOSTOLAKIS:
Unless we bring it up.
14 MR. MARKLEY:
Yes.
)
15 DR. KRESS:
We could include it.
16 DR. APOSTOLAKIS:
This is really an important 17 issue.
18 DR. KRESS:
Yes.
19 MR. KING:
Let's move on.
i 20 DR. APOSTOLAKIS:
One question.
This is a report i
21 from the PRA implementation plan.
22 MR. KING:
Right.
l 23 DR. APOSTOLAKIS:
And as you know, there has been i
24 criticism of the plan, I believe, also, criticism of the 25 agency by the CSIS, is that the acronym?
That we don't ANN RILEY & ASSOCIATES, LTD.
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E 38 1-appear'to have a strategy.
-( )
12L MR. KING:
GAO made that.
3-DR. APOSTOLAKIS:
GAO said that. MR.. KING:
We're going to talk about that.
5 DR. APOSTOLAKIS:
I thought the CSIS said.the same 6
thing.
7 MR. KING:
The CSIS said we don't have a good 8
definition of what our safety --
9 DR. APOSTOLAKIS:
That's definitely one of the 10 things they said.
Anyway, independent 11-MR. KING:
Slide 19 and beyond is where we're 12 going to talk about tlie GAO recommendations.
13 DR APOSTOLAKIS:
But I wonder whether what you 14 are presenting here, Tom, ic really a plan.
Is it really a O
(,,/
15 plan?
16 MR. KING:
That's part of the problem.
What we 17 have in today's PRA implementation plan is a catalog.
It's 18 not a plan and it's arranged by office and here is what each 19 office is doing in the PRA area.
20-DR. APOSTOLAKIS:
So you will address that when 21 you come to the GAO report.
- 22 MR.' KING:
Yes.
Next item,. Rich is going to talk 23:
a little bit about the risk-informed licensing actions that 24' have been taking place.
25 MR. BARRETT:
When we briefed the Commission in O
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early September, we had a section on risk-informed licensing (R-]i 2
actions.
So we include it here, but, in fact, I don't think 3
we should spend much_. time on it today.
We had a very 4
extensive briefing for the ACRS back in April.
Mark Rubin 5
went through it in quite a bit of detail for this 6
subcommittee, as well as for the full committee.
7 And in large measure, nothing has changed in terms 8
of where we're going and what we're trying to accomplish.
I 9
would like to say that this is an ongoing program.
It's a 10 healthy program.
We continue to get submittals from the 11 industry, we continue to turn them around at a healthy rate.
12 Right now, what we're trying to do, more than 13 anything else, is to focus on making this type of licensing 14 action as much -- as close -- resemble as much as possible r"
(,x) 15 every other licensing action we do.
Specifically, 16 quantitatively, in terms of the timelines with which we can 17 turn these things around and the resource burden associated 18 with reviewing these licensing actions.
19 We're trying to get to the point where we can 20 essentially do these in the same -- with the same amount of 21 effort and with the same timeliness as with other licensing 22 actions.
23 We think we're doing pretty well on that, but one 24 of the things we're trying to do is to develop the 25 capability to monitor both those parameters, so that we can
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have a quantitative measure of how well we're doing.
l, ~)
2 So I really would propose not to dwell very much
\\_/
3 on this particular aspect of the PRA implementation plan.
I 4
think it's something we've discussed a great deal in front 5
of the committee in the recent past.
6 MR. KING:
The risk-informed reg guides.
When the 7
Commission approved issuing those as final guides, they also 8
said do an annual review of those guides to see uhat needs 9
to be updated to keep them current.
10 That annual review came due over the summer.
We 11 issued two memos to the Commisrion, one in June and one in i
12 August, that said based upon the experience to date, here i
13 are some areas that we think need to be updated and we 14 proposed a schedule to go update the guides.
(/
15 What I've listed here is just a quick summary of 16 the areas that we feel right now are candidates for revision i
17 in the regulatory guides.
These revisions would start 18 sometime early next calendar year.
19 Reg Guide 1.174, if we get a PRA standard, we
~
20 certainly want to endorse it.
We had said, when we issued 21 the guide originally, that we needed to think about 22 additional guidelines for the shutdown condition, because 23 right now it's just CDF, based upon the low power and 24 shutdown work that Mary is going to talk about later, that 25 comes out of that, we may propose some additional more l
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1 specific guidelines for the shutdown condition.
()
2 And then it was pointed out that we have risk 3
. guidelines in 1.174, particularly a lot of plants, like half 4
the plants doing the IPEEE didn't use seismic PRA, they used 5
seismic margin; should we put something in that deals with 6
that methodology and allows -- provides some guidelines, l
7 So those are the three main areas in 1.174.
8 DR. KRESS:
Do you recall Rick Sherry's paper on 9
that' subject?
10 MR. KING:
On seismic margins?
11 DR. KRESS:
Yes, and'how to convert them into risk 12 numbers.
13 MR. KING:
No, I don't remember that.
14 DR. KRESS:
There ic such a paper.
You'd probably
)
15 want to look at it.
16 MR. KING:
I'd like to see that.
17 DR. KRESS:
I don't know -- I don't want to 18 endorse it, but it's something you might want to look at.
19 MR. KING:
Mike can get us that?
20 DR. APOSTOLAKIS:
Regarding 1.174, a I remember, 21 it's been a while since I looked at it, but as I remember, 22 there isn't really very much in 1.174 on importance measures 23 and it turns out that very important risk-informed decisions 24 are based on the use of importance measures.
25 In fact, risk-informed ISI, risk-informed GQA, the
?
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regulatory guides deal exclusively with importance measures.
([
2' It seems to me there is a disconnect between the general 3
guidance and the applications.
It would be nice, when you 4
revise'1.174, to give it -- to pay attention to the L
5 importance measures, the attention they deserve, and offer 6'
astute comments as to how, by using that, does one really --
l 7
it's not' clear how one complies with -- whether one complies 8
with 1.174 delta CDF and delta LERF guidelines, because we
(
9 don't have the models to calculate delta CDF and delta LERF.
10 And we take it on faith that if you categorize the 11 components according to RAW and Fussel-Vesley, it makes 12 sense then to relax some of the requirements.
13 Tomorrow we'll have more on that, but I think it's 14 an important omission because if you -- if a new reader
()
15 reads only 1.174, that person will have no idea that these 16 very important activities are taking place in the name of 17 1.174 without really having a direct connection to 1.174.
18 So I think a good discussion there, right after 19-you have figure 3 and 4, delta CDF and delta LERF, would be 20 really very appropriate, becauce that will give you the 21 opportunity also to think again about the connection between 22 the two.
23 DR. KRESS:
I suspect if you ever get around to 24 including these other objectives in the policy statement, 25 those might have to show up in future version 1.174.
4 O.-
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MR. KING:
Yes, that's true.
I( )
'2 DR. KRESS:
But that's sometime in the future.
3 DR. APOSTOLAKIS:
Now, regarding the importance f
4 measures, I was doing some simple calculations on the plane l
5 and I must.say I got very perplexed.
And tomorrow, again, 6
we'll see that basically what the revision to Part 50 is, at 7
this point, is really a reclassification of components and l
8 systems and structures to some new category that will be 9
safety-significant, not safety-related.
10 And the basis for those things are really the 11 importance measures.
So I'm wondering whether we have 12 really thought about importance measures and what they mean 13 and I'm toying with the idea, Mike tells me I can do it, so 14 I may do it.
Tomorrow morning I will use a slide or two to
()
15 show you why I am perplexed.
16 But I can give you the flavor of it right now, if 17 you want.
18 MR. KING:
Sure.
i 19 DR. APOSTOLAKIS:
Take a simple system, where you 20 only have one accident sequence, just one, and it has three 21 elements, one, two and three.
One can be the initiating 22 event and the othe.r two the unavailability of systems.
23 So the product or the three frequencies are j
24 unavailabilities is the ultimate bad thing, the core damage.
25 DR. KRESS:
The contribution.
l I
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DR. APOSTOLAKIS:
Yes, but there is only one I \\
<V sequence in this fault experiment.
So I ask myself what is 2
l 3
wrong for each of the elements.
And if I take them as 4
having the same unavailability, if you do the calculation, 5
it's one-over-Q.
So if the unavailability is 6
ten-to-the-minus-two, RAW is 100, because RAW says take the 7
unavailability,'the baseline availability, set Q equal to 8
one-for that component, and divide by the total.
9 Now, the total is the product of the three.
In 10 the top, you have the product of the remaining two.
So it's 11 one-over-Q1.
And Fussel-Vesley is one, because there is 12
-only one minimal cut set.
So the numerator and the 13 denominator are the came.
Right?
14 So now it appears -- well, okay.
So now, what do
()
15 I have?
I have a RAW of one-over-Q and a Fussel-Vesley of 16
'one.
Now, I'm saying, well, gee, I really want to improve 17 my system.
I'll go out of my way to improve my system.
18 So I had only two components to save me and now 19 I'm adding 100.
Defense-in-depth at the extreme, right?
20 One after the other, all of them must fail.
So now I have a 21.
' huge accident sequence that must -- that has 100 plus 303 22 elements.
23 Calculate RAW again.
Still 100.
Calculate 24 Fussel-Vesley. Still one.
Nothing happened.
25 DR. KRESS:
So you've got 100 things and I'll have
('s)
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h:
45 1
a RAW of 100.
()'
2 DR. APOSTOLAKIS:
That's one observation.
The 3
other observation is that I went through this extraordinary t
4 expense and I-have not affected RAW, I have not affected 5
Fussel-Vesley for the original component, and I don't know.
l l
6f I mean, it was just two hours ago.
I don't know what the
'7 consequences of that are.
8 I think what's missing.here, Tom, is the absolute 9
value of the core damage frequency.
We are working only 10 with relative stuff.
So in a relative RAW sense, it's still 11 100.
The fact that you spent five million to improve the 12 system is completely irrelevant, and that bothers me.
13 Then I go to another case.
Suppose now there are 14 two accident sequences, the original one plus another one.
I 15 The system must be worse, right?
Because now there are two 16 ways it can fail, two minimal cut sets.
17 And I recalculate the RAWS and now they are 18-smaller.
Do the calculations.
It's not one-over-Q anymore.
19 It's smaller.
So because I have a new way of failing the 20 system, the importance of the original component went down.
21.
DR. KRESS:
Becauce of parallel paths.
22 DR. APOSTOLAKIS:
Yes.
But isn't that crazy?
23 That's crazy.
But by making the system worse, the l
24 individual risk must go down, and Fussel-Vesley.
It goes 25 down.
It's not one anymore.
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Fi 46 1
So I'm able to put those in a viewgraph for (e<}
'2 tomorrow morning, because I don't have the answers myself.
3 But I think what happened is that people developed these 4
things in the past and now just use them, it's simple to i
5 use, and say, well, gee, that's great.
But I'm not sure 6
that anybody really has sat down to think about what exactly i
7 these things mean.
8 I don't understand why, by having an additional 9
accident. sequence, it diminishes the importance of the 10 original components.
11 MR. BARTON:
It sounds like you're perplexed, 12 George.
13 DR. APOSTOLAKIS:
I am completely perplexed.
So 14 tomorrow morning you may get it in writing, but that's
()
15 essentially the essence of it.
16 MR. KING:
Okay.
All right.
Let me just quickly 17 go through the rest of these reg guides.
The one on tech 18_
specs, we had this tier one, two and three concept in there.
19 Tier two was really a configuration risk management program.
20 With the maintenance rule now requiring that, we don't need 21 the tech spec reg guide to put the same thing on.
So that's 22 a change we propose.
23 DR. APOSTOLAKIS:
Let me understand what this is.
24 Reviews of the tech spec AEOD request indicates the tier 25 two.
What.is tier two?
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MR. KING:
Remember, that was the configuration I )h 2
risk management that they had to analyze.
\\_
3 MR. BARTON:
That they put in their tech specs.
4 They went for an extended period of time.
5 MR. KING:
With an extended allowable outage time.
i 6
DR. APOSTOLAKIS:
I'll go back and -- that's fine.
7 MR, BARRETT:
I think it's actually tier three.
j 8
DR. APOSTOLAKIS:
Now, regarding the allowed 9
outage time, you will still have that five-ten-to-the-minus l
10 seven probability.
i 11 MR. KING:
That is, yes, probability, that is 12 still in there.
13 DR. APOSTOLAKIS:
Still in there.
It's 14 interesting.
I was reading a paper written by three guys f.
s
()
15 from Southern California, Don Hook being one, on their risk 16 monitor and they say something interesting there.
They say 17 that when they have -- when they are in these temporary 18 conditions, they have also a limit on the -- an upper bound 19 on the condition of core damage probability, like everybody 20 else does, but then they go on and say but we are really 21 believers in conservative risk management, so we also have a 22 bound on the condition of core damage frequency, which is 23 such and such.
24 So they don't only look at the integral over time, 25 but they also want the CCDF never to exceed that bound,
,Q(. /
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which is interesting.
It's more conservative than this I
2' regulatory guide and, again, the question is whether the 3
staff has thought about these things.
4 MR.- KING:
That's one of the safety goal issues.
5 I.didn't put it on the slide, because I didn't think it was 6
at the magnitude of the others, but should we have some 7
guidelines!on temporary risk conditions.
8 DR. APOSTOLAKIS:
Okay.
9-MR. KING:
So that's one of them.
10 DR. APOSTOLAKIS:
Fine.
But I thought it was 11-interesting that the licensee was doing something more 12 conservative.
J i
13 MR. KING:
The other thing that's being thought 14-about now is those same conditional probabilities that are
)
15 in the tech spec reg guide are being considered for 16 implementing the new maintenance rule A-4 requirement.
So 17 it would be the same numbers.
18' The Reg Guide 1.175, the IST guide, there has been 19 some feedback about even though things are categorized as 20-low safety significance, we still require too much testing.
21 So the staff is thinking about ways to relax tha.t in the 22 revision and, also, if the ASME code cases on risk-informed
-23 IST ever get approved, we'd go ahead and reference those, as 24 well.
25 GQA is sort of on hold at this point.
We don't
[)
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l 49 1
have any specific recommendations.
So there was a rule that
()
2 was issued in April of tilis year that allows plants to make i
3 changes to their QA programs on a 50.59 type process.
If l
l 4
another plant had been approved to make those changes, 5
similar plants are allowed to come in and put them in 6
-without any prior staff review and approval.
So that may 7
take care of a lot of the problem.
I don't know if Rich l
8 wants to talk anymore about that.
9 Then Reg Guide 178, the ISI one, remember, we 10 issued for trial uLe or scheduled to incorporate experience 11' and issue it as'a final in June.
12 DR. APOSTOLAKIS:
Tom, it appears to me that you 13 are halfway through your presentation.
You have 24 14 viewgraphs.
Shall we take a break here?
()
15 MR. KING:
Whatever you want to do.
16 DR. APOSTOLAKIS:
Okay.
Recess for 15 minutes.
i 17 Be back at 2:25.
j 18
[ Recess.]
19 DR. APOSTOLAKIS:
We're back in session.
So we're i
20 on viewgraph 12.
21 MR. KING:
Number 12.
Number 12 is something that 22 was discussed in a SECY paper,99-182, but I'm not sure how 23
.much.the committee-saw it or discussed it.
I thought it was 24 an important' piece of work and that we had been asked by the 25 Commission to look at the risk impact of exemptions to l
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V; 50 1-Appendix R.
(m) 2 We approached that by taking nine plants whose 3
IPEEEs said that the fire risk from those was at the high 4
end-of the list.
We excluded Quad Cities because that had 5
been looked at separately and they were off doing things as 6'
a result of that.
But we looked at nine others and came out 7
with results.
8 There were 169 exemptions that were looked at.
9 Most of them turned out to be non-risk-significant, but 10
.there were several that were risk-significant, and I've 11 asked Alan Rubin, if you wanted more detail on what was done 12 and what they came up with, he's here to -- he did the study 13 and he's here to talk to you about it.
14 But there is going to be some follow-up action by
()
15 NRR on the ones that they found that were risk significant.
16 DR. APOSTOLAKIS:
So can you give us one example, 17-Alan?
18 MR. RUBIN:
Let me just make a general observation 19 now.
We based our analysis on IPEEE results and we felt 20 that the overall big picture was very robust, the 21 conclusions that the large majority of the exemptions were 22 not risk-significant, were either small or indeterminate.
23 For the plant-specific results, we need to follow 24 up to verify the' analysis.
So an example is at one plant, 25 in an area where there was a high core damage frequency or
/
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ac.
51 v
11 high contributor to core damage frequency for that plant, i.
/~ \\
2 the cable vault area, the lack of automatic fire suppression l V
-3 covering the entire area and also lack of a one-hour fire 4
barrier.
5 So we're following up to see whether or not indeed 6
the data that we've got in the IPEEE submittal, in our 7
analysis, bears out when we go back and talk to the utility.
8 DR. APOSTOLAKIS:
So the utility had requested an 9
exemption.
10 MR. RUBIN:
This was going back historically, in 11; the past, had requested an exemption.
Yes.
I 12 DR. APOSTOLAKIS:
They didn't have an automatic 13 suppression system?
14 MR. RUBIN:
Not complete coverage in this case, l
15 yes.
16 DR. APOSTOLAKIS:
Now, it turns out, what, that 17 not having that makes the CDF high?
18 MR. RUBIN:
By definition, we looked at high risk 19 significance as a potentially -- we call them potentially 20 risk significant, it's greater than ten-to-the-minus-fifth 21 contributor to CDF.
It was consistent with Reg Guide 1.174 22' definitions.
23 DR. APOSTOLAKIS:
So the exemption there -- I 24 mean, if I were to submit an application, a request, 25 following 1.174, I would say I don't want to put in an I
O
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52
.11 automatic suppression system in.this particular room, and
()
2:
here is the reason,~and then it wouldn't pass.
That's what 3-you're saying.
4 MR. RUBIN:
. hat I'm saying, one of the -- Tom W
- 5 mentioned.the follow-up activity that we're doing is on the 6.
specific plants that we found potential risk significant 77
. exemptions.
I,think it's.particularly significant.
8 Another' follow-up actio t -is. that in the future, 9
Lwe're going to encourage licensees to'make exemption 10 requests risk significant, provide information in the 11' Appendix R~ area that,'as a basis,.looking at their IPEEE 12 results to-see whether the exemption effects scenario, that 13 high risk contributor, for example, provide that information 14 in their exemption-request.
)
15 DR. APOSTOLAKIS:
When they requested the 16 exemption,-what arguments.did they give'you?
17 MR. RUBIN:
Pretty much,uit's deterministic.
18 DR.'APOSTOLAKIS:
Yes.
But I'm curious to know,
.19 because it's interesting that on a deterministic basis, D20 their request was approved and now we find that in a
.21 probabilistic basis, it might not have been approved.
22 LIs there anything we can read to understand better 23' Ewhat I
24' MR. RUBIN:
We'd have to go back.
That's one of 25-the follow-up actions we're doing, to look at those specific O
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53 1
exemptions.
And it's a relatively small number.
Only --
()
2 there are really only five exemptions out of 169 that were 3
in this category of-potentially risk significant.
4 DR. APOSTOLAKIS:
Could you send us anything to 5-read?
6 MR. RUBIN:
Yes.
There's a SECY paper that's 7
available.
8 DR. APOSTOLAKIS:
On this particular issue?
9 MR. RUBIN:
On this, yes.
10 MR. KING:
And the numbers are on the viewgraph 11 there.
)
12 MR. RUBIN:
13 DR. APOSTOLAKIS:
I'd like to look at that.
14 MR. KING:
But I think the answer to your question r
15 is yes.
If this had been a risk-informed exemption request, 16 it would have been denied.
17 DR. APOSTOLAKIS:
And I want to understand better 18 why.
That's an interesting situation.
19 MR. BARRETT:
What's interesting, from our 20 perspective in NRR, is that the SECY paper gives some 21 guidance as to the characteristics of the types of 22 exemptions that might be risk-significant versus the types, 23 the vast majority of the exemptions which are not 24 risk-significant.
25 So what we're planning -- what we're doing right
[ ')
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now is developing guidance for how to screen these Appendix
()
2 R exemptions so that we can decide which ones to kick up for 3
risk look, and then if, upon examination, it looks like it 4
might be risk significant, we would open a dialogue with the 5
licensee on that.
6 DR. APOSTOLAKIS:
Last time we had a presentation 7
here, I believe you were here, Rich, discussing the P
. authority O(..the staff to invoke risk arguments when the 9
licensee does not use them.
y 10' MR. BARRETT:
Right.
11 DR.-APOSTOLAKIS:
This would be a good case, 12 right?
The licensee comes, thinks they have a good case and s,
13 a deterministic. basis not to do something, then you come 14.
back and say, no, on a risk basis,.you can't, there goes the (A) 15 two-tier system.
16 MR. BARRETT:
This is a little different from a 17 regulatory perspective because this is a case where a 18 licensee proposes not to meet the rule, whereas the paper we 19 discussed last month was what to do if they meet the rule 20 and yet you think there is a risk issue.
21 But technically, it is still the same problem.
t 22 DR. APOSTOLAKIS:
Conceptually.
23 MR. BARRETT:
Yes, right.
So what we're planning 24 on doing is implementing this guidance informally and then 25 after we've identified the first case, then I think we'll be ANN RILEY & ASSOCIATES, LTD.
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developing general guidance on how to deal with these things (h
2 and put out some guidance to the industry.
3 And as Alan said, we would like to encourage 4
certain types of Appendix R exemptions to be risk-informed.
5 DR. SHACK:
Just out of curiosity, what are your 6
tools for doing this risk impact assessment of the Appendix 7
R exemptions?
8 MR. BARRETT:
Well, if we identify one that looks 9
like it's risk-significant, the first thing we would ask is 10 for the licensee to use their risk model.to address it, 1
11 which, in this case, would be their IPEEE.
12 If the licensee chooses not to do that, then we 13 would have to go and look at -- I really don't know where we 14 would go at that point.
We might have to actually look at 15 their IPEEE.
16 MR. RUBIN:
Let me give you an example of what we 17 did as our study, and, again, with limited resources, we had 18 a lot of exemptions to look at.
We would take a case where 19 there was an exemption and.look at the IPEEE and if that was 20 in an area that was a dominant risk contributor, generally j
21 that was' listed as what contribution that was to core damage 22 frequency for the plant in the fire area.
23 We would then go and say, okay, if the exemption l
24 were not granted and there were a different -- automatic l
25 fire suppression was included at the plant, how would that i
l O
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(
)
2 overall. contribution to CDF, and we find a delta of
\\~/
3
. ten-to-the-minus-fifth or greater, we considered that 4
potentially risk-significant.
5 Less than ten-to-the-minus-sixth, we said small or 6
very small, basically a non-contributor to risk.
So we're 7
relying on the best information we have.
There are 8
limitations that are discussed in the Commission paper and 9
using IPEEEs, but it really is probably the best and most 10 solid information that we have available to do this kind of 11 assessment.
12 MR BARRETT:
The ground rules for this kind of a 13 licensing action are different than for, say, a license 14 amendment.
10 CFR 50.12 gives the criteria under which the 15 staff may consider granting an exemption and those criteria 16 are different than the finding you would make for approving 17 a license amendment.
18 It's a somewhat higher hurdle to cross.
19 MR. KING:
Okay.
Fire risk methods, just quickly.
20 We'll talk about three risk methods.
First, fires.
We had 21 issued, back in June, a program plan on fire risk research, 22 and I know we've got a -- I believe there is a meeting 23 scheduled with the subcommittee in November, so you will 24
-hear more about it then. But that started about nine months 25 ago, the work on fire risk.
t 1
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It still has a long way to go, but it has, to t( )
2 date, helped out on developing, for example,-in the IPEEE, 3
developing the questions to ask licensees, providing some 4
information on how to evaluate their heat loss factors, for 5
example.
6 So it's feeding into IPEEE at this point.
It's 7
developing information for model validation, but there's 8
still quite a few areas that need to be done.
And I don't 9
intend to go into this in detail, since you'll get a 10 separate briefing on it, j
11 DR. APOSTOLAKIS:
We will be briefed in a month, j
12 is that what you said?
l 13 MR. KING:
November, I understand.
I don't know l
14 the day.
)
15 DR. APOSTOLAKIS:
The full committee or the 16 subcommittee?
i 17 MR. BARTON:
It's a subcommittee meeting, I think, l
18 in November.
l 19 DR. APOSTOLAKIS:
Subcommittee.
But then there 20 will be a full committee meeting.
21 MR. KING:
We would like to get your letter on the 22 plan we sent you back in June.
f 23 Methods to address aging, the risk of aging.
We j
24 had done a feasibility study, the draft report has been 25 issued, that looked at one aging mechanism, flow accelerated
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corrosion.
It looked at the application of that Surry plant
/
)
2 to determine the-practicality of implementing such a model.
3 DR. APOSTOLAKIS:
These two bullets there, who did 4
that work?
5 MR. KING:
A contractor did this work.
I think it 6
originally. started at INEL and they had a subcontractor.
7 DR. APOSTOLAKIS:
Yes.
I have a conflict of 8
interest with.this, too.
9 MR. KING:
I'm not sure it's a subcontract with 10, you or the university, but you're involved in-this, 11 DR. SHACK:
You have to ask, George?
12 MR. BARTON:
Guilty by association, George.
13 DR. APOSTOLAKIS:
The third bullet there was a 14 little bit of a red flag to me.
I gave a paper on that up
(
15 here.
So Dr. Kress is chairing now.
16 MR. KING:
We're still looking at the feasibility, 17
.whether we ought to continue this program, extend it to 18 other aging mechanisms, how practical is it to implement, 19 and how do you treat uncertainties given that, in some 20 cases, if your model works really well, you're not talking 21 about random failures, you're talking about being able to 22
. predict when something will fail due to aging mechanisms, l
23 whether it's flow accelerated corrosion or thermal fatigue 24 or.whatever.
25 If you do a good job, it's not a random effect i
[
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anymore.
It's a failure prediction.
So in the next few 2
months --
l 3'
DR. SHACK:
Does this try to include the effect 4
of, say, your inspection. program to prevent the failure?
5 MR. KING:
I'm not sure I can answer that level of 15 detail.
7 DR. APOSTOLAKIS:
So far, no.
8 MR. KING:
We'd certainly -- if the committee 9
wanted to be briefed on this, I don't think we have any 10 separate briefing schedule for the subcommittee on this 11 program, but it could be arranged if you felt you wanted to 12 hear more about it.
13 DR. KRESS:
Speaking as the Chairman, I think it's 14 definitely an area we'd want to hear about later, whenever 15 it's ready.
16 MR. KING:
Okay.
j 17 DR. APOSTOLAKIS:
Do you want him to bring the 18 contractor?
19 DR. KRESS:
Yes, and you can bring your contractor 20 along.
21 MR. KING:
All right.
Low power and shutdown work 22 is underway.
Mary can talk briefly about it.
There is a 23 separate briefing schedule, again, in November to the 24 subcommittee, so we won't spend much time on it.
But I know 25 there have been a number of plant visits and visits to EPRI O
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and so forth after our workshop that we had back in April.
)
- 2 '
DR. APOSTOLAKIS:
So what is the consensus?
It t
3 says here -- am I back on?- Yes, I'm back on the i
4 subcommittee.
5 The last bullet says that there is consensus that I
6 it maybe significant.
In fact, I think from the studies we J
7 have seen, there should have been consensus view that LPSD 8
risk'is significant.
9 It may be significant for an individual plant, but
)
10 it's agreed it is significant, is it not?
Several PRAs have 11 showed that.
12 MS. DROUIN:
All that bullet was trying to say, 13 George, is that prior to.the workshop, in terms of the NRC, 14 we had looked at strictly Surry and Grand Gulf and can you O(_,/
15 extrapolate that to the industry.
16 So we had the workshop.
Industry is coming in and 17 they're just saying yes, when you look at lower power i
18 shutdown, you need to be concerned about the risk, it is 19 comparable to full power.
So there is not a debate there, 20 is all I'm trying to say.
21 DR. APOSTOLAKIS:
That's, in fact, why I'm raising 22 the question.
The question, as I recall, when we met, was 23 should -- and I think the Commission is very much interested 24 in this -- should the agency start from scratch, so to 25
. speak, or from the two studies t the two national labs 04 ANN RILEY & ASSOCIATES, LTD.
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did and take it from there and then the concern is that that (p)
- 2 may be too expensive, or has the industry or other parts of 3
the world made significant strides in this area, so we don't 4
have to reinvent the wheel everywhere.
5 So what is it that you learned from these site 6
visits and meetings.with the developers?
Did you find out 7
that they went beyond what Brookhaven and Sandia did or they 8
are simply copying those methods?
9 MS. DROUIN:
What you have seen is a complete 10 range going from one extreme to the other, where some 11 utilities have done nothing to some utilities who have 12 developed very detailed low power shutdown PRAs.
13 DR. APOSTOLAKIS:
But have they gone beyond what 14 BNL and SNL have done?
)
15 MS. DROUIN:
No.
16 DR. APOSTOLAKIS:
No.
17 MS. DROUIN:
No.
18 DR. APOSTOLAKIS:
So the state-of-the-art is still 19 those NUREG reports.
20 MS. DROUIN:
Right.
And if you go to the next 21 slide -- and we're going to come in, like I said, in 22 November and give you a detailed briefing of what we've 23
' learned from those site visits and from other arear.
24 But everyone agrees -- and when I say everyone, 25 both at the NRC and as we went to the site visits, also,
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people who were at the workshop who weren't necessarily
[V]
2 licensees that we visited, are issues that need further work 3
and the issues are all over the place, also.
4 So'everyone agrees that additional work needs to 5-be.done in this area'and supports the idea of that, because 6
everyone is agreeing that, yes, you need to be concerned 7
with the risk from low power shutdown.
8-DR. APOSTOLAKIS:
So that confirms suspicion.
9.
Now, I think this is a very sensitive issue.
I don't think 10 that some Commissioners and'perhaps other senior managers of 11
'this agency really want to do another 1150 on this.
12 I don't think that by just saying that low power 13 shutdown risk may be a significant contributor that is a 14 reason that people will feel is compelling enough to start
()
15 the research project here.
16 I think an additional argument, which is very l
l 17 strong, in my opinion, is that the industry is doing certain 18 things to manage low power shutdown risk.
They use ORAM, 19 SENTINEL and so on, which is a mixture of risk insights and 20 deterministic, say, defense-in-depth kind of things; do you 21 have means to cool the core,'that kind of thing.
22 And the argument that has bee-made on our side is 23-that the staff right now really doesn't have the analytical 24 tools to be able to evaluate the validity of what the 25 industry is doing.
Would you agree to investigate that?
)
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You may be'ablefto investigate part of it based on what BNL f()
2
'and SNL have done,.but overall,'I think that's a true 3
statement.
4:
And-the.need then to look at low power shutdown 5
risk really should be anchored on that rather than the fact 6
that it's important, because they may tell you it is 7
important,'but we are controlling it this way.
But if you 8
say, okay, that may be great, but I really can't tell, j
9 that's the whole idea of doing the research in these 10 matters, to be able to convince yourself that, yes, what 11' ORAM and SENTINEL does makes sense to us.
12 DR. KRESS:
George, I agree, but.I wouldn't want L
- 13_
to put all my eggs in that-basket either, because as I 14-mentioned before, there are two distinct types of low power
()
15 shutdown risks.
One of them is to manage outages and it's 16 an instantaneous risk meter, and that's what you're talking 17' about.
I personally think that's in fait 2y good shape.
18 DR. APOSTOLAKIS:
Yes.
19 DR. KRESS:
But you do need a way to monitor it, 20 like George says.
The other part of that is what 21 contribution does this make to the average overall risk over 22 the. lifetime of a given plant for putting into your 23 risk-informed regulatory procedures has nothing to do with 24
-instantarcous risk.
Well, it does, but not much.
And 25 that's an entirely different application --
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MS. DROUIN:
I agree.
()
2 DR. KRESS:
-- that takes a different PRA and --
3 DR. APOSTOLAKIS:
You're right.
4 DR. KRESS:
for use in that, I think that's 5-another strong motivator.
6 DR. APOSTOLAKIS:
I agree.
7 MS. DROUIN:
And that's the one, because what you 8
see when you do look at ORAM and all of these, they are 9
exactly that.
They are configuration control management 10 tools.
They' don't go in and calculate the risk of the 11 plant.
And in doing that --
12 DR. KRESS:
It's an instantaneous risk.
13 DR. APOSTOLAKIS:
Let's call it conditional.
No,
14 I fully agree.
I fully agree that for risk-informed
()
15 applications, we have to have a good number from there.
So 16 that's a third argument.
17 MS DROUIN:
And a good model.
18 DR. APOSTOLAKIS:
But it seems to me, based on my 19 impression now, and talking to various groups, the only 20 argument that really flies at this point is the ability of 21 the -- the lack of the tools, the ability of the staff to 22 really look at what the industry is doing and say, yes, we 23 like it, or maybe you should change this.
24 I notice the Commissioners are much more willing 25 to listen if you tell them that than if you say no, it's I
)
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'l important, we have to understand.
'(
2 MR. KING.:
Isn't it really more than that, though?
3 Right now we have 1.174 that doesn't say much about how do 4
you deal with a shutdown, what's important, what should you 5
look for.
We don't need a full benchmark PRA every time 6-somebody wants to go in and do something that affects the 7
shutdown condition.
8 If we can get some insights out of work that's j
9 been done by industry, by overseas, wherever, that says 10 these are the plant conditions that are important, some are 11 relative or ballpark idea of how important they are, and t -l 12 then just use that as some sort of checklist or evaluation 13 tool for looking at licensee submittals, so if they're not 14 in this condition, we don't worry about it; if they are, we 15 do. worry about it.
16 DR. APOSTOLAKIS:
Submittals for what?
17 DR. KRESS:
License amendments.
18 MR. KING:
License amendments.
19 DR. APOSTOLAKIS:
License amendments.
20 MR. KING:
We've also had operating experience 21 that says things, risky things happen in plant 22 configurations that were not analyzed in the Brookhaven and 23 Sandia studies.
They focused in on a couple of specific 24 plant operating states, but they're not the ones that always 25 pop up as the risky ones.
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DR. APOSTOLAKIS:
And I think this, again, brings n
(
i 2
up the issue of objectives.
I keep coming back.
Because x/
3 some people make the argument that the risks simply cannot 4
be comparable because the hazard is lower.
5-On the other hand, perhaps if you look at it from 6
the public risk perspective, maybe there's come point there.
7 But can you really afford an incident, you know, start 8
spilling radioactive water into containment and so on and 9
there is panic and emergency and so on, even though nothing 10 happens outside?
No, I don't think we can afford that.
11 And I think, again, that comes back -- that's the 12.
first; cornerstone of the staff oversight process.
We don't 13 want initiating events.
But we are not really stating that 14 as an overarching principle anywhere.
)
15 So, again, I think people are talking in different 16 wave lengths there.
One person says, well, gee, from the 17 public health and safety perspective, I really don't think j
18 this is that important.
But then others worry about it, and 19 I think that there is this intermediate objective that j
20 people are concerned.
'21 So really we need those principles somewhere.
-22' MR. KING:
I agree.
23 DR. APOSTOLAKIS:
You don't always have to kill 24 people outside the containment.
25 MR. KING:
No.
[
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67 1-DR. APOSTOLAKIS:
In order to worry about it.
]
2 MR. KING:
No.
We just have to get them excited 3
and that's enough.
4 DR. UHRIG:
We've already had one incident with --
5 I think it was Vermont Yankee, went critical with the lid 6-off, about 20 years ago, 15 years ago.
They had a 7
criticality.
8 DR. APOSTOLAKIS:
For:how long?
9 DR. UHRIG:
It was up in the -- I don't remember.
10 Was it kilowatt power up in the -- then they got to 11 megawatt.
It went critical with the lid off.
Somebody 12 moved something and, of course, it brings you back to the 13 SL-1 accident.
14 DR. KRESS:
That went critical, didn't it?
h 15 DR. APOSTOLAKIS:
Prompt.
16 DR. UHRIG:
I don't think it was prompt critical, 17 but it went critical.
18 MR. BARTON:
SL-1 was.
19 DR. UHRIG:
SL-1 was prompt critical.
20 MR. KING:
But anyway, I think the standards 21 effort will go a long way toward trying to give us a tool by 22 which to evaluate submittals.
23 DR. APOSTOLAKIS:
But how can the standard be 24 written when the basic work has not been done or is the 25 staff happy with the two studies that the laboratories did?
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My understanding is that they only looked at limited number 2
of data.
3 MR. KING:
The standard could be written saying 4
this is what.ought to be done.
Maybe there aren't PRAs that 5
have done all of that yet, but there's probably been enough 6
work done that you could say, gee, if I had to do it again, 7
this is how I'd like to do it.
8 Now, speaking for myself here, I'll let Mary 9
correct me.
10 MS. DROUIN:
We have in our writing group for the 11 standard identified areas that are going to be needing work.
12 You just can't write the standard there yet because the 13 work, the technology is not there.
So we have recognized 14 that, but'I don't think because there are areas that need 15 some further work, that doesn't mean you can't write a 16 standard.
You just don't write a standard for that 17 particular area.
18 DR. APOSTOLAKIS:
Well, if the standard simply 19 says additional work is needed, sure, you can write it.
j 20 DR. KRESS:
This is going to take a different kind 21 of PRA. This is going to have to be some technology 22 developed.
23 DR. APOSTOLAKIS:
Yes, that's what I'm saying,
(
24 that you have to do this basic stuff first.
1 j
25 DR. KRESS:
You can't do it.
You don't have the l'
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technology.
We can't wait till then to write the standard,
( )j f
2 DR. APOSTOLAKIS:
What's what I'm saying.
I agree s-3 with you.
Maybe I didn't say it in so many words, but.
4 DR. KRESS:
Yes.
5 MR. KING:
Anyway, this culminates in a report to 6
the Commission in December that is going to lay out where do 7
we go from here, and that's what we want to talk to you 8
about in November, and get your insights.
s 9
DR. APOSTOLAKIS:
Incidentally, I was looking at I
10 some of the risk monitoring, a paper that described what was 11 in the risk monitor the other day, and this is -- they claim 12 that they also put or they will put shortly the low power 13 shutdown model.
14 I think there is a problem there and I think it i
/~
's,N) 15 applies also to the maintenance configurations.
If you take 16 out a particular component, they go to the baseline PRA and 17 they say component A is out, let's put its unavailability 18 code to one, simple enough.
Try and count the numbers again 19 and now we have the new numbers and do whatever we want to 20 do.
21 Well, it turns out it's not as simple as that.
It 22 really is not as simple as that.
If you really look at the 23 PRA -- let me give you an example.
24 Let's say I have two trains in parallel.
In the l
25 PRA, I'm going to put various terms about the unavailability l
(')
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1 of the system.
One term is'the random, so-called random
..j 2
failure contribution, which is the product, right?
Then 3
there will be a common cause failure contribution.
That I
4 will be the unavailability of one times beta.
5 And there may be others, human errors, that's the 6.
maintenance, he torgets to do it here and then does it again 7
there.
8 Now I'm going to a situation, a maintenance 9
situation where train A is down and I go to my PRA and I 10 say, well, Q for'that train is one.
What happens is that 11 that affects only the random failure of the two trains.
12 Instead of Q-square, they will put Q.
Are you still going j
13 to keep Q beta, the common cause failure probability?
What 14 common cause is this?
()
15 That should be eliminated, it shouldn't be there 16 anymore.
Are you still going to use the same human error 17 probabilities for forgetting to re-close valves?
No.
18 Because that has a probability that they forget to do it in 19 one and a conditional probability they will repeat the i
20 error.
i 21 Well, there isn't any possibility like that 22 anymore, so that should be modified.
23 And in the case of recovery actions, now they know 1
24 that train A is down.
So it's not like it's hitting them --
25 an initiator is hitting them Christmas Eve and they're O_-
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trying to recover and so on.and that's what the PRA
(
2 analyzes.
3 Now they know this is out.
Maybe there is more 4
vigilance.
I don't know.
Maybe people are more aware of 5
what's going on.
So the probabilities that were used there 6
are not valid anymore.
7 The net result of all of this is by taking systems 8
out or trains out, and it's not a simple matter to modify 9
the PRA, it's not a simple matter of saying Q is one, and 10 I'm not sure that many people realize that.
11 DR. KRESS:
But, George, when you do that, you get 12 an effect on, say, the CDF that is conservative.
13 DR. APOSTOLAKIS:
For some of them.
14 DR. KRESS:
I would have thought all of them.
l C )\\
g 15 DR. APOSTOLAKIS:
Maybe, maybe.
Because I said 16 that you should eliminate some terms.
17 MS. DROUIN:
I agree with you, absolutely.
I 18
.certainly haven't looked at all the -- there aren't that i
19 many, but all the ones who have created low power shutdown 20 models.
The ones that I have looked at are aware that even 21 though they might start with their full power model, all 22 they're doing is taking the essence of the fault trees.
I 23 They do know to go in and change the data 24 appropriately, because you have to go in and you have to l
25 look at your test and maintenance, because that all changes, i
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your common cause does change.
(f 2
DR. APOSTOLAKIS:
Right.
l 3
MS. DROUIN:
But you made a statement of risk 6-4 monitor --
5 DR. APOSTOLAKIS:
But they don't do that.
6 MS, DROUIN:
No.
The ones I've seen have done it.
7 I think that's just a lack --
8 DR. APOSTOLAKIS:
The risk monitor does it?
9 MS. DROUIN:
Risk monitor -- that's not a feature 10 of the software.
That's a feature of the analyst.
I 11 wouldn't put that on risk monitor.
12 DR. APOSTOLAKIS:
Right.
No, but --
13 MS. DROUIN:
The risk monitor is just taking the 14 physical model.
It's the analyst who has decided what data
()
15 to put in there.
16 DR. APOSTOLAKIS:
Right.
But what I'm saying is 17 the analysts have not made those provisions.
I'm sure they 18 are aware of it, but when the utility uses the monitor and 19 we say now we're going to take this out because we're not 20 going to do on-line maintenance on train A of the emergency 21 core cooling system, and then they put that down and now you 22 see the core damage frequency going up.
23 I think that's the result of a calculation where 24 only their hardware and availability of that train was one.
25 DR. KRESS:
I think they made a judgment that that i
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1 because it's conservative, that's all that's worth doing to
()
2 Lit.
3 DR. APOSTOLAKIS:
That's speculation.
4 DR. BONACA:
I think -- no.
I know that more than 5
that is done.
All the considerations that you're making are 6
being taken into consideration.
That's why you have a guy 7
applied. full-time to doing those kind of evaluations.
He 8
just goes through the model and you have really guidelines, 9
in fact, very specific about going back and checking that, 10 for example, if there are certain cut sets where you had 11 some measure that you made, you take back the sequences and 12 you look at them, because those considerations are being 13 taken.
14 MS. DROUIN:
I am sure --
)
15 DR. BONACA:
Yes, because there is a big impact --
16 you're sure.
17 MS. DROUIN:
I am sure that you have utilities who 18 have not done it properly.
I am aware of some that have 19 done it properly.
But I would say that this is a very good 20 argument for a standard, because it would get into those 21 kinds of things.
22 DR. APOSTOLAKIS:
Nobody is arguing against it, 23 but I have not seen evidence, written evidence that this is 24 being done.
Now, if you tell me that some people are doing 25 it, sure.
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74 1-DR. BONACA:
And when you go to two components out
()
2 of service,,it makes an additional complication.
In fact, 3
you cannot take the same model.
You have to really go back l
4.
in and do -- so it's very time-consuming and when we talked 5-about the issue of evaluating two or more components out of 6
service, recognize that this is --
7 DR.-APOSTOLAKIS:
My point, Mario, is that if they 8-do this and they have an analyst doing it, maybe they do it 9
for some cases, but it's hard for me to see how a 10 computerized system, like a risk monitor, does it exactly.
11-DR. BONACA:
I agree.
12 MR. BARTON:
I don't think the risk monitor does.
13 I think an analyst looks at it.
You've got certain standard 14 configurations'that analyst has looked at and considered
()
15 what the risk is and if you deviate from that and you go 16 back and re-look at it, the deviation from that previously
.17 analyzed configuration, that's what they do.
18 DR. BONACA:
I don't know who uses blindly a risk 19 monitor, because you're absolutely right, it doesn't work 20 that way.
You're right.
21 MS DROUIN:
That's a decision made by the 22 analyst, not by the software.
23 DR. APOSTOLAKIS:
I understand that.
l 24 DR. SHACK:
The question is what is the software 25 doing.
h.
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DR. APOSTOLAKIS:
What is the software, that's
()
2 what I'm asking.
.I have no doubt that people will sit down 31
-and do this if asked.
But what I have difficulty accepting 4
is that the risk monitors, as they are now, have all these 5
separate analyses.
6 DR. KRESS:
It's not just the input'that matters.
7 DR. APOSTOLAKIS:
It's not just the input.
It's a 8
structural -- they may do it, they may do it.
I'm not 9
making a blanket statement.
10 DR. BONACA:
I'm sure, in several cases, the issue 11 of bounding is one that is taken into consideration, because 12 ultimately you're not -- but the -- and there are a lot of 13 approximations that you make.
For example, if you have -- I 14 mean, if you have -- if they're asking you to perform a
()
15 sensitivity on risk by.having two components out of service 16 at the same time or separate times and do it separately.
17 I remember we used to make just one evaluatio'n.
4 18 And having both of them simultaneously, that gives you a 19 bound.
Now, you know that if you take them separately, then 20 it's less risk.
But the other thing is that you communicate 21 the bound of having both simultaneously out and typically 22 you do it because you know that if they do it one after the 23 other, there is a chance that they will, in fact, be l
24 simultaneously out of service.
25 So there are a lot of things that are being done ANN RILEY & ASSOCIATES, LTD.
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to simplify the task and it's being done by the analyst, 2
you're right.
3 DR. APOSTOLAKIS:
That's my concern.
4 DR. BONACA:
I.know.
5 DR. APOSTOLAKIS:
That I know that the analyst can 6
do it.
Analyst intervention is required.
7 MS. DROUIN:
Yes.
8 DR. APOSTOLAKIS:
So I would -- now, if you give 9
me a risk monitor, I have serious doubts that they have all 10 these ultimate analysis there, but I may be wrong.
11 MS. DROUIN:
To my knowledge, they don't.
)
12 DR. APOSTOLAKIS:
That's my point.
13 MS. DROUIN:
I think you have a valid concern, 14 George.
I think you have a valid concern.
I was just
()
15 trying to differentiate that it was the analyst problem, not 16
'the software problem.
17 DR. APOSTOLAKIS:
Sure.
In fact, that's why I 18 have the concern.
Precisely because it's an analyst issue, 19 not just a user issue.
20 MS, DROUIN:
Yes.
21 DR. APOSTOLAKIS:
Okay.
Where we are?
22 MR. KING:
Let's move on.
23 DR. APOSTOLAKIS:
We are developing insights, no?
24 MR. KING:
We are bringing you up to speed on l
25 important things.
g
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DR.,APOSTOLAKIS:
SPAR looks like a Roman acronym.
(
12.,
cWasn't there a Roman thing, SB.--
3 DR.'BONACA:
QR.
'4 DR. APOSTOLAKIS:
QR.
That's why I said looks 5
like.
I didn't say it is.
What does it mean, SPQR?
It 6
means-accident sequence precursor.
7 MR. KING:
This is the last item we thought might 8
be of interest to you, before we get into the GAO stuff.
9
'The accident sequence precursor program, usually you start 10 out with looking at events, it then occurs, and you go in 11 and you calculate what was the conditional core damage 12
-probability of,that event.
13 But we're also using those same models for other 14 things and one that's kind of prominent right now is looking 15 at'D.C. Cook, where a number'of design and configuration 16 issues were identified, almost a couple of years ago, and 17 the plant has been shut down for a long time, and they're 18 facing a restart decision in January.
19 DR. APOSTOLAKIS:
Let me ask again here.
When did 20 the Cook plant do an IPE?
21 MR. KING:
Cook did an IPE.
22 DR. APOSTOLAKIS:
And how did they find those 23 design problems?
l 24 MR. KING:
Through inspection, as I understand it.
25 Maybe Rich could answer that.
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MR. BARRETT:
There was -- I guess a2most two
-2 years ago now, there was an architectural engineering 3
inspection at Cook.
It was one of the design basis 4
inapections and that inspection uncovered some problems with 5
the way in which the design of the ice condenser containment 6
was being controlled.
'7 That led the licensee to shut the plant down and 8
begin an internally initiated set of inspections, which 9
identified, I believe, in excess of 100 design basis 1
10 problems.
j 11 DR. APOSTOLAKIS:
When was the IPE done, before j
12 this happened?
13 MR. KING:
Yes.
1 14 DR. APOSTOLAKIS:
And the IPE does not reflect any 15 of this.
16 MS. DROUIN:
The IPE on D.C.
Cook was not one of 17 the better ones.
In fact, this was one that we did a site 18 visit and we wrote -- when we wrote the staff evaluation 19 report on it, we only blessed it with a lot of caveats.
20 The caveats being that D.C.
Cook was going to come 21 in and make all these changes to their PRA.
22 DR. APOSTOLAKIS:
The reason _why I'm raising the 23 point is I'm wondering to what extent this particular 24 experience supports the Union of Concerned Scientists'
-25 argument that we can't have risk-informed regulation because ANN RILEY & ASSOCIATES, LTD.
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.1 your PRAs don't.have design errors.
(
)'
2 MR. KING:
Well,LI think --
1'
[
3 MS.-DROUIN:
I would be real --
4-MR. KING:
On the surface, you can make that 5
argument,-but I~think what the results of this study-is 6
going.to show is that when you.look at'those 114 issues',
l-7 there's'only one that's risk-significant and that's from l
8
.looking.at them individually.-
There's also going to be --
19 try and group them and look at more of a cumulative effect,.
10
. which hasn't been done yet,.but will be done between now and 11' December.
I 12 But to me, what this study says is in terms of 13 corrective actions at the plant, what should be focused on.
i
'141 Well, it should be focused on the one that really pops out
()
' 15 as risk-significant and maybe not worry about the others so 16 much.
J 17 DR. APOSTOLAKIS:
When we claim that our PRAs are 18 for the plant as it is, not as designed, are'there any 19
' lessons from this that one can use in future PRAs to make 20 sure that indeed that what the PRA analyst puts down really
- 21 reflects the real thing?
22 MR. KING:
I think that's the flip-side of this.
-23 In theory, the IPE should have recognized these things and 24 included them in their model, and they didn't, and how many 25 other plants out there have similar situations.
l L
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MS. DROUIN:
I don't'think this'is a good --
)
2 MR. BARRETT:
The issues that have been raised at 3
D.C. Cook and in other places where there have been design l
4 basis problems, by and large, are issues that fall below the 5
radar screen of the PRA.
In other words, these are issues 6
regarding whether the design basis of a particular piece of 7
equipment is being met, and that may or.may not affect the 8
reliability and availability of that piece of equipment.
9 But the kind of issues we're talking about here 10 would not be modeled in a PRA, by and large.
Some of them 11 might, but --
12 DR. APOSTOLAKIS:
Because they are 13 risk-significant.
14 MR. BARRETT:
Because PRAs don't necessarily know
)
15 how to deal with them.
For instance, the issue that was 16 found to be significant was one that had to do with 17 environmental qualification and it's difficult to 18 systematically evaluate the effect of environmental 19 qualification on reliability and availability.
I don't 20 believe it's generally done in PRAs.
21 MS. DROUIN:
Well, what is done in a PRA is that 22 you look at the accident scenario and see if an adverse 23 environment has been created and then if it's been created, 24-typically what has happened, then you assume failure.
25 What happens with many people is that they neglect l
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to look at1that.
They don't look to see if there's adverse I )
2 environments.
It's not'that the PRA can't.do it.
It's
\\,,/
\\
L 3
mainly'the analyst didn't do it.
4 MR. BARRETT:
I think that's what happened here.
5 DR. BONACA:
Let me say that.we have some i
6 experience tx) evaluate, at Millstone, for example.
At 7-Millstone-3, a very specific equipment example was the RSS 8
NPSH issue.
Now, since we found a condition of very lcw 9
pressure, assuming a full failure of containment, where NPSH 10 could be challenged, that you could have cavitation, the
'11 assumption is, from the. design standpoint, that the pump, 12 that the RSS doesn't work.
You would not be able to do that
'13 because you have an NPSH problem.
14 In reality, what we're addressing is a very narrow
- p ).
(_,
15 spread condition.
Again, full open containment with 16 atmospheric conditions and certain others, they will 17 challenge your NPSH.
18 Under other conditions, your NPSH will be 19 available and you will be available to recalculate.
The 20 issue I'm trying to say is that when we looked at it and 21 quantified it, from a PRA standpoint, contribution to risk 22' was minimal, because it was a hypothetical failure of 23 delivering that function and even then an assessment was 24 done to show that those pumps may cavitate, but not fail.
25
~
From a design standpoint, that's categorized as a ANN RILEY & ASSOCIATES, LTD.
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failure, because you don't deliver, under all conditions,
()
2 what you're supposed to deliver.
3 So the PRA is such a more complete model because 4
it allows -- it is much more robust in the sense that it 5
takes into consideration all the other scenarios under which 6
a system will function, will be successful.
7 Furthermore, conditions where you don't deliver
'8 your design objective, but you're still operable or 9
functional, functional, are considered a PRA success, not 10 considered in design failure.
11 I mean, we did the evaluation and wrote, in fact, 12 to Lochbaum, because he asked questions regarding that, and 13 it's interesting how the PRA was still fundamentally valid 14 for those plants.
)
15 DR. APOSTOLAKIS:
But the argument that UCS is 16 using is that this is a fatal flaw of risk-informed 17 regulation.
Design problems that your PRA does not reflect,
[
18 and'there is a need for a rational argument for or against 19 this position.
20 DR. BONACA:
But, in fact, it is a strength of the 21 risk-informed approach that is able to truly put into 22 perspective what the failure of a system means.
It means 23 under certain conditions, in a very narrow scenario, and 24 what.is the contribution to risk resulting from that 25 specific deficiency that you may have, which may even not
)
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^
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affect your functionality.
It may affect your operability
( ).
2 from a licensing standpoint, but it may not affect 3
functionality.
4-DR. APOSTOLAKIS:
Sure, you can do that if you 5
know that there is something that's called a design error.
6 You can evaluate its significance.
7 But the argument they make is not that.
The 8
argument they make is I have a PRA, I have the. core damage 9
frequency. distribution and so on, and I really don't believe 10 it, because I don't think those guys looked for these 11 errors, possible errors.
12 DR. SHACK:
But the deterministic is no better.
13 If the wall is half the thickness that you tnink it is --
14 DR. APOSTOLAKIS:
That's the argument I would use,
)
15 too, but the fact that I'm repeating the concern does not 16 mean I agree.
17 DR.'BONACA:
But I think we have documented very 18 important basis upon which the risk evaluation is much more 19 robust and' credible, because it gives you a full measure of 20 it.
If you're saying that a piping system is not designed 21 to withstand 200 degrees Fahrenheit, what does it mean?
It 22 may mean the support systems may be banned iv. the one time 23 in which you use that system for recirculating, for example, 24 inside containment.
25 Piping would be unaffected, any evaluation will O'-
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tell you that.
From a licensing standpoint, you will say j
i 2
that the system has failed because it doesn't deliver it's
' _/
j 3
licensing intent, which is the one of being fully compliant 4
with the temperature requirements which were imposed in the 5
design.
6 So you see, deterministic is very myopic.
It i
7 doesn't tell you if it works or not.
The PRA will say 8
that's another issue, because when called upon to operate, 9
it will function, there will be no leakage, and so they will 10 be functional.
11 DR. APOSTOLAKIS:
Anyway, this is the argument and 12 13 DR. BONACA:
I understand that.
I'm only saying i
14 that --
T
(,)
15 DR. APOSTOLAKIS:
And 1.174, by the way, is not --
16 has not been promulgated as an alternative.
Let's go on.
17 MR. KING:
I view this as good news.
You've got a 18 bunch of design errors and not much comes out of them in 19 terms of risk.
20 DR. APOSTOLAKIS:
Except for one.
21 MR. KING:
Except for one.
22 DR. APOSTOLAKIS:
And even that is not one.
23 MR. KING:
I just thought that -- I don't think 24 you're aware that we're using the models in this fashion.
25 DR. APOSTOLAKIS:
I remember many years ago,
.m
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Diablo Canyon had similar problems and PRAs had not been g
?
2 developed at that time.
I got a bit involved in that and 3
one of the Bechtel guys took me on the side and gave me a 4
lecture about what it means to design a nuclear power plant, 5
that you expect to have these deviations, just because the 6
regulations'and the standards say you do this and that.
7 It's such a complex facility, that there will be all sorts 8
of deviations.here and there and that's why you have such a 9
' conservative design, to make sure that these will not be 10 significant.
11 So you're confirming this.
I mean, the naive j
l 12 approach of an (cademic might be, gee, you really violated 13 the regulations, you know, when you built the thing, and the 14 guy says, well, let me give you the real story here, yeah,
()
15 we do that all the time; not all the time, but if you look 16.
carefully, you'll find a lot of them.
17 MR. BARTON:
You'll find a lot of these, yes.
18 DR. APOSTOLAKIS:
You will find a lot of them.
19 But the system is still robust because of the extreme 20 conservatism that's everywhere.
21 MR. KING:
Should we have defense-in-depth to 22 account for design and construction --
23 DR. APOSTOLAKIS:
That's what defense-in-depth 24 did, yes.
25 MR. KING:
Okay.
GAO.
O ANN RILEY & ASSOCIATES, LTD.
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1-DR. APOSTOLAKIS:
I'can see structurally written
()
2 all over you, Tom.
Is.not Tom asking?
Now I know.
3 DR. KRESS:
Tom L. King, i
4 DR. APOSTOLAKIS:
.Oh, it's L.
5 LMR. KING:
It's L.
GAO, as George mentioned in 6
his. opening remarks, put a report out in March that 17 basically had one recommendation in it and that was the.
8 agency ought to develop a strategy for where we want to go risk-informing our activities and how do we get there, 9
- u1 10 because they came in and interviewed a number of people, 11 found out what we_were doing, but-it wasn't clear to them, 12 beyond what we were doing today, what were our goals in 13 terms of how much of this -- what the agency does, do they 14-want to risk-inform, how practical 11t is to do it,.when are r
15-we_ going to do_it, what are the resource implications and so 16 forth.
17-And at least we in Research felt that they had a 18 point in that the'PRA implementation plan only really told 19 you what-you were doing today and what you had accomplished 20 in the past.
21-So we had prepared a response and the Chairman 22
_ signed it out back to GAO that said we will go ahead and 23 pursue this recommendation and since that letter has gone 24 out, I've gotten a number of calls from GAO folks saying, 25 you know, _how far have you made it, can we have something to O.
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look at.
()
2 DR. APOSTOLAKIS:
Why are they interested so much?
3 Who is the force behind this?
l 4
MR. KING:
I'm not sure.
I mean, GAO doesn't 5
really do anything unless some Congressman or Senator asks 6
them to do something, and I'm not sure who originally kicked 7
off their audit where they came in and looked at 8
risk-informed regulation.
9 But they had told -- they had said that the --
10 there were supposed to be Congressional hearings, in fact, 11 today.
They've been postponed, but the focus of GAO's 12 testimony at those hearings, they told us, was going to be 13 what have we done about their recommendation to develop this 14 strategy.
)
15 So it's fairly important that we make some 16 progress and we decide what we're going to do and make them 17 aware of it.
Otherwise, it's going to come back and we'll 18 be criticized again.
19 Anyway, what we've done is we've been working on 20 an outline as to what this document would look like and it's 21 raised a lot of questions regarding how it fits into the 22 overall structure of other agency documents that exist, 23 what's really its purpose, how much detail is it going to 24 have and so forth.
25 So what we're talking about is work in progress.
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88 l-1 We're still debating a number of these questions.
But the
- p) 2 next few viewgraphs sort of lay out at least a concept
(
3 that's on the table now for discussion and we're hoping to 4
'have this sorted out'and have a first cut at this document 5
by February 2000.
6 What we basically envision is that we will take 7
today's PRA implementation plan and turn it into what we 8
call a risk-informed regulation implementation plan.
It 9
will hava this front end to it that talks about what are the 10~
agency's goals and objectives for risk-informed regulation.
11 DR. APOSTOLAKIS:
That's not what you have here, i
12 right?
When you say objectives to describe what, how and I
13 when the NRC decides to risk-inform an activity, that's 14 really a much lower level objective.
)j 15 MR. KING:
The agency's strategic plan has these 16 high level objectives that we will pursue risk-informed 17 initiatives.
18 DR. APOSTOLAKIS:
So you believe that is 19 responsive to the GAO criticism?
20 MR. KING:
No, I don't think that is.
I think 21 what's needed is a document that says, okay, your high level 22
~ goal is to risk-inform your activities, what are you going 23 to do,'how do you decide and how do you make those decisions 24 as to what you're going do, and I view this document as --
25 DR. APOSTOLAKIS:
So the question of why you want O
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to risk-inform is not raised.
I thought -- if I look at
()
-2' MR. KING:
I think it is.
It is.
3 DR. APOSTOLAKIS:
It says scope, objectives, 4
goals..Somewhere there maybe there is a word vision, but 5
they are not~ interested in that.
In other words, if the 6'
agency were completely risk-informed, what would the agency.
?
.be doing, how do you see that.
I thought that was part of 8
.he question.
And then having established that, the 9
question is now what strategies do you have to get there.
10 Maybe'I misunderstood.
11 MR. BARRETT:
I think part of the problem that GAO 12 had was that we were -- we had a strategic statement, we 13 have a policy statement that we think this is a good thing 14 to do, and then we -- you kind of -- when you look at all
)
15-the documents that we have, you jump right to the PRA 16 implementation plan and what you see is a catalog of things 17 we're doing and it looks -- from an outsider's perspective, 18 it looks like we just found some targets of opportunity and 19 we went and started doing it and that we really didn't have 1
20 a strategy, that we didn't know -- we didn't have a 21 statement of where we wanted to arrive and how much we were 22 willing to' spend to get there and how we were going to set 23 our priorities.
24 So this document is meant to be that middle 25 document that-takes those high minded goals and the ANN RILEY & ASSOCIATES, LTD.
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strategic goal and says here is how we're going to make
(,_')
2-decisions as to prioritize our activities and allocate our v
3 resources and measure our progress, and make a statement of
- 4 where we want to go, how far, how fast.
5 DR. APOSTOLAKIS:
So the GAO then did not question 6
the wisdom of going to a risk-informed system.
I 7
MR. BARRETT:
No, I don't believe so.
8 DR. APOSTOLAKIF:
They took that as a granted and 9
they just complained that they don't see a plan to get i
10 there.
11 MR. KING:
In fact, I think it's probably the j
12 opposite.
I think they support risk-informed and they'd 13 like to see us go as far as we can go in that area, but they 14 don't see us laying out a plan to do that.
)
15 DR. APOSTOLAKIS:
And, in fact, you agree with 16 them, from what you're saying.
17 MR. KING:
We agree with that.
It's not evident 18 as to where we want to go and when we want to go there.
All 19 the strategic plan says today, for example, in the reactor 20 area is we will develop and implement risk-informed and, 21 where appropriate, performance-based regulatory approaches.
22 That's all it says.
So it doesn't help you very much.
I 23 DR. APOSTOLAKIS:
Now, the first sub-bullet there, 1
24 I think, is a bit misleading to describe what, how and when 25 you decide to risk-inform an activity.
I get the l
l l
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20036 (202) 842-0034
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impression, and I'm sure it's not correct, but I get the rr 2
impression that, again, you're looking at individual things 3
- and saying I'm going to risk-inform this and that.
4
\\
4 I would expect to see something more global, more f
5 noble, you know.
Attack the whole thing and look at it and 6
7 MR. BARTON:
They're not going to attack the whole 8
thing.
9 DR. APOSTOLAKIS:
Attack is the wrong word.
10 MR. BARTON:
What is an activity is really your 11 question.
12 MR. KING:
That's right.
13 DR. APOSTOLAKIS:
But risk-informing Part 50, you 14 would call that an activity?
f 15 MR. KING:
Yes.
Risk-informing the inspection 16 program.
17 DR. APOSTOLAKIS:
Come on.
Really?
i 18 MR. KING:
Risk-inform the inspection program, 19 risk-inform the enforcement program, risk-inform the NMSS
]
20 activities, risk-inform the regulations for fuel cycle 21 facilities.
22 DR. APOSTOLAKIS:
That smells of a bottom-up 23 approach and a bottom-up approach is never really -- I mean, 24 they can be -- that can be your implementation, but your 25 strategic thinking should be top-down.
That's my objection I
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1.
to that.
2, MR. BARRETT:
Let's take the example of the 3
. oversight process, the inspection ~, enforcement, and plant 4'
assessment process.
5' DR. APOSTOLAKIS:
Yes.
6
'MR. BARRETT:
The agency made the decision to 7'
riGK-inform that and we are risk-informing it at a couple of 8
different levels.
But. suppose you came'back two or three 9'
years from now and you took a look at it.
How would you 10'
. evaluate whether or not you had sufficiently risk-informed 11-it, whether you had really gotten as far as you wanted to i
12 get?
13
~For instance, we know that we're using -
we're 14-trying to use risk-informed indicators, we're trying to use 15'
.a risk-informed inspection process.
Two or three years from 16.-
now, when we look at the results of this thing, will we be 17-able to say whether or not it accomplished what we set out 18 to accomplish?
19 I'm'not sure that we've written down enough today 20 to make that determination.
I think that we'll be able to 21-evaluate the program in a year or two when ve look back on 22 it and make adjustments as we go along.
I don't think we're 23' wandering:in the desert here.
But this kind of a document 24 would force you to start out by saying what your goal is and 25 how you're going to judge yourself.
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MR. KING:
You're saying let's start at the top.
p).
(
Let's.look at reactors and then everything under regulating 2
3 reactors.
Then let's look at power reactors, non-power l
4 reactors, fuel cycle facilities, enrichment facilities, 5
radiographers, the whole --
j 6
DR. APOSTOLAKIS:
And then within the power 7
reactors --
8 MR.' KING:
Then there's regulations, there's reg 9
guides.
10 DR. APOSTOLAKIS:
-- I have oversight, I have 11 enforcement, I have other things, and I'm making a judgment 12 now which one to attack first or maybe a combination.
13
.MR. KING:
Or not to attack any of them.
1 14 DR. APOSTOLAKIS:
Or not to attack any of them,
)
15 yes.
And maybe.that's what you meant, but it didn't come 16 across.
17 MR. KING:
That's what I meant.
That's what I 18 meant.
-19 DR. APOSTOLAKIS:
Activity, to me, is down here.
20 If you call the oversight program an activity, then --
21 MR. BARRETT:
In risk-informing Part 50, we chose 22 to go forward with the scoping regulations and hold back 23 with the option three and study it more.
We could have done i
24
.just the opposite.
We had reasons for making that decision.
25 DR. APOSTOLAKIS:
sure.
y i
s~
/
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MR. BARRETT:
And we laid those reasons out in 2
98-300.
3 DR. APOSTOLAKIS:
Anyway, I think it's a matter of 4
communication.
I'm pretty sure you've done this kind of 5-thing.
So these words I would change, if I were you.
6 MR. KING:
The idea is to start at that top, work 7
your way'down to some level.
8 DR. APOSTOLAKIS:
Make sure that people understand 9
that, that's all I'm saying.
10 MR. KING:
But not get down to the level that 11 these are these are the words we're going to change in Part 12 50.
You get down and say, hey, we want to risk-inform Part 13 50 and that's where this document would stop, and then the 14 details of actually figuring out what pieces of Part 50 you O)
(,
15 want to change would be done through our normal operating 16 plans and other documents.
17 DR. APOSTOLAKIS:
Yes.
So we will see a first 18 draft next February, that's what you're saying here.
19 MR. KING:
We hope to have an outline developed 20 soon, in the next couple of weeks.
We're going to send it 21 to the Commission.
We owe the Commission an outline.
22 DR. APOSTOLAKIS:
So when are we going to see you 23 again on this subject?
24 MR. KING:
We haven't really talked about that.
25 The next February date is when the next update of the PRA h
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implementation plan is due and our view was let's turn that
()
2 PRA implementation plan into this higher level strategy 3
document, call it a risk-informed regulation implementation 4
plan, and take a first cut at that in February.
5' I think a lot of the reactor stuff you can fill in 6
and you might have placeholders~in there for a lot of the 7
NMSS stuff, but at least with a placeholder, you'll know 8
that, hey, I've got to look at.that and figure out what we 9
want to do there.
And don't organize it by office, like 10 it's currently organized.
Organize it by reactors, 11 non-power reactors, however, whatever makes sense.
12 DR. APOSTOLAKIS:
Why is the GAO interested only 13 in risk-informed and not risk-informed performance-based?
14 MR. KING:
I can't answer that.
I think
-15
-performance-based is clearly, to me, an implementation 16 alternative.
If you decide you want to risk-inform a 17 regulation, when you end up with this new thing looks like, 1
18 can you specify it some performance-based fashion.
That's 19 what we're thinking about in the Part 50 work that we will 20 hear about tomorrow.
21 Anyway, certain elements we viewed as being part 22 of this document.
One is how do you decide what you want to i
23 risk-inform, there needs to be some criteria or set of 24 guidance that you'd go through systematically and the agency 25 could decide these are the things that I want to O
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risk-inform.
f3 2
( j It could deal with items like stakeholders that 3'
indicate a need for change.
You can clearly see removing an 4
unnecessary burden if you do this.
It might improve the 5
NRC's' effectiveness and efficiency if you do this.
Would it 6
improve public confidence?
7 We were trying to develop sort of the set of 8
criteria that you.could then go through and test all the 9
things we do against and make some decision that, yes, 10 that's a candidate to be risk-informed and then if it's a 11 candidate to be risk-informed, is it feasible to risk-inform 12 it.
Are there methods, are there data available that you 13 can actually apply to risk-inform this stuff?
Are the 14 licensees in a condition to actually be able to implement A"s,)
_15 risk-informed regulation, some radiographers, for example, 16' if it would take some sophisticated knowledge of PRAs to 17 implement it, then it's not going to be practical for them.
18 Costs, maybe it's feasible to implement it, but 19 the costs are just out of line.
So those kinds of 20 considerations.
And that would be costs to licensees, as 21 well as costs to NRC.
22 So we're working on what are these factors and 23~
then at some point we'd have to go and actually start 24 applying those to what the agency does and I view this sort 25 of as an iterative process.
We take a crack at this
)
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document, first crack in February 2000, we'll have a lot of
(
2 holes in it, then we'll continue to look at other areas and 3
start to fill in the. holes as time goes on.
4
-Then once you decide --
5 DR. APOSTOLAKIS:
How about if we change the words 6
principles.there to maybe objectives or something like that?
7 These things are not really principles.
Like the principle 8
of conservation of momentum.
I think they are just 9
objectives.
10 DR. KRESS:
You could call them regulatory 11' objectives.
12 DR. APOSTOLAKIS:
Yes.
Because that's what i
13 bothers me about defense-in-depth, when it's called 14 principle.
It gives it a prestige that it does not deserve.
15 MR. KING:
Maybe it does deserve that prestige.
16 All right.
17 DR. APOSTOLAKIS:
There are only three or four 18 7ceat conservation principles.
Defense-in-depth is not one.
19 MR. KING:
The conservation of defense-in-depth?
20-DR. KRESS:
The principle of conservation of 21 uncertainty.
22 DR. APOSTOLAKIS:
It's energy mass, momentum, and 23 difficulty, that's all.
The last one probably is unfamiliar 24 to you, but it's a true one.
25 MR. KING:
All right.
Once you would go through i
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and select an area that would make sense to risk-inform, O
2.
.then you've got to bring in the concept of risk, and we've
%.I 3
done that in reactors through the safety goal policy, but 4
there's a lot of places where we haven't brought that in.
'S So the thought here was to lay out what are these 3
1 6
high level -- I call them principles, call them whatever you 7
want -- but'what are the guidelines that need to be followed j
8 if you're going to actually implement a risk-informed 9.
approach.
10 These are the kinds of things we talked about that
)
11 high level safety principles address.
12 DR. APOSTOLAKIS:
In fact, you know we had a 13 workshop recently where we asked experts on these things.
14 The first results are coming out.
Overwhelmingly, worker 15 and public protection are up there, you better make sure you 16 protect the worker and public health and safety.
17 Then environment sometimes comes close, sometimes 18' it doesn't.
Everything else is at the bottom, like 19 political considerations, economic and all fhat.
But I 20 found that surprising, because the stakeh',lders that were 21 present, a couple of them really were not nuclear people and 22 I thought those guys would elevate the political concerns or 23 other issues, 24 No, that's way at the bottom.
So your first three 25
-- well, two, the way you have them, worker and public (O
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protection, environmental protection, those are the ones
()
2 that evidently the experts really care about.
3 DR. SHACK:
Well, those are really incommensurate 4
sorts of things.
i 5
DR. APOSTOLAKIS:
They're incommensurate and in i
J 6
the language of decision analysis, the first two are 7
fundamental objectives, defense-in-depth is really a means 8
objective.
It's a means for achieving a fundamental 9
objective.
So we are mixing objectives here.
10 But'for the present purposes, it's fine.
I'm just 11 telling you there were some interesting insights from that.
12 But I think the distinction between fundamental 13 objectives and means objectives is an important one, and 14 we'll just put it in different words, that they are not O( j/
15 commensurate, because defense-in-depth certainly is a way of 16 making sure that you're protecting worker and public health 17 and safety.
18 Okay.
We don't disagree with this.
19 MR. KING:
Okay.
And then the actual 20 implementation phase, what are you going to do to 21 risk-inform that activity, would be going in and identifying 22 the' regulation, the reg guide, the SRP, the inspection 23 program, what are the things that you're going to work on, 24 and then what do you need to develop to actually work on 25 those things, is there methods that have to be developed, ANN RILEY & ASSOCIATES, LTD.
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data standards, guidance, training.
(J, ')
2 Not to get into the details of, like I said, what 3
the new words would be in the regulation, but just to 4
identify those things and then you can have a schedule and 5
have a priority associated with it, and then this could feed 6
into your normal operating plans and budget process that 7
take place to make sure this work gets done.
8 So as Rich said, that in between document, between 9
the strategic plan and the actual operating plans that put 10 people and dollars on projects and help you to make those 11 decisions as to what you're going to do.
12 So that's how -- at least that's how I view it.
13 That's what we're talking about.
I'd bc glad to come back 14 and discuss it with the subcommittee at some future point, f'\\
(,/
15 if you want.
16 DR. APOSTOLAKIS:
I'm sure that is something that 17 the members would be very much interested in, because this 18 is really a critical activity.
19 MR. KING:
And I think the reactor folks are way 20 out ahead of everybody else.
21 DR. APOSTOLAKIS:
Sure.
22 MR. KING:
The NMSS folks, when they heard about 23 this idea, were very interested in it, because they're sort 24 of sitting there with a whole slate of things in front of 25 them that the Commission said go risk-inform and they're
[)
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1
. struggling with what do we do.
They're very interested in l (qj 2
getting this put in place so they can use it.
s_-
I 3
DR. APOSTOLAKIS:
Well, when the joint 4
subcommittee, the joint ACNW/ACRS met with them, that was 5
about the only recommendation, that they should develop 6
these objectives.
7 MR. KING:
Maybe that's the joint committee we 8
ought to come back, not just with the reactor orientation, 9
but get the --
10 DR. KRESS:
The joint committee was only looking 11 at NMSS activities.
12 DR. APOSTOLAKIS:
This is bigger.
13 MR. KING:
Yes, this is bigger.
14 DR. APOSTOLAKIS:
It should come to the ACRS.
(
15 MR. KING:
All right.
16 DR. APOSTOLAKIS:
Because the joint subcommittee 17 letters have to be approved by each committee separately.
18 You're better off coming here.
I 19 DR. KRESS:
You'll never get a letter out.
20 MR. KING:
Okay.
21 DR. APOSTOLAKIS:
So this is it.
So first of all, 22 we are interested and, as you know, we are willing to listen 23 to half-baked or quarter-baked ideas and offer suggestions.
24 So whenever you feel you have done enough and there is any 25 question as to how to proceed, it would be easy to schedule I l ANN RILEY & ASSOCIATES, LTD.
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I i
2' takes.
G 3
MR. KING:
But clearly we ought to do it before 4'
February.
5 DR. APOSTOLAKIS:
Yes, that's what I'm saying.
I 6
would rather do that than receive a document and read it and 7
then us --
8 MR. MARKLEY:
I just wanted to ask a few 9
que,stions.
When we were talking about fire, you had 10 mentioned a subcommittee, and then when we got into 11 shutdown, you mentioned a subcommittee again.
I guess the 12 October subcommittee, what did you have in mind?
13 MR. KING:
I thought these were November 14 subcommittees.
/D
'j
(
15 MR. MARKLEY:
November?
16 MR. KING:
Yes.
17 MR. BARTON:
November.
18 MR. MARKLEY:
Are you working through one of the 19 other engineers on that particular one?
Because I'm not 20
' aware of it.
I 21 MR. KING:
The lower power shutdown?
l 22 MS. DROUIN:
I'm sorry.
What was the question?
23 MR. KING:
You scheduled the low power shutdown 1
24 subcommittee meeting for November?
25 MS. DROUIN:
My understanding, it is scheduled.
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1 MR. MARKLEY:
For when?
(N) 2 MS. DROUIN:
November.
r 3
MR. MARKLEY:
When?
I don't have a date.
I have l
4 a general time slot that we talked about'many, many months 5
ago, but we haven't worked toward --
6 MS. DROUIN:
Because I was contacted yesterday or I
7 two days ago by Glen Tracy and he said it was on the agenda.
8 MR. MARKLEY:
Okay.
I'll follow up.
9 MR. BARTON:
It's probably under future 10 activities.
But there is a spot on here for -- and it's an 11 open date.
It's just open, it's date to be determined.
12 MR. MARKLEY:
We have a November for briefing the 13 full committee for the low power and shutdown risk insights 14 report, but I don't know -- I'd have to look.
That's q_j 15 another engineer, clearly.
I'll check outside the context 16
.of the meeting.
17 MS. DROUIN:
Okay.
Well, I'm confused.
You're 18 saying you do have it on the agenda, November, 19 MR. KING:
Full committee only, you mean.
20 MR. MARKLEY:
Yes.
21 MR. KING:
No subcommittee.
22 MR. MARKLEY:
I'd have to check.
I don't have a 23 subcommittee list with us.
24 DR APOSTOLAKIS:
Okay.
Now, the plan here is 25 that the two gentlemen and the lady will not come back next (O, -
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week?
(~~N
.J 2
MR. MARKLEY:
Right.
All we~have scheduled right j
'3 now is the subcommittee chairman's report for you to talk 4
about what was discussed.
5 DR. APOSTOLAKIS:
How long is-that?
6 MR. MARKLEY:
However long you want to make it, l
7 five, ten minutes..
8-DR. APOSTOLAKIS:
How much time do we have in 9
there?.
10 MR. MARKLEY:
Well, it's grouped with several 11 others from 11:30 to 12:15 on the last day of the meeting.
12 DR. APOSTOLAKIS:
So I would just summarize what 13 was presented today.
14 MR. MARKLEY:
Yes.
)
15 DR. APOSTOLAKIS:
Without using viewgraphs.
All 16 right.
17 MR. MARKLEY:
So that the other half of the answer 18 is that we're not expecting a briefing at the full committee 19 and we're not expecting-to prepare a report.
20 DR. APOSTOLAKIS:
Do I also have to prepare a 21 written document or oral is good enough?
22 DR. KRESS:
Oral is good enough.
23 DR. APOSTOLAKIS:
I think it would be a good idea 24 to give everybody this at the meeting.
25 MR. MARKLEY:
That could be the context of h-ANN RILEY & ASSOCIATES, LTD.
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2 DR. APOSTOLAKIS:
And I can walk them --
3 MR. BARTON:
You can hand that out and walk people 4
through it.
5 DR. APOSTOLAKIS:
I will walk them through it.
6 MR. BARTON:
And that will take care of it.
7 DR. APOSTOLAKISi That will take care of it.
I 8-Sure. -Do any of you-plan to be here in case of any 9
questions?'
10 MR. BARTON:
Or in case George says something i
11 wrong.
12 MR. KING:
We'd better be here.
13 MR. BARTON:
When is it?
14 DR. BONACA:
It's a Saturday.
/3
(,/
15 MR. BARTON:
It's a Saturday?
16 DR. APOSTOLAKIS:
No, no.
17 DR. BONACA:
No.
18.
MR. MARKLEY:
The actual subcommittee report is 19.
scheduled for Saturday, so I'm not sure you want to be here, 20 11:30 to 12:15.
21 DR. APOSTOLAKIS:
I have free reign then.
22' MR. BARTON:
Read the transcript.
23 DR. APOSTOLAKIS:
There will be no transcript.
l 24 MR. MARKLEY:
No transcript on Saturday.
i l
25 DR. APOSTOLAKIS:
On Saturdays, there are no 1
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transcripts.
(
)
2 MS. DROUIN:
Which Saturday?
3 MR. MARKLEY:
October 2nd.
- 4 DR. APOSTOLAKIS:
Next week.
5 DR. KRESS:
Next Saturday.
6 MR. MARKLEY: -Right.
7 DR. APOSTOLAKIS:
What time?
8 MR. MARKLEY:
11:30 to 12:15.
If, for some 9
reason, it does get moved up, because that's one of the 10 items that can be moved around a little bit, I'll give you a 11 call and let you know.
That's the best we can do.
12 DR. APOSTOLAKIS:
At 12:00 Saturday a meeting.
13 DR. UHRIG:
Have you cleared that with Dana?
14 DR. APOSTOLAKIS:
The Vice Chairman is elected
)
15 separately.
I have the power of the people with me.
16 Anything else?
No?
Well, thank you very much.
17 This was very informative, as usual.
See you next time.
18.
MR. KING:
We'll see you tomorrow.
Thank you.
19
[Whereupon, at 3:43 p.m.,
the meeting was 20 recessed, to reconvane at 8:30 a.m.,
Friday, September 24, 21 1999.]
22 23 24 25 I
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RhPORTER'SCERTIFICATE This is to certify t$at the attached proceedings before the U;. ted-States Nuclear Regulatory Commission in the matter of':
NAME OF PROCEEDING:
. ' MEETING :
RELIABILITY AND PROBABILISTIC RISK ASSESSMENT AND REGULATORY POLICIES AND PRACTICES CASE NUMBER:
1 PLACE OF PROCEEDING:
Rockville, MD were held as heyein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to I
1 typewriting by me or under the direction of the court i
reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
k Mark Mahoney Official Reporter i
Ann Riley & Associates, Ltd.
I O
F
INTRODUCTORY STATEMENT BY THE CHAIRMEN OF THE 7
.(d SUBCOMMITTEES ON RELIABILITY AND PRA AND ON REGULATORY POLICIES AND PRACTICES 11545 ROCKVILLE PIKE, ROOM T-2B3 ROCKVILLE, MARYLAND SEPTEMBER 23-24,.1999 The meeting will now come to order. This is first day of the joint meeting of the ACRS Subcommittees on Reliability and Probabilistic Risk Assessment arid on Regulatory Policies and Practices. I am Dr. George Apostolakis, Chairman of the Subcommittee on Reliability and Probabilistic Risk Assessment.
Dr. Kress is the Chairman of the Subcommittee on Regulatory Policies and Practices ACRS Members in attendance are: John Barton, Mario Bonaca, William Shack, Jack Sieber, Robert Uhrig The purpose of this meeting is to review proposed revisions to the NRC Probabilistic Risk Assessment Plan. Tomorrow, September 24,1999, the Subcommittees will review the proposed rulemaking plan and study for development of risk-informed revisions to 10 CFR Part 50," Domestic Licensing of Production and Utilization Facilities." The Subcommittees will gatherinformation, analyze relevant issues and facts, and formulate proposed positions and actions, as appropriate, for deliberation by the full Committee. Michael T. Markley is the Cognizant ACRS Staff Engineer for this meeting.
The rules for participation in today's meeting have been announced as part of the notice of this meeting previously published in the FederalRegisteron September 3,1999.
A transcript of the meeting is being kept and will be made available as stated in the Federal Register Notice. It is requested that speakers first identify themselves and speak.with sufficient clarity and volume so that they can be readily heard.
We have received no written comments or requests for time to make oral statements from members of the public.
(Chairman's Comments-if any)
The key document fot today's meeting is SECY-99-211, " Status Report on the PRA e
Implementation Plan," issued August 18,1999.
The staff has made substantial revisions in this update, in part, to address e
comments in General Accounting Office (GAO) report dated March 19,1999.
The staff briefed the Commission on SECY-99-211 on September 7,1999.
e We will now proceed with the meeting and I call upon Messrs. Thomas King, RES, and Gary Holahan, NRR, to begin.
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