ML20212H780
| ML20212H780 | |
| Person / Time | |
|---|---|
| Issue date: | 06/22/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3081, NUDOCS 9906280141 | |
| Download: ML20212H780 (400) | |
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m ClliGlNAL AcRs7=.gom L-g OFFICIAL TRANSCRIPT OF PROCEEDINGS NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
Title:
MEETING: 463RD ADVISORY l
COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
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Docket No.: e Work Order No.: ASB-300-808
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{ .l LOCATION: Rockville, MD 3
DATE: Wednesday, June 2,1999 PAGES:1 - 266 9906200141 990602
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i DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS' JUNE 2, 1999 i
The contents of this transcript'of the proceeding
- of the United States Nuclear Regulatory Commission Advisory
(~' Committee on Reactor Safeguards, taken on June 2, 1999, as
. reported herein, is a record of the discussions recorded at the meeting held on the above date.
1 This transcript had not been reviewed, corrected I and edited and it may.contain inaccuracies.
l l'
L O' i
l 1
)
l 1 UNITED STATES OF AMERICA
(^N 2 NUCLEAR REGULATORY COMMISSION j
(-l i 3 *** I l 4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 MEETING: 463RD ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l
6 (ACRS) 7 ***
1 l
8 I 9 U.S. Nuclear Regulatory Commission 10 11545 Rockville Pike 11 Conference Room 2B3 12 Two White Flint North 13 Rockville, Maryland 14 Wednesday, June 2, 1999
(' ) 15 The subcommittee met, pursuant to notice, at 8:30 Gs 16 a.m.
17 MEMBERS PRESENT: l l
18 DANA A. POWERS, Chairman, ACRS 19 GEORGE APOSTOLAKIS, Member, ACRS 20 ROBERT L. SEALE, Member, ACRS 21 GRAHAM B. WALLIS, Member, ACRS 22 THOMAS S. KRESS, Member, ACRS 23 MARIO V. BONACA, Member, ACRS 24 ROBERT E. UHRIG, Member, ACRS 25 WILLIAM J. SHACK, Member, ACRS g ANN RILEY & ASSOCIATES, LTD.
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h 2
1 PROCEEDINGS 4
()
U 2
[8:30 a.m.]
3 DR. POWERS: The meeting will now come to order.
1 4 This is the first day of the 463rd meeting of the Advisory !
5 Committee on Reactor Safeguards. ,
1 6 During the day's meeting the committee will 7 consider the following: hydrogen control exemption request 8 for the' San Onofre Nuclear Generating Stations, Units 2 and j 9 3; status of the pilot application of the revised Inspection 10 Assessment Programs; proposed risk-based performance 11 indicators, performance-based regulatory initiatives and 12 related matters; proposed ACRS reports.
13 The meeting is being conducted in accordance with 1
- 14. the provisions of the Federal Advisory Committee Act. Dr.
()
' 15 16 John T. Larkins is the Designated Federal Official for the initial portion of the meeting.
17 We have received no written statements or requests 18 for time to make oral statements from members of the public 19 regarding today's session. A transcript of portions of the 20 meeting is being kept and it is requested that speakers use 21 one of the microphones, identify themselves and speak with 22 sufficient clarity and volume so that they can be readily '
23 heard.
)
24 We have a special event to note today. Michelle, 25 could you stand up?
i l
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3 1 Michelle has been selected to receive a 2 Meritorious Service Award for support staff excellence.
)
3 [ Applause.]
4 DR.' POWERS: Many of us, of course, have worked 5 with Michelle for several years and know that it's just 6 overdue, that's all that~is.
1 7 DR. SEALE: Why so long?
8 DR. POWERS: Michelle, congratulations. When do 9 you actually receive this?
- 10. MS. KELTON: The 16th.
11 DR. POWERS: June the 16th. Very good.
12 DR. SEALE: And exactly where is this party going 13 to be?
14 [ Laughter.]
() 15 MS. KELTON: Outside on the lawn. A picnic.
16 DR. POWERS: And with the monetary award
'17 associated with that you get a cup of coffee in the 18 cafeteria, is that --
19 [ Laughter.] l 20 DR. POWERS: Well, very well deserved and 21 congratulations.
22 Members will notice that John Barton is not with us today and that is a problem for us, because as usual we 24 have laden down John with more work than anyone possibly 25 deserves, so Dr Kress, can you take responsibility for the ANN RILEY & ASSOCIATES, LTD.
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1 low power in shutdown program?
j 2 DR. KRESS: Certainly. Sure.
3 DR. POWERS: And Dr. Shack, if you can take care 4 of the inspection and assessment program.
5 I will also remind members that we have a reports 6 and letter scheduling here where we indicate discussion 7 times and preparation times. I think it is important that 8~ we do have draft letters available for the preparation.
9 It's nice we have them for the discussion but not essential.
10 We should have them available for the preparation time.
11 In that regard, I'll call members' attention to 12 the schedule, especially the time of four o' clock today and 13 four o' clock on Thursday. There is a new approach towards 14 scheduling that should make it possible for members to have
() 15 draft reports available. That is an experiment in 16 scheduling that we are attempting and we will see how well 17 it works out.
18 On additional items of interest, I'll call your 19 attention to a speech by Shirley Jackson entitled, 20 " Teamwork: Individual Commitment to a Group Effort." I i
21 think that will give you some idea of the range of l
22 accomplishment by the Staff and by the Commission during Dr.
23 Jackson's tenure as the Chairman.
1
! 24 With that, do any members have any additional 25 comments they would like to make?
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5 1 [No response.]
(}
V 2 DR. POWERS: Then I think we can turn to the first 3 item of business, which is the hydrogen control exemption 4 request for the San Onofre Nuclear Generating Station, which 5 has the nicest acronym of any of the nuclear power plants --
6 SONGS. I love that.
7 Tom, I think you are the cognizant member on that 8 subject?
9 DR. KRESS: Yes. Thank you, Mr. Chairman.
10 We did have a subcommittee meeting to hear about 11 this last week. You will hear an abbreviated version of 12 what the subcommittee heard.
13 This is an interesting request because it is once 14 again another test of the NRC resolve to grant exemptions n
I i 15 based on risk criteria. It could very well have been O
16 granted under just the regular exemption rules. I think 17 that is 10 CFR 50.12. But because it meets all the 18 deterministic regulations, they also chose to chow the i
19 risk-informed part and it's interesting because it is one of 20 those cases where it doesn't affect CDF.
21 The request is to remove all of the hydrogen 22 control in the SONGS plant, except for there's four parts of 23 that. There is a purge-and-vent, there's recombiners, 24 there's a monitoring system, and there's also a mixing 25 system to mix it up inside containment.
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6 1 Well, the request is to remove all that except the ts 2 monitoring. I think they are going to decide to retain the v)
(
3 monitoring so that they at least know when hydrogen is 4 there.
5 The interesting part about it is it doesn't affect 6 CDF. If it has any effect at all, it is LERF and a 7 technically appropriate way to do that would be to look at 8 the uncertainties in the loads and the uncertainties in the 9 f ailure of the containment and see whether they cverlap and '
10 get kind of a probability of a delta LERF, but this is 11 another example of -- you know, that's a real sophisticated 12 PRA application and this is an example where qualitative 13 analyses are good enough. You don't really need a PRA here.
14 You can show that this, by just qualitative analysis that
() 15 16 the recombiner systems or that overlap is so small that it's just hardly even worth considering, so with that as a --
17 DR. POWERS: Before we go on, let me ask this j 18 question. We consider CDF and we consider LERF in the I 19 probabilistic types of analyses, but there are a variety of 20 other safety functions built in to the regulations that 21 don't get addressed.
22 Do we have any issues associated with those?
23 DR. KRESS: You would have if you were just 24 looking at CDF and LERF. I think there are other regulatory 25 objectives that have to do with the fission product release pg ANN RILEY & ASSOCIATES, LTD.
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7 1 in general and that LERF and CDF doesn't fully capture that.
2 In this case'though, I mentioned they meet all the L
l 3 deterministic rules and the deterministic rules are intended l 4 to capture some of those other regulatory objectives. As 1
5 long as you meet those and don't really compromise 6 defense-in-depth, then I think you are all right, so I think 7 for.this application where you have a large dry containment, 8 I think those concerns are not there, but they could be for 9 other applications, so we don't want to view this as a 10 blanket approval of removing hydrogen control systems from 11 all plants, but with that, why I think I will turn it over 12 to the SONGS people.
13 Ed Scherer I think will introduce the SONGS l
14 presentations, so the floor is yours -- up front, and please
() 15 16 remember to identify yourself before you start for the benefit of our recorder 17 MR. SCHERER: Thank you and good morning. My name 18 is Ed Scherer I am the Manager of Nuclear Regulatory Affairs 19 at Southern California Edison, and I would like to open with 20 a'few remarks, most of which have been very effectively 21 covered by Dr. Kress.
22 I would like to briefly cover the scope of our 23 application and then Tom Hook, who is the Manager of our 24 Nuclear Safety Group,.with the responsit *ity for the PRA 25 analysis and our safety monitor operatioli at the plant will ANN RILEY & ASSOCIATES, LTD.
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8 1 cover the basis and the details of our application.
l 2 As indicated, the scope of our Hydrogen Control 3 System are four parts: the hydrogen recombiner, the purge 4 subsystem, the monitoring subsystem, and the mixing system
- 5. inside.the containment.
6 The next slide shows the scope of our exemption 7 request. At this point we are asking for the removal of the 8 regulatory requirements on the hydrogen recombiners and the 9 hydrogen purge. If approved, we would not remove the 10 equipment from the plant. We would remove them from the 11 FSAR and the technical specifications. We would reclassify 12 the equipment as nonsafety-related. And while we would 13 remove them from the EOIs, we would not remove them from our 14 severe accident management guidelines, but would maintain
() 15 16 them in the severe accident management guidelines with the caveat that as they are available, they would be utilized.
17 So basically -- and we have also -- at the request 18 of the staff we've agreed that we would notify the staff 19 should we ever abandon our efforts to maintain the equipment j 20 that we already have.
21 As part of another application, we -- in this 22 application we had originally asked to remove the hydrogen 23 monitors. We thought our risk-informed application had 24 justified that. But as part of another application, we do 25 intend to maintain the hydrogen monitors, so we've asked the ANN RILEY & ASSOCIATES, LTD.
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7---
9
<1 staff not to take action on our request to eliminate I
l 2 hydrogen monitors as part of this application.
b(~S - 3 DR. POWERS: What type of monitors do you have for 4 hydrogen?
5 MR. HOOK: The monitors are an
'6 electrochemical-type cell that utilizes an electrolyte in a 7 permeable membrane through which the hydrogen from the 8 containment atmosphere passes through.
9 MR. SCHERER: And it requires some temperature 10 compensation during operation, but -- and its range is 0 to 11 10 percent.
12 The original scope or the original reason we made 13 this application was not because it was the most expensive 14 system to maintain, but because we believed it would serve 15 as a basis for other exemption requests. It was considered 16 a Task 0 of an NEI whole-plant study which had three 17 applications, the first one of which the staff granted to 18 Arkansas Nuclear 1, which was the approval to go from a 19 30-minute to a 90-minute requirement. Ours was the second 20 part of that application.
21- It is also an application that's consistent with 22 the modifying of Part 50 to be more risk-informed, and we 23 did go and look, under a risk-informed maintenance rule the 24 hydrogen control system would not be risk-significant and 25 would be outside the scope of any risk-informed maintenance
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1 I
10 1 rule.
2 Basically the conclusions we reached in making our 3 application, and Tom will cover these in some detail, is 4 .that we found the hydrogen control system is not needed for L 5 accidents' based on realistic assumptions. In other words, 6 when you use realistic assumptions, the hydrogen recombiners 7 don't play a significant part in reducing the risk.
- 8 In a severe accident, hydrogen is theoretically 9 generated so fast that the hydrogen recombiners would not 10 meaningfully keep up. The hydrogen purge is also not needed 11 for a large dry containment such as ours', and when we say 12 potentially detrimental, that's always the concern -- when 13 you open a purge of the containment, there's always the 14 finite chance that you can't reestablish that, even though 15 we have dual isolation, and that would be of course a risk 16- of creating a leak path that we didn't intend.
I 17 We would also eliminate hydrogen control steps and 18 activities from the emergency operating instructions, which 19 we think will simplify those instructions, especially in the l
20 early days of trying to mitigate a severe accident. And we 21- think that would be a risk-positive change, in that it would 22 eliminate distractions which would otherwise exist.
23 DR. POWERS: I'm fascinated by the term 24 " risk-positive." I assume that you mean a reduction in 25 risk.
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7
- 11 l 1 MR. SCHERER
- Reduction'in risk.
! /~ 2- DR. POWERS: There must surely be better
'k
- 3 nomenclature.
i 4 MR. SCHERER: Thank you for the comment. It's 5 always difficult when you're talking about risk to know 6 which way is the positive direction'and which one's the 7 negative direction.
8 DR. SEALE: There's a little oxymoron in there.
9 MR. SCHERER: I think we bought that when we used 10 the word " risk" instead of " safety."
11 Let's say it would have been a safety-positive 12 change.
13 Finally, the reduction in regulatory burden would 14 be a positive to us, but not that meaningful. We thought 15 that the principles that were involved here were more
(}
16 important to us than the financial savings that may or may 17 not accrue, but there are some safety benefits and financial 18 benefits that would, and therefore we have asked the staff 19 to proceed based on that basis.
l 20 If there are no questions on my introduction, let 21 me introduce Tom Hook, who will go through the basis we used 22 for providing our exemption request.
23 MR. HOOK: My name is Tom Hook from Southern 24 California Edison Company, the: manager of the Nuclear Safety 25 Group, under which I have probabilistic risk assessment ANN RILEY & ASSOCIATES, LTD.
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12 1 responsibilities as well as independent safety review.
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- V 2 I'm going to discuss the basis for '.nis exemption 3 request and how we came up with the -- met the acceptance 4 criteria in Regulatory Guide 1.174 for a risk-informed 5 regulatory application.
6 I'm going to describe three'different areas in the 7 reg guide and how we meet the criteria for those aspects of 8 the exemption request: the defense in depth, the safety 9 margins, and the risk impact.
10 Turning to the next slide, slide 8, first of all 11 in defense in depth in terms of fission product barriers, 12 the cladding, the fuel cladding, the reactor coolant system 13 pressure boundary and the containment pressu:re boundary, 14 this exemption request clearly affects the containment
[~D 15 pressure boundary as a part of the defense in depth.
\_ > l 16 We concluded as a result of our evaluation of 17 removal of the hydrogen control systems from the plant 18 design that they do not challenge containment integrity.
19 This is based upon an assessment that the hydrogen control 20 system is not needed for realistic assumptions for 21 accidents, and we're going to describe what those are.
22 The hydrogen control system is not sized to 23 mitigate severe accidents in terms of the amount of hydrogen 24 that's generated in a core uncovery situation. The Zircaloy 25 cladding oxidation clearly produces orders of magnitude more j l
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n 13 1 hydrogen than the hydrogen control systems are able to 2 accommodate in terms of removal from the containment J 3- atmosphere. And the hydrogen control system is only 4 valuable for the unlikely design basis accidents which are 1
5 beyond the Appendix K design degradation of the core, but 6 less than a severe accident that's typically evaluated in a 7 probabilistic risk assessment, and IPE or IPEEE.
8 DR. POWERS: When you do your design basis
! 9 analysis, you're looking at hydrogen that comes from say 17 10 percent of the clad oxidizing?
11- MR. SCHERER: Yes.
12 DR. POWERS: And what other hydrogen sources do 13 you consider?
14 MR. HOOK: The hydrogen sources are the actual
( 15 aluminum and zinc in the containment, and the radiolysis 16 from the fission products in the containment sump and in the 17 core.
18 DR. POWERS: And when you do those analyses and 19 you say it reaches some percentage, that must be some 20 percentage at some particular time.
21 MR. HOOK: That's correct.
22 DR. POWERS: And what is that particular time?
23 MR. HOOK: The particular time here is within 30 24 days.
25 DR. POWERS: Thirty days.
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t 14 1 MR. HOLAHAN: This is Gary _Holahan of the staff.
2 I'd like to clarify, the design basis requirement.,
3 the 17-percent oxidation is for the peak. '
4 '
DR. POWERS: I understand.
l 5 MR. HOOK: And 5 percent for the total.
6 DR. POWERS: The point is, Gary, that we go on for 7 some time. These things don't -- he has some continuing 8 sources. His aluminum, his radiolysis, and his zinc 9 oxidation are continuing in time, so, I mean, presumably if 10 you go on long enough, those numbers get very high. If you 11 were to allow me to go five years, I presume I could get 12 well over 4 percent. I might even then get up to the 13 downward flammability limit. And when the staff talks to us 14 about catalytic recombiners and says they don't know what
() 15 16 day to use, well, these gentlemen know what time period to evaluate those things.
17 MR. SCHERER: And we'll show you some parametric 18 studies that we've done to try to bound that.
19 DR. POWERS: And the kinetics on oxidation of the 20 metals, the aluminum and the zinc, is a challenging 21 undertaking but probably not very important to your numbers.
22 MR. HOOK: That's correct. They're a small 23 fraction of the contribution. The long-term contribution 24 predominantly comes from radiolysis in terms of the buildup, 25 slow buildup for which the recombiners and the purge were gs ANN RILEY & ASSOCIATES, LTD.
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15 i i designed to accommodate.
2 DR. POWERS: When you do the radiolysis, you do it 3 for pure water?
4 MR. SCHERER: Do we know?
5' MR. HOOK: I don't know. We utilize a Bechtel 6 code called hydrogen which meets the requirements and the 7 assumptions in the Reg Guide 1.7 in terms of the processes 8 that are occurring. I'm not familiar with the specifics of n 9 how it -- what assumptions about pure water.
l l
l .10 DR. KRESS: The g factor in there is higher, 11 bigger than you expect for pure water by almost a factor of 12 2.
l 13 DR. POWERS: By a factor of 2.
14 DR. KRESS: So I don't, you know, you couldn't say
()
1 15 it's pure water.
16 DR. POWERS: Okay. So, I mean, basically you use I 17 a g fr . tor to calculate the release and assume that there's l 18 nothing in therelthat combines -- yet there would be.
19 MR. SNODDERLY: Dana, I'd also like to -- this is 20 Mike Snodderly from the staff -- that there is no 30-day 21 requirement. Right, it's just that you do not --
22 DR. POWERS: I understand; 30 days is as good a 23 number as any.
24 MR. HOOK: Looking at the table at the bottom of l 25 slide 8 we show for a realistic, a design basis, and a p) g ANN RILEY & ASSOCIATES, LTD.
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16 1 beyond design basis the volume percent hydrogen, the first 2 row without hydrogen systems -- or which hydrogen system's 3 available in the containment, and we see for the realistic 4 that the hydrogen generated in 30 days is less than 4 5 percent. For the design basis we see it's also less than 4 6 percent because of the removal of the hydrogen from the 7 containment either utilizing either the recombiners or the 8 purge, and beyond design basis it's much greater than 4 9 percent.
1 10- And without hydrogen control systems, we see for 11 the realistic that it is less than four percent for the 12 realistic and greater than four percent for the design basis 13 and much greater than four percent for the beyond design 14 basis or severe accident. In terms of the --
() 15 DR. POWERS: Four percent is an interesting number 16 if you have a well-mixed containment and part of your system 17 is.a mixing capability, but now you take that mixing 18 capability out. Do you have a problem of stratification?
19 DR. KRESS: I misspoke. The mixing system stays 20 in.
21 DR. POWERS: Stays in?
22 DR. KRESS: Yes.
23 MR. SCHERER: Yes, we are not intending to make 24 any changes in our mixing system.
l l 25 DR. POWERS: So you can keep things relatively ANN RILEY & ASSOCIATES, LTD.
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1 l
l 17 1 uniform?
('" 2 MR. SCHERER: Yes.
~'
3 MR. HOOK: And we have design features in the 4 plant that I will describe in a little bit of detail that 5 ensure that there is adequate mixing in the SONGS type 6 containment, and in terms of characterization of the 7 usefulness of the individual systems, the hydrogen
)
8 recombiners in terms of realistic accidents are not useful ]
l 3 because they are not needed. Hydrogen purge is also not '
10 useful but not detrimental because of the release it would 11 create if it was used is small.
12 In terms of the design basis, the recombiners are 13 useful and hydrogen purge could be useful, but also would 14 represent a filtered release path and in terms of beyond
() 15 16 design basis, the recombiners would not be useful since the emergency operating instructions and the severe accident 17 management guidelines instruct us to turn off the 18 recombiners at 3.5 percent. The hydrogen purge would 19 potentially be detrimental because it is not designed to i
20 operate at pressures above several psi and the ability of 21 the valves to reclose upon a purge is not guaranteed and is 22 not evaluated and is not engineered, so it could --
23 DR. SEALE: Excuse me. You just mentioned 24 something that was kind of intriguing in the subcommittee 25 meeting that we had, namely that at 3.5 percent you ANN RILEY & ASSOCIATES, LTD.
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18 1 instructions are to turn the recombiners off and it was --
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t 2 let's say the thought was, at least by some, it might be l G l 3 desirable to leave them on, because then they would serve as 4 igniters while you were still in the low or non-explosive l
5 mixture range and purse the system in that way.
6 Do you have any more thought on that?
7 MR. HOOK: No. Since we had our discussion last 8 Wednesday, we wanted to go back to Combustion Engineering 9 and have them look at that and the benefits of leaving the 10 recombiners on, and that is something that we plan to do, 11 but we haven't had an oppormunity to do that yet, and that 12 is something we are taking under advisement because it does 13 appear to be a beneficial use of the recombiners in a beyond 14 design basis type event.
[\ss'\ 15 DR. POWERS: I think I would approach that with a 16 great deal of caution.
17 DR. KRESS: Yes, that was going to be my comment.
l 18 If you need igniters, you put in igniters. ;
19 DR. POWERS: Yes. I look at it from the 20 perspective of source terms and the idea of having hot spots 21 in an atmosphere where I have iodine-carrying aerosols may 22 cause us pause. .
I 23 MR. HOLAHAN: I think the Staff wants to take up 24 this issue with the Owners Groups as well, and make sure we 25 have a common understanding of what is recommended for s ANN RILEY & ASSOCIATES, LTD.
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F 19 1 accident management guidelines.
()
V 2 DR. SEALE: My curiosity is assuaged for the 3 moment.
l 4 DR. APOSTOLAKIS: What exactly do the words "not 5 useful" mean?
6 MR. HOOK: "Not useful" means that they either are 7 not able to mitigate the generation of hydrogen to that 8 which is presumed to be acceptable, below four percent, or 9 either they are not needed within 30 days to ensure that the 10 hydrogen concentration in the containment is below four 11 volume percent.
12 DR. APOSTOLAKIS: I don't remember now -- in 1.174 l
13 what was the requirement regarding defense-in-depth? What 14 were the words? Not be affected at all? Or the philosophy?
/~T 15 b
16 DR. POWERS: Surely you remember that.
17 DR. APOSTOLAKIS: The last few words there are 18 philosophical, I think.
19 MR. HOOK: And I will pick up in terms of the 20 safety margin a discussion about the adequacy of the 21 containment design to address a potential hydrogen burn in
.22 the containment.
23 Moving on to Slide 9, we performed --
24 DR. APOSTOLAKIS: I guess ?.he motivation for my 25 question was what if it had some impact? Then what you have fx ANN RILEY & ASSOCIATES, LTD.
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i 20 1 done?
l 2- Let's say the measure -- I mean this is not for 3 future applications. If you did affect defense-in-depth a 4 little bit, does that mean we give up or you would try to 5 argue that you still have sufficient defense-in-depth?
l 6 MR. HOOK: I believe based upon the guidance in 7 the Reg Guide we would look at the likelihood of the loss of 8 that defense-in-depth, the likelihood of the loss of the 9 containment cooling systems in concert with the generation I
10 of hydrogen and the likelihood that we would have a 11 containment challenge.
12 DR. APOSTOLAKIS: The only problem I see with that 13 is that maybe the PRA would_not be able to quantify small 14 impacts. That would be lost in the noise there, so --
15 DR. KRESS: I think this is one case where it 16 would be actually lost in the noise.
17 MR. SCHERER: And philosophically on a 18 risk-informed submittal we would not make an argument of the 19 zero standard on anything -- defense-in-depth or risk.
20 There is no zero standard that we would like to see us being i
21 held to, but a reasonable standard -- insignificant in terms l 22 of risk or insignificant in terms of compromising the 23 philosophy of defense-in-depth.
'24 If we thought it was significant compromise then 25 we would not make an application, but I don't think we would l
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r-21 1 view this against any zero standard, no compromising of the 2 philosophy of defense-in-depth.
3 DR. APOSTOLAKIS: So in that sense you would argue 4 that you still have sufficient defense-in-depth?
5 MR. SCHERER: Sufficient, and that it is not a 6 significant compromise.
7 DR. WALLIS: Although your arguments for 8 significance are entirely qualitative. There is no 9 yardstick you are using to say whether or not it is 1 1
10 significant. I don't want a zero standard, because that's )
11 ludicrous, but then you don't have a measure of how far from 12 zero we are.
13 MR. HOOK: Well, you will see later in the 14 presentation that we looked at worst case events from a
( 15 deterministic point of view and the pressures that you would 16 see from a hydrogen burn at those concentrations of l
17 hydrogen, and concluded based upon a combined probabilistic, '
18 deterministic evaluation of the containment that the 19 containment would be able to withstand those severe 20 accidents.
21 DR. POWERS: It's a big horse containment.
22 DR. WALLIS: I know at the subcommittee meeting we 23 talked about the 95th percentile and so on and there is some 24 effect on risk.
25 MR. HOOK: Of course.
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22
- 1 DR. WALLIS
- But it is not really quantified in
(
'~T 2 your submittal.
3 MR. HOOK: It's very difficult.
4 Moving on.to Slide 9, we looked at a number of 5 parametric evaluations of the hydrogen generation, 6 considering first the design basis, utilizing the 7 assumptions in Reg Guide 1.7 and the Standard Review Plan l
8 6.2.5.
9 And we looked at three cases where we revised the 10 assumptions involving the hydrogen generation rate. We 11 looked at the metal-water reaction conservatism that is 12 included in Reg. Guide 1.7, a factor of 5, the radiolysis 13 generation rate, the 20 percent conservatism that is in the 14 Standard Review Plan, Appendix A, and we removed those from l
() 15-16 the calculation, the hydrogen code that we used that was developed by Bechtel, and reevaluated the hydrogen 17 generation in the containment over a period of time.
18 We also looked at Case 2 where we revised the sump 19 radiolysis yield from'.5 molecules hydrogen per 100 EV to 20 .4, which is a mid-point between the Reg. Guide and a number 21 of references from Westinghouse and Oak Ridge National Labs 22 for the hydrogen generation.
23 And in Case 3 we looked at the same parameters as l 24 Case 1 except revising the sump radiolysis yield from .5 to 25 .3. i
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E I 1
23 1 So we evaluated, removed some of the conse vatism
(~^g 2 from the Reg. Guide 1.7 and Standard Review Plan analysis
\J 3 and came up with the results in Slides 10 and 11. Slide 10 4 is a table showing the values for hydrogen concentration 5 without any hydrogen control in the containment at 20 days, 6 25 days and 30 days. And we see for the design basis case 7 that we exceed the lower flammability limit of 4 percent at 8 approximately 13 days, and at 20 days we are 4.6 percent and 9 so on.
E10 For Cases 1, 2 and 3, we see, regardless of the 11 assumptions we make about the hydrogen generation rate and j 12 the conservatisms that were removed, that we stay at or l q
i 13 below 4 percent in 30 days for all of these cases. And you l
14 see in slide --
/ \ 15 DR. POWERS: When you do these evaluations, you
%I i
16 are getting -- you have a background level of hydrogen {
17 coming from some assumptions that you have made about 18 metal-water reactions in the core region. And then you have 19 a continuing source coming from the water radiolysis 20 primarily, low within the containment. And my recollection 21 of the containments at SONGS is that you have a large open 22 area up at the top, but down below the operating deck we 23 have a warren of rooms and sumps and places like that where 24 water accumulates. Do you have a problem of hydrogen 25 concentration in these lower rooms?
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I b 24 l l
l 1 MR. HOOK: As a part of the individual plant -
i
(~N 2 examination, we conducted an extensive walk-through of the l k m 3 SONGS containment and concluded from that, and that was a l 4 walk-through that was attended by our contractors as well 5 from Fauski Associates and Erin Engineering, and concluded 6 that the SONGS containment, based upon its design, has vent 7 paths for all of these lower compartments to the upper l 8 compartment, and what we would characterize as generous 9 paths. As well as the mechanical moving mechanisms, the 10 dome recirculators, the containment fan coolers that would 11 assure that these lower areas are vented to the -- and there 12 is good mixing to the large, open, upper area above the 13 operating deck. So that was specifically looked at as a 14 feature, as a part of the individual plant examination, and
[~h 15 it is not a concern at San Onofre in terms of pocketing in d
16 the lower compartments.
17 DR. KRESS: Dana, I raised this issue at the 18 subcommittee meeting and my comment there was, once again, 19 it would have been nice to have some of a code to calculate 20 hydrogen distribution in containment.
21 DR. POWERS: Wouldn't it be nice.
22 DR. SEALE: Deja-vu.
23 MR. HOOK: In Slide 11 we see the hydrogen l I
24 generation rate over time, and you see that the design basis j 25 in the black line -- l I
()
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25 1 DR. WALLIS: ,
Excuse me. This business of the "T 2 walk-through about tr.o venting, this is just a bunch of (O 3 people looking at the room and saying, gee whiz, we think 4 that is well enough vented? Isn't there some sort of 5 analysis made of this? l 6 MR. HOOK: There is no quantitative analysis, it 7 is a walk-through of experts who have viewed other I 8 containments in terms of their --
)
9 DR. WALLIS: I was wondering what their expertise 10 is based on if they haven't done an analysis. Is it just a 11 guess?
12 MR. HOOK: It is engineering judgment.
13 DR. POWERS: But the question is, where does the 14 judgment come from? I mean if you have never seen 15 something, you can't have any judgment about it.
(}
16 MR. HOOK: But the personnel that were involved 17 had conducted walk-throughs of other plants, especially the 18 experts that we had from Fauski & Associates who were our 19 primary contractor for the containment analysis.
1 20 DR, POWERS: But I mean you can walk through a 21 hundred containments -- incidentally, I have walked through 22 the SONGS containment for Unit 2, I believe, and memory 23 fades, but I am reasonably familiar with it. But it is not 24 evident to me that I can do a mental mass transport analysis l 25 and say, oh, yes, there is no pocceting here. And I could !
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26 1 probably' walk through a hundred containments -- I think I am
( 2 at 30 or something like that, and I would be no better at 3 doing a mental analysis. And the question -- i 4 DR. KRESS: Do you think Fauski could?
5 DR. POWERS: But now Hans, I will grant Hans is 6 far better at this than I am, but I am willing to question I j
7 the accuracy of his mental analysis on this if he has not 8 done an analysis of, say, comparing the HDR containment and 9 hydrogen distribution in that, those experiments, to arrive 10 at some judgment an these things.
11 DR. APOSTOLAKIS: Surely, they must have done some 12 analysis in the past.
13 DR. POWERS: Well, that is what we are asking.
.14 DR. APOSTOLAKIS: Yes, I mean their judgment
() 15 16 cannot be based only on the fact that they have walked through any containments. So now -- )
i 17 DR. KRESS: Very few people have done these !
18 hydrogen distribution analyses because they are hard to do.
19 There are a few codes out there that will do it, COMMIX is 20' one of them probably. And COMMIX is familiar to Fauski.
21 HDR will probably --
22 DR. APOSTOLAKIS: COMMIX?
23 DR. KRESS: COMMIX, it is a containment code. HDR 24 will also probably do it.
25 DR. POWERS: Well, I mean I think we have seen ANN RILEY & ASSOCIATES, LTD.
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27 1 that some of the field codes, and even some of the codes
'g 2 that lack a momentum equation can, with skill, calculate --
(V 3 skilled operators calculate the hydrogen distributions.
4 DR. KRESS: Yes, I would be suspicious of it if it 5 doesn't have the momentum equation.
6 DR.-POWERS: Well, they do it with tricks on the 7 noding and things like that. What we have never been able 8 to do is say, gee, these ideas work well, say, for the 9 comparison of the HDR containment analysis -- experiments, I 10 but does it translate into something else, some other q
11 containment? I mean I don't know how you would go about 12 proving to yourself that was the case.
13 DR. KRESS: Right.
I 14 MR. SCHERER: I am not familiar with what they did
() 15 16 or did not do fut the way of analysis, but I do recall back on the original licensing of SONGS that Bechtel had done 17 analyses looking for pockets of hydrogen and making sure 18 that the design had been modified to eliminate and 19 facilitate the hydrogen -- the communication between those 20 _subcompartments so that pocketing did not exist, to the 21 extent that they could at the time and analyze it. So I do 22 recall that as part of the original design basis for the 23 plant.
1 24 MR. HOOK: And there is an evaluation described in l 25 NUREG/CR-5662 entitled, " Hydrogen Combustion Control and 1
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1 1
28 1 Value Impact Analysis for PWR Dry Containments" that
/ 2 indicates for a number of the large dry containments, N.)T 3 including San Onofre, that the time required to process one 4 containment volume utilizing the mixing system, the fans 5 that pull air from the lower compartments up into the upper, 6 is on the order of 10 to 30 minutes, and for San Onofre it 7 is approximately 20 minutes. So there are large fans that 8 would be operating if there was power available that would 9 provide a tremendous amount of mixing in the containment 10 through forced ventilation. But specifically regarding 11 pocketing in a single compartment, we don't have any 12 quantitative calculation to evaluate the potential for that.
13 DR. KRESS: Where are your recombiners located in 14 the containment?
()
15 MR. HOOK: Now, the recombiners are located right 16 above the operating deck.
17 DR. KRESS: So they wouldn't be very useful with 18 these pockets anyway.
19 MR. HOOK: That's correct. And the mixing system 20 actually is located at the operating deck with fans that 21 pull the air from the lower subcompartments up into the 22 large open area above the operating deck.
23 MR. SCHERER: But, again, the original design was 24 reviewed to eliminate pocketing and a recent walk-through 25 certainly confirmed that nothing would have caused pocketing
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'29 1 to exist, t 2 DR. KRESS: Dana, these curves illustrate your 3 point, that they just keeping on. The only things that 4 bends them over is the K-heat.
5 DR. WALLIS: Are you saying the fans draw? But
- 6. the fans are way up here somewhere.
7 MR. HOOK: Right.
8 DR. WALLIS: The fan coolers, the coolers are up 9 here somewhere. The pockets we are talking about are j 10 down -- l J
11 MR. HOOK: We understand.
l 12 DR. WALLIS: It is not quite clear to me how the l I
13 fans up here draw something.
1 14 MR. HOOK: Well, there are actually fans at the 4
() 15 operating deck that take suction from the lower containment 16 volume.
17 DR. WALLIS: So there are fans down there as well?
18 MR. HOOK: That's correct. Looking on Slide 11, 19 you will see that for the case, the Parametric Study Cases 20 1, 2 and 3 where we varied the assumptions, there is very i
21 little difference in terms of the hydrogen generation rate 22 varying those assumptions, but we get to 30 days with the 23 concentration less than 4 volume percent in the containment 24 for the sensitivities.
25 Moving on to Slide 12, in terms of safety margin ,
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30 1 and the impact of the hydrogen control exemption request on 2 the containment, .the SONGS 2&3 have large, dry containments 3 with a design pressure of 60 psig. Large, dry containments 4 'are the least susceptible to damage from a hydrogen burn 5- following severe accidents based upon a number of references 6 and evalua'tions and actual TMI event. In the TMI event with 7 approximately 8 percent hydrogen concentration in the 8 containment from approximately a 45-percent metal-water 9 reaction there was a resulting peak pressure of 28 psig.
10' And the TMI 2 containment design pressure was the same as 11 SONGS at 60 psig.
12 Also, there were a number of other industry and 13 NRC. evaluations. An industry evaluation at NSAC 22 and NRC 1-4 evaluations in the NUREG that I cited previously, 5662, show
() 15
'16 that large, dry containments can withstand hydrogen burns, including those from severe accidents up to a 75-percent I
17 metal-water reaction. And the SONGS 2&3 have been evaluated l 18 in a detailed deterministic and probabilistic containment 19 analysis where we looked at individual penetrations and 20 performed detailed stress calculations to determine the 21 failure pressures for those penetrations.
l 22 We concluded that the median leak pressure for the !
'23 containment -- and this would be at the fuel transfer 24 bellows into the fuel handling building -- is approximately 25 157 psig, and the median rupture pressure, which would be a ;
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31 1 major failure of a containment tendon and a venting of the 2 containment, would occur at approximately 175 psig. The 3 95-percent-confident values, as we discussed in the 4 subcommittee meeting last week, are 99 psig for the leak 5 pressure and 139 psig for the rupture pressure.
6 DR. POWERS: I guess you need to explain to me a 7 little more what you mean by the leak pressure. The 8 containment leaks all the time.
9 MR. HOOK: This is a leak that has the potential 10 to create a source term that could be characterized as a 11 large early release, and for us that's an equivalent hole in 12 the containment that is on the order of about two inches 13_ diameter versus the design leaks.
14 DR. KRESS: Just out of curiosity, why did you
~
\ 15 decide to report medians instead of means here?
[Y -
16 MR. HOOK: That was just a --
17 DR. KRESS: Just a choice?
18 MR. HOOK: Just a choice.
19 DR. POWERS: Good sense.
20 DR. KRESS: Good sense. That's what you would 21 say, right?
22 MR. HOOK: But the 95-percent confidence levels ,
i 23 are the telling certainty we have in terms of the robustness l 1
24 of the containment, its ability to withstand beyond-design i 1
25 pressurization.
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32 1 DR. APOSTOLAKIS: So what are those?
("Sg 2 MR. HOOK: 99 psig for the leak and 139 psig for G' 3 the rupture pressure. Those are 95-percent confident
! 4 values.
5 Turning to slide 13, the SONGS -- based upon the 6 evaluation of the benefit of the hydrogen control system in 7 severe accidents, we concluded that the hydrogen control 8 systems consistent with other large, dry PWRs are 9 ineffective in mitigating hydrogen in severe accidents. If 10 you look at NUREG/CR-5567, it also supports that conclusion 11 for the large, dry PWRs, and the NRC's post-TMI evaluations 12 concluded that large, dry containments could withstand 13 hydrogen burns following severe accidents.
14 Slide 14 contains a worst-case evaluation that we 15 performed with the assistance of our level 2 contractor, 16 FAI, to evaluate the containment pressurization for a 17 worst-case hydrogen burn, and this is at a containment 18 hydrogen concentration of 11-1/2 percent. That 19 deterministic hand calculation for the worst-case hydrogen 20 generation accounted for both in-vessel and ex-vessel 21 hydrogen. We've suppressed all the burning of the hydrogen 22 up to a single point, letting it accumulate. We assumed 23 adiabatic, isochoric complete combustion with no heat 24 transfer to the containment structures and no failure or 25 venting of the -- or loss of pressurization of the burning, l
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m 1
33 1 1 the hydrogen that's burning. !
We looked at the worst-case water makeup to the 2
3 core that would result in the greatest hydrogen generation 4 rate, an unlikely case where we have three charging pumps 5 operating, providing about 150 gallons per minute to the 6 core but no high-pressure safety injection or low-pressure 7 safety injection. So this optimizes the amount of Zircaloy 8 oxidation providing just the right amount of water for that, 9 and this is a very unlikely scenario, to have three charging
'10 pumps operating and no other ECCS operating.
11 DR. WALLIS: There's also pressurization by the 12 released steam; this is taken account of here, too?
13- MR. HOOK: This calculation does not take into 14 account the pressurization from the released steam.
() 15 16 DR. WALLIS: So the actual pressure from that would be higher than the 142 if you considered the released 17 steam as well?
I 18 MR. HOOK: I'll talk about that in a second. But 19 this assumes the burning of 2,433 pounds of hydrogen, and 20 the post-peak pressure in the containment's 142 psig i
21 compared to the median rupture pressure of 175 psig, when we 22 evaluate this scenario using MAPP and look at.the benefit of 23 containment spray, a single train of containment spray .
24 operating, and the actual heat removal from the containment 25 structure as we calculate a peak containment pressure of 115 I
p)
(_
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34 1 psig for this scenario.
l So this worst-case calculation here
\
2 .does not look at the steam contributions.
3 DR. WALLIS: It's not quite worst-case.
4 MR. HOOK: It's not worst-case. There are a 5
number of situations where the containment can fail from a 6 worst-case hydrogen burn combined with a loss of containment 7 heat removal.
8 DR. WALLIS: So if you had decided ~that this case !
9 should not be above the 95-percent value, we hadn't thought l 10 about this at tl.e subcoramittee, this actually is above the 11 k 95-percent confidence value for the -- 1 J
12 MR. HOOK: For a leak. l h
13 DR. WALLIS: For rupture pressure. Rupture 14 pressure's 139.
() 15 MR. HOOK: That's correct, but in terms of the 16 realistic evaluation from MAPP, it's 115 psig, which is 17 below the 95-percent confidence level --
]
18 DR. WALLIS: So if you're going to make this 19 comparison and say it's worst-case, you should put in all 20 the worst aspects and perhaps compare with something like a 21 95-percent value rather than the median, which makes it look 22 better than it does, than it really is.
23 MR. HOOK: Okay. Turning to Slide 15, in terms of 24 the impact of removal from -- of the hydrogen recombiners 25 and purge from the plant design, if they were unavailable l
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35 1 and unable to operate, how would we accommodate the hydrogen 2 generation utilizing the severe accident management 3 guidelines? The guidelines provide direction to prevent a 4 fission product release, to bottle up the containment 5 structure and penetrations, to maintain a leaktight 6 structure, to reduce containment temperature and minimize 7 long-term hydrogen buildup from the metal-water reaction or corrosion of the zinc and aluminum utilizing the fan coolers l 8 I
1 9 and/or containment spray. They provide direction to operate 10 both to reduce containment pressure and temperature, to 11- scrub the fission products utilizing the -- operating the 12 containment spray and the fan coolers. Obviously the l
1 13 containment spray is much more beneficial in terms of 14 scrubbing fission products out of the containment atmosphere
() 15 16 than the fan coolers.
They also have some limited capability to provide 17 long term clean-up of the containment after extensive l
18 scrubbing, and the potential exists then if the containment 19 pressure is reduced to near-atmospheric that we vent the 20 containment, utilizing the mini-purge or other temporary 21 filtration systems if the hydrogen purge system was not 22 available.
23 DR. KRESS: I would like to go back to your
- 24. previous slide just a second. For Graham Wallis's benefit, '
l 1
25 the hydrogen recombiners control system would have no effect
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36 1 on this at all. Whether it was there or not, you get the O 2 same numbers, b 3 MR. HOOK: That's correct.
4 DR. WALLIS: For a reading you get 142? You don't 5 get something like 139 with the --
6 MR. HOOK: No.
7 DR.'WALLIS: They don't -- don't they remove --
8 but they have been switched off.
9 MR. HOOK: They have been switched off. In f act ,'-
10 they probably would never be turned on because we would go 11 past the 3.5 percent cutoff limit before they had an 12 opportunity to sample in the containment the containment 13 hydrogen, and the purge --
14 DR. WALLIS: It's your strategy that is making 15 this -- making them ineffective.
1 16 MR. HOOK: That's correct, and that is the Owners !
17 Group strategy and consistent with the other --
18 DR. WALLIS: If the strategy had been to leave j 19 them on no matter what, then they would have had some effect 20 on this worst case?
21 MR. HOOK: Probably by creating a burn earlier, 22 but not by actually removing any hydrogen, because there 23- removal rate is on the order of a fraction of a percent of 24 the hydrogen that is actually being generated.
25 They have a design flow on the order of 100 CFM l
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1 I
37 l
1 and we are talking --
/"'g 2 MR. SCHERER: Very frankly, I think if you leave k/s 3 them on, it would reduce this number because this has been 4 4 done so conservatively to maintain all the hydrogen until 5 the worst possible time, you turn on that hydrogen 6 recombiner and those numbers will go down but then again you 7 are adding realism to a very conservative calculation.
8 The calculation we tried to do as conservatively J 9 as possible. Any time you try to add realism the number 10 will go down, but then again how did you get this in the 11 first place?
12 DR. WALLIS: I was just responding to Dr. Kress, 13 who said they would have no effect.
i 14 MR. SCHERER: They have no effect because we are
() 15 16 trying to create the most conservative calculation.
DR. KRESS: And there are probably remote 17 sequences you can dream up where they would have some effect 18 on the peak pressure, but not much.
19 If the hydrogen generation is low enough that j 20 their rate can keep up with it, it's not going to be a l
21 severe problem anyway, and if the hydrogen generation rate J 22 is anywhere comparable to this, they are not going to be 23 able to keep up, not going to have --
24 MR. SCHERER: Please don't confuse this with the 25 strategy. We would not intend to turn off the high pressure l
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38 1 safety injection either We would not intend to turn off
.(\s -2 .the low pressure safety injection. We would not intend to 3 turn on the three charging pumps.
4 DR. KRESS: This is just an illustration of the 5 robustness of the large dry containment.
6 MR. SCHERER: Exactly.
7 DR. WALLIS: It's good to make the calculation 8 suppose that you don't intend to but somebody does.
9 MR. SCHERER: I understand.
10- DR. WALLIS: To investigate that territory.
11 MR. SCHERER: And that is why we did the 12 calculation.
13 MR. HOOK: And turning to the summary slide, we 14- have indicated that the proposed change does not-affect the
- ~h 15 SONGS 2, 3 defense-in-depth of the containment design.
b It 16 does not challenge or increase significantly the likelihood
-17 of containment challenge of large, dry containments like San 18 Onofre 2 and 3 that have the capability to withstand the 19 worst case hydrogen burns as a result of the robustness of ;
20 .the containment design and the confidence we have in that 21 robustness as a result of a combination of a probabilistic 22 and deterministic evaluation.
23 The hydrogen control system is not needed for 24 accidents based on realistic assumptions. When we take out 25 the conservatisms that were indicated in the Reg Guide and ANN RILEY & ASSOCIATES, LTD. !
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1 39 1 Standard Review Plan the hydrogen control system is not l
("*)g 2 ,
sized for severe accidents and could be potentially l
3 detrimental in the case of the hydrogen purge since the 4 filter system was not designed for a high pressure release, 5- the valves were not designed to open and close at elevated 6 ' containment pressures.
7 Elimination of the hydrogen control steps in the 8 activities'from the EOIs.
- 9. [ Pause.]
10 DR. POWERS: Obviously there are some systems I 11 would like to turn off here.
12 (Laughter.)
13 DR. APOSTOLAKIS: I have a question. This is not 14 really a risk-informed approach, is it?
() 15 DR. KRESS: It meets the rules for the normal 16 exemption rather than a risk-informed -- but you are asking 17 what'is the CDF, what is the LERF, what is the delta. It is 18 risk-informed from the standpoint of they decided that the 19 change in risk was a decrease in risk and the risk-informed j 20 1.174 says if you have got a decrease in risk, it is 21 always -- if you don't compromise defense-in-depth then it 22 is always granted.
23 So it is, you know, risk-informed in a normal 24 sense in that respect./
25 DR. APOSTOLAKIS: Is it really supporting gs ANN RILEY & ASSOCIATES, LTD.
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l 40 1 risk-informing 10 CFR 50?
- 2. DR. KRESS: I don't know how it does. It is 3
consistent with what -- we don't have a risk-informed 10 CFR 4 50.
5 .DR. APOSTOLAKIS: We're trying to risk-inform it. I 6 DR. KRESS: Yes.
7 DR. WALLIS: At the subcommittee meeting I guess 1
8 we raised the same point and I thought we concluded that l 9 they're barely scratching the surface of risk-informed. i 10 It's actually quantitatively. evaluating risk. It's not 11 required for this application. Eventually it will be, L .12' but -- if you are really going to risk-inform 10 CFR 50.
1 13 DR. APOSTOLAKIS: Because this was also part of 14' the Task Zero of NEI so again it's not a very convincing
() 15 case from that point of view.
16 MR. SCHERER: It is not intended, and you point
'out, it is not a sophisticated approach to risk-informing 1
17 )
18 the regulations. It was intended to be a starting point.
19' DR. KRESS: Take the small stuff --
20 MR. SCHERER: -- and it was risk-informed to the 21' extent that we believe the risk, the change in risk is very l
l 22 small. It was not a risk-significant system and to that
- 23. extent we certainly feel it is a risk-informed submittal.
24 Is it advancing the state of the art? I don't l 25 believe so.
l l
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41 1 DR. APOSTOLAKIS: Well, the thing is --
[~T 2 DR. KRESS: It does illustrate, George, that you V
3 don't always need a full PRA.
4 DR. APOSTOLAKIS: I was.about to say that.
5 DR. KRESS: Depends on the nature of the --
6 DR. APOSTOLAKIS: I suspect we are going to have a 7 lot of cases in the future where one would do calculations 8 like the ones you gentlemen did and perhaps advance
.9 qualitative arguments and ultimately reach the conclusion 10 that,.you know, risk is reduced for whatever -- for the 11 increase is minimal.
12 DR. SEALE: These are the folks that have the risk 13 meter, and they did confirm that there would be no change in 14 the risk meter reading as a. result of this.
15 DR. APOSTOLAKIS: Yes.
O[~D 16 MR. SCHERER: And we could be back here discussing 17 some more applications that will.
18 DR. APOSTOLAKIS: Again, since we are setting 19 precedents here, it may be a minor point, but you know, 20 communication sometimes is important.
21 On the Slide 13 and 14, especially 14, I would 22 delete the words " risk impact" from that heading of the 23 slide because.you say -- the analysis that you are doing is 24 worst case so I don't want to associate worst case analysis 25 with risk impact..
Wg ANN RILEY & ASSOCIATES, LTD.
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i 42 1 DR. KRESS: That's a good point.
2 DR. APOSTOLAKIS: Just delete the words " risk U("'t 3 impact" --
I mean what you have done is fine. Okay?
4 Because if we start creating a tradition again of jumping 5 into conservatism and worst case analysis every chance we 6 have, we will never become risk-informed. That is a minor j l
7 comment.
8 MR. HOLAHAN: One additional point I would like to 9 add. One of the things that was really tested in this 10 application is not so much the risk analysis as much as what 11 values we place on other things, some of which can't be 12 quantified or are sort of at the boundaries of what you 13 think are valuable, things like hydrogen monitoring.
14 I think the Staff was very reluctant to give up
() 15' 16 hydrogen monitoring because there's some value to knowing what is going on in containment.
I 17 I think the Staff placed some value on the I 18 accident management guidelines as a way of dealing with 19 things like multiple hydrogen burns, subsequent burns. Even 20 though the analysis would show they are unlikely to cause 21 containment failure, and so you wouldn't change your LERF 22 values, as a matter of fact they occur so far out it's 23 probably not LERF anyway -- but there's some value I think 24 to not having additional burns in containment, so some of 25 these things are not easily quantified but to the extent ANN RILEY & ASSOCIATES, LTD.
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i 43 1 that they are tested in this case I think may be very 2 typical of what future risk-informed applications do.
3 MR. SCHERER: Why don't I just summarize then.
4 Perhaps this is as good a point as any for me just to 5 briefly summarize our position that for the four subsystems 6 of the hydrogen control system. Obviously, we intend to 7 make no change on the hydrogen mixing system inside the 1
8 containment.
9 We asked the Staff to hold aside any effort on the 10 hydrogen monitoring system. We'll maintain that system as 11 part of another application.
12 As far as the hydrogen recombiner and the purge 13 subsystems, if our application is granted we will remove 14 them from the FSAR and the technical specifications. We
() 15' 16 will reclassify the existing systems as non-safety related systems, but we will not remove them from the plant.
17 We will maintain them as they are available and we 18 will maintain them in the severe accident management 19 guidelines as the equipment is available, and we have agreed 20 to notify the NRC should we ever abandon our attempts to 21 continue to maintain either the hydrogen recombiners or the 22 hydrogen purge system.
23 By the way, there are two other purge systems in 24 our plant -- mini-purge and the full containment purge.
25 Those will continue to exist.
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44 1 Are there any questions?
2 DR. KRESS:
O 3 Since I see no further questions --
DR. APOSTOLAKIS: Just out of curiosity, do we 4 ever calculate the Fussel-Vesley importance measure or RAW 5 with respect to LERF?
6 MR. HOOK: We do at San Onofre?
7 DR. APOSTOLAKIS: You do?
8 HMR . HOOK: Yes.
9 DR. APOSTOLAK1S: Do you have any importance 10- measure for these equipment?
11 MR, HOOK: Oh, it has not importance based upon 12 our evaluation that the equipment plays no role in a severe 13 accident.
14 There was a conclusion made early in the analysis 15 that as a result of the direction to turn off the
)
16 recombiners at 3.5 percent and the fact that the hydrogen 17 purge is not designed for a high pressure release that they 18 would play no role in mitigating a severe accident, so their 19 Fussel-Vesley role is basically inconsequential -- so there 20 is no calculation.
21 It's like looking at another system in the plant 22 for which you conclude plays no role in the severe accident, 23 and therefore you don't include it in the PRA model because 24 of the lack of its contribution to mitigating the event.
l 25 DR. APOSTOLAKIS: Isn't that an argument in !
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( 45 i
1 itself? The thing is not modelled at all because it is 2 irrelevant. Thar. is essentially what you are saying.
3 MR. HOOK: That's correct, and that is one of the 4
reasons this was selected was because it was a clear-cut 5 case for all the lightwater large, dry PWRs where this 6 conclusion had been reached.
7 DR. KRESS: George, earlier on when I was first 8 looking at this, I had thought there may be sequences that 9 went through early something like a design basis accident, 10 so-that the generation rate early-on in the accident would 11 be something like what you got from the design basis and 12 then -- and during that time the recombiners would be taking 13 out some stuff at about the same rate it's generating until 14 you turn them off and enter it into a severe accident, but
() 15 16 you did reduce for those sequences some hydrogen and lowered the probability that you would fail the containment to some 17 extent by this overlapping of the uncertainties.
18 I searched and searched'and I couldn't find any i 19 sequences like that for large drys. There may still be some 20 for BWRs, I'm not sure. I didn't look at those. I just 21 looked at the PWRs but I just couldn't find any, so they j 22 wouldn't show up in a PRA.
23 DR. WALLIS: Now the folks that required that you 24 . install these in the first place, I take it, have all 25 retired? 4 i
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46 1 [ Laughter.]
2 DR. WALLIS: And there is no one to testify I was 3 wrong.to insist that they were installed or --
4 MR. HOLAHAN: Professor Wallis, is that a question 5 or a statement?
6 (Laughter.)
7 DR. SEALE: Just an observation.
8 DR. WALLIS: I was just thinking it. This was a 9 requirement that was insisted upon at some time and they 10 have been in here all this time and now it's been decided 11 they are not necessary, which may well be true.
12 We don't have -- we don't get to question the 13 people who required they be put in there'in the first place.
14 MR. HOLAHAN: As a matter of fact, some of those
() 15 people still do exist. I think you could have spoken to 16 them if you asked them --
17 DR. WALLIS: Did the Staff ask them? I mean I l 18 just. wonder what their opinion is.
l l 19 MR. HOLAHAN: I think some of them are l
20 knowledgeable of this because they are in the same branch.
21 DR. WALLIS: So they go along with it then?
22 MR. HOLAHAN: Mike, do you want to speak to it?
23 MR. BARANOWSKY: I think that part of the problem 24 you run up against, and I spoke about this to the 25 subcommittee, is that we're mixing the risk world and the ANN RILEY & ASSOCIATES, LTD.
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f i
47 '
1 emotional world. If you look at the original statement of
^
( 2 considerations for why these things were put in, it was
\>}
3 because of the adverse public reaction to the possibility of 4 public -- I'm sorry, adverse public reaction to the 5 possibility of venting at TMI, and then when you look at I 6 this from a risk perspective, the risk is acceptable, so i l
7 that is really the basis for why the recombiners were put i 8 in, and there was so much uncertainty with the risk at the 9 time of TMI and now that we have done a lot more research !
10 and we have a lot more -- we have quantified those numbers 11 better and we have looked at it through 1150, which we are 12 going to discuss here in a little while, then I think that 13 argument, the emotional argument isn't as strong.
14 DR. KRESS: That is the nice thing about
() 15 risk-backed information. You can go back and re-evaluate i
I 16 the basis.
17 DR. WALLIS: But if this was installed originally 18 because of adverse public reaction, if that was the 19 criterion, they I guess you would want to be reassured that 20 there wouldn't be adverse public reaction to taking out 21 recombiners -- if that was the reason why they wer. put in 22 in the first place. It's the public that's concerned, and 23 so you do have to make a case to them.
24 DR. KRESS: We are going to have that issue every 25 time we remove something based on risk-informed.
i
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48 1 MR. HOLAHAN: True. I think the other point I 2 would like to make is in response to your comments at the 3 subcommittee meeting, I did go back and look a little bit at .
4~ the history of this issue, and I was reminded that in fact 5 the. Staff raised the hydrogen issue as part of the marginal 6 to safety program in the early '90s as a candidate issue for 7 being removed from the regulations.
.]
8 And at that time the industry indicated that it 1
9 was.not one of their priority considerations for removal.
10 They had other priority issues such as graded quality 11 assurance which we have dealt with in the last few years.
12 So, I think, . you know, this is not a surprising issue, we 13 have known it is a candidate for removal or modification for 14 a fair amount of time.
() 15 DR. POWERS: Gary, I guess I am a little confused.
16 I mean hydrogen recombiners have nothing to do with TMI. j l
17 MR. HOLAHAN: Hydrogen had something to with TMI.
18 DR. POWERS: Hydrogen has something to do with 19 TMI, but tl.a recombiners have been in there for a lot longer 20 than TMI.
21 MR. HOLAHAN: Yes.
i 22 DR. POWERS: But that is not why they were 4
)
23 originally put in. They were originally put in to handle i
24 the' hydrogen that was produced by a combination of H25 metal-water reactions, radiolysis and corrosion of metals in !
1 O ANN RILEY & ASSOCIATES, LTD.
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49 1 the containment. There was a presumption that those 2 hydrogen sources could be larger than maybe they were O 3 anticipated to be based on deterministic analysis at the l
4 time, and so it was considered a defense-in-depth 5 measurement. These gentlemen have come in and said, whoa, 6 we are smarter now, know more, we have adequate 7 defense-in-depth from other sources. They may in fact 8 arguably make severe accidents worse. It has nothing to do l 9 with adverse public reaction to anything, l
I 10 MR. HOLAHAN: Right.
11 MR, SNODDERLY: Dana, I was just, I guess -- you 12 are absolutely right, and the recombiners were installed at 13 TMI 2. And the only point I was trying to make was that the 14 recombiner rule was reconsidered in 1981 as a result of TMI a
(} 15 to see if that requirement was sufficient, or the design 16 basis for the recombiners needed to be reconsidered. And in 17 that Statement of Considerations is where I got the 18 statement that.I' quoted. I 19 DR. POWERS: Sure, I understand. But I mean I 20 just don't want people to think that the original reason had 21 something to do with TMI.
1 22 DR. BONACA: One thing I would like to just point i 23 out, I don't have a concern about having increased the 24 challenge to the containment. In terms of what you, Gary, 25 mentioned as your concept of defense-in-depth here, I agree I gg .MRJ RILEY & ASSOCIATES, LTD.
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50 1 with that. I am comfortable with that.
l
(g 2 The only thing that I see, however, in the
() 3 presentation, we are being boxed in between design basis 4 below 4 percent, severe accident above 10 percent. Life, it 5 is different. I mean I am convinced if we have a design 6 basis event and everything works as design basis says, we 7 will have no hydrogen probably there, but there will be 8 scenarios possibly, okay, in many different kind of LOCA 9 events we may get, and, hopefully, zero, that will give you 10 some hydrogen generation somewhere in the range of 4, 5, 6, 11 7 percent and I think that the recombiner could be useful 12 because all the curves you showed us didn't all the benefit 13 of the recombiner. If you use those, you will be tracking 14 this curve down, you know, in those cases.
15 So I mean I agree that there is no increased
(}
16 challenge to the containment and I am comfortable with that.
17 However, we are removing equipment that could be potentially 1
18 useful, and I think that is a realization that -- at least I '
19 would like to hear somebody telling me that is not true and 20 I will be glad to agree.
21 MR. HOLAHAN: No, I think we agree with you, and 22 whst I would characterize as the recombiners being equipment l 23 that is not essential, but might be useful in some cases.
24 And what we did was we struggled with a place to put such a 25 category of equipment. I think we are satisfied with the ANN RILEY & ASSOCIATES, LTD.
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g 51 1 idea that the severe accident management guidelines and a 2 voluntary commitment on the part of the utility to maintain l
3 that equipment is a reasonable way of dealing with equipment l 11 that is not essential but could be useful in some cases. So 5 it is a kind of gentle middle ground for treating this sort 6 of equipment.
7 DR. SEALE: And in the subcommittee meeting, the 8 concern was that, while this may be a no-brainer from a risk l'
9 point of view, that there was a serious issue of precedent 10 as to whether or not you might construe what you did in this 11 case as a basis for dropping useful equipment that had 12 previously been subsumed into a commitment for an issue that 13 was judged to be safety significant but no longer had that ]
14 status, and I think you probably addressed that issue.
15 MR. HOLAHAN: Yes.
16 MR. SCHERER: Can I make a comment?
17 DR. KRESS: Yes.
l 18 MR. SCHERER: One of the reasons we pursued this 19 application wasn't, as I said, the cost, but a belief that 20 this was a system that was not meaningful in terms of 21 improving the overall risk of the plant and it, therefore, 22 felt as an example of something that could be removed as a ,
23 regulatory requirement.
24 I was a licensed operator, and as an operator I 25 would love to have as many levers as I could if I was facing e- ANN RILEY & ASSOCIATES, LTD.
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52 1 a challenge. And as many systems as I could find a use for, i
T 2 I would want to see in that plant because it gives me more
[O 3 options as an operator, especially facing an unknown 4 situation. But at some point we have to look at the risk 5 benefits of the system, and adding systems upon systems upon 1 6 systems also adds to the complexity. If I had a severe 7 accident, I would be doing three simple things, I would be 8 buttoning up that containment, I would be trying to cool it 9 and I would be trying to clean it. And those are the things 10 I want the operators concentrating on at the time of the 11 accident.
12 There is a lot of useful information to be 13 gathered. 'There are a lot of useful tools to make sure they 14 have them and, as we indicated, we have no intention of v)
[ 15 ripping it out. But if it had been the converse, could we
, 16 have justified adding that piece of equipment now if it 17 didn't exist? Well, should we spend assets that we would 18 rather spend on risk significant issues to maintain this 19 piece of equipment? I think this is a good approach and the 20 test isn't the risk significance or the sophistication of 21 our risk approach here but a test in our mind of whether the 22 Commission, as the Chairman said, is able to let go of 23 something if it is shown to be of very low risk 24- significance.
25 DR. BONACA: I appreciate your comment, and I g
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l l
53 i 1 agree with you. I am only pointing out that there is some And the reason why I raised it also during the O
2 issue there.
l l
3 subcommittee meeting, I pointed out, you know, I have a l 4 concern in general about piecemeal removal of equipment, 5 because you already told us that you will come back and 6 propose to remove PASS from your emergency action level.
7 Now, at the time you also were planning to remove 8 the hydrogen monitoring system. See, that is the point I am 9 trying to make, is that I totally agree that some of this 10 equipment shouldn't be there and is not needed, but there 11 should be a comprehensive strategy to deal -- not boxed in 12 design basis, severe accidents, but simply looking at 13 possible scenarios, to look at what you have got and 14 determine and decide what you want to keep and what you want
( 15 to propose to eliminate.
) And there shouldn't be boxing of, 16 you know, just -- you suggest hydrogen, and this is severe 17 accidents and this is -- you know. That would be useful, I 18 think.
19 MR. SCHERER: We should not have started on a 20 piecemeal approach, we agree, and that is why we backed off 21 and took it as a holistic approach and have resolved that 22 issue.
23 DR. KRESS: I think we had better move on to the 24 staff's presentation. We still have to get through the full 25 agenda. So I will turn it over to you, Gary or Mike -- is f' ANN RILEY & ASSOCIATES, LTD.
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54 1 it Mike?
('] 2 MR. SNODDERLY: Good morning, my name is Mike
\_J '
3 Snodderly. I am with the Safety Assessment Branch of the 4 NRR and I have been assigned the task or reviewing this 5 exemption request. And I guess what I want to discuss today 6 is how I approached this review, and basically it was to 7 start off by looking at how did we, the staff, model 8 hydrogen combustion in NUREG-1150, and then to try to 9 determine what value, if any, do the hydrogen recombiners 10 have. And to do that, I requested and received assistance 11 from the Office of Research and they helped us do some 12 analysis and we are going to present those results today, l 13 too.
14 The first thing I'd like to try to do is talk
() 15 about different hydrogen source terms, and the first one I'd 16 like to talk about is the source term in 50.44. And Dana 17 alluded to it earlier.
18 It basically says that you need to address three 19 things: Zirc metal-water reaction, radiolysis, and 20 corrosion. And 50.44 talks about dealing with an amount of 21 hydrogen five times greater than what you would calculate in 22 50.46(b). And I'll call -- what I'll call the true -- what 23 I'll say, let's consider the design basis LOCA. And that 24 says that you won't exceed 1 percent metal-water reaction in 25 accordance with 50.46(b). The amount of solid fission
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55 1 products that you would expect from that type of an accident
(~'T would be much less than .1 percent. So radiolysis isn't a V 3 concern from the design-basis LOCA.
4 And the corrosion rate, of course, you wouldn't 5 expect much corrosion. 50.44 said we want you to address 6 five times that amount. We want you to look at 1 percent of 7 the solid fission products. And 1 percent of the solid 8 fission products corresponds exactly with the amount of 9 solid fission products that you needed to consider from a 10 TID 14844 type of source term which I would consider and I l l
11 believe the committee does too more of a severe accident or l 12 beyond design basis accident.
13 So the point I'd like to try to make here is that 14 recombiners are needed to address this type of accident.
() 15 16 DR. KRESS: In these source terms, the iodine was not considered a solid fission product?
17 MR. SNODDERLY: No , sir. It is considered, but 18 not as a -- well, it's part of the solid fission products.
19 It's considered -- you also need to consider iodine. But 20 that's not what I'm --
21 DR. POWERS: I guess I don't really quite 22 understand the technology here. I get radiolysis of water 23 to produce hydrogen from radioactive material distributed or 24 dissolved in the water. I get hydrogen also from the 25 gaseous fission products radiolytically decomposing steam in rs ANN RILEY & ASSOCIATES, LTD.
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56 1 the atmosphere.
g 2 MR. SNODDERLY: Okay, a
l 3 DR. POWERS: Why does it make any difference?
4 MR. SNODDERLY: The only -- I'm just --
5 DR. POWERS: You're just repeating what's in the 6 particulars, the cited. documents, but I just wondered why --
l 7 MR. SNODDERLY: Yes. I'm trying to do more than 8 that.
9 DR. POWERS: G values are about the same, I mean, 10' roughly.
11 MR. SNODDERLY: Yes. The main point I was trying 12 to make here, what I was -- I think part of the thing I've 13 been struggling with and that I've had difficulty 14 communicating to the Committee and to others is that what 15 amount of hydrogen do we really expect from a true design 16 basis LOCA? What were we asked to design for in 50.44 which 17 l we're now saying is this kind of in-between accidents, no* 1 l
18 really severe accidents, not really a design basis accident, l
19 somewhere in between which says that you need recombiners, 20 and then where is really the risk from hydrogen combustion.
21 And the risk from hydrogen combustion I would argue would be 22 this type of a source -- this type of a hydrogen source 23 term, like a TID 14844 source term or a NUREG-1465 Early 24 In-vessel or Late In-vessel.
25 So what I want to do in this presentation is to ANN RILEY & ASSOCIATES, LTD.
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57 1 talk about how NUREG-1150 looks at the risk from these types 2 of accidents, and we're going to look at that, and then 3 we're going to say what value are hydrogen recombiners, and 4 really the hydrogen recombiners are only of value in dealing 5 with mainly radiolysis. They're overwhelmed by this source 6 term, and corrosion is about a 10-percent contributor to the 7 overall hydrogen source term.
8 So it's something that yes, the recombiners would 9 help with, but what you're really concerned about is 10 radiolysis. So the accident that we're going to look at or 11 that we analyzed was to say okay, the hydrogen recombiners 12 can't do anything about that initial burn, okay, but you're 13 going to have a lot of radiolytic decomposition in the sump 14 and hydrogen created from that. How much is that hydrogen?
15 Because I don't think we've done a good' job of answering
(
16 that, and is that of -- how much risk is associated with 17' that, and what's the concern with that.
18 So all I wanted to try to do with this slide was 19 to just try and show the Committee, you know, just to give 20 some order of magnitude of the source terms and what we're 21 going to look at, because what the PRA or NUREG-1150 finds 22 is that the risk from these source terms doesn't even !
23 warrant really modeling in the -- for early containment 24 failure or prior to vessel breach, it's not a threat to 25 containment and was not modeled, and in late containment f ANN RILEY & ASSOCIATES, LTD.
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58 l 1 failure it was seen as a very, very small contributor. So 2 once we accept'that modeling or that level -- once we accept l 3 .that modeling, then these conclusions fall out that igniters 4 were not needed for large drys, and I think a subsequent 5 fallout is that the recombiners are not a risk-significant 6 system.
7 So what I did was I went to NUREG-1150 to see how 8 hydrogen was modeled at the Zion plant, which was the large 9 dry that was looked at, which would be equivalent to San 10 Onofre. And basically containment cailure was looked at in 11 four categories: early containment failure, which as I said
.12 is prior to vessel breach; late containment failure, which 13 is after vessel breach; no containment failure; and bypass.
14 And basically about 73 percent was no containment failure,
)_ 15 24 percent was late containment failure, about 1-1/2 percent 16 is.early containment failure, and the rest was bypass.
17 Now for early containment failure the containment 18' failure was composed of in-vessel steam explosion, 19 overpressurization, which includes high-pressure melt 20 ejection, and containment isolation failure.
21 The expert elicitation showed that or had 22 concluded -- in earlier drafts they modeled hydrogen but 23 found that the contribution to failure was so small that it 24 was not modeled in the final.
25 It was modeled for late containment failure, and i
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l 59
! 1 what they found was 99.5 percent of the late containment f" 2 failure came from basemat meltthrough and only .5 percent Q} 3 comes from hydrogen.
j 4 So you can see that hydrogen combustion was not
)
i 5 seen as a big threat or risk-significant from 1150. !
6 DR. WALLIS: What happens in those .5 percent i
7 cases? What do you mean by containment failure due to l 8 hydrogen ignition in those cases?
9 MR. SNODDERLY: Meaning that hydrogen combustion 10 would result in containment failure due to hydrogen in 11 containment due to the zirc metal-water reaction and 12 additional hydrogen from core concrete interaction.
1 13 DR. WALLIS: Containment failure, I mean, what 14 happens?-
15 MR. HOLAHAN: I think we're talking about the kind
(}
16 of case that San Onofre was talking about, overpressure 17 rupture of part of the containment.
18 DR. WALLIS: It's a big hole?
19 DR. POWERS: I think NUREG-1150 used a specific 20 definition, and it was 10 times the design basis leak rate.
21 DR. WALLIS: So essentially you've lost the
! 22 containment then?
23 MR. SNODDERLY: Yes.
24 DR. POWERS: Well --
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60 1 characterized as a large leak rather than catastrophic 2 failure, v 3- DR. T?OWERS: Well, one containment volume per day j 4 .I think is what they used as a definition, so it has some 5 ramifications in that it's not lost. But for the purposes i 6 of this discussion I'think it's satisfactory to assume that 7 you're getting very little mitigation from the containment.
8 DR. KRESS: Whereas you would get some mitigation 9 in the 99.5 percent basemat meltthrough.
10 DR. POWERS: I think it's fair to say that we 11 don't understand exactly what the release characteristics of 12 a basemat meltthrough are, except that they surely must be 13 much less than a badly leaking containment.
14 DR. KRESS: Yes. So comparing the .5 and the 99.5
() 15 16 is really'not a real good comparison.
DR. POWERS: Well, I think what it tells you is 17 that in a large, dry containment hydrogen combustion 18 failures are not the dominant mechanism of containment 19 failure.
20 DR. WALLIS: Well, I guess I'm asking because I 21 thought we'd just heard the hydrogen ignition does not fail 22 the containment. Now you're telling us it can.
23 MR. SNODDERLY: Let's put some risk numbers with 24 that, then. So you're at -- excuse me.
25 DR. KRESS: You wouldn't have any LERF at all.
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61 1 DR. WALLIS: lt may not be relevant The message I got from the previous presentation was hydrogen ignition is 2
3 not a problem.
4 MR. SNODDERLY: It would be very, very small.
5 DR. WALLIS: It can't fail the containment.
6 MR. SNODDERLY: That .5 percent, Graham, would be 7 something on the' order of 10 to the minus 8th.
8 DR. WALLIS: I don't know what you mean, because 9 you don't say how many of the hydrogen ignitions resulted in 10 containment failure.
.11 DR. KRESS: You can always -- you can postulate an 12 accident.
13 DR. WALLIS: You are talking about a different 14 world. I mean they essentially were talking in a
[~}
\J 15 deterministic world. And I think the message was hydrogen 16 ignition doesn't challenge the containment, the containment
- 17. can take it.
18 MR. SNODDERLY: Right.
19 DR. WALLIS: Now put something up here which 20 suggests that hydrogen ignition does fail the containment.
21 I am just trying to reconcile the two statements.
22 MR. HOLAHAN: Dr. Wallis, I don't think they are 23 so inconsistent. I think the San Onofre presentation said, 24 under, you know, rare circumstances you would show that the 25' pressure exceeded the failure pressure of containment, but ANN RILEY & ASSOCIATES, LTD.
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i 62 1 they had to search for rare cases. And I think this 2 analysis is a similar conclusion.
3 MR. SNODDERLY: This would be -- I would argue 4 that 10 to the minus 8th number would be in that 5 percent 1
5- of that 95 -- outside the 95 percent confidence limit. I l
t 6 mean I think the two are in agreement, It is a very -- it 7 is a negligible contributor to risk.
8 DR. KRESS: You will fail containment under some-9 rare circumstances without hydrogen there. The contribution 10 to the LERF due to hydrogen is very small is the point. You 11 are going to have a LERF anyway.
12 DR. WALLIS: I don't know, I am sort of puzzled.
13 The whole -- the previous presentation made no reference to 14 risk calculations whatsoever.
/ 15 MR. SNODDERLY: Yes.
16 DR. WALLIS: But you did some, 17 MR. SNODDERLY: I am just saying the staff in 18 NUREG-1150 looked by hydrogen combustion as -- they did not 19 -- I guess what I am saying, although the modeling is not 20 exactly the same and they did not find any failures, we 21 found a very, very small fraction and that I would not 22 characterize that as rising to the level of something that 23 needed to be looked at.
24 DR. WALLIS: So they didn't make a real risk 25 analysis, they did some qualitative stuff. You did some f-s ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
63 1 real calculations?
l "g 2 DR. KRESS: Now, these are going back to some real l..
3 calculations?
I L 4 DR. W.LLIS: 'Or somebody made some real l 5 calculations.
6 DR. KRESS: Yeah, these are real calculations that 7 exist'already and there are risks.
8 DR. POWERS: The question, of course, comes as 9 these are.for a containment over a Westinghouse reactor of a 10 particular design that does not have the same pressure 11 capabilities of the combustion engineering containment, or 1
12 the containment around the combustion engineering plants on 1
13- the coast of California. The relevance is a bit missing, 14 but interesting nonetheless.
15 DR. KRESS: Yes.
(
16 DR. WALLIS: I am tempted to say this doesn't 17 matter, but I am not quite sure why it is being presented.
18 I am t!.ging to beconcile.
19 DR. KRESS: Well, it is illustrates for large dry
- 2 0 - containments that the possibility of having much 21 contribution from hydrogen to a LERF is pretty small.
22- MR. SNODDERLY: As a reviewer, I would have to-23 say, did we find any risk significant sequences from 24 hydrogen combustion-that I thought that we should look at or l 25 have San Onofre look at, from the standpoint of would the ANN RILEY & ASSOCIATES, LTD.
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64 1 recombiners impact or have an effect on those sequences?
2 And what I am trying to say is, from 1150, I didn't see
- 3. 'that. I did see that they did not model late containment 4 failure, meaning after vessel breach, in their PRA. From 5 these numbers, it would not make me say, ACRS, or to my 6 management, I think they need to go back and look at this, 7 because it is such a small contributor. That is what I 8 think --'that is what I did as a reviewer, Graham. I didn't 9 see this as rising to the level to say --
10 DR. POWERS: I know I am going to jump ahead in 11 your viewgraphs, but maybe it is time to bring it up.
12 MR. SNODDERLY: Yes. Thank you.
13 DR. POWERS: Suppose -- I know this cannot happen 14 at the San Onofre unit, but suppose that there were some 15 sort of an event, a perturbation, a change of mode and 16 damaged some equipment, otherwise did not damage the core 17 greatly.and whatnot, put a little steam into the containment 18 and whatnot. The NRC sent out an augmented inspection team.
19 as to the plant, A confirmatory letter shut the plants down 20 for a year. And we have for then outrageous circumstances, 21 a buildup of hydrogen taking place in the containment. The 22 hydrogen recombiners could be used to eliminate that 23 hydrogen?
24 MR. SNODDERLY: Yes, they could.
25 DR. POWERS: And without them, what would we have?
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65 1 MR. SNODDERLY: What we would have, I believe is tg 2 circumstances where they would be needed, but that there V 3 would be a great deal of time, I would estimate on the order 4 of 7 to 10 days, before it would build up to the lower-5 flammability limit. I think in that time, we could come up 6 with some type of a contingency action, either getting a I 7 recombiner from some off-site and brought onto the site and 8 could be used.
9 DR. WALLIS: But you know, this came up in the 10 subcommittee meeting, it seems to be very speculative that 11 someone is going to find something in a month, which they i 12 then move to the site and hitch it up and it does somethinj ,
l 13 --.unless it is already being planned for. So, assuming it l
14 is going to be found, somehow appear within a month. I
~
)
() 15 16 MR. SNODDERLY: Well, there are a number of utilities that already share -- 5044 allows you to share 17 recombiners between sites.
18 DR. WALLIS: If someone has actually, yes, has 19 researched it and said, yes, there exist these things and, 20 yes, they can arrive within two weeks, and, yes, they will 21- work, that is fine. But if it based on the sort of'an 22 assumption they might be available, that doesn't --
23' MR. SNODDERLY: And I think if we were talking 24 about reaching the lower flammability limit in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, Dr.
25 Wallis, I would agree with you that we would need more g ANN RILEY & ASSOCIATES, LTD.
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66 1- pre-planning ahead of time. But I think when we look at the
N 2 timeframes that we are talking about of in the 7 to 10
-(d 3 range, I think that that is -- it is justified to have that '
4 kind of --
5 DR. POWERS: I kind of think in the 7 to 10 day 6 range, but we are not talking about that. We are talking ;
i 7 about months for my scenario to approach 2 or 3 percent of 1 8 . hydrogen in there. You do run the. risk of headlines, but 9 regulation by headlines is something that I am not willing 10 to do here. But, yeah,'they can take of these small sources 11 of radiolytic and corrosion based hydrogen in ways that are 1 12 different than venting, which, quite frankly, in my scenario 13 that I posed to you, if you didn't vent the thing, rather 14 than hooking up some jerry-rigged thing, I think you are out l l
15 of your mind.
{
16 DR ., KRESS: .Well, they are still going to have the 17 recombiners in there they'said.
18 DR. POWERS: Well, yeah, but maybe, but I still 19 think the appropriate thing in.my particular scenario is to 20 vent it.
21 DR. KRESS: Vent it. I think you are probably
.22 right, through the filter system. l 23' DR.. POWERS: Go ahead, please.
24 MR. SNODDERLY: -Sure. So after looking at I I
25 NUREG-1150, the other thing I wanted -- I did some value of l
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67 1 the recombiners to address radiolysis from a severe 2 accident. So the scenario I postulate is that you had the zirc metal-water reaction occurring over a two-hour time
~
3 4 period. It overwhelms the recombiners, you have a burn 5 inside containment. The containment survives but now you 6 have a slow buildup of hydrogen. So what I did, working 7 with the Office of Research, we went and used the COGAP 8 code, which is what we used to model the current design 9 basis hydrogen source term to come up with the type of 10 curves -- to confirm the curves that San Onofre showed 11 earlier.
12 Basically, what we did was we tried to go in and 13 take out the conservatism. We zerced out the metal-water 14 reaction contribution and we tried to -- as I shared 15 earlier, I looked at NUREG-1465, looked at the amount of
(
16 solid fission products and I estimated that to be around 8 17 percent, so I increased from 1 percent to 8 percent the 18 solid fission productions in the sump. We modeled 75 19 percent of the iodine-released to the sump and we looked at 20 that radiolytic source term with a G value of .5 and then 21 another run with a G value of .4. The theoretical maximum 22 is .44 for pure water.
23 And when we did those runs, we found that it was 7 24 percent when you used a G value of .5 and 5 percent when you 25 used a G value of .4.
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68 1 DR. POWERS: When you say a theoretical maximum on g~ 2 the G value.of hydrogen, what theory?
\
3 MR. SNODDERLY: I was going by a paper done by 4 Parczewski and Benaroya that was presented and looking at 5 hydrogen source terms. I can give you the reference, Dr.
6 Powers.
7 DR .. POWERS: Even the vintage would be enough.
8 MR. SNODDERLY: I'm sorry.
9 DR. POWERS: The vintage.
10 MR. SNODDERLY: 1984, generation of hydrogen and 11 oxygen by radiolytic decomposition of water in some BWRs, 12 Parczewski and Benaroya.
13 DR. POWERS: There's been just an excellent piece 14 of work coming out of Canada that looked at all of these l\ 15 data, did some additional data, and came up with the g O
16 values for low LET and high LET radiation as a function of 17 temperature and pressure by Elliot, 1993.
18 MR. SNODDERLY: Thank you.
19 DR. WALLIS: Well, is this okay, 5 to 7 percent?
l 20 What do you learn from that? '
21 MR. SNODDERLY: I think that what we learned from 22 that is that yes, the recombiners would prevent that 23 subsequent burn, but that that burn would not -- that level 24 would not be reached for 30 days -- the lower flammability 25 limit of 4 percent will not be exceeded for 11 days, and in ANN RILEY & ASSOCIATES, LTD.
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69 1 that time contingencies could be made to either bring a
_(~ 2 recombiner from offsite onsite or, if worse comes -- or h- 3 venting, as Dr. Powers mentioned, or just to let it burn.
4 That'that burn would not be a threat to containment.
5 DR. WALLIS: Because? Because the 7 percent is 6 too low.to --
7 MR. SNODDERLY: Right. The pressurization I
8 associated with 7 percent --
1 9 DR. POWERS: When you say it's not a threat to 10 containment, I mean, that's a strength argument, but busting
- 11 something in the containment can have impacts on other 12 things. What kinds of other things do you worry about in 13 containment?
14 MR. SNODDERLY: Equipment survivability.
15 DR. POWERS: That's right. I'm thinking of the
{
- 16 TMI telephone --
17 MR. SNODDERLY: Right.
418 DR. POWERS: Substantially scorched on one side.
19 MR. SNODDERLY: As a result of the TMI event 20 there's been a lot of work that was done at the Nevada Test 21 . Site and at Sandia, SCETCH facility, and the basic 22 conclusion to determine if something needed to be done from 23 .an equipment survivability standpoint, the conclusion was 24 that the equipment most likely would survive up to a single 25 burn of a 75-percent metal-water reaction, 11-1/2 percent.
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70 1 There was - .when you talk about multiple burns in a single
/N 2 compartment, there was more of a concern with failure, but 3 overall that conclusion is what I think --
4- DR. POWERS: Not much heat load, is what you're 5 saying.
6 MR. SNODDERLY: Right. And that was considered.
? So with those two data points I believe I came to 8 the same conclusion that San Onofre did, and so then I 9 think -- I don't want to spend a lot of time on this, 10 because I think we're in agreement with San Onofre now about 11 the'importance or the need to -- or the part that the 12 recombiners would play within the Severe Accident Management 13 Guidelines, and the fact that they don't intend to rip the 14 recombiners out at this time, and that if they did, they
/
t 15 would notify the staff I think gives us a good assurance
(
16 that because the plant -- because the recombiners exist in 17 the plant that they would be part of the severe accident 18 management guidelines as directed by NEI 9104, which really 19 provides the guidance on how to develop a plant's severe-20 accident management guidelines.
H 21 DR. POWERS: The previous speaker brought up I 22 thought an interesting philosophical discussion. He says if 23 I've got a problem in this plant, I'm out to do two L 24 things -- three things I guess he said. Shut it down, cool l-25 it, clean it. And I want my operators to focus on that.
l l~
l g~ e ANN RILEY & ASSOCIATES, LTD.
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71 1 You think about those issues that, you know, if
(~N) 2 I've got lots of levers available to the operators, I'm just G'
3 creating more confusion, more complexity in the system, when '
4 in fact all I want him to do is shut it down and cool it and 5 clean it. I mean, it's nice that they're going to leave 6 these things in here and notify the staff if they take them 7 out. On the other hand, maybe there is a big advantage in l
8 human performance space to take them out. I 9 MR. SNODDERLY: Yes. And I agree with you, Dr.
10 Powers, and I think that in the short time frame the 11 procedures that the operators are going to be concentrating 12 on in their emergency operating procedures which the 13 recombiners are going to be pulled out of and the hydrogen 14 monitoring or the requirement to get it quickly aligned 15
( ))
is -- we've recently granted a relaxation in that area.
16 We briefed the Committee on -- remember the 17 hydrogen monitoring request from 30 minutes to -- so to 18 support your point, yes, those things should be taken out of 19 those emergency operating procedures and put into Severe 20 Accident Management Guidelines, which are going to be used 21 more by the technical support center and those folks, the 22 decision makers. So we're taking it out of the operators' 23 hands and not burdening him but putting the technical 24 support center, which I think is more appropriate for those 25 folks to then support the operators.
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72
'l DR. POWERS: Yes.
/"% 2 MR. SNODDERLY: That's really all -- I wanted to b 3 just let the Committee know what the staff was doing, what 4 our perspective was from 1150 and some supporting analysis 5 we'had done.
6 The remaining slides it just talked about the hydrogen monitoring which it appears that San Onofre has 8 reconsidered and it's going to come in with PASS requests 9~ which you were briefed on I think within the last two weeks, 10 and we would of course expect that submittal to be 11 consistent with the position that was taken and in support l
12 of your -- and consistent with your letter, which we i 13 resolved.
14 If there aren't any questions or if there are any
() 15 16 questions --
DR. WALLIS: I guess I was looking for a more what 17 I'd say is a crisper evaluation where you'd say in came this 18 request and then we applied certain procedures and criteria I 19 philosophies, principles, whatever,.and on the basis of 20 those we checked that certain claims by the applicant were 21 okay.
22 It seems a much more sort of discursive, ad hoc 23 . presentation that you made.
24 MR. SNODDERLY: Well, let me see if I can allay l 25 your concerns, Dr. Wallis If you go to page 6, basically 1
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73 1 .the basis for the exemption request is going to be in 2 accordance with 50.12, and the criteria for exemptions, and 3 I guess -- I'm sorry, wrong slide.
4 DR. POWERS: Slide 5.
5 MR. SNODDERLY: I can go from memorization --
6 Slide 5, 50.12, and what 50.12 -- thank you, Dr. Powers --
7 on Slide 5, application of the regulation in a particular 8 circumstance would not serve the underlying purpose of the 9 rule or is not necessary to achieve the underlying purpose 10 of the rule. And what I would argue is that the purpose of 11- the rule, the underlying purpose, is to show that an 12 uncontrolled hydrogen-oxygen recombination would not take 13 place or that the plant could withstand the consequences of-14 uncontrolled hydrogen-oxygen recombination without loss of
() 15 16 safety function.
And I think what I've done in my review is 17 confirmed that the plant could withstand the consequences of 18 an uncontrolled hydrogen-oxygen recombination without loss 19 of' safety function as demonstrated or as modeled in 20 NUREG-1150 as supported by the San Onofre's IPE and the 21 additional analyses that we did.
22 Now if that's not the case, then I don't think we 23 have a basis for an exemption, but I think that is the case, 24 and that's what I would argue, yes, the basis for the 25 exemption.
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74 1 DR. WALLIS: I'm glad you got to Slide 5, because 2 you made a bigger point of it, and I think it was 3 appropriate at the Subcommittee, what was the basis for your 4 decision. And then'today we seemed to get a bit away from 5 that to more fringe areas.
6 MR. SNODDERLY: Well, thank you. I forgot about 7 this slide. I'm trying to -- better make sure I --
8 DR. KRESS: If there are no more questions then, 9
I'd like to thank Southern California Edison and the staff 10 for their presentations, and I'll turn the floor back to 11 you, Mr. Chairman.
12' DR. POWERS: Thank you, Tom.
13 I guess I still come back to the idea that this 14 was a test case to see if we could make use of 1.174 to get 15 rid of something, and I guess I turned to Gary and said was 16 it a successful test case or just kind of a test case?
17 MR. HOLAHAN: Well, like a lot of test cases, it 18 probably has some pluses and minuses. I think a lot of 19 people would say it's probably taken us too long to come to 20 a conclusion. I think the conclusion's a very reasonable 21 one. I think like a lot of these cases it's going to force 22 us to deal with marginal issues.
23 In this case in a sense we are lucky to have 24 accident management guidelines as a place to put issues 25 which I think otherwise we wouldn't be comfortaole with
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75 1 walking away from completely. If you remember, in the South
(~ 2 Texas graded QA issue in fact the licensee created sort of a V} 3 middle territory of -- they didn't put everything as very 4 important or unimportant, they created a middle territory 5 where they targeted some QA activities. And to that extent 6 I think it's a useful exercise, because in the future we're 7 going to have to, you know, not only use risk information to 8 decide what's really important, we're going to have to deal 9 with other values and some of these middle grounds. And i
10 we're just going to have to, you know, find ways to deal 11 with these issues.
12 DR. POWERS: I think what you're saying is that 13 cur PRA tools are simply not adequate for addressing some of 14 these what you call marginal issues, and so you can't get a I")
kJ 15 cutting decision that way.
16 l MR. HOLAHAN: Sure. I agree.
])
17 DR. POWERS: And I think we will learn to regret a 18 tradition of finding halfway measures.
19 MR. HOLAHAN: I don't feel that way. I'm not sure 20 I would describe the kind of issues here as halfway 21 measures. In fact, I think one of the reasons we have a 22- risk-informed approach rather than a risk-based is that we 23 do recognize there are other values besides core damage 24 frequency and large early release, and we're trying to find 25 a way to deal with some of those values.
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76 1 DR. POWERS: As are we.
2 With that, I'll take a recess until 20'of the
[
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
l 4 [ Recess.]
5 DR. POWERS: We'll come back into session. We'll 6 now turn to the status of the pilot application of the 7 revised inspection and assessment program, and our cognizant 8 member for this is usually John Barton, but we have pressed 9 into service Dr. Shack, and so I will turn it over to you.
10 DR. SHACK: Okay. I guess since the last time we i
11 have looked at this program a few things have happened. The '
12 Watch List has been eliminated. The recognition of superior 13 performance is gone.
14 We will be hearing today about some items from
() 15 16 SECY-99-007A, which presumably will give us some more information on the pilot program, which has been one of the 17 focuses of where this program is going, and I believe we 18 will start off with Mr. Madison, who will begin the 19 presentation for the Staff.
20 MR. MADISON: Good morning. I am Alan Madison. I 21 have to my left Morris Branch, from NRR also, and we also 22 have Frank Gillespie, Phil Dean, Michael Johnson, and Gareth 23 Parry available if there are specific questions.
24 I will apologize in advance not necessarily having 25 a slick presentation ready for you. With yesterday's extra O ANN RILEY & ASSOCIATES, LTD.
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77
- 1. day off, our preparation time got --
2 (Laughter.)
)
3 MR. MADISON: -- got shrunk to this morning.
4 The reason we came, wanted to come talk to you is 5 to give you the Staff's update. It's been some time since 6 we have been to talk to the ACRS about the improvement l
7 process, talk about where we are today, and we are ready to j 8 start the pilot, as Dr. Shack mentioned, also talk about the 9 significance determination process and the feasibility 10 review, which I know there was a great deal of interest at i 11 the ACRS, and talk a little bit about what is yet to be l
l 12 done.
l 13 I am going to address the first and last item 14 briefly, and hopefully leave sufficient time for Morris to
( 15 go'in depth or somewhat in depth in the significance 16 determination process, l 17 DR. POWERS: I hope that we have some opportunity l 18 to discuss how we interpret results of a pilot.
19 MR. MADISON: We had not prepared to talk about 20 that at this time, but I would be interested in your 21 comments.
22 DR. POWERS: Maybe just philosophically discuss 23 it. I mean my concern -- I look upon pilots as experiments l 24 and so when I think about experiments I think about 25 ' experimental error, representativeness, and making use of 1
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( l l
[ l
78 1 the results.
()
V 2 Perhaps you used the pilots to say are there any 3 problems with this, and you can come away and say 4 conclusively for this plant there are no problems or yes, 5 .there were problems. The question is how you extend it to 6 the larger range of plants and the larger safety philosophy 7 when you have done one plant for a very finite period of 8 time, which may not be indicative of the problems you will 9 have at other plants.
10 MR. MADISON: I am going to talk briefly about 11 some of that, Dr. Powers, but we can talk a little bit more, 12 as you wish. Next slide, please.
13 We have issued SECY-99-007A, and we briefed the 14 Commission on March 26th on this document, talked about some 15 of the changes that are additions to the process,.which 16' included adding a significance determination process, and 17 dealing with some questions in the enforcement arena.
18 The Performance Indicator Manual has been 19 redrafted and we are Draft Number 2, wnich looks like this.
20 We have done an awful lot of work in conjunction with NEI to 21 get this document ready at least for the pilot program.
22 There is still more work to be done on it. 1 23 There's some improvements that we'll be looking at during 24 .the pilot and. subsequent to the pilot, but it is ready to go !
i 25 to be published as a draft manual for pilot implementation.
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( 79 )
i 1 The baseline inspection procedures have been 2 written. We have gone through concurrence, not necessarily {
3 concurrence but a round of comments with all the regions and 4 some headquarters staff, and on May 20th this package, which 5 includes all the baseline inspection procedures was signed 6 out by Sam Collins and for comment. I don't know if the I
7 ACRS has' received a copy of this.
8 We also expect to put this package out for public 9 comment in a Federal Register notice.
I 10 We have done a significant amount of work in the 11 assessment process development and looking at changing the 12 action matrix, which we can talk about some of the details !
l 13 in that, if you wish. We have also developed our definition 14 of what we are calling unacceptable performance, which is I
() 15 16 the last column on the action matrix.
this package.
That's made part of 17 In the significance determination process arena, 18 'which Morris will go into more detail, we do have a process 19 now that we have tested several times, one by doing a 20 feasibility review, and I might mention that industry did 21 kind of a parallel feasibility review with the same data 22 that our folks were working with, and came out with 1
23 consistent results, so we have got kind of a double-check 24 there.
25 We do have some work yet to be done in this area.
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80 1 We are still working right now on fire protet d on, in the 2 fire protection arena, coming up. We have a process that is 3- in draft form. We are working with industry and others to 4 get that in better shape.
5 We are looking at the shutdown area, to add some 6 improvements to the STP process and in the containment area.
7 In the enforcement arena, I mentioned that 8 briefly, and I am not really prepared to discuss that today, 9 but we have issued a draft enforcement policy. We do have 10 an enforcement policy for the pilot program that ties very 11 closely to the significance determination program.
12 DR. POWERS: I guess you alluded to difficulties 13 that you encounter with respect to shutdown and operating l
14 states and I am going to be interested in how you do i
( 15 significance on things like emergency diesel generators when 16 you don't have that kind of risk information about shutdown l
17 states.
18 MR. MADISON: As I said, we are still working in 19 the shutdown area right now but what our direction would be 20 is to empanel, and I am going to go into this a little bit, 21 a group of SRAs and risk experts to help us in that arena 22 until we do develop a significance determination process 23 specifically focused on shutdown issues. ;
24 DR. POWERS: Now your SRAs, I mean, are acquainted 25 with the techniques for doing risk assessments during
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81 l 1 shutdown?
()
V 2 MR. MADISON: Our intent is we would make sure 3 that they are, the ones that we would use, yes, and .e would 4 be asking Gary Holahan and Rich Barrett to help us out in b that area. Next slide, please.
6 DR. POWERS: And Gary, I take it, is an expert in 7' shutdown rick assessment?
8 MR. MADISON: Gareth, you will have to help bail 9 me out on this one.
10 MR. PARRY: I think there are people in the PSA 11 Branch of NRR and DSSA that have studies shutdown and I 12 shutdown risk assessments quite a lot, particularly for 13 things like the shutdown rule, for example.
14 DR. POWERS: Okay.
() 15 MR. PARRY: Okay.
16 DR. POWERS: So we will have a knowledgeable cadre 17 of people working on this issue?
18 MR. PARRY: Yes. Also, I am sure you are aware, 19 that Research is developing a shutdown program, which you 20 have heard about a couple of weeks ago, I think.
21 DR. POWERS: No, we will hear about it in this 22 meeting --
23 MR. PARRY: Oh, okay.
24 DR. POWERS: -- and the substance of that is that 25 they don't yet have a program.
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I'.
82 l 1 MR. PARRY: Right. They are planning it.
\ 2 DR. POWERS:
l (d 3 And that they are relying on the literature survey to get some insights into what is and is
)
14 not feasible here, and I'll telegraph to you that there are 5 members of the committee that think that that is not a
~6 useful activity, in fact that we have to be much more 7 groundbreaking in this area and not -- that the existing 8 literature is not adequate to address the kinds of issues 9 that are going to be encountered in this kind of activity.
10 MR. PARRY: Okay.
11 MR. MADISON: Some of the other things --
12 DR. POWERS: I could be wrong too.
13 MR. MADISON: Some of the other things we have 14 accomplished to date -- we held three workshops so far to I 15 train staff, industry and the public, or at least make them 16 knowledgeable of the proposed processes in the pilot 17 program.
18 The first workshop was held in the Glen Ellen area 19 on April 12th, the week of April 12th, to train the pilot 20 program industry and NRC Staff primarily on the performance 21 indicators and how to report and how to analyze the 22 performance indicators.
23 The second workshop was a closed workshop with NRC 24 Staff and state personnel, state inspection personnel, to 25 train our folks on the inspection process, the baseline O ANN RILEY & ASSOCIATES, LTD.
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83 1 inspection procedures, how to plan inspections, assessment Q
v 2 of inspections and the enforcement policy. That was held 3 the week of April 26th in the Atlanta area or in Atlanta.
4 The third. workshop was just recently held the week 5 of May 17th near the Philadelphia Airport and that was a 6 large public conference. We had approximately 350 to 400 7 people present and we talked about the entire process and 8 directed primarily at the pilot program.
9 We plan a second inspection training workshop. We 10 were able to get over 120 inspection staff trained in the l
l 11 Atlanta workshop, but we found -- we feel that we need more l 12 inspectors trained to fully implement the pilot program, so l
13 we are going to go for an additional cadre in the week of 14 June 21sr and we will do that in the Region IV area, planned 15 in Irving,. Texas.
l 16 We have accomplished, we think, a lot of 17 communication activities. I say "we think" because you 18 never know with communications whether you fully 19 communicated or not,.and a lot of that is based upon the 1 20 feedback we get. We have gotten a lot of questions. We
'21 have responded to those questions. We continue to collect l 22 questions and respond to them. We have actually put some of 23 our frequency-asked questions on our internal website. We 24 are working towards building an external website and we will 25 put those frequently asked questions on that website.
l i
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84 1 We have held at least two briefings of various
(~'j 2 staff down to the inspector level and senior management
\_/
3 level at all four regions. We have also held briefings here 4 at headquarters for various inspections staff and review 5 staff.
6 We are also planning on doing public workshops at 7 each of the pilot facilities.
8 And in fact, I will be going out next week to do 9 the first one the evening of the 8th, in the Quad Cities
- 10 area.
11 As I said earlier, we'are ready to start the pilot 12 program. We have developed some ground rules, upfront "
13 ground rules which we have published and expect to maintain l 1
14 during the pilot program.
]
15 We have established some criteria in advance,
[)
\
16 actually guide a few criteria in advance. Some of them l 17 were, as I mentioned at the March 26th Commission briefing, 18 some of them are numerical or quantitative in nature, but a 19 lot of them are qualitative. Because of that, we have 20 established a couple of different things that we are looking 21 at during the pilot process, and this may address a little 22 bit of your concern, Dr. Powers, of how you assess the 23 success of a pilot program.
24 The qualitative ones, we felt uncomfortable with J 25 just the NRC staff saying, yes, we have been successful. So
("'
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85 1 we established what we are. calling the Pilot Plant 2 Evaluation Panel. It will be chaired by Frank Gillespie.
3 We have members of industry, in fact, one member from each 4 region that has a pilot plant. We have -- NEI is 5 represented on there with Steve Floyd. We have one member 6 from the NRC staff in each region. We also have a 7 representative from the State of Illinois and Dave Lochbaum 8 from UCS participating on the Pilot Evaluation Panel.
9 DR. POWERS: I guess one of the things that 10 continues to concern me a little bit about this whole thrust 11 is how the inspectors themselves are reacting to these 12 rather different activities that they are being called on.
13 Are they going to have some inpuc on the judgmente of 14 success and failure here?
() 15 16 MR. MADISON: The inspection staff has had input from the beginning.
17~ DR. POWERS: Yeah, I understand that.
18 MR. MADISON: Of course, you are aware that they 1
19 helped write the procedures. We made sure we incorporated-20 their comments during the writing of the procedures, during 21 the comment period of the procedures and during the l
! 22 development of the program. We have kind of made it open 23 season on the transition task force. We will collect any 24 comments received and work towards responding to them and l 25 incorporating them into the program.
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86 1 During the pilot program, we have established a 2 support group that includes a regional coordinator for each 3 region to collect and collate and ensure that the comments 4 are addressed during the pilot program. l 5 We also have, as I mentioned on the slide, an 6 oversight group that will be chaired by Bill Dean on a 7 biweekly basis, poll and actually solicit comment from the 8 pilot plant branch chiefs and inspectors to how the plant --
9 how the pilot program, how the program itself is being 10 implemented, how it is -- the problems that they are running 11 into, where improvements can be made. And we will consider 12 actually revising the process and the details of the process 13 during the pilot program, on a limited basis. We are going 14 to try to -- we want to minimize the editorial type
() 15 16 revisions.
pilot program.
We will kind of hold those to the end of the 17 But if there is something that is presenting an 18 implementation problem, we will make the change during the 19 pilot program.
20 We also have -- it is noted up here as an SDP, but 21 during the pilot program, Rich Barrett's branch, under Gary 22 Holahan, is establishing a -- what are you calling it?
23 MR. PARRY: It is an operational support group.
l 24 MR. MADISON: Operational support group that will 25 be reviewing-the significant findings. They will review all g ANN RILEY & ASSOCIATES, LTD.
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87 1 Phase 2s from the SDP and they will participate in any Phase
~
2 3s during the pilot program to ensure that we maintain --
3 have a consistent application of the process.
4 DR.'SEALE: During the presentations we had 5 earlier this year, a lot of us were very impressed, and I 6 think we said so in some of our letters, with the input that 7 this whole process had received from people from the regions 8 and from the inspection people. Since that time, other 9 things have happened. In particular, there has been a 10 reorganization of NRR and in that process a lot of us were 11 concerned with losing the independence and objectivity of 12 the old AEOD functions that were integrated into --
13 partially into NRR and partly into Research.
14 But another effect of that reorganization, at 15
())
least it appeared, was to take the relationship between the 16 inspection process and the staff people here who were i
17 working on this evaluation thing and sort of put them at the J 18 . poles of the NRR activities rather than shoulder to 19 shoulder, from an organizational point of view.
20 I hope that all of these things you have listed 21 here are an attempt to overcome the adverse effects of that 22 kind of long communication line within the linear aspects of 23 .an organization chart in getting this process done. And I 24 certainly will be sensitive to hearing about how well you 25 are continuing to carry out the kind of cooperative l ANN RILEY & ASSOCIATES, LTD.
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88 1 creativity that the early efforts in this revision of the
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2 inspection process showed. Hopefully, you can keep that up.
3 MR. MADISON: I echo that hope. That is 4 definitely one of the major objectives of a lot of the 5 processes that I have described, including one that I didn't 6 mention was the -- we have assigned owners of the inspection 7 procedures, and one of their functions is to solicit 8 comments and collect comments and make sure that they are l 9 incorporated, j 10 We have tried to make sure that the staff, the 11 inspection staff, feels fully engaged, fully involved in the l 12 process and that they are being listened to.
l i
13 One of the things we -- one of the nice things we '
14 got out of the Atlanta workshop was to see an actual change
() 15 in attitude from inspectors from the first day of the 1 16 workshop to the last day of the workshop. Once they had <
l l 17 seen the details and actually had a chance to talk about the 18 details, challenge them and talk to the people that wrote 19 them, there was a lot more acceptance. There was a lot more 1
20 of an attitude of, well, yeah, let's get on with it, let's 21 try it now.
22 And we are seeing that --
in fact, I got an e-mail 23 from a Region I inspector this morning that said the same 24 thing, you know, we are -- he provided a criticism, a 25 comment, but he said, don't get me wrong, you know, we are O ANN RILEY & ASSOCIATES, LTD.
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89 1 anxious to get going. We are ready to get started on it.
2 We just want to make sure you are still listening. And we 3 want to make sure they know that we are still listening.
'4 There is still a lot of work to be done. We are 5 not complete yet. Still that is why we are piloting. We 6 are piloting with draft procedures to let --
again, to let 7 folks know that we are still looking for comments. As I 8 mentioned, we are still -- we are considering sending out 9 and will send out a Federal Register notice with the 10 baseline procedures. I want to kind of highlight that a 11 little bit. This will be I think the first time the agency 12 has ever sent out for public comment its inspection 13 procedures, but we feel that is appropriate with this major 14 change that we are making with the process and the program.
() 15 The pilot program is going to run till the end of 16 the' year, so we have got a lot of work yet to do. We are 17 just beginning, we are in day three of the pilot program --
18 day four. It started April -- or May 30th.
19 We still, as I mentioned earlier, have some work 20 to do on the Significance Determination Process in the areas 21 of fire protection, shutdown, risk in the containment area.
22 Fire protection, we are getting pretty close. We have held 23 several public meetings. We have a' draft process, we are 24 working now at incorporating that process into the general 25 Significance Determination Process, or at least O ANN RILEY & ASSOCIATES, LTD.
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90 1 incorporating their thinking. Industry has had a chance to 2 look at it, comment, and_we are going to do a tabletop 3 exercise with industry to make sure we have the same 4 understanding of how the process should work.
5 We are looking at performance indicator changes 6 not just revisions to the draft, but possible additions in 7 the performance indicator area, either during or following 8 the pilot program, in the areas of shutdown, fire protection 9 and we need -- we think we need in the near future an 10 unreliability indicator, and we are working very hard to get 11 that.
12 We are getting assistance from the Office of 13 Research in those areas, and they may be talking about that 14 more later this afternoon.
() 15 I have training up here as a bullet. We feel that 16 we are accomplishing some training as we go. We probably 17 have over 200 -- about 50 percent of what we look at as the 18 inspection staff, somewhat trained, at least trained j 19 adequately to implement the pilot program. But we need to 20 train the rest of the staff. And we are developing right 21 now in conjunction with the Technical Training Center plans 22 to train the rest of the staff, to update the staff that has
- 23. received training already in the fall and winter time 1
24 periods, and we will try to accomplish that such that all 25 four regions will receive adequate attention, as well as O ANN RILEY & ASSOCIATES, LTD.
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91 1~ headquarters staff.
2 We are also looking at holding a public workshop b 3 in all four' regions, and we would do that in conjunction and 4 cooperation with NEI, to inform the public and be able to 5 respond directly to public questions as well as industry 6 questions. Ana I already mentioned that we are going out 7 and doing public meetings at each of the pilot facilities.
8 Members of the technical -- or the Transition Task Force 9 will also be going out to the pilot plants. Morris, Don 10 Hickman in the performance indicator area will avail 11 themselves at each of the pilot plants, to not just the NRC 12 staff but to the industry staff.
13 DR. SEALE: .Will you keep us informed as to the 14 location and time of those public workshops in the regions?
-)
( 15 16 that.
MR. MADISON: Certainly, I will make sure you get 17 One other thing that is not on the slide here, 18 that didn't appear on the slide, it was meant to be on the 19 slide -- it was talking about what I will call right now the 20 above the baseline inspection activities. What happens when 21 a performance indicator crosses the threshold? What happens 22 when an inspection finding crosses the threshold? What do 23 we respond with? <
24 We have just begun staffing to develop that. We 25 have a concept that would include both that focused ANN RILEY & ASSOCIATES, LTD.
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92 l
1 inspection to follow up, reactive inspections, a broad l r~
i 2 spectrum including incident investigations, AITs and other, 1 c
( 3 and also generic. What do you do with generic safety 4 issues, how do you continue to follow up on generic safety 5 issues?
l 6 As I mentioned, we have just begun to staff up {
7 developing that program and expect to have it in place prior 8 to full implementation.
l 9 That concludes my status and yet-to-do remarks.
10 If there aren't any questions, I am going to let Morris get 11 started on the Significance Determination Process.
12 MR. BRANCH: Good morning, I am Morris Branch of 13 NRR and I am currently assigned to the Transition Task 14 Force. I am the task lead for the Significance
(h 15 Determination Process that I will describe, and, also, I was O
16 the task lead for the feasibility review that we did in 17 February, that I will describe later.
18 I am here today to discuss these two tasks that 19 were key elements in the development of the new reactor 20 oversight process. And both of these areas are described in 23 SECY-99007A.
l 22 Before I begin, I would first like to say that 23 this effort involved a wide variety of agency assets. Our l
24 task group included members from Research, NRR, the Office 25 of Enforcement, the Technical Training Center, and all four l r" ANN RILEY & ASSOCIATES, LTD.
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s 93 1 regional offices and their members that are here today as 2 well.
3 My background is inspection. I was an NRC field 4 inspector for 16 years, I was a resident inspection and 5 senior resident. Since I have been in headquarters, I have 6 led several of the AE design reviews, and I brought the end 7 user perspective to the project.
l 8 I would now like to briefly describe our efforts 1
9 to date in developing the process to assign a risk I
10 characterization, which we refer to as the Significance I 11 Determination Process, to an inspection finding. This -- I 12 you didn't talk too much about'the process. Anyway, the 13 reason that we needed to apply a risk characterization or 14 significance to an inspection findings was so that the
() 15 inspection finding could be dovetailed with the performance 16 indicators during the assessment process. And we wanted to 17 develop a process that would give a significance scale that 18 was similar to that used in the PI thresholds.
19 The process is intended to be used by field 20 inspectors and their managers, and this presented a 21 challenge to our task group in that -- to try to make a 22 simple tool, but at the same time provide some fidelity to 23 the process. And for the most part, wed use the old 24 enforcement criteria as a basis for coloring the findings in 25' the non-reactor cornerstone area, and in the reactor
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(;
1 94 1 cornerstone areas, the process was developed using inputs l
()
\/
2 derived from other agency products.
l 3 We used Reg. Guide 1.174, NUREG-5499, which was an 4 AEOD study providing the likelihood of initiating events.
5 We also used NUREG-4674 and that describes the as-screening 6 rules we used the as-screening as part of our process. And 7 we used typical equipment and human performance reliability 8 ' values generally consistent with those obtained from PRA 9 models.
10 From this slide you can see that we have developed 11 several processes to address inspection findings in all the 12 cornerstone areas. Our guidance to the inspectors will be 13 contained in the NRC inspection manual and there will be 14 attachments to describe the many processes. And I will
() 15 16 briefly describe some of the non-reactor cornerstone areas.
As Alan mentioned, we still are working on the shutdown 17 Significance Determination. Process. Containment, currently 18 in our process we have the inspectors calling the risk 19 support group in headquarters for help and the SRAs in the 20 region. ind as Alan mentioned also, for the fire 21 . protection, we are still working on development.
22 DR. POWERS: This flow chart that you have here, 23 are you intending to walk through this?
24 MR. BRANCH: Yes, I was going to show you that 25 basically what I was -- the purpose of this chart was to O ANN RILEY & ASSOCIATES, LTD.
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95
- 1 show that we do have different processes. If im id
/"s 2 ' radiation safety safeguards or emergency preparedness, we 3 are going to have an attachment appendix to the manual 4 chapter that will cover those. And we used a different 5 methodology, we didn't really use risk as well there, we 6 used more of a process flow barrier type. And, also, the 7 chart was to demonstrate that as you go through the process, 8 if the issue is of low risk significance, then we send it to 9 the' licensee and let them correct it through their 10 corrective action program. And also, after we go through 11 the significance determination, the output of all of these 12 processes is the input to the assessment and the enforcement 12 process, and that was the purpose of the slide.
'14 DR. POWERS: Here is the question that comes to my 15 mind. I started at the top on this and I said I have a
(
16 finding or an issue, and I have a question here. It says, 17 affects emergency preparedness, radiation safety or 18 safeguards. Now, those are the areas where you don't use 19 risk, you have some other criteria. And I said, now, can I l
20 imagine a finding or an issue that I wouldn't answer yes to !
1 21 that if I used my imagination a little bit? And I said, 22 even if it was a finding that I would subsequently answer j 23 the questions lower down on this, I come yes and it takes me i 24 out of the loop.
25 I mean there has to be some real constraint on me ANN RILEY & ASSOCIATES, LTD.
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96 1 there because I have this radiation safety term in there, f"" 2 And with a'little imagination I can say "affects radiation V) 3 safety, yes, it affects radiation safety." Any finding that 4 I come up with I can say, "Yes, it affects radiation 5 safety."
6 How do I avoid always going on the yes loop there?
7 MR. BRANCH: The purpose of the slide was just 8 really to show the different processes. It wasn't intended 9 to show any real logic to it. You don't have to go through 10 that gate first. I mean, we could have had this coming in 11 at all ends. It was just to show that there are different 12 processes that we'll have. We had to use a different method 13 !
to develop for the nonreactor cornerstones. That was the 1 14 purpose.
L15 DR. POWERS: Okay. So really the situation is
(
16 that in reality, and the way it would be actually i
17 implemented is that I would first check those things where I 18 could use risk, and if it didn't fall in those categories, 19 then I would go to the nonrisk ones or something like that?
20 MR. MADISON: Yes, that would be the right way to 21 do it.
22 MR. BRANCH: Okay. This process diagram doncribes 23 the SDP for the power reactor cornerstones. You can see 24 from the diagram the first step in the process is to clearly 25 identify the concern. That's this part up in here. You ANN RILEY & ASSOCIATES, LTD.
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97 j 1 have to -- doing the process development and doing our 2 feasibilicy review it became clear that the inspector's 3 concern and any assumptions has to be formulated prior to 4 using this tool. And this part of the process is similar to 5 performing an engineering calculation. You first state the 6 problem, the assumptions you're making, and then you can use 7 the process and expect repeatable results. This is an 8 assumption-driven process. I 9 The next step we refer to as phase 1, and that's ;
10 our screening process. And this screening will be j 11 accomplished by field inspectors. We believe that many l 12 items will be screened as nonrisk-significant in this step 13 and will be passed to the licensee for resolution through
- 14. their corrective action program.
p 15 Our process forces the inspector to make d 16 reasonable but conservative assumptions. Therefore, i i
17 inspectors will most likely pass more items than necessary 18 to the phase 2 review. But that's okay, because false 19 positives at the inspector level could be refined later 20 during the phase 2 review we'll describe later, and also the 21 phase 3 if it's necessary. l 22 After you go through the screening, and I'll go 23 into the screening process in a little more detail after I 24 . finish going through the logic here, but after the screening 25 you've determined that an item requires a phase 2 review, ANN RILEY & ASSOCIATES, LTD.
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i 98 1 the inspector has to ask what initiating events are impacted i
g 2 by the finding. There may be more than one scenario that 3 has to be reviewed. We have attempted to provide guidance 1
4 to allow a field inspector to conduct the phase 2 review. I 5 However, until the inspectors become more familiar with the 6 process, we anticipate additional risk analyst help will be 7 needed.
8 The next step in the phase 2 review involves !
j 9 determining the frequency of initiating events, and I'll go l 10 into the Table 1 and Table 2 after I finish going through ;
11 this process. You determine the frequency of the initiating 12 event and the duration of the gra'ded condition, and then you 13 determine the likelihood of the occurrence of the initiating 14 event while the degraded condition exists. And then you 15 consider the availability of mitigation equipment.
)
16 Mitigation of the risk-significance of an issue is 17 based on the equipment available to perform the high-level 18 safety functions: heat removal and inventory control, et i
19 cetera. The general rule of thumb is that each line of l
20 mitigation available that will describe in the Table 2 '
21 represents an order of 10 change for the better in delta 22 core damage frequency.
23 After you finish the phase 2 review, you will have 24 determined the final worst-case risk significance of an 25 issue. This determination is represented by a color scheme i
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l 99 l
j 1 similar to that used in the PI threshold values. l 2 We build into the process a phase 3 review if 3 needed. This review will be performed by risk analysts and 4 will allow refinement of the risk characterization and the i
5 significance of an issue prior to final action.
6 I'd now like to briefly describe the screening 7 process and the use of Table 1 and 2, and also, as Alan 8 mentioned, NEI worked through several examples of issues --
9 DR. APOSTOLAKIS: Before you go there, in phase 1 10 screening, in step 1.2 --
11 MR. BRANCH: Yes, sir.
12 DR. APOSTOLAKIS: Potential impact on risk means 13 CDF and LERF, I suppose, not risk itself, CDF, core damage 14 frequency.
15 MR. MADISON: Yes.
16 MR. BRANCH: Yes. l 17 DR. APOSTOLAKIS: Impact on risk. You mean 18- potential change in CDF and LERF for that plant? Is that 19 the impact we are looking for?
20 MR. PARRY: Yes, it is. I mean -- and we're using 21 the risk here and CDF and LERF as surrogates just like in 22 Reg Guide 1.174.
23 DR. APOSTOLAKIS: Now if I follow the approach for 24 setting thresholds described in SECY-99-007, taking the 95th 25 percentile, the plant-to-plant curve --
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l 100 1
1 MR. PARRY: We need to discuss that. That's --
7'N 2 DR. APOSTOLAKIS: Yes.
%,,] k 3 MR. PARRY: Not the right interpretation, I don't 4 think. l l
5 DR. APOSTOLAKIS: But let me just complete the 6 argument here.
7 MR. PARRY: Okay.
8 DR. APOSTOLAKIS: Then of course four or five 9 plants will be above the threshold the moment I select it.
1 10 So now I take one of those plants, but there is no impact on 11 risk, because that is already part of the PRA for that l 12 plant, right? So you will say the threshold tells me that 1
13 the unava 1 ability of this system is higher than the 14 threshol so I go and look for potential impact on risk, f
() 15 16 and that ,zero.
number.
Because that risk value came from that That number is already part of the PRA. And that's 17 the problem with using plant-to-plant curves to define these 18 things -- one of the problems.
19 DR. KRESS: I think you could interpret that 20 differently, George. i i 21 MR. PARRY: Yes.
1 22 DR. KRESS: You could say that the value of the l
23 performance indicator for that plant is a measure of whether 24 or not the system is matching the availability that you put 25 into your PRA number, reliability number. So that that is
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l l
101 1 an indicator telling you whether or not that was a good fg 2 number in the first place,.or whether you're matching it.
V 3 DR. APOSTOLAKIS: But that's not the use of the 4 thresholds right now. You are making it now plant-specific.
5 DR. KRESS: Yes. That would be --
6 DR. APOSTOLAKIS: That's what I've argued all 1
7 along.
8 DR. KRESS: Yes, it would be.
l 9 DR. APOSTOLAKIS: But if it's the way it is now as 10 described in the document without any oral interpretations,
( 11 automatically this plant is above the threshold, then I take 12 the unavailability and I go to --
l 13 DR. KRESS: I think most of those unavailabilities 14 are not plant-specific; they come out of a data base that's 15 industrywide.
16 DR. APOSf0LAKIS: No, but they have plant-specific 17 numbers.
18 MR. PARRY: This is -- the way that the setting of l
19 the thresholds was described in 99-007 doesn't give you the 20 full story. What the threshold was set on was data from all 21 the plants that we had in the data base, and it chose the 22 worst value of that indicator over the period of 23 observation, which I think was something like three years.
24 So in a sense you should interpret that graph as meaning 25 that over the period of observation that five or so of the ANN RILEY & ASSOCIATES, LTD.
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102 l 1 plants at one time or other exceeded the threshold, but it )
2 didn't'mean to say that they were stuck there, f
3- DR. APOSTOLAKIS: Oh.
I 4 MR. PARRY: It actually fluctuates over the years.
5 So it's a way of setting -- it's a way of trying to catch i 6 outlier behavior. Now if you remain at that level for a i 7 long time, then this. calls for concern. But remember also 8 that these indicators are only a license to dig a little i
9 deeper. They're not necessarily saying that the plant is 10 unsafe at that point.
11 DR. APOSTOLAKIS: Sure, but unless you make the 12 indicators plant-specific, you will have logical problems 13 all the time. Here is one.
14 MR. PARRY: You will, in the sense that I think 15 that the way the threshold's been set for the PRAs, they're 16 set to the -- I don't want to call it the lowest common 17 denominator, but it's the smallest increase of the plants i
18 that we looked at. So therefore for some plants that when '
19 we say they're going into the yellow, for example, if they I l
20 were to do a plant-specific PRA, they would certainly not ;
21 be. They could well be in the white, they could even be in 22 the green, depending on the details of that plant. And 23 that's one of the things you have to live with when you have 24 a generic process as opposed to a plant-specific.
25 DR. APOSTOLAKIS: Can we settle _this thing once l
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103 1 and for all, plant-specific or -- I mean, now you're giving
("T 2 me new information which was not in the d'ocument I reviewed.
Nl 3 MR. PARRY: Yes, I think you're right.
4 DR. APOSTOLAKIS: Which would certainly affect --
5 MR. MADISON: I don't think we've ever advertised 6 them as plant-specific performance indicators.
7 DR. APOSTOLAKIS: But they have to be 8 plant-specific. It seems to me --
9 MR. PARRY: The measurement is plant-specific.
10 MR. MADISON: But the thresholds and the idea of 11 the performance indicators were on a band, provide a band of 1
12 performance and to be in a generic manner, there's a couple 13 of reasons for that. One is the time frame to develop )
14 plant-specific performance indicators we'd still be doing
[D 15 that, just that part of the work. Well, there's another Q) 16 issue. l 17 NR. PARRY: There's another issue there too, and 18 that is that, as you know, not all the PRAs are done to the )
19 same standard. Therefore, if you want to develop 20 plant-specific thresholds, then I think you have to j 21 effectively open up the whole question of whether the PRA is 22 adequate.
23 MR. MADISON: But I think you also need to look at 24 what is the response, what's the NRC response to those 25 crossing that white threshold, and as Gareth mentioned, ANN RILEY & ASSOCIATES, LTD.
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I 104 1 that's a license or a permission or direction actually to 2- the staff that you may need to look at this closer, you may 3 need to consider followup inspection. They have -- there's 4 a significant -- they deviated significantly from the norm, 5 .and NRC, you need to keep an eye -- it doesn't say that 6 we're going to issue an order or that we're going to take 7 any punitive action against the licensee for crossing that 8 threshold other than we need to investigate it.
9 DR. APOSTOLAKIS: But even in the investigation, 10 there has to be a discussion of the issue. Let's take the 11 other case. Let's say that somebody -- a plant has a low 12 unavailability of a particular system, and they have 13 maintained it for years, and the PRA uses that number, and 14 that happens to be, you know, a factor of four below the
}
15 threshold you choose, because the threshold is industrywide.
16 Then the plant looks at that and says well, gee, you know, 17 even if this goes up a little bit, I will never cross the 18 threshold, so nobody's going to notice.
19 Is that something that you would like to see? So 20 the plant now has deviated from its practice before that 21 time because now you've set the threshold higher, so now the 22 numbers slowly shift up and nobody notices, because it's 23 still below the threshold. So the excellent performer is 24 allowed to become a little worse.
25 You see, you really need a good section there l ANN RILEY & ASSOCIATES, LTD.
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l I-105 1 describing exactly what you are trying to do. At this point j
('} 2 either you have to tell me what's hidden behind the data
' ]
3 that you show, and that was, you know, an important piece of l 4 information, or it will be left up to the people who will 5 implement this later to make judgments like this. I think j 6 the issue of plant-specific versus industrywide performance 7 is an extremely important one here.
8 DR. BONACA: Yes. I would like to add from that l
9 respect also, because you have the generic curves addressing )
10 an individual system, for example, for different plants. I 11 But these plants are all different.
12 DR. APOSTOLAKIS: Yes.
13 DR. BONACA: If they were identical, I would say 14 that is meaningful, but it's meaningless in my mind to call !
() 15 generic when you're looking at different plants for which an 16 individual system has different importance.
17 DR. APOSTOLAKIS: That's right, and they recognize j 18 that. They recognize it when it comes to the diesel 19 unavailabilities.
20 MR. GILLESPIE: Yes, I think we're kind of --
21 these indicators were picked as indicators, not as measures.
22 They are not measures of risk. I think we were very 23 up-front with that in the beginning. They are -- and 24 there's multiple parameters involved. And they were set at 25 basically a level that was a 95-percent level from '92 to l
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106 1 '96 as an indicator, not as a measure.
2 George, I don't disagree --
3 DR. APOSTOLAKIS: I understand.
4- MR. GILLESPIE: That it wouldn't be nice to have 5 them plant-specific, but then we're going to get into 6 high-fidelity PRAs, staff review of PRAs, for every plant.
7' Now maybe we get there in the future, and then -- this is 8 not competing with it. If you break an indicator, it's only 9 an indication. Then you get an inspection. The specific 10 inspection results go through this process, and then you're 11 plant-specific. So evaluating the risk isn't done by the 12 indicator, it's done by the plant-specific inspection 13 results.
14 DR. APOSTOLAKIS: But it does trigger some action, 15 though.
l 16 MR. GILLESPIE: It triggers us looking at 17 something, but if the unavailability - South Texas, for 18 example, told me they're within 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> on one particular 19 system on unavailability, and they said they feel like 20 they're riding the threshold very, very, very close just 21 with their normal plant maintenance.
22 DR. KRESS: I'd certainly --
1 1
23 MR. GILLESPIE: We know that.
24 DR. KRESS: Yes.
'25 MR. GILLESPIE: If they break the threshold, we're l
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107 1 going to know that.
It's, you know, if -- I'm not sure what 2 your --
3 DR. APOSTOLAKIS: Well -- Tom, do you want to --
4 DR. KRESS: I'd certainly disagree with the 5- concept that these indicators ought to be on a 6 plant-specific basis. I think that's just the wrong way to 7 go. You guys are confusing comparing the plant-specific 8 ' performance to the criteria that they ought to have met.
9 You want to set a performance criterion of some kind, and 10 the question is now how are we going to arrive at what these 11 thresholds of performance criteria are.
12 There's lots of ways you can set the baseline 13 values you want. You can derive them -- you can pull them 14 out of the air, for one way. You can derive them in sorts
() 15 16 of ways. This was a way to set an industrywide threshold set of criteria that you want performance to meet. Then you 17 compare on a plant-specific basis, those are plant-specific 18 comparisons, see whether they meet these performance. It's 19 a plant-specific comparison of an industrywide set of 20 performance indicators. I think that's the way it ought to 21 be.
22 DR. BONACA: Let me just say my main concern is 23 only one, that in one particular case a plant may have a 24 system that sticks out, just because of the configuration of 25 the plant. Now what will happen is the inspection program O
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108 1 will recognize that. But I'll tell you, that will be like a 2 stigma. It will never go away. It will never go away. It
("')]
N._
3 happens that way, because it is too high, the manacement 4 will say why are we high, and back, and then you'll have 5 people looking at precursors and that thing -- the plant 6 will be for 40 years -- it might be 60 if we go to life 7 extension -- and discussing why. That's not a big issue 8 with them.
9 DR. KRESS: What you're raising there is the issue 10 of whether these are indeed generic performance indicators.
11 Maybe you throw that one away if you have one like that and 12 don't use it anymore. But if these are generic performance 13 indicators, that should never happen.
14 DR. APOSTOLAKIS: This is -- the fundamental (nx -)15 m
question is the following, at least in my mind. First of.
16 all, I've heard many times that it's good to know who's 17 doing better than you are and, you know, why they're doing 18 better. The fundamental question is is this a job for the 19 oversight process or is it a job for industry groups and 20 organizations like INPO. Each plant should know whether 21 they are doing worse in certain areas than other plants.
22 But that's an industry issue, not an NRC oversight 23 issue. These plants have been declared as safe by the i l
24 Commission. That's why they're allowed to operate. The 25 oversight process wants to make sure in my mind that what
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109 !
1 .you thought or what you verified was happening yesterday 2 will be happening six months from now, not to compare six 3 months from now this plant with other plants. See, that's i
4 tue fundamental disagreement. '
5 MR. MADISON: George, I read your comment on that, 6 and that is definitely one way to do it. In fact, I would 7 say that's the way we've been doing it for the last 20 8 years. That's the deterministic method to look at whether 9 the licensee's complying with their license, cheir 10- commitments, and the regulations. But nothing :n this 11 process tells the licensee that they don't do that anymore. '
12 But we chose to go a different way, a different direction, 13 to assess the licensee's performance.
14 And we have already explained our method, our
} 15 madness in the way that we chose to go. It is different, it 16 is not looking at the licensee's commitments. It is not 17 looking at the regulations directly. And it is just a 18 different way to look at the assessment process.
19 DR. APOSTOLAKIS: I understand that, Alan, and I 20 thought the difference was going to be the risk information, l 21 not to include other plants into the assessment process.
22 MR. PARRY: I think it is -- we have got to back 23~ off this a little bit. The reason for choosing the 24 population of plants is that what we were looking for was a 25 level of acceptable performance across the industry. And I i
f V
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110 1 you have already said that all of the plants --
(~} 2 DR. APOSTOLAKIS:
Why is that the job of the V
3 oversight process? ,
4 MR. PARRY: It is not a job of the oversight 5 process, it is a job of trying to fix a criterion for the 6 performance indicators.
7 MR. MADISON: When it would be appropriate for the 1
8 NRC to engage.
9 MR. PARRY: What we have said --
10 MR. MADISON: And that helped us determine that 11 level.
i 12 MR. PARRY: What we said was, exactly as you 13 pointed out, that all the plants have been reviewed and 14 considered as being safe. So that given that, if we look at
() 15 16 the performance of the individual systems in that population of plants, then we should be able to set a performance goal l 17 for those systems that is consistent with the plants being 18 safe. And that is just setting a criterion, just one way of
]
19 doing it.
, 20 DR. APOSTOLAKIS: Well, no, I guess I disagree 1
1 21 with that. I don't think there are many ways and this is i 22 one way. I think the fundamental issue is what are you 23 trying to achieve. And in my mind --
24 MR. PARRY: All we are trying to achieve is 25 indicators that point out when the performance in a l
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111
-1. :particular system becomes significant. Now, we have chosen 2 the green light threshold as saying if it is below that, l -3 then it is not particularly significant.
l 4' DR. APOSTOLAKIS: Yeah, I understand. I guess the l
5 question is, what is significant? Significant with respect 6 to what? And in my mind, the determination of what is 7 significant should be_with respect to the performance, 8 anticipated performance of this particular plant. If San 9 Onofre decides to spend $5 million to make an improvement 10 someplace, I should not be penalized for that because I have l 11 been licensed, you have looked at my IPE, my IPEEE, I am 12 doing fine.
1 13 Now, if the industry wants to put pressure on me i
14 to perform better, that is the industry's job.
{
, 15 MR. PARRY: Are'you under the impression that 16 these thresholds are going to change continuously?
17 DR. APOSTOLAKIS: No.
18 MR. MWISON: No.
19 DR. APOSTOLAKIS: Even if they don't, you start --
20 there are two problems. The plants that are above the 21 threshold automatically get a stigma that Mario mentioned.
'22 And the plants that are below now, I don't know, if their 23 performance deteriorates, how you will catch it, because 24 they will still be below the threshold. And there are other 25 questions as well. That is why I am saying that you should l
l
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112 1 really spend a little more time thinking about this.
2- You talk about randomness and so on in the report.
[
3 You just old us that the data we saw in the report were over l '4 three years. There is no discussion that I recall as to 5 what.the sample should be. When you calculate 6 unavailability, what do you'do? You do it every month and 7 then you compare with the threshold? Or you do it over a 8 year, over two years?
l l
9 MR. PARRY: Actually, I think it is a three year 10 rolling average, I think.
11 DR. APOSTOLAKIS: But that is the data you have.
12 Now, when you start --
l 13 MR. PARRY: No , that is the way the indicators are 14 going to be evaluated, I think. And if Don Hickman is --
() 15 DR. APOSTOLAKIS: But your pilot is for six 16 months. So you are going to go back three years and get the 17 data?
l 18 MR. MADISON: Yes. We have already collected data 19 from the licensees that will give us that backward look, i 20 DR. APOSTOLAKIS: Now, why three years? Why three 21 years and not one? I mean --
i 22 MR. PARRY: Well, the longer the better, I guess, l 23 but in some ways. For smcothing out.
24 DR. APOSTOLAKIS: I don't know. That is what I am 25 saying,~ Lhat I have not seen evidence that you have really ANN RILEY & ASSOCIATES, LTD.
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113 1 thought about it very carefully and .a decided to do this
[
2 and not do that, and the implications or consequences of 3 certain choices you have made.
4 MR. PARRY: Actually, I think we have thought 5 about it quite a lot.. And one of the --
6 DR. APOSTOLAKIS: You just don't want to tell us 7 about it.
8 MR. PARRY: One of the problems, as you know, that 9 the events we are dealing with are not very frequent and 10 they'are fairly random in their distribution. When you have 11 got things like that, you have got to accept the fact that 12 there is going to be some statistical uncertainty. We need 13 some averaging.
14 DR. APOSTOLAKIS: And it is not clear to me how
() 15 you are handling that, that is what I am saying. It is not 16 clear to me how you are wandling that. Are you going to 17 have a band? I mean that is what they do in quality 18 control, they don't deal with rare events, so, you know, 19 they can check.
i i
20 MR. PARRY: Well, the bands are the white and the I 21 yellow bands, if you like. l 22 DR. APOSTOLAKIS: No, but there may be a 23 statistical variation that takes the number a little bit 24 above the threshold, and I don't know whether that justifies 25 going --
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114 1 MR. PARRY: Well, to some extent, that has already
/~T 2 been accounted for, at least in the green and white N) 3 threshold. Now, I agree that when we set the white, yellow 4 and the yellow, red, because we are dealing with average 5 values, we are dealing with PRAs, which deal with means that 6 don't capture these statistical fluctuations, there may be a 7 problem there. But, actually, if you look at the 8 thresholds, and I was looking at some of the data this 9 morning, it is not -- it is very rare that they are actually l 10 going to cross into the yellow for sure.
11 CR. APOSTOLAKIS: Well, clearly, then, the 12 arguments you gave me, because I don't think we are going to .
1 13 close this today, did not convince you when it came to 14 diesels. You felt that for two train plants, the threshold
/~N I
( 15 should be at .05, while for three or more trains, it should
)
16 be .1. So there is an attempt to come closer to the design 17 because you couldn't get away with it.
18 And I will come back to my comment and Dr.
19 Bonaca's comment -- why not make the whole thing 20 plant-specific instead of playing with trains and this and 21 that? I don't know that the high pressure injection system 22 may have the same problem somewhere. I mean you are a PRA 23 guy, you should know that. If there is one thing I have 24 heard a million times that we have learned from the PRAs is 25 that they plant-specific.
p)
(,
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115 1 MR. PARRY: I understand that. And, clearly, that 2 would be a nice goal. But as you know --
3 DR. APOSTOLAKIS: It is unattainable.
4 MR. PARRY: Well, certainly in the short-term it 5 is unattainable.
6 DR. APOSTOLAKIS: How the maintenance rule, didn't 7 we ask the licensees to set some threshold values there?
8 'Why can't we do the same here and have them do the work if 9 it is too much for us? We didn't say that the 10 unattainability --
11 DR. KRESS: George, these are performance 12 indicators. Would you give me a high level principle that 13 allows me to work from to derive a value, an acceptance 14 value on a performance indicator?
(( 15 16 DR. APOSTOLAKIS: The principle is this, the plant has already been declared safe. Even if the CDF is greater 17 than the goal, as you know very well, we don't do anything.
18 So all I want him to tell me is, I have achieved this number 19 by this kind of performance, which means this train has this 20 unavailability, that train has that unavailability, that is 21 my threshold. If I exceed that, then I am deviating from my 22 -performance and the NRC ought to know about it. I think 23 that is a perfectly logical way to do it.
24 DR. KRESS: Would you, in a risk-informed world 25 like 1.174, instead of performance indicators, if we had
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116 1 risk indicators like CDF or LERF -- let's ignore the fact 2 I that you-are never going to see those right now, of course, 3 and assume there was some level thing, would you like to see j i
4 different CDFs and LERFs for different-plants as acceptance 5 criteria? i 6 DR. APOSTOLAKIS: For the oversight process, yes. ,
7 DR. KRESS: You would like for each one of them?
8 DR. APOSTOLAKIS: My fundamental problem is, what I 9 is the objective of the oversight process? I am not saying 10 that is the objective of the whole agency. But when I say I 11 am going to inspect, I go with very stringent boundary 12 conditions. All I want to know is that six months from now, 13 they will be doing what they are doing today, which I have 14 approved. And if they deviate from that, I want to know 15 about it.
J 16 Now, whether I don't like the overall performance, 17 this is not the program to tell me that.
18 MR. MADISON: But, again, as I pointed out, we do !
19 not have the same objective that-you are stating for this' 20 oversight process. We have -- our objective is to assure 1
21 that-the agency meets its mission through the safety goals, 22 by meeting the objectives of the cornerstones, that is, of 23 the process.
24 MR. JOHNSON: George, this is Michael Johnson. I 25 haven't spoken yet today, and I almost hesitate because we ANN RILEY & ASSOCIATES, LTD.
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117 1 have got so much to cover to try to jump in, but I just want 2 to remind us that what we are up to is something that is 3 very simple and we really are about trying to figure out ;
4 what is happening with respect to overall plant performance.
5 Yes, we have seized upon some performance 6 indicators, some better than others, and we hope to improve 7 those performance indicators, Research is going to talk 8 this afternoon about how we will make those improved and 9 more risk-based PIs, but we really wanted to come up with a 10 simple way to look for variations in performance that tell 11 us that we need to engage, become increasing engaged before 12 plants end up in a situation where we need to take some 13 drastic action to ensure that our overall mission in 14 protecting public health and safety is not being threatened.
15 In essence, it is very simple, and I almost -- my 16 medical analogy that I always throw out applies. If we were 17 trying to figure out, if we seize on one indicator, one 18 medical indicator, it would be your temperature, your body 19 temperature, and your body temperature is different from my 20 body temperature, which is different from Alan's body 21 temperature, but we could simply agree, I think, that if we 22 have let's say that exceeds 99 degrees or whatever it is, 23 you tell me what it is, that may be an indicator that there 24 _is something going on that I need to do some additional l 25 investigation on -- and I could probably measure a delta l
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118 1 body temperature --
2 DR. APOSTOLAKIS: Mike, nobody licensed you to 3 live with a 99 degree temperature.
4 MR. JOHNSON: Exactly. Now this threshold that we 5 are talking about is a threshold that is overall 6 performance. It is well -- it is below, it is at a level 7- where we have time to take some additional interaction. We 8 are not at the point where we are looking at even changes 9 that are significant changes that could be measured in terms 10 of delta CDF, as you point out, a the Green to White 11 threshold, so we are looking for a threshold that enables us 12 to go as the regulator and begin to engage, very low 13 consequence for the action, begin to look at the licensee to 14 say what is going on, is there something going on?
() 15 There will be instances because of the crudeness 16 of the PIs because we are not plant-specific where the 17 answer will be is the something that is going on is the 18 plant is a little bit different and so we don't need to take 19 additional action.
20 There will be other instances where there really 21 is something going on with respect to performance that we 22' need to take additional action, but again we are trying to ,
23 come up with a single template that enables us to take a 24 look across the spectrum of plants to be able to recognize 25 performance declines before they get to be significant.
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119 1 That is what we are about.
[ \ -2 DR. APOSTOLAKIS: Well, I guess we cannot reach d
3 closure today, so the best way to approach this is to air 4 the difference, especially make sure the Commissioners 5 understand that there is a difference of opinion and then 6 leave it at that. If they say go ahead, this is what we 7 like, they are the ultimate authority.
i 8 I am not even sure the industry understands this. l l
9 Did the issue come up in your workshops?
10 MR. MADISON: We have talked about having 11 individual plant-performance indicators. I don't know, Tom, 12 if you want to comment on that. Tom Houghton from NEI.
13 MR. HOUGHTON: We looked at that. We tried 14 looking at that and what we decided was that it would be
() 15 best to use a generic level of performance that would 16 trigger the beginning of a look, In other word, the idea 17 being that currently any deviation by the licensee becomes
-18 subject to inspection and the inspection doesn't have any !
19 boundary and we thought by setting a random error band in 20 performance -- if you were above that threshold, then the 21 NRC would have justification for saying, okay, your 22 performance is a good band and we'll just look at what you 23 are doing.
24 On the issue of, if I could answer another l
25 question -- thank you - -that had to do with would the
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120 1 performance, you know, would the utility allow its
-2
( performance to slip if it stayed within the green band, the 3 . indicators are going to be tracked graphically so that will 4 be visible if the performance slipped.
5 I don't think they are going to'let it slip 6 because I know that utilities are setting up administrative 7 thresholds higher than the Green-White threshold so that 8 they don't come in danger of exceeding the Green-White 9 threshold.
10 DR. APOSTOLAKIS: Well, one last comment and I am 11 done.
12 Let's say we follow this process and South Texas 13 is doing well or San Onofre. They are above the threshold, 14 so the first time around the NRC says, well, gee, you are
() 15 above the threshold, so they look. They go through Phase 2 16 and possibly Phase 3, so the risk analysts get together and l 17 say, oh, yes, sure, we looked at the PRA and so on, and so 18 this particular value is indeed above the threshold but for 19 this plant is it okay.
20 Now from.then on, would the threshold be this new 4 21 value for that system for that plant, given all this 22 analysis, or we forget about it and we'll go back again to 23 the generic threshold and we repeat the thing a year 24 later? -- because if you say the Phase 3 risk refinement 25 demonstrates that this value is acceptable for this plant l
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p 121
-1 and from now on this is our point of reference, then all you
< l 2 -are doing is you are becoming plant specific but at a slower V)-
3 pace, which is fine with me.
4 But if you say, well, I convinced myself this 5 time. Now a year later we look again. It's higher. We go 6 through the process again. 'Then it doesn't make sense.
7 MR. MADISON: Well, philosophically --
8 MR. PARRY: We learn from the process.
9 MR. MADISON: I think to answer your question, 10 Mike was starting to, but we are going to look at the 11 process. That is part of the reason for the pilot. It is a 12 living, dynamic process. It is not going to be static. We 13 will continue over the next couple years to look at the
. process and make those adjustments if they are deemed i
14 l 15 necessary.
16- You are mixing apples and oranges in one respect 17 though. We are not using the significance determination 18 process to review the performance indicators. The 19 significance determination process reviews inspection 20 . findings and so the risk associated with that is equal at 21 any plant. The idea was to make it fairly and maintain that 22 fairly generic at this point until we develop better 23 confidence in specific findings.
l 24 DR. APOSTOLAKIS: No , what I meant, Alan, is you l 25 say specific finding identified. It is above the threshold.
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122 1 You go all the way down --
2 MR. MADISON: But the performance indicator is not 3' the finding. What we are talking about are inspection 4 findings and actual issues and Morris is going to go into a 5 little bit of detail, I think, of the types of issues that 6 we are talking about. Exceeding a performance indicator l
7 threshold is not an issue or a finding that would go under 8 che SDP.
9 MR. PARRY: There is not an equivalent Phase 3 10 . evaluation, if you like, currently, but you're right. You 11 could probably,for a specific plant go in, look what the 12 value of that indicator does for you, and use that as a 13 reason to'show why it is not significant, although it has 14 not been written into the programs.
( 15 DR. APOSTOLAKIS: And that should be from that 16 time until forever the new threshold --
17 MR. PARRY: Or at least the knowledge --
18 DR. APOSTOLAKIS: Because otherwise you repeat the 19 process every time.
12 0 MR. MADISON: Definitely. Yes. And there is no 21- intent to do that.
22 DR. APOSTOLAKIS: So you don't think that would be 23 useful to put in the document?
24 MR. PARRY: It might be. I mean it might be 25 something we should think about.
~
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1
[ 123 i 1 MR. MADISON: We think those are exceptions and we will deal with those as they come up.
l' } 2 l
3 DR. APOSTOLAKIS: I am not sure they are 4 exceptions, Alan. I am not sure.
5 MR. MADISON: That is part of what the pilot 6 program is going to tell us.
7 .DR. APOSTOLAKIS: You would have 104 exceptions at i
8 'the end. I'm done.
9 DR. SEALE: Stick a fork in him.
l 10 [ Laughter.]
11 DR. SHACK: Do you remember where you were?
l 12 MR. BRANCH: Earlier I described the process as a 1
13 Phase 1, which is a screening process, the Phase 2 as our 14 simple assessment of the risk, and then the Phase 3 we
() 15 didn't talk about that in as much detail, but in Phase 3 16 will be a refinement, if necessary. In the Phase 2, the 17 screening process, the first --
and we have tried different 18 methods of teaching this to the inspectors. We have j 19 worksheets that we are working on to try to get the 20 information out'to them.
21 This was just a simple diagram we tried to use 22 doing the feasibility review, but basically what you do is 23 once you have your finding, and let's say it is an MOV that 24 .is not operable that affects a train _of equipment, you have 25 to ask yourself, well, does it affect more than one 1
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l 124 1 cornerstone. If it could impact or initiate an event as
] 2 well as mitigation, we go right straight into a Phase 2 3 review. If there is no expected impact, in other words if 4 it is just qualification issue under 91-18 to still 5 operable, we-would screen that out and the licensee would i
fix it under the corrective action program.
6 7 -The next question we ask ourselves is does it 8 represent the loss of a safety function of a system. If the 9 answer is.yes, it's a loss of function, we go into a phase 10 2. And then the next question we ask is does it represent a 11 loss of safety function of a single train greater than the l
12 tech spec allowed outage time. Again, if the answer is yes, 13 we go into a phase 2. If it's no, then we ask is the 14 impact -- this is for the initiating event -- if the impact O
g / 15 of the finding is no greater than increasing the likelihood 16 <of an uncomplicated reactor trip, if that's yes, we screen 17 it out, and if we go through this process, we'd end up into 18 the phase 2 review.
19 In the phase 2 review I mention we look at once 20 we've screened the process in and we're in the phase 2 1
21 review, what we developed is a table -- this is Table 1, and 1 22 then Table 2 -- and Table 1 is basically -- and this was 23 based on the AEOD's recent study as far as the generic 24 probability of initiating events -- once we decide the piece 25 of equipment that's inoperable, let's say it affects a steam ANN RILEY & ASSOCIATES, LTD.
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i
m 125 1 generator tube rupture, aux feed equipment, you have to run t-("' 2 .through this process several times. But you enter the table 3 with a probability of occurrence, and then you ask yourself 4 how long did the condition exist. If it's less than three 5 days, we're in this column over here. Three to 30, in the 6 center column. And greater than 30 days, we remain at the l 7 initiating event frequency.
8 We.then go through the process, we select a 9 color -- excuse me, a letter -- and then we go to Table 2.
10 And Table 2, if we -- let's say if we picked a -- I don't 11 know, what was the -- tube rupture was a C -- if we came in i 12 on this table here with a C, if we had no mitigation, we 1
13 would color -- this finding would be colored red. If we, as 14 we go over, we allow credit for recovery. This is one in (I 15 ten, and this is 10 to the minus 2, 3, 4, 5, as we go over l 16 with more equipment.
l 17 DR. APOSTOLAKIS: What does nonmitigation mean?
l 18 MR. BRANCH: Well, for this event here, if there l 19 was no equipment to remove heat --
20 DR. APOSTOLAKIS: It seems to me that a 21 fundamental requirement for all these -- now I guess it 22 comes back again to what is a finding, Alan? What is a 23 finding?-
24 MR. MADISON: It has to be -- it's associated with 25 some inspection activity. And as Morris said, I thought I ANN RILEY & ASSOCIATES, LTD.
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126 1 defined what we would rise to the level of finding. It has 2 to be more than what would be considered today a minor 3 violation.
4 DR. APOSTOLAKIS: Okay. So you don't really 5 expect that for any of those findings there will be no 6 mitigation capability?
7 MR. PARRY: No.
8 DR. APOSTOLAKIS: Otherwise --
9 MR. PARRY: The finding may be related to the 10 availability of a system.
11 DR. APOSTOLAKIS: I thought Alan told me that's 12 not the case.
13 MR. MADISON: It won't be related to the 14 performance indicator, but it may be related to this piece
( ) 15 of equipment was unavailable for an extended period of time.
16 -
DR. APOSTOLAKIS: But I thought the general 17 guideline was the performance indicators and the various 18 things we inspect are at a low enough level so that if there 19 is a violation, we are not in trouble. So how can you ask 20 the question is there mitigation capability? There must be 21- a hell of a lot of mitigation capability.
22 MR. MADISON: Well, that's not necessarily true, 23 George. It's just like the same with the scram. The scram 24 indicator counts scrams. But there are all kinds of scrams.
25 There's a very simple, uncomplicated scram which would just
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127 1 be one tick on the performance indicator, it would be
('N
\_A 2 minimal followup by the NRC, but then there are other scrams 3 that are more complicated that identify that there were 4 pieces of equipment that were not ready to perform their 5 function, that there were a lot more -- there was a lot more 6 going on and the cause of the scram was a lot more 7 complicated. Those types of scrams are going have to have 8 more followup by the NRC, and they may fall into a finding, 9 may generate a finding that goes into the significance 10 determination process.
11 MR. PARRY: Just to give you an example of a 12 finding that mignt help your understanding of what that 13 means. When we were doing the feasibility studies there was 14 an example of a finding related to the automatic switchover
() 15 to pump reset, that it would not have worked under certain 16 circumstances at a plant. And in those cases for that 17 particular scenario, which would be a small LOCA, or even a 18 large I4X:A, it would not have -- the amount of mitigating 19 system would have been zero for that case, which is -- it's 20 the finding that puts you in that column.
21 MR. BRANCH: Right. One of the issues that we did 22 do in the feasibility review for -- it was a D.C. Cook LER 23 issue that dealt with the containment sump, and as we went i 24 through the process, again, you know, I indicated earlier 25 you had to state your assumptions. And our assumptions were
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128 1 that the condition would not allow the water to get to the
('g 2 sump, therefore all ECCS was iraperable when you went into V
3 the recirc phase of operation. And with that we went in and 4 credited no mitigation.
5 Now I think on that one it was the medium-break '
6 LOCA turned out to be the one that drove it into the red 7 area, because of the frequency of occurrence.
l 8 MR. PARRY: Because that was the condition that i
{
9 was in existence since the plant was licensed, I guess. '
10 MR. BRANCH: Right.
11 MR. PARRY: I mean, it turned out later that it 12 wasn't that serious, but the initial LER had that finding in 13 it, and that's what we analyzed.
14 MR. MADISON: Also keep in mind that the numbers
() 15 16 of issues that are going to actually rise to the red level
{
are going to be very small.
17 DR. APOSTOLAKIS: Yes. I hope so.
18 MR. MADISON: On an annual basis.. We hope so too.
19 DR. APOSTOLAKIS: I was sort of arguing that it 20 would be none.
21 MR. MADISON: In the foreseeable future it may be 22 possible that there are none, and that would say that the 23 industry's performance has risen to that level.
24 MR. BRANCH: The purpose of this slide is just to 25 demonstrate that in the emergency preparedness area -- and ANN RILEY & ASSOCIATES, LTD.
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129 1 we have a slide also for the radiation protection, and then 2 one for safeguards -- and this was just to demonstrate how I
3 our process logic goes. And in this case here you have a 4 violation identified -- I'm having a hard time seeing 5 this -- and then in the area of emergency preparedness we 6 use planning standards out of the 10 CFR as our basic -- j 7 like a barrier that failed, and as you go through the 8 process again, these logic gates that you just -- if it's a 9 failure to implement a planning standard during an actual 10 event, you go to another chart.
11 And in this case here the way the criterion eas 12 set up was that if you didn't implement the planning 13 standard, and it's a risk-significant' planning standard, 14 during an actual unusual event, on alert, then as the issue
() 15 as you process through here would color the finding. So 16 that was the logic we used for emergency preparedness. l 17 This one here is the one we used for safeguards. l 18 We've had some question, and during our training we're l 19 working on developing better definitions for some of these.
20 .But basically as you go through the logic, and in this area 21 here, the issues that typically would fall out here are the 22 ones that are currently covered by enforcement policy as a 23 level 4 violation. In the future they'll be NCVs.
24 DR. POWERS: I don't know how I answered the first 25 question.
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130 1 MR. B: RANCH: It is subjective. We are in the 2 process of working through this.
3 MR. MADISON.: We are developing guidance in that 4 area.
5 MR. BRANCH: We are developing guidance. We're 6 working with --
7 DR. POWERS: How do you think about that? I mean, 8 how do you go about developing guidance in that area?
9 MR. BRANCH: Well,'the first logic gate is if you 10 just had a failure to foll)w procedure that dealt with 11 something that was minor, the intent here was to go right 12 straight into considering it a green finding, handing it --
13 passing it on to the licensee for a resolution through the 14 corrective action program.
() 15 DR. POWERS: Well, I'll admit that I can probably 16 find items that any reasonable person would say well, that's 17 kind of a trivial thing. But I'm not sure that I am in a 18 position to take a collection of incidents and know which 19 ones of those are not a trivial thing.
20 MR. MADISON: And that is why we have asked -- I 21 don't know if Dick Rosano, from the security group is here, 22 safeguards group is here. We have asked them to develop 23 guidance not just a definition of terms, but actually 24 provide some examples to give the inspector guidance in how 25 this would be implemented.
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131 1 MR. ROSANO: This is Dick Rosano, Chief of the
("N 2 Reactor Safeguards Section. That question does not ask what
, \s-)
l 3 is the likelihood of a potential attack. That question is l )
l l 4 intended to ask, how much would that finding, that 1 5 vulnerability assist the design basis threat in l l 6 accomplishing sabotage? What we need to do is better i 7 define, and we do need to do that, we need to better define 8 the risk that is associated with that finding and how much 9 would it assist the design basis threat in accomplishing 10 sabotage. It is not the probability of whether the attack 11 would occur.
12 DR. POWERS: Well, you haven't helped me very much 13 because if I say that first one is how much does that 14 assist, then I don't understand the purpose of the second b
N_/
15 question.
16 MR. ROSANO: Okay. The second question goes to 17 some issues that have a lot of history. For example, let me 18 begin with an example so that you can test it out through 19 the first block. If you found some administrative errors or q 20 minor vulnerabilities relating to barrier protection, but 21 these -- let's say, for example, the intrusion detection 22 system, be it microwave, refill, whatever the intrusion j l
23 detection system is, its operability is essentially ]
24 invisible to an attacker. A zone in a fence may be down.
25 When I say the zone, I mean the intrusion detection system,
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(~ 132 1 not the fence itself.
l 2 That would be a vulnerability, that would be a 3 finding. And I am not going to assess right now whether it 4 is minor or not because we need to define risk. But that 5 would be a finding that you would put into the process. It l
6 would have perhaps a low probability of assisting an attack 7 because it is invisible.
8 DR. POWERS: Okay. So it is not easily 9 exploitable and it is not predictable.
10 MR. ROSANO: Well, no. No, but --
11 DR. POWERS: It seems as if you are answering the 12 same -- 1 and 2 have gotten clouded with each other.
13 MR. ROSANO: The two are very close, but if I can 14 continue with that example, if there are several zones that
() 15 16 are down, or if there is a single zone that is down for a significant period of time such that the staff on the site l 17 knows it, you have gone past the first block of whether 18 there is some risk, because you are talking about several 19 zones.
20 You get into the second block of whether it is I 21 predictable or easily exploitable. That has to do with how 1
22 many people know it, how long the vulnerability exists, and 23 what extent or what percentage of the entire area is now 24 degraded.
25 DR. POWERS: It seems to me that the first Q
(,/
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133 i 1 question that is properly worded, it is not -- it seems to 2
me, to take your example, you have got a zone down, you know 3 that there is some risk. Now, you come to the second 4 question, you say, yeah, but nobody can tell that it is 5 down. It is not common knowledge on the site because it is 6 only down for an hour.
7 MR. ROSANO: If a single zone was down, it would 8 probably fall out on the first question to green, if it was I l
9 a single zone of a short duration.
10 DR. POWERS: Well, okay. l 11 MR. ROSANO: But let's say, for example, that 1
12 there was a single zone that was down over a period of a few 1
l 13 shifts, so that it was known to several different shifts, no f 14 correction had been made. It would pass the first block and
() 15 16 go to the next one. And ther fou would ask, was the noncomformance predictable or reasonably exploitable? And 17 that would be an assessment of whether this information, or 18 -the fact that the zone was down or out of service was known 19 and whether there was a threat, whether there was a 20 heightened security condition at that time, whether there 21 was some known probability of an attack being generated 22 against nuclear power.
23 A lot of other factors now become part of it to 24 decide whether it could be seen and whether it could be 25 < exploited and not just whether -- the point of the first f-s ANN RILEY & ASSOCIATES, LTD.
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134 1 _ block was to_ eliminate small findings, things that, again, would be NCVs or 4s, or used to be 4s, to just drop them out O 2 3 so that they not be~ processed according to the other blocks l
)
4 having to do with exploitability.
5 DR. POWERS: I think I understand now. The 6' identi-fication of a nonconformance, ipso facto, means that
)
- 7. there is some risk. The first block really is a question on 8 whether that is above some threshold of risk.
9 MR. ROSANO: Yes.
10 DR. POWERS: Okay. So now we have to presumably 11 work out in the future what that threshold is.
12 MR. ROSANO: That's true. And as Alan has pointed 13 out, we have a problem with that definition right now and we s i
14 need to work out some details. But I think that the point
() 15 16 is that we don't want to enter this process with minor findings that wouldn't have gotten any attention in the 17 past. We are trying to have an avenue to drop those out of i
18 the process before we start analyzing their significance in 1
19 terms of exploitability.
20 DR. POWERS: Okay You just want to find what 21 threshold do you go to the second question, what takes you 22 to the second question.
23 MR. ROSANO: Yes.
24- DR. POWERS: And you don't have that yet.
25 MR. ROSANO: Not yet.
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135 1 DR. POWERS: And do I have any understanding on 1
2 how you get that? I don't know what the equ.'. valent of 3 engineering judgment is in security space. I know that some I
4 people at Los Alamos failed in their security judgment. But 5 --
6 MR. MADISON: Well, Dick is going to get a lot of 7- help because they are also working with industry to come up 8 with what that definition is.
9 DR. POWERS: Well, hopefully not Los Alamos.
10 MR. ROSANO: We will certainly get a lot of input.
11 I am not sure whether we are going to get a lot of help.
.12 But I am being optimistic.
13 DR. POWERS: Well put. Let's move on.
14 DR. APOSTOLAKIS: Where do the numbers two events,
( 15 three events, two or three events come from?
16 MR. MADISON: That would be inspection, basically 17 that number of inspection findings.
18 MR. BRANCH: Yes, that was inspector judgment .
19 DR. APOSTOLAKIS: Why 12 months and not three 20 years that you will.be using for other things?
21 MR. BRANCH: Well, the indicators, some of the 22 indicators are 12 month indicators. Some of the indicators 23 are -- but this was basically an assessment cycle is 12 24 months.
25 DR. APOSTOLAKIS: And there is a logical
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136 1 explanation of this somewhere?
! f'%g 2 DR. POWERS: Why isn't it a cycle?
\s l 3 I' l
l MR. MADISON: I beg your pardon.
I 4 DR. POWERS: Why isn't it a cycle?
{
5 i l MR. MADISON: We are redefining the assessment !
6 cycle to be an annual cycle.
7 DR. POWERS: Yeah, but why not a refueling cycle?
8- MR. MADISON: It is a good question. We chose to 9 have the assessment process fit with not only providing an 10 annual assessment, which we feel is required of industry 1
11 performance, but also fits in with our budget cycle for 12 planning purposes.
13 MR. FALLON: Yeah, and just almost arbitrary, I )
14 would guess, but the Commission preferred an annual report f^'s 15 or an annual assessment of the performance of the plants.
Q 16 And so we said annual sounds reasonable to us.
17 MR. BRANCH: Any more questions on this slide?
1 18 DR. APOSTOLAKIS: An annual assessment using three 19 year data, is that it?
20 MR. MADISON: Some of the performance indicators i
21 have a three year -- they are three year rolling average.
22 But the look is an annual assessment.
23 MR. BRANCH: Again, this process is just to l 24 describe our logic dealing with public radiation safety.
25 And as you go through the process, we have developed -- are r"s ANN RILEY & ASSOCIATES, LTD.
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137 1 in the process of developing transportation process logics f%
2 as well, but, again, this is a way that we would go through U 3 to take a finding dealing with public radiation exposure and 4 run it through our process and color it into u scheme + bat 5 we'could use for assessment.
6 MR. MADISON: We have kind of used up our time. I 7 don't know how much more you want to --
8 DR. POWERS: We have a.lready handled that. We are 9 letting this session go on till 12:15, 10 MR. MADISON: Okay.
11 DR. POWERS: You started 10 minutes late, so.
12 MR. BRANCH- And we have done the same with 13 occupational. Now, in this area here, I think earlier we 14 talked about there wasn't a clear tie back to risk on some
(#'\ 15 of these non-reactor cornerstones, but in chis area here,
\s l i 16 when we'uere developing this, we did use some risk insight, I 17 and, also, I mentioned earlier, we used the enforcement 18 policy. But in the case of exposure, we changed where the 19 current enforcement policy on overexposure may be a Level 3, 20 which would be the equivalent of a white finding, but in ,
21 this case here, we ran it through the process and we --
22 DR. POWERS: I guess this one confuses me. Well, 23 but it may be just because of the words on the slide and not 24 the words in the text. If I have an extremity overexposure, 25 that is one thing. If I have a whole body overexposure, b
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N y
138 1 that is quite a different thing. Is there a difference of
- 2 the exposures that are going into this process?
i 3 MR. MADISON: Roger.
4 MR. BRANCH: Roger Pederson.
l 5 MR. PEDERSON: Yeah, this is Roger Pederson, I am L 6 l
a Senior Radiation Protection Specialist in NRR and I helped j i
7 develop this with NEI and our other stakeholders. No, we 8 didn't look at the differences between the types of 9 overexposures. We looked at the dose limits that are in 10 Part 20 for the different types of exposures and an 11 overexposure is an overexposure.
12 DR. POWERS: Okay. It is just that the thresholds L
13 are different to finding what an overexposure is.
14 MR. PEDERSON: Yeah, there are different dose !
() 15 16 limits for different types, for skin dose, for organ dose, for what used to be considered a whole body dose.
)
Now it is 17 5 rem TEDE is a basic dose limit. But there are differant 18 dose limits for minors, different dose limits for fetal
! 19 dose. So that overexposure is if it is any of those, if it t
20 in a dose in excess of any cf the limits that are in Part 21 20.
22 DR. SEALE: You chose not to argue with the ICRP.
23 MR. PEDERSON: E>cuse me? There is a little bit 24 y of a problem with skin dose and hot particles. But tnat 25 1 unintended exposure block up at the top, we -- that is l ANN RILEY &' ASSOCIATES, LTD.
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139 1 actually a definition that is in the PIs, the unintended 2 exposure and that is 2 percent of the stochastic limits, 10 3 percent of the non-stochastic limits that are in Part 20, 20 4 percent of the minor and fetal dose limits, and 100 percent 5 of the skin. dose from a hot particle. So there is some 6 adjustment there in terms of risk.
7 MR. MADISON: Thank you, Roger.
8 DR. POWERS: We are back to this marvelous 9 question that I don't know how to answer. Substantial
,. 10 potential. I mean potential I understand, substantial 11 potential, I don't know how to answer that question.
12 MR. MADISON: This is not just -- the definition 13 of terms is an issue in all of the non-reactor charts.
14 MR. BRANCH: But on this one here, though, the
() 15 16 term is actually in the enforcement policy today.
MR. PEDERSON: Yeah, that is exactly right. In 17 the enforcement policy today, in the supplements, an 18 overexposure is the Severity Level 3 or a substantial 19 potential for overexposure. That term " substantial !
20 potential," we defined in the enforcement manual about five 21 years ago. It basically says if the situation, if the 22 exposure event that happened, that did not exceed the dose 23 ' limit, if a minor alteration to the circumstances as 24 happened would have resulted in an overexposure, that is a 25 substantial potential for overexposure.
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140 l
1 MR. MADISON: Thanks again.
{
p 2 DR. POWERS: And so now all we have to do is j 1
~
3 understand what a minor alteration of events is. I mean you 4 are always going to run into this problem.
5 MR. MADISON: I should stop trying to sit down.
6 MR. PEDERSON: In that definition, there is a j
l 7 number of examples to clarify that point.
8 MR. BRANCH: When I started off I indicated I was ;
i 9 going to basically describe our feasibility review in SECY 10 99-007, which outlined the new oversight program, it 11 describes the Staff's plan to test the workability of the 12 new reactor oversight process in early 1999.
13 This was advertised as a limited review of a few 14 plants using the available data to demonstrate the ability 15 to assign a risk characterization of items typically O
16 contained in the plant's issue matrix, the PIMs, and the 17 Staff also planned to conduct an exercise of the new process 18 of the assessment matrix on limited data and to reach l
19 conclusions related to the actions to be taken using the new !
20 process.
21 Because of schedule constraints, the feasibility 22 review was performed at a time when many elements of the new 23 program were still under development. We felt that was okay 24 because the review was intended to identify improvements 25 needed to support the pilot and the pilot is intended to ANN RILtY & ASSOCIATES, LTD.
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141 1 identify and correct' additional issues prior to full
"*g 2 implementation in early 2000.
[Q -
3 The plants we looked at were D.C. Cook, Units 1 4 and 2, for the 1996-97 time period, Millstone Units 2 and 3 5 for 1994-95. To balance out plants between regions we 6 picked St. Lucie out of Region II, Units 1 and 2, for 7 1997-98, and Waterford 3 for 97-98, and the reasors we picked I 8 the time periods was in this process we had to align the ,
9 inspection findings again with the performance indicators 10 and these were the periods of time when the plants were 11 actually operating, plus for Millstone and Cook this also 12 encompassed the period where we had what was considered I 13 guess at the time significant issues that we could run 14 through the process and make sure that our Significance l% 15 Determination Process would work for us.
V 16 The participants for the one-week feasibility 17 review consist of several inspectors or first-line 18 supervisors from the four regions and we had several risk 19 analysts'from Headquarters. We had a member from the Office 20 of Enforcement and also we had members from Technical 21 Training Center.
22 The first day we spent. training, giving an 23 overview of our new process that we had developed to the .
I 24 team. We broke into two groups, and during the second and j 25 third day we processed as many PIMs items as we could ANN RILEY & ASSOCIATES, LTD.
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l
142 l-1 through the Risk Significance Determination Process.
We l 2 could.only effectively review about 20 or 30 issues per the 3- groups in the two days allotted. However we did process l 4 items that we expected to be of risk significance, hardware 5 items from LERs, and also this challenged the assessment 6 processes I have described.
7 DR. POWERS: Let me ask you a question.
8 MR. BRANCH: Sure.
9 DR. POWERS: When you went through the 10 Significance Determination slides, there were lots of 11 questions that I was unable to answer but presumably more 12 educated and better trained people could answer, but that 13 ' burden falls to do all those answers falls on somebody.
14 In the steady state application of this, I presume
() 15 16 it falls on the inspectors, is that true?
MR. MADISON: That's true.
17 DR. POWERS: So now we are going to enhance the 18 amount of desk time of inspectors at the expense of plant 19 time. Is this a good strategy?
20 MR. MADISON: That was one outcome of doing the 21- feasibility review, and one of the reasons why during the 22 pilot study we are going to capture or collect the time 23 spent on using the Significance Determination Process.
24 One of the things though that we think there won't 25 be such a great expenditure in this area is the screening ANN RILEY & ASSOCIATES, LTD, O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036
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I 143 1 process. The' screening process allows the inspector to 2 screen to Green a lot, a great many of the findings that 3 they have without going through this process of the two 4 tables that Morris showed, without going through the process 1
5 of determining what are the mitigation factors that you can 6 give credit for or how long it was an issue, so that again 7 most of the findings will be screened through the screening 8 process, Phase 1, which we think should be a relatively 9 short period of time to accomplish.
10 DR. POWERS: When you do an assessment of that, 11 and it seems logical to me that a screening process helps 12 you a lot on this, but I am thinking, gee, I am an 13 inspector, I have been trained on something that I am
{
14 inspecting, then I have to get trained on this other thing, l
() 15 and nobody is going to be happy with me being trained once.
l 16 They are going to have me doing refreshers and things like 11 that. All these things are conspiring to keep me out of the 18 plant if I am an inspector.
19 I mean there is a burden, even if you screening 20 saves --
21 MR. MADISON. I understand your concern and that 22 is why we are gcing to capture the time and monitor it, and 23 we may need to ma'<.e adjustments to the overall p: vgram, but 24 I think there is a strength and we think there is a strength 25 with this process in that it causes the inspector to ask the O ANN RILEY & ASSOCIATES, LTD.
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144 l
1 right questions. What is significant? What is important
(/
2 about this issue that I need to go' find out as part of my {
1
\_
3 I inspection activities to determine the overall risk '
4 significance of my finding?
5 So we think it will also help focus that 6 inspection activity into the right areas.
7 MR. GILLESPIE: Alan, in fact this may cause the j i
B inspector to be in the plant more, because you have got to I 9 consider what he is doing today and has been doing in the I 10 last several years, and the-first Phase 1 of this is going 11 to screen out likely a lot of issues that we spent a lot of 12 time on the telephone about in morning calls. A lot of 13 stuff that happens at the plant gets called in in morning 14 calls and the inspectors are on morning call every morning,
() 15 so we need to try this during the pilot.
16 This could end up with the inspectors spending 17 more time in the plants rather than less and part of the I
18 initial thinking on this whole thing as already kind of
{
19 gotten into the current enforcement policy where people are 20 screening things with a little more discipline already.
21 .DR. POWERS: I don't discourage you in your 22 enthusiasm but I am willing to bet that burdens enly go up l 23 on inspectors here, that they will still get morning calls 24 about things and discuss things on those morning calls that 25 would not pass the screening, and it will take a generation r~% ANN RILEY & ASSOCIATES, LTD. I Court Reporters <
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145 1 of inspectors.
2 MR. GILLESPIE: Well, that's also true, because 3 it's not just the inspectors. You have to get their 4 supervisors trained to say this is a trivial scram, let's 5 not spend hours discussing this.
6 DR. POWERS: Yes, you are going to have a lot of 7 people to train there, some of whom are less trainable.
8 MR MADISON: Yes, and that is part of the reason 9 for the oversight group to monitor the implementation during 10 the pilot program and provide that feedback and training to 11 not-just the inspectors but to their managers.
12 DR. POWERS: Well, I hope when you -- I hope you 13 will come and talk to us about your findings from this and I 14 think it wou'dj be particularly interesting to see how the
() 15 16 lives of the inspectors -- how badly for the worse the lives of the inspectors have changed.
17 (Laughter.]
18 DR. SEALE: Make a value judgment.
19 DR. POWERS: I know which direction it is going.
20 'I just don't know the magnitude of that vector.
21 MR. BRANCH: Like I say, we processed as many 22 issues as we could through the Significance Determination 23 Process in the two days. The fourth day we ended up 24 generating PI data from these four plants. We could only 25 get initiating scrams, transients. There were only about s ANN RILEY & ASSOCIATES. LTD.
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1 146 1 three or four'PI that we could actually get generated --
l 2 MR. MADISON: Six.
l s 3 MR. BRANCH: There were six, I think, total.
l 4 We processed, we aligned those up to the different l
5 cornerstone areas and on the fourth day what we did is --
6 the fifth day, excuse me, we then took the inspection 7 finding as we colored them through the Significance 8 Determination Process.
9- We took the PI data and we aligned it at a l
1 10 cornerstone and we did a plant assessment, and we asked the 11 regional representatives to bring in the information as to 12 what was actually the actions that the agency took on those 13 p.'. ants, and then what would we recommend with the new 14 process.
() 15 16 Basically, as the slide says, we determined that the process is feasible to pilot, that the Significance 17 Determination Process was successful for the items that were l
l 18 within the scope, and again we took some "to dos" back. We i
l 19 are working on checklists for the inspectors, for the 20 screening tool. We changed some of the logic in our 21 process. We learned a lot from this feasibility review.
22 Also the actions proposed by the new assessment 23 process were similar to past actions but again we made our 24' decisions based on the whats that occurred at the plant and 25 not the whys.
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1 147 1
We took the equipment that was the Red findings 2 and those were hardware type issues, and we passed that 3 information back.
4 We also determined that we did need to do a lot of ,
5 training of our inspectors, and as Alan mentioned, we are in 6 the process of doing that now..
7 MR. MADISON: This concludes our remarks.
8 MR. BRANCH This concludes it.
9 DR. APOSTOLAKIS: One question?
10 DR. POWERS: Please.
11 DR. APOSTOLAKIS: The White-Yellow threshold and 12 the Yellow-Red are defined by looking at changes in CDF, 10 13 to the minus 5 and 10 to the minus 4.
14 I don't remember exactly now how it is described
() 15 but do you use plant PRA to define those thresholds for 16 particular systems, or is it done also in a generic way?
17 MR. PARRY: Are you talking now about the SDP or 18 the PIs?
19 DR. APOSTOLAKIS: The PIs.
20 MR. PARRY: The Pls, all we did was we took a 21 number of plant specific PRAs, as many as we could actually 22 get, did the evaluation on a plant-specific basis, but then 23 took the lowest of those values.
24 DR. POWERS: When you took plant specific PRAs and '
25 what-not, were these ones that the NRC had done or --
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148 1 MR. PARRY: No. These were ones that the NRC has 2 but they were licensee PRAs that the NRC has Sapphire.
3 DR. POWERS: And we have some confidence that l
4 these are useful in high quality PRAs that somehow will 5 reflect the plant as it actually is -- I mean it is a 6 notable defect in the IPE assessments, that we have found 7 sometimes that the IPEs are of questionable fidelity to the 8 plant.
9 MR. PARRY: Some of them, yes, but a lot of them 10 were actually fairly good too, and I am trying to remember 11 which plants they were, but I think they were.
12 DR. APOSTOLAKIS: These you had reviewed?
13 MR. PARRY: They had been reviewed, yes, 14 DR. POWERS: Well, I mean the IPE review itself 15 was for conformance to a generic letter --
16 MR. PARRY: Right. Well, that's true, i
17 DR. POWERS: Conformance to utility in the 18 inspection and assessment process.
19 MR. PARRY: That's true, but I am going to look at ,
20 that. I am not going to comment on the quality of these
'21 PRAs because I am not sure i have looked at all of them.
22 M2. MADISON: That was about a lifetime ago in 23 this process. It was at least six months ago that he looked 24 at in de : ail . i i
25 DR. POWERS: I marvel at the speed with which you O ANN RILEY & ASSOCIATES, LTD.
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149 1 have.~gone from a concept to now virtually implementation in 2 thic process. You ' re congratulated on what must- have been a 3 heroic effort.
4 MR. MADISON: Thank you. There are a lot of ]
5 ~ people in the region and in the Headquarters that put a lot 6 .of time and a lot of good quality effort, I think, 7 in developing this, l
8 DR. POWERS: The committee has documented it. In 9 fact, it's been impressed at the breadth that you threw your 10 net to drag people into this effort.
11 MR. PARRY: Could I make a quick contnent on the 12 SDP with respect to plant specific issues here, just so that 13 you get the picture right.
14 The number that we use in Tables 1 and 2 are sort 15 of generic, but the systems that you take credit for would 16 be done on a plant-specific basis, so it's getting more 17 towards Dr. Bonaca's concern, that at least the des?.gn 18 features of the plant are going to be handled in that way.
19 DR. APOSTOLAKIS: I second what Dr. Powers just 20 said, by the way. I think this has been a heroic effort, 21 and all I'm trying to do with mv objections is improve the 22 product.
23 I do believe that these numbers eventually must 24 become plant-specific, and if you follow the process that 25 was described to us by the NEI representative and keep track
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150 1 of these assessments and so on, I don't see any reason why t 2 in maybe two, three inspections you won't end up with V) 3 reasonably plant-specific numbers.
4 MR. MADISON: What may happen, though, George, 5 is -- and you'll hear this afternoon about Research's work 6 on risk-based performance indicators -- may be a moot point 7 in another year. We may be replacing these performance 8 indicators with something new as developed by Research.
9 DR. APOSTOLAKIS: And I will raise the same point 10 this afternoon.
11 MR. MADISON: Make sure you do that this 12 afternoon.
13 DR. APOSTOLAKIS: At least the same day.
14 MR. MADISON: I'd also like to mention that OPA t
L} 15 has just reissued NUREG-1649. We've revised it to make it 16 more current with the processes. And I think we can also 17 make available to you the slides that were used at the May 18 17 workshop that might provide some better -- we had several 19 left over that I'll make sure that we make available to you.
l 20 DR. POWERS: That would be useful.
21 DR. APOSTOLAKIS: Are you expecting a letter from 22 us?
23 MR. MADISON: No. This was just primarily to 24 provide you with status and try to address some questions.
25 DR. POWERS: Yes. I didn't -- I mean, you've ANN RILEY & ASSOCIATES, LTD.
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l 151 1 gotten sufficient feedback about the questions, and I think 2 it's -- I think the only thing that I would caution is when 3 you come back, clearly we need to schedule a little more 4 time, because there are lots of issues that we're really 5 interested in on the outcome of the pilot program.
6 MR. MADISON: I understand.
7 DR. POWERS: And what not. So with that I l 8 think -- I 9 DR. SHACK: You were going to make the inspection 10 procedures public; right?
11 MR. MADISON: Yes, we intend to make those 12 publicly available. That hasn't occurred yet. We're 13 working on the mechanics of how we do that. As I said, this 14 is the first time I think the Agency's ever done it, but we 15 feel it's the right thing to do.
(
16 DR. POWERS: I think it will -- I think it has the
)
1 17 potential of adding credibility to the Agency to make these j l
18 things public.
19 With that --
20 MR. GILLESPIE: Actually, all of our inspection 21 procedures have been public for years. This time we're 22 asking people to tell us what they think of them. That's 23 different.
24 (Laughter.)
25 MR. MADISON: And actually listening to their s ANN RILEY & ASSOCIATES, LTD.
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152 1 response; yes. j l
2 MR. GILLESPIE: 'And I would suggest that we need I 1
l
- 3. this pilot program to answer kind of George's question how l 4 many exceptions are we really dealing with. Yc,u know, is 1
5 the South Texas where they know they're within 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> of a i 6 threshold, is .lat a problem for South Texas? Is it a 7 problem for others? We need the six months of 8 implementation' time to see what comes out of it.
9 Because one of our ingoing assumptions is that the 10 thresholds that were set in the PIs, and industry concurred 11 in this, are reasonable for the purpose they're being used 12 relative to indicating whether we should look a little more, i
13 And they're certainly more re'sonable than the process we've I 1
14 documented and used to date, which is really a very g 15 subjective process of do we want to go look at some more 16 there. There's no structure to it.
17 The value of this is we've got a decision 18 structure we can now criticize and we can change. There's a 19 skeleton.there. There's a logic flow. We may not have l
20 everything defined, but we know we have to define it. And 21 then we can argue about the definition. That doesn't exist 22 today. So I think that's going to be the major contri ution 23 here is the structure it puts us in.
24 DR. POWERS: I hope that you have steeled yourself 25- for the possibility that this pilot, which is very valuable, ANN RILEY & ASSOCIATES, LTD.
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l 153 l 1 is just too short, that you really need to go'to a cycle.
~
' :2 DR. SHACK: Let me get one more question in before 3 you-bang --
4 DR. POWERS: Certainly.
5 DR. SHACK: Nobody actually addressed George's 6 question of, you know, when you had a PI that you found for 7 a specific plant'was, you know, there was an explanation for 8 it and, you know, would you really go back and do the whole 9 process again, or would you simply adjust the value?
10 MR. GILLESPIE: Oh, for that plant, we would --
1 11 ycs, we would not react, because we know there's -- in fact, !
12 there's -- South Texas was one -- the Combustion Engineering 13 plants have a problem with loss of normal decay heat removal 14 if they don't have a bleed and feed, and newer ones don't.
() 15 16 So where we know the specific explanation of what's happening, we wouldn't go out and re- and re- and reinspect 17 every single time it happens. We document it once, and 18 that's when we have to step back and reevaluate okay, if the 19 Combustion plants,. do we need to make an adjustment on X for 20 the BWRs.
21 DR. APOSTOLAKIS: So you are going to move toward 22 a more plant-specific number --
23 MR. GILLESPIE: I think we're going to move there.
24 I'm not going to say we're going to move rapidly, but as the ;
25 exceptions start showing up, and since we're getting this l i
l l
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1 data reported each quarter, that's actually a fairly
( )
2 frequent milestone. If there's the same explanation quarter !
3 .to quarter to quarter to quarter, and it's programmatic yet 4 it's acceptable, then we'd go in and say okay, what kind of l 5' -adjustment do we need to make in this one. And it might be 5 plant-specific, it might be design-specific.
7 DR. SEALE: Well, similarly the difference -- we 3 i
8 spent the morning, earlier part, lauding large drys, and we j i
9 may find that there's a systematic difference between those l 10 and ice condensers.
11 MR. GILLESPIE: Yes.
12 (Laughter.]
13 DR. SEALE: We might. 1 14 DR. POWERS: I will recess until 1:30. ;
() 15 16
[Whereupon, at 12:30 p.m., the meeting was recessed, to reconvene at 1:30 p.m., this same day.)
17 18 19 20 21 22 23 24 l
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I 155 1 AFTERNOON SESSION
[]
'w) 2 (1:30 p.m.]
3 DR. POWERS: Let's come back to into session.
4 We're going to turn now to an allied topic to our last 5 presentation, in their performance-based regulatory 6 initiatives and related matters. Our cognizant member on 7 all things performance based and -- is, of course, Professor 8 Apostolakis, and so I'll defer to him and expect an 9 outstanding performance.
10 DR. APOSTOLAKIS: This is a risk-based performance 11 indicator program, right?
12 [ Laughter.]
13 DR. POWERS: I'm sorry.
14 DR. SHACK: They all look Elike, George.
()
15 16 DR. SEALE: A pretty low success criteria.
DR. APOSTOLAKIS: Okay. Well, what we received 17 before today's meeting was a copy of the viewgraphs that you 18 guys plan to use. We did not get the report -- or the 19 section that you're working on. Is that ready now?
20 MR. BARANOWSKY: No. What -- is this working?
21 DR. SEALE: Yes.
22 MR. BARANOWSKY: We didn't get the report done.
23 What we did was we put together these viewgraphs -- they're 24 really sort of an annotated outline of the report. And we i
25 were going to write the report and we realized we weren't )
)
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156 1 going to get it done in time to have it here before this 2- meeting. So, we put extra information, if we could, into 3 .this so-called set of viewgraphs. We don't plan on covering 4 every page and every word. So that we did the best we 5 could, in-terms of getting you information. But, 6' eventually, we would like to'have one; we just haven't had 7 the time to do-it.
~8- DR. APOSTOLAKIS: Now, we did get the copy of the 9 paper that --
10 MR. BARANOWSKY: Yeah.
11 DR. APOSTOLAKIS: -- will appear in PSA-99.
12 MR. BARANOWSKY: Right. We did -- we did take 13 this information and put together the paper that we're
-14 presenting at PSA-99. But, that's really a short version of
() 15 explaining exactly what we're trying to accomplish over 16 here. So, hopefully, that information we gave you is enough 17 background for you to have formulated some questions and I'm
- 18 sure they are --
i 19 DR. APOSTOLAKIS: Now, I'm a little bit confused 20 about the various programs that the agency has, and there's 21 this other one that we are to discuss this afternoon on 22 performance-based regulatory initiatives. What you are 23 doing is part of the oversight -- part of attempting to 24 revise the oversight process?
25 MR. BARANOWSKY: That's ---the plan is to see if ANN RILEY & ASSOCIATES, LTD.
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1 we can come up with some improvements to the oversight l
/~' 2 process that brings in a little bit better performance D) 3 indication on a risk basis, to be used in a risk-informed 4 process. It's not meant to be a risk-based process. I want 5 -- that's one point I want to make clear, when we give this 6 presentation. But, yes, this is meant to address, and I l 7 hope we will address, some of the questions and concerns 8 that were raised earlier this morning about plant specific l 9 nature performance and so forth.
l 10 DR. APOSTOLAKIS: Okay. Now, is this also the 11 appropriate -- were you here this morning?
12 MR. BARANOWSKY: Yes, I was hiding back there, i 13 DR. APOSTOLAKIS: Okay. So, this is the project, 14 then, that may look into this issue of plant specific versus 1
() 15 generic thresholds and so on?
16- MR. BARANOWSKY: Yes.
17 DR. APOSTOLAKIS: Because, you are the one 18 thinking about the performance indicators.
19 MR. BARANOWSKY: Right.
20 DR. APOSTOLAKIS: Okay.
21 MR. BARANOWSKY: And I, of course, as you know, is 22 heavily involved in the initial development of --
23 DR. APOSTOLAKIS: Sure.
24 MR. BARANOWSKY: -- the framework and the current 25 set of performance indicators, and I'm pretty well aware of l l
l l
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158 1- what their limitations are.
- (
V; 2 DR. APOSTOLAKIS: Yes. You are one of the usual L .' suspects.
4 MR. BARANOWSKY: Exactly.
5 DR. APOSTOLAKIS: And you expect -- what do you 6 expect from this meeting, a letter?
7 MR. BARANOWSKY: No. What we're looking to do is 8 to brief the ACRS and hear comments back, so that we don't 9 come here late in the' game with something that's pretty far 10 along and developed and having spent a lot of time and 11 effort on, and then get some fundamental questions on high 12 level concepts and direction that we could have been 13 debating here today and maybe made some changes in our 14 program earlier.
() 15 16 DR. APOSTOLAKIS: So, there is no need, then, for me to bring up again the questions I raised this morning.
17 You were here and you --
18 MR. BARANOWSKY: Well, I was here, but you may 19 want to bring them up at an appropriate point, and I'm sure 20 you will.
21 DR. APOSTOLAKIS: No , no, no, you took the steam 22 away from me. Well, judging from the viewgraphs that we 23 received, what you are attempting to do here is pretty much 24 consistent with your presentation sometime ago --
25 MR. BARANOWSKY: Yes.
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159 1 DR. APOSTOLAKIS: -- as part of the oversight --
2 the new oversight process.
3 MR. BARANOWSKY: Right. And we, also, briefed the 4 ACRS, it must have been over a year ago, in which we had 5 some barely sketchy ideas that weren't quite as well thought 6 out as where we are today. And so, we want to, as I said, 7 try to get the ACRS aware of what we're thinking right now 8 on this conceptual level, because, pretty soon, we're going 9 to start diving into this and really moving forward with it.
10 DR. APOSTOLAKIS: Okay. So, the members, I think, 11 are familiar with the overall approach. 3 12 ,
MR BARANOWSKY: Okay.
13 DR. APOSTOLAKIS: So, why don't you start your
! 14 presentation.
i
() 15 16 viewgraph.
MR. BARANOWSKY: Okay. Let's go do the second This shows the content of the rest of the 17 presentation. And I'm going to cover information up through 18 the bullet that says, " Programs supporting risk-based 19 performance indicators" and then Steve Mays will pick up on l 20 the principles, attributes, and concepts, etc.
21 I, also, want to mention that the very first item 22 on here, the risk-informed reactor oversight process, was 23 put in there, because when we first started crafting a white 24 paper, if you will, we felt we had to put some background 25 material in there. And I think we still need to lead off a A ANN RILEY & ASSOCIATES, LTD.
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160 1 little bit with that, because this work needs to be looked
-['s J 2 at in the context of that process. This is not something 3 that's gone off on its own direction and then, hopefully, 4 you're going to try and sway the whole process into some new 5 way of doing things. I think you'll see that our objective 6 is to show that this can be an improvement to and consistent 7 with the current process.
8 Our basic objective is progress, not perfection, 9 and so there will be things that we can't do and we'll tell 10 you about that may take a longer time to do. But the things 11 that can be done to fix some of the deficiencies that have 12 been identified, we'll try to address them as soon as we 13 can.
I 14 DR. APOSTOLAKIS: When do you plan to finish this g j 15 work?
v 16 MR. BARANOWSKY: We have a schedule and it's sort 17 of a multi-phase schedule. I think the first operational 18 set of risk-based performance indicators would be January, 19 2001, and then others could come after that. And you'll see ,
20 the kinds of things that we're having some trouble with.
21 DR. APOSTOLAKIS: Okay.
22 MR. BARANOWSKY: The other thing I want to mention 23 is that we want to cover the viewgraphs in somewhat of a 24 limited way; in other words, not go over every single word, 25 because they were fairly detailed. And so, we'll talk about ANN RILEY & ASSOCIATES, LTD.
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I' 161 1 some of the figures and then we'll just have some O '2 discussion.
1 V
3 DR. APOSTOLAKIS: That's fine.
4 MR. BARANOWSKY: So, let's go to the first figure 5 on page three. And I'm not going to go over this, because, 6 obviously, you know what the new oversight-process is. But 7 the key point is that there are both performance indicators 8 and'there are risk-informed inspection findings, and that 9 those two sets of information provide a complementary 10 indication of performance at the plant. I won't call the 11 risk-informed inspections performance indicators. But, if 12 you think about it, they are measures of performance. And l 13, so, we've taken that into consideration. That's sort of a 14 new thought, I think, that wasn't in some of the earlier
- 15
~/]"\ concepts that we had been working on, and that's going to be 16 factored into some of the risk-based performance indicator ]
17 development activity.
18 DR. POWERS: I think understand pretty well what 19 human performance means in this slide and I may understand 20 problem identification and resolution, but the safety 21 conscious work environment is new terminology for me. Would 22 that be at all related to something I know of as safety 23- culture?
24 MR. BARANOWSKY: Probably, and as you might have I
25 heard us say in previous discussions, we don't currently see i O ANN RILEY & ASSOCIATES, LTD.
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162 1- a way to measure, or whether we even should measure safety 2 culture directly; but that if we select the right types of 3 performance indicators, the impact of that so-called culture 4 would be seen through the performance indicators, i i
5- themselves. I 6 DR. APOSTOLAKIS: We'll come back to that --
7 MR. BARANOWSKY: Yeah. )
8 DR. APOSTOLAKIS: -- when you talk about the l
9 limitations.
10 MR. BARANOWSKY: Right.
11 DR. APOSTOLAKIS: But, actually, it's not i 12 probably. In the report, you very clearly state that some 13 people call this safety culture.
14 MR. BARANOWSKY: Right. And --
15 DR. POWERS: Well, I think it's interesting that i 16 on a viewgraph of an outline nature, boxed diagram nature 17 that only highlights the most important things, that i
18 something that we shy away with -- from so carefully 19 actually shows up. !
20 MR. BARANOWSKY: The other thing is, of course, 21 this is meant to be representational of the current 22 framework that was put together for the new reactor 23 oversight process. And I think those three cross cutting i 24 issues, in particular, were discussed, because there was a l 25 lot of interest in them. And those were the kinds of things l'
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163l 1 that were focused on, in one way or another, in some of the 2 . performance assessment activities that were in the old 3 process, let's say. And we recognize that it's pretty 4 difficult to measure those kinds of things, but that people 5 still have an interest in them and they fit somewhere. And 6 -that's what we're trying to show here. So, if there are any 7 other question?
8 Let's put up the figure two, Tom. This chart is 9 the equivalent to a framework for us, on this project, much 10 .like the cornerstone framework that was presented for the 11- reactor oversight process. We tried to devolve risk, if you 12 will, into some constituent elements.
13 And what I want to do is talk a little about what 14 are risk-based performance indicators. Simply, they are
() 15.
16 indicators that measure either chai m " in risk or the constituent elements of risk associated with a particular 17 plant, or they could be measurements for the total industry.
18 And there are some role, in this whole business, for a total 19 industry risk indication. The risk-based performance 20 indicators use parameters that you are familiar with in risk 21- assessment, such as frequency, reliability, availability, 22 and probability. And they use them to calculate these --
23 either calculate or, as part of the measurement of the 24 various indicators that are associated with risk, through an 25 absent sequence logic. And lastly, the risk-based l
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164 1 performance indicators, they have thresholds that are 2 objective indication points for judging the significance of l 3 performance changes associated with corresponding changes 4 and public risk.
5 DR. UHRIG: Is this a bottom-up type approach 6 here?
7 MR. BARANOWSKY: Yes.
1
! 8 DR. UHRIG: That is to be read --
9 MR. BARANOWSKY: What we did was we said, you can 10 measure or calculate risk at various levels. And those l
11 levels go from the highest level, which is basically what is l
12 the public risk associated with operating a plant in a 13 certain mode, versus what.are the risk implications of 14 either equipment or people performance, as they affect
() 15 16 trains and components and so forth. And what you are going to see is that we're going to talk about developing 17 performance indicators at different levels, some of which 18 would be primary indicators, much like the current set of I
19 performance indicators that we have; and others would be 1
20 more secondary, that allow you to understand what are some l
21 of the causative elements associated with changes in 22 risk-based performance indicators.
23 So, one could have really a large set of 24 performance indicators. And some industries -- I've been 25 .looking into what other either licensees or other industries ANN RILEY & ASSOCIATES, LTD.
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165 1 are doing. They will_have sort of a pyramid shape, if you 2' will,fto'their own performance indicators. The top one 3 might be corporate performance, and then you get down to 4 various lower levels, which feed those different levels that 5 get up to corporate performance. And we're taking a similar 6 approach here to looking at performance indicators. So, 7 it's not just measuring risk only at the highest levels, 8 such as public risk; it could be reliability or some other 9 parameter, which ultimately feeds into risk.
10 But, it feeds into risk through a logical 11 framework. It's not just sitting down and saying, I think 12 reliability is important, so let's go measure some 13 reliability. We have a notion as to how that reliability 14 fits into the risk picture, so that we can eventually set
() 15 16 performance thresholds that might be related to plant specific differences in design.
i 17 The other thing I want to point out with this is l 18 we're measuring performance in risk significant areas.
19 We're not trying to do a plant specific risk assessment.
20 We're measuring performance, in order to determine if there 21 are performance changes that are risk significant, that 22 warrant NRC actions. Now, that's a subtle difference, but 23 our intent is not to come up with a plant-risk indication, 24 because for one thing, we're going to have some holes in our 25 model.
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166 1 DR. APOSTOLAKIS: In your, I guess the previous
(T 2 slide, which you didn't show, what are risk-based b 3 performance indicators, I think you're addressing --
4 MR. BARANOWSKY: Yeah.
5 DR. APOSTOLAKIS: -- now. It would be nice to 6 have a slide with a maybe slightly different title, listing 7 requirements, perhaps, for developing the performance 8 indicators and so on. One thing that comes to mind, for 9 example, is: what is the level of redundant information 10 that you would like to receive from the performance 11 indicators? In other words, if I have a performance 12 indicator -- and I trust it, should I say, I will do nothing 13 on the basic events now, because the train level is good 14 enough; or the other extreme is, of course, is to have a s
15 train level indicator on every single indicator you can 16 think of at the event level; or some sort of an optimal in l
17 between. !
18 MR. BARANOWSKY: Right.
19 DR. APOSTOLAKIS: I don't -- I haven't thought 1
20 about it, myself, but something like another -- another l 21 requirement or question. Should we try to develop -- to 22 establish performance indicators at the highest possible 23 level in that diagram or not?
24 MR. BARANOWSKY: I think that's a principle that 25 we believe is true, but we, also, recognize that when you do l [~'N ANN RILEY & ASSOCIATES, LTD.
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167 1 that, you lose a lot of information --
4ID 2 DR. APOSTOLAKIS: That's correct.
U 3 MR. BARANOWSKY: --
and it gives you the ability 4 to take timely actions. And I think Steve is going to cover 5 some of this.
6 DR. APOSTOLAKIS: So, there are objective --
7 MR. BARANOWSKY: Yeah.
8 DR. APOSTOLAKIS: -- I mean, competing -- l 9 MR. BARANOWSKY: Right. I 10 DR. APOSTOLAKIS: -- requirements. But, I suppose 11 what I'm saying is that it would be nice to see a separate 12 discussion of these, you know, setting the stage, so to l
13 speak, of what drives the performance indicator --
l 14 MR. BARANOWSKY: Right.
1 (3) 15 DR. APOSTOLAKIS: -- definition to follow later.
I l
16 MR. BARANOWSKY: Let's see if Steve's --
1 l 17 DR. APOSTOLAKIS: Okay. l l
18 MR. BARANOWSKY: -- first couple of charts cover l l
19 that and then we can add to it.
20 DR. APOSTOLAKIS: Okay.
21 MR. BARANOWSKY: That's the kind of -- we're l
22 looking for that kind of comment.
23 DR. UHRIG: But, let me go back to system level 24 indicator. You've got one in there called capability. Why l 25 is that an indication of performance? Or do I misinterpret 1
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l l 168 1 what you' re driving at.
! /~'N 2 MR. BARANOWSKY: Oh, those are -- yeah, that's --
3 DR. UHRIG: I understand --
4 MR ., BARANOWSKY: No , that's a good point.
5 DR. UHRIG: -- reliability and availability, but 6 not capability.
7 MR. BARANOWSKY: That's a good point. One of the 8 objectives for certain sets of systems is that they be J
9 reliable, available, and capable. And if the system isn't 10 capable, meaning that its design or, for other reasons, it's l
11 not able to perform the intended function, even though it, 12 in theory, is operable for technical specifications, or 13 thought to be operable, then that's an indication of 1 14 performance that's unacceptable for that particular piece of 15 equipment.
16 DR. UHRIG: But -- l l
17 MR. BARANOWSKY: I mean, in theory, you can pull 18 that into reliability, if you want to. And we had some 19 debates on this, when we did the reactor oversight framework 20 cornerstones. But, we thought that, in light of the way we 21 do inspecticns and what this means to inspectors and 22 licensees, that we would pull capability out from 23 reliability and availability, wherein availability would 24 mean mora or less is the system in or out of service, as 25 planned or unplanned; reliability meaning is it able to l
~
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r 169 1 perform on' demand; and capability meaning if it's in. service 2 and it starts up on demand, is it able to provide the 3 necessary flow for the particular accident that we're 4 talking abcut, especially since some of the tests don't 5 necessarily capture full capability.
6 DR. UHRIG: But that's a function of design of the 7 plant.
8 MR. BARANOWSKY: Right; correct.
l 9 DR. UHRIG.: And that's the history --
l 10 MR. BARANOWSKY: Yes.
11 DR. UHRIG: -- unless you go back and revamp the l 12 plant. And it strikes me that that's not fair game for an l
I 13 inspection demerits, so to speak.
1 14 DR. BONACA: But, you have the degradation taking
() 15 _ place in components. I mean, there are some systems that l 16 are limited by design, although they were effective enough, 17 and then, because of aging, they get limited in performance.
18 MR. MADISON: This is Alan Madison. There's also 1 19 on inspection, and I've been involved in this and several 20 diagnostic evaluations, you run into not just degradation, 21 but you, also, find out new information. The qualification i
22 of the equipment may impact it. Capability, as Pat was '
23 talking about, was, is the system function capable of l 24 performing its design capability, its design function.
25 DR. UHRIG: That has to do with aging, then.
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170 1 MR. BARANOWSKY: It may have to do with aging; it
/s 2 may have to do with other things you learn about.
(_,/ I l 3 MR. GILLESPIE: The net positive suction head l
l 4 problems we found in the AE inspections --
5 MR. BARANOWSKY: Okay. Some of the --
l 6 SPEAKER: Is it inspected for 20 years?
7 MR. BARANOWSKY: Some of the logical system --
8 distribution system type problems that we've identified --
1 9 DR. APOSTOLAKIS: So, there is a fundamental 10 unepoken condition here that you are -- the performance 11 indicator is related to quantity that may change with time.
12 Because, I think, Dr. Uhrig is right, I mean, the original 13 design must have made sure that the components were capable, 14 at that time; and because of aging or other reasons, you may
/~' 15 have a change. That does not apply, for example, to D) l 16 separation criteria. I can't imagine that something that --
l 17 if two components are, say, five feet apart, three years I
l 18 later they will be only three feet apart.
l 19 MR. BARANOWSKY: Right.
20 [ Laughter.)
21 DR. APOSTOLAKIS: There's nothing that --
22 MR. BARANOWSKY: No, I think you would --
23 DR. APOSTOLAKIS: So, that's not part of a l 24 performance indicator.
25 MR. BARANOWSKY: Right; correct. If the -- let's i
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171 1 say a new generic issue came up, in which we determined that r
2 we need five feet of separation instead of three. We 3 wouldn't call that a performance issue.
i 4 DR. APOSTOLAKIS: No , that's right.
5 MR. BARANOWSKY: But if the licensee was supposed l 6 to install new wiring with five foot of separation and l 7 installed it with three, and we observed that through an l 8 inspection, then that is a performance finding, that their 9- design and installation performance is not up to what we i
i 10 expected. So, it's got to be treated somewhat differently.
11 I'm not saying to put them all in the same pot, but you have 12 to account for this kind of thing in your performance 13 assessment. And it's not the same kind of performance j 14 characteristic as one gets from the reliability of equipment
! I' % 15 failing, say on demand; but still under certain accident
!V 16 conditions, it doesn't meet the specifications for 17 performance.
18 DR. BONACA: That would include also issues of 19 code compliance, where a system is functional, but is not i 20 operable, because it doesn't meet the code?
21 MR. BARANOWSKY: I think that what we're not going 22 to do is account for things that don't affect the 23 performance necessary for the risk signiff_ cant acts and
-24 sequences. That.might be true for some design bases 25 envelope. And compliance will be treated -- as Al said this ANN RILEY & ASSOCIATES, LTD.
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172 1 morning, we find compliance issues that are in risk 2 insignificant areas. I think they showed that in the STP
['}
%./
3 process. They go in to inform the licensee and they will 4 take care of them. In the risk significant procesa, that's 5 another story. Keep an eye on that.
6 DR. BONACA: Okay. Let me understand this, 7 because I'm confused: so this really would be risk-based -- <
8 MR. BARANOWSKY: Yes. !
9 DR. BONACA: So, therefore, a component that is 10 capable functionally would be considered operable, by this i 11 standard --
12 MR. BARANOWSKY: Correct.
13 DR. BONACA: -- even if it doesn't meet a specific 14 code.
15 MR. BARANOWSKY: Right.
16 DR. BONACA: But, it's capable of performance.
17 MR. BARANOWSKY: Right. Now, we wouldn't even 18 have that information probably get factored into the i 19 indicators here, because we're going to have an approach 20 that only collects the information necessary to get the risk 21 significant, say, design or capability defects. The other 22 parts of the inspection program might pick that up, but 23 that's not necessarily what we're trying to do here.
24 DR. BONACA: That's a significant distinction.
25 MR. BARANOWSKY: Yes.
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173 1 DR. BONACA: I mean, it's a huge departure.
2- MR. BARANOWSKY: It is.
3 DR. SEALE: At some point, it does dovetail with 4 the new way of handling category four violations.
5 MR. BARANOWSKY: Correct.. That's what we're 6 doing.
7 DR. APOSTOLAKIS: I think what we need, Bob, is 8 that report or --
9 MR. BARANOWSKY: Yeah; okay.
10 DR. APOSTOLAKIS: -- definition of performance, 11 and bring up the issue of time.
12 MR. BARANOWSKY: Good. One -- bring this 13 questions up and we can fold them in. I think that's gocd.
14 That helps us out.
() 15 16 DR. APOSTOLAKIS:
we mean by performance.
I think we need to define what 17 MR. BARANOWSKY: Okay.
18 DR. APOSTOLAKIS: And then we have performance 19 indicators. But, it seems to me there is a fundamental 20 element of time. Something can change, in other words; 21 otherwise, you don't need them. Then, it's a design issue.
22 So, all the example you gave us really indicate that 23- something may go wrong over the lifetime of the plant and 24 you need some indicator to monitor that.
l 25 MR. BARANOWSKY: The design and capability part of ANN RILEY & ASSOCIATES, LTD.
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I l
( 174 1 this whole thing is really one more difficult ones to f
2 describe, I think. I'm not so sure it's hard to treat, but 3 I think it's hard to describe. And I think I agree, we need 4 to put something up.
5 DR. APOSTOLAKIS: Let's go on now, because we're 1
6 spending --
7 MR. BARANOWSKY: Okay.
8 DR. APOSTOLAKIS: -- too much time.
9 MR. BARANOWSKY: That really does finish that 10 viewgraph. Let's go to item seven, Tom. I am just going to 11 briefly run over this, why we're having risk-based 12 performance indicators. I think the first three bullets are 13 the usual types of things, you know, becauce of the policy 14 on use of risk.
() 15 16 I guess I will say the second bullet, the framework, it's very important. I've had the opportunity to 17 work on that new oversight process framework, and it's hard 18 to figure out how to pull things together in a logical 19 framework, where you can put things on an even playing field 20 that's not associated with a risk model of some sort. And 21 so, risk -- the risk framework provides that ability for 22 capturing and analyzing and comparing and integrating 23 information. Integration is important, too. So, I think 24 that's a pretty important one.
25 We expect that the risk-based performance I
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1 175 l' indicators will obviously be an improvement to the current 2
i set of indicators. You talked about some of those this 3 morning. And the next viewgraph, I think, probably
! 4 identifies some of the limitations a little bit more. And 5 then Steve will be talking about some of the holes that are 6 filled in by the risk-based performance indicators. They're 7 going to more closely link performance to risk and to risk 8 thresholds. And, in particular,
- hey're going to provide l
9- the ability to look at things on a more plant specific 10 basis, so that some of these concerns that we have about 11 using the same threshold with indicators that are basically i
12 designed, say, on a train basis, giving some misleading i
13 indication of how risk significant that performance is, can '
14 be handled through this process. I don't know exactly what l I
,( } 15 that would do,-in terms of changing the thresholds, but we I 16 would have the ability to do that.
)
17 So, let's go to the next viewgraph, number eight.
18 What this viewgraph does is makes a list of the kinds of 19 areas of improvements, or limitations, as we call them here, 20 that the current set of performance indicators has; and the 21 first one being that there's no reliability indicator, the 22 next one being that there's limited indication of 23 availability for certain systems. We don't have indicators 24 for barriers or for shutdown or external events. We have 25 very limited indication capable of capturing things like ANN RILEY & ASSOCIATES, LTD.
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1 l
176 l 1 human performance and design and procedural quality.
-+
2 There's no integrated indicator.
%/
3 DR. APOSTOLAKIS: Pat? l l
4 MR. BARANOWSKY: Yes.
5 DR. APOSTOLAKIS: It so happens that the Swedes 6 are doing a lot of work on this. And I don't know if you're 7 aware of it, there was a report from SKI, published in 8 February, '99. Have you seen it, Steve?
9 MR. MAYS: Yeah, we have it.
10 DR. APOSTOLAKIS: Okay, you have it. And they are 11 actually using expert opinions. One of the experts is 12 sitting to my left here. It's interesting, by the way, that 13 I counted that they used 21 experts, more than 50 percent 14 were from the industry. They developed a list of !
15 performance indicators. I mean, you can question what are
(} 4 16 the things they do, but there's all the work that went into 17 it.
18 And they -- the experts identified the top five.
19 Now, this deals with culture, human performance and so on. l 20 So, number one is the annual rate of safety significant i 1
21 errors by plant personnel, contractors, and others. The l 22 fifth one is annual rate of plant changes that are not 23 incorporated into design basis documents, by the time of the 24 next outage following the change. Now, these are things 25 that you can see, I mean. So, perhaps we were too quick to s ANN RILEY & ASSOCIATES, LTD.
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177 1 say that we can't find performance indicators for these-2 cross cutting. issues.
l There are -- these experts, at least, l 3 were able to identify -- they started with a list of 11, I l
4 believe, and they ended up-with five most important.
5 DR. BONACA: Actually, 11 were cut down further
! 6 manipulation. There were over 100.
7 DR. APOSTOLAKIS: Over 100.
8 DR. BONACA: And then went down to about 11, and 9 then down to about five.
10 DR. APOSTOLAKIS: About five. So, I suggest that 11 you read this report carefully ard see whether there's 12 anything there that you want tg'# orrow b 1 rom them.
s
- 13 MR. BARANOWSKY
- Ydbs, we looked at it. That's --
14 we're looking for anything that has been done in the last
[ 15 couple of years, and I know that was just done.
l 16 DR, APOSTOLAKIS: Yeah.
17 MR. BARANOWSKY: In fact, we contributed an expert 18 to that. panel, too.
19 DR. APOSTOLAKIS: I know.
20 MR. BARANOWSKY: Okay.
21 DR. POWERS: Similarly, we've come to the -- that 22 no indicators -- or things like fire, they have been FPA 23 performed, according to creating a performance-based fire 24 protection rule. And they clearly have slots and a rule for 25 performance indicators. Are there indicators not defined or i
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I ._
178 1 don't meet your criteria? I r .2 MR. BARANOWSKY: I'm not sure I know their 3 performance indicators.
4- MR. MAYS: I don't know what their performance 5 indicators are and I haven't seen anything right now that I
6 tells us what.they're looking at.
I 7 DR. POWERS: But, I mean, you have a member of the l
d 8 NRC staff that is on that panel, trying to create those.
9 MR. MAYS: That's correct.
l 10 MR. BARANOWSKY: We can look into it, I guess is 11 what we can-do.
I 12 DR. APOSTOLAKIS: Since you have the Swedish 13 report, you don't seem to change, though, your position that 14 you can't get indication of cross cutting issues. I mean,
( 15 you've said that to us several times.
-16 MR. BARANOWSKY: All is aid was we had limited 17 indication. I expect us to have some indication on cross 18 cutting issues. I think we are planning on that.
19 DR. APOSTOLAKIS: Oh, okay.
20 MR. BARANOWSKY: Now, what we are trying to do a 21 little bit different than the Swedes, and we could fall back 22 on what they're doing, what we're trying to do is make a L 23 more direct link between the indicators that we're looking l 24 'at and risk, that doesn't rely on expert opinion so heavily.
25 Now, if'it's not possible --
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179 1 DR. APOSTOLAKIS: If you could, yeah, that would 2 be great 3 MR. BARANOWSKY: Yes, of course. But, if it turns
'4 out that that's the only alternative open to us -- we use 5 that a lot on quantification of different events and so 6 forth, and we wouldn't ignore it.
7 DR. APOSTOLAKIS: So, you don't feel constrained 8 by the current climate of not getting into organizational
! 9 issues?
10 MR. BARANOWSKY: Well, I'm not sure I'd call that 11 organizational issue.
l l 12 DR. APOSTOLAKIS: See, that's the thing. I think 13 a lot of it has to do with communication.
14 MR. BARANOWSKY: Yeah. If I was to say I'm 15 concerned about some of these parameters that you mention,
(
16 because they reflect poor organizational performance, then 17 I'd be off on a different tangent. But, I think what we're 18 going to do is look at it and say, what, even on a 19 judgmental basis, does that information tell us about the
.20 risk significance of these kinds of things. And if we can
- 21. make an argu aent that connects it to risk, even if it's 22 connected indirectly or implicitly, instead of explicitly, 23 okay. But, if it's connected through, I just think it's 24 important, because I think organizational factors are 25 important, unless directed to, I don't think we see that in i
l.
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180 1 this program. !
I 2 MR. MAYS: I think Pat talked about earlier, the 3 key thing was, is that we're putting together a framework 4 related to risk, as opposed to a framework related to 5 anything I can think of that relates to the performance. I 6 mean, if you just say performance -- and you raised the 7 question,.what do you-mean by performance. ;
8 I think the key thing here is that we're looking 9 at the performance, as it relates to risk, as opposed to the i 10 performance, as it relates to management effectiveness or !
l
\
l .11 public confidence, or any other metric you might want to !
l j 12 ~ choose there. And I think if we don't have a way to take I i 13 any information and relate it back to risk through some 14 model process, we're probably going to be reluctant to I
() 15 include it as a performance indicator.
16 DR. APOSTOLAKIS: But, these top five that they' i
l 17 identified, are the top five that affect the failure rates
? 18 of components or.the frequency of initiating events. So,
! 19 they are making the connection to risk. The question is ;
20 whether that connection is quantitative. But, again, you l
21 -can have a qualitative connection. Everybody agrees that 22 this is important. Now, the fact that you cannot quantify 23 the precise impact perhaps should not deter you from having i 24 some indication of how well the plant is performing, with 25 respect to that --
1 l
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l 181 1 MR. BARANOWSKY: I think we're open-minded on
- 2 that.
J 3 DR. APOSTOLAKIS: Yeah. Because, I think you are 4 getting into an area, where quantitative relationships are a 5 little difficult to. abide.
6 MR. BARANOWSKY: Right. But, this stuff will have 7 to stand up to a much wider and more critical audience than 8 whatever the Swedish report went through.
9 DR. APOSTOLAKIS: No , I understand that. And, 10 again, remember that the audience may be critical if you 11 don't address the issue at all.
.12 MR. BARANOWSKY: Agreed.
13 DR. APOSTOLAKIS: You would be criticized anyway, 14 but --
15 [ Laughter.]
16 MR. BARANOWSKY; Okay. We've got the message.
17 Let's see, where was I. And we know that there are some 18 problems with trying to come up with indicators in the areas 19 of emergency preparedness, radiation safety and security.
l 20 And also, lastly, I want to mention that there -- the l 21 current indicators, at least some of them, are heavily 22 count-based, and you run into some statistical problems on l
23 count-based indicators.
24 DR. APOSTOLAKIS: The maintenance rule, they don't 25 have any reliability base?
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l 182 1 MR. BARANOWSKY: Well, we aren't using the 2 maintenance rule. I would think they have -- they can do 3 the maintenance rule anyway they want, as long as they can 4 relate it back to whatever their performance objectives are 5 and, in some way, back to their PRA. My understanding is 6 it's done qvite differently at each plant and it's going to 7 be hard for us to use that, as a case in point, to make a 8 judgment on this. But, I'm talking about indicators of ,
1 9 ' numbers of reactor trips per, what, day or year or whatever 10 we're talking about; or numbers of failure counted. If you I 11 use those kinds of approaches, you run into some problems 12 with statistics. And I think the ACRS has gone over this 13 over the years.
14 The last point, we have to be realistic about what
(} 15 16 can be done, in light of the lack of certain things, in particular risk models in areas. It will be awfully hard 17 for us to develop risk-based performance indicators, when we 18 don't have a good model framework to relate the basic event 19 information, that is the essence of the indicator to the 20 risk. We would be back into the business of using judgment, 21 as to how important things are, and we can do that probably 22 outside the framework of this particular project.
1 23 DR. BONACA: One comment I'd like to make is.that, 24 you know, one difficulty that we, also, have in the Swedish l
l 25 study was the effort to try to connect human factors or ANN RILEY & ASSOCIATES, LTD.
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183 1 cultural indicators to risk and to plant operation. And
(~} - 2 that's a very difficult task,'because dependancies are not
(/ .
3 so clear. So, you go to an elicitation process and so on 4 and so forth.
5 From a practical' standpoint, however, you could --
6 you could select groups of performance indicators from 7 cult ural areas, and they're being done -- utilities out 8 there. I mean, there are certain specific groups, which are
- 9. focused on that -- for which you don't have a direct 10 correlation to risk. Right now, it doesn't exist, although l 1
11 we suspect there is, of course. And then, you could monitor I 12 them separately, the group of risk indicators, which are 13 top, and then some of the cultural indicators, okay. And, 14 again, those, you know, I can't just make -- I have the 15
( list, actually, I'll present to you and the rest of the 16 committee the day after tomorrow. But, safety conscious 17 work environment, there are that that is being monitored of i 18 the units: operator challenges, corrective action program, 19 self assessment, quality of maintenance. I mean, there are 20 really literally eight or nine of those boxes that utilities 21 track pretty religiously right now, because they realize 22 that all the past experience, in so far as failures of 23 system and availability and so on and so forth, is tied to 24 those kinds of general areas of performance.
25 And, I mean, it seems to me that you don't have ANN RILEY & ASSOCIATES, LTD.
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1 p 184 1 necessarily to identify an analytical dependency. That's a
[ 2 challenge always to do so, to try to sort out some cultural 3 indicators.
.4 DR. APOSTOLAKIS: So, when you say risk-based, are 5 you excluding these kinds of indicators?
f 6 i MR. BARANOWSKY: No. I think what we're saying is 1 7 we need to at least have a logical connection, which can be j
8- through expert judgment, but that what we're not going to do
- 9. is have a pure human performance indicator that takes the 10 10,000 records that we have in the human performance 11 database and say, here's the plant norms and here's the 95 12 percent thing, when only 20 or 15 or 10 percent of those are 13' related to risk. We want to be able to deal with the ones 14 that are mout risk significant. That's what I mean.
r 15 DR. APOSTOLAKIS: Even though the connection may 16 be qualitative?
17 14R . BARANOWSKY: Even though the connection might 18 be qualitative.
19 DR. APOSTOLAKIS: And just to make my position 20 clear, I do not necessarily agree with everything that's in 1
21 the Swedish report. All I'm saying is look at it and see j 22 what you can use.
23 MR. BARANOWSKY: I agree.
24 DR. APOSTOLAKIS: I'm not saying this is something 25 you have to use.
l
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185 1 MR. MAYS: And, as well -- and, again, as Pat 2 indicated earlier, this is an oversight process of which 3 indicators is a part. If you talk to Alan and the people, 4 who have been putting together the risk informed base line 5 inspections, one of the things they tried to do was to go 6' perform inspection activities in areas like the corrective 7 action program and self-identification of problems and other 8 things, to get information about whether plant performance 9 was heading in-the right direction or wrong direction, 1 10 independent of a direct indicator. So, it's not a necessity 11 that the indicators cover everything you would ever want to 12 know about plant performance, because we, also, have a 13 baseline inspection program, which is supposed to go out and 14 examine other areas of performance that are not readily
{
() 15 16 amenable to indicators.
DR. BONACA: Well -- but, that's what concerns me l 17 a little bit. I agree that you're looking at those things.
18 And I appreciate that fact that you have that layer there 19 of, you know, safety conscious work environment and so on 20 and so forth. It is the statement that you cannot build 1
21 indicators that I guess I have some problem with.
22 DR. APOSTOLAKIS: But, they didn't really mean it, 23 though.
24 DR. BONACA: Okay. But that's what I heard.
25 MR. BARANOWSKY: Did we say we couldn't? I'm just ANN RILEY & ASSOCIATES, LTD.
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186 1 looking to see if we said that. But, I think we said it
(' 2 would be difficult.
C 3 DR. BONACA: Yeah, okay.
4 MR. MADISON: It depends upon how you use the 5 indicators. If you use the indicators for enforcement or 6 for sanctions against the licensee, I don't think you're 7 going to be getting them through judgment. I think there 8 are going to have to be some qualitative guidance associated 9 with those performance indicators. If we're using 10 performance indicators, on the other hand, to perhaps make 11 some minor adjustments in our resources, I think you can be 12 a little more judgmental.
13 MR. BARANOWSKY: That's a good point.
14 MR. MADISON: It really depends upon what the use
[N 15 of the performance indicators is going to be.
16 DR. BONACA: But the way -- the way in which you 17 are going to either use those indicators to just a portion 18 of your resources. It's good to give a very clear signal to 19 the -- the utilities that are going to follow some -- I 20 think you're providing an example --
21 MR. MADISON: You're absolutely right. And that's 22 why we, again, have to be very careful with -- for example, 23 a good manager is going to have a lot of different 24 performance indicators. At the sites now, they have a stack 25 of performance indicators probably about that thick, that
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1 187 1 they get a report on, on a monthly basis, that they manage I 2 .their plant with, and that's an appropriate use of that 3 level of performance indicators. As a regulator, we don't 4 want to-get to that depth.
5- DR. BONAC.1: Yes.
6 MR. BARANOWSKY: I mean, as an example, I think to
-7 what Alan is talking about, I can have a motor-operated 8 valve performance indicator. That may not be one that I' 9 want to use to judge a licensee's performance in the 'j 10 assessment process, but it might be one I want 'o use to 11 plant risk-informed inspections. I have some latitude in ;
12 performing those inspections. So, that might be used to 13 point us in the right direction. 1 14 DR. APOSTOLAKIS: Well, I think what you -- the 15 focus of the discussion has shifted a little bit. When we 16 say subjective, or when we use that word subjective here, we 17 didn't mean -- I don't think that Dr. Bonaca and I meant 18 subjective indicators. The indicators are quantitative. I 19 mean, these guys are telling you to count the number of 20 times that they did not recommend something. But maybe 21 subjective is the connection of that indicator to risk.
22 MR. MADISON: Right.
23 DR. APOSTOLAKIS: But the indicator, itself, is 24 quantitative. Now, that, according to Bob, is something 25 that he will consider.
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188 1 MR. MADISON: But, also, the thresholds for f~% 2 action, that's where the rubber meets the rubber. What are U 3 you going to do, based upon those performance indicators?
4 DR. APOSTOLAKIS: I agree.
5 MR. MADISON: The thresholds for action are going 6 to have to be more than subjective, depending upon the 7 action you take.
8 DR. APOSTOLAKIS: And they will have to be plant 9 specific, of course.
10 MR. BARANOWSKY: Well, to some extent. But, I 11 mean, we are definitely not going to have 150 new 12 performance indicators, even though there might be 150 13 possible ways of measuring performance.
14 DR. APOSTOLAKIS: I think we've reached the point 15 of agreeing.
16 MR. BARANOWSKY: Okay.
17 DR. BONACA: Just one last comment I have.
18 DR. APOSTOLAKIS: I'm sorry, yeah, sure.
19 DR. BONACA: Just one example, okay. When I look
. 20 at a power plant and I see under operator challenges -- let 21 me just, you know, I have an indicator, I'll call it that 22 way, that there are a very large number of operator 23 work-arounds. There are a lot of temporary modifications in 24 place, bypass jumpers, and all kind of stuff like that, and, 25 for example, you know, control room enunciators lit. That ANN RILEY & ASSOCIATES, LTD.
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189 1 is a big problem. It is truly challenging the operator on a f- 2 daily basis with his ability to perform effectively.
3 Now, you know, I had, personally, put together an 4 indicator that is being used somewhere that embodies those 5 kinds of elements. It's just a number counting, and it has 6 to be a point at which you say this is too much. You cannot 7 allow that. That's also a terrific indicator of management 8 philosophy, because those things don't happen -- management 9 doesn't accept that kind of operations. It's really similar 10 to you driving your car with, you know, lights lit in your 11 dash, because, well, you know, that's okay and these breaks 12 are okay. But, that's not the way to operate. That's an 13 example of an indicator, which I believe it will give you a 14 lot of insight in cultural. And, you know, I don't see why 15 we shouldn't pay some attention to it.
16 DR. APOSTOLAKIS: I agree.
17 MR. BARANOWSKY: -- in terms of the ones that are 18 connected more qualitatively to risk.
19 DR. BONACA: I just wanted to give an example --
20 DR. APOSTOLAKIS: That's fine. No , I think that's 21 very useful.
22 MR. BARANOWSKY: Okay.
23 DR. APOSTOLAKIS: Now, which slide will you jump 24 to, now?
25 MR. BARANOWSKY: Ne s , t:- 11 jump to number nine, ANN RILEY & ASSOCIATES, LTD.
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1 190 l 1 if you don't mind.
2 DR. APOSTOLAKIS: Ours are not numbered. So, it's 3 an interesting exercise to figure out what nine means.
4 DR. SHACK: Get today's package.
1 5 MR. BARANOWSKY: You don't have today's package?
6 They're not numbered?
l 7 DR. APOSTOLAKIS: Well, I marked up the one that 8 was mailed to me, so I don't -- but today's packages are 9 numbered?
10 MR. BARANOWSKY: They're different. We made some 11 changes in the viewgraphs, too.
12 MR. MAYS: It was trick to see if you were paying 13 attention.
14 [ Laughter . ]
() 15 16 numbered.
DR. APOSTOLAKIS: Well, what do you know, they're 17 MR. BARANOWSKY: Okay. We've actually shown this l
18 before, when we talked about the programs that we had, when 19 we were back in EOD. And what you see here are a number of 20 p;:ojects that we have ongoing from data, to industry-wide l
21 analyses, to plant specific analyses, all of provide some of 22 the building blocks for the development of risk-based 23 performance indicators. In fact, what we're talking about 24 doing is trying to have sort of an off-the-shelf approach to 25 building these indicators, wherein we take models, data, and r- ANN RILEY & ASSOCIATES, LTD.
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191 1 ' methodology that we developed for these other activities and
,/ 2 put them together, as building blocks, to come up with the
- 3. risk-based performance indicators, so we can try them out in 4 a pretty short peried of time. Now, not everything is going 5 to come off the shelf. Some things are going to take a 6 little bit of developmental work. But, our objective is not 7 to try and advance the state of the art in risk analysis 8 technology, but to take risk analysis technology that we 9 found that we could use successfully in the past, and then 10 just use it to build these indicators.
11 And the elements that you see, starting from the 12 bottom, you have the operational data. We have a number.of
- 13. raw data systems, some of which are fed by the nuclear 14 industry. For instance, the Equipment Performance
() 15 Information Exchange System, EPIX, some through NPO., and 16 others that are associated with data collected more directly 17 by NRC, such as LARS. They are provide the input to the 18 models.
19 In industry-wide analyses, we had developed the 20 framework for analyzing systems and components and for 21 pulling that information together in an integrated fashion.
22 'We presented both the methodology and the results at the 23 ACRS before and that information has been used, for 24 instance, to help define some of the risk-based inspection 25 areas that should be looked into. And we continue to do ANN RILEY & ASSOCIATES, LTD.
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192 1 trending of primarily industry-wide performance using that
/~N 2 analytic information and data. And, also, we are able to
)
(V 3 get plant specific results. The problem is that the data 4 density that we were working with prior to what we're trying 5 to do over here was fairly sparse and it took probably five 1 6 years or so to see a change in performance that was 7 statistically meaningful. But, now, we're talking about 8 making a few changes in the data and the way we're handling 9 it, to enrich the statistics, if you will, and we think that 10 we'll be able to see some changes a lot more quickly.
11 DR. APOSTOLAKIS: So, how should I read this 12 diagram, now?
13 MR. BARANOWSKY: What you should read this diagram 14 is that we came up with a number of programs that existed
() 15 16 that have --
DR. APOSTOLAKIS: Come closer to the microphone l 17 again, Pat.
18 MR. BARANOWSKY: We have a number of programs that 19 start with data, that gets fed up into models, that we i 20 perform analyses that are covering the kinds of areas that j 21 we're talking about having risk-based performance indicators 22 in. And then we have plant specific, what I call integrated 23 models, in which we can look at the more complete risk 24 picture associated with these piece parts to the risk.
25 DR. APOSTOLAKIS: But what do you call rx ANN RILEY & ASSOCIATES, LTD.
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193 1 industry-wide?
l 2 MR. BARANOWSKY: Industry-wide --
3' DR. APOSTOLAKIS: Includes plant specific 4 analysis. But, when you're doing initiating events, you 5 look at each plant; right? I 6 MR. BARANOWSKY: Okay. What I haven't explained l
7 is that we-have taken into account enough of the design and 8 operational differences in our models to account for plant l 9 specific differences. What we haven't done is modeled every 10 single thing in the plant. We've only modeled those things 11 that PRAs and the operational data has shown us to be 1
12 important, in terms of discriminating performance amongst 13 plants.
14 DR. APOSTOLAKIS: So, when you do an initiating
() 15 16 event study, you have --
MR. BARANOWSKY: Yes.
17 DR. APOSTOLAKIS: -- to look at each plant?
18 MR, BARANOWSKY: Yen. And we come up with an 19 industry-wide analysis, which has both plant specific 20 elements summarized over the industry. And that's what I 21 mean.
22 DR. APOSTOLAKIS: Okay.
23 MR. BARANOWSKY: And that's true for everyone of 24 these elements that we have in here. It's all plant 25 specific information, which is done for the full industry.
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194 1 So, we have essentially simplified models for initiating 2 events or components or systems, trains, and so forth, a 3 number of which we've presented at the ACRS. They're either 4 on a plant class or individual plant basis. And the model 5 only goes to the depth that we understand is.significant 6 from past PRAs and from the operating experience analyses 7 that were done, for instance, in the Accident Sequence 8 Precursor Program.
j 9 And the Accident Sequence Precursor Prc:l ram and 10 the models we'have there are undergoing some work, to make 11 them of sufficient quality, that we can use them to 12 integrate all the indications, whether they come from the 13 performance indicators -- what I haven't shown here is the 14 risk informed inspection results, which could also be folded 15 in through the Accident Sequence Precursor models, in order 16 to.come up with an integrated assessment. So that you would 17 then have your indicators at different levels, systems, !
18 trains, and so forth, as I showed in that prior viewgraph, I 19 or at the higher levels, if you want.
20 But, that's -- the point is all these are the 21 building blocks to get to that capability. And they're 22 ' pretty much in existence. Some of them need a little I 23 refinement. If they needed to be completely developed from 24 scratch, we'd be talking five or six years down the road to 25' do this project. Instead, we're talking maybe two.
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195 1 The other, I'think, good. thing about this is a 2 number of the analyses that are done on an industry-wide 3 basis are used to feedback into the regulatory process, 4 generic lessons learned.
5 DR. APOSTOLAKIS: The only box that's not here, to 6 me, the operator error probability studies.
7 MR. BARANOWSKY: Right.
8 DR. APOSTOLAKIS: Actually, why?
9 MR. BARANOWSKY: Why it's not what?
10 DR. APOSTOLAKIS: Well, I don't -- what do you 11 mean there? I mean, what --
12 MR. BARANOWSKY: We have --
13 DR. APOSTOLAKIS: What do you mean?
14 MR. BARANOWSKY: What we mean is we know, for
() 15 16 instance -- like, say, common caused failure is a special element of reliability and availability that needs to be 17 taken into consideration, in doing an analyses that aren't 18 apparent from just looking at, say, component failures, when 19- you're trying to do that. And the same thing we think is 20 true for operator error. You have to factor that-in somehow 21 into your model, to reflect the fact that there are going to 22 be some plant spec.fa: differences that aren't always 23 captured within the data that makes up the components or 24 system performance that relates to how well the operators 25 will perform during an accident, okay.
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196 1 DR. APOSTOLAKIS: So, this would include, then,
(} 2 the annual rate of plant. changes that are not incorporated 3 in the design basis document? Is that an operator error? i l
4 MR. BARANOWSKY: No. '
5 DR.'APOSTOLAKIS: What do you mean operator error?
6 MR. BARANOWSKY: What I mean by operator error is 7 I mean operator-fails to initiative, actuate, control, and-i 8 do whatever they have to do, to systems and components and l
9 so forth, during an accident. '
10 DR. APOSTOLAKIS: Would the Wolf Creek event be 11 here?
12 MR. BARANOWSKY: Yes. The one where he --
13 DR. APOSTOLAKIS: No accident; they started the 14' accident.
() 15 MR. BARANOWSKY: Right. You could -- it could be 16 an initiator. We didn't say it couldn't.
-17 DR..APOSTOLAKIS: I don't understand what you 18 would do with that. That was a fluke, right? Or was it i
19 systemic? How do you decide what's systemic -- 1 I
20 MR ., BARANOWSKY: Don't now. I don't have the 1
21- answer for that over here, but I am telling you that we need 22 to try.to factor that into the risk-based performance 23- indicators. Certainly, we would either account for that 24 through the inspection type finding, where we take the l 25 significance of the incident and' roll it up through some i ANN RILEY & ASSOCIATES, LTD.
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197 l'
sort of an integrated model; or we could capture several 2 events and if they seem to be through a model outside the 3 norms, then that would also give indication that there's a 4 problem.
5 I think there are really two ways of getting at 6- these things. One is if you have an event and it's 7 important on its own, you can deal with it. The other thing 8 is, if you have small things occurring over time, such as 9 equipment malfunctions or personnel errors, that 10 individually aren't important, but over time, when you have 11 them in a model, indicate that there's a problem, you have i 12 to deal with them in that way.
13 DR. APOSTOLAKIS: But, it seems to me, Pat, that 14 you have to, at some point, look at the root causes of
) 15 things. I mean, to say that at Wolf Creek, they created the 16 path because they opened the valves inadvertently, doesn't )
17 help you much, until you dig deeper to understand why that 18 happened. Fcr example, there may be a history there of 19 postponing work and doing'it at another time, without 20 checking what other things are scheduled for that --
21 MR. BARANOWSKY: Yes, I think we agree with that.
22' What we're saying is --
23 DR. APOSTOLAKIS: So, is that what you're doing 24 there?
25 MR. BARANOWSKY: Yes. What we're saying is either O ANN RILEY & ASSOCIATES, LTD.
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198 1 through the significance of the incident, itself, or through
(}
V 2 the accumulation of information on lesser incidents, you will determine you need to know the root cause.
s l 4 DR. APOSTOLAKIS: Okay.
5 MR. BARANOWSKY: This isn't a root cause program.
l 6 DR. APOSTOLAKIS: I understand that. So when are 7 you going to come here and talk to us about that program?
8 MR. BARANOWSKY: The root cause program?
9 DR. APOSTOLAKIS: Yeah.
10 MR. BARANOWSKY: That's be Alan Madison talking to 11 you about that.
12 DR. APOSTOLAKIS: Alan Madison again?
13 [ Laughter.)
14 MR. BARANOWSKY: No , that's part of our -- that's
() 15 16 part of our follow-up inspection. When a performance threshold is tripped, whether it's on an individual incident 17 or inspection finding, or if it's associated with 18 performance indicators that collect a number of pieces of 19 information, if you go over a threshold, part of that 20 investigation by the inspection folks is to look at the root 21 cause and corrective action.
22 MR. MADISON: It may be part of that. And it will 23 be the supplemental inspection activities that I talked --
24 that we're in the process of developing now. We're staffing 25 up to do that.
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199 l 1 MR. BARANOWSKY: So, we're not trying to provide j I
l
\ 2- indicators that.take the. place of that supplemental 3' inspection.
4 DR. APOSTOLAKIS: I'm sure Alan wants to come back 5- have the pleasure of another meeting.
6 MR. MADISON: Several more times, I'm sure.
7 MR. MAYS: I think we're also, George, missing-a 8 key point that's -- that Pat talked about earlier.
9 DR. APOSTOLAKIS: Is this the first time, Steve?
10 MR. MAYS: Let's see, last -- what was the time 11- frame? I think the key point is the -- in putting this 12 program together, as Pat mentioned, we're trying to make it i i
13 related to risk and consistent with the regulatory oversight 14 process. And one of the fundamental principles in
() 15 16 regulatory oversight process is that we're trying to get away from trying to figure out all the possible causes of 17 things going wrong and trying to control them at the Nuclear 18 Regulatory Commission, to a process where -- that's the
- 19. licensees job. And our job is to monitor performance and to 20 monitor it a level, where we can interface with them, when 21 that process isn't working. And our interface will become 22 -greater and greater, as the risk significance of that 23 process'not working becomes more and more evident.
24 So, I think that's the basic reason why we're not
.25 as interested in this program, in trying to come up with
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l 200 1 causal indicators, as -- we're not saying that they're 2 impossible, that they're not useful; we're just saying that 3 they're not exactly the same fit with the regulatory 4_ philosophy that's embodied in this new process.
5 'DR. APOSTOLAKIS: Well, we can discuss this. You l
6 have 26 minutes, Pat.
1 7 MR. BARANOWSKY: Right. And now I'd like to turn 8 it over to Steve, to go to the next chart, which is number 9 12.
10' MR. MAYS: And as a matter of fact, that was a 11 perfect lead in. There are two fundamental principles that 12 we're tr, 'g to maintain in this particular project. And 13 the first one was, we want to have the risk-based 14 performance indicators measure performance that's related to
() 15 16 the cornerstones in the reactive oversight process.
wa're not trying to put together some new process that's So, 17 brand new complete and conclusive just to replace it. We're 18 saying, what we find out from a risk-based perspective that 11 9 will make this process better. And we have a list of 20 several attributes that are listed there.
21 DR. APOSTOLAKIS: So, here, is where you will 22 define performance next time?
23 MR. MAYS: That's correct.
24 DR. APOSTOLAKIS: Okay.
25 MR. MAYS: And the second principle is, they have ANN RILEY & ASSOCIATES, LTD. j j Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 i i Washington, D.C. 20036 l (202) 842-0034 l
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201 1 to be related to risk, and we spent a lot of time already l /~ 2 talking about that. And that figure two that we had up l I
k.)T !
3 earlier gives you our concept of what we think that means.
l 4 And, again, to reiterate something we talked about before, 5- we're looking at progress versus perfection here. And our 6 purpose is_also not to go out and measure total plant risk 1
7 and then compare that against some standard. That's not 8 what we're about here. What we're trying to do is take the 9 performance as it is and assess its risk significance, 10 wherever we find it, and then be able to take regulatory 11 action in accordance with that risk significance.
12 DR. APOSTOLAKIS: Wait a minute. Take the 13 performance as it is --
14 MR. MAYS: That's correct.
( 15 DR. APOSTOLAKIS: -- and compare it to what's 16 expected from that plant.
i 17 MR. MAYS: That's correct.
l 18 DR. APOSTOLAKIS: Otherwise, what's significant; !
19 right?
20 MR. MAYS: Well, we had -- see, we have a whole 21 set of regulations out there that the plants are expected to 22 meet.
23 DR. APOSTOLAKIS: You're right.
24 MR. MAYS: And what we're dealing with is, when 25 t"=e plants are out there and we have a situation where ANN RILEY & ASSOCIATES, LTD.
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202 1 they're not meeting our expectations or they're doing
/"') 2 something differently than what our regulations do, the N_/
3 amount and the level and the nature of the involvement of 4 the regulator we're basically saying should be a function of 5 the risk significance of that performance deviation. And 6 that's what we're really about.
7 DR. APOSTOLAKIS: Right.
8 MR. MAYS: So, that, in essence, strains a lot of 9 things that might be in the general universe of things about 10 performance indicators --
11 DR. APOSTOLAKIS: Right.
12 MR. MAYS: -- or causes that limit what we're 13 trying to do, in this particular thing.
l 14 DR. APOSTOLAKIS: And what a plant at another part
) 15 of the country does is irrelevant.
[/
\_
16 MR. MAYS: So, the next thing I wanted to talk l
17 about on that --
18 DR. APOSTOLAKIS: Now, one other thing that we 19 commented on earlier. Desired attributes, would you like 1
20 them to be as high as possible in that top down thing?
21 MR. MAYS: You're getting down into the second --
22 two slides down from.me.
23 MR. BARANOWSKY: Do you mean in terms of measure 24 -- we can measure or calculate?
25 MR. MAYS: Yes, you're reading the script ahead of ANN RILEY & ASSOCIATES, LTD.
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203 1 time. If you put up slide 13 here, Tom. Some of the
{ 2 technical characteristics make things related to risk, and 3 we've talked about most of these-a]. ready. But one of the l 4 points that came up this morning, and I want to make sure we l
5 talk about here, is we want to have definitions for these 6 risk-based indicators. The cefinitions need to be 7 consistent, so the industry knows what it is we're looking 8 -for and how we're going to collect data and count it. But, l 9 there also has to be capable accounting for differences in 10 plant design. And you can do that a number of different l
- 11 ways, and 1'll talk about that and a little bit difference.
12 The second thing is: accounting for the 13 sparseness of data, and I've used this example before and 14 I'll put it out again, if we have 10- plants and they test a
() 15 16 piece of equipment 10 times a year, and there's one failure last year -- that would have been one failure in a thousand 17 test, and that would be roughly 10 to minus three 18 probability failure on demand. But if you go to that one 19 specific plant and look at the data alone, only in that 20 ' plant specific context, you get one and 10. That's two 21 orders of magnitude worse than the industry average, if you 22 take that kind of a look. Well, that would be 1
23 inappropriate. And so --
24 MR. BARANOWSKY: That's the count-based problem.
25 MR. MAYS: That's the count-based problem. This l
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204 1 is the problem that served as the basis for the many
() 2 3
discussions, . letters, and other stuff on trigger values --
DR. KRESS: Trigget values 4 MR. MAYS: -- that ve had with diesel generators l 5 years ago. And what we're trying to do is avoid that same 6 scenario coming again.
7 DR. APOSTOLAKIS: But, this issue was addressed 8 many years ago, when methods for developing plant to plant 9 variability curves were developed. The fundamental question 10 is whether the evidence that you just described for 1,000 --
11 not a 1,000 -- from 100 plants can -- whether the components 12 of those plants can be treated as being identical.
13 MR. MAYS: Or similar enough.
14 DR. APOSTOLAKIS: Similar enough, yeah. But, if
() 15 16 you can answer that question in the affirmative, then you can do this; otherwise, you can't. It's as simple as that.
17 MR. MAYS: Agreed.
18 DR. APOSTOLAKIS: So, I'm not saying that generic 19 information should not be used. What should be use is plant 20 specific information. Now, if you decide that something 21 that happened at another plant could happen in yours, that's 22- plant specific, too.
23 MR. MAYS: Agreed.
24 DR. APOSTOLAKIS: Okay.
25 MR. BARANOWSKY: No, I think we agree with what l
l 1
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( 205 1 you're saying, George, because, I mean, we would be using 2- that in some sort of updated procedure.
3 DR. APOSTOLAKIS: Sure; sure; fine.
4 MR. BARANOWSKY: Okay.
5 MR. MAYS: Okay. And the other thing is, we 6 wanted to have thresholds consistent with the regulatory 7 oversight process, that would identify a couple of things 8 for us: one, when deviations were occurring outside of what 9 the normal expected variation and the performance was and 10 when that continued to degrade to the point where it became l
11 risk significant at different levels.
12 DR. APOSTOLAKIS: Now, by the way, I know you 13 don't mean that, but the statistical fluctuations should not 14 be compared with the epistemic distributions, right? I r
() 15 16 mean, the epistemic distributions shows the variability in the mean value or the parameter value. The fact that you 17 had three occurrences instead of one is something else.
18 It's in the aleatory part.
19 MR. MAYS: Correct.
20 DR. APOSTOLAKIS: It's not clear in the 007 report 21 now, these things. I'm sure the authors understand these 22 differences, but it's not there.
23 MR, MAYS: Okay. So on the --
24 DR. APOSTOLAKIS: This is the first time probably 25 we have to deal with those underlying aleatory models. In fN ANN RILEY & ASSOCIATES, LTD.
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206 1 the PRA, you never do. You deal only with the epistemic, 2 the variability, the mean, and the medium, and that kind of 3 stuff. But because you are dealing with the real world, you 4 have to -- the aleatory model dels with the real world, not 5 the epistemic.
6 MR. MAYS: So the next thing I want to talk about 7 in some of the PI -- risk-based PI concepts we want to look 8 at was that we wanted to have the ability at the highest 9 level possible providing risk indication. If we had it and 20 could do it at the plant level for all the things associated 11 with public risk, that would be great and we'd want to do 12 that. I don't think we have the data and I don't think we 13 have the models to do it, at that level. So, we're going to i
14 go down to the next level where we came. And sometimes,
( 15 you'll get that directly through data and sometimes you have 16 to do it through data and models to build up to it. And 17 that's why we have a program here that will have information l 18 in-different levels.
19 The accident sequence logic from risk assessment is the tool 20 we're going to use for establishing the order and priority 21 of how we try to do this stuff. So we're trying to come up 22" with indicators that would have data from industry and peer 23 groups, as well as plant-specific.
24 When I say " generic data", I mean data from 25 similar plants and similar circumstances. I don't mean just ANN RILEY & ASSOCIATES, LTD.
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207
{
l 1 a number somebody came up with, and say that generically 1 1
2 applies. So,.we're looking to gather data in similar groups I
3 and similar structures that relates to that performance of 4 that group, and then apply probabilistic principles to 5 determine what the plant-specific performance is, related to
'6 that.
7 As we talked about the other indicators, one of 8 the interesting things is, we're not only going to'be
)
, 9 getting indicators as it would indicate from a risk model, i 1 1 10 For example, you can look at a BWR HPI system an d get I
11 information about turbo-driven pump performance and valve '
l '12 performance, and put it all together in that train 13 reliability. But again, the time between tests and demands 14 and that is pretty small, compared to what the expected 15 probabilities are, so you're not going to get very much on
(
16 plant-specific. And even when you use that 17 industry-combined data, you're going to have some 18 limitations on your data.
19 So, one of the ways we're going to look at this is 20 to also look at motor-operated valves, air-operated valves, 21 motor-driven pumps and other things across the plant to be l 22 able to see where the greater density - you may be able to 23 see some of the implications of some of those cross-cutting 24 issues that people seem to be concerned about. That's why 25 we have a common-cause failure database. That's why we have frg ANN RILEY & ASSOCIATES, LTD.
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208 1 component studies underway, to be able to come up and say,
/S 2 how would those kinds of causal factors manifest themselves b 3 into something that we can get counts on that is related to 4 risk. So, that's the purpose of doing that effort.
5 The other thing that was raised this morning is 6 about thresholds. Here's an example on this side about 7 thresholds. We may have the exact same indicator definition 8 for reliability of emergency diesel generators. But a plant 9 that has two diesel generators and needs at least one of 10 them in the event of a loss of off-site power to safely deal 11 with that particular initiator might have a different 12 threshold than a plant that has four emergency diesel 13 generators of a similar nature but only needs one of them to 14 be able to cope with the loss of off-site power.
( 15 So you should be able to get credit in your 16 performance thresholds for the amount of redundancy and 17 capability you have in the plants. That's one of the ways 18 you can deal with plant-specific issues.
19 Another way is a situation which we've used, the 20 example here of the AFW system. There are so many different 21 designs in the AFW systems, we came up with 11 plant classes 22 when we did the AFW study. And even within those classes, 23 there was variability among them.
24 What we would do in that case is try to come up 25 with indicators that are the piece parts of that, use the I
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i
209 1 models to come up with the reliability of those systems,
[^}
%J 2 then the threshold might be the same. If you go above an 3 x-number increase in the reliability of AFW system, that 4 transforms you into a particular white, green, yellow, or 5 red zone. But the particular model would have less 6 capability in it because you have had less trains. So we 7 would devolve it in that direction. So there's a couple 8 ways we can deal with that. We haven't made up our mind yet 9 on any particular ones, which one we're going to use, but we 10 intend to look at that to see which ones make the most 11 sense.
12 DR. APOSTOLAKIS: But my argument this morning was 13 not with the ways dealing with it.
14 MR. MAYS: It was whether we would do that. And 7x 15 the answer is, we are going to.
iV) 16 MR. BARANOWSKY: Well, let me say, we're going to 17 look at it.
18 DR. APOSTOLAKIS: That's a definitive answer, I 19 guess -
20 MR. BARANOWSKY: Before we say we're going - we're
)
21 going to look at it and see what the implications are.
22 DR. APOSTOLAKIS: You're going to think about it. .
l 23 MR. MAYS: In fact, a lot of the work that we're j i
24 going to do is run a number of test cases to see what the '
25 implications are. How much detail do we need, and does it
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210 1 make sense to put all this stuff in there?
2 DR. APOSTOLAKIS: When I say " plant-specific", I
)
3 don't necessarily mean, you know, that you have to take into l
4 account every little detail pertaining to that' plant. If 5 you' decide that for the purposes of this program, knowing 6 the numbers of trains, or redundant systems that you have, 7 is good enough, that's good enough for me too. You have 8 looked at it from the perspective of making it 9 plant-specific.
10 Now, in some cases, in some systems, they may have 11 -cross-ties, for example. And that may not be important, so 12 you will have a third category. But it doesn't have to be, 13 boy, for each plant, for each component, we're going to have 14 one number that's unique to that plant. I didn't mean that.
() 15 MR. MAYS: That's right. And there's a spectrum 16 there between having completely generic and being totally 17 plant-specific.
- 18. DR. APOSTOLAKIS: Exactly.
19 MR. MAYS: And what we're trying to do is find 20 some sort of a balance in there that's practical to do, that 21 maintains progress in this oversight process, as opposed to 22 perfection, and moving on. I just wanted to make sure you 23 understood, that you knew, that we understand that. We've 24' looked at enough data to tell us we think we can do that.
25 Juld we're going to go try and see where we can.
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211 1 DR. APOSTOLAKIS: Great.
2 MR. MAYS: The other thing about the structure 3 that we had here is that, when we talked about the highest 4 levels to the subsequent levels, one of the leading issues 5 we keep getting talked about is, what about leading 6 indicators? We want to know about things before they 7 happen.
8 Without getting into the causal discussion again, 9 if you think about that picture, what you see is that in 10 order for you to get to public risk, you have to have 11 several layers of things go wrong. So you can look at that 12 chart as, the bottom level as the leading indicators of the 13 next level, as the leading indicator of the next level, so 14 when you have to talk about leading indicators, their first
() 15 question is, leading of what?
16 So, what we have here is a structure that will 17 allow us to have indicators on multiple levels, where you 18 should be able to see and reflect what the implications are.
19 For example, suppose you had diesel generator performance 20 going bad, and reliability was decreasing. Well, what if, 21 at the same time, the loss of off-site power frequency was 22 getting lower and the reliability of the other mitigating 23 systems was going up? Well, right now you have no mechanism 24 for dealing with that.
25 But the kind of thing we're talking about in ANN RILEY & ASSOCIATES, LTD.
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212
!- 1 building an integrated model, you'll be able to put those 2- together in a logical sequence, based on accident sequence 3 logic, that would say, is that a big deal or is it not?
4 Similarly, one of the concerns that was raised in the 5 original framework was, what if you have a lot of little 6 things that don't seem to be very important? Well, supposed 7 of the reliability of diesels only went up a little bit, but 8 at the same time, for the BWR HPCI unavailability went up a l 9 little bit, and the RPCI reliability went up a little bit, 10 and off-site power frequency went up a little bit? ,
11 Together, those might be important.
12 DR. APOSTOLAKIS: It's like a million here, a 13 million there. Pretty soon --
14
() 15 16 MR. MAYS: Right. Pretty soon it adds up to real money, as Senator Dirksen once said. And so that's the purpose of 17 having indicators at multiple levels is to enable you to l
18 . deal with some of these issues that were raised, as we were 19- putting together this framework back in the workshop in 20 September of last year, It's not going to be perfect; it's 21 not going to capture everything. But it's going to be 22 progress. And that's why we're looking at.
23 DR. APOSTOLAKIS: So what you're saying then is 24 that a performance, a set of performance indicators that are 25 not risk-informed cannot be leading?
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213 1 MR. MAYS: No. We don't know what they're leading
~T 2 to. That's the problem.
(G 3 DR. APOSTOLAKIS: Well --
4 MR. MAYS: They could be leading, but we don't 5 know what.
6 DR. APOSTOLAKIS: Well, we had a very interesting 7 presentation by Scientech at the subcommittee meeting, where 8- they did make the point that, you know, something that was 9 leading, that is significant with respect to one criteria 10 may not'be with respect to another. For example, if you had 11 a cladding temperature as an indicators - you know, how far 12 you are from 2,200 degrees - that does not necessarily give 13 you, that is not necessarily a leading indicator with 14 respect to core damage frequency.
() 15 16 MR' . MAYS: Right. I agree.
DR. APOSTOLAKIS: So that's a fundamental 17 weakness', then, of a non-risk informed, performance-based 18 system.
19 MR. BARANOWSKY: That's our point. We agree with 20 that completely. You can have a lot of indicators that 21 -don't tell you very much useful information. But they just 22 get people confused about where to spend their resources.
23 MR. MAYS: Some of the limitations about risk 24 based PIs -- again, they're not going to be perfect and do 25 everything. If you have, for example, in this regulatory
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E 214 j 1 framework, the idea is you have indicators of some variance.
(~h 2 You get worse; we go look at you a little more.
V 3 But the simple fact of the matter is, we don't 4 have enough data to calculate the plant-specific steam 5 generator tube rupture frequencies. They don't occur that 6 often. So it would be senseless to put together a steam 7 generator tube rupture indication because, you know what?
8 The next one that occurs, we're going. We'll be there. And 9 we'll have inspection people out there and we'll be trying 10 to find out what happened and what the cause was and how to 11 fix it.
12- So, there's no point in making a risk-based 13 performance indicators on everything that's associated with 14 risk because some of them we're not going to have data for.
[N -)
15 And one occurrence is going to be enough to trigger our 16 increased regulatory attention. So we're not going to try I l
17 to put performance indicators into that area.
18 We talked earlier about - yeah. The risk-informed 19 . inspections is where we're going to rely on people to go and 20 look at the programs and the processes to try to keep those 21 particular infrequent events, keep them infrequent.
22 DR. APOSTOLAKIS: That's why you need --
23 MR. MAYS: And there's a lot of money being spent 24 right now between the industry on how to deal with steam 25 generator cracks, and all that other stuff, as mechanisms
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215 1 for preventing steam-generator tube ruptures, from both 2 financial and risk considerations. There's a lot of work 3 going on out there and we're not going to try to do that.
4 DR. POWERS: Let me ask, this class of things that l 5 -you need to have indicators on because they are so very 6 risk-significant that they're going to attract attention the 7 first time you have one. I mean, that's like, a steam l 8 generator tube rupture, as you're saying. The steam 1
9 generator tube - people generator tube. People are going to 10 be interested in that.
11 Is this a complete set that you've listed up here, l
l 12 or is there a broader set of these?
! 13 14 MR. MAYS: That's not necessarily the complete
() 15 set. We're trying to convey the concept that as we're going 16 through and determining which risk-based performance !
17 indicators we can do and are practical to do, one of the 18 things we're going to do is take the principle that if it 19 has a long period of occurrence, such as data's sparse, and 20 it's such a situation that regulatory attention would be 21 focused on it regardless, then that's a candidate for not 22 putting together one. That's the principle and what we 23 wanted to get some agreement on. I don't think that's l
24 necessarily a complete list in this slide, but it's 25 exemplary.
l 0
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.3 216 I
1 MR. BARANOWSKY: But the other important part is 2 that thetc would be risk-informed inspection tied around 3 that because the consequences are potentially high.
4 DR. POWERS: How about risk-significant scrams, 5 unplanned?
6 MR. BARANOWSKY: Well, they're in between, 7 probably.
8 MR. MADISON: Again, I think you're getting into 9 the supplemental inspection activities. I described - the 10 reactive inspection is going to be more kind of a broad 11 scheme that's going to go all the way from the 12 risk-significant scrams up to an IIT or an ARG, up to the 13 f TMI event, is the scope of the development of that process.
14 DR. POWERS: Really, what I'm understanding is,
() 15 16 you've got a principle here and I think you're inviting us to comment on things that don't need an indicator because 17 they're so significant that they're going to attract 18 attention. I'm just trying to understand the bounds on what 19 your thinking is right now. How about inadvertent control 20 rod movements?
21 MR. MAYS: I don't know if we have an answer for 22 every one of them, to be honest with you. ,
23 MR. BARANOWSKY: I don't know.
24 DR. APOSTOLAKIS: That's one that, those are items 25 that have caused substantial amounts of regulatory attention O ANN RILEY & ASSOCIATES, LTD.
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217 1 at a couple of plants here in the recent years, that maybe, maybe that wasn't necessary.
") 2 So I'm just wondering where 3 that stands.
4 MR. BARANOWSKY: Personally, I wouldn't put it in 5 there, but we really haven't gone through all these types of 6 things the way you're talking.
'7 DR. BONACA: But activity management is a major 8 issue in the industry. I mean, that would fall right into 9 that category. For example, INPO has paid a lot of 10 attention to the issue, and driven it in the -- so, it's 11 significant.
12 MR. BARANOWSKY. It could go to into an operator 13 performance indicator.
14 DR. POWERS: And I think, you know - I mean, that
( 15 particular one, it seems to me what you're wrestling with is 16 the kind of thinking that INPO would have, which is, that's 17 really a bad thing to do. I mean it's just bad conduct of 18 operations to be moving, jerking around your control rods in 19 ways that you don't know.
20 On the other hand, from a regulator's point of 21 view, because nothing happens in there and it is difficult 22 to see how control rod movements result in core damage with 23- any kind of probability at all, that the regulator may well 24 want to take that one and say, okay, that's an indicator -
25 that's a mark against his inventory of bad operator
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218 1 performance. And if he gets enough of those, then he has a i
2 decreasing trend in operator performance, and that probably 3 raises questions about his training program and things like 4 that, that I need to go and inspect.
5 DR. BONACA: That's exactly right. What I mean 6 is, you went to the training now. The bigger issue, in 7 fact, is not necessarily an individual event, but the fact 8 that if'you have a significant sequence of minor events --
9 one may be rod movement; then you have a slight boron 10 dilution, or something is happening out there; or you have a 11 number of events that you classify as activity management.
12 And then you look at your program and you're saying, this 13 guy does not understand some of the basics.
14 So that's really where you come back, and now you
() 15 16 have a higher indicator that you want to look at because that indicator there is telling you something very 17 substantial. It means that maybe your training program is 18 not adequate. Maybe there isn't sufficient respect for the 19 core in the power plant. So --
1 20 DR. POWERS: It's understanding when you use an '
21 event, a happenstance, as the springboard for giving close 22 attention - in and of itself - versus using it as just one 23 more checkmark in a demerit list, that if it gets too big, 24 then it prompts you.
25 MR. BARANOWSKY: I think that it's the latter that ANN RILEY & ASSOCIATES, LTD.
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L 219 1 we would be thinking about, not a particular event but just 2 some modest error, t
O 3 DR. POWERS: But you know what I'm talking about.
4 MR. BARANOWSKY: Yeah, I know what you're talking 5 about. I've seen them. I mean, it provoked a huge amount 6 of response.
l 7 DR. POWERS: Which under this system - I don't 9 know. It may or may not. But it would seem like it would 9 not.
10 MR. BARANOWSKY: Alone it might now, but taken in l
11 the context of a number of other things, it might be quite l 12 important. It might be just the straw that broke the 13 camel's back at that point.
14 DR. APOSTOLAKIS: Did you say insufficient reapect j
() 15 16 for the core, Mario?
DR. BONACA: Yeah.
17 DR. APOSTOLAKIS: I like that.
18 DR. POWERS: I mean, that's the concern.
l 19 DR. BONACA: Because there is -- what you do, you 20 tend to have people who have run the plant for a long time, 21 they become complacent. They don't understand the 22 implications of this.
23 DR. POWERS: And it happens so easily.
24 DR. APOSTOLAKIS: It's just the expression that I 25 like. Not the content - the content I understand. The ANN RILEY & ASSOCIATES, LTD.
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220 1- expression.
/"T 2 DR. BONACA: We always hate to talk about how -
V. 3 you know, what kind of power there is inside that.
4 DR. APOSTOLAKIS: So do people go and pay their 5 respects to the core in some plants?
6 DR. POWERS: It's - when you're working with high 7 energy processes, who work well, through those periods of 8 times, you get this tendency toward the cavalier.
9 DR. BONACA: Yes.
10 DR. APOSTOLAKIS: Yes.
11 DR. POWERS: And you say, I can do anything to 12 this and it's okay because I know this system. And those 13 are the ones that bite you.
14 DR. BONACA: We had an example this morning with 15 regard to working with nitric acid in the lab.
16 DR. POWERS: Oh, yeah. Would you have respect for 17 that?
18 DR. BONACA: Oh yeah, one had better.
19 20 MR. MAYS: That's all we need, by definition all 21 we'll take.
22 Okay, this table here is designed to give you -
23 it's probably what you'd call a target-rich environment.
24 But what we've done is indicated, in the two phases that 25 we're looking at working on - risk-based performance l
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221 1 indicators -and we've tied these things to the corner
~
l 2 stones, as well as to operating modes of the reactors.
3 We've given you an indication of, visually of how i
4 much more depth and breadth we're trying to cover in terms 1
of making progress in this process of risk informing the 5
6 oversight process. You can see where there are several 7 indicators that we're looking at right now that we've at l
8 least gone and done a preliminary look and say, is this ones l 9 we think are worthy of going after? So if you don't see one 1
l 10 in here, it means that so far we haven't found it worthy of 11 going after, but we'll be happy to take into consideration 12 any of the ones that you think we ought to.
l 13 DR. APOSTOLAKIS: Do you want to identify those as 14 you go along?
() 15 16 MR. MAYS: Yes.
DR. APOSTOLAKIS: Because fire frequency doesn't 17 mean anything to me.
18 MR. MAYS: Well, the fire frequency was one we 19 were looking at to see what it is we could come up with 20 related to add power as an indicator of performance.
21 Everybody will agree that the frequency of fires can be an 22 important contributor to risk, but it's not the complete 23 picture.
l 24 DR. APOSTOLAKIS: Well, what fires? See, that's 25 important in my opinion.
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222 1 MR. MAYS: That's correct. But we have to go - we 2 have a fire report that we put out and you guys have seen.
3 We classified different levels of significance of fires.
4 And we're looking to see what we can use with that to 5 determine what we can put together as a performance 6 indicator.
7 The key thing for you to look at here is that 8 issues associated with the barrier cornerstone are primarily 9 going to be for phase II, which means we're not going to be 10 looking at them right now. Our primary focus on phase I is 11 on the initiating event and the mitigating system
- 12. cornerstone, and putting together an integrated indicator 13 for which there is no integrated cornerstone, but that would 14 take into account those two cornerstones and put them
( 15 together in a risk structure so we'd be able to come up with 16 a little better picture of what the risk significance of 17 things were as we go through this process. I 18 MR.'BARANOWSKY: And also, not only just 19 mitigating systems and so forth, but shutdown conditions i
20 versus power. I think we have a pretty significant deficit i 21 there that we're looking to try and fill as soon as we can.
1 1 1 22 DR. APOSTOLAKIS: Good. Anything else?
23 DR. POWERS: Well, I guess the target-rich 24 environment that you advertised there, it really comes to 25 maybe the words that are associated with Table 1.
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223 1 The basic premise is, utilize readily available i t
("% 2 data and methods and models that are already developed. ,
3 That's an enormous constraint, it seems to me. Why? Why l
l 4 can't you make use of data that are not so readily 5 available, or why is it not possible to develop models?
6 7 MR. MAYS: It's not that it's not possible. It's 8 not that it's not possible to get additional data that we 9 either don't already have or are expecting to get. As Pat l
L 10 mentioned earlier, we're expecting to get some significant 11 amounts of new data and new data density through the 12 voluntary reliability and availability reporting that we're 13 getting through EPICS, which was in response to our proposed 14 rule.
15 We got the first batch of that data in a month or 16 so ago, and we're loading it up into that rad system, which 17 is the developed database that you see on that program l l
18 slide. So we are taking advantage of stuff not only that's 19 current.'y off the shelf, but that is going to be on the 20 shelf very shortly, in putting these together.
21 The biggest issue with respect to doing brand new 22 projects was, if we wait until we get to develop new stuff 23 and get new data, we're going to be three, four, five years 24 down the road before we make any improvements or any changes 25 to the current reactor oversight process. j l
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224 1 And in light of some of the current concerns about
(~ 2 limitations that have been already expressed, we thought it 3 was a more prudent course to take stuff that we already had 4 available that might answer some of those concerns. That 5 might broaden the risk coverage of the indicators and the 6 risk focus of the inspection activities to make a more 7 robust system now while we can and then build this as an 8 iterative process, rather than try to wait until we got a 9 really, really good one five years from now and then find 10 out that maybe it really took six or seven years to be a 11 really, really good one and in the meantime had nothing in 12 between.
13 So that was the concern we had. We wanted to make 14 some consistent, real progress in a fairly short time 15 period. There's nothing fancier than that as the reason for
[
16 wanting to do that.
17 DR. POWERS: I mean, that sounds very laudable -
18 get something that's better than what we have right now.
19 It's not contributing to what I would call regulatory 20 stability by any means. l 21- MR. MAYS: I think the --
22 DR. POWERS: Continuously generating the PIs.
23 Every time I turn around, it gets very difficult to know how 24 to run a plant.
25 MR. BARANOWSKY: Well, I think we're not trying to ges . ANN RILEY & ASSOCIATES, LTD.
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225 1 just generate PIs for the sake of generating.them.
I
(~'g 2 MR. MAYS: We're going out and talking to people V 3 about what indicators we have now, and what we're going to 4 have to rely on through inspection, and how to combine those 5 two together in a coherent process, that's more coherent 6 than we have now.
7 And we've from people inside the agency and from 8 people outside the agency that they have concerns about some 9 of the capabilities and limitations that we have now.
10 So what we're saying is, let's go ahead and try to 11 address those issues that we can. I recognize that that 12 will be new PIs and new data, but we're trying to get data 13 and information that's either currently reported in EPICS, 14 or currently reported in to INPO's SSPI indicators, or 15 current information to minimize that kind of impact on 16 people. And we're trying to put the ones together that we 17 can get general agreement will have an impact on the way we 18 do business in a positive way that makes it more logical and l 19 coherent and predictable to the industry. We're not just 20 going to do any old indicator because we can. We're going 21 to sue indicators that we can agreement that adds pretty 22 much value to the process, otterwise we wouldn't be going, l
23 DR. POWERS: If.I look at this table, it seems to 24 me that in comparing current and proposed - refining, 25 expanding and refining your performance indicators in an ANN RILEY & ASSOCIATES, LTD.
O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
226 1 area that you already have for many of them. Some sort of 2 an indicator. What I don't see is a table that says', here 3 are those areas that currently I don't have very good 4 performance indicators. They're the security safeguards, 5 . radiation protection -- sort of security and safeguard sort 6 of things. And I don't see a corresponding slide that says, 7 here's how I'm going to attack those problems.
8 MR. BARANOWSKY: I guess our corresponding slide 9 is, we're not going to attack security and safeguards, or 10 radiation safety cornerstones. They aren't within this risk 11 framework.
12 MR. MAYS: 17.
13 Now, if someone said, please do
~
MR. BARANOWSKY:
14 something with those and come up with better indicators, we
() 15 would give it a shot. But that's not the kind of area that 16 we necessarily have the expertise in doing. I think we know 17 how to develop indicators, but on the first set of 18 cornerstones is the areas that we do have the expertise to 19 do that in. I 20 And by the way, that's the bulk of what we're l i
going to be looking at as a regulatory agency anyhow.
21 We're 22 only covering a small fraction of the risk with the current 23 indicators.
24 DR. POWERS: Well, at least from what we head this 25 morning, we were presented with some flowcharts that posed ANN RILEY & ASSOCIATES, LTD.
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227 L.1 challenges to me to try to answer the questions in the other 2 ' areas. And so I gttess it surprises me that a research l 3 organization doesn't want to attack those juicy targets.
l:
4 Not many footprints in that sand.
5 MR. BARANOWSKY: I'm not saying that we don't as a 6 research organization. I'm saying this project is not doing 7 '
it; it could. happen elsewhere.
8 DR. APOSTOLAKIS: So you're final thoughts.
9 MR. BARANOWSKY: Just the schedule, I guess, 10 MR. MAYS: The schedule slide indicating - that 11 was asked earlier. We're looking to complete our definition 12 of the candidate set of risk-based performance indicators 13 .and start apply the data we're getting from EPICS and other 14 things to see which ones we can put together and use, and 15 which ones make sense.
16 We plan on coming back in the November timeframe l
17 to talk to ACRS about which ones we were able to put 18 together, what they showed us, what they didn't show us, why 19 we decided to do.or not do things. Then we would go to the 20 Commission, and then go out to the public, with the proposed 21 risk-based performance indicators and see what kind of l
22 comments we got about those. And then after responding to 23 those comments, getting more data on an analysis under our 24 ~ belt, we would complete the final set of risk-based 25 performance indicators and come.back in November of 2000 to l
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228 1 ACRS and the Commission, and with their blessing would start
~T 2 implementing them in January 2001.
(Y 3 So, the current PI report that you've been used to 4 seeing that was done in AEOD and is still being done in this 5
branch when we removed research - the Year 2000 would be the 6 last one of those you would see. And in 2001 it would be 7 replaced with a new set of indicators, which would be these 8 risk-based indicators.
9 DR. APOSTOLAKIS: So the indicators that you use, 10 Alan, in your pilots, preliminaries --
11 MR. MADISON: Those are, that's the set we're 12 going to go with as far as implementation of the program.
13 That's the ones that we've gotten. Remember - the 14 performance indicator program for the oversight process is a
() 15 voluntary reporting program by the licensees. And we have 16 agreement in that program with what we have. We'll have to 17 go through - in addition to the process that Steve's i
18 described, we're going to have to go through a process of I 19 review in the industry to get industry buy-in so that they ;
20 continue the voluntary reporting program. Otherwise, we're 21 going to be in the process of writing a regulation.
22 MR. BARANOWSKY: Well actually, all the 23 information we're talking about here, I believe, is 24 currently being reported voluntarily or planned to be 25 reported voluntarily. So it's not new information. I mean, ANN RILEY & ASSOCIATES, LTD.
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F-229 1 we're mindful of that situation.
2 MR. MADISON: Yeah, it will go through - I don't 3 think that process is going to be, going to slow up the j 4 ' implementation that Steve described. But we'll have to do 5 that in conjunction with that.
6 DR. APOSTOLAKIS: Okay. Any other -- you're not 7 requesting a letter? This is just information. Any 8 comments from the members? Thank you very much, gentlemen.
9 It was very useful, as usually. Back to you, Mr. Chairman.
10 DR. POWERS: And I will recess until 3:15, 11 [ Recess.]
12 DR. POWERS: Let's come back into session for the .
l 13 third in our trilogy. And that is a discussion of the 14 performance-based regulatory initiatives, which I assume are
() 15 16 different than those that we've already heard about.
once again, we call on Professor Apostolakis.
And l
17 DR. APOSTOLAKIS: Thank you. We wrote a letter ;
18 back in April of '98 after we had a presentation by the 19 Staff on what we're planning to do on performance-based 20 regulation, which we really performance-based regulation 21 without the benefit of risk information, as I recall. We 22 made some recommendations, which were not really used by the 23 Staff when they met with public stakeholders.
24 The Subcommittee on Probabilistic Risk Assessment 25 and the Subcommittee on Regulatory Policies had a joint ANN RILEY & ASSOCIATES, LTD.
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230 1 meeting last April 21st, when we had a presentation on NUREG g% 2 CR-5392, Elements of an Approach to Performance-Based b 3 Regulatory Oversight. There was a number of issues that 4 were raised at the time. There was an interesting 5 discussion on leading indicators.
6 The contractor showed, that, as I said earlier, '
7 what is a leading indicator with respect to one particular 8 criteria may not be leading enough with respect to another.
9 But they also presented what they called the diamond tree, 10 which at a very high level tries to show how management 11 actions and practices affect programs, and then hardware, 12 and so on. And some members - that one got mixed reviews, 13 As I recall, some members liked the idea of a 14 high-level diagram that showed how all things came together.
N 15 Other members, including me, felt that it was too high-level (G 16 and not of much practical use. And it was another name 17 really for influence diagrams.
18 An accommodation was made at the time - or at 19 least the Subcommittees felt that it would be useful to have 20 an approach to this issue, similar to the one the Staff 21 followed when they developed the Regulatory Guide 1.174.
22 Namely, state a set of principles and expectations before 23 you start developing the performance measures. I don't know 24 I whether :he Staff plans to do this. '
25 One other development after that meeting is that ANN RILEY & ASSOCIATES, LTD.
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231 1 the Nuclear Energy Institute sent a letter to the Chairman, i I
2 I believe, where they - no, to Mr. Rossi - where they argued 3 that this research program is not needed because we already 4 have two performance-based initiatives. The first one is l 5 the one we discussed today on the oversight process, and the ,
l 6 second, the efforts to make 10 C.F.R. Part 50 risk-informed.
7 I must say, I myself am a little bit perplexed.
8 Why? What is the objective of this program, and why is it i
9 needed? I'm sure we'll hear something about it today. So, 1 10 with that, I will turn the floor to the Staff, and Mr.
11 Kadambi, it's yours.
12 MR. KADAMBI: Thank you -
13 MR. ROSSI: Mr. Prasad Kadambi's going to give the 14 presentation for the Staff. Some of it is the same as what i 1
15 you saw the last time, and it reflects everything that we
( )
16 have learned and discussed since the last time we met with 17 you. So with that, I'll let Prasad go ahead. I would like
'18 to point out that this effort is now in the Regulatory 19 Effectiveness Section of the Regulatory Effectiveness and 20 Human Factors Branch in the new research organization.
21 DR. APOSTOLAKIS: Can you finish by 4:15, do you 22 think?
23 MR, KADAMBI: I believe we can, 24 DR. APOSTOLAKIS: Okay.
25 MR. KADAMBI: Thank you very much. Good f-~ ANN RILEY & ASSOCIATES, LTD.
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232 1 afternoon, Mr. . Chairman and members of the ACRS. Basically, 2 what I'll present this afternoon will be an abbreviated
}
3 version of the presentation on April 21st, augmented with 4 some insights that we've had from additional input.
5 This is just an outline of the presentation I 6 expect to make. We did meet with the Subcommittee, as you 7 mentioned. At the time, we thought that we would not have i 8 the time to meet with the full Committee, but we did get an 9 extension on the Commission paper that was due at the end of 10 May and is now due at the end of June. And so I guess we 11 have this opportunity for additional input.
12 We've used the inputs received so far to define 13 more clearly, I hope, what we intend to achieve within the 14 available resources. In this presentation, what I'd like to
() 15 emphasize is what I feel is the statement of the problem 16 that we are trying to address, as articulated in a series of i 17 questions, which I will get to toward the end of the 18 program.
19 This is briefly an overview of the presentation.
20 I believe the Committee has copy, a draft copy of the 21 Commission paper that we had sent around for concurrence 22 review with the offices. As a result of the review process, 23 we have learned about many performance based activities that 24 are currently going on, and what we seek to do is to l 25 integrate and coordinate all the other activities. Some of ANN RILEY & ASSOCIATES, LTD.
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233 1 these are, as you mentioned, a' revision to the reactor r
fV- '} 2 regulatory oversight process, the risk informing of 10 3 C.F.R. Part 50, 4 There is also the ongoing effort with regard to 5 the maintenance rule and the implementation of Appendix G, 6 the performance-based part of it.
7 Also, there are many activities within NMSS that 8 really do fall in the category of improving the 9 performance-based approaches, application of 10 performance-based approaches. Basically what we want to do 11 is leverage our modest resources to learn about the benefits 12 and drawbacks of performance-based approaches. What we will 13 focus on, our observation of what is going on.
14 Based on the observations, you know, we would hope
/ 'N 15 to develop a technical basis for addressing questions on V
16 performance-based approaches. And these questions are 17 those, right now, that I'll address later on in the 18 presentation, based on the inputs that we've received so far 19 from various people, including the ACRS Subcommittee.
20 DR. APOSTOLAKIS: Now, are the last two bullets, H21 something that the speakers of an hour ago really are 22 addressing as well?
23 MR. KADAMBI: Certainly, and that's the point I'm 24 -trying to make, is that this is really part of a lot of 25 other things that are going on in the agency. And we want to g ANN RILEY & ASSOCIATES, LTD.
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1 234 1 really integrate it with the. ongoing efforts, and at the 2' same time provide 3 DR. APOSTOLAKIS: Can you remind us what the SRM 4 -said?
5 MR. KADAMBI: I'll have a separate slide on that.
6 DR. APOSTOLAKIS: Okay.
7 MR. KADAMBI: Just to set the stage, historical 8' background - this is rather text-intensive here. But the 1 9 point of the slide is to show that the Commission has 10 provided a lot of guidance on performance-based approaches.
11 It goes back to 1996. !
)
12 You know, we dealt with direction setting issue i 13 12. And the strategic plan also has specific language on 14 it. In 1998, there were two SECY papers, one on i
()
'15 performance-based approaches, and the other, the white paper on risk-informed performance-based regulation. The white 16 !
17 paper was finalized on March 1, 1999, and that provides
.18 quite specific guidance in preparing the plans. And the SRM 19 from the SECY 98-132 on February lith very clearly lays out 20 the specific elements that the Commission is looking for.
21- The white paper, this is basically an extraction 22 from the language of the white paper dealing with 23 performance-based regulatory approaches. These are the 24 attributes that are associated with it.
25 The first is to establish performance and results ANN RILEY & ASSOCIATES, LTD.
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235 1 as the primary basis for regulatory decision making. I 2
believe that this is tied to the Government Performance and 3 Results Act, GPRA, as we call them. It requires us to do 4 this.
5 There are four attributes that have been 6 identified. These are words directly out of the white 7 paper, I believe. To some extent I have summarized.
8 But, the first one is that " parameters either 9 measurable or calculable should exist to monitor the 10 facility and licensee performance."
11 The second is, " objective criteria to assess 12 performance are established based on risk insights, 13 deterministic analysis, or performance history." So what 14 this says, I believe, is that risk insights are not
[} 15 necessarily the only source of the criteria, but, you know, 16 I guess it depends on the particular situation where 17 performance-based approach is being applied.
18 The third highlights, I think, one of the expected 19 benefits of performance-based approach, which is 20 flexibility. "The licensees, if the performance-based 21 approach is applied correctly, should have the flexibility 22 to determine how the performance criteria are met, and 23 hopefully it will encourage and reward improved outcomes."
24 DR. APOSTOLAKIS: I'm sorry, I don't remember. I 25 thought'there was a period after established performance ANN RILEY & ASSOCIATES, LTD.
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236 1 criteria. 1This is a new thing now, in ways that will l 2 encourage _and reward outcomes?
! -(
3 MR. KADAMBI: That's in the --
4 DR.-APOSTOLAKIS: The white paper?
5 MR. KADAMBI: The white paper.
l 6 DR. KRESS: What does the "in ways" refer to?
7 MR. KADAMBI: I guess that's the implementation of 8 the --
9 DR. KRESS: Implement the rule in such a way.
10 MR. KADAMBI: Right.
11 MR. ROSSI: Well, I think the idea is that if you 12 have a performance-based rule that provides licensee a i i
13 moderate amount of flexibility, that will encourage them to 14 find better ways to meet the performance criteria and even
( 15 ' exceed them in some cases, in a cost-effective way. I think l 16 that's the intent of this.
17 DR. KRESS: That flexibility will automatically 18 give this.
19 MR. ROSSI: That flexibility, right.
20 DR. KRESS: Okay. I understand that.
1 21 MR. KADAMBI: The fourth attribute, I believe, is l
! 22 equivalent to providing a safety margin expressed in 25 performance terms. That is, " Failure to meet performance 24 criterion will not, in and of itself, constitute or result 25 in an immediate safety concern."
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237 1 Now, what the white paper also says is that these t'Sg 2 things could be done either using the regulation, license
(_/- 3 condition, or regulatory guidance that is adopted by the 4 licensee.
5 DR. UHRER: Just a quick question -
6 " performance-based approach" here implies that these are I l
7 almost deterministic results. That is, you either performed l
8 satisfactorily or not. Is there an implication that this !
9 would be automated? That there would be a - as an attempt 10 to eliminate judgement?
11 MR. KADAMBI: Not at the level we are talking 12 about right now, which is - I don't think you can ever l 13 eliminate judgment as a practical matter. But in terms of l
14 how the criteria are established and how the decision is
() 15 16 made, whether the criteria are met or not, the second attribute speaks to that by saying that the assessment of 17 performance that are established based on risk insights or 18 deterministic analysis or performance history.
19 DR. UHRIG: But I was looking at the words 20 " objective criteria" in that second bullet. That implied to ;
21 me that it might be an attempt to eliminate judgment. Okay.
22 You've answered the question.
23 MR. ROSSI: I think that one of the examples that 24 I think you've very recently heard about, if not today, is 25 the Reactor Inspection and Oversight Program improvements, ANN RILEY & ASSOCIATES, LTD.
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238 1 where they have a green band, a white band, .etc.
( 2 DR. UHRIG: Yeah.
3_ MR. ROSSI: And that's probably a very good 4 example of performance-based approach to the teactor 5 oversight process. There, they use mitigating events and 6 that kind of thing. And there was judgment used in setting 7 the criteria, but I do not believe that that could be 8 automated. That is an example where you use risk techniques 9 to establish the parameters you're going to measure and the 10 criteria that you're going to use.
11 DR. UHRIG. Okay. Thank you.
12 MR. KADAMBI: This is where, Dr. Apostolakis, we 13 will address the specific elements of the SRM to SECY 14 98-132.
/~ l (T;
15 The first one says that all the programs offices 16 should be involved in identifying candidates for 17 performance-based activities. It has become clear that 18 there is a lot going on in the program offices, and our 19 Commission paper should reflect that. We expect that it 20 will.
21 The second is that the Staff should take advantage 22 of pilots to improve understanding and maturity. Again, 23 there are many pilots going on in NRR as well as NMSS, and 24 we will certainly learn from these pilots.
25 The solicitation of input from industry is a ANN RILEY & ASSOCIATES, LTD.
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239 1~ continuing effort, industry and other stakeholders. We've 2 done quite a bit of it in the past, and there's a lot going 3 on there also. And again what we intend to do is take 4 advantage of what's going on.
5 DR. POWERS: Let me bring you back to your 6 _ question on pilots, or the issue on pilots. We formulate 7 these pilot programs, we get some plant to volunteer to 8 participate in the pilot, and somebody says okay, this 9 pilot's going to go on for, to pick a number, six months.
10 How do we decide that six months is an appropriate time for 11' a pilot?
12 I guess what I'm asking you overall, is there any 13 technology, any insights on how you design pilots?
14 MR. KADAMBI: Not that I know of, but there may be
() 15 16 others who know better. l DR. POWERS: Why isn't there?
17 MR. ROSSI: Well, I think that the criterion is a !
18 qualitative one that's used, and that is that you want to i 19 have the pilot go on for a long enough time to collect some 20 meaningful information to allow you to know how well it's 21 working, but you also don't want it to go on for so long 22 that you cannot bring the pilot to an end and make a 23 decision on whether you should implement a permanent change 24 by rulemaking or something of that sort.
25 DR. POWERS: But how do I decide --
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il 240 1 MR. ROSSI: But I know of certainly no systematic
(/)
2 3
approach that's been used other than what I just described to decide how long a pilot ought to go on.
4 DR. POWERS: But we're making -- I mean, we seem 5 to have pilots going on for everything I can think of.
l 6 Pilots to the left of us, pilots to the right of us. If l
7 they are really going to volley and thunder, it seems to me 8 that.there ought to be some sort of understanding on what {
9 constitutes a good pilot and what constitutes a so-so pilot.
10 We don't have any bad pilots. .
('
11 MR. ROSSI: Well, I think when you do a pilot, you l
12 want to look and see, you know, how do the licensees feel 13 about that new approach to whatever it is that you're having 14 a pilot on compared with something that's purely
() 15 deterministic, whether they think that it does give them l 16 tlexibility, whether they believe it reduces their cost or 17 increases it, whether they believe that it creates a lot of 18 additional confusion in dealing with the NRC on whether they 19 have met the regulations or not. Those are the kind of 20 things that you look at. And then the time period --
21 DR. POWERS: So really the pilot is more for the 1
22 licensee and less for the NRC? l I
23 MR. ROSSI: No, I think it's also for the NRC, i 24- because I describe what the licensee would be looking for.
25 What the NRC would be looking for is the degree to which l
(
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o 1 241 1 they believe that they can judge whether the licensee is or
('\ 2 is not meeting the rule that is used to have a 1
'O.
3 performance-based approach and whether what is being done is 4 maintaining the proper level of safety, whether we can make 5 objective decisions on whether the licensees are or are not 6 going the proper kinds of things. So I think it's both 7 ways, both the NRC and the licensees try to learn those l 8 kinds of things from the pilot.
l 9 DR. POWERS: It just seems -- always seems curious 10 to me when a pilot for inspection and assessment doesn't go 11 through a full fuel cycle.
I I
12 MR. ROSSI: Well, I think -- I don't know how long 1 l
13 they're going to go through the oversight process, but I 14 think that's --
( 15 DR. POWERS: Six months?-
16 MR. ROSSI: I don't know whether it's going for a 17 full -- is it going six months?
18 . DR . POWERS: It's six months. I mear it's not 19 even --
20 DR. SEALE: Well, it's gotten started a little i 21 earlier than that.
l 22 DR. POWERS: But, I mean, you don't see everything 1
23 unless you go through -- you may not see everything going l 24 through a full fuel cycle, but at least you have a chance of 1
25 seeing most things.
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242 1 Let's continue.
/g 2 MR. KADAMBI: Okay.
N_)
3 MR. ROSSI: Well, at six months you see a variety 4 of things. You may not -- depending on the number of plants 5 that you have pilots at, you may see the kind of things that 6 extend over a whole fuel cycle in total. But you also don't 7 want the pilot to become a permanent thing that goes on 8 without coming to a decision and making something permanent.
9 MR. KADAMBI: In addition to pilots, the SRM l
10 suggested that we should incorporate the experience from the l l
11 maintenance rule and Appendix G. It also said that a plan '
12 should be submitted before expending additional resources.
13 Right now we're planning on about less than one ;
14 FTE effort, and incorporate the existing activities,
/ '\ 15 comments from the Commission, and by comments from the Q
16 Commission I believe is meant the various SRMs that have 17 been issues in this area, the DSI-12 paper, and the 18 strategic plan, et cetera, the ACRS and other stakeholders, 19 and we've I believe done these.
20 It also says to consider providing guidelines and
,1 21 simplifying the screening and review process for selecting 22 activities.
23 Lastly, it directs really that we should look for 24 opportunities in new rulemakings, and the suggestion is made l 25 that when it goes out for public comment, when a rule goes l
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F-243 1 out for public comment, the question should be asked whether I
/ 2 some requirement is overly prescriptive. But in terms of k 3 what s going on, the process that the staff follows, this is 4 a place where the rulemaking activity plan, which is a 5 compilation of all the rulemaking activities going on, 6 including NRR and NMSS, would be very useful. So these are j 7 the sorts of ongoing activities that we can take advantage j 8 of.
9 Now, on April 14th we had a stakeholder meeting 10 here and we solicited proposals based on a set of questions.
11 I would like to just go to the questions and then come back 12 to the slide. The questions posed to the stakeholders i 13 recognize that risk information is hard to apply in some l
l 14 areas such as quality assurance, security, fitness for duty, 15 et cetera, and we asked for input on where performance-based
[}
16 approaches may provide a more cost effective way to address l
17 these regulations.
18 We asked for suggestions that cover NMSS types of 19 activities. The methods, tools and data, these are all I 20 think reasonable obvious sorts of questions and, you know, 21 we also brought up the ongoing activities such as the l 22 reactor regulatory oversight process and the revisions to i 23 Part 50.
l l 24 DR. APOSTOLAKIS: Doesn't your first bullet, I
( 25 though, send a message that you view performance-based ANN RILEY & ASSOCIATES, LTD.
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244 1 approaches as competing with risk-informed approaches?
() 2 MR. ROSSI: No, I don't think it does. As a 3 matter of fact, I wanted to address that first question up 4 there, because I believe one of the major intents of looking 5 separately at performance-based approaches was to complement 6 the use of risk-informed techniques in performance-based 7 approaches and look to see whether performance-based 8 approaches csuld be used in areas that were not readily 9 amenable to reliance on PRAs.
10 And as Prasad indicated, we had the stakeholder 11 meeting in April. We also had the same subject on the 12 agenda at a stakeholders meeting with the industry on 13 September 1st in Chicago, and we made a concerted effort to 14 solicit input from the stakeholders that attended these
( 15 meetings on specific examples or specific areas where would 16 could indeed look at applying performance-based approaches 17 to rules, regulations, other areas of the regulatory 18 process. And we basically got no specific new ideas beyond 19 the things that had developed in the regulatory oversight 20 and inspection improvement process. And I think the NEI 21 letter that came in in response to our stakeholders meeting 22 in April did not have any additional areas that they felt 23 ought to be taken on at this point in time.
24 So we have looked very hard at finding areas that 25 are not amenable to the use of PRA for applying O ANN RILEY & ASSOCIATES, LTD.
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'4 245 1 performance-based approaches. And I believe these areas
(} 2 exist, but I think what the situation is right now with the 3 stakeholder is that they are very interested in the reactor 4 oversight and inspection process and what is going on there.
5 In NMSS, I believe both NMSS and their licensees are very 6 interested in pursing the things that are underway now and 7 there is a reluctance to take on other areas beyond those at 8 this particular point in time.
9 And so a J ot of what we are deciding to do is 10 based on that kind of scakeholder input and the fact that we 11 do have a lot of performance-based approaches underway now 12 that we feel we can learn from. Now, I recognize that the 13 ones that are underway now to a large extent, at least in 14 the reactor area, depend on the use of PRA, but,
() 15 nonetheless, I think we will be able to learn from them.
16 And so I think the real key is that eventually what we want 17 to'do is to address the questions that are in Bullets Number 18 1, 4 and 5 in areas that are not so amenable to PRA. But it 19 may very well be that at this point -- that this is just not 20 the point in time to be aggressive in that area, which is 21 the reason that we are suggesting doing what we are 22 suggesting here today.
23 MR. KADAMBI: Going back to the stakeholder input, 24 these are some of the issues that were raised, and I think 25- the first one addresses the question you just raised. And I O ANN RILEY & ASSOCIATES, LTD.
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246 :
1 believe that the relationship is a complementary one and 2 they are not competing with each other, I
())
(-
3 l
i People wanted to know the relationship of the l f
4 performance-based activities to other NRC programs, and as j 5 of right now, we don't really have a road map to offer on 6 this, and some of the things that we are proposing to do '
7 will hopefully help in that.
8 Going down, I believe what the two --- the written 9 comments that we received afterwards constituted quite 10 significant, I think, inputs as part of the stakeholder 11 input. There was one attendee who proposed a concept of a 12 composite index, collateral or composite index, and NEI 13 comments suggested that the oversight process revisions and 14 the Part 50 rulemaking revisions were sufficient
/N 15 performance-based activities.
16 I believe ACRS has received --
17 DR. APOSTOLAKIS: Now, let me understand that. I 18 thought the staff was trying to risk-inform Part 50, not to l 19 make it performance-based. Is that correct? Or both? ;
l 20 MR. KADAMBI: Well, one of the objectives stated ;
21 in 98-300 is to make it as performance-based as practicable, !
22 I believe.
23 So the stakeholders also suggested that, you know, 24 the rules -- at least the general feeling was that the rules 25 themselves may not be overly prescriptive, but, you know,
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I l 247 L
L l
1 some other aspects of how they are implemented may create
~% 2 the kinds of problems that are observed, and that it is (d
l 3 important to learn.the lessons of some of these ongoing 4- activities such as the maintenance rule, et cetera.
5 DR. APOSTOLAKIS: What is the bullet skepticism 6- relative to accuracy of cost benefit analysis?
7 MR. KADAMBI: Well, I think that was -- I figured l 8 that would come up. One of the questions we asked was, will l
9 work in the quest for performance-based regulations be cost 10 beneficial? And I think, you know, this was a reaction to 11 that. That is Question Number 3, one aspect of it, so.
12 DR. APOSTOLAKIS: Do people really understand what 13 the performance-based system is?
14 MR. ROSSI: Well, I think that we discussed the 1
() 15 16 characteristics that Prasad has on the one slide here, and they are pretty clear. I mean there are four attributes of l
l 17 performance-based approaches, and I believe they are quite 18 clear. So I think people did indeed understand what is l 19 meant. And I believe generally people that that is what 20 being done in the current effort on the reactor oversight 21 and inspection program, is to do exactly that. And now that 22 the challenge that we had hoped we could address was to find 23 other areas that weren't related to the PRA, to pursue 24 performance-based approaches on. And, again, that is 25 complementary to risk-informed regulation, it is not in ANN RILEY & ASSOCIATES, LTD.
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248 1 competition. It is certainly complementing. And I think 1 2 you can use, obviously, use the risk-informed techniques
.3 al.ng with performance-based approaches. I think that in 4 many cases they go together, 5 DR. APOSTOLAKIS: Maybe the skepticism is related 6 to the costs that:will be incurred to switch to a 7 performance-based system. In other words, I am not looking 8 at a steady system where you have a system, you see we have 9 a system already.
10 DR. KRESS: I think there is a longstanding 11 skepticism in the industry about how NRC does it cost 12 benefit analysis, particularly with respect to the costs.
13 This may be just a carryover.
14 MR. ROSSI: Well, I think there are also concerns 15 on the cost to the industry of the maintenance rule, which
(}
16 was a performance -- basically, a performance-based rule, 17 which may have driven some of this also.
18 DR. APOSTOLAKIS: So are you saying then, Prasad, 19 that the stakeholders present were not too enthusiastic 20f about all this, is that correct?
21 MR. KADAMBI: The bottom line is they did not 22 offer very specific suggestions when invited to by the list 23 of questions, and there was -- it wasn't very clear that 24 anybody said, you know, the staff should be giving this very 25 high priority and doing much more than we already are in it.
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l 249 l
1 MR. ROSSI: And you do have the NEI letter that
i
{J 2 3
states what Prasad just said I think pretty clearly.
believe that that is meant to mean at this particular point But I 1
4 in time. I don't think it is for all time in the future.
5 But I am reading that into their letter.
6 DR. APOSTOLAKIS: I am reading it the same way.
7 DR. KRESS: Do we have any other information on 8 the composite index concept?
9 MR. KADAMBI: The letter from Mr. Jones is all 10 that I have. I think it offered some interesting ideas 11 which right now I can't really say very much other than, you 12 know, having read it and tried to understand what was said.
13 MR. ROSSI: I assume that letter has been 14 available to the --
( 15 MR. KADAMBI: Yes.
16 DR. APOSTOLAKIS: Yes. Making it available and 17 making sure we understand are two different things. We 18 certainly need to have somebody explain more. Do you 19 understand it, Prasad?
20 MR. KADAMBI: I believe I do.
21 DR. WALLIS: Can I ask something naive here? If I 22 were to try to choose between doing A and doing B, I would 23 want to have a measure of whether A is better than B. And 24 that seems to me you are always faced here with making 25 choices. Should we make regulations this way or that way?
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c-250 1 Should we choose this path or that path?
( 2 And here we have got some kind of sort of l 3 incantations or something, risk-informed, performance-based.
l 4 I mean they are quasi religious or virtuous concepts, and, 5 yes, you should do more of it. But when you are choosing 6 between doing A and doing B, I like something like cost 7 benefit where you can actually add things up and say A is 8 better than B. I think what you see in the case of 9 risk-informed and performance-based, how I get measures of
- 10. whether doing A is better than doing B.
11 MR. ROSSI: Well, the first thing I think you 12 .w ould do when you have an A and a B, generally, you have an 13 A, and generally A is the way you have done it in the past 14 or the way you are doing it today, and you are looking for a
() 15 B that is a better way. And so the first thing you do is 16 you compare B with A in both a qualitative and quantitative 17 way and, to whatever degree you can, a cost benefit way, and 18 decide that, yeah, B really looks better than A.
19 And then what we are currently doing pretty much 20 within the agency is we are doing these pilots which gives a 21 better indication of whether B is really better than A to, 22 as I indicated before, both to the licensees and to the NRC 23 staff. And.I believe, as I indicated before, that that is 24 the major purpose of the pilots before you, ingraining this 25 thing in concrete and offered up to -- or required cf 0
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251 1 everybody.
i
' (} 2 DR. WALLIS: But this business of, say, applying a 3 principle of risk-informed, it sounds good, it makes sense, 4 but has anyone sort of shown that if you do it in a risk-informed way, then B will be definitely much better
~
5 6 than A? Is there some measure of how much it is better?
7 MR. ROSSI: Well, the reactor plant oversight I 8 process is probably one of the very large efforts underway 9 within the agency, and we are working with the industry 10 there, and we are going to have pilots. So I think we are 11 going to determine whether the risk-informed approach is or 12 is not better.
13 DR. WALLIS: Okay. So what is it you measure 14 about the pilots that tells you it is better? Is it that
() 15 people are happier?
16 And costs are reduced?
17 MR. ROSSI: No. I think you get an indication of 18 the costs and efforts involved and the degree to which both 19 the NRC and the licensees can come to agreement on what 20 should be done.
21 DR. WALLIS: Well, that's what bothers me, is that 22 if it's just that two sides come to an agreement, that 23 doesn't give me any objective measure of whether it's a good y 24 one.
25 MR. ROSSI: Well, it's certainly that the industry
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252 1 is going to look heavily at the cost, and the NRC is going
/i 2 to.look very hard at whether they believe -- and it may be V
3 qualitative belief -- whether they believe safety is being 4 maintained as well or better with B than with A.
5 And it may be a qualitative thing, although we do 6 have a number of measures, very quantitative measures, of l 7 risk now, and I think you just heard that this afternoon in 8 the risk-based performance indicators. They are a very l 9 good -- should be a very good measure of how safety is 1
10 changing.
11 DR. WALLIS: Well, let me assert that if you do 12 your cost-benefit analysis right, then the payoff ought to l-13 show up there.
14 MR. ROSSI: I would agree with you. No question 15 about it.
16 MR. KADAMBI: Okay. Moving on to the ACRS 17 Subcommittee input, the main messages that I carried away 18 from the April 21 meeting were that the staff should 19 continue to develop answers to the question that was )
1 20 addressed last year as the result of the SECY paper that we l 21 were working on then, how and by whom performance parameters 1
22 are to be determined and deemed acceptable, and how to place )
1 23 acceptance limits on them. And that is one of the things I i
24 believe we'll be able to address through the plans or at i 25 least the element of the plans that we are proposing.
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L 253 1 I believe the Subcommittee would also, I think as l
2 Dr. Apostolakis mentioned, the staff should seriously 3 consider developing a guidance document analogous to 4 Regulatory Guide 1.174, and also I believe there was a 5 suggestion that some kind of a pilot application of the 6 currently available methods should be considered.
7 These were the three main points that --
8 DR. APOSTOLAKIS: I'm not sure it was stated that 9 way, to tell the truth.
10 MR. KADAMBI: If it isn't, perhaps, you know, I 11 can correct --
12 DR. APOSTOLAKIS: I don't remember, t1 ?gh, the 13 exact formulation, but we certainly did not urge you to jump 14 into a pilot application before, for example, addressing the
() 15 16 first two bullets. That was my impression, unless another Member recalls differently.
17 Mike, do you remember, perhaps? ]
18 MR. MARKLEY: I don't think it was anything that ;
l 19 strong. It was discussed.
20 DR. APOSTOLAKIS: It was discussed. l 21 MR. MARKLEY: I don't believe individuals made a 22 recommendation to that effect.
23 DR. APOSTOLAKIS: Yes.
24 MR. KADAMBI: Well, that's fine. It was just 25 something --
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I 254 1 DR. APOSTOLAKIS: So the third one is a little bit 2 fuzzy.
l' 3 MR. KADAMBI: Okay. Thank you.
4 DR. APOSTOLAKIS:
But the first two I think are 5 definitely recommendations from the Subcommittee.
6 MR. KADAMBI: Okay.
7 By way of a summary of all of the inputs that we 8 have received, the ongoing programs in the other offices
- 9. represent quite significant efforts that we intend to take 10 advantage of. There were no specific suggestions received 11 from stakeholders that that would drive us towards any 12 specific, proposing any specific projects.
13 The NEI letter of May 13th suggests that the two 14 big projects-going on should be considered sufficient for 15 the performance based area.
16 DR. WALLIS: I'm surprised about Number 2. If it 17- is a good idea, someone ought to say, gee whiz, if you 18 really used it for this problem we would be so much better I
19 off. -There ought to be some enthusiasm.
20 MR. ROSSI: Well, again I think that there are 21 areas that eventually we are going to get suggestions on. I 22- think the situation is that we are pursuing some major 23 efforts now with the industry and their belief is that we 24 probably have enough to do in those areas in the area of 25 performance based approaches to not warrant trying to expand s
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255 1 it aggressively into other areas.
J
/) 2 DR. WALLIS: With the hope that you will then as a
\~) l 3 result of what you are doing now find some real successes to '
l-4 report and then there will be real embracing of the concept?
I 5 MR. ROSSI: I think that is the crux of what we 1 6 are suggesting on our very last slide, as a matter of fact, 7 is exactly that, is to make sure we know sbout all of the 8 performance based efforts that are underway within the NRC 9 and to follow those closely and learn from them and then try 10 to expand out over time from that, but let me not do the 11 rest of Prasad's -- j i
12 MR. KADAMBI: Thank you. Let me just go ahead and 13 get to that point.
14 The next two slides are basically, as I mentioned A
( 15 earlier, a series of questions which involved I believe an
)
16 elementary planning process in which the statement of the 17 problem should be made and in this case what I am trying to 18 do is use a series of questions to do that.
19 I am basically using the input from the 20 Commission, the ACRS, and everybody else says, you know, 21 what are you doing about these things? For example, how are 22 performance and results providing the basis for regulatory 23 decision-making?
24 DR. APOSTOLAKIS: Do you mean that to end there?
l 25 Do you mean how are performance results providing the basis?
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256 1 MR. KADAMBI: Well, I am taking the words out of
('~3 2 the white paper. It says " Regulatory decision-making should V
3 be based on performance and results." I mean I think 4 implied in it is the fact that there is a measurement of 5 performance and that leads to results which are perhaps the 6 outcomes, what we call outcomes these days, so this is a 7 combination of the performance indicators as well as the I 8 specific outcomes.
9 And the parameters that are used, what are they?
10 Are they directly measured or are they based on a l
11 calculation or an analytical model, and how and by whom were ;
1 12 they determined? This is the sort of question one could ask 13 about an ongoing project. To what extent --
14 DR. WALLIS: Is performance-based unique to NRC or
('~S) 15 isn't there some history of using performance-based approach ,
l 16 in some other application, where it was shown to work and 17 learn from how it was done?
18 MR. KADAMBI: I believe that there is plenty of l 19 evidence that it is being applied elsewhere, but I am not 20 aware of anyplace where something like the list of 21 attributes that we have tried to incorporate into a 22 performance-based approach has been articulated in this way, 23 but the NUREG CR-5392 that the subcommittee heard about, you 24 know, does have a literature search in which there were 25 examples given of other agencies that have tried to employ l
(
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257 1 performance-based concepts.
2 And when we are talking about specific projects, 3 we can ask whether it's being implemented through a 4 regulation, license condition, or a regulatory guidance, and 5 these are the sorts of lessons that we can expect to learn.
6 Now in terms of --
7 DR. WALLIS: It's strange, I'm sorry, following I
8- up , but I mean in something like car safety, you have seat 9 belts and air bags. Now the real criterion should be that l
10 your car doesn't kill as many people as it did before.
11 These are just -- and performance-based should be based on l
12 fatalities rather than on acquiring a certain kind of --
13 DR. SEALE: Appliances.
14 DR. WALLIS: Appliance. That would be 15 performance-based regulation, wouldn't it?
16 MR. ROSSI: Well, I think the maintenance rule is 17 probably an example where they look for l 18 maintenance-preventable failures, and that's their criterion 19 as to whether they exist or not, and that's the criterion by 20 which you adjust the maintenance program. So that's kind of 21 analogous to what you're talking about with seat belts, I
- 22. think. But obviously we have to start well before we have 23 any kind of fatalities. I mean --
l 24 DR. WALLIS: That's a case where we have measures, j 25 though, we have fatalities, we have tens of thousands or O
\
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258 1 something, and yet it doesn't seem to be a performance-based
..\ 2 regulation that's used.
(d' 3- MR. ROSSI: Do you mean for the automobiles?
4 DR. WALLIS: We have a real -- all kinds of 5 measures of how well we're doing in a way that we don't have 6 so obvious 3v in nuclear.
7 DR. APOSTOLAKIS: But I think the State of Montana 8 has decided to reduce the speed limit again back to 55 or 9 65?
10 MR. ROSSI: It's 75. It's 75.
11 DR. APOSTOLAKIS: Just last week.
12 MR. ROSSI: That was 75, I'm quite sure, 75.
13 DR. APOSTOLAKIS: Because last year --
14 DR. SEALE: It's 75 now,
'r~sg 15 DR. POWERS:
( f I'm not sure that seat belts and 16 Montana are part of the discussions here.
17 DR. APOSTOLAKIS: No, but it was 18 performance-based. Last year the number of deaths went up, 19 and they attributed it to the lack of a speed limit.
20 DR. POWERS: Again, I'm not sure it's part of 10 21 CFR Part 50.
22 DR. APOSTOLAKIS: I'm sure it isn't.
23 DR. POWERS: I think we should stay on the subject 24 I guess is my point.
25 MR. KADAMBI: Thank you, Mr. Chairman.
l
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259 1 DR. WALLIS: I just mentioned it because it all 2 seems so vague to me.
)
I'm trying to tie it down to d~ 3 something I understand. If I could see an example in the
,4 nuclear industry where --
5 '
MR. ROSSI: Well, I think the oversight process I 6 think has a number of-things ~. I mean, they're tying things 7 like' initiating events that occur at a plant, safety system 8 reliability and availability, they're tying those things 9 back to the risk of a core damage accident, they're setting 10 criteria on~them, and they're looking, you know, they're 11 looking at those things that are directly tied to risk. And 12 that's a very quantitative approach. So I think that's a 13 very good example, the risk-based performance indicators, of 14 doing that. And that will allow performance-based decision 15 making.
( But it's tied to the PRAs.
16 DR. WALLIS: Well, again, the payoff is not in 17 using something, it's in some other measure of success.
18 That's what I guess I'm getting at. You don't get rewarded l 19 for using performance-based, you get rewarded because some 20 other measure of something has improved as a result of using 21 this-method.
22 MR. ROSSI: Yes, I would assume that in the case 23 of the risk-based performance indicators you can plot the 24 risk of the plants as a function of time and see if --
25 DR. WALLIS: Show some success.
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E 260
{
1 MR. ROSSI: Right. I think you can do that. f e- 2 g MR. KADAMBI: And if we used the attributes of
- 3 performance-based approaches, what it says is that there 4 should be additional flexibility. So, you know, one of the l
5 things that we could ask is how is the flexibility being l
l 6 accorded to the licensees. And, you know, is the 1 7 flexibility being used for improved outcomes. And improved 8 outcomes may be reduction of unnecessary burden or, you j 9 know, improving the safety margins if that's what would be 10 indicated by the risk analysis.
11 For example, if the safety margin is decreased i
12 inordinately when the performance criterion is crossed, then i 1
13 it would indicate that the safety margin is not sufficient 14 and should be increased. Whereas on the other hand if there
)
15 is no change in safety margin even if the performance l
i 16 criterion is crossed, it may mean that the safety margin is l
17 much more than is needed.
18 Those are the types of questions that I believe --
19 DR. APOSTOLAKIS: Actually I think your third 20 bullet from the bottom should be rephrased, because, I mean, l 21 it's related to the question we just discussed. I don't l
1 22 think you have sufficient experience to make this judgment.
23 MR. KADAMBI: Right.
24 DR. APOSTOLAKIS: But it seems to me the question 25 really should be can we design a system for determining l p ANN RILEY & ASSOCIATES, LTD.
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[ 261 1 performance goals that would translate to a predictable l ,r T 2 safety margin as providing a basis for consideration of
(_) 3- changes.
1 4 In other words, that's the heart of-this: Jan you 5 come up with an approach to determining these performance 6 goals? I would not call them criteria. Goals. That would 7 give you a confidence I guess, would contribute to your 8 confidence that the plant is operating safely. Because 9 you're not going to get this message from experience. I 10 mean, we hardly have performance measures operating.
11 MR. KADAMBI: Well, you know, the idea is at least 1
l 12 for right now to look at what's going on across the Agency 13 in these multitudes of projects.
14 DR. APOSTOLAKIS: I understand that, but, I mean,
() 15 16 you say planning for performance-based approaches.
MR. KADAMBI: Um-hum.
17 DR. APOSTOLAKIS: Can you define an approach or 18 devise an approach that will achieve this? That you will be 19 confident if all the performance goals are met then that the 20 plant is safe, or meets a certain safety goal.
21' MR. KADAMBI: I guess I don't know the answer to l 22 the question.
23 DR. APOSTOLAKIS: I know you don't. I don't 24 either.
25 MR. ROSSI: I think what you're suggesting is that ANN RILEY & ASSOCIATES, LTD.
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262 1 we need to rephrase that --
2 DR. APOSTOLAKIS: Yes.
-3 MR. ROSSI: As a question. We ought to ask 4 ourselves to make judgments on the effectiveness of the 5 performance-based approaches. That's what you're saying.
6 So it's a matter of not answering the question now but 7 rephrasing the question and asking that question as we look 8 at all the performance-based --
9 DR. APOSTOLAKIS: In other words, can you remove 10 experience from there. I mean, can you logically define 11 something like that.
12 Okay, you have minus one minute.
13 MR. ROSSI: Okay. I would like to point out that 14 I think many of what Prasad has done here is he's tried to 15
( collect the things that we ought to look at, both 16 qualitatively and quantitatively, in judging the 17 performance-based approaches, and many of these I think were 18 covered in questions that you asked, like cost-benefits and 19 a number of the others are the things that we talked about 20 even before we got to these slides in the meeting.
21 DR. APOSTOLAKIS: Why shouldn't we agree with NEI?
22 MR. ROSSI: I beg your pardon? Why should we 23 what?
24 DR. APOSTOLAKIS: Why shouldn't this committee 25 agree with NEI that the agency is doing enough in this area
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263 1 and should stop this effort?-
2 MR. ROSSI:
O, Well, first of all, the effort -- why 3 ' don't we talk about that with.the last viewgraph?
, 4 DR. APOSTOLAKIS: Fine.
5 MR. ROSSI: Because the last viewgraph may be --
6 that may answer your question.
7 DR. APOSTOLAKIS: Good. Go to your last 8 viewgraph.
! 9 MR. ROSSI: So we are very clearly not going to 10 take an aggressive approach to this thing, so we are close 11 to doing what you suggested. We are going to expend modest 12 resources in this area and do the things that are up there.
13 DR. POWERS: When I look at that list I am 14 hard-pressed to find a product coming out of this work.
() 15 16 enhance.
I see observe -- develop if appropriate --
I don't see "and by doing this work we will be 17 able to do something tomorrow that we cannot do today." l 18 MR. ROSSI: We are not guaranteeing that we are l 19 going to -- the product up there, by the way, would be l 20 develop guidelines based on the efforts to better identify 21 and-assess issues and candidate the performance-based 22 activities, and we say "if appropriate" so the product would 23 be developed if our observations indicate that'that is an 24 appropriate thing to do.
25 Basically what is being suggested is that we --
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l 264 1 and we have already done a lot of this -- we clearly collect
()
G' 2 the list of all the things that are under way in the agency 3 that are performance-based activities by comparing the 4 activities with the characteristics of performance-based 5 approaches, so we know what is going on and we feel that 6 there's going to be a variety of these sorts of things that 7
we can then learn-for and we will look and see if we can 8 learn things from them to apply them in other areas.
9 You will notice that the last bullet up there says 10 that we, based on what we do we will either institutionalize 11 or terminate this activity, depending on what we observe.
12 But we still believe that there must be areas 13 where performance-based approaches can be used to address i 14 rules that are not amenable to addressing through the PRA
(" )
\_ /
15 approach. That may not be correct. I mean we may find that !
l 16 everything that people think of to apply performance-based 17 approaches is dependent upon the use of PRA. I doubt if 18 that is going to be the answer but it may be. If it is, 19 then we jump to the last bullet up there I guess.
20 DR. POWERS: Well, I certainly listened this 21 morning to people struggling with how they would do 22 performance-based approaches in connection with radiation 23 protection and safeguards and security and things like that.
24 I just don't see how this helps.
25 You can't do those with PRAs but I don't see how ANN RILEY & ASSOCIATES, LTD.
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l 265 1 this effort helps.
~
2 MR. ROSSI: Well, I.think what this effort is l 3 going to do is follow what is done. I mean this is an 4 agency-wide program. It is not a separate program. What 5 the tie with this effort is is that we will follow what-they
-6 are doing in the areas of radiation and security and see how 7 they are going about it, see what the answers are to the 8 various. issues raised on the previous two slides and then 9 look to see if that can be carried into other areas.
10 This is not going to address what is done in the 11 radiation area or the security area. It will learn from 1
12 those.
13 MR. KADAMBI: What I would like to point out is a 14 lot of these activities are going on right now. I mean we
() 15 16 don't necessarily know what there is to learn from it until we really do try to pose the kinds of questions that the 17 Commission has implied, I believe, in articula. ting the 18 attributes of a performance-based approach.
19 The other point is that there is an SRM over there 20 that the Commission says, you know, the Staff should give us 21 answers or respond, address these items and really we are 22 proposing based on what we see happening in the Staff and 23 with the limited resources available what we can do right 24 now, and hopefully if there is something, if there is a gold 25 mine out there, you know, this will lead us to it.
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266 1 DR. WALLIS: Well, the gold mine could be that the
-~ 2 regulations are far too conservative and that if you really ,
~#
3 redesign them based on all these principles that there will 4 be a tremendous pay-off in terms of productivity of the 5 industry. That could be. I'm just speculating. I am not 6 saying that that is necessarily the case at all, but if 7 there's a gold mine it's got to be something like that.
8 MR. KADAMBI: And that could well come out of even 9 a modest effort like this, that there is a lot of margin 10 over there.
11- MR. ROSSI: I suspect that that particular gold 12 mine that you described would be found by several of the 13 different things that are going on now complementing one 14 another to help lead that way.
15 MR. KADAMBI: Mr. Chairman, that's my 16 presentation. Thank you.
17 DR. APOSTOLAKIS: Any other questions, comments?
18 Thank you, Prasad.
19 MR. KADAMBI: Thank you very much.
1 20 DR. APOSTOLAKIS: Back to you.
21 DR. POWERS: I think we can go off the l 22 transcription at this point-,
23 -[Whereupon, at 4:23 p.m., the meeting was 24 ' recessed, to reconvene at 8:30 a.m., Thursday, June 3, 25 1999.]
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I l
l REPORTER'S CERTIFICATE l This is to certify that the attached proceedings
! A
() before the United States Nuclear Regulatory Commission in the matter of:
l NAME OF PROCEEDING: MEETING: 463RD ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) i CASE NUMBER:
PLACE OF PROCEEDING: Rockville, MD I
,e
( ,/ were held as herein appears, and that this is the original j transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
h h Mark Mahoney l Official Reporter Ann Riley & Associates, Ltd.
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