ML20199E281

Reports Status of PRA Implementation Plan for Period of 971001-1231.Responds to Srm,Dtd 970528,which Related to Staff Plans for Using IPE Result to Assess Regulatory Effectiveness

ML20199E281
Person / Time
Issue date:	01/23/1998
From:	Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-98-012, SECY-98-012-01, SECY-98-012-R, SECY-98-12, SECY-98-12-1, SECY-98-12-R, NUDOCS 9802020120
Download: ML20199E281 (27)

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POLICY ISSUE (Information)

Januan/ 23.1998 SECY-98-012 EQB: The Commissioners EROM. L. Joseph Callar.

Executive Director for Operations

SUBJECT:

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

To report the status of the Probabilistic Risk Assessment (PRA) Implementation Plan for the period of October 1 to December 31,1997, and to respond to a Staff Requirements Memorandum dated May 28,1997, which relates to staff plans for using Individual Plant Examination (IPE) results to assess regulatory effectiveness.

SUMMARY

This paper describes accomplishments and changes to the staffs PRA Implementation Plan for the period of October 1,1997 to December 31,1997, The principal accomplishments include preparation of the final versions of Regulatory Guide (RG) 1.174 (formerly draft guide DG 1061) and Standard Review Plan (SRP) Chapter 19, which provide general guidance on the use of PRA in risk informed decisions for changes in a reactor current licensing basis, completion of the South Texas graded quality assurance pilot program, publication (for public comment) of the draft RG and SRP on risk-informed inservice inspection, and the development of the staffs plan to use IPE results to assess regulatory effectiveness in resolving major safety issues. The principal change is the delay of the application-specific regulatory guides and Standard Review Plan sections from December 1997 to March 1998, to permit the incorporation of the policy decisions associated with the finalization of RG 1.174.

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The Commissioners 2 BACKGROUND:

In a memorandum dated January C .1996, from the t!xecutive Director for Operations to Chairman Jackson, the staff committed to submitting quarterly reports on the status of its development of risk informed standards and guidance. Previous quarterly reports were provided to the Commission on March 26, June 20, and October 11,1996, and on January 13, April 3, July 22, and October 14,1997. This quarterly report covers the period from October 1, 1997 to December 31,1997.

DISCUSSION:

The significant accomplishments and changes to the PRA Implementation Plan in the past quarter are summarized below.' More detailed information is provided in Attachment 1.

Significant achievements during the past quarter include:

Section 1: Reactor Regulation (NRR) 1.1 Develop Standard Review Plans for Risk Informed Regulation NRR and RES staff met with ACRS and CRGR to discuss the final versions of the general guidance on use of PRA in risk informed decision making in changes to the plant specific current licensing basis; Standard Review Plan Chapter 19 (NRR lead) and Regulatory Guide 1.174 (RES lead). A Commission paper providing the final versions of these documents will be provided to the Commission in the near future.

Draft Standard Review Flan 3.9.8 (NRR lead) and Regulatory Guide DG-1063 (RES lead) on risk informed inservice inspection of piping were published for public comment and the subjects of a public workshop on November 20 and 21,1997, The workshop was well attended by industry representatives who offered a number of constructive comments, some criticisms, and some suggestions for changing the guidance. Overall, the comments indicated strong support for pursuing risk informed inservice inspection (RI-ISI) but in a manner which would necessitate some modifications to the draft guidance.

1.2 Pilot Applications for Risk informed Regulatory Initiatives The staff evaluation of the South Texas Project risk informed graded quality assurance (QA) implementation plan was transmitted to the Commission via SECY 97-229 on October 6,1997.

I The staff has modified the format of the PRA Implementation Plan to reduce redundancy and improve readability. This revised format consists of the body of the Commission paper, which now provides a summary of accomplishments and changes to the plan for the past quarter, and the Plan's table (Attachment 1), modified to explicitly show where milestones have been added, completed, or changed. Such changes are discussed and additional information provided in endnotes to the table.

The Commissioners 3 By SRM dated October 30,1997, the staff was informed that the Commission had no objection to the issuance of the South Texas graded QA safety evaluation report. By letter dated November 6,1997, the licensee was informed that the staff had approved the graded QA change and was provided with the associated staff safety evaluation. ,

The staff has received risk informed inservice inspection pilot submittals from Surry 1, ANO 2, and Vermont Yankee which are currerstly being reviewed for completeness. The staff will develop a review schedule if the submittals are determined to be complete and in conformance with the DG 1061 and DG 1063 submittal guidance. The staff is also developing schedules and priorities for the review of other RI ISI pilot submittals as well as submittals expected subsequent to the pilot RI ISI program approvals.

1.3 Inspections The staff completed nine additional maintenance rule baseline inspections during this quarter, which included inspection of licensee methods for using PRA in maintenance programs and inspection of safety assessments performed by licensees when removing equipment from service for maintenance in accordance with Paragraph (a)(3) of the Maintenance Rule. As of December 31,1997, the staff has completed a total of 45 inspections.

Section 2: Reactor Safety Research (RES) 2.1 Develop Regulatory Guides As discussed above, NRR and RES staff met with ACRS and CRGR to discuss the final versions of Standard Review Plan Chapter 19 (NRR lead) and Regulatory Guide 1.174 (RES lead). A Commission paper en policy issues was forwarded to the Commission as SECY 287, dated December 12,1997. A Commission paper providing the final versions of these documents will be provided in the near future.

2.4 Methods Development and Demonstration A demonstration at the Seabrook nuclear power plant of the human reliability analysis method ATHEANA (A Technique for Human Event Analys;s) has been completed. A medium break LOCA scenario, including inappropriate termination of makeup (an error of commission), was selected for analysis and simulator exercise. The ATHEANA demonstration helped plant personnelidentify safety-related weaknesses in plant barriers and design. Specifically, the exercise identified weaknesses in the use of well planned and tested emergency procedures as well as identifying improvements needed in the draft ATHEANA documentation.

2.5 IPE and IPEEE Reviews

- The final version of NUREG-1560, *lPE Program: Perspectives on Reactor Saf9ty and Plant Performance," has been submitted for publication. This report was initially issued in late 1996 for public comment. l Based on the comments received, the report was revised, with an addrtional appendix written discussing the comments received and staff responses. '

9 The Commissioners 4 The first IPEEE staff evaluation report, for the Diablo Canyon Power Plant, was completed and issued to the licensee on December 4,1997, in addition, requests for additionalinformation on fifteen IPEEE submittals were prepared to send to licensees.

An interim report has been developed that provides preliminary IPEEE perspectives and summarizes the information presented in the first 24 IPEEE submittals reviewed by the staff.

This interim report will be sent to the Commission in the near future. (A summary of the significant preliminary perspectives from the first 24 IPEEE reviews was provided to the Commission in Attachment 7 to SECY 97 234.)

Sectinn 3: Analysis and Evaluation of Operating Experience and Training (AtiOD) 3.1 Risk Based Trends and Patterns Analysis Letters are in the concurret.ce process to distribute the common cause failure (CCF) database and associated technical report to all U.S. nuclear utilities for their use. The database contains CCF events from 1980 through 1995.

3.2 Accident Sequence Precursor (ASP) Program All 1996 precursor analyses have been finalized, with the 1996 ASP report now in publication.

Three preliminary analyses of 1997 events are being reviewed. The annual Commission paper describing the ASP program in more detail was sent to the Commission on December 23,1997 (SECY 97 296).

3.6 Staff Training Development activities for the PRA Technology and Regulatory Perspectives (P 111) course were comploted during this quarter. The first course presentation will be January 26 - February 6,1998. The staff has established a goal of having one Resident inspector at each she complete the course by the end of 1998.

Significant changes made to the implementation Plan during the last quarter include:

Section 1: Reac'or Regulation (NRR) 1.1 Develop Standard Review Plans for Risk-Informed Regulation As discussed above, the general regulatory guide and Standard Review Plan for use of PRA in plant-specific current licensing basis changes will be transmitted to the Commission in the near future. To permit efficient incorporation of the resolution of policy issues contained in these I documents into the application-specific SRP sections on inservice testing and technical l

specifications, completion of these SRP sections has been delayed until March 31,1998, a change from their previous completion date of December 31,1997.

l

The Commissioners 5 i

l 1.2 Pilot Applications for Risk Informed Regulatory initiatives The staff is currently developing a draft safety evaluation report (SER) for the Comanche Peak 1 risk informed inservice testing program (Rl IST) program. The licensee (TU Electric) is currently developing a program that is sufficiently detailed and consistent with DG 1062. TU Electric has indicated that it intends to complete a draft revision to their program description by the end of January 1998. Assuming that the program is finalized by mid February, the staff anticipates having a completed Comanche Peak Rl IST SER to the Commission in March 1998, rather than December 31,1997.

The completion date for the graded quality assurance (GQA) pilot interactions has been revised from March 1998 to July 1998 to reflect the anticipated issuance date of the final GOA inspection guidance.

The staff received a supplemental amendment request from the San Onofre Nuclear Generating Station (SONGS) in early January 1998 to put the configuration risk management program description into the SONGS technical specif cations. SONGS has recently become i

the lead plant for this Combustion Engineering Owner's Group (CEOG) activity, when the originallead plant decided not to pursue risk-informed TS changes at this time. With receipt of l the SONGS supplen etal request, the staff anticipates completing the SONGS review as the l lead pilot plant and isung the license amendment by March 31,1998. This is a change from the previous date of December 31,1997.

1.3 Inspections The NRR Inspection Program Branch (P'PB) proposals for revising core inspection procedures have been transmitted to the appropriate NRR technical branches having responsibility for specific core inspection procedures. Due to the large number of branches involved, completing all individual branch concurrences is anticipated to take an additional two months. The revised completion date for th!s task is February 1998, a chan9e from the previous date of October 1997.

1.6 Evaluate Use of PRA in Resolution of Generic issues As part of the IPE follow-up program, the staff is in the process of identifying generic issues to be audited. These issues are those which have been explicitly identified and addressed by the licensee as part of the IPE process.

A report that identifies the above generic issues and staff views on the adequacy of the proposed resolution k. In preparation. The report will provide the basis for the selection of generic safety issues to be audited. The staff has moved the completion date for this milestone to March 1998, in order to utilize the report in the audit process.

In addition to the above issues, RCP seal LOCA had been identified as a dominant contributor to core damage in many PWR IPEs. The staff has a separate ongoing activity in RES to address this issue under Generic issue 23, and will utilize IPti insights in the proposed resolution.

The Commissioners 6 1.7 Regulatory Effectiveness Evaluation in a Staff Requirements Memorandum dated May 28,1997 (Attachment 2), the Commission requested that the staff provide the scope and schedule of activities relatad to using IPE results to assess regulatory effectiveness in resolving major safety issues. With respect to scope, the staff identified three major safety issues for assessment. The selection had been based on both the potential risk significance of the issue, and the fact that probabilistic techniques were used extensively in the resolution process. These issues include:

1, Resolution of USl A-44 Station Blackout at Nuclear Power Plants

2. Resolution of USl A-45 Decay Heat Removal Reliability

3. Resolution of USl A 09 Anticipated Transient Without Scram To evaluate the three major issues, the staff will utilizJ both representative plants, and information contained in NUREG 1560, to audit and draw conclusions regarding regulatory effectiveness. Information generated under Task 1.6, as deteribed above, and Task 1.10, as described below, will also be integrated into the assessment process. These tasks may expar!d the staff's consideration of other cafety issues and effectiveness of the regulatory process. The staff will inform the Commission of any additional safety issues that come under consideration.

The staff plans to complete Task 1.7 by the end of December 1998, and will recommend at that time any additional staff action.

1.8 Advanced Reactor Reviews Doe to personnel being assigned to higher priority activities, such as risk-informed pilot initiatives and IPE followup activities, the staff is reassessing their position regarding the development of an SRP, especially since there are no new advanced design certification submittals anticipated. We will provide the results of this reassessment in a future update of the PRA implementation Plan.

1.10 Evaluation of IPE Insights The staff has developed an IPE followup plan (Attachment 3) which describes those actions to be taken to ensure that plant improvements warranted by 'he IPE results are, in fact, made.

This plan consists of a number of items and its implementation involves NRR, RES, and the Regions, as described in the plan.

Section 2: Reactor Safety Research (RES) 2,1 Develop Regulatory Guides As discussed above, the general regulatory guide and Standard Review Plan for use of PRA in risk informed decision making for plant specific current licensing basis charges will be transmitted to the Commission in the near future. To permit efficient incorporation of the resolution of policy issues contained in these documents into the application-specific regulatory guides on inservice testing, graded quality ascurance, and technical specifications, completion

The Commissioners, 7 of these guides has been delayed until March 31,1998, a change from their previous completion date of December 31,1997.

2.5 IPE and IPEEE Reviews The staff has reviewed all the 76 IPE submittals and issued staff evaluatiun reports (SERs) on their findings to each licensee, in three of the SERs, it is indicated to the licensees that the staff was not able to conclude that the licensee met the intent of Generic Letter 88 20 for their plant (s). These three IPEs include Crystal River 3, Susquehanna 1&2, and Browns Ferry 3.

The licensee for Crystal River 3 has indicated their intention to submit an updated analysis (February 1998) addressing the staff's concerns. It is anticipated that the review of this new IPE submittal will be concluded in June 1998. Discussions are still ongoing with licensees regarding Susquehanna 182 and Browns Ferry 3.

Section 3: Analysis and Evaluation of Operating Experience and Training (AEOD) 3.6 Staff Training Eight PRA for Regulatory Applications courses are now planned for FY 1998 and FY 1999 to meet the needs of the technical staff. Funding for these courses was obtained by reducing the number of SRA series from two to one per year. Modifications to the PRA Basics for Regulatory Applications, PRA for Technical Managers, and PRA Technology and Regulatory Perspectives courses have been made to 'alude the final draft R.G.1.174 and SRP, Chapter

19. Seven PRA for Technical Managers courses are planned for FY 1998, which will allow two -

thirds of agency technical managers to attend.

Procurement actions for acquisition of risk monitor software are in process. The EPRI Risk and Reliability (R&R) Workstation is the current industry standard for risk monitors Current plans are to integrate the R&R workstation into the reactor technology and PRA technology curricula to improve student understanding of configuration management, the importance of plant operations to the risk profile of the plants, and use of the tool to provide insights regarding the use of risk informed applications by the industry. The workstation will also be used to demonstrato the capabilities and limits of this and simi!ar tools as they are being used by the industry.

4 Section 4: Nuclear Materials and Low Level Waste Safety and Safeguards Regulation (NMSS) 44 Risk Assessment of Material Una The target schedule for the work to develop and demonstrate a risk assessment for industrial -

gauges containing cesium 137 and cobalt-60 using PRA (and other related techniques) has been extended from July 1998 to September 1998. The extension is due to difficulties in obtaining data from non-licensees related to actual and potential doses to the public resulting >

from gauges which enter the scrap metal cycle.

- . - - - - -- ___ _ _ , _ ~ _ _ _ _ _ _ _ _ ,

e 1

8 The tar 9et schedule for the work to develop and demonstrate risk assessment methods for application to medical and industrial licensee activities has been determined to be September 1998 based on scheduling of a planned Commission paper on the topic.

4.5 - Framework for Use of PRA in'Reauintina Nuclear Materials The target schedule for providing a p for developing a framework has been extended from October 1997 to January 1998 to permit interoffice coordination.

COORDINATION:

The Office of the General Counsel has reviewed this paper and has no legal objections to its issuance.

M G (/

• L. Jclseph Callan Executive Dire VOperations -

Attachments:

As stated DISTRIBUTION:

Commissioners OGC OIG OPA OCA  !

ACRS ACNW CIO CFO EDO REGIONS SECY

' ATTACHMENT 1 PRA IYPLEMENTATION PLAN TASK TABLE (December 1997) 1.0 REACTOR REGULATION Cegulatory Activity Objectives Methods Target iend Status (tNs Schedule Offee(s) queder) 1.1 DEVELOP Standard revew plans for NRC ' Evaluate available industry NRR STANDAHL staff to use in rak 6nformed guidance. /RES REV!EW PLANS regulatory decison making FOR RISK.

• Develop a broad sco INF ORM* D standard rewew plan ( ,RP)

REGULAtlON chapters and a senes of applicaton specife standard revew plan chapters that correspond to industry initiatives.

• These SRPs will be consistent with the Regulatory Guides developed for the industry.

• Draft SRPs transmitted to Commisson to issue for puble comment G,neral 497C' IS T 497C ISI E97C TS 497C

• Final SRP transmitted to Commmagin for approval General 1/98 in final renew IST 393 Changed (Note 1)

ISt 498 TS 398 Changed (Note 1) la PILOT

• Evaluate the PRA methodology

• Interface with Industry NRR/RES APPLICATIONS ond deveksp staff positons on groups FOR RISK. emerging, rak informed INFORMED Initiatives enciuding those

• Evaluaten of appropnate REGUL ATORY essociated with documentaton te g .10 CFR.

INITIATIVES SRP. Reg Guides, mspecten

1. Motor operated vatves procedures. and industry 1. 2,96C codes) to edentify elements 2 IST requirements entcal to acheving the entent 2a Comanche Peak of extsting requrements. 2a 398 Changed (Note 2) 2b Paio Verde 20.TDD

' Evaluaton of industry 3 ISirequirements proposain. 3 TBD 4 Graded quality assurance.

• Evaluaton of industry pilot 4. 7/98 Changed (Note 3) program implementaten.

5 Maintenance Rule 5 E95C

' As appropnate, complete 6 Techncalspecifcatons pilot revews and tasue staff 6a Commisstun Approval findings on regulatory 6a 597C 6b. Pilot Amendments issued requests. 6b.198 Changed (Note 4)

7. Other appleatens to be identifed later (apphcations related to desel generator start times and hydrogen control are expected) 1 C = Tash prewousy comp 6eted 1

- -. . . - _ . ~ . - . - - .

. - . - _ - - - - - ~ . - ~ - . - . . - . - . - - - - -

4 Cegulatory ActMty Obrectrves Methods Target lead Status (this

_, Schedule Offee(s) quener) 1.3 lNSl%',TIONS

• Provide guidance on the use of

• Develop IC #00 technical 697C NRR plant-specife and genene guidance on the use of PRAs enformaton from IFEs and other in the power reactor inspecten plant specife PRAs. program.

• Revse IC 25t$ Appendix C 7/g7 C on the use of PRAs in the power reactor inspecton program.

• Propose guklance options t097 Completed forint ton procedures totot to 60 59 t,stuntons and regular rnanntenance observatens.

• Review core inspecten 1697 Completed procedures and propose PRA guidance where needed

• Complete revision to propened core .nspecten 2/98 Changed (Note 5) procedures

• losue dran Graded OA Inspecten Procedure 498 Changed (Note 6)

• lasue final Graded QA inspecton Procedure 7/98 C%nged (Note 6)

• Provide PRA training for

• Identify inspector functons 7/96C NRR inspen. tors whch should utilize PRA methods as input to AEOD/TTO for their development and refinement of PRA trairung for inspectors

• Develop consolidated and comprehensive 2 3 week PRA 1697 NRR/ Completed for regulatory ap AEOD tranng course. picatens

' Provide PRA training for Senior Reactor Analysts (SRA)

• Conduct training for Mantenance Rule baseline &960 NRR inspectons

' Conduct training courses according to SRA training Ongoing AEOD programs

• Rotatonal assignments for SRAs to gain working Ongoing NRR/RES exponence

' Continue to provide expertise in

• Monitor the use of nsk in Ongoing NTIR risk assessment to support inspecten reports.

regionalinspection activites and to communcate inspecten

• Develop new methodologes program guidance and and communcate appropnate examples of its implementatort uses of nsk insights to regional offces

• Update inspecten procedures as needed

• Asset regional offces as needed

• Conduct Maintenance Rule baseline inspectons 7/98 2

Cogulatory ActNi'y Objectwos Methods Lead TarDet Status (this Scheoute Offce(s) quarter) 14 OPERATOR Monstry insf.;s from HRAs and

• Reese the Knowiedge and &95C UCENSING NRR PRAs (including IPEs and Atwides (K/A) Cataicos IPEEEs) and operating (NUREGs 1122 and 1123) to 1 e ronce to ioentify possible encorporate operating .

e ncements for inclusaon an exponence and nok 6nsghts planned revisions to guidance for operator licensing actuttes (rvtal

• Revise the Examiner 197C and requahfcation) Standards (NUREG-1021), as needed to reflect PRA Insights 19 EVENT ' Continue to conduct quantitative ' Continue to evaluate 50 72 Ongoing ASSESSMENT NRR event assessments of reactor events using ASP models events while at. power and dunng low power and shutdown conddions

• Assess the desirab6ldy and

• Define the current use of risk TBD NRR feasibihty of conducting analysis methods and insights quantitafive nok assessments on in current event assessments non-power reactor events

• Assess the reasibility of developing appropnate not; assessment models

• Develop recommendations an the feasitulity and desirabihty of conducting quantitative risk asses!,ments.

1C EVALUATE USE

• Audit the adequacy of hcensee OF PRA IN

• Identrry genere safety issues 198 NRR/RES Changed (Note 7) analyses in IPEs and IPEEEs to to be audited RECOLUTION OF identify plant-specifc apphcability GENERIC ISSUES of genene issues closed out

• Select plants to be sudded 398 i Changed (Note 7) based on IPE and IPEEE for each issue.

programs.

• Desende and discuss TBD l licensees

• onetyses supporting i

issue resolution.

• Evaluate results to determine TBD regulatory response; i e., no action, additional acids, or regulatory accon.

1.7 REGULATORY

• Assess the effectiveness of

• Develop process / guidance ongoing NRRIRES EFFECTNENESS maior safety resue resolution for assessing regulatory EVALUATION afforts for reducing nsk to pubic effectiveness.

health and safety.

• Apply method to essess ongoing reduction in nsk.

Note Work in this actuity will be Integrated with broader agency

• Evaluate resulting 12,98 efforts in response to DSI 23 Changed (Note B) effectmeness of station blackout and ATWS rules and Unresolved Safety issue A-45.

• Propose modifications to TBD Changed (Note 8) resolution approaches, as needed (SBO rule imp' ament.h vi and RCP seal assue).

• Identify othe Swes for ongoing Changed (Note 8) assessment 9 4;y:gnate.

)

3

4

^

Regulatory Activity Objectrves Methods Target Lead Status (this Schedule Offee(s) quader) 1.8 ADVANCED ' Contnue staff reviews of PRAs

• Continue to apph current ongoing NRR REACTOR for design certifcation staff review process REVIEWS appicatens

• Devehp SRP to support revww

• Develop draft SRP to tech TBD NRR of PRAs for design certifcatic.a Changed (Note g) staff for rev ew and reviews of evolutonary reactors corcurrence (ABWR and System 80+)

• rrialize SRP. TBD

• Develop indeper. dent technical ' Reevaluate nsk-based 12/96C analyses and critena for NRR/ RES aspects of the techncal bases evaluating tndustry initiatives and for EP (NUREG4396) using petitons regarding sirnphfcaten Inssghts from NUREG-1150 of Emergency Preparedness the new source term (EP) regulations. Informat.m from NUREG-1465. and available plant design and PRA informaton for the passive and evolutonary reactor designs.

1.g ACCIDENT

• Develop generic and plant

• Deveioo plant-specife A!M TBD NRR/RES MANAGEMENT specife nsk ins s to support insghtsinformaton for staff auditsof accident selected plants to serve as a management programs at basis for assessing selected plants cor p6eteness of utihty A/M program elements (e g ,

severe accident training) 1,10 EVALUATING IPE

• Use insights from the staff ' Reyww the report *1PE E97C NRR/RES INSIGHTS TO review of IPEs to idert.N Program Perspectives on DETERMINF potental safety, Reactor Safet NECESSARf technical ssues,topolicy, determineanden Performance *y and and Plant the identify FOLLOW UP appropnate course of action to initiallist of required staff and ACTIVnIES resolve tnese potentialissues, industry actions (if an )

and to identify possible safety including insghts on _

enhancements.

• Revww IPE results and 6/99 NRR/RES Changed (see interact with heensees.

Attachment 3)

• Determine appropnate

• Complete backfit analysis 12<99 NRR approach for tracks tne Changed (see and actions.

regulatory uses of 1 PEEE Attachment 3) results

• Followup on accident SSB i NRR/ Changed (see management programs and regions Iconsee-stated actions. Attachment 3)

• If sopropriate develop 1298 NRR/ RES a h for hnking i PEEE data bases.

4

20 REACTOR SAFE *Y RESEARCH Cogulatory Adivty Objectives Methnos Target Lead Status (this Schedule Offee(s) quarter) 11 DEVELOP Regulatory Guides for industry to

• Draft PRA Regulatory I

REGULATORY RES/NRR use in rak informed regulaton 3uides transnuttedto l GUIDES ;ommesson for aproval to ,

j issue for pubic comment.

l General C l IST C t

ISI C GOA C TS C

• Forwl PRA Regulatory 3uides transmitted to l Commission for approval.,

Genersi 1/98 [

in final revww IST 398 Changed (Note 1) isi 498 GOA 396 Changed (Note 1)

TS 398 Changed (Note 1) 33 TECHNICAL

• Provide techn. cal support to

• Continue to provide ad hoc Continuing SUPPORT agency users of risk RES technical support to agency assesernent in the form of PRA users support for nak based

} regulaten activitwo, techncal

• Expand the database of PRA Continuing reviews, essue nok nodels available for staff use, assessments, statist. cal expand the scope of avadabie analyses, and aevelop 'nodels to include external event guidance for agency uses of nok and low power and shutdown assessment accidents, and refine the tools weded to use these models, and

ontinue maintenance and user w for SAPHIRE and CS computer codes

• Support agency efforts in

'eactor safety improvements in Continuing

'ormer Soviet Union countnes.

3.3 SUPPORT FOR ' Modify 10 CFR 52 and develop

• Develop draft guidance and NRf1 STANDARD 5/98 RES

. Mance on the use of updated 'une.

REACTOR PRA ". tAs beyond denen cenirmation REVIEWS (as desenbod in SECY 93487).

• Solett pubic comment. 11/98

• Finales staff guidance and 12,99

'ulo =

24 METHODS

• Devoiop, demonstrate, maintain.

• Develoo and demonstrate 9/98 DEVELOPMENT and ensure the quality of RES AND Tiethods for including aging methods for performina, effects in PRAs.

DEMONSTRATION revww1ng, and ussng F4tAs and related techniques for

• Develop and demonstrate 9<98 existing reactor designs. Tethods for including human errors of commissen in PRAs.

• Develop and comonstrate TBD netfods to incorporate gnaational performance into

• Develop and demonstrate 9/96 methods for flru nsk analysis.

• Develop and demonstrate 6/99 nothods for assessing

'ehability/nsk of digital systems 5

Cegulatory Actrvity Objectives Methods Target Lead Status (this Schedule Office (s) quarter) 15 IPE ANDIPEEE

• To evaluate IPE/IEEE

• Complete revews of IPE TBD REV?EWS RES Changed (Note 10) submittats to obtain reasonable 6ubmittals.

assurance that the hcensee has adequately anatyzed the

• Complete reviews of IPEEE 699 piant desgn and operations to bubmrttais discovervulnersbees andto document the sgnificant safety

• Continue regionat IPE C insghts resulting from yesentations IPEstPEEEs

'lasue IPE insghts report for 10/96C xiblic comment.

• FinalIPE 6nsghts report 9S7 Completed

• losue prehminary IPEEE 1/98 in final review insghts report =,

• Initiate revew of eight 6/98 New milestone additionalIPEEE submittals

• Comp 6ete contractor 6,98 New milestone avsluations on twelve IPEEE wbmittals

• lasue draft IPEEE insghts 699 New milestone report for comment

• lasue final IPEEE insghts 1299 oport 2.6 GENERIC ISSUES ' To conduct genene safety issue

• Continue to pnortize and PROGRAM ma Continuing RES ment activites, eserve genenc issues inct ing pnorit&tation, resolution, and documentation, for issues relating to currently rating reactors. for need reactors as appropnate, and for development or revtsion of associated r ulat and standards 6n me a 17 NEl INITIATIVE TO

• Review NElinstetive to conduct

• Agree on ground rules for CONDUCT three pilot "whole plant" 198 RES/NRR study.

"WHOLE PLANT

• nsk intormed studes of RISK STUDY requirements vs nsk and cost

• Complete study TBD 2.8 PRA STANDARDS

• work with industry to develop

• Initiate actrvity. 9S7C RES DEVELOPMENT national consensus standard for PRA scope and quality

• Finalize standard. TBD 19 LOW POWER AND

• Collect studes of LP&S nsk as

• Collect and review existing SHUTDOWN 9S8 RES a benchmark for assessi the .P&S nsk information (domestic BENCHMARK need for further staff es and foregn).

RISK STUDY

• Instete additional work. 10S8 l

l 110 SAFETY OOAL 'Assesa need to revtse REVISION Commissiorfs Safety Goalto *Initete disct=sion with ACRS 2/98 RES l

i make core damage frequency a

• Recommendation to 198

fundame ital goal and make other Dmmission changer,,

l 6

3 0 ANALYSIS AND EVALUATION OF OPERATING EXPERIENCE, AND TRAINING Regulatory Otyctives Methods Target Lead Status (t*us Activity Schedule Offee quarter) 3.9 RISK BASED

• Use reactor opeisting

• Trend performance of nsk. 1198 AEOD TRENDS AND exponence data to assess the important components PATTERNS trends and pottems in ooiapment, ANALYSIS systems, inrtistire " .. hurrun

• Trend performance of nsk. 1Z98 performance, s. ant important systems.

accxlent sequence.

l

• Trend fr of nsk. 3,98  !

6mportant events

• Trend human performance TBD for rehatuity charactenstes

• Evaluate the effectiveness of

• Trend reactor operating As Needed AEOD teensee actons taken to exponence associated with resolve nok signifcant safety specife safety issues and losues assess nsk impications as a measure of safety performance

• Develop trending methods and

• Develop standard trending C AEOD special databases for use in and statistical anatysis AEOD trending activttes and for procedures for 6dentified areas PRA ap for rehatulity and statistcal offees. pications in other NRC apphcations.

• Develop special software CCF.C and databases (e g common Penode cause failure)for use in updates trending analys,s and PRA studies 32 ACCIDENT

• Ide, tify and rank nsk

• Screen and analyze LERs, Ongoing AEOD SEQUENCE sgnifcance of operatonal AITs, llTs. and events PRECURSOR events identifed from etner sources (ASP) PROGRAM to obtain ASP events.

• Perform independent revew Annual AEOD of each ASP analyses, report, Licensees and NRC staff peer Ongoing review of each analysis.

• Complete quauty assurance of Rev. 2 simphred piant 3,97C RES specife models

• Complete feasitxl tudy for low and shut 11/96C RES

• Complete initial containment performance and C RES consequence models.

• Compte development of the Level 43 models 7/99 RES

• s Comge plant the Rev. 3 specirc 11K)1 RES

• Complete extemal event models for fire and earthquake TBD RES

• Complete low power / shutdown models TBD RES

• Provide supplemental

• Share ASP analyses and Annual rpt AEOD information on plant specife insights with other NRC performance. offces and Regions.

7 e x

Regulatory Objectives Aethods Target Lead ActMtf Status (this Schedule Offee guarter) 33 tNDUSTRY 8t!SK

• Provide a rnessure of industry

• Develop program plan whch C AEOD TRENDS nsk that es as complete as integrates NRR, RES and possible to oetermine whether AEOD actMties whch use not is increasing. decreasing, or desgn and operating remaining constant over time exponence to assess the emphed level of rtsk and how ll es changing

• Update plan for nsk based Changed ana!yss of reactor operating (Note 11) exponence

• Imp 6ement program plan 6/99 elements whch willinclude piard. specifc models and insghts from IPEs, component and system relaatulity data, and other nsa.

important :;esgn and operational data in an integrated frame work to scally evaluate industry 30 RISK BASED ' Estabish a comprehenstve set

• Identify new or improved C PERFORMANCE of performance indicators and AEOD nsk-based Pls whch use INDICATORS supplementary cerformance component aN system rneasures whch are more rehabdity models & human and clow*e related to nsk ar.d provide organizational performance bolo e. sty indcation and evaluation methods con 9mation of plant performance problems.

• Develop and test candidate Pis/ performance measurts. 900

• Implement nak-based Pts with Commission approval 101 35 COMPILE

• Compile operating exponence

• Manage and maintain SCSS OPERATING Ongoing AEOD lnformation In database systems and the PI data base, provice EXPERIENCE suitable for uantitative rehatxlity oversjght and access to DATA and rak ana is appications. NPRUS/ EPIX, obtain INPO's Information Id be scrutable SSPl, compile IPE failure to the source at the event level to data, collect plant-specife i the exter.t practical and be rehability and availatxiety data.

suffcient for estimatino reinatxlity and avestatxhty parameters for

• Develop, manage, and Ongoing NRC appleations maintain agency ostabases for rahatxutyravailatulity data (equipment performance initiating events, CCF, AhP, and human performance data).

• Determine need to revise 698 LER rule to eliminate unnecessary and less safety.

sgnifcant reporting

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

• Pubhsh revised LER rule. 10/9C 8

s 2 -, -

Regulatory Obrectrves Methods Target Lead Actrvey Status Ohis ,

Schedule Offce quarter) t i

36 STAFF TRAINING ' Present PRA cumculum as

• Continue current cWacts to Ongoing AEOD presently scheduled for FY present courses es 1998 scheduled.

• Maintain current reactor technology courses that include PMA ensghts and apphcations courses wa

• Rowew cunent PRA course matenal to ensure consistency wth Appendix C

• Develop and present Appendix

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

• Present courses on C Appendir C

• Determine staff requirements

• Review JTAs performed to C AEOD for traini} retuding date.

ty t a

• Perform re seentatrve JTAs C for staff ens (JTA Pilot Program .

• Evaluate staff trainino C requirements as identiTod in the PRA im mentation Plan and the Tec I Training Needs Survey (Phase 2) and incorporate them into the training requerernents analysis.

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

• Complete JTAs for other staff posatons as needed. C

• Sohcit a review of the proposed training C requirements

• FAalize the requirements.

C

• Reese current PRA cumculum

• Prepare new courses to Ongoing AEOD and develop new training meet identified needs.

program to fulfill 6dentifed staff neeos.

• Rewse current PRA courses Ongoing i

to meet identifed needs.

f

• Rewse current and New PRA course to include Reg - 9/97C Guide and SRP information

• Revise current reactor technology courses as Ongoing ,

necessary to include additional PRA Insigtds and applications

• Present revised PRA training

• Estabirah contracts for Ongoing AEOD curnculum. presentata:.of new PRA curnculum.

• Present revised reactor Ongoing technoicgy courses.

rove courses based on Ongoing 9

4 0 NUCLEAR MATERIALS AND LOW. LEVEL WASTE SAFETY AND SAFEGUARDS REGULATION Regulatory ActMty Objectives Methods Target Lead Status (this Schecale Offee(s) quarter) 4.1 VAllDATE RISK

• Validate nsk anatysis

• Hold a workshop consisting BS4 NMSS ANALYSIS metxx3 ology developed to assess of experte si PRA and HRA to C METHODOLOGY the relative profile or most hkoty examine existing work and to DEVELOPEDTO contnbutors to misedministration provide recommendations for )

I ASSESS MOST for the gamma stereotecte dence further methodologea! I LIKELY FAILURE (gemma knife) development.

MODES AND HUMAN

• Examine the use of Monte 9/95 PERFORMANCE Carlo simulaten and its C IN THE USE OF apphcation to relative nsk INDUSTRIAL AND profding MEDICAL RADIATION

• Examins the use of expert SSS DEVICES judgement in developing error C rates and consequence measures

• Continue the development of

• Develop functionalty based TBD RES/

the relative nsk methodology, with genene event trees NMSS the additen of event tree modehng of the trachvtherapy remote after loader '

• Extend the appicaten of the ' Develop genere nsk TBD metnodology and as further RES/

approaches. NMSS development into additional devees. including teletherspy and the pulsed high dose rate after loader

! 48 CONTINUE USE

• Develop decisen enterna to

• Conduct enhanced OF RISK BS4 PR RES/NMSS support reculatory decision partcipatory rulemaking to C ASSESSMENT OF making tha't incorporates both establish radmiogeal entena ALLOWABLE Final Rule determaste end nsbbesed for decon.missoning nuclear Pubhshed RADIATION engineenng judgement. sites; techncal e"prart for RELEASES AND 7/97 C rulemaking includtri DOSES comprehenstve nskbood ASSOCIATED assessment of resittual WITH LOW LEVEL contamination.

RADIOACTIVE WASTE AND

• Develop uidance for REstDUAL 2/98 ACTMTY.

I ng the radologeal er ena for iconse terminston..

• Work wtth DOE and EPA to the extent practcable to Ongoing develop common approaches, assumptons, and models for evaluating nsks and attemative remediaton methodologies (nsk harmontraton) 4.3 DEVELOP

• Develop a Branch Techncal

• Solicit pubhc comments 5/97 C. NMSS/RES GUIDANCE FOR Positen on conducting a THE REVIEW OF Performance Assessment of a RISK LLW disposal facdity

• Pubhsh final Branch TBD, ASSOCIATED Techncal Positen WITH WASTE Dependent REPOSITORIES on Resources 10

RegulWory ActMty Obrectrves Methods Target Lead Status (tfus Schedule Offee(s) cuarter) 44 RISK

• Develop and demonstrate a nsk

• Develop and demonstrate ASSESSMENT OF B98 Changed (Note 12) assessment for Industnal gauges methods for determining the MATERIAL USES containing cessum-137 and nok associated with industnli cobalt-60 using PRA and other gauges containing cessum..J7 related techrwques and cobalt 60

• The assessment should allow

• Fnal report as NUREG 12s96 for mcdfcaton based on Changed (Note 12) changes m regulatory

• Wcrkin0 Group with &96 requrements Changed (Note 13) contractor assetance to identify and document a

• Use empircal data as much as t.achnical basis for a risk.

practcatde informed approach to the regulaton of nuclear

• Develop and demonstrate nsk byproduct matenal, and to assessment rnethods for develop plans for a graded appicaten to medcal and approach to nuclear byproduct industnel heensee actmtes matenal regulation based on nsk mformaton 45 FRAMEWORK

• develop a framework for

• Provxkt plan for developing 1/98 NMSS Changed (Note 14)

FOR USE OF PRA applying PRA to nuclear matenal framework IN REGULATING uses, similar to the one NUCLEAR deve g'ed for reactor regulation

• Complete framework MATERIALS TBD (SECY-95-280), where appropnate.

1 11

, 5.0 HIGH LEVEL NUCLEAR WASTE REGULATION Cogulatory ActNRy ObjectNes Methods Target Lead Status (this Schedule Offee(s) cuarter) 51 REGULATION OF

• Develop guidance for the NRC

• Assist the staff in pre- Ongoing NMSS {

HIGH-LEVEL WASTE and CNWRA staffs in the use of hcensing actNtes and in PA to evaluate the safety of HLW Icense appicaten revews programs

• Develop a techncal assessment capattityin totab system and subsystem PA for use in hcensing and pre- j licensing revews.

• Combine specialized techncal drsciplines (earth scences and engineer )

with those of s,ystem__ rs ,

i to improve ...u my.

• Idenhfy agnifcant events,

• Perform sensitNtty studes Ongoing NMSS processes, and parameters of key techncallasues ussng effecting total system iterative performance performance assessment (IPA)

• Use PA and PSA methods,

• Assist the staff to maintain Ongoing results and insignts to evaluate NMSS and to refine the regulatory proposed change s to regulatons structure in HLW disposal gove the ootential repository regulaticas that pertain to PA.

at Yucca ntain.

i

• Apply IPA analyses to advise EPA in its development of a l Yucca Mountain regulaten 1

[

~

• Apply IPA enalyses to develop a site-specife regulation for a Yucca Mountain site

• Continue PA activites dunng

• Provide guidance to the Ongr ng NMSS interactions with DOE dunng the DOE on site charactenzation pre-heensing phase of repository requirements ongoing oesign development, site work, and hcensing issues charactenzaton, and repository important to the DOE's design. development of a complete t

and high-quality license appleation.

• Compare results of NRC's Iterstrve performance assessment to DOE's VA to identify major differences /rssues.

3.3 APPLY PRA TO

• Demonstrate methods for PRA

• P opere user needs letter to SPENT FUEL of spent fuel storage facihtes. 497C RUS/NMSS RES.

STORAGE FACILITIES

• Conduct PRA of dry cask 9<99 storage.

3.3 CONTINUE USE OF

• Use PRA methods, results, and

• t,pdate the database on RISK ASSESSMENT End cf FY NMSS insights to evaluate regulations transportation of raccactive 99 IN SUPPORT OF governing the transportation of RADICACTIVE matenals for future radcactive matenal. appications MATERIAL TRANSPC9TATION

• Revalidate the results of &99 NUREG-0170 for spent fuel shipment nsk estimates.

12 v '

A

4

, Notes

1. The general regulatory guide and btandard Review Plan for use of PRA in plant-specific current licensing basis changes will be transmitted to the Commission in the near future, To permit efficient incorporation of the resolution of policy issues contained in these documents into the application-specific regulatory guides and SRP sections, completion of these guides and sections has been delayed until March 31,1998, a change from their previous completion date of December 31,1997.

2. The staffs RI IST team is currently working on a draft SE for the Comanche Peak RI-IST program. The staff and TU Electric have been actively interacting through meetings and discussions as the licensee develops a RI IST program description that is sufficiently detailed and consistent with the draft Rl IST guidance provided in DG 1062. TU Electric has indicated that it would be able to complete a daft revision to their RI IST Program Description by the end of January 1998. The staff will continue to develop a draft SE based on the licensee's responses to the staffs RAls and discussions with the licensee.

Assuming TU Electric finalizes its RI IST Program Description by mid February 1998, the staff anticipates having a completed SE to the Commission on the proposed RI IST program for Comanche Peak in March 1998.

3. The completion date for the Graded Quality Assurance pilot application has been revised to July 1998 to reflect the anticipated issuance date of the final GOA inspection guidance.

4. With respect to the risk-informed TS pilot program, the staf' received a supplemental amendment request from SONGS in early January 1998 tc put the configuration risk management program (CRMP) description into the SONGS TS. The staff will review the CRMP and, if acceptable, issue the risk-informed TS amendments for SONGS. Once similar supplemental amendment requests are received frora the remaining pilot licensees, the staff willissue those pilot plant amendments. Based on information from the CEOG, the staff expects to receive the majority of the supplemental pilot amendment requests in the first quarter of 1998. With receipt of the SONGS supplemental request, the staff anticipates completing the SONGS review as the lead pilot plar:t and issue the amendment by March 31,1998. This is a change from the previous date of December 31,1997, for issuance of the lead pilot plant amendment, because of the decision by the originallead plant not to oursue risk-informed TS changes at this time.

5. The NRR Intipection Program Branch proposals for revising core inspection procedures have been transmitted to the appropriate NRR technical branches having responsibility for l specific core inspection procedures. Due to the large number of branches involved, completing all indivi :ual branch concunences is anticipated to take an additional two months. The revised completion date for this task is February 1998.

6 A deci ion has been reached to generate the risk-informed regulatory documents in a sequential manner, with the application specific guidance following the general regulatory guide and standard review plan. Under this schedule, the regulatory guide for graded QA will be finalized by the end of March 1998. Since the graded QA inspection procedure will be dependent upon the technical content of the companion regulatory guide, the draft graded QA Inspection Procedure will be prepared by April 1998 and finalized in July 1998 after having received appropriate NRC reviews.

13 a

7.

' As part of the IPE follow-up program, the staff is in the process of identifying generic issues to be audited. These issues will be those which have been explic.itly identified and addressed by the licensee as part of the IPE process.

A report that identifies the above generic issues and staff views on the adequar.,y of the proposed resolution is under preparation. The report will provide the basis for the selection of generic safety issues to be audited and selected plants. The staff has moved the completion date for this milestone to March 1998, in order to utilize the report in the audit process.

In addition to the .uove issues, RCP seal LOCA had been identified as a dominant contributor to core damage frequency in many PWR IPEs. The staff has a separate ongoing activity in RES to address this issue under Generic Safety issue 23, and will utilize IPE insights in the proposed resolution.

8. In at SRM (9700207) datsd May 28,1997, the Commission requested that the staff proviie the scooe and Nhedule of activities related to using IPE results to assess regulatory effectianc.s in resolving major safety issues. . lith respect to scope, the staff identified three major safety issues for assessment. The selection had been based on both the potential nsk significance of the issue, and the fact that probabilistic techniques were used extensively in the resolution process. These issues include:

1. Resolution of USI A-44 Station Blackout at Nuclear Power Plants

2. Resolution of USI A-45 Decay Heat Removal Reliability

3. Resolution of USI A-09 Anticipated Transient Without Scram To evaluate the three major issues, the staff will utilize both representative plants, and information contained in NUREG-1560, to audit and draw conclusions regarding regulatory effectiveness. Information generated under Task 1.6 and Task 1.10 will also be integrated into the assessment process. In particular, the RCP seal LOCA and station blackout issues are closely related; the station bisckout analysis in this activity willincorporate the results of the RES seal LOCA analysis discussed in Note 7.

These tasks may expand the staff's consideration cf other safety issues and effectiveness of the regulatory process. The staff willinform the Commission of any additional safety issues that come under consideration. The staff plans to complete it analysin of the three issues by the end of December 1998, and will recommend ai that time any additional staff action.

9.

Due to personnel being assigned to higher priority activities, such as risk-informed pilot initiatives and IPE followup activities, the staff is reassessing their position regarding the development of an SRP, especially since there are no new advanced design certification submittals anticipated.

10.

The staff has reviewed all the 76 IPE submittals and issued staff evaluation reports (SERs) on their findings to each licensee. In three of the SERs, it is indicated to the licensees that the staff was not able to conclude that the licensee met the intent of Generic Letter 88-20 for their plant (s). These three IPEs include Crystal River 3, Susquehanna 1&2, and Browns Ferry 3. The licensee for Crystal River 3 nas indicated their intention to submit an updated analysis (February ;998) addressing the staffs concerns, it is anticipated that the 14

t review of this new IPE submittal will be concluded in June 1998. Discussions are still ongoing wit! licensees regarding Susquehanna 1&2 and Browns Ferry 3.

11. This 'ask has been subsumed into the office operating plan, which is periodically updated.

12. The target schedule for the work to develop and demonstrate a risk assessment for industrial gauges containing ces;um 137 and cobalt-60 using PRA (and other related techniques) has been extended from July 1998 to September 1998. The extension is due to difficulties in obtaining data from non-licensees related to actual and potential doses to the public resulting from gauges which enter the scrap metal cycle.

13. The target schedule for the work to develop and demonstrate risk assessment methods for app!ication to medical and industrial licensee activities has been determined to be September 1998 based on scheduling of a planned Commission paper on the topic.

14. The target schedule for providing a plan for developing a framework has been extended from October 1997 to December 1997 to permit interoffice coordination.

l I

15

4 Attachment 2 Sta# Requirements Memorandum dated May 28,1997 i

i P

/.ES/ DST TEL 301-415-5062 Jur. 03'97 11:15 No.007 P.03 Acticn (Morrison, Nu/

Collins. NRR

• • • t UNffED 5MES Cygg ,Cg))gn g NUCLEAR Rt0UL.AT0ftY C04mm8840N Jon]en y *ApesGTon.or same Thotpson

% AN RESvuNse, FLk:AbE

( -

May 28, 1997 REFER TO g g 70507 Blahe Ross, AE0D MEMORANDUM 70: L. Joseph Callan .

Exec # iv' Director for Operationa FROM:

k(%

Johr v. Hoyle, Secretary

~

SUBJECT:

STAFF REQUIREMENTS - ERIEFING ON IPE INSIGHT REPORT, 2:00 P.M WEDNESn&V, M&V 7, 1997.

COMMISSIOhT.RS' CCNFERENCE ROOM, ONE WHITE FLINT NORTH, ROCXV:LLE, MARYLAND (OPEN To PUBLIC ATTENDANCE)

The countiwmivu was briefed by the NRC stef f en the Individual Flant Examination (IPE) insight report. The Comission asked the st a:l' to expedite activhium in .Le !vilu lug areas: (U using IPE results to prioritize inspection activities: (2) improving regional capabilities for the use of PRA and risk insights; and (3) providin ted inspecttr training, fEDO) MES)j iSECT suspense: wu'p3o 9700206 The Commission asked the stait to provice tne scopte anc scr.edule of activities relar.ed to using IPE results to assess regulatory effectiveness in resolving r.ager safety issues. The comissien stacifically reqv.2ted that the staff provide an estimate cf the average cost to respond to the Staticn Blackout. rule per persen-rem averted 1.n achieving an average reduction in core damage frequency of 2E-5/RY. These activities should be coordinated with the regulatory effettiveness organization, fEBO-) (NRR) (SECY suspense: 6/27/97) 9700207 After the IPE database has been placed on the Internet, the staff should consider allowing licensees to update their IDES voluntarily to reflect changer i.a plant configuration.

(RES)

-d Attachment 3 lPE Follo36222matarn The IPE program was initiated to have licensees evaluato the;r plants for vulnerabilities to severe accidents and to take actions to correct these vulnerabilities, where appropriate. In this process it was recognized that licensees would gain an appreciation of their plant's overall susceptibility to severe accidents which would help in developing accident management tirategies and programs. In this regard the IPE pregam was principally for the benefit o' licensees. Now, however, as a result of completion of the IPE reviews (except for the three plants where comn!stion is still under discussion) and insights report (NUREG-1560), the staff is now in a position to utilize these results to follow up and see if:

any additional plant specific improvements are warranted, licensees have followed through on the actions they indicated they were taking as a result of their IPE, and any additional generic regulatory activities should be undertaken.

To accomplish this the staff has developed an IPE followup program which willinvolve the efforts of RES, NRR and the Regions. The followup program will consist of the following sctivities:

1

1) reviewing the iPE results for risk significant items that may warrant further attention.

Examples of the screening criteria for selection of plants and items for additional followup are as follows:

any contributor with a aCDF' >10-5/ RY or any contributor with a 6LERF2 >104/RY

2) reviewing the IPE results for similar plants and whether or not actions taken by some l'

plants are applicable to other plants of similar design,

{

3) reviewing licensee responses to specific containment performance improvement items identified in the IPE generic letter supplements to see if additional actions are warranted,

4) reviewing the basis for very low risk contributors that appear to be out of line with other plants (i.e., was the analysis overly optimistic and should further action be taken?),

5) assessing licensee stated actions (e.g., safety enhancements) resulting from their IPE to see if, in fact, they have been completed,

' Core Damage Frequency 8 Large Early Release Frequency 1

9 2

6) assessing licensee accident management programs to see if, in fact, they reflect the results, assumptions and actions from the IPE. This action will be carried out through the staff assessment of the licensee's Severe Accident Management Guidelines (SAMG).

7) assessing the results for their implications for the resolution of generic safety issues or other major safety issues.

These activities are in addition to actions already underway to incorporate '.ne IPE insights into the NRC inspection program.

Implementation of this program will consist of RES providing to NRR information related tc activities 1 through 4 above with NRR then discussing with licensees the appropriateness of additional actions. This will provide licensees an opportunity to provide updated information related to these activities and ultimatcly for NRR to take regulatory action, if such action is warranted and can be justified by the backfit rule. Activities 5 and 6 will be performed by NRR, ,

with Regional followup as necessary. Activity 7 is addressed by items 1.6 and 1.7 of the PRA Implementation Plan.

High priority issues identified in the screening process will be pursued as they are identified.

Dates for accomplishing these activities relative to IPE followup are:

RES supply information to NRR on items 1-4 12/98 NRR interact with licensees on appropriateness 6/99 of additional actions for items 1-4 Backfit analysis and actions complete 12/99 Item 5, identify items for Regional followup 9/98 Item 6, identification of IPE insights for Se'. sre Accident 9/98 Management Guidelines The specific IPEEE followup schedule will be developed following the completion of the IPEEE 4 reviews.

. -