ML17264A943

RES Seminar - the Other Sides of Coins - Ucs - Presentation Slides

ML17264A943
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Issue date:	09/19/2017
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Seminar: The Other Sides of the Coins Dave Lochbaum, Union of Concerned Scientists The Other Sides of the Coins seminar will discuss the mission of and activities of the Union of Concerned Scientists (UCS) and explore successes of the Nuclear Regulatory Commissions regulatory activities viewed through the lens of UCS. The seminar will explore recent activities such as Fort Calhoun flood protection, maintenance rule, reactor oversight process, component aging, OIG safety culture surveys, and knowledge management among other topics.

To get credit in iLearn use Course ID_347150.

To register for the Webinar use the following link:

https://attendee.gotowebinar.com/register/8473022805958701569

- Bridge line No.: 1-800-857-8143 Pass Code: 4592838 Outlook Scheduler Dave Lochbaum, Union of Concerned Scientists (UCS), Director, Nuclear Safety Project One of the nations top independent nuclear power experts. As director of UCSs Nuclear Safety Project, Mr. Lochbaum monitors ongoing safety issues at U.S. reactors, testifies before Congress and the Nuclear Regulatory Commission (NRC), and provides informed analyses of nuclear plant conditions and incidents, such as the March 2011 disaster at the Fukushima Daiichi facility in Japan.

A nuclear engineer by training, Mr. Lochbaum worked at nuclear power plants for 17 years, including many that are similar to the General Electric reactors at the Fukushima plant. He left the industry in the early 1990s after blowing the whistle on unsafe practices and joined UCS in 1996. He then left UCS in 2009 to work for the NRC as a reactor technology instructor and returned to his post at UCS a year later.

Mr. Lochbaum has authored numerous reports, including The NRC and Nuclear Power Plant Safety in 2010, the first in a series of reports he produces annually. Over the years he has been cited thousands of times by a wide range of news organizations, including the Boston Globe, Business Week, Chicago Tribune, Los Angeles Times, New York Times, New Yorker, Rolling Stone, Time, Wall Street Journal, Washington Post, CBS, CNBC, CNN, C-SPAN, Fox, Fox Business, MSNBC, NBC and NPR. Mr. Lochbaum also co-authored the critically acclaimed book, Fukushima: The Story of a Nuclear Disaster (New Press), which was published in February 2014.

U.S. Nuclear Regulatory Commission Two White Flint North Auditorium September 19, 2017, 2:00pm to 3:30pm

The Other Sides of the Coins Dave Lochbaum Director, Nuclear Safety Project dlochbaum@ucsusa.org September 19, 2017 1

Past as Prologue When given the chance to put my two cents in, you probably have heard or read my criticism of the NRC or my whining about some nuclear safety issue. 2

Nuclear Safety Whine List THIS LIST INTENTIONALLY BLANK 3

Past as Prologue Past Today, I want to speak about the other sides of the coins - when the NRCs efforts result in positive nuclear safety outcomes.

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UCS: When and Where Founded in May 1969 by faculty and students at the Massachusetts Institute of Technology Headquarters in Cambridge MA, with offices in Washington DC, Berkeley CA, and Chicago IL (and my office in Chattanooga TN)

More: www.ucsusa.org 5

UCS: Who and What Current staff of about 180 individuals Over 30% of staff are engineers, scientists and technical analysts Staff includes communications specialists, policy analysts, program assistants, lobbyists, economists and development staff 6

UCS: Why UCS is anti-nuclear and pro-nuclear Were anti-nuclear disaster and pro-nuclear safety (not sure why any one would be anything else) 7

UCS: Our Incomes UCSs FY 2016 revenue was ~$32.6 million 8

UCS: Our Outcomes (Nuclear Safety Project) 9

UCS: Our Global Security Program 1992 Dr. Edwin Lyman 1992 Half of UCSs Nuclear Power Team 1996 2002 2003 2002 2011 2007 (07-10) (88-91) 2001 2015 (Ed covers the hard stuff; I tackle the <1996 easy stuff like fire non-protection) 10

UCSs Goals Today Acknowledge and applaud representative positive outcomes achieved by the NRC staff Identify the elements and attributes that help external stakeholders recognize the NRCs positive outcomes (i.e.,

help make such outcomes more transparent) 11

NRC Kudos (abridged listing)

PWR CRDM Nozzle Cracking BWR SLC Test Tank Maintenance Rule Reactor Oversight Process Flooding Pre-Fukushima CFFF Event Lessons Learned NOT Putting Perry in Column 4 Zero-Sum BIP Enhancement 12

More NRC Kudos (still abridged)

Counterfeit, Fraudulent and Suspect Items work NRR and OIG component aging reports Putting Agreement State (Georgia) on probation Hatch undervoltage relay fix OIGs triennial safety culture surveys 13

PWR CRDM Nozzle Cracking March 2001 - CRDM nozzles at Oconee found 14 to be cracked in unexpected locations

PWR CRDM Nozzle Cracking August 2001 - NRC determined key factors causing cracking and put 69 PWRs into three vulnerability bins 15

PWR CRDM Nozzle Cracking March 2002 - Subsequent CRDM nozzle inspections 16 confirm that NRC had right factors and rankings.

PWR CRDM Nozzle Cracking

• Spring 2001 - Cracking identified in unanticipated location

• By August 2001, NRC determined key factors causing cracking, binned 69 PWRs as having high, medium, and low susceptibility for cracking, and mandated inspection regimes based on susceptibility

• The dozen PWRs highly susceptible to cracking were inspected in fall 2001 as scheduled, despite the NRCs need to reallocate resources following 9/11

• When the CRDM nozzle inspections for the 69 PWRs were completed, the results showed that the NRC analyzed and triaged the problem correctly More: http://allthingsnuclear.org/dlochbaum/rapid-regulator-response 17

BWR SLC Test Tank CDBI at LaSalle found that test tank was routinely left filled with water after surveillance tests; but analysis for design basis earthquake assumed the tank was empty. 18

BWR SLC Test Tank 19

BWR SLC Test Tank 20

BWR SLC Test Tank

• CDBI walkdown found SLC test tank routinely left 75% filled with water.

• Surveillance test procedure expressly allowed the tank to remain partially filled following testing.

• CDBI reviewed DBE calculation and found that supports for SLC test tank not designed for loads from non-empty tank.

• Collapse of tank onto nearby safety-related equipment during earthquake could disable SLC.

• NRC issued Green finding.

• Workers at Duane Arnold reviewed OE from this event and discovered they were equally guilty.

Source: NRC CDBI Inspection Report dated 02/15/2011 (ML110460708)

Source: DAEC LER dated 01/07/2011 (ML110070763) 21

Maintenance Rule More: http://allthingsnuclear.org/dlochbaum/nrcs-nuclear-maintenance-rule 22

Maintenance Rule 23

Maintenance Rule Within a decade, the NRC identified an emerging program, implemented an enduring solution, and identified lessons learned from that fix.

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Maintenance Rule October 1986: NRC issues NUREG on maintenance trends March 23, 1988: NRC issues Policy Statement about maintenance and announces plan to pursue rulemaking July 10, 1991: NRC publishes Maintenance Rule June 1995: NRC issues NUREG on lessons from early implementation of Maintenance Rule July 10, 1996: Maintenance Rule becomes effective 25

Maintenance Rule The Maintenance Rule decade yielded an increased awareness of the factors affecting safety system availability and reliability.

The many dividends from this investment of time and effort include:

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Maintenance Rule 27

Maintenance Rule Source: Annual ASP Report (ML17153A365) 28

Reactor Oversight Process Superior Good Performance Performance Satisfactory Performance 29 Source: 1988 Fort Calhoun SALP (ML12209A361)

Reactor Oversight Process Good Performance Superior Performance 30 Source: 1997 Fort Calhoun SALP (ML12212A090)

Reactor Oversight Process 3

Satisfactory Performance (maybe 3 minus) 31

Reactor Oversight Process 32

Reactor Oversight Process 33

Reactor Oversight Process 34

Reactor Oversight Process 35

Reactor Oversight Process Pre-ROP ROP Handful of areas rated 7 cornerstones assessed by NRC findings and ~18 Ratings every 18 to 24 performance indicators months Ratings every 3 months No failing grades Failing grades Under-performing reactors on Watch List without Under-performing reactors pre-determined NRC on To Do list with responses prescribed NRC responses By monitoring more discrete areas more frequently with mandated NRC responses to declining performance, ROP better prevents problems from growing to epidemic proportions.

More: http://allthingsnuclear.org/dlochbaum/reactor-oversight-process 36

Flooding Pre-Fukushima June 2011 - Fort Calhoun became an island in the Missouri River 37

Flooding Pre-Fukushima 08-2010: NRC heard argument that flooding violations had little significance 38

Flooding Pre-Fukushima 10-2010: NRC issued final Yellow finding 39

Flooding Pre-Fukushima 07-2010: NRC issued preliminary Yellow finding for flood protection finding (ML101970547) 08-2010: NRC listened to licensee contend that finding is merely Green (ML102380230) 10-2010: NRC issued final Yellow finding (ML102800342) 06-2011: With flood protection shortcomings fixed, plant survived becoming an island.

40 More: http://allthingsnuclear.org/dlochbaum/the-nrc-in-action

CFFF Event Lessons Learned 07-14-2016: Licensee notified NRC that material containing uranium potentially exceeding the uranium mass limit of 29 kg (criticality control) had accumulated in a ventilation scrubber 41

CFFF Event Lessons Learned More: http://allthingsnuclear.org/dlochbaum/kudos-to-nrc-for-lessons-learned-review-at-42 columbia-fuel-fabrication-facility

CFFF Event Lessons Learned 07-14-2016: Licensee notified NRC of discovery that more than the uranium mass limit accumulated in a ventilation scrubber 07-28-2016: NRC chartered an Augmented Inspection Team to investigate the CFFF event 08-11-2016: NRC issued Confirmatory Action Letter to licensee regarding causes and corrective actions for event (ML16224B082) 10-26-2016: NRC issued the AIT report (ML16301A001) 10-28-2016: NRC chartered a team to conducted a lessons-learned review of the event (ML16301A001) 01-30-2017: NRC issued lessons learned report.

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CFFF Event Lessons Learned The lessons learned report made 18 recommendations in the following areas:

• license review process

• inspection program

• operating experience program

• roles and responsibilities

• knowledge management Great example of pro-active effort not seeking to fix some past sin but to be more effective in the future.

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Preceding Examples Might Suggest That Good Outcomes Require More Regulation or More Enforcement Good Outcomes Can be Achieved via Less Regulation or Less Enforcement 45

NOT Putting Perry in Column 4 1st Quarter 2013: Perry met the criteria for placement in Column 4 due to a White inspection finding and a White performance indicator in the Occupational Radiation Safety cornerstone and a greater-than-green finding in security.

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NOT Putting Perry in Column 4 But Region III sought and obtained permission to deviate from Manual Chapter 0305 and keep Perry in Column 3 (ML13004A403)

More: https://www.nrc.gov/reactors/operating/oversight/deviations.html 47

NOT Putting Perry in Column 4 NRC Region III issued public letter to licensee (ML13018A163) and press release (ML13018A432) explaining that the issues at Perry were:

• isolated and not indicative of broader issues

• understood via baseline and 95002 inspections

• addressed by existing follow-up plans NRC could have stuck to process and wasted resources by a 95003 inspection.

Instead, NRC justified a rare deviation from process and clearly communicated the basis for that deviation.

More: https://www.nrc.gov/reactors/operating/oversight/deviations.html 48

Zero-Sum BIP Enhancement 07-17-2013: NRC staff (HQ and regions) held public meeting with industry and NGO representatives about the ROPs baseline inspection program (BIP) 02-05-2014: NRC staff (HQ and regions) held follow-up public meeting to discuss proposed changes to the BIP 04-04-2014: NRC issued report to NRR Director on BIP enhancement project (ML14017A340) 49

Zero-Sum BIP Enhancement Open, transparent process involving many internal and external participants was commendable - but typical for ROP process changes The atypical commendable aspect to this project was the up-front understanding that any new or expanded BIP inspections needed to be offset by eliminations or reductions elsewhere.

Throwing more resources at something is the easy out. This zero-sum approach maintained BIPs safety focus, avoiding dilution/distraction of NRCs oversight.

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Common Attributes Timely: Not because resolution was within one week or one year but because resolution was achieved without undue delay Clear Communications: What was done and why it was done was explained Durability/Effectiveness: Just as the shortest distance between two points is a straight line, so is the safest path between a problem and its resolution. In these cases, NRC obtained outcomes without tangents, backtracking, etc.

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Conclusions Tens of millions of Americans live within 50 miles of nuclear power plants.

Tens of thousands of Americans work at nuclear power plants.

Thanks to many efforts by the NRC staff like the small sample cited here, these Americans are safer and more secure.

Americans deserve your best effort.

You deserve a big thanks.

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THANKS!

www.ucsusa.org www.allthingsnuclear.org 53