ML17264A943

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09/19/2017 - RES Seminar - the Other Sides of Coins - Ucs - Presentation Slides
ML17264A943
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Seminar: The Other Sides of the CoinsDave Lochbaum, Union of Concerned ScientistsDave Lochbaum, Union of Concerned Scientists (UCS), Director, Nuclear Safety ProjectOne of the nation's top independent nuclear power experts. As director of UCS's Nuclear Safety Project, Mr. Lochbaum monitorsongoing 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 facilit y in Japan.A nuclear engineer by training, Mr. Lochbaum worked at nuclear power plants for 17 years, including many that are similar to theGeneral 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 p ostat 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, incl udi ng 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 CommissionTwo White Flint North AuditoriumSeptember 19, 2017, 2:00pm to 3:30pm"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 Commission's 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

-800-857-8143Pass Code: 4592838 Outlook Scheduler The Other Sides of the CoinsDave LochbaumDirector, Nuclear Safety Projectdlochbaum@ucsusa.org 1September 19, 2017 2Past as PrologueWhen 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.

3Nuclear Safety Whine List THISLISTINTENTIONALLYBLANK 4Past as Prologue PastToday, I want to speak about the other sides of the coins

-when the NRC's efforts result in positive nuclear safety outcomes.

UCS: When and WhereFounded in May 1969 by faculty and students at the Massachusetts Institute of TechnologyHeadquarters in Cambridge MA, with offices in Washington DC, Berkeley CA, and Chicago IL (and my office in Chattanooga

TN)5More: www.ucsusa.org UCS: Who and WhatCurrent staff of about 180 individualsOver 30% of staff are engineers, scientists and technical analystsStaff includes communications specialists, policy analysts, program assistants, lobbyists, economists and development staff 6 7UCS is anti-nuclear andpro-nuclearWe're anti-nuclear disasterand pro-nuclear safety(not sure why any onewould be anything else)UCS: Why 8UCS: Our IncomesUCS's FY 2016 revenue was ~$32.6 million UCS: Our Outcomes 9(Nuclear Safety Project) 10UCS: Our Global Security ProgramDr. Edwin LymanHalf of UCS's Nuclear Power Team(Ed covers the hard stuff; I tackle the easy stuff like fire non

-protection) 1996 2003 2011 1992 2002 2002 1992 2001 2007(88-91)(07-10)2015<1996 11UCS's Goals TodayAcknowledge and applaud representative positive outcomes achieved by the NRC staffIdentify the elements and attributes that help external stakeholders recognize the NRC's positive outcomes (i.e.,

help make such outcomes more transparent) 12NRCKudos (abridged listing)PWR CRDM Nozzle CrackingBWR SLC Test Tank Maintenance Rule Reactor Oversight ProcessFlooding Pre

-FukushimaCFFF Event Lessons LearnedNOT Putting Perry in Column 4 Zero-Sum BIP Enhancement 13Counterfeit, Fraudulent and Suspect Items workNRR and OIG component aging reportsPutting Agreement State (Georgia) on probationHatch undervoltagerelay fixOIG's triennial safety culture surveysMore NRCKudos (still abridged) 14PWR CRDM Nozzle CrackingMarch 2001

-CRDM nozzles at Oconee found to be cracked in unexpected locations 15PWR CRDM Nozzle CrackingAugust 2001

-NRC determined key factors causing cracking and put 69 PWRs into three vulnerability bins 16PWR CRDM Nozzle CrackingMarch 2002

-Subsequent CRDM nozzle inspections confirm that NRC had right factors and rankings.

17PWR CRDM Nozzle CrackingSpring 2001

-Cracking identified in unanticipated locationBy 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 susceptibilityThe dozen PWRs highly susceptible to cracking were inspected in fall 2001 as scheduled, despite the NRC's need to reallocate resources following 9/11When 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 18BWR SLC Test TankCDBI 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.

19BWR SLC Test Tank 20BWR SLC Test Tank 21BWR SLC Test TankSource: NRC CDBI Inspection Report dated 02/15/2011 (ML110460708)Source: DAEC LER dated 01/07/2011 (ML110070763)CDBI walkdownfound 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.

22Maintenance RuleMore: http://allthingsnuclear.org/dlochbaum/nrcs-nuclear-maintenance-rule 23Maintenance Rule 24Maintenance RuleWithin a decade, the NRC identified an emerging program, implemented an enduring solution, and identified lessons learned from that fix.

25Maintenance RuleOctober 1986: NRC issues NUREG on maintenance trendsMarch 23, 1988: NRC issues Policy Statement about maintenance and announces plan to pursue rulemakingJuly 10, 1991: NRC publishes Maintenance RuleJune 1995: NRC issues NUREG on lessons from early implementation of Maintenance RuleJuly 10, 1996: Maintenance Rule becomes effective 26Maintenance RuleThe 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:

27Maintenance Rule 28Maintenance RuleSource: Annual ASP Report (ML17153A365) 29Reactor Oversight ProcessSource: 1988 Fort Calhoun SALP (ML12209A361)Superior PerformanceGood PerformanceSatisfactory Performance 30Reactor Oversight ProcessSource: 1997 Fort Calhoun SALP (ML12212A090)Superior PerformanceGood Performance 31Reactor Oversight Process 3 Satisfactory Performance(maybe 3 minus) 32Reactor Oversight Process 33Reactor Oversight Process 34Reactor Oversight Process 35Reactor Oversight Process 36Reactor Oversight ProcessPre-ROPHandful of areas ratedRatings every 18 to 24 monthsNo failing grades Under-performing reactors on "Watch List" without pre-determined NRC responsesROP7 cornerstones assessed by NRC findings and ~18 performance indicatorsRatings every 3 months Failing grades Under-performing reactors on "To Do" list with prescribed NRC responsesBy 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 37Flooding Pre-FukushimaJune 2011 -Fort Calhoun became an island in the Missouri River 38Flooding Pre-Fukushima 08-2010: NRC heard argument that flooding violations had little significance 39Flooding Pre-Fukushima 10-2010: NRC issued final Yellow finding 40Flooding 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.More: http://allthingsnuclear.org/dlochbaum/the

-nrc-in-action 41CFFF 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 42CFFF Event Lessons LearnedMore: http://allthingsnuclear.org/dlochbaum/kudos

-to-nrc-for-lessons-learned-review-at-columbia-fuel-fabrication

-facility 43CFFF 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.

44CFFF Event Lessons LearnedThe lessons learned report made 18 recommendations in the following areas:license review processinspection programoperating experience programroles and responsibilitiesknowledge managementGreat example of pro

-active effort not seeking to fix some past sin but to be more effective in the future.

45Preceding Examples Might Suggest That "Good" Outcomes Require More Regulation or More Enforcement"Good" Outcomes Can be Achieved via Less Regulation or Less Enforcement 46NOT Putting Perry in Column 4 1 stQuarter 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.

47NOT Putting Perry in Column 4More: https://www.nrc.gov/reactors/operating/oversight/deviations.htmlBut Region III sought and obtained permission to deviate from Manual Chapter 0305 and keep Perry in Column 3 (ML13004A403) 48NOT Putting Perry in Column 4NRC 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 issuesunderstood via baseline and 95002 inspectionsaddressed by existing follow

-up plansNRC could have stuck to process and wasted resources by a 95003 inspection.Instead, NRC justified a rare deviation from process andclearly communicated the basis for that deviation.More: https://www.nrc.gov/reactors/operating/oversight/deviations.html 49Zero-Sum BIP Enhancement07-17-2013: NRC staff (HQ and regions) held public meeting with industry and NGO representatives about the ROP's baseline inspection program (BIP)02-05-2014: NRC staff (HQ and regions) held follow

-up public meeting to discuss proposed changes to the BIP04-04-2014: NRC issued report to NRR Director on BIP enhancement project (ML14017A340) 50Zero-Sum BIP EnhancementOpen, transparent process involving many internal and external participants was commendable

-but typical for ROP process changesThe 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 BIP's safety focus, avoiding dilution/distraction of NRC's oversight.

51Common AttributesTimely: Not because resolution was within one week or one year but because resolution was achieved without undue delayClear Communications: What was done and why it was done was explainedDurability/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.

52ConclusionsTens 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.

53 THANKS!www.ucsusa.orgwww.allthingsnuclear.org