ML20237C103

Reports Status of Probabilistic Risk Assessment Implementation Plan for Period of 980401-0630

ML20237C103
Person / Time
Issue date:	07/31/1998
From:	Callen L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
RTR-NUREG-CR-5500, RTR-REGGD-01.175, RTR-REGGD-01.176, RTR-REGGD-01.177, RTR-REGGD-1.175, RTR-REGGD-1.176, RTR-REGGD-1.177 SECY-98-067-C, SECY-98-139-C, SECY-98-186, SECY-98-186-01, SECY-98-186-1, SECY-98-186-R, SECY-98-67-C, NUDOCS 9808200198
Download: ML20237C103 (36)

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POLICY ISSUE Julv31.1998 SECY-98-186 EQB: The Commissioners FROM L. Joseph Callan Executive Director for Operations

SUBJECT:

QUARTERLY STATUS REPORT ON THE PROBABILISTIC RISK ASSESSMENT IMPLEMENTATION PLAN PURPOSE:

To report the status of the Probabilistic Risk Assessment (PRA) Implementation Plan (PlP) for the period April 1 to June 30,1998.

SUMMARY

This paper describes accomplishments and changes to the staff's PIP for the period April 1 to June 30,1998. The principal accomplishments in this second calendar quarter of 1998 are transmittal to the Commission of the revised standard review plan (SRP) and associated regulatory guide (RG) documenting general guidance on risk-informed decisionmaking for changes to the plant-specific licensing basis; transmittal to the Commission of proposed final risk-informed inservice testing (IST) guidance documents (RG 1.175 and SRP section 3.9.7),

technical specifications (TS) (RG 1.177 and SRP Section 16.1), and graded quality assurance (GQA) (RG 1.176), SECY-98-067, April 2,1998; transmittal to the Commission of revised versions of draft RG and SRP for risk informed inservice inspection (ISI), SECY-98-139, June 11,1998, indicating that the documents would be issued for trial use in the ongoing risk-informed ISI pilot plant and topical report reviews; completion of the safety evaluation report (SER) for the Comanche Peak risk-informed IST program; completion of an additional 13 Maintenance Rule baseline inspections; completion of two more IPEEE staff evaluation reports and an additional eight preliminary IPEEE reviews; completion of the final report on auxiliary feedwater (AFW) system operating experience, to be published as NUREG/CR-5500, l l l CONTACT:

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The Commissioners 2 Volume 1. It is also noted that the staff established several short term initiatives targeting a more efficient review and disposition of an anticipated increasing number of risk-informed licensing submittals; and completed a trial use of the "PRA Applications Database," to help identify and clarify significant regulatory uses of nuclear power plant PRA results and assessment of methods for efficient data collection and dissemination.

BACKGROUND:

In a memorandum dated January 3,1996, from the Executive Director for Operations to Chairman Jackson, the staff committed to submitting quarterly reports on the status of its development of risk-informed standards and guidance. Previous quarterly reports were sent to the Commission on March 26, June 20, and October 11,1996; January 13, April 3, July 22, and October 14,1997; January 23, and May 1,1998. This quarterly report covers the period from April 1 to June 30,1998.

DISCUSSION:

The significant accomplishments and changes for each individual section of the PIP are summarized here. More detailed information is included in Attachment 1.

In order to better ensure execution of the PIP, the Steering Committee for NRC risk-informed activities is being reestablished to give policy, technical, and priority guidance on risk-informed regulatory activities. The committee will be comprised of the office directors from the Office for Analysis and Evaluation of Operational Data (AEOD), Office of Enforcement (OE), Office of Nuclear Regulatory Research (RES), Office of Nuclear Reactor Regulation (NRR), Office of Nuclear Material Safey and Safeguards (NMSS), and the Region 11 Regional Administrator. The Office of the General Ceunsel (OGC) will also be requested to participate. The Steering Committee will be chaired by Mr. Ashok Thadani, Director, RES. The first meeting of the reestablished Committee is briefly discussed under section 2.12," Review of Agency Programs and Processes".

Section 1: Reactor Regulation As the risk-informed regulatory guidance documents are issued in final form and the associated pilot programs are completed, the staff expects to see an increased number of risk-informed licensing submittals. Experience also indicates that improvements in the staff's review process are warranted. To ensure their efficient review and disposition, the staff established the following short term initiatives which are being implemented.

- The priority of risk-informed licensing action reviews is increasing. Allocation of staff I resources will be based on the potential safety benefits of the actions, and on potential l savings of staff and licensee resources, j - A lead project manager (PM) was established for the coordination of the risk-informed, performance-based licensing actions. The lead PM is responsible for identifying, l monitoring, and coordinating risk-informed licensing actions; keeping track of the review schedules; helping identify problems that may require management attention; and coordinating followup actions (if any).

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The Commissioners 3 The Steering Committee for NRC risk-informed activities is being reestablished, as discussed above.

A database of risk-informed licensing actions is being created to facilitate monitoring and tracking of reviews and assist in focusing management attention where needed.

1.1 Standard Review Plans for Risk-Informed Regulation The proposed final versions of SRP Chapter 19 and RG 1.174, documenting general guidance on the use of PRA in risk-informed decisionmaking for changes to the plant-specific licensing basis, were forwarded to the Commission in SECY-98-015 on January 30,1998. In its May 20, 1998, SRM, the Commission approved for publication SRP Chapter 19 and RG 1.174. They are scheduled to be published in final form in July 1998.

The staff completed its review of public comments on the draft risk-informed RGs and SRPs for IST, TS, and GOA. The proposed final versions of the risk-informed regulatory documents for IST (RG 1.175 and SRP Section 3.9.7), TS (RG 1.177 and SRP Section 16.1), and GOA (RG 1.176) were sent to the Commission on April 2,1998. In SECY-98-067. The SRM for SECY-98-067, which approved publication of the Federa/ RegisterNotice and issuance of the

" Final Application-Specific Regulatory Guides (RGs) and Standard Review Plans (SRPs) for Risk-Informed Regulation of Power Reactors" after appropriate revisions by the staff, was issued on June 29,1998. The staff plans to publish the final guides in August 1998.

The staff completed its review of public comments on the draft RG and SRP for ISI. The' staff sent the revised versions to the Commission in SECY-98-139, June 11,1998, indicating that the documents would be issued for trial use in the ongoing risk-informed ISI pilot plant and topical report reviews. This approach sets the ISI RG and SRP apart from the other risk-informed documents recently transmitted to the Commission that were developed with the benefit of pilot plant applications and were proposed for issuance as final documents. The trial versions of these documents incorporate public comments, changes to the general guidance documents (RG 1.174 and SRP Chapter 19), additional management review, and OGC, Advisory Committee for Reactor Safeguards (ACRS), and Committee for Review of Generic Requirements (CRGR) comments. The staff discussed these documents with the full ACRS membership on May 3 and June 4,1998, and with CRGR on May 21,1998. The staff intends to publish the ISI RG and SRP for trial use in August 1998.

1.2 Pilot Applications for Risk-Informed Regulatory Initiatives The staff is continuing to work toward submittal of final safety evaluation reports to the Commission for the ISI pilot plants according to the schedule presented in the May 1,1998, PRA implementation Plan Update (Vermont Yankee - 10/98, Arkansas Nuclear One Unit 2 (ANO-2) and Surry- 12/98). Schedule completion dates are dependent on the licensees meeting critical milestones. Vermont Yankee was in a refueling outage and has not yet responded to the first-round of requests for additional information (RAls) forwarded in March 1998. In response to the l staff's request that Surry supplement its original submittal because of completeness concems, Surry delayed submitting additional material while it requested a review fee waver. The waiver was granted on June 12,1998, and Surry submitted the additional material on June 18,1998. In recognition of substantial industry and NRC interest in expedited review, the staff had prepared first-round RAls based on Surry's initial, incomplete submittal. In a conference call with the u___________________ l

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The Commissioners 4 licensee and Westinghouse on June 24,1998, Surry requested that these RAls be forwarded immediately rather than waiting for the staff's review of the new material submitted on June 18, 1998. The RAls were transrritted to Suny. The staff also transmitted first-round RAls for the ANO-2 submittal and prepared second-round RAls for " Westinghouse Owners Group Application of Risk-Informed Methods to Piping inservice inspection Topical Report," WCAP-14572.

An additional risk-informed ISI submittal from a nor, pilot plant was received from Arkarisas Nuclear One Unit 1 (ANO-1) in June. Browns Ferry and FitzPatrick have, through the Nuclear Energy institute (NEI), also indicated that they intend to submit programs for approval. The staff has developed a long-term plan to address risk-informed reviews to be conducted following the three pilot plant reviews as well as overall risk-informed ISI regulatory activities for Fiscal Year (FY) 1998 to FY2002. The plan is consistent with NRC strategic and operating plans for the period. The staff is also considering granting a relief of up to two years regarding submitting an update of the next 10-year ISI program for the ISI of piping to give licensees an opportunity to develop and obtain approval for the risk informed ISI program for piping, when properly justified.

During the two-year extension period, licensees would be required to continue to implement their current ISI program. For those licensees that receive such an extension, the first ten-year interval under an approved risk-informed ISI program would be shortened by the period of extension, and the total number and types of examinations wouid have to be adjusted ano adequately justified by the licensee based on its individual circumstances.

The staff is preparing a letter to Arizona Public Service documenting completion of the volunteer GOA interactions at Palo Verde. Although the licensee did not submit GOA program changes for revie'w and approval, the interactions with Arizona Public Service and the information provided informally have aided the staff in developing GOA guidance documents. The pilot program phase of volunteer interactions on GOA is considered complete. The staff will continue to mon l tor all volunteer plant GOA implementation as appropriate. Development of the GQA inspection guidance procedure will continue to be tracked under Activity 1.3.

The staff is nearing completion of the SER on the Comanche Peak risk informed IST program.

The SER reflects TU Electric's revised risk-informed IST Program Description dated May 21, 1998, and TU Electric's request to use ASME Code Case OMN 1 to respond to NRC Generic Letter 96-05," Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves"(TU Electric Relief Request V-8), dated June 23,1998. The SER is consistent with the recently approved RG 1.175 and SRP 3.9.7. The SER is currently being reviewed by management and the Office of the General Counsel and should be sent to the licensee in the ne er future.

Arizona Public Service (APS) recently told the staff orally of its intention to withdraw Palo Verde as an risk-informed IST pilot plant. APS has indicated that in the near future it plans to formally document this decision and its basis in a letter to the Gf.

l The staff has received, reviewed, and prepared safety evaluations and license amenoments for risk-informed TS applications, using RG 1.177. These applications include extended allowed outage times (AOTs) for (1) ECCS (emergency core cooling system) equipment at San Onofre Units 2 and 3, which is the Combustion Engineering Owners Group pilot application, and (2) emergency diesel generators (EDGs) at the Fermi and Vogtle stations. The staff issued these license amendments in May and June 1998. In addition, the staff hi.s received, reviewed, l

The Commissioners 5 and is developing safety evaluations and license amendments, in accordance with RG 1.177, for follow-on risk-informed TS amendments, for example, the Southern Califomia Edison supplemental request, received in January 1998, for extending the EDG AOT at San Onofre.

The staff anticipates issuing these license amendments later this year.

The staff received (on March 2,1998) from the licensee for ANO 1 and 2, a request for relief from the staff position in NUREG-0737 for hydrogea monitoring. The request was made in accordance with " Task Zero" of the Risk-Informed, Performance Based Regulation Pilot Program ("Whole Plant Study") proposed by NEl. The staff is reviewing the proposal and believos that extending the time of initiation of hydrogen monitors may result in improved coerDnation of the activities in the control room following an accident. A meeting with the licens ee has been requested to obtain additionalinformation and expedite completion of the revieN with proposed completion by September 1998, subject to licensee support of the needed licensa amendment.

1.3 Inspections The sta ff completed an additional thirteen Maintenance Rule (MR) baseline inspections during the secend quarter of 1998 (April through June). This included inspection of licensee methods for using PRA in maintenance rule programs and inspection of safety assessments performed by licensees when taking equipment out of service for maintenance in accordance with 10 CFR 50.65(a)(3). The staff completed the last MR baseline inspection in the first week of July 1998.

Of the 18 core inspection procedures (IPs),11 have been modified to incorporate guidance on use of risk insights. Application of risk insights was found to be impractical for five core IPs. As noted in SEC'/-98 096, changes to the remaining two core inspection procedures will be completed as follows: (1) for IP 71001," Licensed Operator Requalification Program Evaluation,"

PRA guidance will be incorporated before August 31,1998, and (2) for IP 82701, " Operational Status of the Emergency Preparedness Program," PRA guidance will be incorporated by April 1, 1999, after an audit of licensee severe-accident management programs, it is anticipated that revisions to Sections a(3) and a(4) of the Maintenance Rule may also influence the IP revisions.

These changes are intended primarily to stress the use of Inspection Manual Chapter 2515 Appendix C "Use of insights Derived From Probabilistic Risk Assessment (PRA)"in the selection of inspection items. Further efforts to incorporate a risk-informed basis within the inspection program are being made as part of an overall reassessment of the inspection program.

The schedule for issuing the draft and final GQA IPs has been revised. The staff now expects to issue the draft GOA inspection guidance in September 1998 and the final guidance in December l 1998. This change was made because key personnel were assigned to higher priority tasks, such as conducting allegation-related inspections, working on licensing actions, working on a rulemaking petition for 10 CFR 50.59(a), and supporting AP600 design certification.

' For the purpose of making risk information more accessible to inspectors, a new subtask has been initiated. This subtask," Evaluate Methods of Presenting Risk Analysis Results in a Form Most Useful to inspectors and Develop Options Relating to Providing Inspectors With Plant-Specific Risk Information,"is scheduled to be finished in March 1999.

The Commissioners 6 1.6 Use of PRA in Resolution of Generic Safety issues This activity has been moved to Section 1.10 of the PIP (Evaluating integrated Plant Evaluation (IPE) Insights to Determine Necessary Follow-Up Activities) where licensee closure of generic safety issues using plant-specific IPE results will be tracked.

1.8 Advanced Reactor Reviews in the SRM for SECY-94-182, the Commission instructed the staff to develop a rule that would require applicants and holders of a combined construction and operating license (COL) to maintain, update, and use a PRA for the life of the facility, in the last few Rulemaking Activity Plan updates sent to the Commission, the staff stated this rulemaking activity is on hold pending additional resources. Since no significant interest by a U.S. utility in requesting a COL for an evolutionary LWR design is foreseen, the best use of the staff's resources at the present time appears to be to apply them in other risk-informed initiatives. Therefore, the staff transmitted a memorandum to the Commission on July 1,1998, indicating it is giving this task a low priority. ,

This activity is being tracked in the Rulemaking Activity Plan. '

1.10 IPE Follow-Up Activities in a May 21,1996, Staff Requirements Memorandum (SRM), the Commission directed the staff to track regulatory uses of the results of individual plant examination / individual plant examination, extemal events (IPE/IPEEE). Subsequently the Commission directed the staff to establish procedures to monitor the cumulative changes in risk for a given nuclear facility as the result of license amendments that are conducive to quantitative risk assessments. In response to both Commission directives, the staff is developing a PRA Applications Database capable of tracking regulatory uses of PRA and monitoring changes in quantitative facility risk caused by plant, process, or proceduto modifications that receive NRC review.

The staff noted that the guidance contained in draft RG DG-1061 and draft SRP Chapter 19 was intended to enable the staff to track and monitor cumulative changes in risk associated with risk-informed license amendment requests. Data collected from cumulative risk tracking forms that will be filled out by the staff will be incorporated into the PRA database. This risk tracking process collects information on changes in risk associated with regulatory activities that NRC normally reviews, such as licensing activities and actions. It is not designed to collect information on risk changes in areas in which NRC does not normally perform a risk review such as licensee-initiated PRA modeling changes, plant experience (e.g., changes in equipment failure rates or initiating event frequencies), licensee-initiated PRA assumption changes, or plant modifications made under 10 CFR 50.59. The cumulative risk captured by the database will provide snapshots of the effect that both licensing and other activities have on plant risk; but the database will not provide a continual statement of risk estimates unless they are routinely and voluntarily submitted by licensees.

The staff has completed a trial-use database to help identify and clarify significant regulatory uses of nuclear power plant PRA results and assessment of methods for efficient data collection and disamination. The staff intends to track (1) risk-informed licensing changes, (2) insentice testing and inspection program changes, (3) GOA program changes, (4) risk-informed exemptions, (5) risk-informed notices of enforcement discretion (NOEDs), and (6) other significant PRA applications identified by senior reactor analysts (SRAs) at headquarters or the

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.' l The Commissioners 7 regions. Contractor assistance to fullyimplement the PRA Applications Database on the NRC LAN (local area network) has been obtained and work has commenced. The staff plans to complete procedures to support future data collection and creation of a user interface that can support widespread staff use by December 1998.

Section 2: Rear- Mety Research I

2.1 Regulatory Guides As discussed above, the proposed final versions of SRP Chapter 19 and RG 1.174 were approved by the Commission in an SRM dated May 20,1998, and they were published in final form in July 1998.

The proposed final versions of the regulatory documents for risk-informed IST (RG 1.175 and I SRP Section 3.9.7), risk-informed TS (RG 1.177 and SRP Section 16.1), risk-informed GOA (RG 1.176) were submitted to the Commission in SECY-98-067, and the Commission issued its SRM on SECY-98-067 on June 29,1998, approving their issuance. They are expected to be published in final form by August 1998.

The guidance documents for risk-informed ISI, RG 1.178 (formerly DG-1063) and SRP Section 3.9.8, have been revised to reflect public comments and to conform to the general guidance documents (RG 1.174 and SRP Chapter 19). The proposed trial versions of the risk-informed regulatory documents were submitted to the Commission in SECY-98-139, and are to be published for trial use in August 1998.

2.4 Methods Development and Demonstration An international peer review on ATHEANA,"A Technique for Human Event Analysis" was performed on June 11-12,1998. ATHEANA is a next-generation human reliability analysis (HRA) method being developed by RES to more completely and accurately assess human reliability. The meeting also afforded an opportunity for other interested parties to learn about the method, including representatives from Spain, France, Japan, and the Netherlands and from several national laboratories. The review comments from the peer reviewers, along with feedback from others who have reviewed or used the HRA method, were supportive of the method and will be incorporated into a revision of NUREG-1624," Technical Basis and Implementation Guidelines for A Technique for Human Event Analysis (ATHEANA)."

In its SR^A dated June 29,1998, the Commission directed the staff to eliminate any FY1998

' resource expenditures specifically directed at developing a systematic method of inferring management performance," and disapproved the use of any FY1999 and FY2000 resources for these purposes. Therefore, efforts for developing and demonstrating methods to incorporate i organizational performance into PRAs have been terminated.

2.5 IPE and IPEEE Reviews The staff has reviewed all of the 76 IPE submittals and issued stafi evaluation reports (SERs) on its findings to each licensee. During this quarter the staff reissued to the licensee the SER for Crystal River 3 IPE; also, RES staff sent to NRR its SER on the revised Susquehanna 1&2 iPE, with the recommendation that it be issued to the licensee. On the basis of information provided l

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The Commissioners 8 regarding the revisions performed by the licensees to address the staff's concerns documented in the SERs for the original submittals, the staff concluded that the revised IPEs for both Crystal River Unit 3 and Susquehanna Units 1 and 2 met the intent of Generic Letter (GL) 88-20. The SER for Browns Ferry Unit 3 (BF3), stating that the staff was unable to conclude that the BF3 IPE meets the intent of GL 88-20, was issued to the licensee during this quarter; the staff is planning to meet with the licensee in the near future.

The staff completed its review of an additional two IPEEE submittals (D.C. Cook, and Millstone Unit 3) and issued the SERs for these plants. The staff concluded that both of these submittats met the intent of Supplement 4 to GL 88-20. In addition, the staff completed preliminary reviews  ;

of an additional eight IPEEE submittals. j 2.8 PRA Standards Development ASME has formed a task group, which includes a representative from the RES staff, to develop l

~ PRA standards. The task group had a first draft ready by July 15,1998, and is scheduled to l have a draft ready for the ASME review and comment process by November 4,1998. Although {

the staff continues working with ASME in this activity, it has some concerns in regard to the scope and quality of the group's work. These concerns will be discussed with ASME after ,

completion of the staff's review of the July 15 draft and, if not resolved, could cause {

reconsideration of the staff's continued participation in this activity. j 2.12 Review of Agency Programs and Processes (new item)

As a result of a July 21,1998 memorandum from Chairman Jackson to J. Funches, a new item has been added to reflect improving the effectiveness and efficiency of agency programs and to search for opportunities to make these activities more risk informed. The work under this new task will be directed by the Steering Committee for NRC risk-informed activities being chaired by Mr. Thadani. The Steering Committee held its first meeting to discuss these issues on July 29, i 1998. Specific tasks and schedules will be developed in the near future and reported in the next  !

Implementation Plan update.

Section 3: Analysis and Evaluation of Operating Experience and Training 3.1 Risk-Based Trendo and Patterns Analysis With respect to the system reliability studies, the final report of the Auxiliary Feedwater (AFW)

System Study was completed and it will be issued as NUREG/CR-5500, Volume 1, " Reliability Study: Auxiliary Feedwater System,1987-1995." Some major findings of this study are (1) no j failures of the entire system were identified in 1,117 unplanned system demands for the time l period 1987-1995; (2) the variability in AFW system unreliability primarily reflects the diversity found in AFW system designs and, to a lesser extent, the variation in equipment performance among plants with similar designs; (3) and AFW systems composed of ordy turbine-driven pumps were less reliable than AFW systems with three redundant trains of diverse design (e.g.,

two motor-driven pumps and one turbine-driven pump).

The Westinghouse Reactor Protection System Study was sent out for peer review; comments from the NRC's program offices and the regions have been received. Also, the draft Initiating Event (IE) Update was completed and sent out for peer review; comments have been received.

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4 The Commissioners 9 in addition, presentations were given to the regional administrators and to the Commissioners' technical assistants on June 4,1998, on this report.

The report on loss of offsite power (LOSP) events was updated and it will be issued as NUREG/CR-5496," Evaluation of Loss of Offsite Power Events at Nuclear Power Plants: j 1980-1996." This study found that plant-centered events accounted for most of the losses of l offsite power during power as well as during non-power modes of operation; LOSP frequency for I plant-centered events is significantly higher (by a about a factor of four) during shutdown modes of operation than during power operation; events induced by severe weather are much less frequent but tend to have the longest duration of power outages; and grid-related events occur even less frequently.

The technical reports (four volumes) that support the Common-Cause Failures (CCF) Database were prepared as NRC reports in the NUREG/CR series (NUREG/CR-6362, Volumes 1- 4).

Plans are to distribute the database to utilities during the next quarter.

Two new studies were initiated during this quarter; one for the PWR high-pressure injection system and one for the General Electric reactor protection system .

3.2 Accident Sequence Precursor (ASP) Program The preliminary analyses for all 1997 events have been completed and are being reviewed by licensees. Seven preliminary precursors were identified for 1997 compared to 14 precursors identified for 1996 and 10 for 1995. However, more LERs were issued: from about 1400 for 1996 to 1500 for 1997. Preliminary analysis of the 1998 events has commenced and efforts are under way for establishing an in-house capability for a high quality and efficient ASP assessment to improve the timeliness and reduce the cost of future ASP work.

3.5 Operating Experience Data The database requirements specifications for the NRC Reliability Database were completed during this quarter. The database will provide NRC staff and industry with data to produce unit-specific and generic estimates of reliability parameters required for PRAs and risk-informed applications. It will contain data elements from INPO's Safety System Performance Indicator (SSPI) and Equipment Performance Information Exchange (EPIX) database along with other data derived from LERs and NRC's Performance Indicator Program. A contract to begin development of the NRC Reliability Database will be issued next quarter.

INPO gave users access to its new EPIX system through its Web site in May 1998, including the NRC and NRC contractors. The Office of Chief Information Officer (OClO) will install the required software to give NRC access to EPIX in a pilot mode by the end of July. OClO will provide full access based on the results of the pilot activity at a date to be determined.

The NRC staff attended the first meeting of the EPIX Ad Hoc Users Group in June 1998. Data i

entry into EPIX is running slightly behind schedule. About 80 percent of the plants have provided failure data for 1997 and for the first quarter of 1998. The data were originally expected to be completed by the end of May 1998. Other reliability data originally scheduled to be provided by June 1998 will likely not be ready bore the fourth quarter of 1998. INPO will then begin sending quarterly data from EPIX to NRC for inclusion in the reliability databat e.

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The Commissioners 10

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AEOD is continuing discussions with industry to resolve issues relating to limitations and "workarounds" identified in SECY 97-101, which discussed the voluntary alternative to the reliability and availability data rule.

l 3.6 Staff Training The new 2-week PRA Technology and Regulatory Perspectives course (P-111) was offered l again May 11-22,1998. It is scheduled to be offered two more times during 1998. Course

, attendance and registration support the staff's goal of having one resident inspector at each site

! complete this course by the end of 1998. Current plans call for one course to be presented each quarter to meet anticipated needs.

The 4-day PRA Basics for Regulatory Applications course (P-105) was offered three more times, April 21-24, May 5-8 and June 2-5,1998. This course will be offered two more times during 1998, to address the need for more NRC technical staff to attend this course. Nine more presentations are planned for FY1999 to meet the staff's needs.

The 3-day PRA for Technical Managers course (P-107) was offered twice, on April 14-16 and June 23-25,1998. This course will be offered one more time during FY1998 to support the staff's goal of having two-thirds of the agency's technical managers complete it by the end of FY1998, Four additional presentations are planned for FY1999. The PRA curriculum continues to be updated as more agency policy on risk-informed regulation becomes available.

Procurement actions continue for acquiring risk-monitor software. Current plans are to integrate the risk monitor into the reactor technology and PRA technology curricula to improve staff understanding of configuration management, the irnportance of plant operations to the risk .

profile of the plants, ar'd the use of the tool to gain insights regarding the industry's use of risk-informed applications. The risk monitor will be used to demonstrate the capabilities and limits of

, this and similar tools as they are being used by the industry.

Section 4: Nuclear Materials and Low-Level Waste Safety and Safeguards Regulation 4.5 Framework for Use of PRA in Regulating Nuclear Materials l The staff's plan for developing a framework for using risk-informed approaches to regulate l

nuclear materials was forwarded to the Commission by SECY-98-138 on June 11,1998. The l first step in the plan is a scoping effort in which the staff will (1) complete a preliminary association of appropriate risk assessment methods with regulated uses of nuclear materials,(2) l as appropriate, for each regulated use and in coordination with the Agreement States, identify how these associated risk assessment methods can best be used in a risk- informed regulatory l approach for materials, and (3) estimate the resources needed to develop the framework and make a recommendation to the Commission about its feasibility given the NRC's resource l constraints.

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The Commissioners 11 1

l COORDINATION:

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The Office of the General Counsel has reviewed this paper and has no legal objection to it.

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. olfe'ph Callan l Ex 9Jtive Director l for Operations

! ' Attachments:

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Commissioners OGC OCAA OIG l OPA OCA

( CIO Cr0 EDO

' REGIONS SECY 1

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ATTACHMENT 1' ,

PRA IMPLEMENTATION PLAN ACTIVITY TABLE (March 1998) 1 l

1.0 REACTOR REGULATION Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) auarter) 1.1 STANDARD REVIEW Develo standard review

• Evaluate available industry NRR PLANS FOR RISK- plans (kRPs) to be used in guidance /RES INFORMED nsk-informed regulatory REGULATION decisionmaking.

• Develop broad-scope SRP cha ters and a senes u cation-specific SRP pters that correspond to industry initiatives

• The SRPs will be consistent with the regulatory guides (RGs) developed for the industry

• Transmit draft SRPs to the Commission for approval to issue for public comment:

General 4/97C' IST 4/97C ISI 8/97C TS 4S7C

• Transmit final SRPs to the Commission for approval:

, General 1/98C IST 3/98 C ISI 6/98 Completed TS 3/98C (Note 1.1a)

Update and revise annually SRPs: New (Note 1.1b)

General 6/99 IST 8/99 GQA 8/99 TS 8/99 I

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' See Abbreviations Table at the end of this report 2

C = Task previously completed

Regulatory Activity Objectives Methods Target Load Status (this Schedule Office (s) quarter) 1.2 PILOT Evaluate the PRA

• Interface with industry NRR/RES APPL! CATIONS FOR methodology and develop groups RISK-INFORMED staff positions on emerging, REGULATORY risk-informed initiatives,

• Evaluate appropriate INITIATIVES including those associated documentation (e;g.10 with: CFR, SRP, RGs, inspection procedures, and industry

1. Motor-operated valves codes) to identify elements 1. 2/96C cntical to achieving the

2. IST requirements intent of existing 2a. Comanche Peak requirements 2a. 7/98 2b. Palo Verde 2b. withdrawn Changed (Note

• Evaluate industry proposals 1.2a)

3. ISI requirements 3. 12/98

• Evaluate industry pilot Graded quality

4. program implementation 4. 1/98C assurance (GQA)

• As appropriate, complete

5. Maintenance Rule pilot reviews and issue staff 5. 9/95C findings on regulatory

6. Technical specifications requests 6a. 5/97C 6a. Commission 6b. 6/98 approval Completed (Note 6b. Pilot amendments 1.2b)

Issued

7. Other applications to be identified later (e.g.,

applications related to diesel generator start times and hydrogen control) 7a. 9/98 See Note 1.2c 7a. ANO request for relief from the staff position in NUREG-0737 for hydrogen monitoring, on the basis of " Task Zero" of the Risk-Informed, Performance-Based Regulation Pilot Program ("Whole Plant Study") proposed by NEl.

2

f Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) cuarter) 1.3 'NSPECTIONS Provide guidance on the use

• Develop IMC 9900 6/97C NRR of plant-specific and genenc technical guidance on the information from individual use of PRAs in the power plant examinations (IPEs) and reactor inspection program other plant- specific PRAs.

• Revise IMC 2515 Appendix 7/97 C C on the use of PRAs in the power reactor inspection program i

• Propose guidance options 10/97C l for inspection procedures t

(IPs) related to 50.59 evaluations and regular maintenance observations

• Review core IPs and 10/97C propose PRA guidance where needed

• Complete revision to 6/98 Completed (Note to osed core IPs except 1.3a) l or P 71007 and 82701

• issue draft GOA IP 9/98 Changed (Note i

1.3b)

I

• lssue final GQA lP 12/98 Changed (Note 1.3b)

Provide PRA training for

• Evaluate methods for 3/99 Changed (Note inspectors and senior reactor presenting nsk analysis 1.3c) analysts (SRAs). results in a form most useful to inspectors and their management, and develop options for providing inspectors with plant-specific nsk information

• Identifyinspectorfunctions 7/96C NRR i

that should utihze PRA methods. as input to AEOD/TTD for their development and refinement of PRA training for inspectors

• Develop consolidated and 10/97C NRR/

l comprehensive 2-3 week AEOD PRA for regu'atory applications training course

,

• Conduct training for 8/96C

! Maintenance Rule baseline NRR

! inspections

• Conduct training courses Ongoing according to SRA training AEOD programs

• Develop rotational Ongoing

, assignments for SRAs to NRR/RES l gain working PRA l expenence

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Regulatory Activity Objectwes Methods Target Lead Status (this Schedule Office (s) ouarter)

Continue to provide expertise

• Monitor the use of nsk in Ongoing NRR in nsk assessment to support inspection reports regionalinspection actwitnes and to communicate

• Develop new Ongoing inspection program guidance methodologies and and examples of its communicate appropriate implementation. uses of nsk insights to regional offices Ongoing

• Update inspection procedures as needed Ongcing

• Assist regional offices as needed 7/98

• Conduct Maintenance Rule baseline inspections 1.4 OPERATOR Monitor insights from human

• Revise the Knowledge and 8/95C NRR LICENSING reliability analyses (HRAs) of Abiltties Catalogs PRAs (including IPEs and (NUREGs- 1122 and 1123) individual plant examinations, to incorporate operating external events ( IPEEEs)) expenence and nsk insights and operating expenence to identiry possible

• Revise the Examiner 3/97C enhancements for inclusion in Standards (NUREG-1021),

planned revisions to guidance as needed to reflect PRA for operator licensing acturtles insights (initial and requalification).

1.0 EVENT Continue to conduct

• Continue to evaluate 50.72 Ongoing NRR ASSESSMENT quantitatwe event events using accident assessments of reactor sequence precursor (ASP) events while at power and models dunn low- power and shut own conditions. l Assess the desirability and

• Define the current use of TBD feasibility or conducting nsk analysis methods and .

quantitatwe nsk assessments insights in current event on non-power reactor events. assessments

• Assess the feasibility of developing appropnate risk-assessment models

• Develop recommendations on the feasibility and desirability of conducting quantitative risk assessments 1.6 USE OF PRA IN Audit the adequacy of NRR/RES Changed (Note RESOLUTION OF licensee analyses in IPEs and 1.6)

GENERIC SAFETY IPEEEs to identify plant-ISSUES specific apphcability of genene safety issues closed out based on IPE and IPEEE programs.

I 9.7 REGULATORY Assess the effectiveness of RES/NRR lt is tracked now i EFFECTIVENESS major safety issue resolution as item 2.11 l EVALUATION efforts for reducing nsk to put,iic health and wafety.  !

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Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) ouarter) 1.8 ADVANCED Continue staff reviews of

• Continue to apply current ongoing NRR REACTOR REVIEWS PRAs for design-certification staff review process applications.

Develop SRP to support

• Develop draft SRP for TBD NRR review of PRAs for design technical staff review and certification reviews of concurrence evolutionary reactors (ABWR and System 80+).

• Finalize SRP TBD Develop inde ndent

• Reevaluate risk-based 12/96C NRR/RES technical ana ses and entena aspects of the technical for evaluating industry bases for EP (NUREG.

initiatives and petitions 0396) using insights from regarding simplification of NUREG-1150, the new emergency preparedness source term information (EP) regulations. from NUREG-1465, and available plant design and PRA information for the passive and evolutionary reactor designs Modify 10 CFR Part 52 and

• Develop draft guidance and Changed develop guidance on the use rule TBD NRR (Note 1.8) of updated PRAs beyond design certification (as

• Solicit public comment TBD desenbed in SECY 93-087).

• Finalize staff guidance and TBD rule 1.9 ACCIDENT Develop generic and plant-

• Develop plant-specific A/M 12/98 NRR/RES Changed (Note MANAGEMENT specific nsk insights to insightshnformation for 1.9) support staff audtts of utility selected plants to serve as accident management (A/M) a basis for assessing programs at selected plants. completeness of utility A/M program elements (e.g.,

severe-accident training)

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Regulatory Activity Objectives Methods Target Lead Status (this l Schedule Office (s) auarter) j j

1.10 IPE FOLLOW-UP Evaluate specific

• Evaluate analyses of 5/99 NRR/RES New (Note ACTIVITIES irnprovements and analyses issues requested in proposed as basis for 1.10a)

Genenc Letter 88-20 resolution of generic safety issues at specdic plants.

• Evaluate other issues (e g., 5/99 NRR/RES New SGTR induced severe (Note 1.10a) accident) 1

• Evaluate unsolicited 12/99 NRR/RES New analyses of selected (Note 1.10a) genene issues submitted by licensees.

l Use results from the staff review of IPEs to identify -

• Recommendations to 9/98 NRR/ Changed (Note i

potential safety issues and Commission regarding regions 1.9) determine an appropnate Follow up on accident l course of action to address management programs and these potentialissues. licensee-stated actions.

• Assess reduction in risk 5/99 NRR/RES New (Note 1.10b) 1 associated with facility )

modifications. {

New I Identify plant 12/98 NRR/RES (Note 1.10b) improvements implemented J by licensees New

• Determine in accordance 12/99 (Note 1.10c) with the backfit rule if NRR/ 1 additional plant-specific or regions l genenc plant improvements that would further reduce the nsk of severe accidents NRR are warranted.

• Define use for information, Completed clanfy

• regulatory use," and 5/98 assess the most effective methods for data collection Determine appropriate approach for tracking the

• If appropnate develop regulatory uses of IPE/IPEEE approach for linking NRR/RES results. IPE/IPEEE databases 12/98 l

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2.0 REACTOR SAFETY RESEARCH mams Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) Quarter) 3.1 REGULATORY GUIDES Develop RGs to

• Transmit draft PRA RGs to the RES/NRR provide a basis for Commission for approval to issue for the industry to use in public comment; risk-informed General C regulation. IST C ISI C GQA C TS C l

• Transmit final PRA RGs to the '

Commission for approval:

General 1/98C IST 3/98C ISI 6/98 Completed GQA 3/98C (Note 1.1a)

TS 3/98C Update and revise annualty PRA RGs: New (Note 1.1b)

General 6/99 IST 8/99 GQA 8/99 TS 8/99 2.2 TECHNICAL SUPPORT Provide technical

• Continue to plovide ad hoc technical Continuing RES support to NRC staff support to agency PRA users using nsk assessment in risk-

• Expand the use of PRA models Continuing based regulation available; expand the scope of activities and available models to include extemal, technical reviews; low-power, and shutdown events; issue nsk refine the tools needed to use these assessments and models; and continue maintenance statistical analyses; and user support for SAPHIRE and and develop MACCS computer codes guidance for agency uses of nsk

• Support agency efforts in reactor Continuing assessment. safety improvements in former Soviet Union countnes

• Load plant-specific PRAs in Ongoing New (Note 2.2)  !

SAPHIRE to support vanous risk- l informed regulatory actrvities, e.g.,

pilot applications, resolution of genenc issues, and Maintenance Rule inspections.

2.3 SUPPORT FOR NRR Subsumed by STANDARD REACTOR Section 1.8,

, PRA REVIEW

• Advanced Reactor Reviews" 7 1 l

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Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 2.4 METHODS Develop,

• Develop and demonstrate 10/98 RES DEVELOPMENT AND demonstrate, methods for incorporating aging DEMONSTRATION maintain, and ensure effects into PRAs.

the quality of methods for

• Develop and demonstrate 9/98 Completed (Note performing, methods for incorporating human reviewing, and using 2.4a) errors of commission in PRAs.

PRAs and related techniques for

• Conduct application of ATHENA for 7/99 New existing reactor fire nsk assessment designs.

N nged (Note

• .E_f .. y:-ii.$..

. . ;;,bri r...

.. -____ .)

.7.._......r-----~

• Identify end pnontize key areas to 9/98 improve fire risk analysis Develop and demonstrate improved methods for selected areas Changed (Note

• Develop and demonstrate methods for 9/00 2.4c) assessing reliability / risk of digital systems 2.5 iPE AND IPEEE Evaluate IPE/IPEEE

• Complete the revews of the three RES REVIEWS submittals to obtain outstanding IPE submittals:

reasonable Susquehanna 6/98 Completed assursnce that the Crystal River 6/98 (Note 2.5a) licensees have Draft SER for Browns Ferry 3 6/98 adequately analyzed plant design and

• Continue regionalIPE presentations. 12/97C operations to discover

• lssue IPE insights report for public 10/96C vulnerabilities; and comment.

document significant safe insights

• Issue finalIPE insights report 12/97C resul from IPE/IP Es.

• lssue preliminary IPEEE insights 1/98C l report

• Initiate review of eight additional 6/98 Completed IPEEE submittals

• Complete contractor evaluations of 6/98 Completed twelve IPEEE submittals.

Changed

• Complete revews of IPEEE 12/99 (Note 2.5b) submittals.

• lssue draft IPEEE insights report for 3/00 Changed comment (note 2.5b)

• lssue finalIPEEE insights report 7/00 Changed (Note 2.5b) l 1

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Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) ouarter) 3.6 CENERIC SAFETY Conduct genenc

• Continue to pnontize and resolve Continuing RES ISSUES PROGRAM safety issue genene safety issues management activities, including pnontization, resolution, and documentation, for issues relating to currently operating reactors, for advanced reactors as appropnate, and for development or revision of associated regulatory and standaros instruments.

2.7 NEl INITIATIVE TO Review NEl initiative

• Agree on ground rules for study TBD RES/NRR CONDUCT WOLE to conduct three pilot PLANT' RISK STUDY "whole plant" nsk-

• Complete study TBD informed studies of requirements vs. nsk and cost.

2.8 PRA STANDARDS Work with industry to Initiate activity 9/97C RES DEVELOPMENT develop national consensus standard Issue initial ASME draft standard 7/98 New (Note 2.8) for PRA scope and quality. lssue draft standard for select 11/98 public comment Finalize standard TBD 3.9 LOW POWER AND Collect studies of

• Collect and review existing LP&S nsk 9/98 RES SHUTDOWN LP&S nsk as a information (domestic and foreign)

BENCHMARK RISK benchmark for STUDY assessing the need

• Initiate additionalwork for further staff 10/98 activities.

2.10 SAFETY GOAL Assess need to Initiate discussion with ACRS 2/98C RES REVISION revise Commission's

• Safety Goal to make Make recommendation to 4/98 Completed core damage Commission (Note 2.10) frequency a fundamental goal and Provide information paper 12/31/98 Note 2.10 make other changes.

• Provide final recommendations 3/31/99 Note 2.10 l

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e Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 2.11 REGULATORY Assess the

• Develop process / guidance for Ongoing RES/NRR EFFECTIVENESS effectiveness of assessing regulatory effectiveness EVALUATION major safety issue resolution efforts for Apply method to assess reduction reductng risk to in nsk Ongoing put'a health and safety. Evaluate resulting effectiveness of station blackout and ATWS rules 12/98 and Unresolved Safety Issue A-45 Propose modifications to resolution approaches, as needed (SBO rule implementation and RCP seal TBD issue)

Identify other issues for assessmentif appropnate ongoing 2.12 REVIEW OF AGENCY Perform a broad TBD TBD RES/NRR/A New (Note 2.12)

PROGRAMS AND review of the EOD PROCESSES agency's process to search for opportunities to make these activities more nsk informed I

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O 3.0 ANALYSIS AND EVALUATION OF OPERATING EXPERIENCE, AND TRAINING Regulatory Activity Objectives Methods Target Lead Status (this l Schedule Office quarter)  ;

3.1 RISK-BASED TRENDS Use reactor operating

• Trend performance of risk- 12/98 AEOD AND PATTERNS experence data to assess the important components ANALYSIS trends and pattems in 1 1

equipment, systems, initiatin

• Trend performance of risk- 12/98 I events, human performance,g important systems and important accident  !

sequence.

• Trend frequency of risk. 7/98 important initiating events

• Trend human per'ormance TBD i for reliability characteristics i Evaluate the effectiveness of

• Trend reactor operating As needed licensee actions taken to expenence associated with resolve risk-significant safety specific safety issues and issues. assess nsk imphcations as a measure of safety performance i

, Develop trending methods and

• Develop standard trending C special databases for use in and statistical analysis 1

AEOD trending activities and for procedces for identifed l PRA applications in other NRC areas for reliabikty and offices. statistical apphcations l

• Develop special software C l and databases (e g., (Periodic d i common-cause failure) for updates) (

t use in trending analyses i and PRA studes

~

l 3.2 ACCIDENT Identify Jad rank risk

• Screen and analyze LERs, Ongoing AEOD l SEQUENCE significance of operational AITs. IITs, and events '

l PRECURSOR (ASP) events. identified from other PROGRAM sources to obtain ASP l events

• Perform heensee and NRC Annual AEOD q staff peer revew of each report, ,

ASP analyses Ongoing

• Complete quality assurance C RES i of Revision 2 of the i

simplified plant-specific models f

• Complete feasibility study C RES for low-power and shutdown models

• Complete initial C RES containment performance and consequence models.

!

• Complete development of 7/99 RES

the Level 2 and 3 models l

• Complete Revision 3 of the 11/01 RES

simphfed plant-specific t models

• Complete extemal event TBD RES models for f re and earthquake

• Complete low-power and TBD RES ,

shut down models l

11

. I Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office quarter)

Provide supplemental

• Share ASP analyses and Annual AEOD 1 information on insights with other NRC report j performance. plant-specific offices and regions l

3.3 INDUSTRY RISK Provide a measure ofindustry

• Develop program plan to C AEOD '

TRENDS rmk that is as complete as entegrate NRR, RES, and possible to determine whether AEOD activites using nsk is increasing, decreasing, design and operating or remaining constant over time. expenence to assess the impled level of nsk and how it is changing

• Update plan for risk-based analysis of reactor operating expenence

• Implement program plan 6/99 elements to include plant-specific m ,dels and insights from IPEs, 1 component and system j reliability data, and other '

nsk-important design and operational data in an integreted framework to penodically evaluate industry trends 3.4 RISK-BASED Establish a comprehensive set

• Identify new or improved C AEOD PERFORMANCE of performance indicators and nsk-based Pts which use INDICATORS supplementary performance component and system measures which are more reliabdity rnodels and closely related to nsk and human and organizational provide both early indication performance evaluation and confirmation of plant methods performance problems.

• Develop and test candidate 9/00 Pis/ performance measures

• Implement risk-based Pls 1/01 with Commission approval 1

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(_-__ -_ _ _ - - - - - - - _ _ _ _ _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - _ - - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - - - - - - _ - _ _ . _ _

Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office quarter) 3.0 OPERATING Compile operating expenence

• Manage and maintain Ongoing AEOD EXPERIENCE DATA information in database SCSS and the Pl data systems suitable for quantitative base, provide oversight and reliability and nsk analysis access to NPRDS/ EPIX, applications. Information obtain INPO's SSPI, should be scrutable to the compile IPE failure data, source at the event level to the co%ct plant-specific extent practical and be reliability and availabihty sufficieat for estimating data reliability and availability parameters for NRC

• Develop manage. and Ongoing applications. maints', sgencydatabases for reliamiity/avadability data (equipment performance, initiating events, CCF, ASP, and human performance data) l

• Determine need to revise 6/98 Corr pleted LER rule to ekminate unnecessary and less safety-significant reporting

• Determine need to revise 6/98 Completed reporting rules and to better capture ASP, CCF, and human performance events

• Publish revised LER rule 1/00 l

3.6 STAFF TRAINING Present PRA curriculum as

• Continue current contracts Ongoing AEOD

[ presently scheduled for FY to present courses as 1998, scheduled

• Maintain current reactor Ongoing technol courses that include insights and apphcations

• Improve courses via Ongoing feedback

• Review current PRA course Complete matenal to ensure consistency with Appendix C 1

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1 Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office quarter)

Develop and present

• Prepare course material C RES/AEOD Appendix C training courses. based on Appendix C

• Present courses on C Appendix C Determine staff requirements

• Review JTAs performed to C AEOD for training, including date analysis of knowledge and skil's, needed by the NRC

• Perform representative C staff. JTAs for staM positions (JTA Pilot Program)

• Evaluate staff trahing C requirements as identifed in the PRA Implementation Plan and the Technical Training Needs Survey (Phase 2) and incorporate them into the training requirements analysts

• Analyze the results of the C JTA Pilot Program and determine requirements for additional JTAs

• Complete JTAs for other C staff positions as needed

• Solicit a review of the C proposed training requirements

• Finalize the requirements C Revise current PRA cumculum

• Prepare new courses to Ongoing AEOD and develop new training meet identifed needs program to fulfillidentifed staff needs.

• Revise current PRA Ongoing courses to meet ioentifed needs

• Revise current and new 9/97C PRA course to include RG and SRP information

• Revise current reactor Ongoing technology courses as necessary to include additional PRA insights and applications Present revised PRA training

• Establish contracts for Ongoing AEOD curnculum. presentation of new PRA cumculum

• Present revised reactor Ongoing technology courses

• Improve courses based on Ongoing feedback i

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l 4.0 NUCLEAR MATERIALS AND LOW-LEVEL WASTE SAFETY AND SAFEGUARDS REGULATION I

l Regulatory Activity. Objectives Methods Target Lead Status (this Schedule Office (s) Quader) 4.1 VALIDATE RISK Validate risk analysis

• Hold a workshop 8/94 C NMSS ANALYSIS methodology developed to consisting of experts in METHODOLOGY assess the relative profile of PRA and HRA to examine l DEVELOPED TO most likely contnbutors to existing work and to make ASSESS MOST misadministration for the gamma recommendations for  ;

LIKELY FAILURE stereotactic device (gamma MODES AND HUMAN knife).

further methodological development

)

PERFORMANCE IN THE (JSE OF

• Examine the use of Monte 9/95 C INDUSTRIAL AND Carlo simulation and its MEDICAL RADIATION apphcation to relative nsk DEVICES profikng

• Examine the use of expert 9/95 C judgement in developing error rates and consequence measures Continue the development of the

• Develop functionally based TBD RES/

relative nsk methodology, with genenc event trees NMSS the addition of event tree modehng of the brachytherapy remote after loader.

Extend the application of the

• Develop genonc risk TBD RES/

methodology and its further approaches NMSS development into additional devices, including teletherapy and the pulsed high dose rate after loader.

42 CONTINUE USE OF Develop decision enteria to

• Conductenhanced 8/94 C RES/NMSS RISK ASSESSMENT support regulatory decision- participatory rulemaking to Final rule OF ALLOWABLE making that incorporates both estabtish radiological published RADIATION deterministic and nsk-based entena for 7/97 C RELEASES AND engineenng judgment. decommissioning nuclear DOSES ASSOCIATED sites; technical support for WITH LOW-LEVEL rulemaking, including RADIOACTIVE WASTE comprehensive nsk-based AND RESIDUAL assessment of residual ACTIVITY. contamination

• Develop guidance for 3/98C implementing the I radiological cnteria for

! license termination

• Work with DOE and EPA Ongoing to the extent practicable to

, develop common I approaches, assumptions, I and models for evaluating l nsks and alternative l remediation methodologies l

1 (nsk harmonization) 4.3 DEVELOP GUIDANCE Develop a branch technical

• Solicit public comments 5/97 C NMSS/RES FOR THE REVIEW OF position on conducting a RISK ASSOCLATED performance assessment of an WITH WASTE LLW disposal facility.

• Publish final Branch TBD, REPOSITORIES 3. Technical Position dependent on resources e

15

o RGgulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 4,4 ASSESS RISK Develop and demonstrate a nsk

• Devrilop and derronstrate 9/98 ASSESSMENT OF assessment for industnal methods for determining MATERIAL USES. gauges containing cesium-137 the nsk associated with and cobalt 40 using PRA and industnal gauges other related techniques. containing cesium-137 and cobatt40 The assessment should allow for modification based on

• lssue final report as a 12/98 changes in regulatory NUREG requirements Use empincal data as much as prachcable.

Develop and demonstrate risk

• Through working group 12/93 Changed assessment methods for with contractor assistance, (Note 4 4) application to medical and identify and document a l industnal licensee activites. technical basis for a nsk-informed approach to the regulation of nuclear )

j byproduct matenal and develop plans for a graded approach to nuclear ..

byproduct material regulation based on risk information 4.5 USE OF PRA IN Develop a framework for

• Provide plan for 6/98 NMSS Completed REGULATING epplyino PRA to nuclear developing framework ( NMe 4.5)

NUCLEAR MATERIALS materialuses, similar to the one developed for reactor regulation

• Complete scoping effort 12/98 New (SECY-95-280), where appropnate.

• Complete framework TBD 16

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l 5.0 HIGH-LEVEL NUCLEARWASTE REGULATION Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 3.1 REGULATION OF HIGH- Develo uidance for the NRC

• Assist the staff in pre- Ongoing NMSS LEVEL WASTE and C RA staffs in the use of licensing activities and in performance asse ssment (PA) license application reviews to evaluate the safety of HLW programs.

• Develop a technical assessment capability in total- system and subsystem PA for use in licensing and pre-hcensing reviews

• Combine specialized technical disciphnes (earth sciences and engineering) with those of system modelers to improve methodology identify significant events,

• Perform sensitivity studies Ongoing NMSS processes, and parameters of key technicalissues affecting total system using iterative PA (IPA) performance.

Use PA and PSA methods,

• Assist the staff in Ongoing NMSS results, and insights to evaluate maintaining and refining proposed changes to the regulatory structure in regulations ,0verning the HLW disposal regulations potential repository at Yucca that pertain to PA Mountain.

• Apply IPA analyses to advise EPA in its development of a Yucca Mountain regulation

• Apply IPA analyses to develop a site-specific regulation for a Yucca Mountain site Continue PA activities during

• Provide guidance to the Ongoing NMSS l interactions with DOE dunng DOE on site the pre-hcensing phase of charactenzation reposrtory development, site requirements, ongoing charactenzation, and repository design work, and hcensing design. issues important to the DOE's development of a complete and high-quality hcense application

• Compare results of NRC's iterative performance assessment to DOE's Viabihty Assessment (VA) l to identrfy major differences / issues 5.3 PRA APPLICATION TO Demonstrate methods for PRA

• Prepare user needs letter 4/97C RES/NMSS i SPENT FUEL STORAGE of spent fuel storage facilities. to RES i FACILITIES l

• Conduct PRA of dry-cask TBD l storage l

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

• Update the database on 6/01 NMSS RISK ASSESSMENTIN insights to evaluate regulations transportation of SUPPORT OF 4 governing the transportation of radioactive materials for  !

RADIOACTIVE radioactive matenal. future applications MATERIAL TRANSPORTATION

• Revalidate the results of 12/99 NUREG-0170 for spent fuel shipment risk estimates I

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4 6.0 REACTOR ENFORCEMENT Regulatory Activity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 6.1 CONSIDERATION OF Ensure the consistent

• Prepare an enforcement 6/ 97C OE RISK IN THE Application of the Enforcement guidance memorandum ENFORCEMENT Policy in the Area of Risk (EGM)

PROCESS Informed Enforcement Actions.

• Update the Enforcement 8/98 OE Ongoing Manual to reflect the undance developed in the GM 6.2 RISK INSIGHTS Ensure nsk-informed decisions

• Include regional senior Ongoing OE DURING WEEKLY are made in developing reactor analyst evaluation ENFORCEMENT enforcement actions. on paneled enforcement PANELS cases when warranted 6.3 CHANGE THE Provide the staff with more

• Interface with NRR (SPSB) Fall 98 OE ENFORCEMENT useful guidance for determining to consider additional t

POLICY the Seventy Level of Violations. examples for the policy SUPPLEMENTS supplements TOINCLUDE ADDITIONAL EXAMPLES OF HOW RISK SHOULD INFLUENCE SEVERITY LEVEL l

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s NOTES 1.1a The proposed trial versions of the draft RG and SRP for ISI were sent to the Commission in SECY-98-139, dated June 11,1998.

1.1b In the Staff Requirements Memorandum (SRM) dated June 29,1998, the Commission directed the staff to " perform annual reviews and update the guidance documents, considering the experience gained from risk-informed programs, which should be tracked in the PRA implementation plan."

l l 1.2a The staff has completed its safety evaluation report (SER) on the Comanche Peak risk-informed inservice testing (RI-IST) program. The SER reflects TU Electric's revised RI-IST Program Description dated May 21,1998, and TU Electric's request to use ASME Code Case OMN-1 to respond to NRC Generic Letter 96-05, " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves" (TU Electric relief request V-8) dated June 23,1998. The SER is currently being reviewed by management and the Office of the General Counsel and should be sent to the Commission in the near future.

Arizona Public Service (APS) recently informed the staff verbally of its intention to withdraw Palo Verde as an RI-IST pilot plant.

1.2b The staff received a supplemental amendment request for the TS lead plant, San Onofre Nuclear Generating Station (SONGS), in early January 1998 and issued the amendment for the safety injection tanks and low-pressure safety injection system on June 19,1998. This is a change from the previous date of May 1998.

1.2c in a letter dated March 2,1998, the licensee for Arkansas Nuclear One (ANO), Units 1 and 2, ,

requested relief from the staffs position in NUREG-0737 for hydrogen monitoring. The request was made in accordance with " Task Zero" of the Risk-informed, Performance-Based Regulation Pilot i Program ("Whole Plant Study") proposed by NEl. A license amendment request will be required to implement this change, which the staff anticipates will have been received and reviewed by September 30,1998. I 1.3a Completed (as noted in SECY-98-096, revisions to two core inspection procedures will be completed after further review by the responsible technical branches and are being tracked by the PIPB Action Item Tracking System). These changes are intended primarily to stress the use of Inspection Manual Chapter 2515 Appendix C 'Use of Insights Derived From Probabilistic Risk Assessment (PRA)" in the selection of inspection items. Further efforts to incorporate a risk-informed basis within the inspection program are being made as part of an overall reassessment of the inspection program.

1.3b The schedule for issuance of the draft and final GQA inspection procedures has been revised. The staff expects to issue the draft GQA inspection guidance by September 1998 and the final guidance i by December 1998. This schedule change was necessitated because key personnel were assigned I to higher priority tasks, such as conducting allegation-related inspections, working on licensing l actions, working on a rulemaking petition for 10 CFR 50 59(a), and supporting AP600 design certification.

1.3c Independent of this item, the Office of Nuclear Reactor Regulatory Research initiated a cooperative agreement (No. NRC-04-97-064) with the University of Wisconsin to, in part, explore issues involved in communicating risk to decisionmakers (especially regulators) and to develop guidance on how to l communicate risk. The expected completion date of this activity is December 98. The target l schedule date has been delayed to allow incorporation of the results of this study. j l

20 t

5 1.6 Activity 1.6, "Uts of PRA in Resolution of Generic Safety issues." has been moved to Section 1.10

'IPE Follow-Up Activities'since many licensees used their IPE insights to close generic safety issues.

1.8 in the SRM for SECY-94-182, the Commission instructed the staff to develop a rule that would require COL appi; cants and holders to maintain, update, and use a PRA for the life of the facility. In the last few Rulemaking Activity Pian updates sent to the Commission, we stated this rulemaking activity is on hold. Since we do not now see any significant interest by a U.S. utility in requesting a COL for an evoNtionary LWR design, we are giving this task a low priority. This activity will be tracked in the Rulemaking Activity Plan.

1.9 The staff intends to evaluate licensee implementation of accident management at a limited number of plants and to subsequently establish an approach for confirming the adequacy of implementation at the balance of plants. Plans for performing these evaluations have been communicated to the Commission as part of the periodic updates on the Status of the Integration Plan for Closure of Severe Accident issues (SECY-97-132 and SECY-96-088), and were recently reaffirmed in SEC'Y 131 (June 8,1998). The staff had characterized these evaluations as inspections against licensee commitments, but upon further consideration of the voluntary nature of this program, has concluded that such evaluations would more appropriately be conducted as audits. The objective of the audits will be to assess how licensees have evaluated and implemented enhancements to their accident response capabilities according to the formalindustry position on accident managemert. Key areas to be evaluated include the licensee's development of plant-specific severe-accident management guidance (SAMG), integration of SAMG with the emergency operating procedures and emergency plan, and implementation of severe-accident training consistent with the systems approach to training.

The extent to which the licensee has evaluated plant-specific risk insights for possible inclusion in its SAMG will also be assessed. Upon completion of the audits, the staff will report to the Commission on audit findings and recommendations for remaining actions to achieve closure. We anticipate completing the audits by early 1999, and reporting to the Commission within the first quarter of CY1999.

1.10a An NRR Actics Plan for IPE follow-up activities has been drafted and is currently undergoing management review. The activities described in the plan develop the details for the IPE follow-up framework sent to the Commission in SECY-98-012.

1.10b in order to help assure that plant design modifications and procedure changes credited in the IPE and IPEEE to limit the consequences of severe accidents and resolve generic safety issues actually were implemented adequately at plants, the NRC will identify and evaluate commitments to make these changes, and if they have not been followed through, will consider whether it is prudent to seek the changes under the backfit rule.

2.2 The Office of Nuclear Regulatory Research has an ongoing effort of developing plant-specific input decks (i.e., loading into GAPHIRE plant-specific PRAs) which are used to explore "what if" questions and to assess issues of a plant-specific or generic nature. For example, SAPHIRE models were used in the development of guidance for risk-informe3 IST, IS!, GOA, and TS, the ranking and resolution of generic issues, and in Mainteriance Rule inspections. -

2.4a An intemational peer review on ATHEANA, *A Technique for Human Event Analysis" was performed, June 11-12,1998. ATHEANA is a next-generation human reliability analysis (HRA) method being eveloped by RES to more completely and accurately assess human reliability. The meeting also afforded an opportunity for other interested parties to learn about the method, including representatives from Spain, France, Japan, and the Netherlands and from several national 21

laboratories. The review comments from the peer reviewers, along with feedback from others who have reviewed or used the HRA method, were supportive of the method and will be incorporated into a revision of NUREG-1624," Technical Basis and Implementation Guidelines for A Technique for Human Emnt Analysis (ATHEANA)." The draft NUREG-1624 has been issued for public comment.

2.4b in its SRM dated June 29,1998, the Commission directed the staff to eliminate any FY1998 " resource expenditures specifically directed at develop!r.g a systematic method of inferring management performance," and disapproved the use of any FY1999 and FY2000 resources for these purposes.

Therefore, efforts for developing and demonstrating methods to incorporate organizational performance into PRAs have been terminated.

2.4c Methods developed in this area is deferred until FY2000 because of budget constrains in FY1999 2.5a The staff has reviewed all of the 76 IPE submittais and issued staff evaluation reports (SERs) on its findings to each licensee. The staff has reissued the SERs for Crystal River Unit 3 and Susquehanna Units 1 and 2 concluding that the revised IPEs meet the intent of Generic Letter (GL) 88-20. The i SER for Browns Ferry Unit 3 (BF3), stating that the staff was unable to conclude that the BF3 iPE meets the intent of GL 88-20, was issued to the licensee during this quarter; the staff is planning to meet with the licensee in the near future.

2.5b The target schedule for completing the reviews of all IPEEE submittals nas been changed from June 1999 to December 1999. Correspondingly, changes were made to the target schedules for issuing the draft and final IPEEE insights reports. A number of factors contributed to revising the IPEEE review schedule. Among these were that (1) many submittals needed a review beyond the initial screening review to determine whether or not they met the intent of Supplement 4 to Generic Letter 88-20; (2) not all of the submittals were received on time; (3) it took longer than originally anticipated to issue requests for additional information (RAls) to the licensees; (4) many licensees requested additional time (typically an additional 60 days) to respond to the RAls; and (5) staff resources were needed to complete other high priority NRC work (e.g., risk-informed regulatory guides).

2.8 AGME has formed a task group, which includes a representative from the staff, to develop PRA standards. The task group had a first draft ready by July 15,1998, and is scheduled to have a draft ready for the ASME review and comment process by November 4,1998. Although it'e staff continues working with ASME in this actrvity, it has some concems in regard to the scope and quality of the group's work. These wncerns will be discussed with ASME after completion of the staffs review of the July 15 draft and, if not resolved, could cause reconsideration of the staffs continued participation in this activity.

It is noted that the current draft standard only covers a Level 1 and 2 PRA for internal events (except fire) with the resctor at power Standards for a Level 3, fire, extemal events, and low-power and shutdown PRAs are scheduled for a later date, to be determined.

2.10 The Commission approved the staffs recommendations in SECY-98-101, to modify the Safety Goal Policy Statement and to defer the initiation of this modification for a calendar year. The Commission asked the staff to prepare an information paper by December 31,1998, and make final recommendations by March 31,1999.

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2.12 Review of Agency Programs and Processes (new item)

As a result of a July 21,1998 memorandum from Chairman Jackson to J. Funches, a new item has been added to reflect improving the effectiveness and efficiency of agency programs and to search for opportunities to make these activities more risk informed. The work under this new task will be directed by the Steering Committee for the PRA Implementation Plan. Specific tasks and schedules will be developed in the near future and reported in the next implementation Plan update.

4.4 The staff now plans to report its results to the Commission in a SECY paper. The new schedule reflects the change from September 1998 to December 1998.

4.5 The staff's plan was forwarded to the Commission by SECY-98-138 on June 11,1998. The first step is a scoping effort in which the staff will (1) complete a preliminary association of appropriate risk assessment methods with regulated uses of nuclear materials and (2) as appropriate, for each regulated use and in coordination with the Agreement States, identify how these associated risk assessment methods can best be used in a risk-informed regulatory framework for materials.

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ABBREVIATIONS ABWR advanced boiling-water reactor AEOD Office for Analysis and Evaluation of Operational Data ACRS Advisory Committee on Reactor Safeguards AFW auxiliary feedwater i AIT augmented inspection team l ANO Arkansas Nuclear One AOT- . allowed outage time A/M accident management APS Arizona Public Service ASME American Society of Mechanical Engineers ASP accident sequence precursor ATWS anticipated transient without scram BF3 Browns Ferry Unit 3 C completed COL combined construction and operating license CCF common-cause failures CFR Code of FederalRegulations CRGR Committee to Review Generic Requirements CY calendar year CNWRA Center for Nuclear Waste Regulatory Activities DOE Department of Energy EDG emergency diesel generator EGM Enforcement Guidance Memorandum EP emergency preparedness EPA Environmental Protection Agency EPIX Equipment Performance and information Exchange FY fiscal year HLW high-level waste HRA human reliability ar,alysis GSI generic safety issue GQA - graded quality assurance JTA job task analysis IE initiating event IMC inspection manual chapter INPO Institute of Nuclear Power Operations l lP inspection procedure IPA iterative performance assessment IPE individual plant examination IPEEE individual plant examination, extemal events llT- incident inspection team l lST inservice testing ISI - inservice inspectior.

LAN local area network LER licensee event report LOSP loss of offsite power LLW low-level waste i LP&S low power and shutdown MACCS MELCOR Accident Consequence Code System MR Maintenance Rule 24 i

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1 u________-__ _ _ _ ----_-

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p. '

( NEl Nuclear Energy institute

.NOED notice of enforcement discretion NPRDS nuclear plant reliability data system NRR Office of Nuclear Reactor Regulation NMSS Office of Nuclear Material Safety and Safeguards 0C10 Office of the Chief Information Officer

! OE Office of Enforcement L OGC Office of the General Counsel l PA performance assessment PI, performance indicator i PIP PRA implementation Plan l PIPB inspecbon Program Branch, NRR PM _ , projact manager PRA probabilistic risk assessment RAI request for additionalinformation

.RCP reactor coolant pump RES Office of Nuclear Regulatory Research RG .

regulatory guide l: :SAMG severe-accident management guidance SAPHIRE Systems Analysis Programs for Hands -on integrated Reliability Evaluations SBO Atation blackout SECY Office of Secretary of the Commission SER safety evaluation report SGTR steam generator tuber rupture SONGS San Onofre Nuclear Generating Station SPSB Probabilistic Safety Assessment Branch SCSS sequence coding and search system SRP standard review plan SRA senior reactor analysts SRM staff requirements memorandum SSPl Safety System Performance Indicator -

TBD to be determined TTD Technical Training Division TS technical specifications TU Texas Utilities FY Fiscal Year VA viability assessment i

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