ML20236D736

Transcript of 871021 Briefing in Washington,Dc Re Status of Unresolved Safety/Generic Issues.Pp 1-68.Meeting Viewgraphs Encl

ML20236D736
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Issue date:	10/21/1987
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REF-10CFR9.7 NUDOCS 8710280341
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{{#Wiki_filter:, 01G1A1 Oc - ~ + UNITED STATES.OF AMERICA NOCLEAR. REGULATORYJCOMMISSION ,.,..a..-

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B'riefing on Status of Unresolved Safety /Gener'ic Issues Location:. Washington, D. C., Date: Wednesday, October 21, 1987 O Pages: 1 - 68 9 I '1', e Ann Riley'& Associates ~ Court Reporters 1825 i Street, N.W., Suite 921 (j Washington, D.C. 20006 (202) 293-3950 8710280341 871021 PDR 10CFR PT9.7 PDR

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-.{F-- D 1.S C L A 1-M E R' 3 1" R 2 'I I l 'S l i 4 5 i 6 This is an unofficial transcript of a meeting.of the 7 United States Nuclear Regulatory Commission held on 9 10/21/87 In the Commiss' ion's office at 171'7 H Street, .) l 9 'N.W.. Washington,.D.C. .The meeting was open to public 10 attendance and observation. This transcript.has not been 11 reviewed,' corrected, or edited, and it may contain I!g 12 i n a c c u r,a c l e s. 'l 13' 'The transcript is intended solely for ganaral '14 I n f orma t i ona l, purposes. As provided by 10 CFR 9,103, it is 15 not part of the formal or informal record of decision of the 1 j 16 matters discussed. Expressions of opinion in this-transcript 'I 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in ] 19 any proceeding as the result of or addressed.to any statement I I l-20 or argument contained herein, except as the Commission may l -- 21 authorize. 22 23 I_.- 24 25

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'6-Briefing'on Status of.O'nresolved,V Safety / Generic Ihsues

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9 / 10-1717 H Street, N.W. 11 Room 1130.-. .12-Washington,-D.C. 13 (- 14~ Wednesday, October 21, 1987 15 The Commission met in open session, pursdant to 16 notice, at 10:03 a.m., the Honorable Lando W.,...Zoch, Chairman, 17. presiding. 18 19 ' COMMISSIONERS PRESENT: 20 Lando W. Zech, Cr.inirman 21 Thomas M. Roberts, Commissioner 22 Frederick M. Bernthal, Commissioner 23 Kenneth C. Rogers, Commissioner 1 24 1~ p

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13 W. Parler, OGC i: a, 4' V. Stallo,.EDO i I I L' 5 - ..T. Speis l- ,6-T. Murley r 1 7' .E. Beckjord t.

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-3 ^ J 1V. -P.R O'c E E D I-N G S ,fj ( .2= CHAIRMAN ZECH: Good morning, ladies-and gentlemen.' '3. Today'the Commission will be briefed by the agency's-l4 . Office of ResearchJon the' generic safety issue program, the '5' current process and potential-improvements. 1 '6' Generic. safety issues are concerns that are 1 7 applicabla'to'all,'several, or a class-of reactors or' H 8 facilities. Safety. concerns dre: brought to the. Commission from 9- 'various sources,Lboth internal to the agency and external to lb the NRC, but all are assessed,.prioritized and should.be l 11-resolved ~on:some' reasonable schedule.. 12 The resolution of generic safety issues is en area of 113 priority to the Commission,'and we are particularly interested . ["

1. 4, in making' aura that reasonable progress is being made on the

15 resolution of.these safety issues.

'16 During this briefing, I would like the Staff to let 17 the Commission if the, rate of resolution of these issues is l 18' decreasing,'any backlog, and how long it will take to resolve 19 all current high priority safety issues. 20 This is an information meeting, and no Commission I 21 vote is expected today. 22 Do any of my fellow Commissioners have any opening l-I' '23 comments? 24 COMMISSIONER BERNTHAL: Yes, I want to make a brief = . (s )25 comment, and I guess to start with say that although I can't l - - - - - - - - -9

4 1 claim that I have been in the vanguard of those demanding a - ([ l, 2 meeting.on this subject, it's high time we had a meeting on it. 3 What has concerned me for a long time is the role of 4 research in resolving these issues, and the fact that we 5 continue to have this long backlog, many of the times -- and 6 one of the questions I'd like the Staff to answer -- many 7 times, as I understand it, at least, years' backlog, or at 8 least issues that have been studied for years, and I suspect 9 rather less diligently than might have been, not because the 10 Staff might not want to be diligent, but because we simply 11 don't devote the resources to it, or we haven't asked for the 12 resources. 13 So I'd like those points particularly to be ( 14 addressed, because I have always felt that if this Commission 15 would go before the Congress with a list in the research budget 'of generic safety issues to be resolved and how much it costs 16 17 and how many people we are going to need to do it, I think we'd 18 get the money to do it. But we have never made that kind of 19 approach to this problem, either within the research budget or 20 as the Commission approaching the Congress. 21 Now if there are reasons why this is simply in no 22 sense a personnel and resource' dependent timetable for 23. resolution of these many issues, then I'd like to know what the 24 other lasues may be that are otherwise holding matters up. But (]) 25 I guess those are just the comments and a summary of what I

.q 3 " ; n ' l i, ', 5 I fe L. .il would-like to1see~usLdiscuss today. l f,.[ '2i CHAIRMAN ZECH:-~Any other comments? If not,,Mr. -3' Stallo,Lyou'may begin,Lplease. )

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'MR. STELLO:: Well, thank you, Mr. Chairman. .i 1 L .5 Some of the issues that'the Commission has asked us.

6 to. discuss;this morning are going to be part.of the briefing 7

and we'll sharpen them up-in light of the comments that were ) 8 made when we get-to those areas. ] '9: .The purpose of what we are going to try to do today 10- -- and let-me, before I'get.into more' detail, is to first 11' introduce the' people-here.. 1 l i 12' 'On my far right is Eric Beckjord, the Director of

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" office of Research. To his left is Themis'Speis who will be ) ,{ 14 giving the' briefing, the Deputy Director in the office of I 15 Research. And on the left is Tom Murley, our Director of NR'. j R f 16 To his left, Walt Schwink, who.is' coordinating activities 1 17' between the. offices, because clearly we have the implementation 18 of' generic' issues through the Office of NRR, and the 19.- identification of the resolution through the Office of 20 Research. So there needs to be a very close coupling, and 21 indeed I thina, we have achieved that coupling and are getting 22 these issues now on a tracking system that I'm becoming 23. reasonably satisfied with. 24 I think it is important at the outset to identify how h.7s 25 important it is to have a program like this in the agency. We

6 1 have a staff of very competent, dedicated experts in many ( 2 areas, and they have ideas of how safety can be improved and 3 there needs to be a way in which those ideas can be examined 4 and determined if in fact those are ideas for improving safety 5 of operating reactors. 6 We, of course, have ideas that are generated by the 7 public or the ACRS, or anyone else, so we have a system in 8 place to deal with those issues, and I think it's a very l l 9 important and healthy process that we have built now over a 10 process of almost 10 years, formalizing how to do this, and I 11 think we have learned a lot, and I think there's a lot more we 12 can learn, especially with respect to -- one of the points 13 that's been made is why dess it take as long as it does to get (' 14 the issues resolved. Many of them, in fact, take a long time. 15 There are reasons for some of them. Some of them, I think we 16 could probably move faster. 17 This morning.we will be talking about certain areas 18 where we think we can improve the process. 19 As we go through the briefing this morning, I would 20 urge the Commission if there's any particular area where it's 21 important to stop and to dwell on it, that we just do that, 22 because I don't think we have had a really thorough briefing 23 for the Commission for quite some time. 24 With that, let me turn to Dr. Speis, and let us (.) 25 be. gin.

f: 'y N '7 .11 COMMISSIONER BERNTHAL: Let me'make one other request .- w '. [c l2' here' .As'.I.'look;through your siides, I sea lots of summaries w ? 3 .'and' generalizations of process here. I'd like' to-h' ear a number .4 of examples, outstanding examples, in these various. categories 3' in.the process.: LIf you don't mind doing that, just illuminate-6 our -- 1 7 MR. STELLO: We will. 8 COMMISSIONER BERNTHAL:- -- understanding here. 9 MR. SPEIS: Thank you, Mr. Chairman, Commissioners.. q '10-As.the-EDO said, the briefing will focus on'the l11' current. process lon potential-improvements.' -But we.were asked '12 .to make.sure that we' described the process', you know -- 13' COMMISSIONER BERNTHAL: I understand.

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'14 MR. SPEIS: May I have the next v.tewgraph,.please, i 15 (Slide.) '16 MR. SPEIS: I have an outline of the presentation. I 17 will start by providing yciu with.the definitions of generic 18 issues and unresolved' safety issues. As I said already, I will i 19 describe the process,.the key parts of the process, and the' 20 organizations involved. I will describe the tracking system 211 that we put in place to make'sure that we account for all the 22 issues,that enter the system from -- what people have said, 23 from the cradle to.the grave. i 24 I will discuss the average time that it takes for ] l l(( ) 25 each part of the process. I will provide you a history and.a

( ..y 5. 8: 1 ' status of'all;the11ssues, and last, I will discuss.some' areas 4 .me }j 2' that we;-feel we can' improve the process or the systemj. 3-May I have the next viewgraph, please. h '4 ~(Slide.) 5. MR.' SPEIS: The Chairman already provided the-6 definition, but let me go'over again. 7 Generic issues'are-issues that are-applicable _to all~, 8' several, or.a' class of reactors or facilities. We have two-l 9 classes of generic cafety issues, even though from.a real H l l 10 standpoint there is no distinction. ' 1 11 Generic safety issues, they involve-safety concerns- ~ ~' -12' 'that may affect the design, construction'or operation of all, 13 several or a class of nuclear power plants, and may,have a ~ potential i'or safety improvements, and promulgation of-new or 14 15 revised requirements or guidance. 16-I would like to make the point right now that in .17 general'almost all of the issues that we address here basically c 18 address matters that'are beyond adequate safety. They are in 19 .the realm of safety improvements, because if an issue is 20 tidentified that questioned the existing regulations then we 21 don't proceed via the generic safety' issue process, we take the .22' necessary actions at thot time. l 23 USIs are a high priority generic issue subclass, with 24-special reporting and screening requirements required by 25 Section 210 of the Energy Reorganization Act of 1974, and is

c. =.. - 'O o:.S 9 I '1- . reported by the' Commission: to. Congress in their annual report -

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3,.f-2. to Congress. 3 The criteria for developing USIs from the catalogue. j 'i 4 .of generic issues.are described in NUREG 0705. 5-Basically these are selected as candidates by. { 6-screening the' generic issues. Every.USI^1s= designated by the. 7-Commission itself, and'as I said already, progress on the work' .8 that is done on a USI'is reported to Congress annually. ! - For soms information, back in 1979, when we made the i 10-first report to Congress, we identified 22 of -- 22 of-the 11-issues were designated as unresolved safety issues.. In i 12 December 198'O we added four more. In December 1981'we added I 13 one more for a total of 27.. And out of these 27, only nine A 14-remain to be resolved, and most of them are in very advanced L 15-stages of resolution, as I will talk to you later. l 16. The next viewgraph gives you a kind of a graphic 17 illustration of the process itself. 18 (Slide.] 19 MR. SPEIS: The process includes a number of steps, 20 including the idetitification of the issues. I will say 21 something about each one of them later on. The prioritization l 22 as to potential safety significance. The resolution. This is 4 4 23 the part of the. process where any requirements show up. The 24 imposition on the licensees. This is done normally by rules or 25 generic letters or changes in the standard review plan,

4 i 10 1 2 l' regulatory guides, et cetera. '.( 2' The implementation-in the plans themselves, and l 3 lastly, the verification by -- mostly by regions and' resident i 4 inspectors. ~ 5 As you see on the left of the picture there, in the I 6 identification, everybody is involved, all parts of the agency, j i 7 indluding the ACRS, including the public,. including whoever'has 8 thought about something that could potentially improve the 9) operation-and the design of nuclear power plants. 1 10 In the prioritization resolution, the office of s 11' Research has the lead, even thought NRR is very intimately I 12 involved, and likewise in the imposition, implem'ntation, j e 13 verification, the Office of Reactor Regulation has the lead, 14 even though the other offices are involved. 15 I would like now to say a few things about each part 1 16 of the process. 17 Next viewgraph, please. 18 (Slide.] 19 MR. SPEIS: In the identification, I think we have 20 discussed this already, besically the concerns are raised by I 21 the Staff, by the ACRS, by the Commission, public, mostly as a 22 result of operating events, research, technical review, risk j l 23 assessment studies. 24 For example, in doing a PRA, all of a sudden we will 25 be able to identify an important sequence that has a higher l i J A.

,, J 1 '*1 ~ 3: 11-it . probability.than we thought earlier, and'somehow that is thrown - h l; jh]eM-2'j intoLthe. generic issue basket. l ^ I '4 13! All proposed issues.come to a central point in the d -4 Office of Research. -It's the ARGIB branch, and that i 5l organization is responsible for screening and assigning a ) 6 number, assuming'that the issue is deemed generic. 7. .Now issues not originating in the Office of Reactor 8- ' Regulation are sent to them f'or immediate~ action determination. 9 Now I-think this.is a point that-I would like tol dwell-a little Llo bit, because many people think that.we take this issue, we 11 prioritize them, and we spend five or six years, and resolve '12 them, and only then we take some action. But in many . 7 instances, we don't -- we take action immediately. We don't 13 ds i l'4, put them into the generic hopper basket. 15 We find out that some actions had to be taken, and 16 .th"As actions are taken, either by bulletins or generic 17 letters, or 50.54 letters. 18 Also, many times, even though a generic issue is 19 worked -- some part of the generic issue that we deemed 20 important for something to be done immediately, then we take 21 the action immediately. 22 In fact, on most generic issues or even on most 23 unresolved safety issues, there are parts of that issue that 24 already have been communicated to licensees, you know, along j( 25 the span of time we have been working with them. So we don't

12 j s.- 1 .take an issue and wait till the final process is' complete.. I (' 2' ~want to make that point because that's an important point, and. 3' ~we stressed that point to the GAO also when.they'were doing the 24 ' investigation of the generic issues program. I 5 . COMMISSIONER ROGERS: On that point, I know you have 6 ~ a very mixed bag of things that fall into'that category, what 7 would be a reasonable _ rough time that it would take for 'l 8-immeditte action to manifest itself when something'goes to NRR 9 andLthey decide that immediate action'is called.for? I ~10 MR. STELLO: It depends on the issue. We have had l 1 11 issues that have'come to our attention where we have been able 12 to get abtion by utilities essentially the same day. An 13 _ example,that comes to mind is when we had a problem with the { 14' scram volume on the BWRs, a problem that occurred I think at ~ 15 Browns Ferry some years ago. 16-MR. SPEIS: Partial failure. 17 MR. STELLO: Partial failure. We were able to find 18 out enough about the problem and what actions you ought to take 19 to check immediately with other reactors to assure thet 20 particular problem was understood and precluded from being a 21 problem in other reactors, i 22 If it is really important, we have mechanisms in 23. L place where we can get action in a matter of literally hours, j and then depending on the seriousness of the issue and how much i 24 t I 1; 25-more understanding, it just gradually increases from hours to i k )

I 13 i L 1-daysEto weeks and then' problems that need to be worked, and I (. ' 2 Lguess the one that has been around the longest is.probably i 3-ATWS, and that must have been around for 13 to 14 years. We-4 have worked on it off and on over that period of time. 5 It has the-full spectrum depending on the seriousness 6 of the safety problem as to how immediate the action needs to i 7-be. 8 MR. SPEIS: Mr. Commissioner, you can also get a 9 bette,r statistical view of this by the information on the 10 bulletins and informational letters we send out. ~11 [ Slide.] 12-MR. SPEIS: The next viewgraph, since we are on the 13 identification, I will just give you the issues that 'have been i-14 identified, even though later on I will tell you the 15 disposition of the issues. 16 As you see here, from the time this system has been 17 put into operation, we have identified 741 generic issues, that ( 18 is between January 1978 and the present time. The TMI actio'n 19 plan alone provided 369 issues. Those came from the internal 20 NRC studies, the Rogovin Report, the President's evaluation of 21 TM', et cetera. I 1 22 There were other issues in various staff reports, 1 23 142, and also in addition to that, in the last six years or so, 24 another 120 issues, for a total of 731 issues. I will provide (.; 25 you. later with the status of the disposition of these 731

14 l 11 , issues. ( 2 (Slide.) 3 3G1. SPEIS: Next, I would like to discuss the 4-prioritization. This is where the issue is defined and its J .5 relationship with other issues is assessed. One of the 6 difficulties we'have in the prioritization is'that the issue is j 7 not well defined when they give it to us. As Mr. Stallo said 1 8 earlier, many people have good ideas, sometimes those ideas are t 9 not very well defined and not very well delineated. 10-Everybody gives us their' issues. In many instances, 11 1 as I said already, those issues are not very well defined and 12 one of the difficulties we have which takes some time in the i 13 prioritization process is to really define the issue very well. t 14 Half of the work is done as far as prioritization is concerned, -15 if you have a good understanding and a good definition of the 16 issue. 17 The prioritization process involves a number of 18 elements. We do a quantitative estimate of the risk reduction f 19 attributed to the issue resolution and also taking into account i 20 implementation cost. This process is described in detail in 21 .NUREG-0933. We did brief the Commission about six or seven 22 years ago on that. -23 We would like to point out that the priority 24 determination is based upon safety significance of issue with - (, 25 cost a secondary consideration. We want to make sure that in

yi; ^ k ' ' .3. 15' om ' l- .this point of the" process, we don't want to subsume an issue '2- .because'of. cost considerations. .It is a secondary .i [ 3: cons'ideration,Javen though later on in the resolution process,: 4-a.more ' thorough regulatory analysis is performed and costs: are l '5- ' considered as appropriate. We'want to make sure that.at the i L 61 prioritization stage, we are kind of conservative. l 7 other factors such as. occupational ~ exposure, averted l 8 ' plant damage costs and uncertainty bounds are.also considered. 1 '9 In addition to doing kind.of a quantitative estimate 1 of:the importance1of the issue in terms of its risk reduction' 11 potential,'we send'the-issue to the cognizant branches which 12-deal with those issues from an engineering point of view. :They i 13 take a look at the prioritization that we came up with and risk-i 14 factors to see if they agree. Many times, they agree and times 15 they disagree. Their comments are taken into account'before a l 16 final decision is made on the prioritization of the issue. 17' inuan this is. complete, the office Director assigns a 18 priority to the issue, high, medium or nearly resolved, 1.ow or 19 drop. The. issues that are given low or' drop,'we don't work on 20-them. We just document them in NUREG-0933. It is possible 21 that maybe in a few years, some other information will show up. 22 Some of these that are in the drop category may show up to be 23 important in three or four years. We have that information 24 cataloged always. ( 25' I'd like to point out also that the ACRS reviews and

16 1 comments on all issues as they see fit. They take every issue (~,., separately. 2 3 This is a very deliberate part of the process, the 4 prioritization process. 4 5 CHAIRMAN ZECH: When you put something in the drop 6 category, what kind of a management review is performed to 7 confirm that designation? 8 MR. SPEIS: Mr. Chairman, the same process, not only 9 the initial exposure of the issue to the risk reduction 10 approach but the branches that deal with the issues from an I 11 engineering standpoint participate in the review and that goes 12 all the way up to the Office Director. 13 ' CHAIRMAN ZECH: Do you keep a record of that? (' 14 MR. SPEIS: We keep a record of that, as I said, in 15 NUREG-0933. 16 CHAIRMAN ZECH: Give your rationale for dropping it? 17 MR. SPEIS: Yes, sir. The ACRS also looks at every issue that we have determined to be in the drop or low priority 18 19 category. 20 CHAIRMAN ZECH: Thank you. 21 (Slide.] 22 MR. SPEIS: The next viewgraph describes the 1 23 resolution itself. Most of tho high and medium priorities are t 24 assigned, as I said, to the appropriate divisions in RES and k (~-)' 25 the remainder to NRR. Sometimes some other offices participate __m___

.} g , 3 17 .l N 11 inithe process.itself,

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- 7j; ,2L . A task actilon plan and schedule is developed for 13I . resolving the issue and forwarded to the RES/NRR Office 4 Director'for approval. "5. 'The responsible divisionLdevelops a detailed

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. technical'resolutionTfor the issue, prepares the regulatory. J '7. analysis and. prepares the resolution. package for' inter-office,* I 8' ACRS, CRGR and Commission review and.public comments. Every l 9 issue that. involves a revised.or'a new requirement! goes out for 10 public comment. -11 This part of the. process I will show you later on. 12 It takes a considerable amount of time. This is really the i '13 guts of'the peer review process where everybody really k,' 14 'participatsa in a very extensive way. 15 The status of the resolution process is tracked in 16, the Generic Issue Management Control System, GIMCS, whlich.is i 17 really'a small part of tho' big system that EDO has put in l 18 place, the so-called Safety Issue Management Syst,em, SIMS. 19-We have a management system that goes up to the 20 resolution process. l 21 (Slide.) 22' MR. SPEISI The next viewgraph describes in summary ] 23 the three other parts of the process, the imposition, the -24 implementation and the verification.. On the imposition part, j hm 25 the office of Nuclear Reactor Regulations prepares and issues

7, __-. -- 7 i im 18 li the; vehicle forJimposing the technical' resolution requirements ..15v T{," 2 'on the. licensees, assuming that out of the process, a z3-- requirement ensues. 'The vehicle for that could be a rule or a. 4 generic letterfor some other licensing guidance. 15 IfLthe issue-is generic, and we'do this consistently 6 with 10 CFR-50.109, and the other Commission regulations.- 7 'On the implementation.part, for plant specific 8, issues, for: example, typically the project manager negotiates a 9 schedule for; implementation and manage: technical reviews of' ~1CF licenses submittals'in response to the imposed requirements, 11' In the office of Resources,,we maintain technical: support to. 12. NRR to assure proper implementation of generic r' requirements. 13 As Commissioner Bernthal said earlier, he would like 14 to see an. example. -I will provida you an example. YouLwill 15 see'how all these steps work using a specific issue as an 16 example. 17' An important part here is to make sure the lead 18-project manager assures there is an uniform imposition of 19-generic-requirements across the plant population and completion 20 of all plants' implementation before a pre-established date. '21 In the verification part of the process -- 22 CHAIRMAN ZECH: Excuse me, on the implementation, -23 when you put out the requirement, do you specify a timeframe 24 for completion? () 25 MR. SPEIS: Yes, sir. We usually try to work in a e

.j .c m, a-19 l l 1'I flexible'way-on the schedules, dependin'g on the importance of l f 2 the issue ~. If'we feel the issue is much more important, we 3

will try to make sure it is implemented sooner.

Usually, most 1 ~. 4 of the issues are implemented during' outages. Maybe Tom or Mr. i '5-Stallo can say more.. 6- -MR..STELLO: To help sharpen this up, at the' time of 1 7' the resolution of the issue, at that point.it goes.over to NRR- '8 to work on the schedules and at that point they work with 9-Research for the schedules. Maybe we ought to let Tom talk 10 .about the role of NRR iniimposing a requirement and developing 11 .the schedules. We adjust the schedules if it is an issue that 12 might require an outage, for example. 13 l( . Why don't you just briefly describe that. I 14, CHAIRMAN ZECH: Please do. 15 MR. MURLEY: It depends a little bit on the nature of 1 16-the requirement, whether it is.in the form of.a rule, let's 17 say, or a. generic lett:er. Frequently, it is a generic letter. 18 In that case, we would send it out to all licensees and request 19 that it be implemented within say two outages or some timeframe 20 like that, from the time they get the letter. .21 Then the project managers will negotiate with each 22 licensee to see what makes sense for that licensee. If there 23 is some particular problems -- our gu 11 is to try to hurry it '24 up as much as we can but we do take into account ( 25 practicalities. n ( L

q 20 1 1 CHAIRMAN ZECH: What do you do.in the case of a ] p. i( 2 licensee who doesn't want to effect the requirement as soon as i 3 you would like? l '4 MR. MURLEY: If it comes down to it, we will issue ~an 5 order-l '6' MR. STELLO: I was trying to recall if we have ever 7 had to do that,.if we have ever had a licensee that didn't I 8 cooperate. I don't remember ariy. We have the authority to do l 9 it. l ] 10 CHAIRMAN ZECH: You have the authority but you are 1 11 saying to your knowledge, you haven't had any significant ? 12 problems as far as compliance is concerned; is.that right? 13 MR. STELLO: As far as agreement from the licensee to 14 do it. 15 CHAIRMAN ZECH: What I am thinking about is kind of a 16 generic requirement that applies to a great many plants and 17 most all of them respond and do you have some recalcitrant 1 J 18 utilities that simply drag their feet, and if so, what do you j 19 do about it? 20 MR. MURLEY: There has been come foot dragging. It 21 is not necessarily because thcy are recalcitrant. Quite 0 22 frankly, sometimes we haven't done as much thinking up front ] 23 about implementation before we issued the rule and the 24 requirement. ,sQ 25 CHAIRMAN ZECH: You have enough authority to get it I

L, N:. 1 o-21 .done if you think.they are;really dragging their feet too.mucht 1-t I' [ s . y, 2, ,isythat. correct?. J 3 MR. MURLEY: Absolutely. q \\ 4 MR. STELLO:. I think one of the problems isLwhen you j

5 comeLup

with a generic solution'and especially if it. applies to-6 all plants, you should recognize just about'every plant in the 1

'7-United States-is different.- You have different-equipment'and 8 particular problems. :The application of.that generic { 9 requi,rement. requires a great deal of plant specific -- 10 CHAIRMAN ZECH: I' understand that. My.only point-

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here is if you'are having specific problems and if'the utility i 12 does not respond as you think it would, I hope you would brin'g ,j. 13 'that to the attention of the Commission, too, so we c'an get 14 involved,'if you think we should. I don't want you feeling 15 that you have to put up with some utility that you really l 16 believe is.not being as responsive as they should. If you have 17 that case, I hope you will bring it to the commission's 18 attention. '19. MR. STELLO: Yes, but I think you have already given 20 .the staff enough authority where it is unlikely we will ever 21 have to resort to that but we wouldn't hesitate. 22 CHAIRMAN ZECH: Fine. Let's proceed. 't 23 MR. SPEIS: On the verification part, the regions 24 normally verify licensee implementation of the imposed > s- ,.(j) 25 requirements by one or some combination of inspections during h.

,i I I L il:- construction, testing;. inspections following implementation and g . w.. ,[ ' 2 ', routine.' inspection / surveillance over life of plant. '3 Again,.I would like to make the point here that'our 4 process is an audit and inspections don't' cover'everything. ;We .5. make'a. judgment, what are.the areas to inspect. We don't n 6 inspect 100 percent of everything. I -7 MR..MURLEY: May:I.make a point her% Temis,'just'to' i l 8- 'give an. example of this? l 1 '9' On station blackout, part of the reason:why things j

10 are.taking longer than we thought'.is that we're having to spend 11:

.the-time'up front to' lay'out the inspection procedures to 12 verify how this is going to. implemented. In other words, we '13 didn't always do the thinking up front on implementation and l(- 14-verification that we're doing now, and so it's taking a little 15 longer. 16 COMMISSIONER ROGERS: You don't have it on your list, 17-but I suspect that you do require some documentation from the -18 licenses that they have done it, and that you have to verify 19 that. But you do have a requirement in every case, do you,. j 20 that there is -- at.the station, that they have met that I l 21 requirement? 1 { '22. MR. MURLEY: Generally, yes. 23 MR. SPEIS: Always as a minimum it has to be 24-available at the plant itself available for inspectors. In i ]. j 2 5 most. instancais, they have to respond, but always as a minimum ) 1 1 i l

}-

l~ t } 1:, at the plant,~the documentation available for inspection. -(. s.-',I 4 '2 -MR. MURLEY: We're going to talk later here about 3 -SIMS, and'maybe that's the place to get into it. 4 .4. . COMMISSIONER ROGERS: Because there's nothing -5'- explicit that says that in this. 6 MR. MURLEY:- Yes. You're concerned about something l. 7 ' dropping in a crack. 8 COMMISSIONER ROGERS: Well, that they haven't really l 9-signed on the dotted line that they have, in fact, done it, and 10 that there's a little,-you know, ballet going on, that the ( 11 inspector _is looking for it and it's supposed to be done and.'so 1 12

on and so forth.

Th'ere's no piece of pape'r.that anybody has 13 signed off that says, "We have actually done that, met that (' 14 requirement." 15 MR. STELLC: Commissioner Rogers, that is one of the 16 major' reasons that I ir.sisted that we generate a tracking-17 system that would take identification of the issue all the way 18 through to verification, so we would know with every sing.le 19 . issue that the particular action has, in fact, not only bee'n 20-accomplished, but we have a way of verifying that it was 21 accomplished. Sometimes it'i as simply as'getting a letter 22 from the licensee, "I have now done what you have said." That - 23 is not enough. 24 We have found even when we have a letter from the 25 licensee, that we've had cases where you're right; they haven't _,.___._m_

r 24 '1 signed:off yet.- 'But even when we had, and we went out to the 2~ plant and we looked'at'the verification to see what they had 3 done, they.had not done'it as well as they ought to. So we now 4 -- and we'll be talking.about it later -- have a' system in. 5 place to make sure that that's done in every single case. 6 CHAIRMAN ZECH: All right. Let's proceed. 7 (Slide.) 8 MR. SPEIS: The next Vu-graph summarizes some 9-additional information on.the tracking system. 10 Tom, do you want to say something more about that?. 11 MR. MURLEY: Well, we found that frequently we 12' couldn't go back and trace particularly some of the older 13' requirements as to whether they had been implemented at a plant T 14 and'how we'd verify that they've been implemented. So some time'ago -- in fact,'it was Vic's initiative that we spend the 15 16 time to dig back.into a lot of these old issues to make sure 17 that we knew, number'one, the status of'each of these issues at 18 each plant and, number two, that we had some record that they 19 had either been implemented or that we were going to implement 20 them. 21 The tracking system is called SIMS, and it has been a 22 major effort on the part of our Project Managers to dig out 23 some of this old information. It's now close to being i 24 completed. We think, say, within a month or so, it should be 25 complete, and from then on keeping it up to date will be

w j 25 i 11-relatively> easy and straightforward. B'ut I think it's. going to l( '2 be'an extremely.important management tool to help us follow 3J these issues and make sure that they are,'in fact, implemented. '4 COMMISSIONER BERNTHAL:~ When'was the tracking 5 program, I assume is what we're talking about'here -. computers I .6. can'do wonderful. things:-- when was.the' system finally finished 7' and set up?. 8 )Uk.SCHWINK: Commissioner,'the architecture, the .j 9 computer architecture,.has been in' existence' sinc ~e the end of ~ l 10 .1984. The' data. loading has proceeded since that. time,.and we 11 think-we'll have a; reasonably accurate and complete data r12 loading'for'all'of the current issues and the past. issues 13 within a month. \\ 14 'The system is dynamic, and once we do get it loaded,_ '15 'of course, then it will'be a. continuing thing that we do for 16 each issue. But'what the system has really brought, aside from 17 .being a tracking. system, is a discipline to the process to not 18 let go of a generic issue until the last plant has physically 19 .made.the modifications. 20 COMMISSIONER BERNTHAL: But you have already, then, 21-been using this system for two years or so. It's just that you 22; haven't got all the data in yet. 23 MR. SCHWINK Well, there are two parts to it. One i .4 is loading the data, and the other is verifying that the. data 2 e.; -is accurate, what we think happened did, in fact, happen at the 25 1

'i- [N 26 v U l1 plant,!and..the verif'ication part is taking longer than the. data" -- f: H - ( f. 3 l2 . loading part.. i 4 3 ' COMMISSIONER BERNTHAL: Okay. L 4 j 4 CHAIRMAN ZECH: All right. Let's proceed. I 5 MR. SPEIS:' The next Vu-graph, please. '6 (Slide.) o 7f This is.a Vu-graph, some information here that 8 -creates problems for all.of us, but;these are the. facts so far. 1 '9 I'm trying to capture here in a summary fashion the time that ,10 it takes'for each. step in the process-11 The prioritization takes about an average 1of six 0 12 ~ months par issue. It's an average; we're talkin'g about -13 averages here.- Again, this is based on all of the data that we 14 have so far.- 15 The resolution, it takes an average of 32 months per 16 issue up to the point that we're ready to issue a final generic 17 requirement. As you will see later on, our goal is to reduce { 18 this to at least 24 months. I l 19 The imposition takes another 12 months, and on the { l 20 implementation, even though I have there 48 months, that is I 1 a 21 more of a goal for the future than the experience. We are 22 still having some difficulty identifying what is the correct 33 number for the average time to implement something. 24 I should point out that this time for implementation . <m 1 25 refers to the last plant to implement the item. Some plants, l 1 l l a

m s ,n 27 i 'of course,1do it-sooner'than others, butLthe. goal right now is. t14 .y .g.c y L s/.' y u. to'make sure that'every'issuefis implemented,in 48' months.

2.

h 3. That.is all of them. I '4 CHAIRMAN ZECH: But I hope'if.it's a priority issue, i 5 that you. don't-just. wait for-48-months to go by.: If it's a s 1 '6- ' priority. issue, I would assume that you'd tell them!to'do it as. 7. lsoon as possible, right?' D ~8: MR..SPEIS: .Yes, si'r. U-9- MR. STELLO: lIf the judgment is that.immediate' action. 10 -or near-term: action:is needed for safety,-that kindLof action 11 .would have already,been accomplished through another vehicle, j 12 ^ CHAIRMAN ZECH: Okay. So you're not talking about I 13 that here at all. r. 14 MR.' STELLO: These are not the~ kind of issues that 15 create'significant, immediate kinds o,f safety issues. l , 16 ' CHAIRMAN ZECH: 'But some are higher priority than 17-others, I'm:sure.. 18 MR. STELLO: Oh, yes. 3 19 CHAIRMAN ZECH: And all I'm saying is, the higher 20 priority ones, I would hope that you would. focus attention on, 21 so you don't accept 48 months for implementation, if.you think '22' ' it should be done a lot sooner. l 23 MR. STELLO: If the judgment is that we need ^24~ 'something done quicker, we clearly will do that. - (,. 25-CHAIRMAN ZECH: But is the priority system working? t _______-_A

.7. n by.: ?,y. g.: 28 ,m> i i l I mean, does'it work?: ~ i. .h 2? MR. STEIlo: 'Yes.. ~ ';v 3 CHAIRMAN ZECH: 'All right.. Because it should. ll . Good, all right. Let's proceed. { 5 MR.>BECKJORD: Station blackout is, coming down'the e z6. . pike:now, and the plan'is to have that implemented within two 7 . years. 8 CHAIRMAN ZECH:- Okay. 9 MR. BECKJORD: That's an importantLone. .10 L CHAIRMAN ZECH: Yes, all right. Priority One. Go .j 11 ' ahead, please'.. 12.. [ Slide.']- .13 MR. SPEIS: The next Vu-graph summarizes the history {4 14 - and the st'atus of the issues, and after:I'm through with dhis I . ill.give you an~ example that Commissioner Bernthal mentioned 15 w 16 ' earlier. 17' --I said already'that you have 731, issues on the books. 18

from the starting time.

The TMI action plan, 369; issues in 19-their various staff reports, 142, for a total of 511, and 20. additional 220 issues, so.the total is'731. 21 Now let's find out what has happened to those issues. ~22-

The issues resolved.

From the prioritization process, 25 23-issues were prioritized as-low; 62 issues were prioritized as 24. drop; 119 issues were integrated with other issues. The ( I 25 definition was such that part of the issue could fit into .m,s_2___m.-_m--.m

r.

c. g

-* ? gi I gl j i e. ,b 29 !u 11-.<

anodher issue'and'make the? issue more-offactive.' 88. issues

.s - - 1, w[ j with'. resolution already. defined in NUREG-0737;-if youiracall at-f ( 3; that time;_we didn't_have.a-very rigorous, and we.were under ~ 1 4 theigun to nake so'me changes,f.and some of those. issues were-1 5( LdefinedLsooner than the prese'nt process calls;for. And.275- '6: ' issues.warefresolved,,and also'41 issues were found to balnon-i y 7; / _ safety Lissues,. falling 'into the licensing issue category, I h ~ 8. regulatory impact,1 environmental.; - 9.- .So'that's a total;of 610 for a. total of 83; percent. t 10 So from.the'731'that we have identified that are' described in ' 11 0933, 610 have'been' disposed of. il2 '- The-issues still to be resolved, there are 1?.1. 13. There are 69 that are in the resolution process, inc1'uding nine k-l '14

USIs,

'15_- COMMISSIONER'BERNTHAL: _.Can you name the nine USIs L16 just to bringjme up to date. -i 17i MR. SPEIS: Yes. Three of them are the steam -18 g4nerator issues,-A-1, A-2, and A-3._ And here is.a misnomer. i 19-Even though we say they are not resolved, actually those issues j 20 'have been implemented h long time ago, and we're trying to l 21 fi'nalize the document. 22 So we have three there. The other one is the A-45, 1 23 the decay heat' removal' issue, station blackout issue, seismic 24 design,~and then we have-two issues dealing with systems ] interaction and safety implications of control systems. 25 e .i I

~fl{l /, - i, 30' -i L 3 l .L.11

COMMISSIONER BERNTHAL

I assume that the station.

9,w,...

.?(/"I 2

blackout issueTin principle would be. covered by the proposed yg

~ '3 ' station blackout ru1e. ,~ 14 MR.:SPEIS: Yes,. sir, coming to you in the next month' <5 Xor so. '6 70t. STELLO: That would be the resolution of that 71 issue. '8 MR.oSPEIS: That will be the final resolution. 9 MR. STELLO: As you can see,.most of these areLwell 10 along. 1 11 -COMMISSIONER BERNTHAL: Yes. And'the seismic issue, p 12-what's the essenceiof that at this point? l i 13 -)GR. SPEIS: We'are' revisiting the seismic criteria 14 based on the'more. knowledge that the seismic people have ' llU5. developed the'last'five, ten, fifteen years. 16 COMMISSIONER BERNTHAL: The question of snubbers, to 17-be or not to be? 18-MR. SPEIS: This would affect some tall tanks. 1 19 COMMISSIONER BERNTHAL: Some what? Sorry? j ) 20 MR. SPEIS: Tall tanks, T-A-N-K-S. I 1 1 21 COMMISSIONER BERNTHAL: Oh, okay. l l "22 MR. SPEIS: Slushing apparently has not been 23 considered in their design, but that's the only thing. So most 24-of the issues -- for example, systems interaction, we have gone () 25 to CRGR once 'n the safety implications of control systems. We o

fi 1

p?

31

L1 :

'araigoing.to'CRGR next month,cand'we h' ave; developed resolutions j 2I on all;of them, basically.. i 3 COMMISSIONER BERNTHAL': And.how does the backfit" 4 -analysis.proce'ss~ interface.with resolving'these' issues? .5 MR.'SPEIS: The backfit' analysis.-is considered in ]l - 6. ' 'every issue. that: we go ' through and propose. -7 COMMISSIONER BERNTHAL: So it is.now a matter of -- 81

MR. STELLO:: Commissioner Bernthal-was not'here for' q

9 .the beginning of it. In prioritizing the issue, cost.and- - 10 everything else is. essentially not part of the picture. The . 11 priority is basically done on the basis of safety. '12 COMMISSIONER BERNTHAL: But'the' question'is, at what~- - 13 point does the backfit requirement come in, as.we resolve'an ^ 14 ' issue? 15 MR. STELLO: When the package is-ready for imposition 16' and.'we have. decided to backfit it. At that point, then the 17 backfit analysis'is added'. But I want to make one point very 1 - 18 clear first. In terms of deciding the priority of the issue, 19 .what it is, it's basically done on a prioritizing ranking 20 . system that you've been briefed on that basically deals with 21 safety. 22 COMMISSIONER BERNTHAL: Yes. I would hope that the -23 backfit process doesn't impose itself too early, if for no 24

other reason, simply because of the Staff resources required.

.y ,Q25 The' impact of the backfit rule on this agency has been i ,,,____,,,_,._.____i_.m.____-a = * - - - -

32 1 primarily been in respect to sopping up a tremendous amount of h2 Staff time and resources, and certainly you don't want to-3 proceed down a long path of resolving an unresolved issue when 4 five minutes' analysis would suggest that there is no benefit l 5 to be gained for very high cost. But on the other hand, you 6 don't want to go through this detailed kind of analysis like -7 we're requiring now unless you need to. 8 MR. STELLO: Could we go back to Slide 57 t 9 MR. SPEIS: Slide 5, please. 10 [ Slide.] 11 MR. STELLO: You can see on the priority -- I think 12 this is the point you're making -- on the priority 13 determination, do you really want to include all of that stuff, 14 or should you just basically come to grips with is there a real 15 safety issue here worth dealing with. 16 COMMISSIONER BERNTHAL:. Right, right. 17 MR. STELLO: And that part of the process is 18 essentially pretty anch done on the basis of safety 19 considerations, okay. 20 COMMISSIONER BERNTHAL: Okay. 21 MR. PARLER: That means to me, then, that if 22 something is highly prioritized at that stage, more likely than 23 not it would pass muster under the first test of the backfit 24 rule; that is, that it would achieve a substantial contribution 25 to safety or whatever the test is.

C> 1, w wt 33 + li 1 MR. STELLO: :Probably. I think'that's'a: fair o ! (a,' -2'

observation..

3 CHAIRMAN ZECH: All"right. ~Thank you. Let's i 4? ' proceed. 5 .MR.'SPEIS: Back to Slide 10, please. l '6 [ Slide.]' 7 (o as I said already, 83. percent have b,een completed, 8 and 17 remain to be' completed. We discussed the nine USIs. We i 9 have 32fhigh-priority issues. The schedule now calls for 70 L 10 percent.of them to be completed within the next two years, and l 11-those-schedule have been given to.the -- I 12 CHAIRMAN ZECH: Mcw many within the next two years? h 13 MR..SPEIS:- 70 percent of the 32. I 14 l CHAIRMAN ZECH: Seven. percent of the -- 15 MR. SPEIS: 70, 70. ~ 4 16 CHAIRMAN ZECH: 70 percent of the 32? 21 or h 17 something like that are supposed to be completed in the next ~ 18 two years; is that right? 19 MR. SPEIS: Yes. And also 70 percent of the 16 i i 20 medium priority. 21 CHAIRMAN ZECH: Okay. i 22 MR. SPEIS: Now we still have 52 issues which need to 23 complete final prioritization, and here I'd like to go the next 24 Vu-graph and talk about that. (); 25 COMMISSIONER BERNTHAL: Let me go back first, or stay l

34 1 where we are for a minute. ( 2 Would you also name a few examples in the high 3 category, the category just below the USI category? Can you 4 name three, four, five outstanding examples there? 5 MR. SPEIS: Yes. Reactor coolant pump seals 1 6 integrity is one high priority. In fact, we recommended to the 7 Commission three years ago that it become an USI and the 8 Commission told us to work on it on a high priority basis. We 9 are working on it as if it is an USI. 10 COMMISSIONER BERNTHAL: Do we have to approve your 11 assignment'of the USI category? 12 MR. SPEIS: Yes, sir. It is a Commission edict of a 13 long time ago. ( 14 MR. STELLO: As I recall, that is part of the act. l l 15 MR. SPEIS: It is written into law. 16 COMMISSIONER BERNTHAL: Have I ever approved the i 17 assignment of something to USI since I got here? 15 MR. SPEIS: Were you here in 1981? 1981 was the last 19 one. 20 COMMISSIONER BERNTHAL: I haven't; no wonder. 21 MR. SPEIS: PTS was the last issue. Were you here in 22 19837 23 COMMISSIONER BERNTHAL: Not until late. 24 MR. SPEIS: That was the last issue brought to the ( 25 Commission, the reactor coolant pump seal. 1 l v.

'4 35 i 11 CHAIRMAN ZECH: If we hadn't had any USI's since [' 2 then, does that imply we have' identified.the most significant 3 safety: issues-for the current operating plants? Is that what-i 4 you are telling us? 5 MR. SPEIS: Yes, sir. 4 '6 COMMISSIONER BERNTHAL: That was my-question. Does 7 that'mean, life is getting a lot better out there? Should I be l 8 concerned that some of thesa' things aren't being bucked up here 19 'that should be? 10 10R. SPEIS: I think I said earlier that the high l 11 priorityfgeneric issues really receive the same treatment as 12 USI's. The only difference is we report to Congress on the 13 USI's, because at that time, Congress decided to make it a .i 1 ( ( 14 . requirement. The high. priority issues, we work on them with 4 l 15 the.same intensity. l 16 COMMISSIONER BERNTHAL: Here comes the question that 17 I raised at the outset and that is the priority that we should [ 18 attach to these things in our presentations to the Congress, 19 both verbal and budgetary presentations. It sounds like the i 20 Congress fully intended that in cases where it is conceivable I 21 that staff resources, money, FTEs could hasten the resolution i 4 22 of such issues, it was precisely those kinds of issues I 1 23 presume the Congress wanted to have identified as USI's and 24 brought before them. I 25 I would hope that we are not hesitating for the sake 1 l

i: . 3 'I . f t'- f j 'l.: i ,W 36 t at ils ' ofLappearance or whatever not.to resolve,'that we'are.not- .(. '2 h'esitating/to resolve ~ things as'.USI's that a're in the high 3 priority' category"and.are being treated as.USI's. s-L L4

MR. SPEIS

commissioner,.we have criteria.for-I 5 screening generic; issues t'o'come up with.USI's and we. apply _ 1 ~6-them'everyl year.- The last time we came to you,:you told"us-a u. 7, what I said earlier.. We do that as part.of the normal process. 8 Maybe we are slightly sensitivs but I don't think so.- I think l n 9-none of them have come to the form that we think we should put I i 10 them'into USI. 11 MR. STELLO: Let me try to answer your question .12 -directly. You can'make it an either/or. I don't believe there 13- ' is.any reservation'or hesitation to buck an issue up to the ] JL 14 commission and.say here is an 1ssue we should go to congress 15 with as an USI. I 16-I think the reason the number are really getting i 17' fewer is we think we have been doing a good. job in screening 18 and identifying issues and as you can see, we started'from a 19 very long list, working through it, and we are finally working 20 our way through the system. 21 This doesn't preclude as we start getting into the 22 individual kind of evaluation, a severe accident, that we might 23 have some other issues that we think ought to be elevated ' 24 because if the potential safety benefit is significant enough, 4 25 we may have some in the future and we won't be reluctant to 4 L

v; -- ; - t. J ' % [ ', 37 - l' iraise themn There.isn't a. reluctance,to rais's,them. . -.g f f-. 2 L 'I think the' reason the numbers'are-coming down'is we i J3; have'done^a: fairly good job in this-agency';.especially'after y-o . Remember, that'was'a.very,;very exhaustive list that'.was -) ~4-TMI. 5

generated:by every conceivable source that we had available.to j

!6 .us. I think we have~'done a good: job.

7

. COMMISSIONER BERNTHAL: The'li'stought.to be getting j 81 shorter. I'just want'to eake'sure it'is really getting shorter-i 9-and now that someLstability is creeping in here, it ought to be ] l 10

gettin such as occupational exposure, averted plant damage 4

-11 . costs and uncertainty bounds are also considered.. '1 .In.a'dition'todoing kind of a quantitative' estimate 12-d i 13 'of-the importance of the issue in terms of its: risk reduction 1 '(X t .14 potential,-we' send th.e issue to the cognizant branches which i '15 ' deal with those issues from an~ engineering' point:of view. They' I 16. take a look at theprioritization that we came up with and risk' 17 factors to see-if.they agree. Many times, they agree and-times ] 4 18 they disagree. Their comments are taken into account before a j .19 final decision is made on the prioritization of the issue. 20 When this is complete, the Office Director assigns a 21 priority to the issue, high, medium or nearly resolved, low or -l 22 drop. The issues that are given low or drop, we don't-work on i 23 them. We just document them in NUREG-0933. It is possible ) u 24 ti.st maybe in a few years, some other information will show up. j 25 Some of these that are in the drop category may show up to be

i s ~ .1. important in'three'or four years. We have that information. ' ~ 7 2. . cataloged:always. .I 3 I'd.like to point out also that the ACRS reviews and i 4. comments on all. issues as.they see. fit. They take every issue l 5 separately.. J l 6 'This is.a very. deliberate part of the process,' the j 7 prioritization process.

8

. CHAIRMAN ZECH: When you put something in the drop 95 category, what kind of a management review is performed to ) 10.. confirm that designation? I -l 11-MR. SPEIS: Mr. Chairman, the same, process, not only l \\ 12 the initial exposure of the issue to the risk reduction i 13 ~ approach but the branches that deal with the issues from an ...]I -14 engineering standpoint participate-in.the review and that goes 15 all the way up to the office Director. 16 CHAIRMAN ZECH: Do you keep a record of that? 17 MR. SPEIS: We keep a record of that, as I said, in i .18 NUREG-0933. 19 CHAIRMAN ZECH: Give your rationale for dropping it? l 20 MR. SPEIS: Yes, sir. The ACRS also looks at every 21 -issue that we have determined to be in the drop or low priority p 22 category. 23 CHAIRMAN ZECH: Thank you. l 24 (Slide.] 25 MR. SPEIS: The next viewgraph describes tl... 1

p

,t J.b,:

3p 1: 'res6lution itself. Most'of.the'high and medium priorities are- '2;

ass gned,1as I..said,..to the' appropriate divisions in"RES and-

' /-..

the remainder to NRR..

Sometimes some other' offices participate i3; 4' in the' process itself. 5 A: task action plan and schedule.is developed for 6 resolving the isdue.and forwarded to the RES/NRR Office-L7 Director'for approval. ] -81 The responsible division develops'a detailed j 'l 9 t'echnical resolution for the issue, prepares the regulatory 'l 10 . analysis.and prepares the resolution package for inter-office, { 11-ACRS, CRGR and Commission revi'ew and public comments. Every 12 issue that involves'a revised or a new requirement goes out for I i 13 public comment. 4 14 .This:part of the process I will show you later on. 3- '15' It. takes a considerable amount of time. This is really the i 16- . guts of the. peer review process where everybody really i

17-

. participates in a very extensive way. J ,18, The status of the resolution process is tracked in l 19 the Generic Issue Management Control System, GIMCS, which is 4 a 20 really a small part of the big system that EDO has put in ) 1 21 place, the.so-called Safety Issue Management System, SIMS. j 22 We have a management system that goes up to the 23 resolution process. 'l 24 [ Slide.) h, 25 MR. SPEIS: The next viewgraph describes in stimmary .i ) 4 l w__-_-____-- =__ b

g:.. 4 ' r. L40-b ' l11 'th's three-other partsof-the process,-the imposition,?the' i [21 -implementation and~thefverification.-.On the imposition part, ~ 3 the office. of -Nuclear-Reactor Regulations prepares and issues

j 4

14 the, vehicle for: imposing the technical resolution' requirements: 1 5-on the licensees,: assuming that out of_the process, a -6L requirement' ensues. 'The vehicle for that could be a rule or a. i !R' 7; generic letter or some other licensing guidanc.a. j 8 If.the issue is generic, and'we'do this consistently. si ,with~10'CFR 50.109, and the other Commission regulations. 9. ? ,10 On.the implementation part, for plant specific cll. . issues, for example,-typically the project manager negotiates a 12 schedule for implementation and manage technical' reviews of j 1 '13-licens'ee submittalslin response to the imposed requirements. .C 14 In the Office of Resources, we maintain technical support to l 15 NRR to assure proper implementation of generic requirements. 16 As Commissioner Bernthal said earlier, he would likei l 17 to see an example. 'I will provide you an example. You will i i

18 see how all these st'eps work using a specific issue as an 19-example.

4 i 20 An important part here is to maka sure the lead 21 project manager assures there is.an uniform imposition of 22 generic requirements across the plant population and completion d 23-of all plants' implementation before a pre-established date. j ] .24 In the verification part of the process -- i 25 CHAIRMAN ZECH: Excuse me, on the implementation, 4 .I

FJ 1 L uf ? j. 41 ) l 1'-

when you put?out the requirement, do you'wpecify a timeframe 1

-) -21 'for completion?: 3' MR.;SPEIS: Yos, sir.' We usually trylto work in a l 4 flexible way.on the schedules, depending on the importance of-5 the. issue.- If we feel the issue is much more important, we j , ill try to make sure it is implemented sooner. Usually,:most 16 w i I 7' ofLthe. issues are implemented during outages. Maybe Tom or Mr.. 8 Stallo can say more. 9 MR. STELLO:. To help sharpen this up, at the time of .\\ 10 the resolution of the' issue, at.that' point it goes over to NRR. I 'l -11 to work on the schedules and'at that point they work with 1 i -12 'Research for the schedules. Maybe we ought to let Tom talk l 13 about the role of NRR in imposing a; requirement and developing i 14 the schedules._'We adjust the schedules if it is an issue.that 15-might require an outage, for example. '16 inly don't you just briefly describe that. I 17 CHAIRMAN ZECH: Please do. ,1 18 MR. MURLEY: It depends a little bit op the nature of j 1 19 the requirement, whether it is in the form of a rule, let's 20 say, or a generic letter. Frequently, it is a generic letter. \\ '21 In that case, we would send it out to all licensees and request { i 22' that it be implemented within say two outages or some timeframe i 23 like that, from the time they get the letter. ~24 Then the project managers will negotiate with each 1 .(s.,).25 licensee to see what makes sense for that licensee. If there )

42 l' is'.some.particular problems -- our goal is to try to hurry it 2-A. 'up.as much as we'can but-we do take into account 3 practicalities. 1 4 CHAIRMAN ZECH: What do you do in the case of a 1 5 licensee who doesn't want to effect the requirement as soon as i 6 you would'like? i 1 7 MR MURLEY: If it comes down to it, we will issue an 8 order. j i 9 MR. STELLO: I was trying to recall if we have ever lo had to do that, if'we-have ever had a licensee that didn't 11 cooperate. I don't remember any. We have the authority to do 12 it. 13 CHAIRMAN ZECH: You have the authority but you are

l(' 1 l

.14 saying to your' knowledge, you haven't had any significant 15 problems as far as compliance is concerned; is that right? 16 MR.' STELLO: As far as agreement from the licensee to 17 do it. 18 CHAIRMAN ZECH: What I am thinking about is kind of a 19 generic requirement that applies to a great many plants and 1 20 most all~of them respond and do you have some recalcitrant 21 utilities that simply. drag their feet, and if so, what do you l 22 do about it? 23 MR.;MURLEY: There has been some foot dragging. It l is not necessarily because they are recalcitrant. Quite 24 1 25~ frankly, sometimes we haven't done as much thinking up front 0 l J

y + 43-l17 about[ implementation before:we issued the rule and the p I4 ?:Y p. ,-4 2. requirement. l[ '. oi lt 3 1CHAIRMANLZECH:. You have enough authority to get it '4 done'if you_.think they are really dragging their. feet too much; ~ ,^ f5- 'is that correct?~ '6' MR. MURLEY: Absolutely. .l I 'hink one of the problems is when you. i 1. 7' MR. STELLO: t 8 come up with a. generic solution and especially if it applies to i 9 .all plants, you should recognize just about every plant in the I i 10 United States is different. You have different equipment and 11 particular problems. The application of that generic 12-

• requirement requires a great deal o'f plant specific --

CHAIRMAN ZECH: I understand that. My only point l 13 L(L' 1'4 here is if you are'having specific problems and if the utility 15 does!not respond as you think it woul,d, I hope you would bring i .16 that to the attention of the Commission, too, su) we can get 17. involved, if you think we should. I don't want you feeling i 18 .that you have to put up with some utility that you really 19 believe is not being as responsive as they should. If you have 20 that case, I hope when we do this pre-screening process, when 21 we have identified a large number of drop and low, maybe we can 22-meet with the people that have raised the issues and maybe in 23 one or two meetings we can convince everyone that indeed, those L24 issues belong to the drop or low priority category, so you (7 25 don't have to have everyone suffer for six months on all these 4

m

7. c m

j .44 1 + 1

1!.

Llow1and1 drop issues.: k[ : ' ! 21' _Nextivfewgraph, please.. \\ee 1 7.- 3: (Slide.J. I 3 4' MR. SPEIS:. The issue'of resolution is the most 5 difficult one..This,is where:an intensive' peer. review, i 6 interoffice, the ACRS gets very heavily' involved. 'Wa meet with .7 them three or four times. We have two or three subcommittee l 8 meetings,-maybe one or two' full committee meetings. We go to-j 9-CRGR, 'they provide their review of the issue, and whether we- ) '10 have.followed the procedures, and whether indeed our resolution i 11 is technically.correet, et cetera, et cetera. .12. So this part of the process takes quite a bit of .13 time.

t think here is an area that no question, management

] ~ -14 attention on our.part will help. I think the peer review takes j 15 longer'than it should. Sometimes office directors and division. 16 directors have.other more important things to do -- at least .i 17 they think -- and maybe they put this at the bottom. So this i I '18 is something that hopefully he will be able-to exercise his 19 moral and physical authority to help us do better. 20 CHAIRMAN ZECH: Well, let me just make a point here 21 that it is my understanding that you assign these generic 22 ' issues to the different offices that are cognizant for them, 23 and then' Commissioner Bernthal has raised a question about 24 budgeting as far as people and dollars are concerned, and },e) 25 'Theimmy, you just mentioned now the possibility of people 3 l

n

) t j ,8 ~45 , C y Y - having -- being busy.with 'other priorities. f 2' i. It.seems to;me this-is a.very important issue, and.I i \\ ~ '3" don't think-any of us are really. satisfied that we're moving'as j 4 fast:as we'can'on this USI, as a, generic issue. As,I know q 4 '5 you've set up a tracking system, you have done a lot of things j 6 -to improve it, and we are making prog'ress,-but I think'we'd all 17 'like to go a little bit faster. 8 .One of.the things that.seems to me we just hit.on

9 here,, emphasize at least, is the priority in the various

.i -10 offices. Our people are busy with all kinds of things going 1 11 on. It seems to me that the office directors really have a. 12 responsibility when thcir people get assigned'USIs and generic .13 - issues to decide -- that decision should be made at a pretty ) 'k' 14 high level. The office directors themselves should perhaps get - l 1 15 involved in what their people are being asked to do. Vic, they 'i 16 may come'to'you, the office directors, and you and your senior 17 management team should, I think, be involved in overseeing this 18 resolution of generic issuos and USIs. 19 I guess we don't really have a dedicated group, you l know, that do nothing but solve these issues. It is my 20 i 21 understanding that they go to the various offices for L 22 resolution. Isn't that right? 23 MR. STELLO: No. The whole purpose of getting this I i 24: . set up is we now have one place for that, and that is in ,Q,. \\ 25 Research, and Theimmy is responsible.

L j t 46 c 1 CHAIRMAN ZECH: No, I understand that, but he doesn't )~ 2-solve himself all these generic issues. I don't think. Is -l .3L that right?.Do you have a dedicated grouplto solve generic 4 issues? 5 MR. SPEIS: 80 percent-are in Research now. I think 16 the_ point I was trying to make, which is important, is that the TL 7 concurs -- you know, we cannot go on our own, okay?- We have to 1 8 work with NRR because they are the people who impose these 9 issues. We have to work with them in the final stages of the 10 preparation,fso more management attention is needed on both i 11 sides. I 12 CHAIRMAN ZECH: I understand that. You have a~-- 1 13 MR. SPEIS: But I have dedicated branches who work on (,* 14 issues. o 15 CHAIRMAN ZECH: Fine. But they don't solve them all, 1 16. themselves, as I understand it. They have to go to the other j 17 branches, perhaps to Research, perhaps NRR -- 18 MR. SPEIS: Well, there is always interface in the 19 . review process. 20 CHAIRMAN ZECH: Well, what I am concerned about is 21 those other offices that are involved in these. Now if you are 22' in charge of it, that's fine, you have a dedicated group, I 23 that's fine. But NRR or Research may get involved. You may p 24 need them and they say, "Well, we're too busy." That's the ( ) 25 kind of thing that concerns me. I

gl, j H i ,i ", + ' _47t i .1,

MR.cSTELLO: :And.you're right, you made~a very good

,m o. ,pg Q.g 2 '- point,. Land;that:is:an. area where there's'an awfulilot ofitime, 3 ',.and.-that's the~po' int Theimmy was trying to make. It just 'seems '4' to take.so long'to get' agreement or concurrence,.and-we-have-S .gotsto. find a.way to get those fleshed up, take some reasonable l .6, , amount of' time to'have the discussion and-the debate. If we i

7 can't resolve an issue, don't let it. languish for months and 8-months'and months.

Elevate it, and we are going to do that. ~ '

9 That's.one of

the~. improvements we are going to make.

j

10

. CHAIRMAN ZECH: All right. That's important, though. '11 ' MR'. - STELLO: Just doing exactly what you said, is how 12 we're going to.get,'I'think, a savings in' resources,~ because a 13 lot of resources are devoted to endless debate, and we can.get 1 14: that resolved'by getting a decision.made. 1 15 . CHAIRMAN ZECH: Okay. Well, with that syst'em -- 16-MR. STELLO: Yes. 17 CHAIRMAN ZECH: -- I would expect that we'd make .} 18 better progress in USIs and generic issues. Do you agree? \\ 19 MR. STELLO: I agree. i 20 CHAIRMAN ZECH: Okay. 21 .MR. BECKJORD: Let'me speak to that. With regard to 22' the concurrence question, Tom Murley and I have met on about 23 three times since August on concurrences related mostly to 24 ' generic issues, and there have been problems getting .,.s 25 concurrences because people are busy and working on other - n

c t,, -r .48 4 1 q .11 ' things.< I'think we.can. work that out in time, and he'sigot: 2' -some additional. help coming in the form of a person who is

goingf o l>e~ spending some~ time on these issues.

1 t <3: 1- .4 With regard to the manpower question, I would like to l: .5L point out.that at the time before I came here, the -- if you 1 6 take the Research office as it is now, made up of the component

7 that:came.from NRR, Dr. Speis' division'at that time,'and i

l' 8 Research, there.were about 320 people total in'the combined i s I 9 organization. 10 'We stand today at about 256, plus some vacancies that l-L -11 have to be filled, which rounds out to.about 260. { 1 .12 Under the FTE plan now by the end of the. fiscal year, 13 we'will be at about.246 people. So there's a considerable Li reduction of' staff'that has been underway for the last year and 14 15 a half and will be completed by the and of this year. 16 The manner in which that happens.doesn't' leave us a 17 lot of flexibility on. planning replacement of people, because 18 in a reduction situa' tion like that, you have to depend -- we 19 have had to depend on attrition, and so that happens with 20 individual decisions on career changes and on retirements. And 21 after people have left, only then can you take some action. 2 22 So there are some problems. 23 COMMISSIONER BERNTHAL: How many of those people, 24 though, that work on these issues and how does -- 1 ) 25-MR. BECKJORD: Not all of them. I'm just talking l

, w' ' '.. 'l 1: 6 Of ~ i e 1 49 ali ,o about'-- g". lk ' ls :g Qi@ - 2 , COMMISSIONER'BERNTHAL: No,fno, I understand that, o's J i but:how'doesitheJnumberithat is devoted to resolution 1of these 3 4 , issues -- and I! realize -it's not just in research, ; but how ~does: MO 5~ Lthat" number compare.with'what it is? I notice thatlyouiare-m 6

3. proposing ~here.to assign'one more full-time person to 7

Jprioritization, I guess.- 8-MR. BECKJORD: Well, we can give you the numbers. 1 a n[ .9.' zIts' fewer, I can tell you that. } '10 COMMISSIONER BERNTHAL: How much are you.down inlthe' N -11

allocation of people to resolving.these problems we are talking 12 tabout here today?

~ L 13- . MR. SPEIS: Well, so far we have'been'trying to hold 1.4 the.line with some fewer reductions. Because this is a high 15 priority program of the Commission, you know, we are trying to 1 16 take' reductions in other parts of the program or -- 17 COMMISSIONER BERNTHAL: How many_ people do you have?- 18' I see'you're assigning.one more person today compared with i I a 19 three years ago. j i:j h 20L MR. SPEIS: Total people working on USIs and generic ll 21 issues in the Office of Rosesrch are probably about 22 or 22-something like that. I i 1 23 . COMMISSIONER BERNTHAL: And how does that compare l 24 with three or four years ago? Does anybody know? . (;,j,. 25 MR. SPEIS: We have the numbers. There were more. i ~( l f

^

• /

c + s 50 .~ 1 . CHAIRMAN ZECH:.HaveLyou had' dedicated. people all j

n ~ +

~ .) j jjj!: along working on',these' issues?- 0:2 :- l s 4 3~ .)Dt;. SPEIS : .Yes.' 'On some of-the important issues, 4 1especially the USIs, we have dedicated project 1 managers,1yes,- 35 sir. 6? COMMISSIONER BERNTRAL:- But it sounds.like you're [ -7J down 20' percent or.so? o 8 -)Gl. : SPEIS : We're'down a few; we're down a few. ! -MR. BECKJORD: ife have reassigned, I believe,;two. i 10 ~ people'in'theLlast'two. months, and'we will probably reassign .11 - some'more, and for.myself I anticipate some further changes in 12 theLorganization.- -1 13' COMMISSIONER BERNTHAL: -Reassigned in or out of.this-1 'iN, ~14 program?- .j 15 MR. BECKJORD: To. To.the program, yes. And 'think d l < 16 that there are some other things, as,I say,'in' reorganization,. i 17' probably consolidation, and perhaps some further reassignments. 1 18 The other action that is underway is a -- we are 19 looking carefully at the-prioritization process, and I think we l ~ 20 have also got some people outside working for us on coming up 21. with a better process, which is going to -- the objective of 22 which is to take less time and be more discriminating. 23 Beyond that, I think by the end of this year, I'm 24 going to be in a position to see how we've done since the }h)25 reorganization in April, and at that time that's when we would ~ p w =

,77 7 A '4 + ,o wran 51-15 --taketfurther1 steps on reorganization. -{

x_

T %L) L2l It. ray come to'getting some more people,,too,-because 3 E 3: Ithis is' people-intensive work,fand the otherJ--'there are 4: things that1we have to balance.here. What'I dolnot want~to see 1 l 5-Jis-the1 work:on USIs'and GSIs pushing:the research work outiof. 6 the.next. LI mean that's the immediate thing we can do. We'can ~

7 transfer people from

Research into1 helping in these. areas,.but l

if we do that,1we have.to recognize what is going to happen.to 1

8 .. g. 9' ~Research, and we.have to balance these. things'off. 10: MR. STELLO: I think'we are getting too.far into'a ] 11 budget' discussion'on the issue, and I' don't think we are il2 anywhere prepared to go through it'. I'm convinced we are going 13: to'have enough resources.to do the: job, or if we're going to' l i 1,4 ' come to'the commission and ask the commission to give us those 15 resources. .\\ 16-I' don't see that there's any insurmountable problem J 17 at the moment. 'I think that most of what I~see that will gain j 18 us'the kind of efficiencies to do this job are some of the 19 problems you are going to be hearing about. Just having issues 20 sit around forever'while they're debated and try to get them 21 current -- you'd be amazed at how many FTEs you can save by l 22 making sure that the. issues get managed and management steps in 23 and gets the decisions made to avoid that kind of prolonged -- 24 CHAIRMAN ZECH: Well, that's my point. It's a ) 25 coordination challenge at the senior management level, and I

52 s ,at.

11 l.think'that's"what you're saying, and. I would agree with that.

.h,2< But'it does require the coordination o'f.the' senior' levels. o 3 --MR. STELLO: Yes. 4 CHAIRMAN ZECH: Well, let's move along,iif we can. s 5 [ Slide.] j 6 MR. SPEIS: I think the next viewgraph continues on J7 some of the recommendations on potential improvements for the { 8' resolution. -I think we talked'about them already. I'd'like to 9 go to the last viewgraph.on page 16, on the imposition '10L implementation = verification. -11 (Slide.] 12 MR. SPEIS: One of the things I think Tom Murley 13 mention.ed already, the poor tracking of the issue in the past, 7 { 4 14' .okay, and you know,-the dedicated effort now will help us 15 substantially in this area. 16 Another thing that we weren't doing as well before as 17 we hope to do in the future was the poor definition of what i i 18 licensees ~are to do and on what schedule, and as Tom mentioned, 19 we are taking extra time right now to do that for the station .20' blackout issue, for example. So when it goes out, it's very, g '21 very clear that this is exactly what they have to do. 1 22-Potential improvements, you know, we're putting this 23 in place, we will work with NRR more closely to assure that the 24 issue, resolution and position packages are very clear as to 25 what is required and include appropriate schedule or resource h

7 --- ,f p :. ; $3 .1 L information. 2~, I will explore whether it is beneficial to combine- ', x-3: implementation;of generic' issues in the implementation part, j 14: Also,1I'should have said in the resolution process, L 5 we:are looking at whether.-- we have'been doing some of that'-- _6 whether it makes' sense to combine _some of the issues.that are I i 7 related, and.we have done this on a number of electrical 8 issues. We are looking over whether it makes more sense to 9-comb,ine three or four_ systems issues. But we want to make l L10' sure,;if we do-that, that it doesn't take away from the safety j i 11 benefits and it's only an improvement in the process and i L 12 efficiency of the system. \\ 13 So,.with that, I think. I have completed th' formal s ' ^ 14 part of my presentation, Mr. Chairman, Mr. Commissioners. 15 CHAIRMAN ZECH: All right. Thank you very much. '16 Questions from my fellow Commissioners? Commissioner '17 Roberts? 18 COMMISSIONER ROBERTS: No. 19 CHAIRMAN ZECH: Commissioner Bernthal? '20 COMMISSIONER BERNTHAL: Well, I don't guess I have 21 'any particular further questions. I wish that we would have 22 maybe done a case study or two here. It sort of left the sense 23 of having a vague understanding of what's really involved here. 24 Let me go back and inquire again, because of the i (~~j 25 point you rais'ed about the time required for concurrence and s i 1 1 d

y v/..j q v-o 54. 1

1

approval, and whether and why we couldn't more quickly analyze a.,

~ .{ j [ ' 2' - 'andtresolveisome issues, and I keep going-back-to an issue that'

3.

in one sense.is unprecedented, and that:is the significant, j 4'- whether it even falls in.this program or not,. question of g

5-whether'or.not'a utility.that'for the first time in memory,

-6: Pilgrim, Boston Edison, has stepped forward,. proposing a safety; .7-modification that -- backed by considerable engineering study, 8 which,I~think considerably exceeds the study wa have done.-- 1 9 they argu's will improve safety, and we are on a track basically. j 10; of two. years'here. 11 Now I don't know whether that even falls within the 12 ambit'of what we are~ talking about today. But the NRC is the 13 . impediment,.and it's things like that that make me wonder ,L('z 14- . hether this process is-working the way it should. w -15 MR. STELLO ' We will discuss Pilgrim and what we're, 16 doing; we'll'.do that in a moment. Discussing generic issues,- \\ 17 -that's another matter'. '18 COMMISSIONER BERNTHAL: But it does touch on generic 19 . issues, a generic issue. 20 MR. STELLO: You don't have to have a generic issue l I i 21 .. resolved for a licensee to propose and us to agree with a -l 22 course'of action that he wants to take, separate from any l23 generic issue. 24, Now maybe Tom ought to talk about what we're doing on i ...w I L25 Pilgrim. { H L ___ -

7.:m m - 6..g, 0 6 AL r ^ 55 -1( [-COMMISSIONER BERNTHAL: But, Vic, though,-the point hh [ '21 LthatEI'm making is that'this licensee's well-studied request '3 Lhas been' cast within the net of!a' generic issue, it seems to 4 i 4 me..If not -- now my understanding is that they're talking -l 1 5-Labout'trying to approach this from 50.53,.the provisions under ~6 50.59 a 7. .MR. MURLEY: There are a number of questions that 8-surround that, commissioner, but they had tried to implement a 9" change, a number of' changes under 50.59, and when we looked at lo: that particular one, the' vent, it involves an addition of an 11 isolation valve in containment, which involves a tech spec 12 ' change,.which'you slmply'can't do under 50,59.. 13 But'that's almost a secondary point.- I guess you got ~ h~ .14 a presentation from them when you were there, but they simply, ^ i 15 haven't done'their homework. And I'm asking them a n' umber of 16 questions about'the vent. A vent -- you can classify accidents j 17 into three kinds of categories with regard to a vent: those 18 where a vent clearly helps, those where a vent makes the. 19 accident worse, and those where it doesn't make any difference I 20 one way or the other. 21 I have basically a'sked them to come in and tell me 22 where in your plant a vent would fall into those categories, 23 and they don't have the answer. And I asked my Staff; we don't 24 have the answer either. [( 25. COMMISSIONER BERNTHAL: Has anybody been able' to-

j l 'M 56 q ? 1 conceive of an accident'where it would make'it worse that's &-[a- ) R ..w realistic. 2:

\\

-3. MR. MURLEY: Oh, absolutely. .1 4. COMMISSIONER-BERNTHAL: That's. realistic? ) 5 MR. MURLEY: .Oh, I would say probably in more cases, j f 6 a sequent-vent would open and release fission products where j P 7 they would have been contained otherwise.- And this hasn't been -l L looked at in any kind of quantitative way. 8 a 9 So I've asked if that's been done, and they haven't .10 replied. So the ball is clearly in their court right now on -11, Pilgrim-as a plant-specific issue. 12-COMMISSIONER BERNTHA': Well, your understanding and L l (, 13 ..my understanding of the degree of. study that's been done and i \\ 14 the nature of-disagreement,is just clearl'y different, so maybe ,l 15 we need to resolve that question. '16 But I really want to get to the process here. You 17 know,. here is a sincfle significant issue that has significant L 18 generic implications', and the timetable that's before tts is j 1 19 more or less two years before we would do anything. ] 20 MR. STELLO: No. 21 COMMISSIONER BERNTHAL: Resolve anything, I should 22

say, i

i 23 MR. STELLO: No. If Pilgrim wants to have this fix 24 in their plant, and we are satisfied that that fix is okay from 1 25 a safety point of view, they can do it, and there's a way to L

' i /, c,4 57

11 authorize; going forward.

Then when.we have the generic. ] 4 [ 2' solution, it-might meantws'would, require much less.than they 13 - finally.did por we may require more than they finally agreed! -) 4' to.. We may, require'nothing.. 3 ( ' 5 '- But that'.does,not prevent any utility from-coming in i

6L

and proposing ~a fix' independent of the generic solution.

If a '7L utility were to cometto;us-todayLand say he wants;to add three 8 more diesel' generators and.two gas turbine's to augment his 9' onsite power' supply, and.that'will. eliminate-any issue related

10 to' blackout,-he's not precluded from doing so.

And I. assure 11 you,.we would reviewiit and'quickly come tofa conclusion...It's I I 12 a great idea, I'm sure. ~ -13. But this' issue'is~far more complex. 1 '14 ' COMMISSIONER BERNTHAL: Yes, Vic, but.the statement I ,-15 made and what I really wanted you,to respond to is that there 16 is a' generic question here. And although it may not fit in the i 17' same category as all of these onnes, I think it's generally 18 understood that it's a significant question, and.yet we're on l 19 what basically amounts to a two-year timetable, and that seems 20 to me to.Se a very long time. That was t..e question. 21 And why is it, how is it, that-it takes so long? l 22 MR. STEL?c: It's not two' years. If the licensee has i 23 got the facts, he can come in an support his proposal. I 24 COMMISSIONER'BERNTHAL: I'm talking about the generic phy. 3 . 25 issue, not this. licensee. That's the question.

"s, '1 eW .q l1~

MR.1 STELLO:- 'I.think the generic. issue is~a: lot more

~ 2 . difficult to deal with, but'it will involve the same' questions.. - _..s E3 So maybe'the licensee is really going to take almost as long to 4 answerLtho' questions. I don't know.- But you've got to get the i5 1 answers to those questions to decide.what you want to do, and I 6 ,think we need'them. 97 If you're; going to take action to modify a plant, and -q -8 you.get issues raised,;are you really going to make the plant { 9 safer?. I.think there's no question-we have got to-be convinced l 10. .of that. 111: COMMISSIONER BERNTHAL: Nobody disagrees,with that. i 12 But it's-a-two-year process. That's the thing that I'm asking - 13 about. (: ^ 14' Are we incapable of resolving such an important 15 generic safety issue in less time than two years, or are we not i 16 capable of~doing that? f 17 MR. STELLO: I don't.think I can tell you that we 18 know it can be done in less than two years. If it can, we 19 will. If it can't, it may take longer than that. h. R20 I don't know. It isn't by design that it's two 21 years. We don't want to take two years. But you need to take -22: the time to do the job right. We're not dragging our feet. 23 We're not intentionally -- and this conversation is having a 24 flavor like we're just saying, "Well, it takes us two years, so 25 we're goinIg to use two years." We're doing it as quickly as we O '.

.j u w 59 } <il 'can, as' expeditiously as we can. ,#s)/J2.o

MR.~MURLEY: -Let me add a point on the generic aspect-3

'3 of this; Youtasked,' is it a resource question, and I think in ~ J 4 general it's not resources; it's developing the. consensus that j .5L -takes so much time, both within the Staff and:then with the A'RS,.and then with the industry and.outside. .6! C ._7- , I think'the. MARK-I issue is'a classic example of .i 8. where~there.isn't a consensus. I mean, in people's minds they i 9 may have a consensus,'but there's not a consensus with the-

10 industry.

There's not a consensus within theLStaff even of f 11-what's needed and whether it would be effective. ' ' 12.' Some of these fixes that were proposed in'the past 1 13 ye'ar, in fact some of the Research Staff has said that they '[ L 1,4 wouldn't be; effective. And so it's that consensus-building 15 .that'I find just takes so much time., 16 ~ MR. STELLO: Dr. Beckjord just informed me that our 17 schedule is that we'll be here to you next summer. It's not 18 two years. f 19 COMMISSIONER BERNTHAL: That's one year before -- i 20 yes, I know -- that's one year, and then as I recall, that was I I 21 before we decide what we might do, but we're on a two-year 22 timetable before anything would actually be done. { 23 MR. STELLO: No. 24-COMMISSIONER BERNTHAL: That's the way it work. y, fQ 25, Yes. I mean, that was the schedule. Next summer -- well, we _o

1 don't need to get into the details of thi 60 (ljs) 2 s. ) ,MR. STELLO: Next summer, a propos.ed resolution, 3 recommendations, and depending on what they a 4 re, then it depends on how long it takes -- 5 COMMISSIONER BERNTHAL:It's fair to say that before 6 anything happens, at least, the timetable is two years. 7 MR. STELLO: If it requires an outage, 8 it might even be, quite frankly, longer than that 9 \\ COMMISSIONER BERNTRAL: quite some time. And we've been at it for 10 The concern I have is that this -- si 11 appears to be an example here of a generi nce this c issue -- is that the 12 process is so long on something that we h 13 ave had a lot of C-expert opinion, independent of what the ind ~ 14 ustry's opinion might be, have had a lot of expert opinion o 15 n this issue. MR. STEL10: And it's not consistent. 16 It's not expert opinion for which there is unanimit 17 y of agreement. COMMISSIONER BERNTRAL: Well, there never is. 18 MR. MURLEY: Well, that's why we took 12 years o 19

ATWS, is because there was not a consensus n

20 painful and slow to move forward when you d It just is very 21 consensus. on't have the 22 COMMISSIONER BERNTRAL: good example of another case studyWell, yes, ATWS is 23 Twelve years. 24 didn't have consensus when we finall And we y did move ahead on it, 35 you know. In fact, we had bitter opposition as

60 l 1 don't need to get into the details of this.

h. %

1 -2 MR. STELLO: Next summer, a proposed resolution, { 3 recommendations, and depending on what they'are, then it 4 depends on how long it takes -- 5 COMMISSIONER BERNTHAL: It's fair to say that before 6 anything happens,'at least, the timetable is two years. 7 MR. STELLO: If it requires an outage, it might even I 8 be, quite frankly, longer than that. 9 COMMISSIONER BERNTHAL: And we've been at it for 10 quite some time. The concern I have is that this -- since this 11 appears to be an example here of a generic issue -- is that the 12 process is so long on something that we have had a lot of 13 expert opinion, independent of what the industry's opinion k" 14 might be, have had a lot of expert opinion on this issue. 15 MR. STELLO: And it's not consistent. It's not 16 expert opinion for which there is unanimity of agreement. 17 COMMISSIONER BERNTHAL: Well, there never is. 18 MR. MURLEY: Well, that's why we took 12 years on 19 ATWS, is because there was not a consensus. It just is very 20 painful and slow to move forward when you don't have the 21 consensus. 22-COMMISSIONER BERNTHAL: Well, yes, ATWS is a very 23 good example of another case study. Twelve years. And we 24 didn't have consensus when we finally did move ahead on it, as

- 1.. * + f 'g 61 l' ' MR. STELLO: That's correct. .--{N .I j; 2 COMMISSIONER BERNTHAL: Well, I think enough said.

3 CHAIRMAN ZECH:

Commissioner Rogers? 4 COMMISSIONER ROGERS: Yes. I have just a couple of q 5 comments. 6' Would it be possible for you to give me some examples j 72 of'what are low priority ~ items?- I'm a little concerned about .I 8-that_' category, that' it's there, but it's not-quite there, and c 9' what,you do about it, because that's a place'that frequently '10 leads to trouble because low-priority items don't get the kind ll' of attention that ever.gets-them done, and so they sit out ] 12 there for a long time in general. '13 Now I was just wondering what is a low-priority item s ' 14 on your screening. basis?. 15 MR. SPEIS: Okay. I will give you, but let's make 16-sure that when I talk about low-priority, we drop them. We 17 don't make that a requirement. 18 COMMISSIONER ROGERS: No, no, I understand. I'm ' 19 saying -- that's why I said that they're there, but they're not 20 quite there. They've passed the screen, so that they don't get 21 dropped. But now what happens to them? - 22 What's an example of such an item? Do you have one l 23-handy? Not the ones that have been dropped, but the ones that 24 are still in the system, the 11 out of the 52 that didn't get m 25 dropped but were assigned low priority.

m .jju e, 1 4 .62 o. T .MR. SPEIS: LWell,.'here!is.one: <contaminationfof Efehh 2 instrument air lines,Lpipe break'offacts on control rod' drive-a. ' ' 13 '. hydraulic.-lines'in the drywells.of.the' MARK-I and MARK-II;' '4' iodine. spiking,'whether that' contributes to the offaite I

5

. release,' iodine spiking. 6' COMMISSIONER-ROGERS: Well, now you've got a 7L ~ collection of these. You've got.11 in here out of these g 8 remaining-issues of.52. 9 MR. SPEIS: That's right. 10 COMMISSIONER ROGERS: Do you have a systematic way of 11 'getting at a certain number of those each year or something of 12 'that sort?. 13 I'm concerned about low-priority items that, because i i 14 they are low, just never get done. They, in fact, are almost 15 ' dropped because there's never resources directed to them to 16 clean them up. And sometimes low-priority items become high-17 priority' items because they never get attention. 18 MR. SPEIS: By definition, we don't do anything with 19 . low priority. We drop all low priority. I should have said I l 20 that. But they;are in the books,'and if additional information I 21 on an issue comes out, we scrutinize and try compare that issue 22: with everything that we have in the books. Does it raise the 23 importance of another issue that we thought was low? 24 But we don't do anything with lows and drop. We have '25 them there, though, just for that purpose, so if some L.

ay ,4 ,3- ] n; 163' j -1,

additional:information'shows1up six months from new or some h

>-s '2.- event or some PRA~ study or some-research piece of information .[] 2 3-Lindicates.that we have'to revisit ~that-area,'then we do it, and 4 we.have it'in'the books justJfor'that purpose. 5 'But we only work on high-priority and medium-priority 4 1 1 6

issues.-

COMMISSIONER ROGERS:'lDo they get revisited c '7 E "J 8 automatically orTonly when there's something that.comes up that 9 suggests they should be. revisited? 10. MR. SPEIS:'.Mostly when'it is suggested,:you know. -q i 11 COMMISSIONER ROGERS: Well, it's an eres that I would_ 12 t 'ask'you~to take a little look at, because it's1 been my 13. experience'that.that's a place where there's often a little i ~ ~ ' 14 bubbling trouble, not in what you're doing.; but typically low- ,15 ' priority. items sit out.there. They. don't get attention, and s 16 then somebody is expecting something to happen sometime, but it l -17 never ever nappens. And I just think that.there ought to be 18 some way of reviewing that list of low-priority items just to '19 . see whether they should be dropped or pushed up a little bit on j 20 your scale. 21 . COMMISSIONER BERNTHAL: Or at least give the list to 22 the utilities, so that if we're doing nothing, they can -- 23 MR. SPEIS: Well, ths utilities get that information, 24 of course. You know, 0933, we just update it every year, and ( ) 25 we list all of them, including the low-priorities, is g'ivan to _ _ _ _ _ _ _ - -. - - - _ - = _ - - - - - - -

,x V ; {l I g4; il them for their information. ~ ,l f [ -2, ~ COMMISSIONER ROGERS: 'And just one other thing..You -3. know, I'm new to this whole business,.and these times'look l 4

awfully long to me, as has been already commented on.

I' wonder. j 15 .-if there is any-value to having a kind of fresh look.at the 6, system of resolution. You've talked about some' idea h'ere of-7 . ways to speed it up, but whether.it's possible to have someone 8-else'take c l'ook at this thing from a fresh' point of view,that{ j 9 .hasn't been right'~in throes.of.'it.for. years', to see whether. 10' there's:any way aLnew idea could be evoked or something else to i .11 try-to cut this. time down. 12-I know these are just words, and I'm sure'that you're 13 as concerned about it as we all.are, but somehow it seems to me' "h 14 that' time has to be reduced, the resolution time, from the 32 15 months average,to comething considerably shorter than that. 16-MR. MURLEY: I guess.I have to -- we're continually-17 taking a look at'it', and Eric and I are talking on this, but I i l 18 should reemphasize that this list'is.not all the. safety issues 19 that we're facing. Andfas a matter of fact, I don't think 20 there's anything on this list that remotely compares with the 21. improvement of operations that we are spending a lot of time -22L on. 23 So if, you know, I get forced into a crash effort to 24 resolve these, I think it's going to take away from something -m.

1

-25 that wa are spending a lot of time on. So I would just caution i i

t 0 65 1 "w -) 2' COMMISSIONER ROGERS: But they are generic-issues, 3 which means they go across the board. 4 MR. MURLEY: Yes. 5 COMMISSIONER ROGERS: And if there is a generic 6 . issue, it has the statistical possibility of leading to 7 . something someplace, because it's applicable to everybody. 8 MR. STELLO: We'll try to find a way to take a fresh 9 look. It's' led us to where we are today by going back and i 10 looking at it. I'm convinced there's more to do here. But i ) 'll I'll give you sort of an edge that you can bounce off of. 12 When you go through a generic issue process that f 13 eventually leads to a-rulemaking, our record of doing much ( 14 better then two years, it's awful hard just because of the 15 process itself.to get a lot better than that. It gets tough. 16 MR. SPEIS: Well, on a number of these issues, also 17 the industry takes a dif,ferent view than us and legitimately .i 18 so, and many times we have to, you know -- they. talk to the 19 ACRS, we talk to the ACRS, and somehow we have to work hard to 20 find some consensus that will improve safety. 21 Many times they work much closer with us; many times, 22 you knov, like the ATWS issue that all of you are familiar 23 with. But it's a struggle, and some of these issues, you know, I 24 things are not black and white. This lon't two plus two equals -(xj I 25 four. It's more than that. It's a lot of judgment; it's a lot l 8 i f

1 P 66 11 cf suffering that,you have to go through. ~ 2, COMMISSIONER. ROGERS: Well,..you know, when things.go y 3 along for such a.long time as years and years and years, you-l 4 ~ wonder whether the resolution of it, the achievement of j l 5-consensus, isn't just because somebody outlasted somebody else. ) 1 6 I.mean, you never did get it. Somebody died or resigned or wbathaveyou,.andthereforeitwaspossibletomoveahead. 7 8 So you never really did achieve consensus in a l l 9 situation like that, and I' wonder whether there isn't some i i . device that could be used to force that consensus to.take place 10 11 in.a more -- if it's really just people in opposition, then I i 12 don't know what timeframe is ever a natural one for resolving-13 those kinds of differences. ...(' 14 COMMISSIONER BERNTHAL: The key point, I think, is 15 that any problem that has a half-life longer than the half-life 16 of the Commission will never get resolved. And if you look at 17 the record, I think there is some evidence to suggest that 18 that's a valid law for the resolution of problems in this i \\ 19 agency. j 20 j MR. BECKJORD: If I could add just one point to that. 21 I.think the station blackout is a good case in point. I have l ] 22 talked to a lot of people about that issue and in particular, I 23 know what the ACRS views are. One was explained to me at some 24 length, that they felt that the really essential part of that 25 was to get the utilities' agreement that the direction we are e

4 ~ 67 1 going in is the right one, and to motivate them to take the (I 2 right actions because the matter of what is done, and blackout . 3 is a particular case where every plant is different, it is a 4 generic issue with regard to the need for power, but by no 5 means generic as regards the solution. 6 It is important that people understand what the real i 7 requirement is and how to go about it right, because if they 4 8 don't do that, then we haven't really solved the problem. I 9 thir.k that is a part of the problem that has taken a lot of the I 10 time. Would you agree? ) I 11 MR. SPEIS: Yes and the other plant la all plants are i 12 not the same. If all plants were three loop BWR, dry 13 c6ntainment, that takes more effort and more suffering because j k' A4 of that. 15 CHAIRMAN ZECH: Any other questions?, Commissioner 16 Rogers? 17 COMMISSIONER ROGERS: No, thank you. 18 CHAIRMAN ZECH: Let me thank the staff for e very 19 useful discussion on this very important issue. It does appear 20 we are making some progress btt as we would all agree, I think 21 there is room for improvement. I would ask the staff to 22 continue the efforts to improve. I think we are making ) 23 improvement with the information system. I agree with Dr. 24 Murley's emphasis on operational emphasis. On the other hand, ,) 25 some of these issues are indeed very important. Let's try to i 4

+ j, d ,9.. 68 i ,4 L 1- -s'ee if we'can't. reduce the time if possible.- h .2-I do think a' coordination effort at the senior' level- .s 3 of, staff perhaps could.be effective and helpful. I know the i 4, senior, management is tasked'with all kinds of heavy 15 responsibilities. This is just'another one but it is an u 6-important one. 7-I'would.ask you to continue to work together..Let's 8. see if we can't do '. utter' in $.his regard. : I think that is our 9 main message.- There is a certain amount of frustration that I 10 think you can sense from all of us.and I think from you, too. != 11' You would like-to wind these issues up. Some.are very 12 complicated, very complex, judgmental,'and are not easily c., 13 . solved < k 14 We are trying to enhance safety with these things and 15 certainly not detract from ih. f 16 I do'think we ought to make every effort to speed up 17 the process but at the same time, be satisfied that we are j ) 18 doing the right thing. I think that'is the main message we 19 would leave you with. 20 Are there any other questions? 21 (No response.] 22 CHAIRMAN ZECH: If not, we stand adjourned. Thank 23 you very much. 24 (Whereupon, at 11:40 a.m., the meeting was adjourned.) 25

1-1 e '2 REPORTER'S CERTIFICATE i .3-- ) 4 This is.to certify that the attached events of a 'l 5-meeting of the U.S. Nuclear Regulatory Commission entitled: 6 7 TITLE OF MEETING: Brilefi:ng on Status of-Unresolved Safety / Generic j 8-PLACE'OF MEETING:' issues Washington, D.C. 9 DATE OF MEETING: Wednesday, 0etober 21, 1987 l 10 - 11

were held as herein appears, and that this is the original

- 12 transcript thereof for the file of the Commission taken h 13 stenographically by me, thereafter reduced to typewriting by. 14 zee or under the direction of. the court reporting company, and 15 that the transcript is a true and accurate record of the 16-foregoing events. 17 h- %a.d-9wg 3 -18 1__ 19 20 - 21 - 22 Ann Riley & Associates', Ltd. j 23 l j = 24 f r.. I

l. \\v 25 i

1 _____________.______-------m---

4: q 1, gp : o,, m 2. 1,; ^) .. i e ~Y-1. 0 o e COMMISSION BRIEFING L ON THE GENERIC SAFETY ISSUE PROGRAM l CURRENT PROCESS l AND POTENTIAL IMPROVEMENTS l I T. P. SPEIS' j RES, x27517 OCTOBER 21, 1987 1 ( t 0 lm__E_____. m

v s_ ,c m. .V: .) h .1q ,l GENERIC SAFETY ISSUE PROGRAM j q l PAGE e

DEFINITIONS..:...................................

1 l e-GENERIC ISSUE PROCESS...................-......... 2 TRACKING...................................... 8 l AVERAGE TIME'0F-EACH STEP..................... 9 l e HISTORY AND STATUS OF lSSUES................... 10 4 e-GENERIC' ISSUE PROGRAM EVALUATION i AND POTENTIAL IMPROVEMENTS...................... 12 l

• i l

l b 9 L I i 1 p l-t 1

s 1 ;. _, 1 q 1 p DEFINITIONS { L GENERIC ISSUES ' ISSUES APPLICABLE T0!ALL, SEVERAL, OR A CLASS OF REACTORS OR FACILITIES.. L e GENERIC SAFETY ISSUE (GSI) - A SAFETY CONCERN THAT MAY AFFECT THE DESIGN, CONSTRUCTION, OR OPERATION OF ALL, SEVERAL, OR A CLASS '0F FICLEAR POWER ~ PLANTS AND MAY i HAVE A POTENTIAL FOR SAFETY IMPROVEMENTS AND t -PROMULGATION OF.NEW OR REVISED REQUIREMENTS OR GUIDANCE. .6 USl - A HIGH PRIORITY GSI WITH SPECIAL' REPORTING-AND. SCREENING-REQUIREMENTS REQUIRED BY SECTION 210 0F THE ENERGY REORGANIZATION ACT OF 1974, AS AMENDED,EAND ,lS REPORTED BY THE COMMISSION TO CONGRESS. CRITERIA -FOR USI STATED IN NUREG-0705. e 1 4 1-1 I l

GENERIC ISSUE PROCESS IDENTIFICATION pLL i b v PRIORIT.lZATION RES l V l l-RESOLUTION i , r J L V IMPOSfTION NRR v IMPLEMENTATION J k V VERIFICATION NRR 8 REGIONS v 1 I u - _ _ _ --_ - - _ --

~: -l .l GENERIC ISSUE PROCESS i IDENTIFICATION (ALL) .9 e ' CONCERNS RAISED BY STAFF, ACRS, COMMISSION, AND PUBLIC AS A RESULT OF OPERATING EVENTS, RESEARCH, TECHNICAL j - REVIEW, AND RISK ASSESSMENT STUDIES. 't ' ALL PROPOSED ISSUES'COME TO RES/ARGIB FOR SCREENING AND ASSIGNMENT OF A NUMBER IF DEEMED TO BE GENERIC. ISSUES NOT ORIGINATING IN NRR ARE SENT TO NRR FOR IMMEDI ATE ACTION DETERMINATION. 8 I 4 s 6 _3- + l

,. 4 a E

o GENEPIC ISSUE PROCESS 6 p

L 4 -IDENTIFICATION (CONT.)- STAFF RECORDS SHOW A TOTAL 0F 731: GENERIC ISSUES IDENTIFIED' [ .BETWEEN 1/78'.AND 9/87.- 1, .TMI ACTION PLAN-lTEMS (NUREG-0660, NUREG-0737) i .I '369 1 1 .I'SSilES.IN VARIOUS STAFF REPORTS (NUREG-0371,'NUREG-0471, l II. .NUREG-0510,-NUREG-0705) l 1 s 142 j 1 Ill. ADD.lTIONAL GENERIC ISSUES (INCLUDING HUMAN FACTORS ISSUES) j -NRR 174' l ~ AECD -31 ACRS 12-PUBLIC' 2 REGIONS __.1 - I 220 I ~' TOTAL = 731 l q i I I i e

c GENERIC ISSUE PROCESS PRIORITIZATION (RES)' l e ISSUE IS' DEFINED AND ITS RELATIONSHIP.WITH OTHER ISSUES 'IS l ASSESSED j e QUANTITATIVE ESTIMATE OF THE RISK REDUCTION' ATTRIBUTED TO ISSUE RESOLUTION.AND IMPLEMENTATION COST: i - PROCESS DESCRIBED IN.NUREG-0933 1 - PRA INSIGHTS' EXTENSIVELY UTILIZED e PRIORITY' DETERMINATION BASED UPON SAFETY SIGNIFICANCE OF ISSUE-WITH COST A SECONDARY CONSIDERATION. OTHER FACTORS SUCH AS OCCUPATIONAL EXPOSURE, AVERTED PLANT-DAMAGE COSTS AND UNCERTAINTY BOUNDS ARE ALSO CONSIDERED. e. PRIORITY ASSESSMENT SENT TO TECHNICALLY COGNIZANT OFFICES AND DIVISIONS FOR PEER REVIEW e-REVISE PRIORITY ASSESSMENT AFTER PEER REVIEW, AS APPROPRIATE. 9 OFFICE DIRECTOR APPROVES AND ASSIGNS HIGH, MEDIUM AND NEARLY RESOLVED ISSUES TO APPROPRIATE RES DIVISIONS OR OTHER OFFICES. NO ACTION TAKEN ON ISSUES'PRIORITIZED LOW OR DROP. COPIES OF THE PRIORITIZATION ARE ALSO SENT TO THE PDR, ACRS, AND PUBLISHED IN NUREG-0933. e: ACRS REVIEWS AND COMMENTS ON ALL ISSUES AS THEY S5E FIT. '

~ j x i N l 10 m j ] GENERIC ISSUE PROCESS ^ RESOLUTION (RES/NRR) i i e 'MOST'0F THE,HIGH AND MEDIUM PRIORITY'.!SSUES ARE ASSIGNED T0 THELAPPROPRIATE DIVISIONS IN RES FOR RESOLUTION; THE REMAINDER TO NRR, i . e-A. TASK ACTION PLAN AND= SCHEDULE IS DEVELOPED FOR RESOLVING THE' ISSUE'AND FORWARDED TO THE RES/NRR OFFICE DIRECTOR'FOR ~

APPROVAL, o-

THE-RESPONSIBLE. DIVISION DEVELOPS A DETAILED TECHNICAL-RESOLUTION FOR THE. ISSUE, PREPARES THE REGULATORY ANALYSIS, AND~ PREPARES THE RESOLUTION PACKA'GE FOR INTER-0FFICE, ACRS.,

CRGRi AND COMMISSION. REVIEW. e: THE STATUS OF-THE RESOLUTION PROCESS IS TRACKED IN THE GENERIC lSSUE MANAGEMENT CONTROL SYSTEM (GIMCS) WHICH WAS ~ DEVELOPED IN 1982.-GIMCS IS THE'RES MANAGEMENT. TOOL WHICH IS-UPDATED QUARTERLY BY RES/ARGIB LGIMCS DATA IS INCORPORATED.INTO THE SAFETY ISSUE MANAGEMENT SYSTEM (SIMS).' t e f n j

6 l l GENERIC ISSUE PROCESS l IMPOSITION (NRR) NRR/RES PREPARES AND ISSUES VEHICLE (RULE, GENERIC LETTER, LICENSING GUIDANCE) FOR IMPOSING THE TECHNICAL RESOLUTION REQUIREMENTS ON THE LICENSEES. I IMPLEMENTATION (NRR) PLANT PROJECT MANAGERS (PM) NEGOTIATE SCHEDULES FOR IMPLEMENTATION AND MANAGE TECHNICAL REVIEWS OF LICENSEE SUBMITTALS IN RESPONSE TO IMPOSED REQUIREMENT. RES MAINTAINS TECHNICAL SUPPORT TO NRR TO ASSURE PROPER IMPLEMENTATION OF GENERIC REQUIREMENTS. LEAD PM ASSURES UNIFORM IMPOSITION OF GENERIC REQUIREMENT ACROSS PLANT POPULATION AND COMPLETION OF ALL PLANTS' IMPLEMENTATION BEFORE PRE-ESTABLISHED DATE. VERIFICATION (NRR/ REGIONS) NRR/ REGIONS VERIFY LICENSEE IMPLEMENTATION OF THE IMPOSED REQUIREMENTS BY ONE OR SOME COMBINATION OF: INSPECTIONS DURING CONSTRUCTION, TESTING INSPECTIONS FOLLOWING IMPLEMENTATION ROUTINE INSPEC' TION / SURVEILLANCE OVER LIFE OF PLANT.

q ,..m y 'Jia: .1 yiM' t l GENERIC-ISSUE PROCESS i L o. a; g. I ! TRACKING (RES/NRR/ REGIONS)' f o THERE~IS NOW ONE' TRACKING SYSTEM TO TRACK A' GENERIC l e ISSUE 1FROM CRADLE TO GRAVE: SIMS i

S INFORMATION ON IDENTIFICATION, PRIORITIZATION AND RESOLUTION'!S PROVIDED.BY RES.. GlMCS,;A SUBSET OF SIMS,,IS UPDATED QUARTERLY-TO'SHOW:THE STATUS OF THE PRIORITIZATION AND RESOLUTION PHASES, GIMCS ISSUED BY.

. RES AS A MANAGEMENT TOOL T'O TRACK THE' PROGRESS.0F-GENERIC ISSUE RESOLUTION. 1 9 INFORMATION ON IMPOSITION, IMPLEMENTATION, AND VERIFICATION IS.PROVIDED BY NRR AND REGIONS. I a l 1 4 ^ . I

GENERIC ISSUE PROCESS AVERAGE TIME OF EACH STEP PRIORITIZATION AVERAGE OF 6 MONTHS PER ISSUE ) RESOLUTION AVERAGE OF 32 MONTHS PER ISSUE j (ISSUANCE OF FINAL GENERIC REQUIREMENTS / GUIDANCE) IMPOSITION 12 MONTHS IMPLEMENTATION 48 MONTHS (TWO PLANT OUTAGES MAXIMUM) VERIFICATION WITHIN 6 MONTHS OF IMPLEMENTATION (DOES NOT INCLUDE ROUTINE CONTINUING fNSPECTION) a l g. l u___-_---___

HISTORY AND STATUS OF ISSUES e STARTED WITH 511 ISSUES TO BE PRIORITIZED

• TMI ACTION PLAN ITEMS (NUREG-0660) - 369
• ISSUES IN VARIOUS STAFF REPORTS

- 142 511 i e ADDITIONAL 220 ISSUES (INCLUDING HUMAN FACTORS ISSUES) IDENTIFIED IN PAST 5 YEARS l e AS OF THE END UF FY 1987, THE ISSUE RESOLUTION STATUS IS LISTED BELOW: ISSUES RESOLVED 25 ISSUES PRIORITIZED LOW 62 ISSUES PRIORITIZED DROP 119 IS,, SUES WERE INTEGRATED WITH OTHER ISSUES 88 ISSUES WITH RESOLUTION DEFINED IN NUREG-0737 275 ISSUES ARE RESOLVED (98 W/ REQ'. 8 177 W/0 REQ.) 41 ISSUES ARE NON-SAFETY (LI, RI, E) 610 (83%) l ISSUES STILL TO BE RESOLVED 4 9 ISSUES ARE USIS 32 ISSUES ARE HIGH l 16 ISSUES ARE MEDIUM 12 ISSUES ARE NEARLY RESOLVED 52 ISSUES NEED FINAL PRIORITIZATION (SEE 11) 121 (17%) TOTAL = 731 ISSUES 1

y ,,. ' -b., 1 m HIST 0'RY AND'$TATUS OF ISSUES c ' REMAINING' ISSUES To BE PRIORITlZED AS OF 09/30/87- g: 1 PROJECTED PRIORITY BASED UPON' INITIAL SCREENING NO. OF ISSUES I

• HIGH 1

i a MED1UM 11 f NEARLY RESOLVED 2 RESOLVED ~ 4 LOW 11 DR P 7 i LI 7 RI 3 SUBSUMED _1 TOTAL: 52 i

• ISSUE 125.11.11 - RECOVERY OF MAIN FEEDWATER AS ALTERNATIVE TO AFW j

l I .4.,

GENERIC ISSUE PROGRAM EVALUATION AND POTENTIAL IMPROVEMENTS IDENTIFICATION FINDINGS: e ALTHOUGH THIS PHASE OF THE PROGRAM HAS BEEN I SUCCESSFUL IN PROVIDING A FOCAL POINT FOR THE , STAFF'S CONCERNS, MANY ISSUES ARE OFTEN INCOMPLETELY DEFINED. THE ISSUES CANNOT BE PRIORITIZED UNTIL ADEQUATE INFORMATION IS PROVIDED. e ISSUES SOMETIMES COME I.N LARGE GROUPS AFTER AN INCIDENT (FOR EXAMPLE, THE 1985 DAVIS-BESSE EVENT RESULTED IN 34 PROPOSED ISSUES FOR PRIORITIZATION). MAJOR EVENTS ARE UNPREDICTABLE AND THE RESULTANT ISSUES PLACE A HEAVY DEMAND ON THE PRIORITIZATION PROCESS. POTENTIAL IMPROVEMENTS: e INDIVIDUALS AND/OR OFFICES l'DENTIFYING' ISSUES WILL BE REQUESTED TO PROVIDE BETTER DEFINITION OF PROPOSED ISSUES BY CHECKING FOR DUPLICATION WITH PREVIOUSLY-IDENTIFIED ISSUES, PROVIDING A CLEAR DESCRIPTION OF THE PROPOSED ISSUE, AND MAKING AN ESTIMATE OF THE SAFETY SIGNIFICANCE OF THIS ISSUE. e THE STAFF WILL MAKE A MORE THOROUGH REVIEW OF CONCERNS EMANATING FROM FUTURE MAJOR EVENTS TO REDUCE THE NUMBER OF PROPOSED ISSUES IDENTIFIED I FOR PRIORITIZATION.. w

,. e GENERIC lSSUE PROGRAM EVALUATION l I AND_ POTENTIAL IMPROVEMENTS l PRIORITIZATION l FINDINGS: o PEER-REVIEW PROCESS IS THE MOST TIME-CONSUMING PHASE OF PRIORITIZATION. IT ACCOUNTS FOR, ON THE AVERAGE, 4 0F-THE 6 MONTHS IT TAKES TO P!.10RITIZE AN ISSUE.. e LACK OF-RESOURCES TO WORK OFF THE BACKLOG. POTENTIAL IMPROVEMENTS: e TO SPEED-UP PRIORITIZATION, RES WILL UTILIZE, WHERE PRACTICAL, A MEETING AMONG COGNIZANT STAFF. PERSONNEL FOR PEER-REVIEW IN PLACE OF THE EXISTING ~ MORE " RIGID" PEER-REVIEW PROCESS. RES AND NRR ARE ~ FORMULATING A MEMORANDUM OF UNDERSTANDING WHICH, AMONG OTHER THINGS,.WILL REQUIRE A QUICK TURN-AROUND i (3 WEEKS) ON PRIORITIZATION PACKAGES SENT FOR PEER REVIEW. RES WILL UTILIZE THE EXISTING PRELIMINARY SCREENING STEP IN THE PRIORITIZATION PROCESS TO RESOLVE LOW AND DROP ISSUES. IF THIS PRELIMINARY SCREENING INDICATES AN ISSUE IS OF LOW OR DROP PRIORITY, THEN THE ISSUE WILL BE DISPOSED OF USING A STREAMLINED PROCESS WITH THE PARTICIPATION OF THE ORIGINATOR OF THE ISSUE. e RES WILL ASSIGN THE EQUIVALENT OF ONE MORE FTE TO THE PRIORITIZATION EFFORT TO HELP REDUCE THE BACKLOG. h? 1 GENERIC ISSUE PROGRAM EVALUATION AND POTENTIAL IMPROVEMENTS RESOLUTION q FINDINGS: e ' INCREASED MANAGEMENT ATTENTION IS NEEDED TO ENSL'RE EACH ISSUE IN THE RESOLUTION PROCESS IS RESOLVED ON A REALISTIC, YET AGGRESSIVE SCHEDULE. FOR EXAMPLE, MANY ISSUES'HAVE SLIPPED FROM THEIR L ORIGINALLY ESTABLISHED SCHEDULES. H l e THE TIME REQUIRED FOR CONCURRENCE AND APPROVAL OF RESOLUT'ON PACKAGES (INTEROFFICE, ACRS, CRGR) IS EXTENSIVE (AVERAGES 20 MONTHS). l e SOME ISSUES ARE T00 EXTENSIVELY ANALYZEDJ SIMPLE QUICK SOLUTIONS COULD IN SOME INSTANCES SUFFICE. l e REASSIGNMENT OF TASK MANAGERS OF' ISSUES CAUSES DELAY. POTENTIAL IMPROVEMENTS: e RES AND NRR WILL ISSUE OFFICE PROCEDURES DEFINING THE GSI RESOLUTION PROCESS INCLUDING GUIDELINES FOR EARLY RESOLUTION, UPPER-LEVELMANAGEMENT ' APPROVAL OF SCHEDULE SLIPPAGES, AND BETTER INTEROFFICE COORDINATION. A QUARTERLY STATUS

SUMMARY

OF GSI RESOLUTION PROGRESS WILL BE PROVIDED TO THE EDO HIGHLIGHTING ACCOMPLISHMENTS, PROBLEM AREAS AND PROPOSED RESOLUTION. e l l L 1. GENERIf G UE PROGRAM EVALVATION AND PC'ENTIAl IMPROVEMENTS. 4 { b RESOLUTIONS (CONT.) ] \\ e GSI' RESOLUTION PACKAGES WILL BE SIMULTANEOUSLY ~j I SENTLTO OTHER OFFICES AND THE ACRS FOR REVIEW, CONCURRENCE, AND/0R APPROVAL. TIMELY' REVIEW BY j THESE PARTIES WILL BE SOUGHT WITH PROBLEMS RAISED J TO HIGHER MANAGEMENT, INCLUDING THE EDO. j i e RES, IN CONJUNCTION WITH F.'3R, WILL EXPLORE WHETHER j OR NOT SOME EXISTING UNRESOLVED ISSUES CAN BE ] COMBINED ~AND RESOLVED AS A PACKAGE AND ALSO VIA THE IMPLEMENTATION 0F THE INDIVIDUAL PLANT, EXAMINAT' ION PORTION OF THE SEVERE ACCIDENT POLICY. IF COMBINING ISSUES-HAS THE POTENTIAL TO ACCELERATE THEIR RESOLUTION,.THIS WILL BE DONE. j! e RES AND NRR WILL MAINTAIN CURRENT ISSUE TASK MANAGERS ON THEIR ISSUES WHEREVER POSSIBLE AND WILL ENSURE'A BACKUP TASK MANAGER IS AVAILABLE. j ^ 1 I l l l l 1 k

J 1

0% ~ 'F a! ' GENERIC ISSUE PROGRAM EVALUATION AND POTENTIAL IMPROVEMENTS IMPOSITION / IMPLEMENTATION / VERIFICATION l

FINDINGS:

e POOR' TRACKING'0? ISSUE IMPOSITION, IMPLEMENTATION AND VERIFICATION.IN THE PAST. 4 s POOR DEFINITION OF WHAT LICENSEES ARE T0 DO AND'ON i WHAT SCHEDULE. i POTENTIAL IMPROVEMENTS: i e NRR WILL.INC'LUDE IN SIMS UP-TO-D' ATE'INFORMATIONLON THEL STATUS OF.GSI IMPLEMENTATION BY 11/01/87. A QUARTERLY STATUS

SUMMARY

OF'GSI IMPLEMENTATION. PROGRESS WILL BE PROVIDED TO THE ED0' HIGHLIGHTING PROBLEM AREAS AND PROPOSED RESOLUTION. q e NRR-AND RES WILL WORK MORE CLOSELY TOGETHER T0 ENSURE THE ISSUE RESOLUTION AND IMPOSITION PACKAGES ARE CLEAR AS TO WHAT IS REQUIRED AND INCLUDE APPROPRIATE SCHEDULAR AND RESOURCE INFORMATiON. NRR AND RES WILL EXPLORE WHETHER OR NOT IT WOULD BE BENEFICIAL TO COMBINE THE IMPLEMENTATION OF VARIOUS GENERIC ISSUE RESOLUTION PACKAGES. IF COMBINING THEIR IMPLEMENTATION IS BENEFICIAL, THEN THIS WILL BE DONE. ? 1

NNNNNWWNWW9V0VWWWWWWQVWW9yWGyGVgVgy;VgV;VgVgygVgyggggggggggg \\ Document Control Desk, 016 Phillips x TRANSMITTAL TO: x gl j ADVANCED COPY T0: The Public-Document Room /o d.3//7 DATE: g SECY Correspondence & Records Branch j FROM: E t Attached are copies of a Commission meeting transcript and related meeting i document (s). They are being forwarded for entry on the Daily Accession List and i placement in the Public Document Room. No other distribution is requested or m

required, R

L h Meeting

Title:

4%% // [G M M A /2 bw b -e J D Meeting Date: /o ////f ~/ Open X Closed i Item Description *: Copiew Advanced DCS G to POR C3 h

1. TRANSCRIPT 1

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• POR is advanced one copy of each document, two of each SECY paper.

3 C&R Branch files the original transcript, with attachments, withcut SECY {

g papers.

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