ML20216C626

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Reports Status of PRA Implementation Plan for Period of Jan-Mar 1998
ML20216C626
Person / Time
Issue date: 05/01/1998
From: Callan L
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-98-096, SECY-98-096-01, SECY-98-096-R, SECY-98-96, SECY-98-96-1, SECY-98-96-R, NUDOCS 9805190360
Download: ML20216C626 (39)
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{{#Wiki_filter:1 l .ce.e.e................. f#~ %'o RELEASED TO THE POR e e s shul 48 i Teo inme %,,.....j POLICY ISSUE May 1 1998 SECY-98-096 EQB: The Commissioners FROM L. Joseph Callan Executive Director for Operations

SUBJECT:

QUARTERLY STATUS REPORT ON THE PROBABILISTIC RISK ASSESSMENT IMPLEMENTATION PLAN PURPOSE: To report the status of the Probabilistic Risk Assessment (PRA) Implementation Plan (PIP) for the period January 1 to March 31,1998.

SUMMARY

This paper describes accomplishments and changes to the staff's PIP for the period January 1 to March 31,1998. The principal accomplishments in this first calendar quarter of 1998 are transmittal to the Commission of the final version of the stanc'ard review plan (SRP) and associated regulatory guide (RG) documenting general guidance or risk-informed decisionmaking for changes to the plant-specific licensing basis; transmittal of final tersions of SRPs and associated RGs for (J '/ risk-informed inservice testing (IST), technical specifications (TS), and graded quality assurance (GQA); completion of an additional eight Maintenance Rule baseline inspections; issuance of a preliminary IPEEE insights report; completion of an additional eight preHminary IPEEE reviews; /))3/y issuance of a special study related to service water system operating experience; and completion of important milestones regarding staff training. The principal changes are transfer of Activity 1.7, " Regulatory Effectiveness," from NRR to RES; transfer of Activity 2.3, " Support for NRR Standard Reactor PRA Review," from RES to NRR in accordance with the Staff Requirements Memorandum 9805190360 980501 PDR SECY 98-096 R PDR CONTACT: NOTE: TO BE MADE PUBLICLY AVAILABLE IN 5 Ashok Thadani, OEDO WOPIING DAYS FORM THE DATE OF THIS PAPER 415-1705 _gy g ggj gp y e Erp!$, ar54ca xo Oy)-f ((+^/ /

The Commissioners 2 (SRM) on DSI-22; and inclusion of a new Section 6, " Reactor Enforcement," summarizing activities in the risk-informed enforcement process. BACKGROUND in a memorandum dated January 3,1996, from the Executive Director for Operations to Chairman i Jackson, the staff committed to submitting quarterly reports on the status of its development of risk-1 informed standards and guidance. Previous quarterly reports were sent to the Commission on March 26, June 20, and October 11,1996; Januaw 13, April 3, July 22, and October 14,1997; and January 23,1998. This quarterly report covers tt period from January 1 to March 31,1998. DISCUSSION The significant accomplishments and changes for each individual section of the PIP are summarized here. More detailed information is included in Attachment 1. Attachment 2 presents a diagram that links PIP outputs to associated outcomes defined by the three program objectives: enhance safety decisions, make efficient use of NRC resources, and reduce unnecessary conservatism. The diagram also differentiates between regulatory programs / activities that generate guidance and those that utilize PRA in the decisionmaking process. Section 1: Reactor Regulation 1.1 Develop Standard Review Plans for Risk-Informed Regulation The proposed final versions of SRP Chapter 19 and RG 1.174, documenting general guidance on 1 the use of PRA in risk-informed decisionmaking for changes to the plant-specific licensing basis, were forwarded to the Commission in SECY-98-015 on January 30,1998. The staff has completed its renw of public comments on the draft risk-informed RGs and SRPs for IST, TS, and GQA. The final versions of these documents incorporate public comments on the draft documents, changes made to the general guidance documents (RG 1.174 and SRP Chapter 19), experience gained during pilot plant interactions, additional management review, as well as OGC, ACRS, and CRGR comments. The staff discussed these documents with the ACRS Reliability and Probabilistic Risk Assessment Subcommittee on February 19, with CRGR on February 27, and with the full ACRS Committee on March 3,1998. The proposed final versions of the risk-informed regulatory documents for IST (RG 1.175 and SRP Section 3.9.7), TS (RG 1.177 and SRP Section 16.1), and GQA (RG 1.176) were provided to the Commission in SECY-98-067 with the recommendation that they be published as final guidance documents and noticed in the FederalRegister. The guidance documents for risk-informed inservice inspection (ISI), RG 1.178 (formerly DG-1063) and SRP Section 3.9.8, have been revised to reflect the staff's consideration of public comments and to conform to the general risk-informed guidance documents (RG 1.174 and SRP Chapter 19). The major change to the risk-informed ISI guidance documents is that the staff will consider both partial-scope and full-scope submittals. Specifically, the licensees may submit a risk-informed application for a portion of the plant piping without performing a risk assessment for all piping

The Commissioners 3 segments in the plant. This change was made because the risk from piping was found to be cmall compared to the risk from other events analyzed in a PRA, as well as in response to a number of public comments requesting that the staff consider partial-scope applications. The staff will provide proposed final versions of RG 1.178 and SRP Section 3.9.8 to the Commission in the near future. 1.2 Pilot Applications for Risk-Informed Regulatory Initiatives The staff has developed a schedule for its review of the three risk-informed ISI pilot plant applications (Vermont Yankee-10/98, Arkansas Nuclear One Unit 2 (ANO2)-12/98, and Surry-12/98). These scheduled completion dates are subject to revision dependent upon the licensees meeting critical millstones. The submittals for Vermont Yankee and ANO applications reference ASME Code Cases N-560 and N-578, respectively; the Surry submittal references the Westinghouse Owners Group (WOG) topical report WCAP-14572. As discussed in the last PIP quarterly update, the staff's review for completeness noted that additional material was needed for the Vermont Yankee and Surry applications. Vermont Yankee supplied the requested additional material and the staff has forwarded a first round of requests for additional information (RAls) to the licensee. The staff expects to complete the reviews of the pilots by 12/98. A long-term plan is being developed to address risk-informed reviews to be conducted following these pilot plant reviews. On January 7,1998, the staff sent a letter to Entergy Operations documenting completion of the volunteer GQA interactions at the Grand Gulf facility. The staff will soon send a similcr letter documenting completion of volunteer GQA interactions with the licensee for the Palo Verde Nuclear Generating Station. Although neither of these licensees submitted GQA program changes for review and approval, the interactions with them and the information they provided informally have aided the staff in developing GQA guidance documents. The pilot program phase of volunteer interactions on GQA is considered complete. The staff will continue to monitor all volunteer plant G/3A implementation as appropriate. Development of the GQA inspection guidance procedure will r.,; Aue to htracked under Activity 1.3. The staff is continuing to develop the safety evaluation report (SER) for the Comanche Peak risk-informed IST program. The staff has been interacting with the pilot plant licensee (TU Electric) to develop a risk-informed IST program description that is sufficiently detailed and sufficiently consistent with the guidance in the proposed final RG 1.175. The staff expects that TU Electric will submit a final, more descriptive, risk-informed IST program description to the NRC by March 31, 1998. The staff now anticipates submitting a completed SER to the Commission on the risk-informed IST program at Comanche Peak in May 1998 rather than in March 1998. In SECY-98-015, the staff has proposed a final SRP and RG applicable to risk-informed TS improvements. In this regard, the staff has received, reviewed, and prepared safety evaluations and license amendments for risk-informed TS applications, demonstrating the viability of the guidance. These applications include extended allowed outage times (AOT) for (1) ECCS equipment at San Onofre units 2/3, which is the Combustion Engineering Owners Group pilot application, and (2) emergency diesel generators (EDG) at the Vogtle station. The staff expects to issue these license amendments during this calendar quarter. In addition, the staff has received, reviewed, and is developing safety evaluations and license amendments, in accordance with the guidance, for follow-on risk-informed TS amendments, for example, the Southern Califomia Edison supplemental request, received in January 1998, for extending the EDG AOT at San Onofre. The

The Commissioners 4 staff anticipates issuing these license amendents later this year and proceeding to use the guidance improvements on an ongoiag basis. The staff received (on March 2,1998) from the licensee for ANO1&2, a request for relief from the l staff position in NUREG-0737 for hydrogen monitoring. The request was made in accordance with " Task Zero" of the Risk-informed, Performance-Based Regulation Pilot Program ("Whole Plant Study") proposed by NEl. The staff is currently assessing the most appropriate licensing approach to this request. 1.3 Inspections The staff completed an additional eight Maintenance Rule baseline inspections during this quarter, which included inspection of licensee methods for using PRA in maintenance programs and inspection of safety assessments performed by licensees when removing equipment from service for maintenance in accordance with Paragraph (a)(3) of the Maintenance Rule. (The reported l number of 45 completed Maintenance Rule inspections in the last quarterly report update (SECY-98-012) did not include the Dresden inspection, which was conducted in two parts: an independent safety inspection in September 1996, followed by a limited-scope Maintenance Rule inspection in May 1997.) l l The scheduled date for completing revisions to the core inspection procedures (IPs) has been i deferred to May 1998. Finalization of the core IP revisions entailed coordination with 10 NRR branches and resulted in a longer-than-anticipated review and concurrence cycle. Changes to two of the core IPs-IP 71007, " Licensed Operator Requalification Program Evaluation," ano IP 82701, " Operational Status of the Emergency Preparedness Program,"-will be completed after April 1998 and will be separately tracked by the staff's action item tracking system, i l i l The schedule for issuing the draft and final GQA IPs has been revised. The staff now expects to issue the draft GQA inspection guidance by July and the final guidance by October 1998. This change was made because key personnel were assigned to higher priority tasks, such as the finalization of the risk-informed documents for GQA and ISI and the Millstone restart team inspection. For the purpose of making risk information more accessible to inspectors, a new subtask has been initiated. This subtask, " Evaluate Methods of Presenting Risk Analysis Results in a Form Most Useful to Inspectors and Develop Options Relating to Providing Inspectors With Plant-Specific Risk information," is scheduled to be finished in December 1998. i 1.6 Evaluate Use of PRA in Resolution of Generic Safety Issues l This activity relatu to those generic safety issues (GSis) that have been explicitly identified and addressed by licensees as part of the IPE process. The Office of Nuclear Regulatory Research (RES) is preparing a report entitled " Unresolved Safety issues and Generic Safety issues Related to the IPE Program." The RES report, scheduled to be completed in May 1998, identifies the GSis that were proposed for resolution, and presents the staff's views on the adequacy of the proposed resolution. This report will serve as the basis for selecting which GSIs will be audited, and at which plants. The completion date for these activities has been revised to "to be determined;" a schedule will be developed after NRf; staff completes its review of the RES report.

The Commissioners 5 1.7 Regulatory Effectiveness Evaluation This activity has been moved to Section 2 of the PIP (new Activ':/ 2.11), to more closely link it with the Generic Safety issue program and the Regulatory Excellence Plan, for which RES has the lead. i l l Section 2: Reactor Safety Research 2.1 Develop Regulatory Guides As discussed above, the proposed final versions of SRP Chapter 19 and RG 1.174 were sent to the Commission in SECY-98-015 on January 30,1998. l The proposed final versions of the regulatory documents for risk-informed IST (RG 1.175 and SRP Section 3.9.7), risk-informed TS (RG 1.177 and SRP Section 16.1), and risk-informed GQA (RG 1.176) were provided to the Commission in SECY-98-067. l l The guidance documents for risk-informed ISI, RG 1.178 (formerly DG-1063) and SRP Section 3.9.8, have been revised to reflect public comments and to conform to the general guidance documents (RG 1.174 and SRP Chapter 19). The staff is scheduleo to provide the l proposed final versions to the Commission in the near future. l 2.3 Support for NRR Standard Reactor PRA Review In accordance with the reassignment of rulemaking activities under DSI-22, this activity has been transferred from RES to NRR, and therefore it will be tracked as an item under Activity 1.8, " Advanced Reactor Reviews." 2.5 IPE and IPEEE Reviews The staff has reviewed all of the 76 IPE submittals and issued staff evaluation reports (SERs) on its findings to each licensee with one exception, Browns Ferry 3 (BF3) for which a draft SER has been prepared. In three of the SERs, the staff was not able to conclude that the licensee met the intent of Generic Letter 88-20 for their plant (s). These three iPEs include Crystal River 3, Susquehanna 1&2, BF3. During this quarter, the staff met with the iicensees for both Crystal River 3 and Susquehanna 1&2. It appears that these licensees have addressed the staff concerns and l the staff will issue updated SERs by the end of June 1998. RES forwarded to NRR a draft SER on BF3 in December 1997; the staff is planning to meet with the licensee in the near future. The staff developed an interim report that presents preliminary IPEEE perspectives and summarizes the information in the first 24 IPEEE submittals reviewed; the interim report was sent to the Commission on January 20,1998. The staff has received 70 of the 74 expected IPEEE submittals. Two of the missing four submittals (Ginna and Vermont Yankee) are expected by the end of June 1938; the submittal date of the remaining two (Millstone 1 and Watts Bar 2) has yet to be determined. Currently,65 submittals are l under various stages of review; preliminary reviews have been completed on 57, eight of which were completed during this quarter. The staff has sent RAls to licensees for 46 submittals, and has received responses for 29 submittals. The review for one plant, Diablo Canyon, has been i

l The Commissioners 6 completed and the SER has been sent to the licensee. Similar to the IPE program, the staff will take prompt action should any significant vulnerabilities or safety insights be identified in these reviews (e.g., Quad Cities fire safe-shutdown issues). 2.8 PRA Standards Development ASME has formed a task group, which includes a representative from the staff, to draft PRA i standards. Although the staff continues working with ASME in this activity, it has some concern in regard to the scope of the group's work. The NRC sent a letter to ASME expressing the staff's concerns and desires. Attachments 3 and 4, respectively, are NRC's letter and ASME's response. Section 3: Analysis and Evaluation of Operating Experience and Training 3.1 Risk-Based Trends and Pattems Analysis The staff issued a special study, " Operating Experience Feedback From Service Water System (SWS) Failures and Degradations,"in February 1998. The study used SWS operating experience from 1986--1995 contained in licensee event reports (LERs). Major findings of the study are (1) there were no total failures of the SWS resulting in loss of core-cooling capability during the period; (2) the few short-term losses of SWS were recovered promptly; (3) licensee activities in response to Generic Letter 89-13 appear to have been successful in identifying safety-significant programmatic and design-related issues; and (4) although events affecting SWS performance were observed, they were not dominant contributors to risk. In January 1998, the report on auxiliary feedwater system reliability and the updated report on loss of offsite power were sent out for review by NRC staff and external reviewers. The staff is incorporating reviewers comments and will issue the revised reports in June 1998. The last PlP update report indicated that the common-cause-failure database was being sent to all nuclear power plant licensees. Distribution has been delayed in order to issue the database during the next quarter via an NRC administrative letter. 3.5 Compile Operating Experience Data Revision 1 of NUREG-1022," Event Reporting Guidelines,10 CFR 50.72 and 50.73," was issued in .le.nuary 1998. It has been determined that the LER rule should be revised to eliminate unnecessary and less safety-significant reporting and to capture better risk-related information. A plan to revise 10 CFR 50.72 and 50.73, was sent to the Commission on March 4,1998. The final LER rule is expected to be published by December 1999. 3.6 Staff Training The new 2-week PRA Technology and Regulatory Perspectives course (P-111) was offered for the first time from January 26 to February 6,1998. It is scheduled to be offered three more times during 1998, in support of the staff's goal of having by the end of 1998 one resident inspector at each site who has completed this course.

The Commissioners 7 j The 4-day PRA Basics for Regulatory Applications course (P-105) was offered twice: February 3 - 6 and February 24 - 27,1998. This course will be offered five more times during 1998, to address the need for more NRC technical staff to attend this course. l The 3-day PRA for Technical Managers course (P-107) was offered twice, February 10 - 12 and i March 17 - 19,1998. This course will be offered three more times during 1998, to support the staff's goal of having by the end of 1998 two-thirds of the agency's technical managers complete it. The modifications needed to incorporate information from the proposed final versions of RG 1.174 and SRP Chapter 19 into the course material for courses P-105, P-107, and P-111 have been completed and implemented, i Procurement actions are in progress for acquiring risk-monitor software. Current plans are to integrate the risk-monitor into the reactor technology and PRA technology curricula to improve student understanding of configuration management, the importance of plant operations to the risk profile of the plants, and use of the icel to gain insights regarding the industry's use of risk-informed applications. The risk-monitor will also be usW to demonstrate the capabilities and limits of this and similar tools as they are being used by the industry. Section 5: High-Level Nuclear Waste Regulation 5.1 Regulation of High-LevelWaste On March 17 - 19,1998, the Department of Energy (DOE) and the NRC staff held a technical exchange meeting in San Antonio, Texas. DOE's plans and methodology for conducting a total-system performance assessment in support of its upcoming viability assessment were discussed. Also discussed was the status of the staff's effort to develop its independent performance assessment review capability. 5.2 Apply PRA to Spent Fuel Storage Facilities This study, which would have demonstrated methods for PRA of spent fuel storage facilities, was suspended because of current budget constraints. Potentially, the results of this study could have been used to support the adequacy of the existing dry-storage system designs, procedures, and regulations. Also, the results were expected to be usea to make recommendations about the extent to which an expansion of PRA methods for dry-cask storage would provide further useful information. The staff believes this study should be resumed when resources permit. Section 6: Reactor Enforcement (new PIP section) 6.1 Develop Enforcement Guidance for Considering Risk in the Enforcement Process The Office of Enforcement has developed guidance for the staff with respect to the consideration of risk in enforcement actions (Enforcement Guidance Memorandum (EGM) 97-011, June 1997). In the EGM, it is acknowledged that there are uncertainties associated with risk assessment due to the differences in PRA models utilized by the staff and licensees, and it is noted that there is a need to exercise judgement in using risk as a factor in enforcement decisions. However, it is also emphasized that risk has value as an assessment tool and it should be used, when warranted, as a factor in determining the appropriate enforcement sanctions.

The Commissioners 8 i i 6.2 Include Risk insights During Weekly Enforcement Panels EGM 97-011 directed that Enforcement Panel preparations should include risk insights developed by the regional Senior Reactor Analysts. This initiative is an ongoing activity, routinely utilized during the Weekly Enforcement Panels. 6.3 Change the Enforcement Policy Supplements to include Additional Examples of How Risk Should Influence Severity Level The Office of Enforcement has met with NRR (Probabilistic Safety Asst ssment Branch (SPSB)) on two occasions to work out the details associated with SPSB developing new examples to be included in the Enforcement Policy Supplements. These new examples may give the staff better guidance in determining the appropriated severity level of violations. It is expected that development of these examples will be completed in the Fall of 1998. COORDINATION The Office of the General Counsel has reviewed this paper and has no legal objection to the paper, j 'Js h Callan Exec ive Director for Operations Attachments: As stated l l DISTRIBUTION: Commissioners j OGC OCAA OIG OPA OCA ACRS CIO CFO EDO REGIONS SECY l

i I ATTACHMENT 1' PRA IMPLEMENTATION PLAN ACTIVITY TABLE (March 1998) 1.0 REACTOR REGULATION Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 1.1 STANDARD REVIEW Develop standard review plans

  • Evaluate available industry NRR PLANS FOR RISK.

(SRPs) to be used in nsk-guidance /RES INFORMED informed regulatory REGULATION decisionmaking.

  • Develop broad-scope SRP chapters and a senes of application-specific SRP chapters that correspond to industry iritiatives
  • These SRPs will be consistent with the regulatory cuides (RGs) developed for the industry l

l

  • Draft SRPs transmitted to Commission to issue for public comment:

General 4/97C8 i IST 4/97C l iSI 8/97C TS 4/97C

  • Final SRPs transmitted to Commission for approval General 1/ tea Completed IST 3/98 Completed i

ISI TBD Chan Note 1) TS 3/98 Com ted I l l 1 l l ' See Abbreviations Table at the end of this report

  1. C = Task previously completed

a O 2 \\ Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) { 1.3 PILOT Evaluate the PRA methodology Interface with industry NRR/RES APPLICATIONS FOR and develop staff positions on groups RISK-INFORMED erneiging, nsk-informed REGULATORY initiabves, including those Evaluation of appropriate INITIATIVES associated with: documentation (e.c,10 CFR. SRP, RGs, 1. Motor operated valves inspection procedures, 1,2/96C and industry codes) to 2. IST requirements identify elements entical to 2a. Comanche Peak achieving the intent of 2a. 5/98 Changed (Note 2) 2b. PaloVerde existing requirements 2b. TBD 3. ISI requirements Evaluation of industry 3.12/98 proposals 4. Graded quality assurance

4. 1!98 Completed (GQA)

Evaluation of industry pilot (Note 3) program implementation 5. Maintenance Rule

5. 9/95C As appropriate, complete 6.

Technical specifications pilot reviews and issue 6a. Commission approval staff findings on regulatory Ga. 5/97C 6b. Pilot amendments requests 6b. 5/98 Changed (Note 4) Issued 7. Other applications to be identified later (e.g, applications related to diesel generator start times and hydrogen control) 7a. ANO request for relief 7a. TBD New (Note 5) from the staff position in NUREG-0737 for hydrogen monitonng, on the basis of " Task Zero" of the Risk-Informed, Performance-Based Regulation Pilot Program ("Whole Plant Study") proposed by NEl. ( l l l l

l 3 1 l 1 Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 1.3 INSPECTIONS Provide guidance on the use of Develop IMC 9900 6/97C NRR i plant-specific and generic technical guidance on the information from individual plant use of PRAs in the power examinations (IPEs) and other reactor inspection plant-specific PRAs. program Revise IMC 2515 7/97 C Appendix C on the use of 1 PRAs in the power reactor inspect.on program Propose guidance options 10/97C for insoection procedures related to 50.59 evaluations and regular maintenance observations Review core inspection 10/97C ) procedures and propose l PRA guidance where needed l Complete revision to 5/98 Changed (Note 6) proposed core inspection procedures lasue draft GQA 7/98 Changed (Note 6) Inspection Procedure lssue final GQA Inspection 10/98 Changed (Note 7) Procedure Evaluate methods for 12/98 New (Note 8) presenting risk analysis results in a form most l useful to inspectors and i develop options for providing inspectors with plant-specific nsk Information Provide PRA training for Identify inspector functions 7/96C NRR inspectors and senior reactor that should utilize PRA analysts (SRAs). methods, as input to AEOD/TTD for their development and refinement of PRA training for inspectors Develop consolidated and 10/97C NRR/ comprehensive 2-3 week AEOD PRA for regulatory applications training course Conduct training for 8/96C NRR Maintenance Rule basehne inspections Conduct training courses Ongoing AEOD according to SRA training programs Rotational assignments for Ongoing NRR/RES SRAs to gain working PRA experience

4 i Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) \\ Continue to provide expertise in

  • Monitor the use of risk in Ongoing NRR risk assessment to support inspection reports regionalinspection activites and to communicate inspection
  • Develop new rnethodologies Ongoing program guidance and and communicate examples of its implementation.

appropriate uses of risk insghts to regional offices {

  • Updateinspection Ongoing procedures as needed
  • Assist regional offices as Ongoing needed
  • Conduct Maintenance Rule 7/98 basehne inspections 1.4 OPERATOR Monitor insights from human
  • Revise the Knowledae and 8/95C NRR LICENSING reliability analyses (HRAs) of Abihties Catalogs (NUREGs PRAs (including IPEs and 1122 and 1123) to individual plant examinations for incorporate operating external events ( IPEEEs)) and expenence and nsk insights operating expenence to identify possible enhancements for
  • Revise the Examiner 3/97C inclusion in planned revisions to Standards (NUREG-1021),

guidance for operator licensing as needed to reflect PRA activities (initial and insights requalification). 1.5 EVENT Continue to conduct quantita%

  • Continue to evaluate 50.72 Ongoing NRR ASSESSMENT event assesstnents of reactor events using accident events while at-power and during sequence precursor (ASP) low power and shutdown models conditions.

Assess the desirability and

  • Define the current use of risk TBD NRR 1

feasibility of conducting analysis methods and quantitative risk assessments on insights in current event non-power reactor events. assessments

  • Assess the feasibility of developing appropnate risk assessment models
  • Develop recommendations on the feasibility and desirability of conducting quantitative risk assessments 1.6 USE OF PRA IN Audit the adequacy of licensee
  • Identify generic safety issues TBD NRR/RES Changed (Note 9) ana'yses in IPEs and IPEEEs to to be audited RESOLUTION OF i

l GENERIC SAFETY identify plant-specific ISSUES applicability of generic safety

  • Select plants to be audited TBD Cnanged (Note 9) issues closed out based on IPE for each issue and IPEEE programs.
  • Describe and discuss TBD licensees' analyses supporting issue resolution
  • Evaluate results to determine TBD regulatory response; i.e., no achon, additional audits, or regulatory action

5 Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 1.7 REGULATORY Assess the effectiveness of

  • Develop process / guidance ongoing RES/NRR Changed EFFECTIVENESS major safety issue resolution for assessing regulatory (Note 10)

EVALUATION efforts for reducing risk to public effectiveness health and safety. method to assess ongoing r ion in risk

  • Evaluate resulting 12/98 effectiveness of station blackout and ATWS rules and Unresolved Safety issue A-45
  • Propose modifications to TBD resolution approaches, as needed (SBO rule implementation and RCP sealissue)
  • Identify other issues for ongoing assessment d appropnate 1.8 ADVANCED Continue staff reviews of PRAs
  • Continue to apply current ongoing NRR REACTOR REVIEWS for design-certification staff review process applications.

Develop SRP to support review

  • Develop draft SRP to tech TBD NRR of PRAs for design certification staff for review and reviews of evolutionary reactors concurrence (ABWR and System 80+).
  • Finalize SRP TBD Develop independent technical
  • Reevaluate risk-based 12/96C NRR/RES analyses and enteria for aspects of the technical evaluating industry initiatives and bases for EP (from NUREG-NUREG-0396) petitions regarding simplification using insights of Emergency Preparedness 1150, the new source term (EP) regulations, information from NUREG-1465, and available plant design and PRA information for the passive and evolutionary reactor designs Modify 10 CFR 52 and develop
  • Develop draft guidance and 5/98 NRR Changed ance on the use of updated rule (Note 11) ras beyond design certdication (as desenbed in SECY 93-087).
  • Solicit public comment 11/98
  • Finalize staff guidance and 12/99 rule 1.9 ACCIDENT Develop generic and plant
  • Develop plant-specific A/M TBD NRR/RES MANAGEMENT s

e nsk insiohts to support insights /information for s aff audits of util accident selected plants to serve as a management programs at basis for assessing selected plants. completeness of utility A/M program elements e g, severe accident tra(ining) i i

i 6 Regulatory Activity ' Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 1.10 FVALUATE IPE - Use insights from the staff

  • Review NUREG-1560,"lPE 9/97C NRR/RES INSIGHTS TO revew of IPEs to identify Program: Perspectives on DETERMINE potential safety, policy, and Reactor Safety and Plant NECESSARY technicalissues and to Performance, to identify an FOLLOW-UP determine an appropnate course initiallist of follow-up staff ACTIVITIES of actsn to address these and industry actens (if any),

potentialissues. including actions related to A/M

  • Review IPE results and 6/99 NRR/RES interact wMh licensees
  • Complete backfit analysis 12/99 NRR and actions
  • Fopow up on accident 9/98 NRR/

reenagement programs and regions licensee-stated actions Determine appropriate approach

  • Define use for information, 5/98 NRR/RES Changed for tracking the regulatory uses clarify " regulatory use," and (Note 12) of IPE/IPEEE results.

assess the most effective methods for data collection

  • If appropriate develop 12/98 approach for linking IPE/IPEEE databases

l l l l l 7 2.0 REACTOR SAFETY RESEARCH Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) l 2.1 REGULATORY GUIDES Develop RGs to provide a

  • Draft PRA GRs transmitted to RES/NRR basis for the industry to Commission for approval to issue i

use in nsk-informed for public comment. regulation. General C IST C lSI C GQA C l TS C

  • Final PRA RGs transmitted to Commission for approval:

General 1/98 Competed IST 3/98 Completed ISI TBD Changed (Note 1) GQA 3/98 Compkted TS 3/98 Completed 2.2 TECHNICAL SUPPORT Provide technical support

  • Continue to provide ad hoc Continuing RES to NRC staff using nsa technical support to agency PRA assessment in risk-based users regulation activities, technical reviews, issue
  • Expand the use of PRA models Continuing nsk assessments, available; expand the scope of statistical analyses, and available models to include develop guidance for extemal, low power, and agency uses of nsk shutdown events; refine the assessment, tools needed to use these models; and continue maintenance and user support for SAPHIRE and MACCS computer codes l
  • Support a efforts in Continuing reactor sa improvements in former Sovie Uruon countnes 2.3 SUPPORT FOR NRR Modify 10 CFR 52 and
  • Develop draft guidance and rule 5/98 NRR Changed i

STANDARD REACTOR develop guidance on the (Note 11) PRA REVIEW use of updated PRAs Solicit public comment 11/98 beyond design certification (as desenbed in Finalize staff guidance and rule 12/99 SECY 93-087). 2A METHODS Develop, demonstrate.

  • Develop and demonstrate 10/98 RES Changed DEVELOPMENT AND maintain and ensure the methods for including aging (Note 13)

DEMONSTRATION quality of methods for effects in PRAs. performing, reviewing, and using PRAs and related

  • Develop and demonstrate 9/98 techniques for existing methods for including human reactor designs, errors of commission in PRAs.
  • Develop and demonstrate TBD methods to incorporate gnizational performance into I
  • Identify and prioritize key areas to 9/98 Changed l

Improve fire nsk analysis (Note 14) ' Develop and demonstrate 6/99 l improved methods for selected i areas l l

  • Develop and demon 5: rate methods for assessing reliability /nsk of digital systems

a 8 Regulatory Activity Objectives Methods Target Lead Status (this Schedule Offim(s) quarter) 2.5 iPE AND IPEEE Evaluate IPE/IPEEE

  • Complete the reviews of the RES REVIEWS submrttels to obtain three outstanding IPE reasonable assurance that submntals:

the hcensees have Susquehanna 6/98 Changed adequately analyzed plant Crystal River 6/98 (Note 15) design and operatens to Draft SER for Browns Ferry 3 TBD decover vulnerabilities; and document significant

  • Continue regionalIPE 12/97C safety insights resulting presentations, from IPE/IPEEEs.
  • lasue IPE insights report for 10/96C public comment.
  • FinalIPE insights report 12/97C
  • lasue preliminary IPEEE 1/98 Completed insights report
  • Initiate review of eight additional 6/98 iPEEE submittels
  • Complete contractor evaluations 6/98 of twelve iPEEE submrttals.
  • Complete reviews ofIPEEE 6/99 submrttals.
  • lssue draft IPEEE insights report 6/99 for comment
  • lasue finalIPEEE insights report 12/99 16 GENERIC SAFETY To conduct generic safety
  • Continue to prioritize and Continuing RES activde. management resolve generic safety issues ISSUES PROGRAM issue s, mcluding pnontization, resolution, and documentation, for issues. relating to currently j

operating reactors, for advanced reactors as i appropnate, and for development or revision of i associated ulato and standards in men. 3.7 NEl INITIATIVE TO Review NEl initiative to

  • Agree on ground rules for study TBD RES/NRR Changed CONDUCT 'WHOLE conduct three pilot % hole (Note 16)

PLANT' RISK STUDY plant

  • nsk-informed
  • Complete study TBD studies of requirements -

vs. risk and cost. 2.8 PRA STANDARDS Work with industry to Initiate activity 9/97C RES See Note 17 DEVELOPMENT develop national consensus standard for Finalize standard TBD PRA scope and quality. 2.9 LOW POWER AND Collect studies of LP&S

  • Collect and review existing 9/98 RES SHUTDOWN nsk as a benchmark for LP&S nok information (domestic BENCHMARK RISK assessing the need for and foreign)

STUDY further staff activtties.

  • Initiate additionalwork 10/98 2.10 SAFETY GOAL Assess need to revise Initiate discussion with ACRS 2/98 RES Completed REVISION Commission's Safety Goal to make core damage Recommendation to 4/98 Changed frequency a fundamental Commission (Note 18) goal and make other changes.

l k

i 4 4 l l l i O Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) i i 2.11 REGULATORY Assess the effectiveness Develop process / guidance for ongoing RES/NRR Changed EFFECTIVENESS of major safety issue assessing regulatory (Note 10) EVALUATION resolution efforts for effectiveness reducing risk to public health and safety. Apoly method to assess ongoing reduction in nsk Evaluate resulting 12/98 effectiveness of station blackout and ATWS rules and 1 Unresolvec Safety issue A45 j Propose modifications to TBD j resolution approaches, as ) needed (SBO rule implementation and RCP seal issue) Identify other issues for ongoing assessmentif appropnate l l l l l l

10 3.0 ANALYSIS AND EVALUATION OF OPERATING EXPERIENCE, AND TRAINING Regulatory Objectives Methods Target Lead Status (this Activity Schedule Office quarter) 3.1 RISK-BASED TRENDS Use reactor operating

  • Trend performance of risk-12/98 AEOD AND PATTERNS exponence data to assess the important components ANALYSIS trends and patterns in equipment, systems, initiating
  • Trend performance of risk-12/98 Changed events, human performance, important systems (Note 19) and important accident sequence.
  • Trend frequency of risk-7/98 important initiating events
  • Trend human performance TBD for reliability characteristics Evaluate the effectivenass of
  • Trend reactor operating As needed AEOD hcensee actions taken to experience associated with resolve risk significant safety specific safety issues and issues.

assess nsk imphcations as a rneasure of safety performance Develop trending methods and

  • Develop standard trending C

AEOD special databases for use in and statistical analysis AEOD trending activities and for procedures for identified PRA apphcations in other NRC areas for reliabihty and offices. statistical applicat ons

  • Develop special software C

and databa:es (e.a. (Periodic common cause faTure) for updates) i use in trending analyses and PRA studes 3.2 ACCIDENT Identify and rank risk

  • Screen and analyze LERs, Ongoing AEOD SEQUENCE significance of operational AITs, llTs, and events PRECURSOR (ASP)
events, identified from other PROGRAM sources to obtain ASP events
  • Perform independent Annual AEOD review of each ASP
report, analyses. Licensees and Ongoing NRC staff r review of each ana sis
  • Complete quality assurance 3/97C RES of Revision 2 simphfied plant specific models
  • Complete feasibihty study 11/96C RES for low power and shutdown models
  • Complete initial C

RES containment performance and consequence models.

  • Complete development of 7/99 RES the Level 2/3 models
  • Complete the Revision 3 11/01 RES simphfied plant-specific models
  • Complete extemal event TBD RES models for fire and certhquake
  • oompkete low TBD RES power / shutdown models

e a 11 Regulatory Objectives Methods Target Lead Status (this Activity Schedule Omce quarter) J Provide supplemental

  • Share ASP analyses and Annual rpt AEOD information on performance. plant specific insights with other NRC omces and Regions 3.3 INDUSTRY RISK Provide a measure of industry
  • Develop program plan to C

AEOD TRENDS risk that is as complete as integrate NRR, RES, and possible to determine whether AEOD activites using nsk is increasing, decreasing, or design and operating remaining constant over time. experience to assess the implied lever of nsk and how it is changing

  • Update plan for risk-based analysis of reactor operating expenence
  • Implement program plan 6/99 elements to include plant.

Specific models and insights from IPEs, component and system reliability data, and other nak-important design and operational data in an integrated frame work to penodically evaluate industry trends 3.4 RISK-BASED Establish a comprehensive set

  • Identify new or improved C

AEC9 PERFORMANCE of performance indicators and risk-based Pls which use INDICATORS supplementary performance component and system measures which are more reliability models & human closely related to risk and and organizational provide both early indication performance evaluation and confirmation of plant methods performance problems.

  • Develop and test candidate 9/00 Pis/ performance measures
  • Implement risk-based Pls 1/01 with Commission approval

12 Regulatory Objectives Methods Target Lead Status (this Schedule Ofhce quarter) Actrvity 3.5 COMPILE OPERATING Compile operating experience

  • Manage and maintain Ongoing AEOD EXPERIENCE DATA information in database systems SCSS and the Pl data suttable for quantitative base, provide oversight and reliability and nsk analysis access to NPRDS/ EPIX, apphcations. Information obtain INPO's LSPl, should be scrutaole to the compile IPE faiWre data, source at the event level to the collect plant-specific extent practical and be reliability and availability sufficient for estimatino data reliabihty and availability parameters for NRC
  • Develop, manage and Ongoing applicabons.

maintain agency databases for reliability /availabihty data (equipment performance, initiating events, CCF, ASP, and human performance data)

  • Determine need to revise 6/98 Completed LER rule to eliminate unnecessary and less safety-signrficant reporting
  • Determine need to revise 6/98 Completed reporting rules and to better capture ASP, CCF, and human ;,erformance events
  • Publish revised LER rule 12/99 Changed (Note 20) 3.6 STAFF TRAINING Present PRA curriculum as
  • Continue current contracts Ongoing AEOD presently scheduled for FY to present courses as 1998.

scheduled

  • Maintain current reactor Ongoing technolooy courses that include FRA insights and applications
  • Improve courses via Ongoing feedback
  • Review current PRA course Complete material to ensure consistency with Appendix C l

l l l

e 4 t l 13 l Regulatory Objectivet Methods Target Laad Status (this Activity Schedule Office quarter) Develop and present

  • Prepare course material C

RES/AEOD Appendix C training courses. based on AppendLt C

  • Present courses on C

Appendix C Detemtine staff requirements

  • Review JTAs performed to C

AEOD for training, include date analysis of know e and skilla, needed by t NRC

  • Perform representative C

staff. JTAs for staff positions (JTA Pilot Program)

  • Evaluate staff training C

requirements as identified in the PRA implementation Plan and the Technical Traini. J Needs Survey (Phase 2) and incorporate them into the training requirements a.1alysis

  • Analyze the results of the C

JTA Pilot Program and determine requirements for l additional JTAs

  • Complete JTAs for other C

staff positions as needed

  • Solicit a review of t,1e C

proposed training requirements

  • Finalize the requirements C

Revise current PRA curriculum

  • Prepare new courses to Ongoing AEOD and develop new training meet identrfed needs program to fulfill identrfed staff needs.
  • Revise current PRA Ongoing courses to meet identifed needs
  • Revise current and New 9/97C PRA course to include Reg Gude and SRP information 1
  • Revise current reactor Ongoing technology courses as necessary to include additional PRA insights and applications Present revised PRA training
  • Establish contracts for Ongoing AEOD cumculum.

presentation of new PRA curnculum l

  • Msent revised reactor Ongoing l

t chnology courses

  • Improve courses based on Ongoing feedback l

i I i i l

e o 14 4.0 NUCLEAR MATERIALS AND LOW-LEVEL WASTE SAFETY AND SAFEGUARDS REGULAT!ON Regulatory Activity ' Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 4.1 VALIDATE RISK Validats risk analysis

  • Hold a workshop 8/94 C NMSS ANALYSIS methodology devsloped to consisting of experts in METHODOLOGY assess the relative profile of PRA and HRA to examine DEVELOPED TO most likely contributors to existing work and to ASSESS MOST LIK6LY misadministration for the gamma provide recommendations FAILURE MODES AND stereotactic device (gamma for further methodological HUMAN knife).

development PERFORMANCE IN THE USE OF

  • Examine the use of Monte 9/95 C INDUSTRIAL AND Carlo simulation and its MEDICAL RADIATIOfI apphcation to relative nsk DEVICES profiling
  • Examine the use of expert g/95 C judgement in developing error rates and consequence measures Continue the development of the
  • Develop functionally based TBD RES/

relative nsk methodclogy, with generic event trees NMSS the addition of event tree modeling of the brachytherapy remote after loader. Extend the application of the

  • Develop generic risk TBD RES/

methodology and its further approaches NMSS development into additional devices, including teletherapy and the pulsed high dose rate after loader. O,3 CONT!NUE USE OF Develop decision criteria to

  • Conduct enhanced 8/94 C RES/NMSS RISK ASSESSMENT support regulatory decision participatory rulemaking to Final rule OF ALLOWABLE making that incorporates both establish radiological published RADIATION deterministic and nsk-based enteria for 7/97 C RELEASES AND engineering judgement.

decommissioning nuclear DOSES ASSOCIATED sites; technical support for WITH LOW-LEVEL rulemaking including RADIOACTIVE WASTE comprehensive nok based AND RESIDWA. assessment of residual

ACTIVITY, contamination
  • Develop guidance for 3/98 Completed imp;smenting the (Note 11) radiological criteria for license termination
  • Work with DOE and EPA Ongoing to the extent practicable to develop common approaches, assumptions, and models for evaluating nsks and altemative remediation methodologies (nsk harmonization) 4.3 DEVELOl* GUIDANCE Develop a Branc.h Technical
  • Solicit public comments 5/97 C NMSS/RES FOR THE REVIEW OF Position on conducting a RISK ASSOCIATED Performance Assessment of a WITH WASTE LLW disposal faciltty.
  • Publish final Branch
TBD, REPOSITORIES.

Technical Position Dependent on-resources )

l e 15 l Regulatory Activ;ty Objectives Methods Target Lead Statua (this Schedule Office (s) quarter) l 4.4 RISK ASSESSMENT Develop and demonstrate a risk

  • Develop and demonstrate 9/98 Changed OF Mt.TERIAL USES.

assessrnent for industrial methods for determining (Note 22) gauges containing cesium-137 the risk associated with and cobalt 40 using PRA and industrial gauges other related techniques, containing cesium-137 and cobalt 40 2 The assessment should allow for i modrhcstion based on changes

  • Final report as NUREG 12/98 in regulatory requirements.

l Usee practigirical data as much as le. Develop and demonstrate risk

  • Working Group with 9/98 assessment methods for contractor assistance to application to medical and identify and document a industnallicensee activities.

technical basis for a risk-informed approach to the regulation of nuclear byproduct material, and to l covelop plans for a graded approach to nuclear byproduct material regulation based on risk l information i 4.5 FRAMEWORK FOR Develop a framework for

  • Provide plan for 1/98 NMSS Changed USE OF PRA IN applying PRA to nuclear material developing framework

( Note 23) 1 REGULATING uses similar to the one ( NUCLEAR MATERIALS developed for reactor regulation

  • Complete framework TBD j

(SECY-95-280), where appropnate. t i I

a 16 5.0 HIGH-LEVEL NUCLEAR WASTE REGULATION Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 5.1 REGULATION OF HIGH-Deve uidance for the NRC

  • Assist the staff in pre-Ongoing NMSS LEVEL WASTE and C staffs in the use of licensing activites and in performance assessment (PA) hanse application reviews to evaluate the safety of HLW programs.
  • Develop a technical assessment capability in total-system and subsystem PA for use in licensing and pre-hcensing reviews
  • Combine specialized technical disciphnes (earth sciences and engineering) with those of system modelers to improve methodology identify significant events.
  • perform sensitivity studies Ongoing NMSS processes, and parameters of key technicalissues affecting total system using iterative PA (IPA) performance.

Use PA and PSA methods.

  • Assbt the staff to maintain Ongoing NMSS results and insights to evaluate and to refine the regulatory proposed changes to structure in HLW disposal ulatioris goveming the regulations that pertain to ential repository at Yucca PA ountain.
  • Apply IPA analyses to advise EPA in its development of a Yucca Mountain regulation
  • Apply IPA analyses to develop a site-specific regulation for a Yucca Mountain site Continue PA activities during
  • Provide guidance to the Ongoing NMSS interactions with DOE dunng the DOE on site pre-hcensing phase of charactenzation repository development, site requirements, ongoing charactanzation, and repository design work, and hcensing design.

issues important to the DOE's development of a complete and high-quahty heense apphcation

  • Compare results of NRC's See Note 24 iterative performance assessment to DOE's Visbilrty Assessment (VA) to identify major differences / issues 5.2 APPLY PRA TO SPENT Demonstrate methods for PRA
  • Prepare user needs letter 4/97C RES/NMSS FUEL STORAGE of spent fuel storage facilrtes.

to RES FACILITIES

  • Conduct PRA of dry cask TBD Changea storage (Note 25)

17 Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 5.3 CONTINUE USE OF Use PRA methods, results, and

  • Update the database on 6/01 NMSS Changed RISK ASSESSMENTIN insights to evaluate regulations transportation of (Note 26)

SUPPORT OF goveming the transportation of radioactive materials for RADIOACTIVE radioactive material. future applications MATERIAL TRANSPORTATION

  • Revalidate the results of 12/99 Changed NUREG-0170 for spent fuel (Note 27) shipment risk estimates 1

1

O e 18 6.0 REACTOR ENFORCEMENT Regulatory Activity Objectives Methods Target Lead Status (this Schedule Omce(s) quarter) 6.1 DEVELOP Ensure the consistent

  • Prepare an Enforcement 6/97 OE Completed ENFORCEMENT Application of the Enforcement Guidance Memorandum (Note 28)

GUIDANCE FOR Policy in the Area of Risk (EGM) - CONSIDERING RISK Informed Enforcement Actions. IN THE

  • Update the Enforcement 8/98 OE Ongoing ENFORCEMENT Manual to reflect the PROCESS guidance developed in the EGM 6,3 INCLUDE RISK Ensure Risk-informed Decisions
  • Include

'onal Senior Ongoing OE New (Note 29) INSIGHTS DURING are Made in Developing Reactor A st Evaluation WEEKLY Enforcement Actions. on Paneled forcement ENFORCEMENT Cases when warranted PANELS 6.3 CHANGE THE Provide the staff with more

  • Interface with NRR (SPSB)

Fall 98 OE New (Note 30) ENFORCEMENT useful guidance for determining to consuler additional POLICY the Seventy Level of Violations, examples for the Policy SUPPLEMENTS Supplements TO INCLUDE ADDITIONAL EXAMPLES OF HOW RISK SHOULD INFLUENCE SEVERITY LEVEL j 1

19 NOTES 1. Completion date is under management review. 2. The staff's risk-informed (RI) IST team has continued to work with TU Electric to develop a RI-IST Program Description for Comanche Peak that is sufficiently detailed and consistent with the proposed final Rl-IST guidance provided in RG 1.175. The staff received a_dfait RI-lST Program Description from TU Electric on February 13,1998. The staff has discussed this draft with TU Electric and expects that the pilot licensee will submit a final, more l descriptive, Rl-IST Program Description to the NRC. The staff will continue to develop its SER based on the licensee's responses to the staff's requests for additional information and discussions with the licensee. The staff anticipatea having a completed SER to the Commission on the RI-IST program at Comanche eeak in May 1998. This is a change from the previous date of March 1998. 3. For the purposes of clearer status tracking within the PRA implementation plan, the graded quality assurance pilot application at South Texas Project has been revised to reflect completion of the pilot program effective November 1997. As discussed in SECY-98-012, the licensee was informed by letter on November 6,1997, that the staff had approved the GQA change and was provided with the associated staff safety evaluation. On Janur 7, 1998, the staff issued a letter to Entergy Operations documenting completion of the volunteer GQA interactions at the Grand Gulf facility. A similar letter documenting completion of volunteer GQA interactions with the licensee for the Palo Verde Nuclear Generating Station will be issued by the staff in the near future. Therefore, the pilot program 1 phase of volunteer interactions on GQA is considered complete. Development of the GQA inspection Widance procedure will continue to be tracked under Activity 1.3. 4. The staff received a supplemental amendment request for the TS lead plant, San Onofre i Nuclear Generating Station (SONGS), in early January 1998. The staff has completed preparation of the safety evaluation for changes to the SONGS TS for the safety injection tanks and low pressure safety injection system. The amendment package is being reviewed by the NRR techr:ical staff and the Office of the General Counsel for concurrence, The staff expects to issue the SONGS amendments in May 1998. This is a change from the previous date of March 1998. 5. In a letter dated March 2,1998, the licensee for Arkansas Nuclear One (ANO), Units 1 and 2, requested relief from the staff's position in NUREG-0737 for hydrogen monitoring. 1 The request was made in accordance with " Task Zero" of the Risk-Informed, Performance-Based Regulation Pilot Program ("Whole Plant Study") proposed by NEl. The staff is currently assessing the most appropriate licensing approach to this request. 6. The target schedule for completion of revisions to the core inspection has been revised to May 1999. Finalization of the core inspection procedure revisions required coordination with 10 NRR branches and resulted in a longer than anticipated review and concurrence cycle. 7. The schedule for issuance of the draft and final GQA inspection procedures has been revised. The staff expects to issue the draft GQA inspection guidance by July 1998 and the final guidance by October 1998. This schedule change was necessitated by key personnel

i 20-being assigned to higher priority tasks such as the finalization of the risk-informed regulatory documents for graded quality assurance and inservice inspection and the Millstone restart team inspection. 8. In order to improve the accessibility of risk information for inspector use, a new subtask has been added to Activity 1.3. This new item, " evaluate methods of presenting risk analysis results in a form most useful to inspectors and develop options relating to providing inspectors with plant-specific risk information," has a completion target schedule of December 1998. 9. The Office of Research is preparing a report entitled " Unresolved Safety issues and Generic Safety Issues Related to the IPE Program". The RES report (to be completed in May 1998) identifies generic issues and staff views on the adequacy of the proposed resolution and will serve as the basis for the selection of generic safety issues to be audited, and at which plants. The staff has revised the completion date for these milestones to TBD. A schedule for completion of these tasks will be developed after a review of the RES report by NRR is completed. 10. Activity 1.7, " Regulatory Effectiveness Evaluation," has been moved to Section 2 of the PIP (new Activity 2.11), to more closely link it with the Generic Safety issues program and the Regulatory Excellence Plan, for which RES has the lead. 11. In accordance with the reassignment of rule-making activities under DSI-22, Activity 2.3, " Support For NRR Standard Reactor PRA," has been moved to Section 1 of the PIP because it has been transferred to NRR; it will be tracked as an item under Activity 1.8, " Advanced Reactor Reviews." 12. The item " define use for information, clarify ' regulatory use,' and assess the most effective methods for data collection" was inadvertently deleted from Activity 1.10 in the last quarterly update (SECY-98-012). This item has been added back into the Activity Table 13. Change in the project's principal investigator and funding availability resulted in the slippage of this target date. 14. A preliminary prioritization of issues has been developed based on input from RES, NRR, and AEOD. Work will be initiated in FY 98 for those issues for which there is a consensus that they are of high priority. L 15. The staff has reviewed all the 76 IFE submittats and issued staff evaluation reports (SERs) l on their findings to each licensee with one exception, Browns Ferry 3 (BF3). In three of the SERs, it is indicated that the staff was not able to conclude that the licensee met the intent of Generic Letter 88-20 for their plant (s). These three IPEs include Crystal River 3, Susquehanna 1&2, and BF3. The staff met with the licensees for both Crystal River 3 and Susquehanna 1&2. It appears that these licensees have addressed the staff concerns and the staff willissue updated SERs by the end of June 1998. RES forwarded to NRR a draft SER on BF3 in December 1997; the staff is planning to meet with the BF3 licensee during the second calendar quarter.

.o 21 16. The staff has not yet received a revised plan for the NEl initiative. The completion date for an initial review has therefore been changed to TBD. ] 17. ASME has formed a task group, which includes a representative from the staff, to draft PRA standards. Although the staff continues working with ASME in this activity, has some i concem in regard to the scope of the group's work. The NRC sent a letter to ASME expressing the staff's concerns and desires. Attachments 3 and 4, respectively, are NRC's letter and ASME's response. 18. A Commission paper with the staff's recommendations will be provided in April,1998, instead of March. 19. The date for the final report was changed because more time was needed to analyze new frequencies for large, medium, and small break loss of coolant accidents and allow more time for external review. The date has been changed to July 1998. 20. The date to put,lish the revised LER rule was changed from October 1999 to December 1999 to agree with the proposed rulemaking plan. 21. The target schedule to develop guidance for implementing the radiological criteria for license termination was extended one month to March,1998 to address unforeseen technical complexities. The guidance was forwarded to the Commission in March and will be issued following Commission approval. 22. The target schedule has been changed to correct a typographical error. 23. The target schedule to develop a framework for the use of PRA in regulating nuclear materials has been extended indefinitely to incorporate definitions and concepts from the paper, " Risk-Informed, Performance-Based Regulation," that is now being developed by the Commission. 24. On March 17-191998, the Department of Energy (DOE) and the staff held a technical exchange in San Antonio, Texas. DOE's plans and methodology for conducting a total-system performance assessment in support of its upcoming Viability Assessment were discussed. Also discussed was the status of the staff's effort to develop its independent performance assessment review capability. 25. This study, which would have demonstrated methods for PRA of spent fuel storage facilities, has been suspended consistent with current budget constraints. Potentially, the results of this study could have been used to support the adequacy of the existing dry-storage system designs, procedures, and regulations. Also, the results were expecte d to be used to make recommendations about the extent to which an expansion of PRA rr.einods for dry-cask storage would provide further useful information. The staff believe+, this study should be resumed when resources permit. 26. The target schedule for updating the database on transportation of radioactive materials for future applications has been extended from the end of FY 99 to June,2001 because of a delay in funding. 4 i J

n 22 27. The target schedule for revalidating the results of NUREG-0170 for spent fuel shipment risk estimates has been extended from June,1999 to December,1999 because of a delay in funding. 28. The Office of Enforcement developed enforcement guidance in June 1997, that provided guidance to the staff in the consideration of risk in enforcement actions (Enforcement Guidance Memorandum (EGM) 97-011). The EGM acknowledged the uncertainties associated with risk assessment due to the differences of PRA models utilized by the staff and licensees and noted the need for judgement to be applied in using risk as a factor in enforcement decisions. However, the EGM emphasized that risk has value as an assessment tool and should be used, when warranted, as a factor in determining the appropriate enforcement sanctions. 29. Include Regional Senior Analyst evaluation on Paneled Enforcement cases when warranted. 30. Interface with NRR SPSB to consider additional examples for the Policy Supplements 1 L

o 1 23 ABBREVIATIONS ABWR advanced boiling-water reactor AEOD Office of Analysis and Evaluation of Operational Data ACRS Advisory Committee on Reactor Safeguards AIT augmcnted inspection team ANO Arkansas Nuclear One A/M accident management ASME American Society of Mechanical Engineers ASP accident sequence precursor ATWS anticipated transient without scram C completed CCF common-cause failures CFR Code of FederalRegulations CRGR Committee to Review Generic Requirements CNWRA Center for Nuclear Waste Regulatory Activities DOE Department of Energy DSI Direction Strategic issue EGM Enforcement Guidance Memorandum EP emergency preparedness EPIX Equipment Performance and Information Exchange j HLW high -level waste HRA human reliability analysis GQA graded quality assurance GSI generic safety issue JTA job task analysis IMC inspection manual chapter INPO Institute of Nuclear Power Operations IP inspection procedure IPA iterative performance assessment IPE Individual plant examination IPEEE individual plant examinations of extemal events llT Incident inspection team IST inservice testing ISI inservice inspection LER licensee event report LLW low-level waste LP&S low power and shutdown MACCS MELCOR Accident Consequence Code System NEl Nuclear Energy Institute NPRDS nuclear plant reliabi!Ry data system NRR Office of Nuclear Reactor Regulation NMSS Office of Nuclear Material Safety and Safeguards OGC Office of the General Council PA Performance Assessment Pl performance indicator PIP PRA Implementation Plan PRA Probabilistic Risk Assessment J

o 24 PSBS Probabilistic Safety Assessment Branch RAI request for additionalinformation RCP reactor coolant pump RES Office of Nuclear Regulatory Research RG Regulatory Guide SAPHIRE Systems Analysis Programs for Hands -on Integrated Reliability Evaluations SBO station blackout SECY Office of Secretary of the Commission SER safety evaluation report SCSS sequence coding and search system SRP standard review plan SRA senior reactor analysts SSPI Safety System Performance Indicator SWS service water system "ITD Technical Training Division TS technical specifications FY Fiscal Year VA Viability Assessment I

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===- . Task Numbers Link to PRA implementa* ion Plan 8- ] Only Primary Outputs and Outcomes are Shown l l i .J '_ Updated: April 29,1998 ~ %o5 909o-)

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\\ UNITED STATES / NUCLEAR RESULATORY COMMISSION i WASHIN ETON, D.C. 3080&4001 ,( e.... February 23, 1998 Ms. June Ling American Society of Mechanical Engineers Codes and Standards, Associate Executive Director 345 East 47th Street New York, NY 10017

Dear Ms. Ling:

I was pleased to loam that ASME has initiated an effort to develop consensus probabilistic risk assessment (PRA) standards. The strategic initiatives and plans established by the Commission cell for the staff to increase their interactions with professional societies in developing new codes, standards, and guides needed to support activities important to safety. ) Thic sffort is an important step toward this goal. The quality of PRAs used to support risk informed initiatives is an important issue that the NRC has identified in its Regulatory Guides and Standard Review Plans that are associated with PRA related activities. Development of a PRA standard, with NRC endorsement, can provide a level of confidence to the NRC staff regarding the technical quality of a PRA utilized by a licensee to support a risk informed initiative. Such a standard can, therefore, result in a more focused technical review of the PRA by the NRC staff and thereby make more efficient use of both NRC and industry resources, while still ensuring the safety of the decisions being supported by PRA insights. For such a goal to be realized, any endorsed standard needs to be both comprehensive and ( definitive, providing clear criteria to identify the adequacy of PRA elements that are necessary i to support various risk informed applications. The scope statement submitted to ASME's Board on Nuclear Codes and Standards for approval (Enclosure 1), and early interactions with your PRA standard task group have raised some concem with our staff that your present approach may not provide such definitive criteria. To meet NRC needs, we believe that certain items, at a minimum must be included in the standard, as listed in Enclosure 2. This Standard effort, if successful, can be a major contributor to progress in risk-informed regulation. We are willing to meet with you (or your representatives) to further discuss our needs. The NRC and ASME have a successful history of working together. I look forward to following the progress of this effort. The staff contact is Ms. Mary Drouin in the Office of Nuclear Regulatory Research. You can reach her at (301) 415-6675. Sincerel, 3 /.sho C.Thadani Actin) Deputy Executive Director Sr Regulatory Effectiveness

Enclosures:

As stated cc: R. Simard, NEl 1 ,1,.,* s

' Enclosure 1 ,c ASME Standard on Risk Manacement for Nuctaar Facility Aeolications Erdug This standard sets forth the criteria and methods for applying risk-management techniques to be used to develop risk-informed decisions in implementing nuclear codes and standards to ensure that the cost of compliance is justified by the benefit (reduction in risk) and that the residual risk is acceptable. Guidance on intent lt is intended that this standard be written for nuclear applications but the Foreword will indicate that it may be used in applications beyond nuclear. It will be a high level document covering standardized criteria for risk-managtsment applications intended for use by ASME codes and standards committees, users of the ASME code, and enforcement authorities. Recognized technologies of PRA are to be the basis for the standard, but do not preclude other future technologies. ~ The scope is intended to address the use of expert panels and consideration of factors that blend PRA, performance based, and deterministic aspects. Exolanation This action takes into account the current activity in PTCS to address risk management for non-nuclear applications, allowing for the possibility of broadening the scope of coverage beyocd nuclear in a consistent manner. Upon CCS approval a task group will be constituted under BNCS to develop the initial draft of the standard using the~CCS redesign process. A new standard developmeni committee, under BNCS, will be proposed to serve as the consensus body for the balloting of this proposed standard. 1 l 1 e ( .~ v. i J

e The standard, at a minimum, noods to provide the following: s Specification of the minimum requirements for performing each technical aspect of a quality PRA. The technical elements for a Level 1, full-power internal events PRA should include:* Plant Information Sources Initiating Event Analysis Success Criteria Analysis Accident Sequence Analysis Systems Analysis Human Reliability Analysis Parameter Estimation Intemal Flood Analysis Fire Analysis Level 1 Quantification Analysis and Interpretation of Results Expert Judgement PRA Maintenance

  • Similar elements will need to be identified for a Level 1, full-power, extemal events PRA and a Level 1&2, lowpower/ shutdown, intamal and extemal events PRA.

Specification of the documentation necessary to provide traceability of the work. Specification of the criteria to be used in a peer review that determines whether the required technical adequacy was achieved. \\ Specification of the credentials of the peer review team. Specification of a process for determining which of the requirements are necessary for a specific application. s l l l O ~,t, 4

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r., ASME International des and standards 212 705-8500 345 East 47th Street t212-7058501 New York, NY 10017 2392 "M USA hyglg 4 wu.pch j ktW Blaha RE5 March 9,1998 ] l l Ashok C. Thadani l Acting Deputy Executive Director For Regulatory Effectiveness USNRC l Washington, DC 20555-0001 l

Dear Mr. Thadani:

Thank you for your letter of February 23,1998. This responds to a recent.BNCS request that NRC provide a written expression of its needs pertaining to the standards development effort of the BNCS Task Group on Risk Management. Your lette and its attachments will be given careful consideration by BNCS and the Tas' oup, and we appreciate any additional guidance and input provided by Mary _ ouin as a member of the Task Group. We concur that a management level meeting between ASME and NRC representatives should be held to foster a clearer understanding of the roles and expectations of each organization. We will contact Mary Drouin to make arrangements at the appropriate time. Sincer y, h t-June Ling Associate xecutive Director, Codes and Standards Tel: (212)705-8570 Fax: (212)705-8502 E-Mail: linci@asme. ora Cc: J.A. Perry D.F. Landers R.L. Simard M. Drouin G. Millman G.M. Eisenberg The American Society of Mechanical Engineers .-}}

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