ML20151S868
| ML20151S868 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1998 |
| From: | NRC |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9809090085 | |
| Download: ML20151S868 (120) | |
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ORlG NA_
UNITED STATES OF AMERICA
~' i NUCLEAR REGULATORY COMMISSION i
Title:
BRIEFING ON PRA IMPLEMENTATION PLAN PUBLIC MEETING Location: Rockville, Maryland Date: Wednesday, September 2,1998 Pages: 1 - 100 ,
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t 1 UNITED STATES OF AMERICA '
j 2 NUCLEAR REGULATORY COMMISSION '
l l 3 *** l 4 BRIEFING ON PRA IMPLEMENTATION PLAN
. 5 ***
l 6 PUBLIC MEETING 7 ***
l 8
9 Nuclear Regulatory Commission l 10 Building 1 11 11555 Rockville Pike
- 12. Rockville, Maryland ,
l 13 Wednesday, September 2, 1998 14
- 15 The Commission met in open session, pursuant to 16 notice, at 10
- 05 a.m., the Honorable SHIRLEY A. JACKSON, 17 Chairman of the Commission, presiding.
18 19 COMMISSIONERS PRESENT:
20 SHIRLEY A. JACKSON, Chairman of the Commission 21 EDWARD McGAFFIGAN, JR., Member of the Commission 22 NILS J. DIAZ, Member of the Commission 23 24 25 ANN RILEY & ASSOCIATES, LTD.
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l' STAFF AND PRESENTERS SEATED-AT THE COMMISSION TABLE: 1
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2 MARK CUNNINGHAM, RES t
'3 ASHOK THADANI,-Director, RES .
4' HUGH THOMPSON, Deputy Executive Director for Regulatory Programs S l i
6 GARY HOLAHAN,.NRR i
7 ' CHARLES ROSSI, AEOD t
8 MICHAEL WEBER, NMSS >
9 LAWRENCE CHANDLER, Deputy General Counsel 10 JOSEPH GRAY, Deputy General Counsel 11 JOHN C. HOYLE, Secretary !
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3 1 PROCEEDINGS 2
(10:05 a.m.)
.3 CHAIRMAN JACKSON: Good morning, everyone. I am pleased to welcome members of the NRC staff to brief the 4
. 5' Commission on the status of the PRA implementation plan.
6- The PRA implementation plan was first issued in 7 August 1994. Maybe the name needs to change to 8 risk-informed regulation implementation plan. The plan is ;
9 intended toEbe a management tool that will help ensure the !
10- timely.and integrated agencywide use of PRA methods and 11 technology in the agency's regulatory activities.
12 The Commission recently received the last written 13 update on the status of activities in that plan, 14' 'SECY-98-186. The Commission was last briefed on the plan in 15 October of 1997. During today's briefing the staff will i- 16 cover its recent accomplishments, the status of key 17 -activities, and challenges that the staff and industry are
'18 facing in providing a more risk-informed and as appropriate 19 performance-based regulatory framework.
20 Many activities and initiatives within the PRA l
21 implementation plan are directly related to and responsive 22 to issues raised recently by our various stakeholders. As 23- such, my colleagues and I are looking forward to your j 24 briefing today, in particular, your recent accomplishments
' 25 .and plans to continue to improve NRC's programs and 4
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4 1 processes in a risk-informed manner.
2 I understand that copies of the viewgraphs are 3 available at the entrances to the room. .
4 Do any of my colleagues have any opening comments 5 they wish to make?
6 If not, Mr. Thompson, please proceed.
7 MR. THOMPSON: Thank you, Chairman Jackson, '
8 Commissioners.
9 As you said, this is an agencywide effort, and you 10 can see by the representation that the briefers today 11 represent both NRR, NMSS, Research, and AEOD.
12 At the table is Ashok Thadani, who is the Director 13 of Office of Research; Gary Holahan, who is NRR's Director 14 of the Division of Safety Systems Analysis; Mark Cunningham, 15 who is Research's Branch Chief of the Probabilistic Risk 16 Analysis Branch; Charles Rossi from AEOD, who is the 17 Director of Safety Programs Division; and Mike Weber, who is 18 NMSS's Deputy Director for the Division of Waste Management.
19 I think you laid the foundation for the day's 20 briefing very well, and I'll just turn it over to Mr.
21 Thadani, who will provide the overall summary of the more 22 significant challenges and initiatives, and then each office 23 will discuss individual initiatives and near-term 24 expectations.
25 CHAIRMAN JACKSON: Thank you.
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5 7 1 MR. THADANI: Good morning.
2 May I have viewgraph number.2, please.
i 3 Chairman, as you noted in your opening remarks,-we !
4 do have a. number of challenges in front of us, so the issues !
--. 5 that have been raised by various stakeholders, we thought in 6' terms _of our briefing today we would change the tradicional ;
7 approach we have used in this briefing and focus more ;
8 attention on some of those problems and what we're thinking l 9- about doing, some of the actions we've already taken, and l 10 what else we'd be doing to address some of these concerns.
11 And I'll briefly go over some of the initiatives, 12 and then NRR and Research will provide additional details.
13 AEOD and NMSS would follow up by providing status of where 14- they are in. terms of their activities.
15 May I.have viewgraph number 3, please.
16 As I said, while we have completed a number of l
17 activities, and you'll hear some of those later on, we
-18 thought it was appropriate to focus in on some of the tough 19 issues and what are we going to do about them. Right up i-l 20 front we have industry in particular has raised a number of 21 concerns in various forms through workshop discussions, !
22 communication by letters and so on, and as well as at some i
c 23 meetings- We've tried to put them down in certain specific l
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24 categories.
.. 25 First of all, the concern is that it takes too l
,a
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6 1 long for.,the NRC to complete its review of industry 2 submittals. Second, that the staff is asking some of-the 3- questions which had already been responded to earlier in the .
4 development process of guides and so on. And this really is 5 also related'to transfer of technology between Research and -
6 NRR, and.we're going to do something about that as well.
7 And finally there is this observation on the part 8 of the industry that in some cases the staff doesn't seem to 9 be thoroughly dedicated to this concept of risk-informed 10 regulation and moving forward in that arena.
11 .I would also point out during my initial summary 12- briefing that I think there are a number of issues not only 13 that the staff has to deal with but I think there are
- 14. issues, challenges that the industry has as well that need 15 to be considered. And I'll briefly summarize what I think 16 those are.
17 And then I will go through and indicate specific 18 initiatives that we've already taken and how they're related 19 to some of these concerns on the part of the industry.
20 CHAIRMAN JACKSON: Let me ask you a couple of 21 questions, quick questions, and then get to this initiative 22 issue. You know, your status report indicates that the 23' staff is anticipating an increasing number --
24 MR. THADANI: Yes.
25 CHAIRMAN JACKSON: Of risk-informed licensing
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7 l' submittals. _But.at the same time, you know, that same L -
2- status report indicated that Arizona Public Service --
3- MR. THADANI: Yes.
4~ CHAIRMAN JACKSON: For' instance recently informed _;
... 5 the staff of its intention to withdraw Palo Verde as a f
6' risk-informed in-service' testing pilot plan. And so the j
'7 question is, you know, is there a dichotomy-here, or is 8 there'some -- and this is going-to be a question'that has l 9 many parts, so would you listen carefully -- you know, or is 10 it representative of some kind of growing pains or learning 1 1
11 curve or is there something more fundamental.
l 12 So -- and the fundamental question really is do 13 you feel that the complaints are legitimate and 14 well-founded, and you talk about initiatives to address the.
15 challenges, but.here we, you know, have, I understand, and 1
16 the Commission has seen them, that many of the risk-informed 1 i
17- reg guides and standard' review plans currently are being 1
'18 published in final form. And so a natural question relative 19 to "new initiatives" is if the industry and the staff adhere
'20 to_the' guides and reg guides, should that not help to 21 alleviate at least some of the current concerns, coupled I
22 with management oversight through the assurance of a timely )
23 staff review at least on our side with only focused requests 24 for additional information coupled with quality submittals 25 by the industry guided by these reg guides.
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8 1 I mean, I guess that's the real question that I 2 have, you know, if we have them and they are on the one hand 3 somewhat allegedly drawn from the pilots but are meant to .
4 guide reviews, are they in fact being used as they were 5 intended to be used, and how can they, and if they aren't, -
1 l 6 why haven't they helped to address some of these issues.
7 MR. THADANI: I'll try and address that, and I'm 8 sure my colleagues will also want to provide their views.
9 First of all, it seems to me that just about 10 everything you said relates to this issue. First guides, 11 standard review plans would clearly help if they are 12 followed fully, number 1.
13 Number 2, I think that at least for the 14 foreseeable future, which may be a year or two years, I'm 15 not sure exactly the length of period, it's very clear to me 16 that we have to manage very closely the process that we're 17 going through, and you touched upon the focus questions, the 18 rounds of questions, the timeliness.
19 In my view the guides, the standard review plans 20 in conjunction with some of the initiatives that I will talk 21 about such as the role of steering committees, such as the 22 role of risk-informed licensing panel, and the interactions 23 with the industry, I believe they're all necessary.
24 CHAIRMAN JACKSON: Well, I guess the fundamental question I have is are the guides being used or not. Are 25 ANN RILEY & ASSOCIATES, LTD.
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9 they being used'by the industry?
-1 Are they being used for 2 the review plans by us? And if so, you know, what impact
.3 :are they having, and if not, why are they not?
4 MR. THADANI: I believe the guides are largely
'. 5 being used.
6 CHAIRMAN JACKSON: Okay. So'if they are, why do 7 we have'these problems?
8 MR. THADANI: The problems, if you look at this --
-9 CHAIRMAN JACKSON: Is it a management oversight ,
10' issue?
11' MR. THADANI; Yes A lot of problems relate to 12 timeliness, same questions being asked, more~of the 13- management process type concerns. I think there are other 14' issues that relate I'll touch upon such as the issue of 15 standards. I think there are a number of issues that will 16 help us get there.
,17 CHAIRMAN JACKSON: Right.
18 MR. THADANI: I think'they're --
19 CHAIRMAN JACKSON: In the least the generic reg 20 guide and standard review plan there was some implication 21 relative to PRAs and what they needed to look like.
22 MR. THADANI: Yes, there are. And there are some 23 issues there.
24 CHAIRMAN JACKSON: All right. So let me hear from l -
25 Mr Holahan, and then I think Commissioner McGaffigan is l
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10 1 signaling that he~had questions.
2 - MR -. HOLAHAN: Mr. Thadani has touched on a number ,
3 of issues that I would agree with. I think it's a complex ,
4 ; question and a little bit of a complex answer. The industry :
5- has been frustrated by the length and complexity of reviews.
6 I think we are taking a number of steps to streamline those,
'7 - and'certainly having the guidance documents in place I think -
8_ is a major step in that direction. We've taken other ,
9 initiatives like the steering committee and the licensing 10 panel'to get directly to issues and try to move them along 11 for the review process.
- 12. But I think these are only partially what the
'13 industry is interested in. It's pretty clear from our 5
14 - discussions on graded QA, on ISI, and on IST that the 15 industry is-also searching for opportunities to make changes I:U5 without NRC being involved in the review process. And so 17
-whether it's adoption of an ASME code that would allow. _
'18 licensees to implement a change without NRC review or it's 19 an interpretation of the existing QA regulations to allow 20 them to make let's say more limited changes, what I see is 21 the industry' searching out those examples where they can do '
22 things without review and approval.
7 23 So I'm not surprised to see a utility sort of ,
24 backing off an IST or an ISI initiative, and I suspect in i
25 terms of volume of activities most of NRC's review and
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- 1 . approvals in'the future will probably be related to i 2 technical specifications, where it's quite clear that NRC i
3 needs to be directly involved in a review process. But 4
-where'there are other codes or other mechanisms for-( .- 15 minimizing cn: even eliminating the NRC reviews, I see the 6 utilities'and industry as a whole, you know, searching out 7 those opportunities.
8 CHAIRMAN JACKSON: Actually, I don't know if this 9 really pertains, I mean, because it's a couple of viewgraphs 10 down the line, but I noted that, you know, one of the I 11 challenges you had facing the nuclear power industry was the l
l 12 completion of PRA standards --
L 13 MR. HOLAHAN: Um-hum.
14 CHAIRMAN JACKSON: That can support risk-informed !
15 activities --
l 16 MR. HOLAHAN: Um-hum.
17: CHAIRMAN JACKSON: And then I noted a comment --
18 there was a. question.in terms of this ASME task group that's 19 .been set up to develop PRA standards, and there's some 20 question regarding the scope and quality of the group's work 21 and even its impact on what our staff feels is the l.
22 desirability of our representative continuing to support 23 -that work.
l 24 Can you speak to that a bit, and if it's relevant t-25 to where we are in the discussion?
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12 1 -MR. HOLAHAN: I think I'd like Mark to --
2 MR. THADANI: Let me touch on it, and then, Mark, 3 if you can also provide up-to-date status. I'll give you my 4 understanding.
5 On August 19.we received draft standard that -
6- ' includes -- considers internal events only. As you know, 7 this is a phased approach. Later on they'll include 8 external events.
9 The two areas of concern that the staff has, one 10 has to do with the Level 2 portion, which is containment 11 response source term into containment, containment response 12 part. The second part has to do with applications portion, 13 where there seems to be significant deviation from our 14' regulatory guide. And we -- the staff, Mark Cunningham and 15 Mary Drouin in.particular, has been working trying to get 16 these issues resolved, and our goal is to sit down and try 17 and settle ~these issues fairly quickly and not let it 18 linger. But I would like for Mark to add to that in any 19 specifics.
20 MR. CUNNINGHAM: Yes. As you indicated, in the 21 paper we.were -- at the time the paper was written we were 22 v<ery. concerned that it was not going to be a timely -- as 23 timely a standard as we had hoped. I think we've gotten 24 more optimistic since the time of the paper.
25- The two issues you talked about of scope and
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l 13 t 1 . quality, as Ashok mentioned, it's a phased approach, and one 2' of:the~ things we were' concerned about was, okay, when do we L 3. ,begin dealing with some of these other tough issues like !
4 external' events and things like that.
p, 5' .There was a meeting'of the -- the first meeting of l 6
'the Committee on -- the ASME Committee on Nuclear Risk 7 Management, on which I serve, and one of the issues there 8 was let's develop.a schedule for going on with the next part i
9 .of this.
10 And there is a representative from Southern 11 California Edison that's chairing that task group, separate i
12 task group, and I am on that, and we want to pursue, okay, 13 when do we start on the next parts. Because we recognize i 14 there's some tough, tough issues out there too, but we need _;
15 'to get started on it.
I 16 On the quality, Ashok mentioned some of the i
17 concerns we have, and we have a new draft. We still have. '
18 concerns, we still have comments'on it, but I think we're !
19 .looking more positively _at it today than we did two months
- 20L ago. There's still a lot to be done yet. It's an-extremely ;
21 ~ ambitious effort to develop the level of detail that would :
- 22. -be inLthis standard and.make sure that it's'all tight and l 23L consistent in and among~itself. But I think again we're 24 more optimistic, but there's a long way to go yet.
. 25 CHAIRMAN JACKSON: Did you have any comments?
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14 1 MR. HOLAHAN: No, I think Mark covered it. !
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- 2. CHAIRMAN JACKSON: Commissioner McGaffigan. l My original question was !
3 COMMISSIONER McGAFFIGAN: ,
4 going to be, and I think you're going to get to it as I look
- I 5 at the viewgraph, so I won't linger on it, but the reg
-6 guides.themselves we put out, they may and hopefully will [
7 lead to some stability, but we also said we're going to f
-8 update them.
9 And so if I were from industry and there were 10 parts of.the reg guide resolution process that I didn't ;
11 like, I probably would in my submittal still try to get my l 12 point of view across and. challenge the staff that you're 13 going too far. I think there are a bunch of issues of that ;
- 14. sort that are embedded in this process as you go forward. j 15 So am I right that.the stability may only come once we get 16 Rev. 1 of these reg guides out and we get through this l'7 learning process?
f 18 MR..THADANI: I think there will be improved :
19 stability,-I think, and that's why this -- the initiatives [
20 that I will talk about, while I think they're very !
- 21. .important, we can't -- in many cases I don't think we can l 22 wait or continually be updating these reg guides. We need !
23 to have interaction going, identify and agree on what the 24 _ issues are, and let the next update of the reg guide
'25 incorporate those changes. But we can't wait. *
(
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i l 15 1 COMMISSIONER McGAFFIGAN: Right.
2 MR. THADANI: Until the reg guide.
,.c 3 MR. HOLAHAN: I don't really see Rev. 1 as a big l 4 milestone in the future.
o 5 COMMISSIONER McGAFFIGAN: Okay. !
6 MR. HOLAHAN: I think what will bring more 7 stability to the process is clearer expectations on our part I
- 8. and on the utilitiespart, and I think that will come with i
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9 experience of implementing the existing guides. Because I 10 think maybe there will be minor changes in the future, but I 1 11 think the biggest question is what do the existing guides 12 really mean in practice as applied, and I think we're 1
i 13 beginning to figure that out through experience. And I think experience will bring stability to the process.
14 !
15 CHAIRMAN JACKSON: Is there any kind of regular 16 communication channel or forum that you're building into the 17 process either with NEI -- but I think in terms of the 18 actual use of the reg guide with owners' groups or the plant 19' operators to --
20 MR. THADANI: Yes.
21 CHAIRMAN JACKSON: Where lessons learned can be 22 shared?
23 MR. THADANI: Yes, and I'm going to cover --
24 actually I think this is very good, because you are focusing
. 25 in on the areas where we're trying to make sure we do, and i
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i 1= I'll go ahead and address that now and not wait until later. !
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- 2. CHAIRMAN JACKSON: Then I'll -- go ahead, I'm t i
3 sorry. ,
i 4 MR. THADANIi We have put together the steering f 5 PRS steering committee which includes as you know the NRR ,
t
7 laid out the charter for the steering committee, and the _
- 8. steering committee will interact with the industry. l 9 I have had discussions with NEI, and NEI will have f
10- a counterpart' group that will be chaired by Ralph Beedle, .
11 and we would -- plans are to meet once a quarter to make -
' 1:2 sure that if there are any significant issues that we deal 13 with them. I i
14 Then below the steering committee we have what we i 15 ca:1 risk-informed licensing panel, within the agency, .
i f
16 membership, Gary chairs.that group from NRR. Membership is
{
17 largely-NRR division directors and one division director 18 from Research, Tom King, who is the vice-chair. They also j 19 have some specific charter in terms of what they are going l 20 to be doing. And that includes regular meetings with the 4 21 industry. -And I have discussed that -- ,
122 CHAIRMAN JACKSON: Is there a counterpart --
23 MR. THADANI: Yes.
24 CHAIRMAN JACKSON: That's being -- l 25 MR. THADANI: Steve Floyd is the counterpart from
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1 17 1 NEI for that. I've discussed both those activities with 2 NEI. And I would expect more frequent meetings there, and 3 that the steering committee with Beedle and appropriate 4 chief nuclear officers as part of the industry group will
. 5 meet quarterly.
6 CHAIRMAN JACKSON: I'm encroaching on Commissioner l l
7 McGaffigan's question here, but I'm really interested, you 8 know, he did raise this question about the ongoing revisions 9- to those reg guides. Are you going to be able to meet at a 10 level where there really can be a sharing of lessons learned 11 in terms of people who actually use these things?
12 MR. HOLAHAN: Yes, yes, I think clearly the intent 13 is to involve not just NEI as a coordinating organization 14 but the utilities at the level that are really implementing 15 the documents.
16 CHAIRMAN JACKSON: Okay.
17 COMMISSIONER McGAFFIGAN: The second question that 18 comes from a comment Mr. Holahan made and we may not get 19 back to, I thought it was interesting that industry is 20 looking for relief on where they can make changes on their 21 own, and I know that the staff has changed its view on the 22 NEI petition on QA and is going to grant that petition, as I 23 understand it, in a paper that's forthcoming, in part at 24 least. And Mr. Holahan also said that he sees in the future 25 that our main resources on review are going to be used in ANN RILEY & ASSOCIATES, LTD.
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18 1 the tech spec arena. You may be assuming more success and 2 50L.59 space than is warranted at the moment, but let's 3 assume that success. ,
4 How do we in our rulemaking -- some of this is 5 going to involve rulemaking, giving up~ things that are -
6 relatively low priority,-that consume our resources and 7 licensee resources. I regard that as risk-informed even 8 though it may not ever involve anybody grinding on a PRA, 9 because we're using our risk insights to say that some of 10 these areas just aren't worth the review.
11 'But how do we get there? Aside from granting at 12 least in part, and I'm interested in what the staff means in
'13 part, this NEI petition on QA, we're working on 50.59, are 14 there other areas that they're pushing on where there's some 15 hope that we can scale back the review, because the review 16 just isn't producing much?
~17 MR. HOLAHAN: I'm not prepared to talk about the ;
18 QA example. i 19 COMMISSIONER McGAFFIGAN: All right.
?
20- MR. HOLAHAN: But there are a number of other 21 ~ activities. What we've recently committed to is giving the !
22 Commission an options paper by January that looks at various 23 approaches'to in effect risk-informing the whole of Part 50.
24 In that context one of the options has been put forward by l
25 NEI., They've recently shown us an approach in which they
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19 1 would ask for 51 rule changes and have three plants act as 2 pilot applications for those and actually implement such 3 changes under an exemption process. That's sort of one 4- approach that's been put on the table.
. 5 The staff is looking at a number of other 6 alternatives. I think these are obviously, you know, 7 important policy matters for the Commission to be involved 8 in. So the approach that we've laid out is to pull together 9 these various ways in which the regulations could be 10 risk-informed, and put them before the Commission, kind of 11 in a two-stage process.
12 CHAIRMAN JACKSON: Well, let me just say something {
13 about that for a minute. I think you owe it -- you have a 14 responsibility to the Commission that you don't just say do 15 you want your egg sunny side up --
16 MR. HOLAH4N: Um-hum.
)
17 CHAIRMAN JACKSON: Or, you know, over easy.
18 MR. HOLAHAN: Um-hum, 19 CHAIRMAN JACKSON: Okay. That the issue becomes, 20 you know, somehow, you know, the Commission needs to 21 understand what the implications are of the one or the 22 other.
23 MR. HOLAHAN: Yes.
24 CHAIRMAN JACKSON: Okay. And so --
25 MR. HOLAHAN: Certainly.
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20 1 CHAIRMAN. JACKSON: With whatever you bring 2 forward, you know, one has to do that.
3 MR. HOLAHAN: Um-hum.
4 CHAIRMAN JACKSON: And, you know, it should come
-5 .out of interactions with NEI, et cetera. But, you know, the .
6 Commission is not here to do your job, and so, you know, you 7 can't just say sunny side up or over easy. And that's all
' 8- it really is.
9 MR.-HOLAHAN: I'm afraid none of these will be 10 easy.
- 11. MR. THADANI: Let me say two things. First of
-12 all, Chairman, even for the steering committee side, Ralph 13 Beedle said that the rest of the ind2stry members will be 14 driven by issues and be represented by the industry. So 15 there will be chief nuclear officers who will participate in 16 these discussions. So actual people involved in these 17- efforts will be part of the discussions.
18 I just comment on the NEI issue. We just got 19 their proposal'last Friday, which is quite a bit different 20 than what had initially been proposed. Both the. offices.are 21 taking a hard look at that option, looking at are they 22 alternatives, what the-resource implications would be,
.23 timeliness, we do have a number of initiatives that are
'24 ongoing.
25 -We have a senior management meeting with NEI this
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21 1 Friday. We'll be discussing this issue. We anticipate a 2 follow-on meeting to get into specifics and alternatives and 3 what makes sense. So this dialogue hopefully in the next 4 few weeks will lead to some understanding, and that would be
. 5 what we would pull together as part of --
6 CHAIRMAN JACKSON: Do we ever do our own thinking 7 up front?
8 MR. THADANI: I hope we do. Yes.
9 CHAIRMAN JACKSON: Well, because, you know, when I 10 was initially in NRC --
11 MR. THADANI: Um-hum.
12 CHAIRMAN JACKSON: I raised some questions about 13 things like definition of terms important to safety, safety 14 related, I don't know, there was a panoply that have safety 15 in them. And I got back a kind of hard response in terms of 16 well, we tried to, you know, do this in the past, and, you 17 know, it's too hard, it's across too many regulations, et l 18 cetera, et cetera.
19 Have we done any thinking in the interim --
20 MR. THADANI: Yes.
21 CHAIRMAN JACKSON: In terms of, you know, how one 22 might go about addressing some of these sorts of issues --
23 MR. THADANI: Yes.
24 CHAIRMAN JACKSON: And particularly in a way that 25 relates to the risk --
i l
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22 1 MR. THADANI: Risk-informed -- >
2 CHAIRMAN JACKSON: In terms of --
3 MR. THADANI: In fact --
4 CHAIRMAN JACKSON: You'll make the regulations?
5 'MR. HOLAHAN: In fact, some original staff -
6 thinking was presented to the Commission last year in terms .
7 of. risk-informing the regulations. -It was in the context of 8 the 50.59 paper. But there were -- of the.five alternatives l 9 offered, I think three of them were kind of broad, 10' conceptual, you know, methods of putting risk information 11 into the regulatory process. I think at the time maybe the 12 Commission wasn't ready to pick one of those options, but I 13 think, for example, you know, rethinking each of those three ;
14 options plus what NEI has put on the table is part of this 15 collection of options to be looked at, and, you know, and ;
i 16 _ assessed and offered back to the Commission.
l 1 l
17 COMMISSIONER McGAFFIGAN: But just to follow up l
)
18 on, you were referring to this proposal from NEI as part of 19 the pilot activity to change 51 rules and exempt the three ,
t 20 pilot plants, go through an exemption process on each of 21 'those-rules for the pilot plants, and we'd see whether we P
22 could justify the exemptions. Is that essentially what the l 1
- 23; pilot would be? !
24 MR. THADANI: That's the pilot. )
25 COMMISSIONER McGAFFIGAN: Okay. ~
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13 1 MR. THADANI: Yes. !
2 COMMISSIONER McGAFFIGAN: The resources to do 3 that, you said you were going to talk about resources. I'm !
i 4 worried -- I want this to be successful. I mean, if that's
):
. 5 an option that is real, I want to make sure -- and worth :
1 6 pursuing, we have the resources to do it. How do we get the '
1 l
7 resources in '99 if you all come back and say -- and in some 8 sense I think it's our job as a Commission to say when this i 9 is so high a priority, if we choose that that we'll find the 10 resources. But what wou]d it take in '99 to --
11 CHAIRMAN JACKSON: I don't think they can answer 12 that.
13 MR. THADANI: We can't answer that specifically 14 what it'll take, but that is in fact what we will owe the 15 Commission, what the options are, which one we would 16 certainly recommend an approach and what the implications 17 are in terms of resources and what other work we couldn't 11 8 do, and we'll look at the operating plants to -- in other l l
19 words, that's the kind of information we need to put i l
20 together to provide to the Commission.
21 COMMISSIONER McGAFFIGAN: But it's fair to say 22 that that's probably going to be resource-intensive. If we 23- choose that option --
24 MR. THADANI: I believe so.
25 COMMISSIONER McGAFFIGAN: That that is not the ANN RILEY & ASSOCIATES, LTD.
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1 24 1 pilot that'you. guys have resourced at the moment, that is a ,
2 mach more resource-intensive --
3 MR. THADANI: Absolutely.
4 CHAIRMAN JACKSON: But you're talking of coming to 5 the Commission at a point that's essentially halfway through -
6 the fiscal year or close to that, and I think when you come, ;
.7 _you have to come from the point of view of how it shakes 8 out --
'9' MR. THADANI': Yes.
10 CHAIRMAN JACKSON: Through the operating plan or t 11 the plan --
12 MR, THADANI: Absolutely. I 13 CHAIRMAN JACKSON: In terms of the resource 14 ' implications. And.if the Commission decides that it wants [
15 to adopt one of the options and clearly understands what the l
- 16. implications are relative to those options, then-that's what [
17 .will happen. All right?
18 Commissioner Diaz? i 19 COMMISSIONER McGAFFIGAN: I might just add, I do 20 think that this is a very good development. I mean, however 21 resource-intensive it may be, it seems to me it strikes 22 exactly to the Chairman's invitation at the stakeholder 23 meeting reiterated at the July 30 congressional hearing that
'24 . we.were going to be open to this sort of proposal and now 25 . we're going to have -- we may have to find the resources if -
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l 25 1 that's the way we're going to go.
i 2 CHAIRMAN JACKSON: That's right. But it's going 3 to require some hard thinking on your part, okay, in terms 4 of, you know, as I say --
5 MR. THADANI: Yes.
6 CHAIRMAN JACKSON: Sunny side up or over easy or 7 hard.
8 MR. THOMPSON: And this is -- we are really just 9 at the early stages of this change in --
10 CHAIRMAN JACKSON: Let's hope not.
11 [ Laughter.)
12 CHAIRMAN JACKSON: We want to keep some shape 13 here.
14 MR. THOMPSON: But we are very early in the 15 elements in this dialogue, and it's going to be important 16 for us to really understand as well as do our own thinking.
17 We've talked yesterday amongst ourselves, you know, what are 18 those things that would make this a success, you know, what 19 are the questions that we need to have the dialogue with the 20 industry, because I think it's important for us to if we're 21 going to put our resources on it that we think it is a 22 pathway that will be successful.
23 CHAIRMAN JACKSON: I mean, I've looked at the, you 24 know, preliminarily at the proposal. It's certainly i
25 comprehensive in terms of the panoply of rules and the f
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26
'1. panoply of general design criteria, and I guess -- I believe 2 the Commission needs to have some understanding of how the 3 one plays off against the other.
.4 What is the significance relative to cornerstones
.5 of our regulatory approach, particularly in the general -
6 design criteria arena? Can one be done without the other, 7 and how does one affect the other?
8 But I do believe the opportunity to' provide some
- 9. - clarity, first of all, with terms, through the panoply of 10 regulations. And, of course, you know I am a definite fan 11' of risk ranking various' attributes of plant operations, et 12 cetera, and having a comprehensive scope without these 13 artificial boxes, and then having whatever we do in 14 regulatory space, triggered to that kind of ranking. And I 15 have been working on that since I have been here. And so if 16' this gives us an opportunity, then I am all.for it. Butcyou 17 have to do your own thinking, but not in the sense of I 18 don't want to do it. But you have to do your own thinking
-19 and comeback. And that is the real point, that you have got 20 to think it through.
21 MR. THADANI: Yes.
22 CHAIRMAN JACKSON: Right. Do you have any?
23 COMMISSIONER'DIAZ: No , no.
24 MR. THADANI: I may-note that I have also had some 25 discussions with Commissioner Dia: on this same issue of -
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27 1 various terms.
2 CHAIRMAN JACKSON: Right, I know.
3 MR. THADANI:
And the need to have some 4 consistency.
. 5 CHAIRMAN JACKSON: That is why he is smiling over 6 here. But you have got to develop your own strawman, you 7 understand?
8 MR. THADANI: Absolutely. Yes.
9 CHAIRMAN JACKSON: I mean that is my ball game. I 10 have told NEI this, bring us strawmen. Right. And so they 11 have brought us a strawman. What is your strawman?
1
- 12. MR. THADANI: And that is exactly what we are 13 doing. i 14 CHAIRMAN JACKSON: All right.
15 MR. THADANI: That is exactly what we are doing.
16 Our intention is to sit down and not just say bring me 17 another rock. That is not the plan. We have got to move i
18 towards some constructive way to get to what makes sense and 19 what we can do.
20 CHAIRMAN JACKSON: Well, the constructive way is 21 for you to develop a strawman.
22 MR. THADANI: Right.
23 CHAIRMAN JACKSON: And now you know what you --
24 MR. THADANI: Exactly.
. 25 CHAIRMAN JACKSON: As regulators. Right? And now ANN RILEY & ASSOCIATES, LTD.
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28 1 you overlay these things. And then you go forward.
2 MR. THADANI: We are putting together exactly what 3 you say. Our proposed approach and areas. .
4 CHAIRMAN JACKSON: All right.
5 MR. THADANI: With your agreement, looking at -- I 6 want to be sure that all the offices have an opportunity to 7 say -- I could skip page number 4, viewgraph number 4 and go 8 to viewgraph number 5, because I think we have talked about 9 these challenges enough.
10 There are two or three points I do want to make, 11 i one of them we have already made in terms of the 12 importance of the standard.
13 CHAIRMAN JACKSON: Yes, let me reiterate that.
14 This is more message that I am throwing out beyond those 15 sitting at the table. This issue has to be addressed. And 16 if we can't make progress, you know, we can go through a big 17 rulemaking talking about risk ranking and so forth. We have 18 got to make progress. But, you know, this is my colleague's 19 point and he has educated me on that, that point. I don't 20 know if you have any comments. But I happen to believe now, 21 the more I have come to understand, that there has to be a 22 good faith effort on both sides in other to make some 23 progress.
24 MR. THADANI: Yes.
25 COMMISSIONER DIAZ: No, I think it is a dual road ANN RILEY & ASSOCIATES, LTD.
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29 L
p 1 .and I think that the industry has to also accept the 2- responsibility. If they really want to be risk-informed, 3 they_actually have to come and meet half the way. I also
- 4. think_that we have said many times, it is not a. matter of
. 5- the-staff being serious. I think the staff is always 6.. serious. 'It is being. committed to get this work done so we 7 can have a more efficient system working.
8 CHAIRMAN JACKSON: Right. Now,. if you want to do 9 a rulemaking as comprehensive as the one that-has been F 10 proposed, --
i MR. THADANI: Yeah. l l
12- CHAIRMAN JACKSON: -- and I am talking to my 13 friends from NEI, then you have got to have -- be committed l
-14. to what undergirds it. You don't just go out into y 15 cyberspace. And I am committed to this kind of approach.
16 You have' heard me' talk about it before. But you have got to t
17 'put flesh on the bones. You know, we can't play game, 18L because it is too important if you are talking about 19 migrating or regulatory framework. And so -- and I will go 20 on record on that one.
- 21. MR. THADANI: And I think that is one of the 22 issues that is very important to us, that we have the right i
23- technical base for these decisions, because, otherwise, X j 24' -years from now, we would be concerned about what changes we i -25 made and whether they are appropriate or not.
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30 1 Again, on these issues, challenges that I think 2 the industry has, they are really sort of similar in nature 3 in terms of the criticism that -- in many cases, valid .
- 4. criticism at our performance. I think some of these areas 5 that relate to quality of submittals, timeliness of response 6 from the industry to questions, they also apply oftentimes I ,
t 7 thinit to the industry as well. So our objective here, as j I
8 part of the steering group, as well as part of the licensing 9 issues panel,.is to make sure that the industry is focusing 10 their attention on thess issues. The goal that they and we 11 have is the same, more efficient and effective process.
.12 I will go on to viewgraph number 6. Okay. Now, I 13 think this, to me, is an important piece. We have really 14 talked a lot about it already. I do want -- the three major 15 areas that we are focusing attention on, regulatory [
16 framework, priority and resources, clarity of guidance, we ;
17 have talked about all of these. But the steering committee ;
18 charter includes all of these issues and where there is a ,
i
.19 need for policy guidance, we come back to the Commission, '
i 20 get policy guidance once we -- otherwise, we make sure that ;
21 the current policy is, in fact, being implemented. ,
22 And then we get into issues, we'will get into' [
t 12 3 issues of guidance, priority, coordination, resources, 24 schedule. Interaction with the industry, I talked about the [
i 25 membership, we have already established that. I apologize '
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31 !
l I
.1' .to Louise Reyes because I did not mention that part of the ;
i 2 steering commit' tee is. Region 12. . Louise Reyes represents the 3 regional. thinking as part of our group. !
(
4 I'said we have already established counterparts. !
I o 5' We are -- you will hear a little bit more, and you already 1
6- 'know about this because.it is addressed'in'the response to j
'7- your tasking memo, Chairman,.that many of the programs and.
i 8- activities, where we are using. risk-informed thinking. So I 9 won'tigo into these unless you have questions.
10 The steering committee is also going to be 11 focusing attention, as I said,.in terms of priority and 12 resources issues. We have also established the L 13 risk-informed licensing panel which will also be looking at 14 the issues of timeliness, consistency. This panel is more ,
15 in day-to-day interaction with the industry and the specific 16 licensing submittals.
17 CHAIRMAN JACKSON: The nuclear power industry?
18 MR. THADANI: . Nuclear power, yes. ,
l 19' CHAIRMAN JACKSON: If I was looking in here and I 20 were one of our other licensees, my feelings would be hurt
- 21 even though, you know, we are talking about'this, right?
22; MR. THADANI: Yes. Nuclear power, yes.
l 23' COMMISSIONER McGAFFIGAN: Could I ask about the i 24 licensing panel? It seems to me that what you are inventing t
l t-25 here is something'similar to what was invented, improve t-l t
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l 32 1 standard tech specs, dry cask storage, AP600, other areas 2 where we had timeliness goals and where we were trying to 3 keep the process moving, make sure REIs are appropriate and .
4 not asking for duplicative information, et cetera. Is that 5 -- is the licensing panel going to establish timeliness a 6_ goals for risk-informed licensing actions, and follow, 7 eUsentially all of them?
8 MR. HOLAHAN: Yes.
9 COMMISSIONER McGAFFIGAN: And break ties among, 10 you know, --
11 MR. HOLAHAN: Yes, exactly.
12 COMMISSIONER McGAFFIGAN: So that is your intent?
13 MR. HOLAHAN: Yes, exactly.
14 COMMISSIONER McGAFFIGAN: Are you going to write 15 all that down?
16 CHAIRMAN JACKSON: Well, it had better be in the 17 operating plans. Will it be in the operating plans? And I 18 don't want a knee-jerk answer.
19 MR. THADANI: When you say --
20 CHAIRMAN JACKSON: Well, do you plan to have 21 timeliness --
22 MR. THADANI: Oh, yes, yes, yes.
23 CHAIRMAN JACKSON: And you are policing the 24 process relative to those goals?
25 MR. THADANI: Yes. Yes. If we have goals and -
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33 l 1 . criteria, they have to appear in the -- 1 1
l 2 CHAIRMAN JACKSON: Okay. And so the real question l l
'3 .has'to do with this. .Is the only way the agency is going to '
4 be timely is to create steering' committees'each time? 1 i
, 5~ MR. THOMPSON: No, no, no. I think.the steering i 6 committees are only for those areas we are kind of plowing 7 new fields, or need to get in place some processes that will l
8 eventually become our way of doing things. I don't see us l
)
9- having to have steering committees to be able to -- as a
- 10. general practice.
11- CHAIRMAN JACKSON: So you are doing it for high 12 hat activities?
- 13. MR. THOMPSON: That's right. Yes.
- 14 MR. HOLAHAN
- And also, the way in which we are 15 doing it, what we are really doing is pulling the line 16 managers together to put special attention on these 17 particular. issues. But these are the same managers who are 18 responsible for the other 1200. licensing actions a year.
1 19 CHAIRMAN JACKSON: I mean because, you know, I '
20 agree that for high hat activities, you perhaps need special 21~ mechanisms to move them along, particularly at an early l 22 stage. But in the end, if we are doing.the right job from a i 23 ~ planning and a management point of view, just as with our '
24 licensees, it should be embedded in how the line !
25 organizations do their jobs, even if the activities cross I l-ANN RILEY & ASSOCIATES, LTD.
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34 1~ the boundary lines.
2 That is not something that needs to come happen 3 .every time there is a steering committee. You know, this 4 manager here in NMSS and this manager here in Research, they 5 don't need to be doing that. Right. And so that is a job -
6 as managers that you all need to be held to, and that is my
'7 expectation of you, as Chairman,- I mean you all need to be 8 doing that. And so it shouldn't always be steering 9 committees. But for the high hat activities, to move them 10 along. !
'll MR. THOMPSON: Right. ,
t 12 CHAIRMAN JACKSON: And so I am just, you know, 13 playing off of Commissioner McGaffigan. [
?
14 COMMISSIONER McGAFFIGAN: I agree with the !
15 Chairman on that. But I'do think that it is probably a good :
16 safeguard on these high visibility issues, license renewal, j 17- .this' sort of thing, to have these sorts of mechanisms.
L
.18 CHAIRMAN JACKSON: Absolutely.
19 COMMISSIONER McGAFFIGAN: Extraordinary 20 mechanisms. ;
z*i 'MR.. THOMPSON: We are in a transitional aspect on l 22 some -- )
23 CHAIRMAN JACKSON: We are in violent agreement.
24 Commissioner.
25 COMMISSIONER DIAZ: Yes. I was just thinking -
i
- i
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i e e i 35 1 .that,.you know, in how things work, and I was trying to put 2 simple words in my mind, I am a simple person.
L D
- 3 CHAIRMAN' JACKSON: Don't trust him.
r
- 4 COMMISSIONER McGAFFIGAN
- Hold your wallet.
1 51 COMMISSIONER DIAZ: I was trying to figure out 6_ whether the steering committee is actually going-to function
! 7 .like the guru of PRA, you know, as'the place where policies, 8 ' ideas that follow Commission direction are going to be 9 . directed.to'the staff. And-I'look at the licensing panel in 10- the area of licensing, but they might be.a risk-informed 11 panel sometime as.the one that massages this and tries to-12 get with the interface. The thing that it seems to me 1ike
~
+
13' might be missing in this arena, and it something that, you 14 know, we all need to consider, is an implementer, is 15- .somebody that actually --
16 CHAIRMAN JACKSON: Who owns'it.
17 COMMISSIONER DIAZ: Who owns this and who moves i 18 it. The ombudsman of PRA implementation. You know, what is 19- .the interface? .
20 CHAIRMAN JACKSON: Is that you, Gary?
l 21 MR. HOLAHAN: Well, if we are talking about 22_ licensing actions, I think it is.
23 MR. THOMPSON: Right, it is. Right.
24 -CRAIRMAN JACKSON: Okay. So we have identified
. 25 that individual.
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36 l' COMMISSIONER DIAZ: In the licensing.
2 MR. HOLAHAN. In licensing.
3 MR. THOMPSON: In licensing, yes.
4 . COMMISSIONER DIAZ: And now we might want to 5 'think, you know, when you guys go through these things, is .
6 there something that maybe the Commission should look at?
7- -Maybe the Chairman should be' responsible for?-
8 CHAIRMAN JACKSON: Well, I have asked the staff, 9 and each time there is an initiative,.the problem has been
-10 that no one owns it. And that each time there is something 11 like this, it can't just be steering committee, that someone
- 12- has to own it. And that's what I meant about how you 13 manage, how you do your jobs as managers. That somebody has 14 to be identified, even if it is across organizational 15 . activity, who owns it and is vested with the authority to .
i 16- drive the process. If not, then you are not doing your jobs L
L 17 as managers and, ultimately,-you know, I.will take a look at i 18 it, as well as the Commission. But in actual performance 19 expectations basis.
20 MR. THADANI: Yes.
21- CHAIRMAN JACKSON: Right. {
! 22 MR. THADANI: The only point I would like to make l:
L 23 on this chart, because when you look at it --
c >
- 24 CHAIRMAN JACKSON: Which one are you talking 25- about? -
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37 F
1 MR. THADANI: Number 6, I am sorry.
2' CHAIRMAN JACKSON: Okay.
3 MR. TFmDANI: Is to make a note that a number of' a . .
initiatives, NRR has, in fact, underway, as well as other 4
o 5 _ offices, but, particularly, NRR, that you will hear about. 1 Which I'think'would help respond to some of these concerns. I 7 Now, let me go to Gary so you can more about some 8 of the specifics of some of these.
9- MR. HOLAHAN: Well, I am going to follow up in
'10 _this context for NRR activities. I think some of this we 11 have already talked.about a little bit.
12 The first thing I would like to emphasize fus that i I
13 we are having a continuing dialogue with the stakeholders.
14_ As the Commission met at a higher level, we are meeting with 15 the PRA and licensing community. So we had a workshop on 1 16 July 22nd with about 150 participants from industry and the 17 public,-and I think the issues out of that meeting were very
, j 18 similar to the issues that the Commission has heard at the 19 stakeholder and the Senate hearings, with concerns about the 20 . timeliness of NRC actions where, from the industry's point !
i 21 of view, they agree with where we want to go, but, simply, '
22 it takes too long and it is too hard to get there.
23 But I think it was important that at the meeting l
~ 2 4 -- there were a number.of constructive' comments. It was not
+ 25 .just a complaining session. In fact, I would'say about
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38 1 three different presentations from different industry groups 2 recommended some sort of panel or arbitration board to get 3 issues moving. And, in part, we have put our risk-informed 4 licensing panel in place, recognizing that need.
5 In addition, I thought it was particularly -
6 interesting that in an eight-hour meeting there were no 7 comments and no complaints about the risk criteria or the 8 use of risk information in the licensing process. The 9 decision criteria and all that we worked on for quite a long 10 time is not a controversial issue. How to bring together an 11 integrated decision with deterministic and risk information 12 is really the difficult process. And seeing that these are 13 difficult decisions to be made at the reviewer -- at the 14 branch level, we see this panel as a mechanism for providing 15 guidance and oversight to the staff and moving things along.
16 I have already mentioned that the staff is 17 developing options for rulemaking. There are also really 18 fundamental re-looks at a number of important areas, 19- inspection, enforcement, assessment, 50.59 being a 20 particular example in the regulation area where there are 21 initiatives to put risk information into those processes.
22 I think the one I would like to focus on is, later 23 this month, there will a four-day workshop to address both 24 inspection and assessment and we are expecting that to be an 25 important element in deciding how to bring risk information
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39 1 Linto the-inspection.and assessment processes. That will'be l L2- a key issue. l l
l
'3 I would like to go on to slide number 8, if I ,
j 4 could. With. respect to priorities.and resources, I think we
- 5 ~have already mentioned the panel more than once. And to 6 give it a little 'more than just a name, the panel has met on i 1
17 three: occasions already. It has worked and reworked a
- 8. charter,to identify how itLwould function and how it would i
- 9. relate to line management.
10 ' CHAIRMAN JACKSON: Let me give you one little 11 -~ trivial recommendation.
12' MR. HOLAHAN: Yes.
.13 CHAIRMAN JACKSON: You are calling yourself a 14 licensing panel.
15 MR. HOLAHAN: Yes.
16 CHAIRMAN JACKSON: And that has a certain meaning 17- in a legalistic world. So you might want to substitute 181 panel with something else. You can pick your choice.
19 MR. CHANDLER: Okay. Not a problem.
-20 CHAIRMAN JACKSON: I beg your pardon?
i 21 MR. CHANDLER: That's not a problem. I 22 CHAIRMAN JACKSON: No , it is not a problem for 23- _you.. But in terms of clear communication --
24' MR. CHANDLER: For clarity.
. - 25; CHAIRMAN JACKSON: -- to the public.
l l
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i 1 MR. HOLAHAN: And we have an OGC member of our 2 current panel. Perhaps she can help us.
3 CHAIRMAN JACKSON: You are charged with coming up 4 with a new name. ;
5 MR. HOLAHAN: On the panel, we like to assign the -
6 responsibilities for various members to get things done, so ;
7 that would be a good assignment.
8 We have met on the NEI Task Zero, which was the 9 Arkansas request for changing the hydrogen monitoring 10 requirements. We have worked out a solution to that 11 problem. We have communicated that to the licensee. I have ;
12 in this pile of papers a draft order which will resolve that !
13 issue. We expect next week for the licensee to send us a i 14 letter and a confirmatory order will be issued later this 15 month. And we think that having this panel in place as a l
16 forum for airing that issue was helpful in moving that 17 along.
18- We have also looked at the issue of the ISI pilot i 19 activities and their schedule. It was in response to the 20 industry's desire to have those done more quickly, our 21 recognition that there are important safety matters 22 involved. There are occupational exposures and other 23 reasons why the NRC ought to wish these changes to be in '
24 place as soon as possible. So the panel requested that the 25 Division of Engineering go back and re-look at its schedule -
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41 1 and see to what extent it can be shorted. And so that looks 2 like it has been helpful, as well, in pulling those dates 3 back a little ways.
4 We have also requested and have a draft of an
. 5 office letter to clarify the responsibilities among the 6 technical and the project managers within NRR in moving 7 licensing activities along.
8' We have also called for a database and a mechanism 9 for which our normal process for keeping control and 10 monitoring of activities will tag risk-informed licensing 11 actions in a special way, so that those can be pulled out 12 and the schedules and the progress on those can be tracked 13 simply.
14 One of the things we identified early on was, 15 although there were a number of complaints about 16 risk-informed activities not moving along quickly, in fact, l
l 17 no one had a real list of what those activities were. And
[
18 we found that we were, in some sense, having discussions 19 without having the real list of what activities are we 20 talking about. So we are much closer to that point now.
21 I would also like to mention that we have l 22 established a lead project manager, which is a mechanism for i
23 coordinating activities among the various project managers.
! 24 It gives the project managers for all the reactors a point 25 of contact where they can be comfortable and understand what J
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> 42 ,
1 is expected of them when their licensee is looking to 2 implement the risk-informed activity. So these all look 3 like steps in the right direction. .
-4 Can I have slide 9, please? f 5 Mr. Thadani mentioned earlier the importance of 6 guidance and having clear expectations in where we are going !
7- in risk-informed activities. I think this is an area where, !
I 8 in fact, we have made very significant progress. The 9 Chairman challenged-us a few years ago to put broad and !
10 comprehensive guidelines in place. There has been quite a i 11 lot of activity in that area. The Commission has been ,
12 involved. .There have been lots of meetings. Draft
- 13 documents were out for comment last year. And we have come ,
i 14 now to the point were regulatory guides.and standard review 15 plans for the use of risk information have been published. .
16 They are out there and they are being used, both general h 17 documents, as well as specific guidance documents for 18 in-service testing, technical specifications changes, graded {
19 QA. I 20' We have recently issued for trial use the !
- 21. in-service inspection guidance documents. And we are using r
22 the South Texas implementation of graded QA as a mechanism l L
23 for observing that activity and developing guidance I 24l documents for an inspection program, and we expect that to [
25- be done by the end of the year. -
{
f l !
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43 1 We have made significant progress on the pilot 2 activities. We have completed the Comanche Peak IST pilot j 3 activity. A number of the technical specifications with j i
4 respect to diesel generators, safety injection tanks, and 5 ECCS equipment have issued, and those are moving along more 6 quickly.
7 The graded QA pilot was completed last year. And 8 at the moment our focus is on the ISI pilots. And the 1
9 reason the dates are not in your slide is, frankly, because !
i 10 the licensing panel was meeting and trying to optimize those l 11 dates and pull them back. So the dates that Mr. Callan has 12 recently forwarded to the Commission in the context of the i
13 tasking memo shows that we have pulled those back so that l 14 issuance of completed reviews for Vermont Yankee would be 15 done in November, Surrey and AMO 2 would be done by the end 16 of the year. I 17 We expect the Westinghouse Owners Group topical, 18 for which we currently have a draft in place, we expect that 19 to be done by November. And the EPRI topical, we expect to 20 complete in the spring. An exact date, I think we are l
21 waiting upon an additional submittal from the licensee, so 22 that we will set the specific date when we receive their 23 next information. So the ball is in their court at the 24 moment.
25 I think these will be significant, not only I
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44 1 reviews in and of themselves, but.they will be significant 2 -signals to the industry that the NRC is not committed to 3 make these changes but is capable of putting those in place. .
4 CHAIRMAN. JACKSON: Let me ask you this question.
8 5 I am told'that a representative from South Texas, you have 6 South Texas,. the graded QA.
7 MR. HOLAHAN: Yes.
8 CHAIRMAN JACKSON: SER as having been issued in 9- November of last year.
, 10 MR. HOLAHAN: 'Yes.
11 CHAIRMAN JACKSON: And that this representative 12 felt -- fairly recently indicated that it had not provided 13 the expected returns because of so many overlapping 14' requirements.
15 MR. HOLAHAN: Yes.
16 CHAIRMAN JACKSON: Can you speak to that issue?
17 MR. HOLAHAN: Partially. I have heard that 18 comment as well. I have spoken.to a utility manager from 19 South Texas. We have arranged a public meeting for 20 September 15th on that topic.
21 What I understand is, in implementing the graded 22 QA program, they found that the same equipment that is
.23 covered by QA requirements is also covered by other 24 requirements, 50.59, for example, and their ability to 25 implement changes, they felt was restricted by other parts -
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i 45 )
i 1 of the regulations, I think in a.way that was not
- L anticipated either by the staff or by the licensee in this L
3 process.
4 I still don't understand the details of why that
~
L6 'S has come about. That is why we have asked for the meeting 6 with the utility. It is conceivable to me that perhaps 7 -their interpretation of these restrictions is maybe overly 8 conservative. It may be that,.in fact, they are not quite 9 as constrained as they may feel. Or it may be that they 10 have, in fact, identified some relationship among the 11 regulations that means that you.can't just deal with one 12 regulation at'a time. So I think that remains to be sorted 13 out. But we see it as an issue. 'They have raised it in a 14 number of forums, and I think we need to understand and deal 15 with that.
16 CHAIRMAN JACKSON: Right. I am encouraged that 17 you are going to have this meeting in September.
18 MR. HOLAHAN: Yes.
19 CHAIRMAN JACKSON: And that -- I just would like 20 to reinforce two things with you. One is that it is very 21 important to have these continual interactions.
l 22 MR..HOLAHAN: Yes.
l 2
.3 CHAIRMAN JACKSON: You know, not just on a broad 24~ basis industry-wide, but with those who actually make use of
. 25 .these things.
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1 46 ;
1 MR. HOLAHAN: Yes.
2 CHAIRMAN JACKSON: That is something that is very 3 important from my perspective. .
4 MR. HOLAHAN: Yes. I agree completely. That is 5 where we get very useful feedback. ,
6 CHAIRMAN JACKSON: And then the second is, being a 7 learning organization, and extracting what we can from what 8 may come out of this, where there may be intersections with 9 other regulatory requirements, and capturing them relative 10 to the response the NEI proposal or developing your own 11 strawman relative to where the panoply of regulations or 12 regulatory requirements may need to be changed. Because
- 13 this is the real life data.
14 MR. HOLAHAN: Yes.
15 CHAIRMAN JACKSON: And so I think it's very 16 important that we don't kind of have this going on over here 17 and an activity going on over here where the one can inform 18 the other.
19 COMMISSIONER DIAZ: I think in expanding on that 20 point, you know, sometimes we look at regulations like a 21 flat, you know, level with our hierarchies, and people seem 22 to think each one of them. I'd be very interested in 23 knowing from this discussion whether there is a hierarchy in ,
24 which you can establish that, you know, Appendix B --
25 MR. HOLAHAN: Um-hum.
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47 1 COMMISSIONER DIAZ: You know, is more 1
2 hierarchically important at what whatever it is and \
3 therefore, you know, by following that, you are actually in 4 compliance with X, B, and Y. And so that's -- I would be
. 5 happy to hear the feedback from that.
6 MR. HOLAHAN: I think that's a very important 7 issue. I think today we're not in a position to understand 8 quite how these things fit together. But I think that's an 9 important topic to cover with South Texas.
10 COMMISSIONER McGAFFIGAN: Could I ask on the tech 11 spec area that there are a fair amount of license amendments j 12 that are now going through, or I think I saw one, the Blaha 13 Weekly Report mentions it seems one almost every week now it 14 seems. So there seems to be folks in the queue following on 15 the pilots.
16 In the case of inservice testing, are there people 17 behind Comanche Peak trying to get relief in the inservice 18 testing area and filing amendments, graded QA, are there 19 people coming in behind South Texas. I know inservice 20 inspection we're still trying to get the first one to work, 21 but what is the -- how many licensing actions do you have in 22 or anticipate that would fall in these different categories?
23 MR. HOLAHAN: We've seen very, very few, if any, 24 follow-on activities for the ISI and graded QA. The number
. 25 I have -- I'm looking at a number of about 59 licensing ANN RILEY & ASSOCIATES, LTD.
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48 1 activities that we're monitoring, and virtually all of them 2 have to do with technical specifications or inservice 3 inspection, and I don't see any of them that are IST or .
4 graded QA.
What does that tell us?
- 5 COMMISSIONER McGAFFIGAN:
6 MR. HOLAHAN: It tells us that licensing review --
7 I don't think it tells us that the industry's not interested 8 in risk-informing those topics. I think it's telling us 9 that the industry is not pleased with the approach and the 10 amount of effort it's taken to get those first two done. I 11 think the industry is searching for other alternatives, 12 either through the, you know, consensus code or through an 13 interpretation of the existing regulations and through 14 50.54 (a) , which will give them a little bit, you know, 15 increase the ability to make changes in their own processes 16 without review and approval.
17 So I'm not anticipating a flood of graded QA or 18 IST reviews. That doesn't mean that there won't be risk 19 information used in the process, and perhaps the staff needs 20 to be in a position of inspecting those activities when they 21 are implemented in the field. But I don't see them as 22 licensing reviews.
23 COMMISSIONER McGAFFIGAN: I'd be interested at 24 some point in you all discussing that in public with the 25 industry and sort of asking them if they're not going to -
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l i
l 49 1 follow up on those activities, and we yet nevertheless want 2 to risk-inform those areas, how are we going to get there.
3 CHAIRMAN JACKSON: Yes.
- 4. MR. HOLAHAN: Yes, if you remember, we -- at least a 5 in the graded QA area we anticipated that most licensees 6 would not be looking for license amendments, and that's why 7 there's no standard review plan for graded QA. We chose to 8 develop an inspection document, because I think that's were 9 most of the activity will be. It's a little bit of a 10 surprise to see that perhaps there won't be many license 11 amendments for inservice testing, but we'll see.
12 I guess the -- I'd like to make two more points, 13 if I could, and that is I already mentioned that we are 14 close to issuing the Arkansas hydrogen monitoring order.
15 We've also made a decision that other licensees who are ;
16 interested in a similar change would be issued relief from 17 the TMI order, and we're putting in place a mechanism for 18 doing that quickly. So we're trying to convert what was a i
19 one-plant issue into a generic resolution of an issue.
20 And lastly I'd just remind the Commission that 21 we've taken wha': I think was an important step in the AP600 22 review. There was considerable use of risk information, 23 especially in the area of treatment of regulatory treatment 24 of nonsafety systems, which I think was a ontroversial l + 25 subject matter, and a recent ACRS letter to the Commission I l
l l
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T 50 1- think was very. favorably -- was very favorable in that it 2 identified this as a good use of a risk-informed process.
3 And I think, even though we're not following up with another .
4 review, I think we've laid a foundation here where risk 5 information can be used to treat other difficult cases. *
'6 And-I'd like to turn it over to Mark if there are 7' no other questions.
.8 MR. CUNNINGHAM: Slide 10, please.
9' The next three slides cover how Research supports 10 the response to the three challenges that Ashok laid out 11 earlier on providing regulatory framework and providing 12 . adequate resources and providing clear guidance.
13 Slide'10 talks about our support in the area of
. 14 improving the regulatory framework. The first two bullets 15 indicate.that we're supporting NRR in a number-of changes l
16 that they're undertaking which were described in your 17 tasking memo, Chair Jackson, and Mr. Callan's response. In i
18 the areas of inspection and enforcement assessment, 50.59, 1.
l - 19 and a paper that's coming up on longer-term changes or more
' 20 . broad changes to Part 50, in a very general sense what 21~ Research is providing-there is a couple of things. One is
~ 22 trying to do some conceptual-level thinking of how best to
' 23 bring together risk.information into these different 24 activities, and then providing to the extent that we can L
25 practical. examples of how to apply risk information in these -
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i l 51 1 areas. I i
2 Other things we're doing, as we've indicated !
l' 3 earlier, Mr. Thadani is chairing the PRA steering committee.
4 We are providing the point-of-contact support with the
. 5 Center for Strategic and International Studies. Chairman 6 Jackson and Commissioner McGaffigan are -- obviously you are 7 on the steering committee. Mr. Thadani is the contact on 8 the working group, which I believe is meeting next week to 9 start to decide how best to pursue that work. And the 10 steering committee is meeting later this month.
11 Research has the lead on the interactions with NEI 12 on the whole plant study. This has been talked aDout a good 13 bit earlier in the presentation, so I wouldn't presume to go 14 back into that in much detail.
15 The last point is we have an item to evaluate the 16 effectiveness of certain rules and unresolved safety issues.
17 Specifically in the next six months or so we're supposed to 18 look at the station blackout and ATWS rules and look at 19 unresolved safety issue A45. What we'll be doing there is 20 trying to assess what the costs of actual implementation of 21 those rules in A45 were versus how much gain we had in risk. I 22 We'll be using the IPE results as -- the ensemble of IPE 23 results to look at the benefit that we've achieved, in 24 particular using the information we compiled in NUREG-1560, 25 which is perspectives on the IPEs again to get a measure of l
l i
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52 ;
I how much gain we've had,'for example, in core damage 2 frequency'as a result of the station blackout,-that sort of l 3' . thing. There is some limited information in the IPEs that -
4 .
gives-us some ideas about them.
51 COMMISSIONER McGAFFIGAN: Could I ask a question? -
l 6 MR. CUNNINGHAM: Yes. ,
7_ COMMISSIONER McGAFFIGAN: One licensee, and I 8 forget which one it was, had a nice color viewgraph when he ;
I 9 came in to see me, and it showed their core damage frequency i
10 moving downward in the right direction as a result of !
l 11 various rule changes. And in their particular case station ;
i 12 blackout, for example, had made a big contribution. In ;
13- their particular case Three Mile Island action plan items l 14 had made a minuscule change.
15 I thought.that that -- it sounds like what you're ;
i 16 trying to do now'is more generalized. If you could 17 generalize that for the industry, it would sure give us f f
18 hints as to where we should back off and where we shouldn't, 19 station blackout being a classic case of where we shouldn't, 20- but can you get help from licensees, you know, and just put 21 out a -- on a voluntary basis, because OMB would probably j
-22 kill us'if we demanded it, but just ask everyone to give us >
23 that sort of chart, their best judgment as to what the j 24 effect of our rules have been in marching them down in core l
25 damage frequency? -
E I
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5
53 1 MR. THADANI: I think if I may during the 2 discussion of research we talked about the importance of 3 changing our prioritization scheme to bring in burden i
. I 4 reduction as an important element in that. And we do have 1
. 5 initiatives as part.of our efforts to meet with the industry !
l 6 and try to get that kind of information as part of trying to 1 I
7 make sure that if they are targets of opportunity, and I'll l
8 for the moment focus on rules that are really not leading to 9 much safety benefit and are yet pretty expensive.
10 CHAIRMAN JACKSON: Or ones that are.
11 MR. THADANI: Or ones that are. Exactly. I 12 agree. I think you touched on station blackout as being 13 clearly a very important one. Our objective with this ;
14 effort under regulatory excellence is to look at both ends. I 15 I'm not suggesting only looking at one end. But that we are 16 looking at both ends. And yesterday as a matter of fact 17 there was a workshop in Chicago. There were three parts to 18 that workshop. One part, and I think, Ernie, you were at 19 the workshop.
20 MR. ROSSI: Yes, I was at the workshop.
21 MR. TRADANI: And one of the issues at the 22 workshop was to try to get some information from the 23 industry are there those targets.
24 CHAIRMAN JACKSON: Well, aren't there three i
25 overarching sort-of outcomes in terms of the risk-informed Alm RILEY & ASSOCIATES, LTD.
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54 1 thinking? ,
2 MR. - HOLAHAth Yes. ;
- 3 CHAIRMAN JACKSON: What is it, better safety
, t 4 decision making, burden reduction, and what was the third?
- 5. MR. HOLAHAN: More efficient staff use. -
]
6 CHAIRMAN JACKSON: And that coupled with something 7 I had asked for in terms of looking at the do our rules i
8 achieve their-desired outcomes.
9 MR. HOLAHAN: Right. .
10 CHAIRMAN JACKSON: I mean, I think that 11 addresses -- and the point is -- but the pregnant question i
12 is how on a systematic basis do we actually get that input. ,
13 MR. THADANI: Yes.
[
t 14 CHAIRMAN JACKSON: To understand whether either >
-15 .our initiatives a la the PRA implementation plan or certain L 16 again.high-hat rules at least' achieve their intended 17 outcomes. But what'I'm hearing is certain specific things 18 in specific areas, but'I think where there's an opportunity [
19 is in addition to what you're talking about to try to !
t 20 systematize how to get information. [
21' MR. THADANI: We in fact owe the Commission that.
22 It's what we had called strategy 5. And that is exactly 23 what the intent of that strategy was. And I don't remember 24- the schedule right now --
25' CHAIRMAN JACKSON: I was going to.
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55 I' 1 MR. THADANI: But we owe you a. paper which lays l i
.2: out the-process, and it's sometime later this year, I L;
L3 believe, but I will check-to be sure And that is an area f
where AEOD has the lead and with support from research.
~
4 And ?
. .5 one piece is -- all I describe .taa you is one piece, and that l l 6 was to get external input to that~ process.. And that was one 7 of the objectives of the workshop. !
8 And the rest of the process does exactly what you j 9- say. It is a systematic way of looking-at various sonrces
.10 .of-information to be able to pass judgment on which rules, ~
11 at least from experience and various studies, to see which ,
12 rules may, in~ fact,z be very, very important in terms of
- 13 safety and that it is a good thing we have certain 14 requirements out there. But it will also provide \
-15 information on which rules may not be so important, and it ;
16= is a systematic process. '
17 CRAIRMAN JACKSON: I think the appropriate 18 statement is, Do our rules accomplish their intended 19 purpose? And if the. intended purpose has to be risk 20 reduction,' safety, et cetera? And it seems to me that is 21 the way'you answer the question.
22 MR. THADANI: Yes. Okay.
23 CHAIRMAN JACKSON: And if they don't accomplish 24 their intended purpose, then you don't need them or they 25 need to be changed.
v .
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56 1 MR. THADANI: Yes.
2 CHAIRMAN JACKSON: Okay. But if they do, and you 3 are marching down the core damage frequency curve, along the 4 lines that Commissioner McGaffigan spoke, then that also --
5 I mean that says something about is the rule achieving its -
6 intended outcome.
7 MR. THADANI: Yes.
8 CHAIRMAN JACKSON: But you need to systematize.
9 MR. THADANI: And those are the metrics and the 10 strategy 5, incidentally. Yes, indeed.
11 MR. CUNNINGHAM: There are examples in the 12 utilities where they have that type of information and they 13 share it with us. Many cases, it is harder to get that 14 information. We asked, I think, as part of the review of 15 the draft NUREG-1560, if people wanted to give us 16 information on how much core damage frequency reduction we 17 got out of -- they received out of the station blackout 18 rule, and we have got some information. There is more 19 information on that than probably the ATWS and any of these 20 others.
21 CHAIRMAN JACKSON: You know, in the response to 22 the tasking memo, you talked about having a team approach to 23 improvements and activities in this area. So as you go 24 through these bullets on slide 10, you know, how much of 25 these are being done as research only activities, and how
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57 1 many of them are as part of actual teams? And then, the 2 second part of the question, and I always have multi-part 9
3 questions, as far as your involvement in supporting changes 4 to inspection, enforcement, and assessment, and 50.59, does j l
. 5 your team include recent field experience, such as the i 6 senior reactor analysts from a region or regions?
7 MR. THADANI: Let me touch on that, and, Mark, 8 please provide more information, as appropriate. First of 9 all, it was critical that the team include field experience. l 10 And we have two staffers who have rotated from AEOD who have I 11 had extensive field experience and have been working with us )
12 on these programs. In addition to this support, these 13 activities are closely linked with the efforts that NRR has 14 ongoing in this, and that they fit into the overall planning ;
15 and schedule of when we want to get to final --
- 16 CHAIRMAN JACKSON: Why are you all not part of one 17 team?
18 MR. TRADANI: We are. We are.
19 CHAIRMAN JACKSON: No, you are saying linked to 1
20 what NRR is --
21 MR. THADANI: No, no, no. We are part of the
! 22 team. In fact, the workshops that you heard about, Gary 23 mentioned earlier, it is the whole group, it is not just l 24 NRI, it is not just Research, it is not just AEOD. It is
. 25 the whole group. The workshop will have focus, so within ANN RILEY & ASSOCIATES, LTD.
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50 1 the --
2- CHAIRMAN JACKSON: I mean one team, led by one 3 person that has representation from everybody. .
4- MR. THADANI: Right. Team led leadership 5 responsibility.
6 CHAIRMAN JACKSON: Okay.
7 MR. THALANI: The ownership of tasks.
8 CHAIRMAN JACKSON: And does.it include senior
- 9. reactor analysts? You kind of skirted my question.
10 MR. 7EADANI: I think it does. I think it does.
11 MR. HOLAHAN: One of the senior reactor analysts 12 is on my staff. The headquarters has two senior reactor 13 analysts. The one on my staff --
14 CHAIRMAN JACKSON: But no one from the field? No 15 one from the Region?
16L MR. HOLAHAN: I believe the mechanism that they 17- are using, and I could be corrected, the senior reactor 18 analyst who works for me, who, in fact, he works in 19 headquarters, but has.18 years of field experience, is on t-20 the team.
21 CHAIRMAN JACKSON: When was he last in the field?
22 MR. HOLAHAN: I believe he is in the field today.
23L CHAIRMAN JACKSON: No, but when was he last in the 24 field on a regular basis?
25- MR. HOLAHAN: All of the last year he was
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59 1 providing the support the maintenance team inspections. He 2 is routinely involved in inspection activities. He is also 3 --
4 CHAIRMAN JACKSON: I mean I have cautioned you
. 5 many times about creating activities that relate to 6 activities that have to be implemented, or at least l
7 partially implemented in the field, made up of teams that i l
8 only have headquarters people. Okay. And so I am going to I i
9 reiterate that. Okay.
10 MR. HOLAHAN: I might add --
11 CHAIRMAN JACKSON: And in this area, it is very 12 important that you take heed of that. And so I will monitor l 13 that, because I don't see how you are going to get there if 14 you don't involve the people whose job it is, and have an !
\
15 impact there, if you don't involve the people whose job it '
16 is to implement these things.
17 Yes, sir.
18 MR. CUNNINGHAM: I was going to say, starting next 19 week we have two SRAs in training coming in on assignment to 20 Research for four months, three months. And their jobs, 21 they are going to have three jobs, and two of those jobs are 22 going to be supporting the 50.59 and the inspection process 23 that we are talking about here, making them more 24 risk-informed. So we have got two SRAs who are, in effect, 25 still in the field, they are still in training, but they are L
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. . ._ , . _ _. _ _ _ = _ _ _ . . _ _ . . _ . . _ . . _ . _ _ _ _ _ _ _ _
i 60 !
1 going to be helping.us. .
2 CHAIRMAN JACKSON: Where are they coming from?
3 MR. CUNNINGHAM: They are coming from Region 3. l 4 MR. HOLAHAN: Region 3.
- 5. CHAIRMAN JACKSON: Okay. All right. -
l 6' MR. CUNNINGHAM: I believe that the team also has !
7 more direct involvement from the regions, I am just not 8 exactly sure what it is.
9 CHAIRMAN JACKSON: Yes.
10 COMMISSIONER McGAFFIGAN: On slide 10, before you i 11 leave, the only point I would make is if, on Research's lead 12 'with regard to interacting with the NEI and the whole plant ,
-13 study, you may need to reevaluate that if you go down this !
14- route of 51 exemptions, three plants, 51 rule changes. !
P 15 That's a whole lot. l 16- MR. THADANI: Yes. The thing has. changed 17 significantly and we need to take a lot. ..
?
18 CHAIRMAN JACKSON: Okay. I i
19 COMMISSIONER McGAFFIGAN: Okay. l
- 20. MR. CUNNINGHAM: Slide 11, please. In terms of r
21 resources and resource allocations, one of the things we are 22 going to be doing is trying to prioritize the research ,
23- program to make it more risk-informed. That is, we are i
24 going to develop a general process for including risk 25 ' information more directly into the research planning process ' i ANN RILEY & ASSOCIATES, LTD. ,
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- 1 and to look at this issue of how research could support 2- burden reduction activities. Risk is one of the measures 31 that would be used'in this, if you will, a value impact 4 analysis of_ risk -- of research programs or some such thing.
.- 5 CHAIRMAN JACKSON: Let me ask a question, though.
6- ~ You know, over.50 percent of your budget is expended on 7 responding to user needs identified by other offices.
8' MR. CUNNINGHAM: Yes.
'9 CHAIRMAN JACKSON: And so the question I have is, 10 have the individual offices themselves used risk-informed 11- principles to prioritze their user need requests? Or is it
- 12. a question of the Office of Recearch, once things have come 13 in, doing its own prioritization? So there are two levels 14 at which the risk-informed prioritization can occur. And so 15 can you give me some insight on that?
- 16. MR. CUNNINGHAM: I suspect what will happen is, as 17 we systematize this process and make it more explicit, then 18 the user offices will see that and be involved in, will be 19 thinking about it before they come to the Office of 20 Research. So I think it will work its way back into the 21 system once we lay it out a little more clearly.
l 22 MR. HOLAHAN: Historically, NRR has not used a 23 formal risk assessment process in prioritizing requests to 24- Research. Obviously, there is some element of risk thinking
. 25 that goes into all of your requests, but it hasn't been l
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' 1' formalized in the past.
2 CHAIRMAN JACKSON: Well, I think there has to be a 3 little more-thinking of this because you can do the lec me .
~
4 throw it over the-fence process, and then whoever is on the 5- other side of the fence can do his own ranking. But then .
you may come back'when the Commission asks, well, why
~
6 7 haven't you done such and such? And you will say, well, it 8 was Research's fault, because, you know, they decided what
!r the priority was. But we can't afford to play that game, 10- and so there has to be -- you know, Research needs to know 11- what-the offices feel based on a prioritization scheme is 12 really important. And then Research itself has to then try 13 to sort through that and decide how it is going to rank the 14 work to get it done.
15 MR. THADANI: Yes.
16 CHAIRMAN JACKSON: Right.
17- MR. CUNNINGHAM: With respect to the IPE and the 18 IPEEE programs, basically, for all intents and purposes, we 19 are done with the IPE reviews. We have one last set of 20 issues,1small set of issues associated with the IPE for
~21 Browns Ferry 3. Other than that, which we expect to get 22 resolved in the next month or two, we are essentially done 23 with those.
24 A lot of the understanding of what came out of the 25 IPE program has been embodied now in NUREG-1560, which I .
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63 l
1 have talked about a couple of times before. What we have 2 been doing now is reassigning resources from that into other 3 activities in the office, including the IPEEE reviews. We 4 are -- further, we are not nearly as far along on the
. 5 IPEEEs. We have completed about eight or so SERs. We have 6 all of the preliminary reviews completed on all the IPEEEs 1
7 we have received to date. We have got about, I believe five I 8 to ten more than we haven't received as yet. And so the 1
9 resources from IPE reviews have gone into the IPEEE reviews, 10 as well as into these issues of developing PRA standards and 11 the 50.59 process we are talking about now, and that sort of 12 thing.
13 A last element is the development of what we call 14 SPAR models, which also are called ASP models. The SPAR 15 mod'ls, e simplified plan analysis risk models, are intended 16 to'be the models that are used in precursor analyses in the 17 agency, mostly by AEOD and NRR. We have -- what we have 18 done over the last few years is developed a set of 19 improvements to the models that make them much more, at 20 least site-specific, if not plant-specific.
21 We have a set of 74 models now that are consistent 22 in nomenclature and level of detail, and that sort of thing, 23 which are these -- they will be called the preliminary level 24 one models. They include full power. What we can do now is
- 25 analyze events that occur during full power operation and l-I l
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-1 ~ internal -- from-internal initiators, traditional internal
~
2 initiators. We have underway --
3 COMMISSIONER DIAZ: I am sorry. The SPAR and the l 4- ASP are the same or.~they are closely related? l l
5- MR. CUNNINGHAM: The SPAR models are the tools - !
l 6 that-are used-in the precursor analyses. We get that all 7 mixed up ourselves all the time.
8 COMMISSIONER DIAZ: All right.
9- MR. CUNNINGHAM: We have underway --
10 MR. ROSSI: Let me say one-thing about those 11: models. 'Daat is an example where NRR and AEOD worked 12 together to develop a user's need.for research and then had 13 . interaction to make it very clear to Research what our l
- . 14 office priorities were, which replies'to one of your earlier L 15 questions. But that is an example where that was done and j
~61 ' appeared to work quite well.
i 17 CHAIRMAN JACKSON: Good. ;
18 MR. CUNNINGHAM: That's correct. And that user 19 need really drove the other points here in terms of our 20 priorities within the office and within the branch. We have
- 21 ' developed what we call the -- we have initiated development 22 of the Rev. 3.models which are going to be a bit more
-23 comprehensive in terms of how the support systems in the !
24 plants are modeled and some other initiating events. We are 25.
just -- we will finish up in fiscal '99 some models for
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65 1 treating the level two or the consequence part of risk 2 calculations, or the ASP calculations.
3 We wanted to have, in addition to having the 4 traditional metric of core damage frequency, or conditional
< 5 core damage probability coming out of the ASP analyses, we 6 also wanted to have something in there that was a measure of 7 consequences. Because the consequences of core damage 8 accidents can range considerably. So you wanted to have 9 some additional measure there to see that implication or see i 10 that effect. I 11 Finally, we have completed some feasibility .
l 12 studies on extending these models into the area of handling 13 external event initiators such as fires and seismic, and 14 looking at trying to model events that occur during low 15 power shutdown conditions. We are planning in '99 to start 16 more model development to extend the models in those areas.
17 Slide 12 in terms of guidance, Research was 18 responsible for the development of the regulatory guides 19 that have been issued over the last well couple of months 20 here analogous to what Gary was talking about earlier on the 21 SRPs. Reg Guide 1.174 and SRP chapter 19 have been 22 published. The notice was put in the Federal Register on 23 August 20. The others will be published later on this month 24 with a notice of availability.
25 Reg Guide 1.178 on ISI has been issued for trial l
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66 1 use. Research has the lead for the support to ASME on the 2 development of PRA standards. We've talked about that 3 before, so perhaps we could just gloss over it to some 4 degree. But's it's again -- there's two main things right 5 now. There's a large effort under way to develop standards >
6 for level 1, 2, full power, internal event initiators except 7 for fire, That's what was alluded to earlier as incoming.
8 We have a draft of that -- we received a draft of that on 9 August 19. We're just now starting the process to define 10 how to work with ASME and to define how we want to go on to 11 the other initiators and the other parts of the risk 12 analysis.
13 We have the responsibility in Research to lead the 14 modifications, proposed modifications to the safety goal 15 policy statement. There were a couple of Commission papers 16 over the last six months recommending that we consider this 17 further. This is one issue that was actually slipped a bit 18 in response to the Chairman's tasking memo. So we're I 19 believe going to have an update or a status report on this 20 in March of '99 instead of December of '98, and then a full 21 paper with recommendations in July I believe of next year.
22 And finally we provide research and methods 23 development in PRA to fill what we consider gaps or weak 24 spots in our ability to use PRA in risk-informed regulation.
25 I've listed a number of them here. I should say essentially -
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67 1 all of these items are items that are of considerable 2 international interest. We lead an international -- what we 3 call-the International Cooperative PRA research program, 4 CPRA. We have representatives from about 17 or 18 different a 5 countries on that. And when we sit down with the people, 6 we've had two meetings of the steering committee on this, 7 and we sit down and say what should we be focusing on in 8 terms of PRA research. There's a strong pattern that 9 emerges on human reliability, fire, shutdown, digital 10 systems. Across the world, people who are in the PRA 11 research business are concerned about those issues. So to 12 some degree what we're doing here is reflective of what's 13 going on throughout the world.
14 COMMISSIONER DIAZ: We have not been able to even 15 tackle the containment as an issue that, you know, should be 16 there to mitigate the consequence of an accident in PRA 17 space in any manner that, you know, solves anything? I 18 mean, is that --
19 MR. CUNNINGHAM: No. I --
20 COMMISSIONER DIAZ: Well, I know that you have, 21 and I think that I can see it as a priority.
22 MR. CUNNINGHAM: I think that's because we have --
23 well, there's two things. One is I think we have from a PRA 24 perspective a better level of comfort, if you will, in our
- 25 ability to model the level 2 portions of PRA. The key l
l i
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68 1 issues are phenomenological issues, and those are covered 2 not so much in CPRA but in the CSAR program that also comes 3 out of the research program, a different part of the 4 research, the Office of Research. And that's the group 5 that's dealing with the nasty issues such as lower melt 6 progression in the lower part of the reactor vessel and that 7 sort of thing.
8 So we can -- we feel fairly comfortable that given 9 that they can resolve the issue reasonably well 10 phenomenologically that we can handle it in PRA.
11 MR. THADANI: I think that's the distinction Mark 12 is reflecting more of trying to develop probabilistic 13 estimates, and not phenomena challenges, loads, and so on, 14 where you're quite correct, but that should be on the list, 15 but not necessarily from the point of view of numerical 16 analysis. But -- and again, that's an area where the 17 international community has very extensive programs, ongoing 18 programs.
19 CHAIRMAN JACKSON: This may be more a question for 20 Mr. Thadani than Mr. Cunningham. You know, for years the 21 Office of Research has had ongoing programs to evaluate the 22 effects of plant aging, you know, not necessarily 23 specifically within the PRA context, but more broadly.
24 How useful or to what extent was this information 25 being used to support the license renewal process? -
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69 .
.1- MR. THADANI: We'll give you a more complete 2 . answer,-but'I'll give you my understanding Office of 3' Research has prepared a number of reports looking at a i 4 unumber of reports looking at experience. The one that comes 4 5' to my mind right away is on instrumentation, for example. [
6 Imd those reports have , led -- were ' directly into the license :
7 renewal activities.
- 8' The area where research has not really looked hard ' t i
9 has been-more in the context of are there degradations as a
- 10. function of time, and if there are, how would they impact 11 . things like risk analyses.and so on. Lots of components are i
12 replaced, so the real focus has to be on the long-lived 13 components, passive long-lived components, not replaced in 14 particular.
i 15 I think we -- and I think Mark touched on this --
l 16 that we're just beginning to look at that aspect in terms of l 17' risk implications. But for license renewal, the aging
-18 program has.provided very useful informati,n. The one I 19- remember clearly is instrumentation where that was done by i
20 the Office of Research. I believe there are others that we l- 21 can provide you some additional information on.
22; There are ongoing programs in aging research which 23 don't.necessarily relate to the license-renewal decision per
'24' se, but they relate to aging issues, for example, cables and 25 the performance of cables. So there is ongoing research i
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70 1 work in the area of aging, but not necessarily focused on 2 license renewal. It could be 30 years, 40 years, 50 years, 3 60 years, what are the effects.
4 CHAIRMAN JACKSON: Okay, so there's been -- the 5 real answer is that except in the specified area there's -
6 really not been any direct coupling of the aging research 7 of -- that you've been doing to the aging phenomena and 8 concerns vis-a-vis license renewal.
9 MR. THADANI: Yes. The coupling made was to make 10 sure we identify what the concerns were under license 11 renewal, that we get the responses done by a schedule that 12 NRR is working on. That's the coupling.
13 CHAIRMAN JACKSON: Okay.
14 MR. CUNNINGHAM: So if there are no other 15 questions on the research program, I'll turn to Charles 16 Rossi.
17 MR. ROSSI: The next three viewgraphs summarize 18 recent and ongoing AEOD activities related to PRA, and I'd 19 like to have slide 13 first.
20 In the area of risk-based analysis of reactor 21 operating experience, this slide lists the recent key 22 products completed by AEOD, and these include issuance of an 23 advance notice of proposed rulemaking on July 23 of this 24 year to modify the reactor reporting requirements in 10 CFR 25 50.72 and 50.73 to make them more risk-informed.
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71 1 CHAIRMAN JACKSON: How do you think that ANPR is 2 going lto affect the number of licensee event reports?
3 MR ROSSI: Well, it will drop them -- I don't i-.
4 'know an exact number. I think we have estimated.that. But
- . 5 it will drcp them rather than increase them. -It will 6 increase them in'some areas,.but it will drop the ones that
- 7. we feel are reports on non-risk-significant items.
8 And these--- one area that.we're dropping reports
'9: on is on missed surveillance tests where when they actually 10 perform the surveillance they. find that the' equipment 11 operates in the way it was supposed to.. Those will be 12 dropped. And there are some other areas where they're 13 dropped. That rulemaking effort will also increase the 14 times allowed licensees to make the initial reports.
15 CHAIRMAN JACKSON: In a risk-informed way.
16 MR. ROSSI: On a risk-informed basis; right.
l 17 CHAIRMAN JACKSON: Okay.
18 MR. ROSSI: We have issued a final report en the 19 reliability of auxiliary feedwater systems based on 20 operating experience between 1987 and 1995. We have 21 completed the preliminary analyses of 1997 accident sequence j_ 22 precursor events. There were six such events in 1997, and 23 for comparison there.were 14 ASP events in 1996 and 10 in 24 1995.
. - 25 We have completed the development of the f
i 2
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f-72 1- specification for the system that we intend to use for 2- industry-supplied reliability and availability data to j 3 . combine that data along with other operational data to r
4~ compute. estimates of component reliabilities. And we have 5 issued a CD-ROM containing the common-cause failure data 6 L
l 6 base that's been developed from operating experience to the 7 utilities for their use in PRA analyses.
8 CHAIRMAN JACKSON: Earlier there had been an issue 9 having to do with the length of time it took to do an ASP t
l 10 analysis of an operating event in the sense of having that 11 done in a way that would inform other processes such as 12 enforcement assessment or even inspection. And has that 13 time interval for doing ASP been shortened, and what impact, 14 you know, are the SPAR models or do we anticipate these SPAR 15 models having on that? Because, you know --
16 MR. ROSSI: Well, we have done some things to
( 17 decrease that time. One of the' things that we've done is i
18 that as we complete each ASP event analysis we deal with
- 19 that individually, send it to the licensee for their
- 2 0 - ' comments, and then we, as soon as we get their comments and 21 evaluate'them, we put it into the PDR and make it available.
22 CHAIRMAN JACKSON: You're wearing out our lawyers.
- 23 It's time to end this meeting.
,24 MR. ROSSI: That's a difficult thing to do.
- 25. [ Laughter.) -
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73 !
1 So we have done that, and I believe the new models 2 will further help us in doing that.
l 3 MR. CUNNINGHAM: Yes. There's a couple of parts ;
4 to the new models again that will be much more systematic in 'i
& 5 the sense of -- and consistent between plants so that it'll 1 6 be easier to apply the models. In parallel with the 7 development of the models we're developing software known as 8 the GEM software which allows -- it's supposed to be kind of {
9 a very user-friendly way of being able to access the models 10 and make changes in responses to the particulars of the 11 event and calculate a CCDP very quickly. So I think both l 12 will help.
13 MR. ROSSI: One of the things that we do do in 14 the --
15 CHAIRMAN JACKSON: So you'll be able to carry it 16 around and do it on a laptop.
17 MR. CUNNINGHAM: A laptop with NT, with the j 18 Windows NT; yes. You should be able to do it. l 19 CHAIRMAN JACKSON: Okay. I mean, because that's 20 important. This has been a lingering issue in terms of the 21 timeliness of these ASP -- okay.
22 MR. ROSSI: Other ongoing efforts are shown on 23 slide number 14. We have issued the contract for the 24 reliability and availability data system, and we're also I -
25 resolving peer-review comments on draft reports for the ANN RILEY & ASSOCIATES, LTD.
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74 1 three studies that are shown in the viewgraph. We also plan 1 2 to issue the contract to develop risk-based performance 3 indicators this November. .
4 Now I would like to make the point that the 5 risk-based analysis of operating experience in AEOD, we have .
6 an integrated plan for this, and we've had that for several 7 years, and that integrated plan includes system reliability 8 studies, initiating-event studies, the common-cause failure 9 data information, and the accident-sequence precursor 10 analyses, among other things, and each individual product 11 provides informatien based on operating experience that we 12 believe can be used in other agency risk-informed activities 13 such as in the inspection program.
14 And of course as you know we're going to over the 15 next couple of years combine all of this information into 16 risk-based performance indicators, and we'll be working with 17 the industry in parallel with what we're doing to come to an 18 agreement in the plant performance assessment process on .
19 performance indicators that should be used. So it is that 20 integrated program.
21 Yes?
22 COMMISSIONER McGAFFIGAN: Before he leaves this 23 slide, I'd -- the NUREG/CR-5499 on rates of initiating 24 events, the press reports on that, I haven't seen the draft, 25 I'm sure I could have if I'd asked for it, but the press -
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l 1 reports on it basically said that initiating events are 2 occurring much less frequently than was assumed in many of 3 the ' IPEs '. Therefore, core damage frequencies are going to 4 get a one-time boost in the right direction. They're going
!i 5' to go downward.
6 MR. ROSSI: That is indeed. correct. That is what 7 we saw, and the draft report's been sent out widely to get 8- comments on it to make sure that --
9 COMMISSIONER McGAFFIGAN: How big an effect is 10 this goingito have on a typical IPE?
11 MR. ROSSI: I don't --
l l 12 COMMISSIONER McGAFFIGAN: I think -- my 13 recollection is they're about a factor of 3 reduction, with l 14 the exceptions of fire and service water initiating events, 15 I believe. l 1
- 16 MR. THADANI
- Right. Right. And I would -- I'd l I . I 17 note that.there are some AEOD studies, I believe it was,.for "
l 18 example, on the -- I believe it was high-pressure injection I E19 system - there's some cases where the calculated l .
i L 20- availability in the IPEs versus experience may be ;
21 optimistic. So there may be some -- I think the AEOD ;
! 22 reports are. showing areas of perhaps conservatisms in the 23 analyses as well ac some areas where there may be, you know, i
L 24 some optimistic assumptions as well.
. ' 25 This is very important information for various i
1
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76 1 reasons. As we move towards risk-informed, we want to make 2 sure we're using the best available information. We're 3 looking at reassessment of some of the rules and their 4 effectiveness. We need to use the best available 5 information. -
6 We're going to use AEOD reports as part of that, 7 and I want to just personally commend AEOD for I think an 8 outstanding study of aux feed systems, and many other 9 reports, but aux feed was in my mind an extremely good 10 study, provides very useful information, not only in 11 reassessing rules and regulations, but also in terms of 12 areas that are more important from an inspection point of 13 view and areas that are not so important.
14 We have a tendency, and I'm one of those too, 15 sometimes we say well aux feed system is very important.
16 Well, that's too general a statement. They are parts of 17 auxiliary feedwater system which are truly very important.
18 There are parts that are not so important in terms of their 19 contribution to system unavailability.
20 Now I think the AEOD report has really provided 21 some very, very good operational information. We're going 22 to use it.
23 COMMISSIONER McGAFFIGAN: I think that's the 24 important thing, is to get this information --
25 CHAIRMAN JACKSON: Yes. -
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l 77
! l' COMMISSIONER McGAFFIGAN: Wherever the chips fall, 2 :and apparently they're falling mostly on the side of 3 'overconservatism, but if.they fall the other way, as the l .
l 4 Chairman has said frequently, then we have to deal with'that 4 5 too and impose additional requirements. But getting this
-6 information that's' coming out of these AEOD studies,.which I 7 'also commend AEOD for, is very important. And they 8 shouldn't be_ sitting on the shelf,.they should get into the 9- NRR rulemaking and other people's programs.
10 MR. ROSSI: We are working very' closely with NRR 11 on the inspection program to suggest ways they can'be used 12 to make the inspection program more risk-informed. That 13- auxiliary feedwater study is one of the ones that's listed 14 on slide 13, and that's one of the ones that has been 15 finalized, and we did send a letter or a memo over to NRR ,
16 summarizing the results and how it might be used.
17 CHAIRMAN JACKSON: Actually,-following along v x.
l 18 line, I am' going to ask you a question about NUREG-5496. !
19 Your report, or at least your status report indicates that !
- 20 l'oss of off-site power frequency due to plant-centered 1 21 events is'a factor of four higher than non-power modes of 22 operation than during -- at power. Is this statistically 23' risk significant, and is it mainly due to maintenance 24 -activities? -
. 25 MR. ROSSI: Well, my recollection of that is that i i
- l'
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78 1 the shutdown ones, what you said about that was correct, but 2 they tend to be, as I recall, corrected more quickly. And, 3 you know, I think we sent that information on to the other .
4 offices to make further judgments on it.
5 The other thing that that study did show was that <
6 the contribution of grid-induced losses of off-site power 7 were very small.
8 CHAIRMAN JACKSON: Exactly. Small. That is what 9 struck my attention.
10 MR. ROSSI: Compared to the loss of off-site 11 power.
12 CHAIRMAN JACKSON: So it was more plant-centered 13 than --
14 MR. ROSSI: More. Right. And it had a lot of 15 information on durations of weather-related ones and that 16 kind of thing.
17 MR. THADANI: And, again, this is another report 18 that is very useful in reassessment of station blackouts.
19 And we will be using it as part of that reassessment, along 20 with the auxiliary feedwater system that we talked about.
21 CHAIRMAN JACKSON: Will this data then affect our 22 implementation guidance under the current proposed revision 23 to the maintenance rule having to do with looking at 24 performing safety assessments at all times, including during 25 shutdown operation? -
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l 79 1 MR. THADANI: There is an ongoing expectation that l 2 the licensees are supposed to do that. What the experience 3 and what the impact is, safety impact, and, as you know, i
! 4 1 there are Parts A2 and Al of a maintenance rule which hike l 3 5 up the relative importance. Therefore, management will pay l 6 more attention to certain areas. If that happens for a ;
7 specific plant, that is what one would expect they would be 1
8 doing.
1 1
9 CHAIRMAN JACKSON: And, also, I notice, before you 10 go into the next slide, this last-bullet about issuing a 11 contract for risk-based performance indicator development in 12 November of this year. And the question I have is, how does !
1 13 this play into the ongoing process having to do with plant 14 assessment, where there is, you know, at least ala the NEI I 15 proposal, is to have a heavy reliance on performance
- 16. indicators?
17 MR. ROSSI: That's -- our schedule is fully 18 integrated with the agency's schedule, and we are 19 participating with NRR on the plant performance assessment 20 process. And the intent is for us to have continual 21 interactions with NEI along the way, so that they know what 22 we are doing and we know what they are doing and that, as we 23 progress, we will be able to use results up to a certain 24 date in the process at that time. And then as we fully
. 25 develop our risk-based performance indicators, we intend to l-i 4
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80 1 come to closure with the industry on an agreement of 2 indicators that we can all come to agreement on.
l 3 CHAIRMAN JACKSON: So the implication is that you 4 would expect to have these indicators developed by a 5 contractor on a time frame where they would actually be used .
6 as part of --
7 MR. ROSSI: Yes. Now, that time frame, that 8 schedule is, I believe, 2000 -- January 2001 for full 9 implemer: tation, if you just go with our risk-based 10 performance indicators. But, as I indicated, we are having 11 the continual interactions with the industry along the way.
12 I will say something about the study. The 13 risk-based performance indicators require that the key risk 14 importance system reliability studies be done, the 15 initiating event studies be done. We have plans for a trial 16 use along the way that we are working with the industry 17 through the ongoing things on plant performance, and we will 18 use whatever we can get as we go along. That is our intent.
19 COMMISSIONER DIAZ: Just as a matter of, again, a 20 small mat.er of nomenclature and consistency. Do we want to 21 call this risk-based?
22 MR. ROSSI: Operating experience?
23 COMMISSIONER DIAZ: Yes.
24 MR. ROSSI: Well, the reason we call it risk-based 25 is that this is a case where we are truly using numbers. -
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81 1 COMMISSIONER DIAZ: I know. I know. But in the 2 overall scheme of things, we always try to reserve 3 risk-based to when the entire issue is really, in a 4 probabilistic sense, you know, completely risk-based. And i 5 so I was concerned that maybe, although you are right, that 6 in consistency space, we might be best served by calling it 7 risk-informed.
8 MR. ROSSI: Okay. Well, we will take another look 9 at that. What we have assumed today was that we are doing 10 numbers here that then are used, the numbers are used in the 11 risk-informed.
12 COMMISSIONER DIAZ: But our lawyers have warned us 13 that we cannot infringe into risk-based space and, 14 therefore, you know, I encourage you to look at it.
15 MR. ROSSI: We will take another look at it and 16 discuss it with the lawyers.
17 COMMISSIONER McGAFFIGAN: Just to probe on the 18 degree of integration, at this workshop that is going to be 19 held at the end of this month, the four-day workshop on 20 assessment, will you lay out at that meeting your plans for 21 what this contract is supposed to achieve and, you know --
22 MR. ROSSI: We will be fully involved in the 23 workshop and that is our plan. Yes, we will do that.
24 COMMISSIONER McGAFFIGAN: Okay.
. 25 MR. ROSSI: I am a little hesitant to say exactly l
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82 1 what we are going to do in terms of discussing our formal 2 plan, but we have discussed all of this with the industry
- 3 already. .
4 CHAIRMAN JACKSON: Nuclear power.
5 MR. ROSSI: And we are going to continue to do it, L 6 and we are -- beg your pardon?
7 CHAIRMAN JACKSON: The nuclear power industry. I 8 remind you Mike Weber is at the table.
9 MR. ROSSI: Okay. Now, let me go on quickly to 10 viewgraph 15. We have continued in AEOD to provide PRA 11 training for the staff. We expect that one inspector from 12 each site will have completed the PRA Technology and 13 Regulatory Perspectives course by the end of calendar year 14 1998. Sufficient courses have been given or planned to 15 allow 200 technical staff to attend the PRA Basics for 16 Regulatory Applications course in fiscal year '98, and 17 another 200 to attend in fiscal year '99. And our 18 expectations at this point in time is that we expect that 19 there will be about 180 agency-wide staff that will have 20 attended this course by the end of fiscal year '98.
21 CHAIRMAN JACKSON: Let me -- okay, go ahead.
22 COMMISSIONER DIAZ: I was going to say that, of 23 course, this is a very important operation, going and 24 hearing -- training the staff. But I wonder if somebody can 25 tell me approximately how many expert PRA practitioners do -
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i 83 1 we have in the NRC? I mean people that actually could go 2 and do a PRA.
- 3. CHAIRMAN JACKSON: That's a good question.
4, MR. ROSSI: You mean industry hands-on experience?
i 5 CHAIRMAN JACKSON: Or just doing training, to be 6 able to --
7- COMMISSIONER DIAZ: The capability of doing it?
l 8 MR. ROSSI: I don't know how many.
l 9: CHAIRMAN JACKSON: Can you do a PRA calculation?
{
l10 MR. THADANI: We have such a list. We have a such
- 11 a list of experts.
12 CHAIRMAN JACKSON: Are you on it? Are you on it?
! '13 MR. THADANI: I think I can do some.
14 CHAIRMAN JACKSON: Can you do it?
15 MR. CUNNINGHAM: I would have said I have been in 16 management too long to be a real hands-on practitioner.
l 17 CHAIRMAN JACKSON: Can you do a PRA calculation?
i 18 MR. CUNNINGHAM: I can do some PRA calculations, l
19 yes. '
-20 CHAIRMAN JACKSON: Hugh? I 21- MR. THOMPSON: I would be very' limited. l 22 CHAIRMAN JACKSON: I am-going to skip you, Gary, 23' because the answer had better be yes.
24: MR. CUNNINGHAM: My answer is.I did it once
-25 before, but Mr. Thadani criticized it rather harshly, so I i
).
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84 1- am not sure if I am qualified either.
2 CHAIRMAN JACKSON: Mr. Rossi.
3 MR. ROSSI: I would have limited capabilities with a
4 large uncertainties, I think.
5 CHAIRMAN JACKSON: Mr. Weber? ..
6 MR. WEBER: I have had the training. I could so
- 7. some crude calculations. Most of my experience has been in i
8 the materials area, specifically for performance assessment 9 for'high level waste, which is, as you are well aware, the 10 analog in the waste area.
'11 CHAIRMAN JACKSON: Okay. In the interest of full 12 disclosure, Mr. Gray?
13 MR. GRAY: .The lawyers could probably do it.
14 [ Laughter.] :
15 CHAIRMAN JACKSON: Mr. Hoyle?
16 MR. HOYLE: No, Chairman Jackson. And I have no 17 one on my staff that could.
18 CHAIRMAN JACKSON: Commissioner?-
19 COMMISSIONER DIAZ: I could do as well as Thadani.
20 .[ Laughter.]
21 . CHAIRMAN JACKSON: And Commissioner McGaffigan?
22 Do you want=my answer? Yes, I can do simple PRA I
23 calculations.
1 24 MR. HOLAHAN: Can I maybe fill in a little bit? I
. 25 would say there are probably two dozen staff members who -- -
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85 1 CHAIRMAN JACKSON: That's out of how many staff?
2 MR. HOLAHAN: -- who could routinely do j 3 development of logic models and actual PRA calculations. j 4 And over the last couple of years, we have actually hired a i 5 number of staff who I would say are real world class experts 6 who have participated in a dozen or two dozen actual PRAs on 7 the operating reactors.
8 COMMISSIONER DIAZ: And are those positions in the 9 Commission so the expertise can bear on the issues? Or they 10 in a little corner that -- in which they do these wonderful 11 things, but we would only see the --
12 MR. THADANI: I would speak for Research.
13 Certainly, they are not buried and they are working on what 14 we think are the high priority issues.
15 MR. HOLAHAN: I think both NRR and I think a 16 number of the offices, for example, have senicr level 17 positions with experienced PRA experts who are either 18 reporting to the branch or division levels to provide not 19 only expertise but advice at a relatively important level.
20 MR. ROSSI: We hired two people from industry 21 within the last year to work on this program that I have 22 been describing.
23 CHAIRMAN JACKSON: I heard a complaint from a 24 regional individual who took the PRA, one of these PRA
. 25 courses recently, who felt it was kind of boilerplate, and l
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86 l 1 that it.wasn't really up-to-date, it wasn't informed by the ;
2- fact'that and how the agency intended to use this kind of 3 capability in licensing and that kind of thing. And so that
.4 is something I would ask you to look at, because the issue
.5 is not to give people, first of all, five-year-old 6: information if the information needs to have been updated. j
- 7. And, secondly, if they don't understand what they f 8 are hearing within the context of how the agency either is ;
9 or plans to use it in its regulatory programs. And that is 1 10 actually where the complaint'seemed more to be. Okay.
11 MR. HOLAHAN: I am'little surprised to hear that 12 since, in general, the feedback we get is more positive.
13 And, certainly, for example, --
14 CHAIRMAN JACKSON: Well, what your feedback is may 15 be informed by how informed the individual is about ongoing ,
16 initiatives. So if you go in and you don't know a lot, 17 then, you know, there is a certain amount you are going to 7 18 get. But if you happen to know about where these tools are 19 being used or we plan to use them, then there is a different i 20 reaction. So that.is all I am saying. I am sorry. ;
21 COMMISSIONER DIAZ: And I don't know what the i i
221 -number should be, I have no idea, but I think that the [
23 .Ccmmission, sometime, when you come next time, we should f 24 know what.is the solid number of PRA expert practitioners 25 that we should have, and in what positions, so-that their
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87 1 expertise can be brought to bear.
2 CHAIRMAN JACKSON: Right. Okay. Please go on.
3 MR. ROSSI: Okay. We expect to meet the goal of 4 having two-thirds of the agency technical managers complete 5 .the PRA for technical managers course in fiscal year '98, 6 and sufficient courses for the other one-third will be given 7 in FY '99.
8 Work at the technical training division is 9 continuing to develop risk monitor software with models to 10 cover at least four of the reactor designs for use with 11 simulator and classroom training, and that can also be used 12 by others in the NRC such as the senior reactor analysts.
13 And I assume I said -- that covered viewgraph 15. I think I 14 said that at the start.
15 And that completes what I had to say.
16 CHAIRMAN JACKSON: Next time we will start with 17 nuclear material safeguards.
18 MR. WEBER: Well, on that note I will briefly
~19 address the other 40 industries or types of uses out there 20 of materials.
21 [ Laughter.]
22 MR. WEBER: In NMSS and the Materials Program, we 23 are moving forward or a multi-pronged approach in figuring 24 out to implement and develop the L;ols necessary and the 25 guidance necessary to go forward on risk-informed, ANN RILEY & ASSOCIATES, LTD.
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88 1 performance-based regulation.
2 Most fundamental to that, on the top of slide 16, 3 is the completion of the plan, really, the strategy for how 4 we plan to develop the framework for using a risk-informed 5 approach, including development of the necessary tools and .
6 guidance to regulate nuclear materials. ,
l 7 We are a different stage in the process than our 8 counterparts in the reactor area. Although we have 9 practiced risk analysis for.many years in the performance 10 assessment area, for example, as the Commission is well 11 aware, in the larger part of the Materials Program we have 12 no been so advanced in the use of, certainly, quantitative 13 risk analysis techniques. And so before we go too far, we 14 want to make sure that we spend the time necessary and ,
15 invest the effort to develop a coherent framework to go l
16 forward on risk analysis.
l 17 CHAIRMAN JACKSON: Yes. I'm sorry.
18 COMMISSIONER McGAFFIGAN: It strikes me one of the 19 challenges you have that the previous two hours of -
20 discussion doesn't have is the variety of stakeholders. And l
-21 at times, it came across in the Part 70 briefing we had last 22 week, the overlap with over agencies. In that case it was 23 OSHA and EPA. Sometimes it is Transportation, et cetera.
24 So you have a much more complex -- they have an industry 25 that has been working on PRAs for plant-specific IPEs, et
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89 1 . cetera, for two decades. And you have a bunch of folks who, i 2 if-you used the: term PRA, they would probably think you mean 3 3 --! ERA, earned run average, or something.
4 . CHAIRMAN JACKSON: Let's be careful. ,
'l 5 COMMISSIONER McGAFFIGAN: Not to disparage them.
6 But just -- in any way,.but it is a much more complicated 7 process for-you, isn't it? Outside of high level waste, 8 where you have a group of people who have been working 9 'similar to the reactor industry on probabilistic models for 10 at least a decade and a half. So how do you bring those 4
11- stakeholders in? Are they as interested in these
, 12- .probabilistic methods as we are?
13 MR. WEBER: As you might expect, there's a varying ,
14 spectrum of interest. Part of it is the sophistication of -
the user of the nuclear materials. A lot of it has to do 16 the risk posed by those materials. Where the risk is small, 17 the.use of quantitative methods like PRA simply - it is not 18 there.
19 CHAIRMAN JACKSON: Don't make sense.
l 20 MR. WEBER: And that is one of our challenges that 21 we' plan to pursue with the development of this framework, 22 trying to best map the techniques for risk analysis to the 23 'different uses of-the material, and that'is something that 2
.4. , we hope to come ba'ck to the Commission with later this year, 4
25 with,.you know, here are the results of this framework.
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90 1 I mentioned a multi-pronged approach. In addition 2 to working on the strategy or the framework, we are also 3 moving forward on Commission priorities. For example, the 4 development of the guidance recently completed by the Office 5 of Research with input from the other program offiras for -
]
I 6 the implementation of the License Termination Rule.
7 As the Commission is well aware, that guidance was 8 approved for a two-year interim use and there will be 9 extensive interaction with the stakeholders, not just the 10 user communities but also states, other regulatory agencies, 11 as you pointed out, Commissioner McGaffigan, EPA, DOE, and 12 other parties certainly have a large stake in there as we 13 move forward in a coherent fashion.
14 The Commission is well aware of the work that the l
15 staff has done on the development of the site-specific rule 16 for Yucca Mountain. Part 63, we believe we are moving
, 17 forward with a risk-informed rule in that arena, and that is l
18 due to the Commission later this month. And then the last l
1
- 19 bullet, as the Commission is aware from last week's 20 briefing, the staff developed and provided to the Commission 21 a. risk-informed rule for Part 70 which would apply to fuel 22 cycle facilities.
23 If you would turn to the next slide, Where do we 24 go from here? Certainly, a large part of our effort within 25 our resource constraints will be focused on the development -
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91 l
1 of the. framework. As I mentioned earlier, we are planning 2 to develop that and complete that by the end of this year.
3 The task force is up and. running and we hope to get a large ,
4 ' amount of interaction there, not just with the headquarters e 5- folks, but also region. folks, and our state regulators who
'6 turn out ' to regulate the majority of the materials !
7- licensees.
l l
f 8 In addition to the strategy development, we have I
! 9 got work underway in demonstrating methods for assessing the I.
L 10 risk of industrial gauges. The Office of Research is l.
I 11 ' undertaking this work, and it is a soup to nuts risk i
12 analysis, not just to demonstrate the technique, but also to !
l 1
13 give us risk insights. What is the likelihood and the ;
l 14 consequences of the loss of a gauge? What are the impacts i 15 to the steel workers? What is-the likelihood, frequency of l
16_ occurrence would you would expect to actually melt down the 17 gauge once it gets to a steel mill? So that will be very j 18 much of us to us across the board.
19 We are also moving on the completion of the 20 technical basis in the byproduct material use area. We have 21- a comprehensive survey out to NRC inspectors, license L 22 reviewers, both in headquarters and the region, as well as 23 the agreement states, on what exactly are the risks 124 associated with the use of radioactive materials. The 1
. 25 survey is quite lengthy and we hope to compile the results i
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92 1 and use that as the basis for, again, informing us on where 2 can we get the most return on the investment.
3 If we are going to focus on priorities in the 4 near-term, what should those priorities be? Where can we 5 stand to gain the most from a risk standpoint in the 6 materials area? And that works both ways. You know, where 7 do you want to increase your involvement, and where do you 8 want to back off? Because what we are currently requiring 9 poses an excessive burden.
10 And the last item there is implementing the 11 screening values. Again, it is part of the development of 12 the guidance for the implementation of the License 13 Termination Rule. The staff plans to consult in the near 14 future with the Commission on this subject because we can 15 anticipate that there might be some concerns out there as we 16 go forward with that. And we want to make sure that people 17 have a full view.
18 We are also coordinating that with the other 19 agencies that are involved. In fact, as we speak, I believe 20 the staff is wrapping up a meeting with the ISCORS 21 Subcommittee on the cleanup and they are trading notes and 22 exchanging experiences and discussing how do we procaed 23 collectively, as a federal community, in the development of 24 meaningful pragmatic guidance for moving on with the ~1eanup 25 rules that we have. -
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I 93 1 There are just a few examples. I guess to sum up' 2 for the Materials Program, . we are. moving forward. We have 3 got varying levels of sophistication. We try to map that to 4
4 theEdegree of risk that is involved, as best we know it, and
-( 5 at the same time we try to quantify what those risks may be.
6 And we are learning from the experiences of our colleagues
'7 in the Reactor Program. That is one of the reasons we ;
i 8 -wanted to the emphasize the development up-front of the' !
9 strategy so that we -- if we.do move forward, as we move
- 10. forward, we move forward in a coherent manner and not in 11 fits and starts.
12 CHAIRMAN JACKSON: I notice that you didn't 13 explicitly mention other waste management areas, such as low 14 level waste.
15; MR. WEBER: Right. ;
16 CHAIRMAN JACKSON: Is that -- I mean do you not 17 have not have initiatives in that arena?
' 18 MR. WEBER: The low level waste program, as it 19 currently stands, is rather limited from the Commission's 20 standpoint.
21 CHAIRMAN JACKSON: Right.
22 MR. WEBER: Most of the work today is being done 23' outLthere by the agreement states. We do, however,' move l-
- 24. . forward in this arena on the development of the low level
. 25 waste BTP, as resources permit. Many of the resources that
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r i 94 1 are working.on the development of the guidance for the 2 Licence Termination Rule are the same staff resources that 3 we would -- .
- 4. CHAIRMAN JACKSON: You would be working on.
P 5' MR. WEBER: -- want~to rely on and contract e i 6L resources for the --
7 CHAIRMAN JACKSON: And when you talk about the 8 License Termination Rule, you are including in that what has .
9- been the SDMP?
t 10 MR. WEBER: It is all part of the transition as we 11 move forward. ;
12' CHAIRMAN JACKSONi All right. Commissioner.
13 COMMISSIONER'McGAFFIGAN: A couple of questions on
- 14 SECY 98-138. One-of the areas that you talk about is the
- 15. use of.PRA techniques and dry cask storage. But, 16 unfortunately, you also say that the study originally [
17 scheduled has been suspended, and you say, at the end, the i
- 18. staff believes this study should be resumed when resources '
. 15f permit. When will resources permit? Because it does strike
. 20 . me that dry cask storage is an area where some of these 21 techniques could well be applied, both for reg. reform'and ;
22- ' others. But is this a Research study? f 23' MR. CUNNINGHAM: Yes,-that's correct. I believe
, 24 that.is in the FY 2000 budget.
- 25 COMMISSIONER McGAFFIGAN: FY-2000. -
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95 1 MR..CUNNINGHAM: To restart that.
2' COMMISSIONER McGAFFIGAN: Why -- we have been 3 putting a lot of resources into dry cask. What would be the 4 result of this study? What sort of things might come out
( 5 that would help us reform our dry cask regulations or ]
6 practices? i 7 MR. CUNNINGHAM: The original user request from 8 NMSS to Research dealt with just trying to understand the 9 risk of:the process of moving fuel from the spent fuel pool,-
10 for example, to a dry cask facility. Where is the risk 11 associated there? Is it in -- once it is in the cask, is it 12' a risk, or is it the motion? Is it the movement throughout 13 the site? And that sort of thing. Trying to get'an idea of 14 are we regulating the right parts of that process. And so 15 we were trying to develop -- demonstrate a method for 16 assessing that process for motion of fuel. That was what 17- was started in FY '97 and suspended.
18 COMMISSIONER McGAFFIGAN: The other area that I 19 note in here is Fart 71, you point out the regulations there
-20 are mostly prescriptive and deterministic. And that largely 21 follows because IEA's model regulations are prescriptive and
- 22 deterministic, which means there is yet this'other 23 stakeholder, which I guess is all other world regulatory 24 bodies,-that you have to influence. But in that particular
. 25 case, the four Becquerel per square centimeter requirement l
l-i
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96 1 that is in the IEA model has proven problematic.
2 In Europe recently, I know we historically have 3 not -- we, in the Department of Transportation, haven't 4 supported that. But how do we get to a risk-informed 5; transportation rules and how do' influence IIUL model so that
- 6 we. don't even up, you know, doing things that really are 7 pretty close to nonsensical from a risk basis? I mean they
.8 are way, way down in the noise.
9 MR. WEBER: I think the methods that'we would 10 pursue are not unlike those that we would use in the 11 Reactors Program area, where you do also have international 12 interest. There was, of course, a comprehensive modal study-13- done years ago. .That addressed different risk aspects of 14 transportation. I think we had one point -- we still do, I 15 .think, have-intentions to go back and revisit that again as 16 resources permit. j 17 If we do that, and you have a comprehensive risk :
18 basis to'go to the international community, I think that 19 stands a chance of having a fair amount of. influence on what 12 0 some of those decisions might be. As you point out, the !
21 -European community.has recently really' encountered a lot of !
22 controversy associat'ed with this phenomena, a phenomena that i 23 has also occurred in the United States, historically. So it l 1
1 24 is something.where we have to have the prospect that, coming l
'25 forward with a comprehensive, defensible analysis will. '
l
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97 1 eventually influence the ultimate decisions that are made 2 globally.
3 COMMISSIONER McGAFFIGAN: Do we have that 4 comprehensive defensible analysis in the case of Part 71 at t 5 the current time where we could take that to the -- I know 6 there's_a meeting this fall. I know you have some thoughts 7 as to what we may say at that meeting. But is it a I
8 compelling analysis at the current time? '
9 MR. WEBER: I can't --_I'm not really prepared 10 to --
11 MR. THOMPSON: We'll probably get back to you. I 12 don't believe that we've probably got such a compelling 13 analysis on performance-based risk analysis approach to be 14 able to do that. Traditionally those have been much more 15 deterministic-type requirements, and I think that's kind of 16 where the international community is right now.
17 COMMISSIONER McGAFFIGAN: Deterministic at times 18 sounds like pick a number out of the air, and if it's
)
19 conservative enough and, you know, you can make some cases '
20 achievable, you work to it even if you're in fact working to 21 microrems per year or something at that point. l 22 CHAIRMAN JACKSON: Besides, I take issue with 23 deterministic. It's never totally deterministic in the '
24 Newtonian sense.
. 25 COMMISSIONER DIAZ: I guess we're wrapping up.
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98 1- Well, I just wanted to make a couple of comments. As you )
2 probably know or suspect, I do believe that risk-informed l 3 regulation is_one of the key issues that needs to be ;
4- resolved in the real short term so we can really have an 5 agency that is responsive to the needs of the country, and s 6 so I strongly support efforts in this area. .
7 I want to say that the last briefing that we had I i i
8 'didn't end up very happy. You might remember I ended up i 9 sending a series of questions to the staff like does the i
10 staff know that the Commission decided to become j 11 -risk-informed regulation, and the answer was yes, we think i 12 .the staff.knows. The other things the staff committed to -
-13 do , well, we apparently believe that some of them do. And ,
i 14 the last question was,'you know, can the benefits be l 15 quantified and expressed. !
16 I'm a lot happier with the briefing today. I !
l 17 think there's been a change. I think that like we all know 18 we are really now embarking,on how these things are 19_ implemented.
! i 20 And to finalize, I'd like to maybe pick up on 21 something that Commissioner McGaffigan would say, and what 22 does PRA mean. And there might be a parallel, you know, a ,
23 word for PRA that if you use it together with probabilistic 24 risk assessment might actually push us in the right l 25 direction. And I call it that PRA should also be conceived -
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. .- - .. - .- -. . .- .. - . ~ .- -- - - - . . .
L :
l L ,
99 '>
.1 as' programmatic resolution of issues. If you put them '
2 together, that.certainly will help.
3 CHAIRMAN JACKSON: Let me-thank the staff for a
. 4
.4 .very informative and comprehensive briefing on the agency's L3 5- PIU4 implementation plan. You've obviously made some 6 significant accomplishments in this area, and in'so doing, 7 as is usually the case, you've identified areas that require '
-8 improvement and increased management and Commission l 9- attention. '
10 As we've been talking obviously the incorporation 11 of risk-informed and performance-based initiatives into the
- 12 reactor licensing inspection, assessment, and enforcement 13 program needs to be accomplished in a clear and coherent and 14 timely manner, and that requires the synergy of progre.ms and 15 processes as well as the requisite staff training that 16 you've spoken to. But equally important are the feedback 17 mechanisms that should allow us to judge the overall j i
18 . efficiency and effectiveness of our actions, you know, the I 19 outcomes in terms of improved plant safety through enhanced 3 20 safety decisions and the efficient use of our resources. l i
21 In that regard then interactions with our various 22 stakeholders is very important, as well as our own 23 .self-assessments of the efficacies of our regulatory 1
24 requirements and rules. And I look forward to more meat on !
I 25 the bones.in the material safeguards and safety arena, but j .,
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100 1 again let me caution you to eliminate stovepiping, to really 2 have teams, and to build risk-informed thinking not only in 3 the' specific quantitative ways we're talking about into our .
4 regulatory process, but into our planning and scheduling and 5 the building of teams. -
6 And so unless there are any further comments, 7 we're adjourned from this meeting.
8 [Whereupon, at 12:22 p.m., the briefing was 9 concluded.]
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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h ;
i' CERTIFICATE P
This is to; certify that the attached description of a meeting -
e of.the U.S. Nuclear Regulatory Commission entitled:
L TITLE OF MEETING: BRIEFING ON-PRA IMPLEMENTATION PLAN ;
PUBLIC MEETING PLACE OF' MEETING: Rockville,. Maryland DATE OF MEETING: Wednesday, September 2, 1998 was held as'herein appears, is a true and accurate record of the meeting, and that this is the original transcript thereof taken stenographically by me, thereafter reduced to typewriting by me or under the direction of the court reporting company Transcriber:_ Martha Brazil Reporter:_ Mark Mahonev ,
9 l~
l
pR REGug 8 O g
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PRA IMPLEMENTATION PLAN UPDATE Ashok C. Thadani, Director Office of Nuclear Regulatory Research Gary M. Holahan, Director Charles E. Rossi, Director i Division of Systems Safety and Analysis Safety Programs Division Office of Nuclear Reactor Regulation Office for Analysis and Evaluation of Operational ,
Data !
- Michael F. Weber, Deputy Director Mark A. Cunningham, Chief ,
Division of Waste Management Probabilis6c Risk Analysis Branch Office of Nuclear Material Safety and Safeguards Division of Systems Technology Office of Nuclear Regulatory Research September 2,1998 ;
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OUTLINE e introduction e Summary Challenges (staff and industry)
Responses to challenges e Nuclear Reactor Regulation e Regulatory Research e Analysis and Evaluation of Operating Experience & Training
- Nuclear Material Safety and Safeguards Regulation 2
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INTRODUCTION t
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e Staff completed several activities, however, e Staff receiving numerous complaints, examples:
Staff review of submittals too lengthy Duplicative RAls (request for additional information)
Lack of technology transfer within/among offices Question seriousness of staff to become " risk-informed" e Staff and industry faced with several challenges e initiatives implemented with staff to address the challenges (and complaints) 3 1
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CHALLENGES FACING THE STAFF e Provide a risk-informed and performance-based regulatory framework 0 Modify agency processes and programs to be more risk-informed e Provide adequate priority / resources across and within offices O Assign responsibility, resolve issues and allocate adequate resources to efficiently implement and accomplish risk-informed activities e Provide clear guidance to staff and industry o Provide necessary " tools" to efficiently implement / support risk-informed regulation i
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i CHALLENGES FACING INDUSTRY e Provide sufficient information in submittals to support application e Provide priority of needs (e.g., submittals) to the staff t
i e Solicit formal staff input during development of industry programs (e.g., PRA certification) .
e Complete PRA standards that can support risk-informed activities e Decrease response time in support of staff questions 5
STAFF RESPONSE TO CHALLENGES Providing a Regulatory Framework:
e Re-establishment of PRA Steering Committee (SC) with representatives from AEOD, NMSS, NRR, OE, OGC, Regions, RES) e Establish industry counterparts -
e Change agency programs and processes to be more risk informed (e.g., inspection, enforcement and assessment, 50.59, research)
Providing Adequate. Priority / Resources:
- Re-establishment of PRA SC e Establishment of Risk-informed Licensing Panel (NRR, OGC, RES) e Increase priority and management attention to risk-informed submittals Providing Clear Guidance:
e Update and supplement regulatory guides and SRPs after pilot plant reviews and further development of methods, data and guidelines e Support development of PRA standards 6
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, I NUCLEAR REACTOR REGULATION REGULATORYFRAMEWORK SUPPORT
- Conduct ongoing interaction with industry and public July 22 Workshop e Develop options for rulemaking to implement risk-informed regulation e Change agency processes and programs (e.g., inspection,
, enforcement, and assessment, and 50.59) to be more risk-informed 7
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NUCLEAR REACTOR REGULATION PRIORITY / RESOURCES )
e Established Risk Informed Licensing Panel !
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- Streamline the review of risk-informed licensing actions
- Provide guidance on policy implementation to NRR staff j i
- Composed of four NRR Division Directors (DSSA, DE, DRP, and DRPM), one RES Division Director (DST), and one OGC Asst General-Counsel ;
e Determine scope and depth of licensee analyses and staff review i
e Appointment of lead project manager for coordination of risk-informed, performance-based licensing actions e Database for tracking risk-informed licensing actions 8
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i NUCLEAR REACTOR REGULATION !
CLEAR GUIDANCE ;
e issued standard review plan (SRP) Chapter 19, General and supporting SRPs ;
i (Inservice testing (IST) SRP Section 3.9.7, Technical specifications (TS) SRP Section 16.1) e Inservice inspection (ISI) SRP for trial use e issue draft and final graded quality assurance (GQA) inspection guidance l
e IST pilot: Completed safety evaluation report (SER) for Comanche Peak e TS pilots: Completed safety evaluation of licensee amendments for extended .
allowed outage times for ECCS equipment and emergency diesel generators e GQA pilots: Completed SER for South Texas e ISI pilots and topical reports: Westinghouse Owner's Group, Vermont Yankee, Surry, ANO 2, and EPRI
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e Completed AP-600 PRA review i
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l REGULATORY RESEARCH REGULATORY FRAMEWORK SUPPORT l
e Support changes to inspection, enforcement, assessment and 50.59 e Support longer-term changes to Part 50 e Chair PRA steering committee e Support interaction with CSIS e Interact with NEl on whole plant study e Evaluate effectiveness of station blackout and ATWS rules and unresolved safety issue l
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i REGULATORY RESEARCH PRIORITY / RESOURCES e Prioritize research programs (develop general process for making research program more risk-informed as well as focus on potential for burden reduction)
- IPEllPEEE Program:
Completed reviews of all IPEs (met with TVA to resolve IPE on Browns Ferry 3)
Issued NUREG-1560, " Individual Plant Examination Program: Perspectives
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on Reactor Safety and Plant Performance" Completed preliminary reviews of all IPEEEs received Issued preliminary insights report on IPEEEs e Simplified Plant Analysis Risk (SPAR) Program:
Completed preliminary Level 1 (full power, internal events) SPAR models Initiated enhanced Level 1 SPAR models Initiated Level 2 (LERF) SPAR models Completed preliminary assessment of external events and low power shutdown to support development of SPAR models 11
REGULATORY RESEARCH CLEAR GUIDANCE e issued regulatory guides (1.174,1.175 (IST),1.177 (TS), and 1.176 (GQA))
e issued regulatory guide 1.178 (ISI) for trial use 4 e Lead agency support for PRA standards / certification
- ASME draft standard (Level 1/2, full power, internal events (excluding fire) scheduled to be ready for public review and comment, December 1998 C has not been through consensus process O
- ASME initiated process for fire, external events, and low power shutdown e Update safety goal policy statement
- Provide necessary research in PRA, examples
- Human reliability analysis - Low power shutdown risk .
Fire risk - Quality assurance impact on risk
- Aging effects into PRAs -
Digital I&C risk 12
l ANALYSIS AND EVALUATION OF OPERATING EXPERIENCE & TRAINING l' REGULATORY FRAMEWORK SUPPORT i
e Continue risk-based analysis of reactor operating experience in support of regulatory framework changes Issued ANPR to modify -10 CFR 50.72 and 50.73 Issued NUREGICR-5500, Volume 1, " Reliability Study on Auxiliary / Emergency Feedwater System: 1987-1995" Completed preliminary analysis of 1997 ASP events (6)
Developed specification for reliability and availability data system (RADS)
Issued CCF database, analysis software, and NUREG supporting documents on CD-ROM 1?
i ANALYSIS AND EVALUATION OF OPERATING EXPERIENCE & TRAINING PRIORITY / RESOURCES r
e Resources identified to complete risk-based analysis of reactor -
operating experience in developing risk-based performance indicators e issued contract for RADS i l
4 e Respond to comments and publish final report:
- NUREGICR-5500 Vol 2, Westinghouse Reactor Protection System [
Unavailability
- NUREGICR-5499 " Rates of Initiating Events at Commercial Nuclear Power Plants: 1987 through 1995"
- NUREGICR-5496, " Evaluation of Loss of Offsite Power Events at Nuclear Power Plants: 1980-1996" e issue contract for risk-based performance indicator development (11/98) 14
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ANALYSIS AND EVALUATION OF OPERATING EXPERIENCE & TRAINING CLEAR GUIDANCE i t
i e Provide staff PRA training !
Resident inspector at each site (PRA Technology and Regulatory Perspectives course (P-111)) ~
- 200 NRR technical staff during FY 1998 (PRA Basics for Regulatory Applications course (P-105)); another 200 in FY 1999
- 2/3 of agency technical managers by the end of FY 1998 (PRA for Technical Managers course (P-107)); additional courses will be provided in FY 1999 l e Risk-monitor software :
- Integrate into reactor technology and PRA training curricula
- Support staff understanding of configuration management, :
importance of plant operations to the risk profile of plants Tool to gain insights regarding industry use of risk-informed applications 15
Y NUCLEAR MATERIAL SAFETY AND SAFEGUARDS RECENT COMPLETED ACTIVITIES e Completed plan for developing a framework for using a risk-informed approach to regulate nuclear materials (SECY-98-138) e issued draft Regulatory Guide to implement License !
Termination Rule (July 1998) e Completed staff working draft of site-specific rule for high-level waste disposal at Yucca Mountain and briefed ACNW (July 1998)
- Completed draft proposed rule for fuel cycle facilities as amendment to Part 70 (July 1998) 16
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1 L NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
- NEW INITfATIVES AND PLANNED ACTIVITIES .
v e Complete scoping effort in support of plan for risk-informed approaches.to regulate nuclear materials e Demonstrate methods for assessing risk of industrial gauges e Complete technical basis for risk-informed and graded regulation of byproduct material e issue appropriate screening values for surface contamination to implement License Termination Rule ;
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