ML20198R884
| ML20198R884 | |
| Person / Time | |
|---|---|
| Issue date: | 11/06/1997 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3015, NUDOCS 9711130396 | |
| Download: ML20198R884 (162) | |
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-O OFFICIAL TRANSCRIPT OF PROCEEDINGS V.-
NUCLEARtREGULATORY COMMISSION-ADVISORY COh1MITTEE ON REACTOR SAFEGUARDS
Title:
- 446TH ADVISORY COMMITTEE ON-REACTOR SAFEGUARDS (ACRS)
TR:4 Acas bEU M DR:3:NAL oJWHITE v c; , ,.
Docket No.: Li . ,ii " i rHAnys:
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v-Work Order No.: ASB-300-34 i
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LOCATION: Rockville, Maryland ;
DATE: TtuirsJay, November 6,1997 PAGES:1 - 154 l l'
! 9711130396 97110$
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t DISCLAIMER.
UNI'E O ' ATES NUCLEAR REGULATORY-COMMISSION'S ADVISORY COMMITTEE ON. REACTOR SAFEGUARDS NOVEMBER 6,-1997 i The contents of this transcript of-the proceeding
.of the Uniter'1 States Nuclear Regulatory Commission Advicory.
' Committee on Reactor Safeguards,-taken on November 6, 1997, as' reported herein,-is a record of the discussions recorded
- at the meeting held-on the above date, This transcript had not been reviewed, corrected and edited ar' it may contain inaccuracies, t t
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1 1 UNITED STATES NUCLEAR REGULATORY COMMISSION
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! j 2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3 ***
4 446TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 {ACRS) 6 7 U.S. Nuclear Regulatory Commission 8 TVo White Flint North 9 11545 Rockville Pike 10 Rockville, Maryland 20852-2738 11 12 Thursday, November 6, 1997 13
,_ 14 The Subcommittee met pursuant to notice at 8:30
' )
\ _,/ 15 a.m.
16 17 MEMBERS PRESENT:
18 ROBERT L. SEALE, Chairman, ACRS 19 DANA A. POWERS, Vice-Chairman, ACRS 20 JOHN J. BARTON, Member, ACRS 21 WILLIAM J. SHACK, Member, ACRS 22 DONALD W. MILLER, Member, ACRS 23 MARIO H. FONTANA, Member, ACRS 24 THOMAS S. KRESS, Member, ACRS 25 ROBERT E. UHRIG, Member, ACRS
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2 1 PROCEEDINGS (q-j 2- [8:30 a.m.)
3 CHAIRMAN SEALE: This_ meeting will now come to 4 order. This is the first day'of the 446th meeting of the 5- Advisory Committee on Reactor Safeguards.
-6 During today's meeting. the committee will 7 consider the following: the use of uncertainty versus point 8 _ values-in the PRA related decision making process; proposed 9 final generic letter regarding loss of reactor coolant 10 inventory and associated potential for loss of emergency 11 mitigation functions while in a shutdown condition; NRC 12 safety research program; and proposed ACRS reports.
13 In addition, the committee will meet with Mr.
14 Thadani, Acting Executive -- pardon me, too many adjectives
>O
(,/ 15 here -- Acting Deputy Executive Director for Regulatory 16 Effectiveness, to discuss regulatory excellence and related 17 matters.
18 Members are all in attendance today with the 19 exception of Dr. Apostolakis. It seems that he was called 20 to a higher duty as a member of a jury panel in 21 Massachusetts this week. Dr. Kress will deputy for him in 22 the presentations <nt PRA point values versus uncertainty 23 questions.
24 The meeting is being conducted in accordance with 25- the provisions of the Federal Advisory Committee Act.
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43 1- Dr. John T. Larkins is the designated Federal
() -2
~3-official for'the initial portion of-the meeting.
~
We have received no written comments or requests-
[
4' for time to make oral statements from-members of the public 5 ,regarding today's sessions.
- 61 A_ transcript of portions _of the meeting is being 7 kept and it is requested that the speakers use one of the 8_ -microphones,cidentify themselves, and speak with sufficient 9 Eclarity and volume so that they'can be readily heard.
'10 I will begin with a few items of current relevance 11 and interest. Before I do though, I'd like to remind 12 everyone that we have a transcriber-today who perhaps is 13- still getting used to'the particular fuddles of this 14' ' committee, and I'm sure we drove him to the point-of *
) 15 frustration and agony in the meeting of the subcommittee the 16' last couple of days, and I would ask the members to have a 17 little bit of good manners in interrupting each other and so 18 forth, so we don't tax him too much.
19 DR. KRESS: He's not a newcomer. He was here when
- 20 Lewis and'--
21 CHAIRMAN SEALE: I'm aware of that. When I first 22 came on the-committee, he was a regular. I remember that.
23- 'Somehow, this. strikes me as an e.:t'which one may never 24- exactly forget how to do, but on the other hand, there-are 25 probably-contortionsLthat we require or at least present f ANN RILEY & ASSOCIATES, LTD.
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4 1- which may be a little bit difficult.
( ) 2 _Today, among other things, we have interviews with 3 a suggested candidate for membership on this committee, and 4' you have a schedule for those interviews. Dr. Corcoran is in 5 the room and I think everyone knows him. He will be 6 available for you to talk to later.
7 I have the rather painful duty to remind -- to 8 mention to everyone that Dorothy Shewmon, the wife of Paul 9 Shewmon, passed away about two weeks ago. Most of the 10 members of the committee and almost all of the staff, both
-11 ACRS and other NRC staff members, remember Paul, who was 12 chairman of the committee five years ago. Dorothy was a very 13 tough and brave lady who suffered through quite a bit of 14 difficulty for several years. We certainly send our 15 condolences to Paul.
16 DR. MILLER: Bob, I'd like to mention I did go to 17 the memorial service on Saturday and did stop and see Paul.
18 It was quite crowded, as you would expect.
19 CHAIRMAN SEALE: Thank you very much.
20 Among the more normal or usual items of interest, 21 we have a series or a pack of items that the staff has 22 collected for us since last time. There are three speeches 23 by Chairman Jackson, I must say all of which we probably 24 should read with considerable attention because first of 25 all, comments on the International Nuclear Regulators
/
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5 1 Association, something about future trends in nuclear safety Oj 4 2 research, which we probably all could stand to digest in 3 more detail, and the NRC's strategic direction in issues 4 affecting agreement states.
5 There is also a list of some six civil penalties 6 that have resulted from recent enforcement activities. For 7 those of you who were in the meetings the last couple of 8 days, a quick scan indicates that at least most of those 9 involve clearly defined safety issues.
10 I would urge you to go over those. I think it 11 helps calibrate one's feeling for exratly what is involved 12 in some of these enforcement and civil penalty issues.
13 DR. KRESS: This list seems to get longer.
14 CHAIRMAN SEALE: Well, certainly the average value A
klm 15 tends to go up, too. I think that's -- finally, there's an 16 article in here -- well, the other two articles are 17 interesting, but there is one particular article on the 18 Cuban nuclear power plant construction process that all of 19 us, I'm sure, will find of interest.
20 DR. MILLER: I wanted to note that one of those 21 penalties was for Ohio State University, but it did not 22 include the OSU nuclear reactor laboratory.
23 DR, BARTON: Penalty? Was it interference or 24 holding?
25 (Laughter. ]
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1 CHAIRMAN SEALE: Clipping.
A-() 2- [ Laughter.)
3 DR. KRESS: Osing two with the wrong cleats on a 4 wet-field.
5 CHAIRMAN SEALE: I think it's an interesting 6 situation, but I think -- my experience is for the people'in 7 the radiation protection business in universities, the 8 -reactor is a piece of cake and the isotopes related research 9- and biosciences in the medical school just drives them up 11 0 the wall. The Physics Department doesn't help on occasions 11 either.
12 Well, are there any other comments or questions 13 that any of the members would like to bring to the attention
, 14 of the rest of us?
! )
\._/ 15 [No response.)
li6 CHAIRMAN SEALE: One other item before we go on 27 with the program. We have a list of reports and letters 18 scheduled. That list has grown-with a couple of items.
19 There is the proposed final generic letter on loss 20 of reactor coolant inventory. That's a proposed Priority A 21 letter. I guess we've just about got a draft on that?
22 DR. BARTON: We have a skeleton, 23 CHAIRMAN SEALE: We have a skeleton. We should 24 plan to get that out this meeting.
25 There's a proposed letter on the AP-600 schedule.
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7
'1_ -We have a draft on that. We really:should tryLto get=this
() 2 to the stafffthis~ time because'this-AP-600-looks like~a 3- juggernaut that is coming down the way. We need toilock~
- 4 ourselves into;the appropriate steps. Of-course, all of1this 5' is-hostage _to getting the appropriate materials on the-6 schedule, and in-fact, you will see some options on the- -
~
7 ~ scheduling', at least in some of the versions I've seen. i 8 _
There's a letter that we are proposing to send to
.9 Mr. Hanson with Consumers Energy regarding some questions 10 that have arisen as to the way in which particular problems 11 -were addressed. We will get to that a little later.. There 12 is also a draft on that that will be available. We would 13 like to get tF t one out today, tco.
14 The e two other reports. One is in fact a
- 15 progress or in progress work draft-that we would like to get l
l- 16 out on the annual report to Congress on the NRC safety 17 research program. We held subcommittee meetings the last 18 'two days on that. Hopefully, we will have something -- we 19 will have a report from Dr. Powers, who is the chairman of 20 that subcommittee, during this meeting. We will nail down 21 the schedule in some greater detail.
22= Finally, there is the useuof uncertainty versus 23 point values in the PRA related decision making process. Dr.
24: Apostolakis is the chairman of that subcommittee. We will 25 hear a report from the staff on that issue today and we-will ,
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8 1 discuss, try to define and give some feedback on the things
/~N i ) 2 that should be contained in a letter which will hopefully go
</ .
3 out during the December meeting.
4 We also have a PRA related subcommittee meeting 5 coming up next week. That whole process is in a 6 considerable -- well, a state of flux right now, although I 7 think things are converging, but there's a lot of work going 8 on there.
9 Tom will be acting, as I indicated, for George on 10 that matter.
11 Any other problems? Sam, do you have anything 12 else that I should be sure to do?
13 [No response.)
.14 CHAIRMAN SEALE: Well, the first topic on the
) 15 agenda today is on the use of uncertainty versus point 16 values in PRA. I'll ask Dr. Kress to introduce our speakers 17 and make any other comments he might wish to make.
18 DR. KRESS: Thank you, Mr. Chairman. I am a last 19 minute substitute because George was called to jury duty. I 20 can't imagine any defense lawyer in his right mind selecting 21 George.
22 [ Laughter.)
23 DR. KRESS: Apparently he has to be there just to 24 be rejected, I guess.
25 VICE CHAIPl.iAN POWERS: Does.that presume that you
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9
-li thin _k.the prosecution-would?--
02? DR. KRESS: 'Yes,-definitely. - -
33 ~ [Laughte r . ) .
- 4. l-CHAIRMAN ' SEALE : I.would think.only'iflone is.-
-- 5 ; interested in-lengthening-the; proceedings
- 6. -DR. KRESS:: As'you mentioned, Mr. Chairman,--the,
.7 purpose ofLtoday3s--briefing is.to continue"our review of-the
-8 question of uncertainty versus point values in PRA related-This was- an SRM item that was: senc to us
~
' decision making.
t10 'with an SRM-dated May 27th. >
-11 We are-also going to discuss, I think, the 112 proposed. reconciliation of_public comments on'the RP 13 Chapter 19 and~DC-1061,1both of'which are part of the: PRA 14 ' risk 4.nformed decision making: process.
15 CHAIRMAN SEALE:' Tom, could..I'ask you a question --
16 -on that?-
DR. KRESS: Sure.
18 CHAIRMAN SEALE: Are the topics-there getting so-19- .far afield that we might be well advised to split them and 20- -address different issues separately?'
1 21 lDR . KRESS: Well, of course, the question of J22 uncertainty is part and parcel of the whole question of f23 .using.PRA in' decision making. It's integrated, it's part of 24- it.
25 i CHAIRMAN SEALE: It's.a coherent' package.
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10 1 DR.-KRESS: It's a coherent system; yes.
)'
, -2 CHAIRMAN SEALE: Okay. I just wanted to double 3 check.
4 DR. KRESS: In' fact, George had earlier prepared a 5- -list of questions and issues that we might want to discuss.
6 I think you will.tind those under tab two, along with other 7 background material. I won't try to summarize any_of that 8 at this time.
9 I will-note that during the last subcommittee 10 meeting, v:hich was October 21 and 22, we had an extensive 11 discussion. I won't say we bogged down but we had extensive 12 discussions on the kind of figures one might use for the 13 criteria on the use of CDF and LERF. A lot of the discussion 14 centered around whether or not we should have bright lines i 15 or fu==y lines.
16 VICE CHAIRMAN POWERS: This was the diagram again?
17 DR. KRESS: The diagram again. I don't know if 18 you recall, you should have received --
19 VICE CHAIRMAN POWERS: Yes.
20 DR. KRESS: -- a George straw man example of a 21 fu==y line diagram, which I frankly didn't care much for.
22 VICE CHAIRMAN POWERS: It was pretty fuzzy.
23 DR. BARTON: I'm looking for the lunar module on 24 that fu :y diagram. '
25 DR. KRESS: Anyway, maybe we will get involved in
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l11
--li that discussion again,;too. With'that,:-I'11;: turn the
-2C meeting overito theEusual suspects,-is it,+ Bob?: c
- 3 CHAIRMANJSEALE:-~Yes. -What didiyou guys do with- _
4^ _ Mark today?,
- MR KING:'! Mark is-working on'.theLregfguide.-
-6x -SPEAKER:- I_saw:him taking off-the-other way.- .I -
~
7- said I thought he was lost...
8: MR . : KING: My name is Tom King from the Office of
'9 Research. I have here_ Gary Holahan and-Gareth Parry from 110 NRR. As-.I-said,'even though this slide says Mark, he-won't 11 bSLhere this morning.
12 What we wanted to do was summarize what we talked 13 to the subcommittee about:on October 21'and 22, which,would 14- be a quick review of the public comments, at least the major 15 _ones received on the draft regulatory guides and SRP. We
' 16 - want to review-again the policy issues. We had talked about
-17 six policy issues at the subcommittee meeting. It's now L18 down to four. We will talk about those.
Very_briefly, we will highlight the major changes 20- -that we are considering making in the reg guide. We are not 21 requesting a-letter at this time, but we will be at the 22 December meeting.
23 CHAIRMAN SEALE: What timing.
24 ;MR.-KING: As you recall, when these guides were 25 putitogether'as draftsiand issued for:public comment, they
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12 1 'all:came as a package. There was-a draft guide 1061 and its
-[ j
%J 2 SRPIthat had general guidance-and then there was specific 3: . guides on IST,' tech spec's andJgraded QA and-their
- 4. associated SRP's.
5= Where we are now is we've got an extensive set of 6 comments from the public. We are on a very tight schedule 7 to get -- we are on a tight schedule'to get these done by.
8 the end of December. Our plan now is to focus at this point 9 on the general guide and its SRP and try to get that done by 10 December.
11 We are going to-proceed in parallel with doing 12 that with a paper to the Commission on the policy issues and 13 in parallel with the Commission reviewing those policy 14 issues, we will be trying to develop a final draft of tho
) 15 regulatory guide and SRP, the general guide and SRP, 16 consistent with our recommendations in that policy paper, 17 We are going to defer work on what we call draft 18 NUREG-1602, which was really a draft document that tried to 19 describe what we felt were the attributes of a quality PRA, 20 and we will talk about some comments we received on that.
21 Then we have a plan to come back and visit the 22 _ application specific guides after we complete the general 23 guide, and then make those consistent with the general guide 24- and incorporate the comments then, and the schedule for 25 doing all this is shown on page three, where we plan
/
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13 1- -tomorrow to~get youca draft of=the general guide and SRP for
() 13 2 ' review ~
week.
. The: policy paper, we hope to get up in3about a-It's'in concurrence now.
[
4- As you mentioned, we have a meeting with the i
.5 ' subcommittee next week.- We will: come back tx) the full 2
6 committee in December and discuss the proposed. final-draft, l
- 7. general guide'1061-and its SRP, get that to the Commission 8 -the endLof December and then come back in February with the-9 revised application specific guides.. Hopefully, get a letter
- 10 after your March full committee and get those to the 11' Commission. -The schedule calls for-the end-of March.
.12, There is also a guide on ISI, which is on a 13 somewhat later schedule.. It's due to the Commission the.end 14 of April.. We are not goi'ng to talk about that today.
15 Public comments. We-issued the package of guides 16- for comment back in June. We held a workshop in August. It 17 was attended by about 150 people, as I remember. The 18 comment period closed the end of' September. We got a little 19 over 40 sets of comments. Attached to the end of this 20- package _are the four pages that show who the commentors were 21 and what documents _they commented on. - We also have a more 22- detailed summary, at.least for the general guide and SRP, of
.23 what those comments were. If the committee is interested,
'24 we can certainly make it-available to you.
25 lWhat I wanted to do in these vu-graphs.is just go J ~
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~ , w
l 14
~
1 -- _through_the more major-set of comments. We have broken 2 those down'into basically seven categories.
- They are shown-3 on-page!five. I will go through these. fairly quickly.- We- 1 4- have a'vu-graph on;each of these seven categories of 5 comments. i 6 -Starting with comments on draft NUREG-1602, there -
7: was a' lot of confusion about what we were_ intending by 8 issuing 1602 and. referencing it'in the general guide. Our 9 intent was to put it out as useful information for licensees ;
10 to_use when they are trying-to make decisions on what's the 11 quality and scope and depth of analysis they need to do for 12 an' application.
13 The intent was they could look at this and decide, 14 do I need to go into this much depth or can I do something 15 -- you know, if I'm just doing some sort of prioritization 16 -or risk rankita, maybe I cannot do such a rigorous L 17 traatment.
18 It turned.out as being interpreted that the NRC l 19 wants a gold plated PRA for every change that comes in here.
20 'At this point, what we are doing is we are not going to 21 issue NUREG-1602 as a final. We are going to use it as sort
- 22. of a starting point to help develop-a standard.
23- We have started at least initially an activity _
24 -with ASME to scope out sort of the scope and depth of a
'25 standard and: hopefully' work with them over the next 12 to 14 l
I L i 'K i
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l 15 1 months to see,if we can' develop a standard.
- 2 -We are going to remove references to.NUREG-1602-2 3- from the reg guide and in the interim, we will substitute. j J
-4 some general ~ description of what;weithink about.PRA quality Si in the. reg guide. l 6- There were also a lot of detailed comments onJ1602 l 7 =which will be' dealt with as part of_trying to work on a I 8 standard.
.9 DR. KRESS: - Will that general description in the 10 reg guide be individually tailored in the various sub-11 elements, like-ISI? ,
12 MR. KING: No.
13 DR. KRESS: It will be all the same?
14 MR. KING: It will get into level 1, 2 and 3, 15 external events, internal events, that kind of thing. No, 16 not application specific stuff.
17 DR. SHACK: It.will be put in 10617 18 MR. KING: It will be in 1061. 1061 now has a 19 section called PRA quality, which really deals more with the
.20 traditional quality assurance type of things, and it's_now 21 _ going to have two. parts, the traditional quality assurance-22 --and then a new section that deals-with the qualityLof the
-23 PRA 24- The second category had to do with what we call 25 -acceptance guidelines,/and that was primarily the ANN RILEY & ASS'OCIATES, LTD.
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16 1 probabilistic' acceptance guidelines we had in the document.
'q i
2 All of our policy i~ sues stem from the comments
(~-).
3 that we received in this particular category, and what I'd 4 like to do,:when we get to policy issues, we will talk about
-5 the very small risk increases, the treatment of 6 uncertainties,-_ temporary changes and shutdown, guidelines 7 for shutlawn. We can talk about what the comments were 8- then.
9 The other two items, the first item, use of the 10
-10 to minus 4 per reactor year benchmark on CDF. There were 11 some comments that we really shouldn't worry about the 12 absolute CDF, our guidelines should really deal with the 13 changes and the trends that are taking place as these 14 various submittals come in.
15 We basically still believe that the use of some 16 benchmark values for both CDF and LERF are useful, and they 17 are retained in the guidelines in a little different fashion 18 than they were in the draft, and we will get to that.
19 We are not raising to the Commission a policy 20 issue of removing those benchmarks on CDF and LERF 21 guidelines.
22 DR. KRESS: I think if you did not have those in 23 there, your whole system would just be completely -- I don't 24 think you have a' system without that.
25 MR. KING: Yes. That was a policy issue we had i ANN-RILEY & ASSOCIATES, LTD.
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17 1 talked about at the subcommittee, but at this point, it's n
(,,) 2 not a policy issue because we decided not to go back and do 3 anything different in that area.
4 DR. MILLER: I thought the comments are more on 5 focus versus absolutes. The comments focus on changes, not 6 necessarily remove --
7 DR. KRESS: I don't know what that means. Of 8 course, they are focusing on change, in the context _of where 9 you are in terms of absolute, and I don't see any other way 10 to do it.
11 MR. KING: The last bullet, guidelines for use of 12 level 3 analysis. We have not gone in and put in separate 13 guidelines that are based upon the OHO's, for example, 14 although I think there may be some role when you get into 15 what we call management attention, Region IV, level 3 16 analysis, and that's where we would tend to put some 17 additional words in the guide, to talk about if you are in 18 that region, perhaps looking at level 3 information might be 19 useful. It wen't be the deciding factor necessarily, but it 20 might be an useful piece of information to look at.
21 DR. KRESS: It seems to me like when you get into 22 that level 3 part, you need to face up to still retaining 23 the 10 to the minus four.
24 MR. KING: Yes. To me, you still have the ten to 25 the minus 4, but if you are worried about uncertainties,
(
A
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18 1 maybe.looking at level 3 information could help settle some i ) 2 of'the uncertainty questions or at least put them in 3 perspective.
4 The third category, integrated decision making.
5 If you recall, this involves the traditional engineering 6- analysis, the probabilistic analysis and then the monitoring 7 and feedback program that would.go along with the change.
8 When you look at all three of'those things, how do you make 9 a decision.
~
10 Again, there were some comments that talked about 11 not using the absolute CDF and LERF, and also in the tech 12 spec guide, some absolute limits on conditional core damage 13 probability, which were comments received to remove those.
14 Again, we are not proposing to do that at this point.
l
) 15 There was some discussion on better defining what 16 we mean by " defense-in-depth and safety margins." We are 17 taking a look at the words in the guide. I don't think 18 there will be any major changes in that area, but we might 19 be able to add some additional clarification.
20 They wanted a better definition of what we meant 21 by " increased management attention." We plan to expand th:t.
22 Provide guidance on bundling of changes. Bundling 23 is can you take changes, for example, in IST, that look at a 24 bunch of systems, and on one system, the risk may go up, 25 another may go down, you add them altogether and look at the A
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19 1 aggregate. We think bundling is something that is
-s acceptable, provided it's done within certain guidelines and (v) 2 3 the guide will have some words in it on what we think these 4 acceptable guidelines are.
5 DR. MILLER: Are you' going through those 6 guidelines today?
7 MR. KING: I can talk in general about them. When 8 you get the guide tomorrow, you will see more specific 9 words. I'd like to really defer any detailed discussion on 10 the guide until next week.
11 DR. MILLER: You will have it next week at the 12 subcommittee meeting?
13 MR. KING: Yes.
14 MR. HOLAHAN: I think the key to the bundling O
\ms/ 15 issue is we ought to insist on the bundling of related items 16 and what does it mean for issues to be related versus 17 completely disparate.
18 I think when we talked with the subcommittee last 19 time, it became clear that if you are dealing with unrelated 20 changes, you can get-into some very complicated things that 21 you wouldn't have approved otherwise. That's probably not 22 what we want to do.
23 MR. KING: Lastly, there was some requests for 24 more guidance on what we meant by how we balance qualitative 25 and quantitative risk evaluations. We are trying to expand
[\
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20 l
~
1 somelof the-discussion on the qualitative aspects. ;
() 2' t Licensing issues was another category 1of comments.
3- ALnumber ofLpeopleitook issue with the definition ~of ,
" i 4 current licensing; basis" which1we used, which was the Part 5 54111 cense renewal definition.
6 Really, I don' t see any change in .that- area. The 7 things that'have to come in for approval, they aren't going 8 toJchange-as a_ result'of this guide. If a licensee makes a 9 change'without._ coming to NRC, this guide doesr't change'that 10 either. Whatever normally comes in for us for a.oproval, it-11 would still normally come in for us for approval, i
..t's just 12 it would come in -- the licensee has a choice to use this 13 guide when he makes his submittal. I don't see'any chenge 5 The issue of 50.59 came up in terms of can't some 16 of these changes be done by the licensee. I think that's a 17 separate issue that we are not dealing with as part of this.
18 I understand there is a separate Commission paper at the 19 Commission on 50.59, including the issue of risk informed 20 50.59.
21 DR. KRESS:. Isn't it geared towards this process
-22 rather than --
o 23 MR. HOLAHAN: 't's the staff's recommendation.
24' -The-staff offered a numbu. . alternatives to the 25 Commission, and I would say at least two and maybe three of
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-e n
' 21 -
- 1? the five alternatives are.either_ drifting'or rushing in'this fT g 12.
di.rection; 13- _(Laughter.)-. "
4- DR. KRESS:1 Towards. ;
5: DR.: SHACK: ""cherent" is the word.-
6- CHAIRMAN 2SEALE: Rational.
7- MR. KING:- There was concern from licensees on the
.8- burden this process. puts on them. We-talked about the gold 9 -plated PRA concern. There was concern about being able to 10 build more on the. maintenance rule requirements in terms of-Lil: categorizing system structures and components using 12 performance monitoring from the maintenance program, not-13 having to-develop a separate program and so forth.
14 I think our general-approac1 s to try and allow i 15' ' building on the maintenance rule as much as possible. We 16 will try to clear that up in the guide.
17 There was a concern on monitoring corrective 18 action and focusing too much on risk monitoring on low 19 safety:significant-components. It was unclear when you do 20 the_ monitoring-and feedback and you find out you want to 21 make a change, do you have to come back in with another 22 submittal,.what kind of reporting requirements are necessary 23 Las you collect this monitoring information, does it have to
'l 2 <4 be reported to NRC. The guide sort of was silent on a lot 25 of~that, and we are going to try to clean that up.
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1 MR. HOLAHAN:' IfiI~can go back a: step, this idea j L2 that:there1ought-.to:be more coherence between the
' maintenance rule and the risk informed: activities, I think !
3 E=
4 it is being reinforced by maintenance rule change 5 considerations-that the Commission hassunder consideration.
1
-6 -Even the last guidance document the staff put out-7 on the~ maintenance rule'has a reference in-it that in the 8 ' future, asi t hese reg guides and the_ philosophies are worked
-9 ' o'u t , we expect it tx) be used more-in'our. guidance documents
- 10. for the maintenance rule.
'11 In our last. endorsement of NUMARC 93-02 Rev. 2, 12 - which is-the industry guidance document for the maintenance 13 rule, there's-a. footnote that identifies that we intend to
- 14 . move in the-direction-of making our maintenance rule 15 expectations consistent with what's in these guidance 16 documents. Although those are sort of in a developmental 17 process, they are also -- I consider them converging.
.18 I think the rule change that the Commission is 19 considering, the so-called should/shall rule change related 120' to assessing-maintenance activities, it seems to me that's 4
21 going-in the same direction as well.
22' DR. KRESS: That's the right way to go.
23- CHAIRMAN SEALE: I wantLto clarify something.here.
= 24 We keep. running into this situat' ion where people worry-about -
o25 being too-prescriptiveLbut on the other hand,'they.want more ANN-RILEY & ASSOCIATES, LTD.
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23 1 guidance inforder?to narrow-or-to better define'what_your.
] )
~
2- expectations"are.
-- e ll; Tellime what the meaning-of dash one under: bullet 4L _three, more_ focused _ guidance needed, too much expected, does
- 5 -; that mean that they want --
6' MR. KING: That got into the concerns of we are 7 asking for too much monitor.ing, maybe on low safety 8 significant components. They read it as everything-that 9 .they: monitor has to be reported to NRC. They were concerned K10 that it;they. wanted to~make a change based upon their-
[11: monitoring feedback,_they'd have to come back to NRC,
- 12 CHAIRMAN SEALE: So what they are saying is you 13 -have been too diffuse in your definition of what the 14 monitoring requirements are, they'd like_for you to be_ morel 15- specific and limiting.
16 MR, KING: Yes, I think clearly, we need to be 17 more specific, 18 MR, HOLAHAN: Limiting on oUr expectations.
19 CRAIRMAN SEALE: I understand. It's that horse 20 race, 21 MR, HOLAHAN: Yes.
22 CHAIRMAN SEALE: Both ways.
-23 MR. KING: The'last bullet referred to section y
24 'threeLofuthe: guide,-which was what'needs to be sent in as
- 251 -part of the submittal. 'I think we are re-looking at that, ,
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24 El =We probably;askediforz too:much-in the draft-guide. -
We;will-() :2 ' reduce that somewhat.
3: Then there were concerns ~on the staff--review-14- process. ;These don't really affect the guide. .I think they !
5 will affect some:of the things we are doing to get ready to -l 6 process more applications in this' risk informed fashion.
7 -There war concern about inconsistency among' ;
8 reviewers,_whether'it's the tech spec reviewer versusLthe-
-9 IST reviewers and so.forth, whether there-would be common-p 10- interpretation by headquarters and regional offices,-and-
~ 11 what they called bringing complex issues to closure. ~The 12 concern was we have-some of these pilot programs underway, 13 some of-the applications there were felt to be pretty 14 tsimple,- straightforward things to change and-it has taken'18 O
\_,/ - 15 months.to change them. What's it' going to be like when you 16: get the tougher ones?
17- CHAIRMAN SEALE: Are you going to tell us what you 18- are going to do about that?
19 MR. KING: Because -- I'm not sure because of 20- these comments but certainly what's helping to address these 21 is we have a fairly extensive' training program starting.
oGary is doing!some in-house discussion with the NRR. people
~
22 i
23- .that are ac^ually going to be_doing the reviews, get-them bt all.to present a consistent story.and approach in~ terms of h '25 what these guides-say and what the SRP says. We have more-J ' ANN'RILEY'&= ASSOCIATES, LTD.
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25 1 detailed training for managers, for regional people, being
-yf3,) 2 done by the training center in Chattanooga.
3 There's a-whole series of sort of -- I'll call 4 them almost required courses that we want people to take 5 that are going to be dealing in this risk informed arena.
6 CHAIRMAN SEALE: Yes. We received a schedule on 7 your managers' PRA training yesterday. I think several of 8 the committee members are looking forward to taking the 9- final examination that goes with that course.
10 MR. KING: Gary took it.
11 MR. HOLAHAN: I took the course myself last month.
12 I highly recommend it.
13 DR. MILLER: They don't give an exam in that 14 course, do they?
x, 15 MR. < ' AHAN: That's one of the things that makes 16 it highly recommendable.
17 (Laughter.]
18 DR. BARTON: Sign me up.
19 DR. KRESS: These set of concerns, you could 20 almost make them general for anything.
21 MR. HOLAHAN: Yes. These are the normal concerns 22 for our regulated industry, I think.
23 CHAIRMAN SEALE: Well, the reg guide is the first 24 step.in addressing those issues.
25 MR. HOLAHAN: Yes.
I\
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26 1 CHAIRMAN SEALE: The next question is are you (3
s_-) 2_ going to follow through, 3 MR. HOLAHAN: Exactly. We have spent the last 4 almost two years, developing guidance documents exactly for 5 the reason, you know, to introduce consistency and 6 appropriate standards into the process.
7 MR. KING: The last category is called 8 implementation issues. There was some concern about what do 9 we mean by tracking cumulative changes, who is doing that, 10 how are we going to use the information. What we expect is 11 licensees to keep track of their cumulative effect of their 12 proposed changes or changes that are implemented.
13 We also are going to do some of that -- some over 14 check of that by the staff. Exactly how we are going to do q
ss/ 15 that is yet to be worked out.
16 We are going te put in draft guide 1061 some more 17 discussion of the cumulative trackinn, cumulative changes 18 and what that means, what we are looking for.
19 MR. HOLAHAN: We haven't entirely settled on these 20 things but there are two thoughts that were raised recently 21 that I like, and one is there is a little too much emphasis 22 on management attention, when in fact what we mean in a lot 23 of these cases is the staff reviewers are going to spend 24 more attention on the subject also.
25 A little bit of the flavor of want more attention O
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r 27 I 1 means, we are going to provide some discussion on it. l
() 2 The other I thought was an useful comment was what 3 Dr. Parry made the other day, which was a lot of these 4 issues, like the cumulative effect and additional attention '
5 are really not PRA issues. They are really integrated 6 decision making issues.
7 We (4rb thinking about whether they belong as a PRA 8 engineering section of the guidance document or whether they 9 belong in the broader decision making guideline part of the i
10 document. That might also help put them in better 11 perspective.
12- CHAIRMAN SEALE: But at least you need something 13 in the PRA document that would say something about the 14 quality requirements on the input that would be necessary in 15 d order for it to qualify as part of the integrated decision 16- making process.
17 MR. HOLARAN: Yes, exactly. Tom mentioned that 16 section is being strengthened as well.
19 CHAIRMAN SEALE: I have another question for you.
20- Are you in here going to make the point that the CDF is a 21 time dependent parameter or let's say plant status dependent 22 parameter, shutdown or not?
23 MR. HOLAHAN: Yes, it's clearly a-plant status 24 dependent parameter, and we would expect licensees, if they 25 are looking at their plant for an operating period and a ANN RILEY & ASSOCIATES, LTD.
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28 ;
1 shutdown period, to look at that differently. If they are i r~s
() 2 shut down for one month out of the year, to adjust their CDP calculation to reflect that period of time.
l 3 :
i 4 CRAIRMAN SEALE: Or if a diesel is out for two :
l F days for maintenance.
i 6 MR. HOLAHAN: Well, Tom is going to do a 7 discussion later on temporary changes. I think we haven't 8 quite Pettled on that issue. Clearly,.we are interested in 9 the effect that each of those temporary conditions has on i 10 the total. Whether and how much additional attention you 11 should ha /e on that particular point in time, above and 12 btyond its effect on the long term average, is an 13 outstanding question.
14 DR. KRESS: The issue of cumulative changes, it 15 seems to me like it better fits over in the integrated 16 decision making but that if you have a living PRA, it will 17 automatically show up in that part, should automatically.
18 MR. KING: Yes. The comment noted on the third 19 bullet here is with the tracking of cumulative changes, are 20 we in effect requiring a living PRA. Since this whole thing 21 is voluntary, we are not requ.fing it, but I think if l 22 somebody wants to do it right, they in effect are going to 23 have to have a living PRA.
24 MR. HOLAMAN: Or maybe a re-incarnating PRA.
25 DR. KRESS: That may be better, every so often.
()
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29 1 MR. KING: The second bullet here, we call limited 4
() 2 scope submittals. This was an item we had talked to the 3 subcommittee about as being a policy issue. This is one 4 that we are not calling a policy issue any more. We think 5 it's more of an implementation issue in that limited scope 6 submittals can be consistent with the intent of risk ,
7 informed regulation. .
8 The concern it. caused us initially to think of it ,
9 as a policy issue is licensees may come in and just go for ;
i 10 burden reduction type chcnges that increase risk.
11 I think there clearly could be some burden reduction changes 12 that decrease risk as well. ,
13 I think we can put some guidelines in 1061 that 14 say whether it's a full scope or a limited scope, if they
() 15 are really applying the intent of the PRA policy statement 16 and risk informed regulation, which is not just to reduce 17 burden at the expense of increasing risk, but to take a 4 18 comprehensive look -- well, if they want to take a limited '
19 look and it results in a risk reduction, that could be okay, t 20 too. We are going to try to deal with that in putting some 21 guidance in '.J61 regarding acceptable scope of changes. You 22 won't see this as a policy issue any more.
23 That moves us to slide 13 which is the titles of 24- the four policy issues that are in the paper that is in 25 concurrence right now.
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30 1 We' talk about the issue of very small-changes in
() 2 3
CDP and LERF; treatment of uncertaintiest guidelines for shutdown operations; guidelines for' temporary-plant-4 configurations.
5 We start off with very small-risk increases. If-6_ you recall the draft guide that went out for comment o 7 : basically-said if you'want'to propose a= risk increase as 8 part of your change, that your baseline CDF and LERF had to-9 be-below what we called guideline values, ten to the minus 11 0 four for CDF, ten to the minus fifth for LERF. Otherwise, if 11 you were coming in, if your baseline was above those values, 12 your change had to be risk neutral or a risk reduction, 13_ There were comments on what do we mean by risk 14 neutral. Itc it have to be zero or can it be a really small
( 15. band around zero Also, comments that, gee, that's not-1G really appropriate in the sense that it could cause us-to 17- focus on very small risk increases and not be able to make 18' changes or do something that made sense just because we have 19 a calculated small risk increaue, which really- runs counter 20- to risk informed regulation.
21 We really want to focus on the more risk important 22 things, not these small little' changes.
23 VICE CHAIRMAN POWERS: I just never understood 24 that section. Your CDP has to be-below this value if you are 25 ' going to; propose changes that increase risk. I just ran a ANN RILEY &-ASSOCIATES, LTD.
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31 ;
1 ground there. How do I know? It tells me elsewhere in the (A) 2 document that, gee, if you are going to estimate CDP, you 3 have to include risk during shutdown operation, you do that 4 qualitt.tively. I think it actually says it may be better to 5 handle this qualitatively.
6 If I've got some substantial block of my CDP 7 probability that's qualitative, I have very little idea 8 where I am there, except I know I'm high, low or medium.
9 Now, I'm worried about some increment that is demonstrably 10 low. I mean those definitions of "small." ;
11 MR. KING: I think you are making part of the case 12 for why to us it makas sense to go and define a band of what ;
13 we call very small, where it shouldn't be tied to the 14 baseline because even if you have a PRh that only looks at
\ 15 power operation, you really don't know where you are on the 16 baseline scale because you haven't analyzed these other 17 modes.
18 Whether or not you even ana?.yze those other modes, 19' this change is so small, it isn't going to make any 20 difference in terms of really adjusting where you are.
21 That's one of the reasons we felt that defining that small 22 band made some sense. It doesn't then force licensees to go 23 in and do shutdown analysis when we are talking about 24 something that is very minor in terms of risk. They would 25 be spending resources to do something that's got a very
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1 minor risk impact.
() 2 We wanted to try and get out of that and allow a 3 little more flexibility. What we are proposing is a band t 4 above me.*o that we define for CDF, if changes in CDF are ;
5 lest than ten to the minus six, or changes in LeRF are less 6 than ten to the minus seven, we will call them very small, P
7 and tnose changes won't be tied to some baseline value.
8 DR. MILLER: Wait a minute. Does that mean that-9 .tbe CDF still has to be less than ten to minus four?
10 MR. KING: No. Maybe the easiest way to look at it 11 -- when I found out George wasn't going to be here, I stuck 12 a figure in, a hastily drawn figure. !
13- (Laughter.)
14 DR. BARTON: It's better than the moon shot up O 15 there.
16 MR. KING: Nevertheless, a figure. The idea was 17 trying to explain what we mean Before, we had a limit on 18 delta CDP of up to ten to the minus fifth and a baseline CDF 19 of ten to the minus fourth. The line came right down and 20 anything to the right of that, the change had to be a risk '
21 reduction.
22 VICE CRAIRMAN POWERS: This is to be precise, CDF 23 during power operations for a typical unit?
24 MR. HOLAHAN: No.
25 MR. KING: This could be delta CDP --
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33 l l
1 VICE CHAIRMAN POWERS: No , the horizontal-scale. ;
2 MR. HOLAHAN: No. It is total CDF for the i 3 specific plant that you are considering to change.
4 MR. KING: The intent was total. Internal events, 5 external events, shutdown operation, j 6 VICE CHAIRMAN POWERS: Effectively then, my CDF 7 for power operations, where that line comes zinging down, if l 8 I were to plot CDF for power operation, it would come 9 zinging down at three times ten to the minus fifth or seven 10 times ten to the minus fifth, some number. 1 11 MR. KING: Right.
12 VICE CHAIRMAN POWERS: And then I would make an 13 argument to you, high, medium and low, and I'd say, in 14 total, this is all below ten to the minus fourth?
15 MR. KING: The current guide, the guide that went 16 out for comment, would allow someone to come in and make 17 that argument I've got seven times ten to the minus fifth 18 for power operation. I've calculated that. For some 19 qualitative reasons, I think shutdown and external events 20 don't add much and they can try to convince us they are 21 still below ten to the minus four.
- 22 VICE CHAIRMAN POWERS
- As opposed to making an 23 argument that my delta -- the thing I'm planning to change
- 24. doesn't affect those things that I don't calculate, so I'm 25 just not going to worry about them.
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34 1 DR. KRESS: That's the issue, they should focus on -
( ) 2 delta's rather than absolutes? I don't see how you can do 3 that.
4 MR. HOLAHAN: What we have done in effect is we 5 have compromised to say we will consider both absolute and 6 only delta's, but we will limit our consideration of only 7 the delta's to such small values that they really don't 8 affect the baseline in any substantive way.
9 DR. KRESS: I think you guys-are really brave.
10 This addresses the issue of de minimus that's been around 11 for years and years. I really think you guys ought to 12 defend this vigorously.
13 CHAIRMAN SEALE: Yes, but maybe not with those 14 words.
(_, 15 MR. KING: Perhaps not with those words, yes.
16 DR. KRESS: I think this is great.
17 DR. MILLER: I agree. I'd like to see you move 18 more, where small is maybe slightly larger.
19 DR. KRESS: You can always argue about the 20 Lumbers. These are probably about right. I don't see how 21 you could come up with -- if I were to go sit down and do 22 it, I'd have to come up with the same numbers.
23 DR. MILLER: One thing I'll be concerned about is 24 consistency between the number of less than ten to the minus 25 six in temporary changes. Until you define temporary changes ,
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35 r i
- 1' and your policy on adding together and averaging all that, j
() 2
.3-but I'think in some way, they have.to be consistent.
In other words, ten to the minus six,~if we agree 4 ten to the minus four is the right benchmar:k, that's less 5 than one percent. Then if you have a temporary change, that 6 would be less than 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> of zero change --
7 MR. HOLARANi .If done only once. ,
8 DR. MIuLER: Right. It seems like you are going l t
9 to have trouble getting all'that to hang together. It !
- 10 .. wouldn't be consistent. If your average is going to be less [
lL1 than one percent change over a year, you are not going to 12 allow too many temporary changes, if you follow my logic 13 here. ,
14 MR. MARKLEY: Temporary changes can exist for a 15 very long period of time, despite the licensee procedures to 16 the contrary.
17 DR. MILLER: I understand that. Let's say a t
18 temporary change, you allow going from ten to the minus four 19 to say two times ten to the minus four. You allow it for 20 half a year. That's a lot more than one percent.
21 MR. HOLAHAN: I don't think that's th; way 22 temporary changes.really turn out. What happens is the 23- ' temporary change is'not likely to cause one times ten to the 24 minus?four to.two-times ten to the minus four. ,
25 -WhatLhappensLis the temporary change tends to
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i 36 ->
1 af fect one sequence or just a subset of sequences. It's not !
() 2 ;1ike you take the whole -- every sequence and maite it worse 3- by a factor of two. ;
4 The net effect of them tends to be a whole l 5 collection of unrelated things that happen from day to day.
6 DR. MILLER: It doesn't change your bottom line, f 7 if we believe in absolutes, doesn't it change your bottom 8 line CDP somehow?
9 MR.. HOLAMANt- .They accumulate into yearly.effect,-
10 yes. What we've seen -- even now,' when there are really 11 let's say-limited restrictions on temporary conditions, you 12 have tech specs for some of them. We have the maintenance l 13 rule which discourages certain sort of activities.
14 If you look ati licensees who track their hour to 15 hour and day to day changes and you look at what effect it i 16 has, what most of them show is it increases the risk' 17 noticeably baseline, zero maintenance, but it doesn't push 18- them up'beyond what was assumed in most of the IPE's.
19 What you normally think of as the baseline PRA has 20 built into it a certain amount of maintenance, although in 21- PRA's, they tend to be sort of thrown in on a random basis.
22 IMt. MILLER: In a way, temporary changes are-kind i 23 of built in in the' uncertainty --
r
-24 MR.: HOLARAN: They are built in.-- In effect,-if a >
25 ilicensee were to randomly do maintenance throughout the -
()
D
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37 1 year, they would come out with what's in a typical PRA. By
() 2 following the maintenance rula and being very smart about 3 how you schedule maintenance, even though there are spikes 4- and a large number of them, they come out to have less of an t 5 impact than if you had done them at random.
6 DR. MILLER: Getting back to the one percent being 7 so small that it would be in that uncertainty band of ten to 8 minus four, it's not noticeable.
9 DR. KRESS: I think the two are not that related.
10 There's nothing at all magic about the one year time frame 11 in CDP, and the real consistency is what you are doing is an 12 average over a time frame. If you keep that consistency, 13 you know, we are talking about that's one way you deal with 14 temporary changes, but they are also talking about something O
\_ I 15 else, like putting caps on things. That's the consistency 16 factor. That would make the whole thing consistent. You 17 wouldn't have to worry about it if you did something like 18 that.
19 It doesn't really address this de minimus stuff 20 that much.
21 DR. FONTANA: Let me back up a little bit.
- 22. Including the fire and seismic contribution in the baseline 23 CDP that you start from, I think it will lead to some 24 logical inconsistencies. In other words, if you have a 25 plant that has a higher fire and seismic contribution to
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38 -
1 lanotherone,then that plant _would basically be kind of l
2 penalized'on looking at some changes, and some=of those
({
3 changes:could have nothing to do with fire and seismic l
4- consequences. !
l 5 I am. wondering whether there might be a little bit !
6 : of unfairness there, h a 7 MR. HOLAHAN: Inconsistency, yes. Unfairness, I l i
8 don't think so. What we are doing is compromising between !
9 two approaches, one of which says -- a previous approach, j 10 which says if you are above - ten to the minus four,- you ' get 11 zero, and the approach, I think the one suggested by l
12- industry, which says the risk to the plant is irrelevant, ;
13 only look at the changes, and whether you draw the line here -j i
14 ' or there or wherever. 4
- 15. I think both of those have down sides to them.
16- What our compromise says is if it's fire and l
L17 seismic or.any other reason that pushes your plant up above l 18 ten'to the minus four,--then we are not going to entertain, 1 19- you know, larger than very small changes, whether they are 20 - related to that subject or not. I 21' - DR.'FONTANA: I guess it's probably the only thing 22- you can do practically, otherwise you_get into little !
- 23. -details.- [
24 -- MR [ KING:- This provides.more flexibility than the 25 Ifirst draft version did. !
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39 l 1 DR. FONTANA: _Oh, yes. !
, 2 DR. KRESS: It could even make things like fire 3: and seismic fit into this, ten to minus six could be the- !
4 definition. This adds coherence to a. lot of things we do. -l 5 The five thing, it says when you go through that, you don't 6 really have a significant CDP contributor. That may be the 7 definition there. !
8 MR. Y.ING: This also, I think, provides'some 9 consistency with the risk informed 50.59, which is down in l l
, 10 this Region III somewhere.
11 DR. KRESS: Exactly.
12 CHAIRMAN SEALE: It's like the trap door in 13 Dungeons and Dragons. You just have to make sure what's on 14 the other side.
35 MR. KING: Anyway, we are still keeping this in !
16 Region II, which we call management attention, because you 17 are getting changes that are greater than very small. ,
- 18. Also, we'd expect once you are out with a baseline 19 CDF above ten to the minus fourth, although I'm not calling 20 that management attention, I think clearly you'd want to pay 21 more attention to the cumulative effect and the trends and ;
22 so forth to make sure they are not drif t-ing up closer and '
23- closer or further and further away from the ten to the minus -
24 fourth. j 25- There would be a similar plot for LERF that would i
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. . , . . .,_,_..-,,,,,,...a..-...,,--..,.-,,,-,
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i 40 }
1 look just like this, except the numbers would be different f
() 2 on the scale.
3 DR. MILLER: You are proposing putting this plot 4 in the guidelines? ;
5 [ Laughter.)
6 MR. HOLAHAN: What does the committee recommend?
7 MR. KING: Yes, what does the committee recommend.
P 8 DR. KRESS: This is our chan~e. What you got from 9 George, I recommend you put it in file 13 and go with this.
10 VICE CHAIRMAN POWERS: Do we want to quickly tako 11 a vote on this?
12 [ Laughter.]
13 DR. KRESS: Before next week.
14 MR. KING: I'm not suggesting go to George's !
15 shading, but clearly these are guidelines. They are not 16 hard and fast. There is some judgment.
17 DR. KRESS: Do the shading and the words.
18 DR. MILLER: In the previous version, you had the 19 words and tPs shading.
20 MR. HOLAHAN: My problem is both, either, drawing 21 the lines or shading the lines to me focuses on the wrong 22 thing. What I would like to do is find a way of focusing on 23 the region, not its boundaries. The question is are you 24 generally asking for things in Region II and not arguing 25 about what is exactly the boundary of Region II. Are you I ANN RILEY & ASSOCIATES, LTD.
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41 1 generally asking for things that are so small that we ought ,
r~' 2 not to be so concerned about them.
I
(_)
3 We find it exceedingly difficult, even when you l
4 draw fuzzy boundaries, we end up focusing on the fuzziness i 5 as opposed to the general area most of the time, i 1
6 DR. KRESS: You know, there are some things that 7 just have to bite the bullet and say, hey, we'll say it and 8 we will say it again and say it again. I would go ahead and ,
t 9 do the lines and then in words, make sure I focus on the 10 regions. If people misunderstand it, that's their problem.
11 DR. MILLER: You do the lines and then you focus 12 your attention during the training programs on the regional 13 approach. I assume you have workshops in industry and so 14 forth. 1 15 DR. KRESS: Yec.
16 DR. MILLER: Of course, hopefully, industry will 17 start coming to your training programs and they will pick up 18 these things, too. I agree with Tom to go with the lines.
19 MR. PARRY: I think George's shaded version of 20 this probably helps indicate where the degree of attention 21 that the analysis is going to get increases. It increases 22 as you go toward the darker regions.
23 DR. KRESS: Yes, but it's a little misleading, 24 too. I contend degree of attention is not a continuum.
-25 That shows it as a continuum, I don't know how you guys
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42 1 feel about it.
2 - DR. BARTON: It's a riippery slope.
3 DR. KRESS: Yes. l I
4- MR. KING: The other thing I want to point out is j 5 this scheme also has implications for the uncertainty 6 analysis that we had' asked for.- In Region'II, we'd expect !
7 to evaluate the uncertainty associated with the baseline I
8 value as well as the delta, that once you are down in Region 9' .III where the baseline doesn't come into play any more, it l
'10 simplifies what a licensee has to do. We had gotten some i
-Il comments that we were asking for too much on uncertainties.
12 The next policy issue is the treatment of ;
13- uncertainties. I'll-ask Gareth to talk about where we are 14 going.with that.
15 MR. PARRY: In a sense, we are being pushed from 16 two directions in this question of the treatment of 17 uncertainties. A lot of the public comments we got were that i
18 we were asking for too much, that we should '- be 19 concentrating on mean values. We shouldn't be talking about 20 statistical measures of confidence, i
21 On the other hand, we've had SRM's from the .
- 22 Commission that ask us to consider more mathematical 23 treatment of uncertainties.
24- We have done quite a lot of thinking about-this l 25 issue, as to what would be the best approach, given the
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43 j 1 state-of-the-art of PRA. l
() 2 3
I think we have concluded that the basic approach that we had written in DG-1061 still holds, but we need to !
4 be clearer about what we actually meant when we wrote tha ;
5 words there. :
6 Effectively, if I can capture it in a nutshell, I t
7 think practically means that as -- remember, we divided the 8 types of uncertainties into three different categories; the 9 parameter uncertainties; model uncertainties and 10 completeness issues.
11 The completeness issues, which we have talked 12 about with you before, were particularly contentious issues, 13 I think, with respect to the way the guidelines are written 14 because most licensees do not have complete full scope PRA's ,
15 and they cover low power shutdown and all the external 16 events.
17 That really meant that trying to demenstrate that 18 they were in the region below ten to the minus four for core 19 damage frequency was going to be extremely difficult, even 20 though we tried to find out that you could do that 21 qualitatively, but as Dr. Powers pointed out, how you do 22 that is a little-difficult. I 23 With the introduction of this new Region III, to a 24 large extent, for changes which result in only small 25 increases, we have got rid of that problem of completeness 7d07 RILEY & ASSOCIATES, LTD.
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- 44 1 on the baseline CDP. ,
() 2 3.
I would like to point out though that it does not get rid of the completeness issue with relation to the ;
4 change. l 5 The evaluation of the. change has to address all 6 modes of operation. Now, that can be done in a variety of 7 ways. One of'the ways might be to ensure that the change {
8 does not affect the equipment that is being used in those l
9 modes of operation. That's certainly perhaps the cleanest a;
10- way of showing that.
- 11 In any case, it will be necessary to address the ;
12 completeness issues for the deltas, regardless of where we 13 are.
14 Similarly, model uncertainty changes will also
() 15 need to be addressed. Now, we've concluded that it's !
16 impractical to try to integrate model uncertainties into the 17 probability distributions on the risk matrix that we could 18 generate. In fact, not only is it impractical, I think it 19 would be a recipe for having a lot of subjectivity thrown in 20 there that would be extremely difficult to review.
21 I think in terms of addressing model 22 uncertainties, we are focusing more on the role of things 12 3 - like~ sensitivity analyses, to demonstrate *Se impact of
- 24_ choosing different models or different assumptions. !
= 25- As far as the parameter uncertainties go, which O ANN RILEY & ASSOCIATES, LTD.
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45 1 can be treated very straightforward 1y, we believe that it
() 2 should be the mean value of the calculated risk that we are 3 gcing to use in comparison with these guidelines.
4 Quite simply, the guidelines have been established 5 on the basis of the safety goals and subsidiary objectives 6 and on the regulatory analysis guidelines, which in fact 7 were focused on using mean values.
8 I think that would entertain people using point 9 estimate values, if they could demonstrate that those were 10 adequately close to the mean values. I think you can do 11 that by inspection of the contributors.
12 The bottom line with the uncertainty analysis is 13 that we are using it as a tool to understand the 14 contributors and how the changes and how the baseline, if 15 that's necessary, how it's all made up. It's a tool for the 16 analysis of the results to gain confidence in them.
17 DR. KRESS: Let me be sure I understand this. We 18 have a baseline CDP that we are going to calculate with PRA.
19 A lot of people when they calculate a PRA put in values for 20 reliabilities, values for parameters. A lot of times, they 21 are single values. They end up with a value. Are we going 22 to call that a mean or are we going to have to demonstrate 23 that's related to the mean? Are we going to have to -- are ,
24 we saying now we are going to allow people to put ranges or 25 distributions on the parameters and maybe even distributions
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46 1 on some of the values of probabilities for failure and ,
() 2 propagate these through and end up with a distribution, even 3 though this doesn't include some model uncertainties, it 4 doesn't include completeness, we will call that the mean? !
5 MR. PARRY: We will call that the calculated mean. [
6 DR. KRESS: You all are talking about propagating 7 the distributions through?
8 MR. HOLAHAN: The acceptance guidelines are based 9 on mean values. If for a relatively simple circumstance, a 10 licensee wishes to argue that their point estimate is a 11 reasonable approximation of the 12 mean --
13 DR. KRESS: Or a bound to the mean.
14 MR. HOLAHAN: And can therefore use the same 15 acceptance guidelines, I think that's okay, but the burden 16 of that argument is left for the licensee.
17 SPEAKER: In practice, is that a big burden?
18 DR. KRESS: It could be. One way to do it is to 19 propagate the distributions.
20 VICE CHAIRMAN POWERS: I got the impression, at 21 least when I read the thing, that there are going to be a 22 lot of changes that one could imagine. I'm thinking of some 23 of the changes where the delta and even the absolute's are 24 going -- the delta is going to be ten to the minus ninth or 25 something like that. It is going to be really, really tiny.
f
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47 l 1 There is simply no economic, if I can use that
() 2 word, incentive to go propagating distributions around a 3 number that I don't believe anyway, it's so small. [
4 DR. KRESS: First off, I'm focusing on where we 5 are on the CDF/LERF. That is where I think the :
6 uncertainties I'm talking about come into play, on mean 7 value. I'm trying to figure out how that mean is determined ,
8- in view of the uncertainties, and what is included in the !
9 calculation. Then I was going to get to e delta. You are 10 absolutely right, I think, on the delta. You have to deal ,
11 with uncertainties on the_ delta, but normally, they are so 12 small, that you can almost throw them out.
13 j I think uncertainties come into play when you are 14 trying to decide where you are on the map in the first O
k/
s 15 place.
16 MR. HOLAHAN: I would do it in the reverse order, 17 that is to say first, I would decide whether I'm talking 18 about a very small, exceedingly small change, and if I were 19 convinced of that - -
20 DR. KRESS: You would think you would have a 21 region III maybe.
22 MR. HOLAHAN: I nave not the problem of arguing, 23 -you know, do I really know whether I'm in region I or II.
24 DR. KRESS: I agree with that.
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- --wg ----,,e w -y-m-c.----r r w-,.n..w- g-.-a-r,p - y- .y .'
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48 ;
1 theoretical back bone to this process, would it be l 2- worthwhile-to make some reference to the whole question of 3 uncertainties with high' entropy-distributions, that is that 4 the-95 percentile value inherently has a certain value for !
5 high entropy distributions, and that's kind of a limit, f
6- where all else fails, if you can't argue anything else,
.7 .that's sort of the default value that you are willing to l 8 accept on uncertainties. t 9 MR. PARRY: That's a very conservative approach f
- 10 though. I don't think the problem with parameter .
11- uncertainties is as big as a lot of people have made out.
12 DP KRESS: I agree, I don't think that's a big l 13 deal. ,
14 MR. PARRY: The codes can handle it. It may need l
15 some manipulation of the input data into the PRA, but if all +
16 else fails, if you look ot contributions, you can tell what 17 the signature of the contributions that will give you the i 18 big difference between point estimates 19 and -- [
20 CHAIRMAN SEALE: The real justification for not f
- 21 -worrying about uncertainties in region III is that if you do 22 take the default value, you still don't have a significant
- 23 uncertainty.
24' MR. PARRY: Right, but here in region III, I think 25- it's not-so much where you calculate yourself to be i
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49 1 necensarily but where you could be if you had made other
() 2 assumptions. That's where I think the modeling issues and the completeness issues perhaps become more important in 3
4 that region, but they can also be more focused because the 5 change is likely to be affected by a limited number of these 6 model issues.
7 I think one of the messages we have to get across 8 in DG-1061 is as we discussed last time with the 1
9 subcommittee, that the uncertainty analysis'has to be 1 10 focused on the application, and it will be-as extensive as l l
11 it needs to be to make the case. In many cases, it will not 12 need to be extensive.
1 13 DR. KRESS: I was still working my way through l l
14 this. The model -- I'm still focusing on where I am on the
( 1
\ 15 CDF/LERP map. The model uncertainties are always difficult l 16 and they have been handled in the past by using expert 17 opinions. .
l 18 You are saying now that one way to deal with that 19 is to use a sensitivity study, which is a type of expert 20 opinion, because you have to decide on these ranges, and 21 generally they are one number or the other you put in.
22 You are saying that will kind of give you an 23 expert opinion type of judgment on the effect of these model 24 uncertainties and you can use that to guide your thinking 25 and insight, but it won't enter into the thinking of where
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50 1 the mean is? Just sort of we will thrown away its effect on
() 2 3
the mean?
MR. PARRY: Effectively, it would give you a new 4 mean. I think what you have to do is you have to weigh the 5 evidence of the two alternatives and say do I believe this 6 one rather than the other one.
7 DR. KRESS: That's the thinking you have put into 8 it.
9 MR. PARRY: Right.
10 MR. HOLAHAN: What is really important is whether 11 it has effect on what region you are in. If I say, well, if 12 I use this expert as opposed to those two experts, I would 13 have ended up in region I as opposed to region II, well, 14 this perhaps is not a change, this magnitude of change is --
15 DR. KRESS: That's part of the integrated decision 16 making. I think it is reasonable. You guys have thought 17 this out good.
18 MR. KING: To me, the important point is trying to 19 focus on identifying where are the sources of uncertainty 20 and then looking at how those affect a mean, instead of just 21 coming up with a distribution that may be real or not real, 22 you know, going by some mathematical formula.
23 MR. PARRY: Ultimately, you'd have to unravel that 24 distribution anyway to find out what it was made from, if 25 you were going to believe it.
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51 f 1 DR. KRESS: Yes, that's right. [
'2 MR. HOLAHAN: I think it has if not the technical 3 at least a philosophical back bone of saying I'm more l 4 worried about where you are when you are going to make more !
5 substantive changes than when you were effactively making' !
-t 6 changes that are so small that a different ana'aysis by l i
7 someone different on a different day might have made a a 8 change just as large. ,
E 9 DR. FONTANA: Is there enough agreement across the l 10 spectrum of people who work in this business regarding model 11 uncertainties and-completeness questions, so that when it 12 comes to the table, you won't be really miles apart?
13 DR. KRESS: We are generally only talking about 14 fire and seismic and shutdown. It's really very limited.
15 MR. PARRY: Yes, and certainly as far as fire and' 16 seismic, only for a few.
17 DR. KRESS: It's really limited.
18' MR. HOLAHAN: In effect, what we are saying is !
.19 these are difficult questions, and if a licensee wants to 20 make a change as big as ten to the minus five, which in fact 21 in my mind is like adding a dominance sequence to the plant, ;
22 these are fair questions. What do you really know about the 23 fire risks at your plant, is yours a modern plant or is it 24 .one with 200_ exemptions tx) Appendix R.
4 25- DR. FONTANA: They certainly are legitimate
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52 1 questions. I was just wondering how you get around to the 2 answer.
3 MR. HOLAHAN: I think we will have to tackle those 4 on a case.by case basis. What this compromise does is it i 5 says we will put that effort in only when you have to and 6 not in -- I don't want to say trivial, but not in very small 7 change cases.
8 MR. KING: The third issue is the guidelines for 9 shutdown risk. We did get comments from the public that 10 suggested we ought to treat skutdown different than we treat ,
11 full power. We agree.
12 Clearly, when you are shut down, your source term 13 is different. Your containment may be open. Certainly, in 14 some conditions in shutdown, tying something like LERF to an 15 early fatality may not make much sense. One, because there 16 is no large release or early release, and second, you may 17 not even have early fatalities off site in the accident.
18 I think clearly something needs to be done but at 19 this-point, we really need to take some time to think about 20 this and not rush and put something in the guide for 21 December.
22 What we are proposing is to go back to the 23 Commission in this policy paper, as a policy matter, get 24 agreement that yes, we ought to work on separate guidelines 23 .for the shutdown condition, we ought to do that in r
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=-. . - - . . _ .. _ _ - . - . _ . - _ - - -. _- - - - . - - - - _ ,
i 53 1 . conjunction with the additional-work we have planned to-look
() -2 at shutdown risk, but-in the interim, in'the draft guide, we 3 ought to allow some flexibility for licensees, particularly j 4 for the LERF, to propose sometning.different than just using f 5 the LERF guideline we developed for power operation. ;
6 We intend to put some words into allow that ,
7 . flexibility and I think also say as a default, if they want !
8 to use CDF, a CDP limit of say ten to the minus fifth during r 9 the shut. lown condition, that clearly would meet the intent !
10 of any LERF guideline you would come up with for that 11 condition. '
12 VICE CHAIRMAN POWERS: When you speak to this CDF 13 limit for shutdown as a surrogate, you are still speaking of 14 an annualized CDF?
15 MR. KING: Yes, I'm still apeaking of an 16 annualized CDF.
17- VICE CHAIRMAN POWERS: What you are essentially 18 saying is the CDF limit is the same if you are down one ,
19 month out of 12?
20 MR. KING: On an annualized basis, yes.
21 MR. HOLAHAN: We are saying its contribution to 22- the long term average would be built in. !
23 VICE-CHAIRMAN POWERS ' I think I understand. !
24 DR. KRESS: That's an interesting concept, trading ;
- 25. CDF for --
+
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1 DR. FONTANA: It's logical. ;
() 2 3 else can you control it'r DR.-KRESS: It's the only thing you can do. How i
I 4 VICE CHAIRMAN POWERS: It is not in principle e i
5 consistent with the ideas of defense in depth as a principle 6 thing, because what you are doing_is over emphasizing ;
7 prevention because there is not very much you can do about
~
- 8. mitigation.
9 DR. KRESS: It's departing from that on a
- 10 temporary basis, t
11 DR. SHACK: You don't have much choice.
i 12 DR. KRESS: You don't have much choice. You are 13 not going to build another container there.
14 VICE CHAIRMAN POWERS: Well, you have limited 15 choices. ,
J 16 CHAIRMAN SEALE: This is an emminately sensible 17 thing to do, it seems to~me, because what you have done is
- 18 to put shutdown risk into the equation, but you have said 19 try to be smart and figure out how to handle it, and that's 20 .a challenge that I think the utilities can do something 21 with, because they have been pretty innovative in other 22 things in the past. This is one way to get them to think 23 _about it real hard. I think that will bring more creative 24 fjuices to flow than almost anything else you could_do. -
'25 MR. KING: Yes.
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55
'l - DR. KRESS: On that'second-bullet, the first dash,:
2 you< talk 1about.the lower radionuclide inventory. How-long '
are.they? What's a good' number: for a shutdown?
7 4: MR. HOLAHAN: -35 days.
5: DR. KRESS: You are starting out firstJwith I 6 basicallyftheffull inventory and mostly you are really only 7; dealing with iodine, and after 35 days, you_have reduced the 8 risk considerably because a lot-of iodine is gone.
- 9. MR. HOLAHAN
- -- .Yes, exactly.
10- DR. KRESS: Your CDF-is probably changing, too. -
11- LERF is' continually decreasing.
12 -: MR.' KING: Yes. Response. times are changing.
-13 VICE' CHAIRMAN POWERS: Tom, the release fractions,
- 14. - their' potential in a shutdown situation, it is not evident 15 to me those release fractions are the same as we have in 16 14.65.
17 DR. KRESS: Yes. The heat up rates are different 18 MR. KING: Because of the oxygen environment.
19 DR. KRESS: You are absolutely right.
20 CHAIRMAN SEALE: The inventory goes from an iodine 21 dominated inventory 7 to something else.
22: VICE CRAIRMAN POWERS: I think what you find,-if 23 indeed you have an error type of an environment, those kinds 24 - of oxygen partial pressures,_ that your. refractory metal 25; contributions are significant, and in fact, on a risk worth
~
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_56
=1 ' basis,_ _ the rutheniuid s in. this world are very significant, -
- 2 - the molly's are'just not'very significant.
-3( - DR. KRESS: I_ agree with you, Dana. When I was:
3 4 - talking about LERF here, I:was really in the back of.my mind 5 using conditional containment, early failure probability. <
6- VICE CHAIRMAN POWERS: The trouble is that is one.
/7. MR. HOLAHAN: For the PWR's, 'I don't_think it's 8! ' quite one. That 's good because I :think. the PWR's have the
-9 ' larger problem.
10 VICE CHAIRMAN POWERS: The larger problem.
DL1' DR.-KRESS: The ideal would be to-have shutdown risk included in the.PRA.
13 MR. HOLAHAN: Of course.
14- DR. KRESS: You have to be-realistic and not1 1 15 expect-that. I think this is about the only other good
} . 16 option you have.
17 MR. HOLAHAN: This is also supportive of an 18 ongoing research program and it gives it some focus as to 19 fill out those areas that you'are having problems 20- understanding at the moment so we can do-better later.
21 MR. KING:- The fourth policy issue is the one on 22 temporary plant conditions. Again, we think this is an area 23- where we ought to consider some different guidelines, We
- 24 - think:this is one that is; going to take-some-time to think about.
~
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-t 1 What we_are going _to propose to the Commission is. -
l (f, 2; Efrom a policy standpoint, get their agreement that we ought 3 to-go work in this-area,_but get_back to them at a later_ .
4 date with actual proposals as to-how to deal with this.
5 I-think the4 issue we have coming up that'was. l 6 raised initially.by:ACRS to elevate _ CDP to a safety goal and 7 subsequently that' led to SECY 97-208, which said if we are
-8 _ going.to'do that, snt oughtDto con: f dating the safety 9- goal policy in a number of other e
~- 10 We have-put temporary p1 r 'ond tons on that "11 list-of things to-talk about as part update for the 12 safety goal policy. -I think in that con'- o, we want to ;
4 13 re-visit this issue and ultimately maybe the safety goal 14 policy ought to say something on spikes and risks and so 15 _ forth, whatever-flows out of that then can feed into what we 16 put in the reg guide.
17 Again, it's a deferral recommendation to the 18 Commission, but at least get a nod from them that this is 19 something we want to work on.
_0 DR. KRESS: What were you doing in 1061 about 21 this?
22 MR. KING: 1061 is going to be silent in the 23 draft.
24- MR. HOLAHAN: Silent on the specific issue, but I 25 think, in my mind, temporary conditions is a secondary issue ANN RILEY & ASSOCIATES, LTD.
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58 1 because what we are doing in the-reg guide addresses
()
v 2 directly, you know, the most important aspect, which is the 3 long term effect of those temporary changes is considered in 4 the analysis and it's in the guidelines and it's treated.
5 To me, the next layer of concern is we have a 6 defense in depth concern that Jays even though you might 7 make things worse for some period of time, there are certain 8- limitations on how you would make things worse.
9 What we are asking is what residual issues are 10 there, that the risk acceptance guidelines and the defense 11 in depth and the safety margin issues haven't taken care of.
12 There may be some but they don't look like 13 dominant issues at least to me, not at the moment.
14 VICE CHA RMAN POWERS: I guess I've always been
>D is ,/ 15 interested in having a risk capping on spikes. Experience 16 has shown me it was useful in other contexts. I also found 17 that your allowed outage time approach looked very 18 attractive as a mechanism for doing that, and subsequently, 19 some words that you have written and the Commission has 20 written about an ALARA like approach also looked very
'21 attractive. Are those the kinds of things you are toying 22 with here?
23 MR. KING: Yes, clearly the tech spec limit on 24 allowed outage times, -the intent is to keep that in the tech 25 spec guide and certainly consider that approach for the t
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.x
-Iu .-) 2- .VICE CHAIRMAN POWERS: It had the attraction of a 3 certain amount of historical' precedent to'it and it looked 4 very-palatable. It did have a capping effect on it.
5 On the other hand, a more qualitative sort of 6 ALARA type principle also has a certain attraction to it, 7 for a lot of reasons. ALARA has proved to be a very useful 8 concept.
9 MR. KING: And the industry has proposed one also.
10 I_think on CDF, it was ten to the minus three per reactor 11 year cap on spikes. We want to consider what that means as 12 well.
13 MR. HOLAHAN: The maintenance rule, at least in 14 the area of maintenance activities, implies some sort of 15 spike, not quantified.
16 VICE CHAIRMAN POWERS: I guess the question I'm 17 asking is are you considering both quantitative and 18 qualitative things, and I think the answer is yes.
19 MR. HOLAHAN: Yes.
20 MR. KING: In theory, if this turns out to produce 21 something that makes a lot of sense, you might just apply 22 this to the shutdown conditions as well.
23 VICE CHAIRMAN POWERS: Shutdown can be viewed as a 24 spike.
25 MR ., KING: Plant configurations change and so
[)
\~
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60 1 forth. That's another consideration.
/~
(N) 2 The-last slide is just a very short summary of the 3 major changes we see in the guide and the SRP. I think we 4 have talked about most of these.already. I'd really prefer 5 next week when we get to the subcommittee and you have the 6' guide in front of you, to get into these. I don't think it 7 makes a whole lot of sense to go through these at this point 8 in time.
9 The last four pages of the handout were just the 10 list.of commentors, for your information.
11 At this point, unless you have any questions, 12 that's our status.
13 VICE CHAIRMAN POWERS: Just to ask you a question 14 on scheduling and what not, because I've gotten a little
(_) 15 confused. Graded quality assurance is now deferred like 16 three months or something like that.
18 VICE CHAIRMAN POWERS: Graded QA, right.
19 MR. KING: We are planning to get to you on 20 February 6, the revised application specific guides and 21 SRP's. That's graded QA, IST and tech specs. ISI is on a 22 later schedule. That's when you will see the proposed 23 revisions. We would schedule a subcommittee meeting in 24 February sometime, bring those to the full committee for a 25 -letter in March.
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61 1 VICE CHAIRMAN POWERS: That's feeding us with a (M
( ). 2 fire hose there, I think.
3 DR. KRESS: On the other hand, there are a let of 4~ other fire trucks lined up.
5 VICE CHAIRMAN POWERS: les. The graded quality 6 assurance, I think we-have to think very carefully about 7 that one.
- 8. DR. KRESS: It would be nice to have George here.
9 He's the one that set up this.
10 VICE CHAIRMAN POWERS: Yet another cause for 11 concern.
b 12 CHAIRMAN SEALE: Reassure me on one issue. I'm 13 always intrigued by the idea that one way to reduce the 14 effect of a particular event is to subdivide the definition 15 of what event is, so that you just chop it up into so many 16 pieces. That's a version of the completeness problem for 17 the PRA, in a sense. Are you going to say anything about 18 completeness in that sense in 1061? That is that in fact, 19 in the overall PRA that you have, yco are including a suite 20 of initiators that pretty well covers the spectrum of
, 21 experience for operating plants, and as you go to other 22 conditions and so on.
23 MR. KING: I think the guidance on PRA quality is 24 going to deal with initiating events It's standard, 25 whether you are talking full power operation, you know, O.
\~
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62 1 _you'd clearly want to cover the full range of initiating
. r~T
_ ( jf 2 events.
3 CHAIRMAN SEALE: What I am saying is --_I can 4 remember asking a group a question one time to the effect 5 that have you seen any initiating events this year which 6 aren't in the PRA's that you use. After thinking a while, 7 they said, no. My response to that, aren't you glad.
8 Now, the question is, are you_asking or among the 9 things you are asking of a 1061 PRA, that it in essence 10 cover the experience waterfront?
11 MR. HOLAHAN: The answer obviously is yes. In 12 some sense, it's not a 1061 issue in the sense that we 13 haven't written = guidance down at the level of here's how to 14 do a PRA. It's not like we have a PLG eet of guidance and
\
15 that sort of stuff. It's at a high enough level that how 16 you accumulated initiating events and how you did the 17 analysis and how you divided things up, you know, ought to 18 work itself out in a good quality analysis so the results 19 can be compared with what we have suggested.
20 CHAIRMAN SEALE: But it would seem to me that you 21 could state the idea that you would cover the scope of 22 experience in a high level way.
23 MR. KING: I think it's a good point. I think we 24 can certainly suggest they do that.
25 MR. HOLAHAN: To a larger extent, I think this
/~ .
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'63 1'
ti' ' issue is'an 1602,-it's a national-l standard, it's a quality, 7
of-PRA irsue.
J 2' i b-- ,. '
3 (CHAIRMAN SEALE: Yes. .
. 44 -VICE CHAIRMAN POWERS: . Bob,-i I , wonder "if ; we i could-t 15 pursuela questionfthatfyou posed yesterday in the- -i
?
6 subcommittee: meeting, and that-is we now have a risk 7- = assessment technology. We now have guides-on how to apply 1
8~ 'that to reactors _and what not,,some advice to the licensees.
9: .I wonder, do we have-the information now and the 10 tools now that would allow us to take this wealth of l11 information'and technology that we have, apply it to the'
'12 rules and regulations and identify their risk significance 13 and from that, identify those that are of minimal risk 14- significance?
O A ,) 15 MR. HOLAHAN: I think we certainly have outlined 16 an approach and a set of tools that could do that. I think ;
17 there's a serious resource question about picking up the 18 . regulations, 10 CFR 50, page one, going through beginning;to 19' -end and applying it.
20 In one form, this issue is before the Commission 21 in SECY 97-205, on integration of lessons learned from Main 22 Yankee, Millstone and other places, and 50.59 and scope and 23 content of FSAR's. I think in its most extreme version, 24- .it's a suggestion, one of the options. . think it's the 25 third but.it might:be the fourth, basically saying, well, t ANN RILEY & ASSOCIATES,'LTD.
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,* .64 why don't s re-write-the regulations to be risk informed. l
~
12 VIci "HAIRMAN POWERS:- That is a :little: further --
3= _thanfILasked:yc to 90. _ _
4 MR.: KING: NEI.has hade a proposal t'o us to take !
5' 'three pilot' plants, do full scope PRA,.and compare the 6- results-of that PRA-to-.one, where:arefthey. spending money-to 7_ maintain and operate the plant,'are they spending a lot on-18_ riskzinsignificant things,-but in; conjunction with-that, to-9 .look at why are they spending the money-there. Do-they have-
.10- regulations, you know,-some other'part-of the CLB 11 requirements that are causing them to putimoney and effort 12 into things that are not risk significant' .
13 I think in effect this NEI initiative-is going to get_---
15 CHAIRMAN SEALE: It will evolve in that direction.
16 MR. KINC: It is going to look-in that direction.
11 7 Exactly how far it is going to go, I think remains to be 18 seen. I-think it's a step to do what you are talking about.
19 DR. BARTON: You said three,-what's the third?
20 CHAIRMAN SEALE: Songs.
21- MR. HOLAHAN: ANL.
.22' MR. KING: Me have had several meetings with them-12 3 on this,_ what_they are proposing-to.do. We have another 24 meeting scheduled-for the 24th of this month', where they are 25 going - to :come: in and lay out' their criteria as to how they ANN RILEY & ASSOCIATES, LTD.
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65 1 Lare going to_take these PRA'results an'd come up with-2 ~ recommendations.in terms of we have_a mismatch in
_3 requirements and'_ resources versus= risk. _
4 . We are very; interested in: this and plan to pursue
- - this_ initiative.
- 6 .- DR. KRESS: This is:something that ACRS has~ sort 7 of recommended-for years,iand we have recommended it sort of ;
- 8 like-it sounds like-a good-idea, we didn't really know what~
9' we were-asking. What we.are really asking is to take.any 10 given-regulation, say what is1the risk worth of this .
,11- regulation. Sort of like the Fussell-12 _Veseley thing with systems - that's not an easy thing to 13 do.
14 What you have to do is-take.that regulation and 15 say what parts of the PRA does this affect'and how much.'You 16 have to do=a risk worth analysis and it is not going to be
- 17. easy. _It's a step of relating the regulation to what it 18 does to the PRA. 'It's going to be tough.
19 I would recommend you talk to George about that, i
20 We have talked about it. He thinks his1 concept of influence 21 diagram as an expert opinion is about the only.way to_ deal "22 with a lot of that. You might want to think about that.
~
23 MR'. - HOLAHM1: I'd just like to suggest, and'I 24 ' don't_th' ink'that you meant to leave it out, that we would
- 25- use the ~ whole: 1061 integrated ' process . We would ask'about ANN RILEY & ASSOCIATES, LTD.
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\
1 66 m (
i
= 1-: the? defense;in depth; safety margin influences on each
!\ ) 2i bregulation.
.- 3 There are a number of' ways of approaching this.
4 -Effectively, what we'are doing now is the-industry is }
5- bringing to us i examples of_ regulations'which they find'
= burdensome :and for. which they think relief: can be L 7 -- appropriately justified.
8 The San Onofre and other examples that1 Tom J
- 9 mentioned are basically a_way of screening through the 10- -regulatory requirements and seeing which ones are most 13n costly,'and then deal with'those examples. Still, it's a t 12 piecemeal approach but it's picking ones that are most
-13 -burdensome.
14 A third approach would be start at the beginning 15- of the book and do them all. There isLa suggestion in the 16- 205 SECY paper. The Commission hasn't acted on this. I 17 -think even in the Commission meeting in December, it was 18 still being thought of. There is a suggestion in 205 that
'19 one=way of approaching-it, rather than taking on all the regulations, and-as an alternative to picking-and choosing
'21 this one and that one, to come up with a subset, a
-22 collection of regulations _and do those as a collection.
23 The suggeste'd collection are the ones that staff
- 24' -has. identified as being operationally _ oriented, the ones 25 that affect the. plant on a day to day basis, since in ANN RILEY'& ASSOCIATES, LTD.
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67 1 reality, we are largely in a monitoring of operating plants
)- 2 as opposed to construction phase.
3 DR. KRESS: Probably a good idea because those are 4 the toughest ones to deal with anyway.
5 MR. HOLAHAN: If you look at what that collection 6 is, we already have a head start on some of them.
7 Maintenance rule, 50.59, QA, in-Lervice inspection, testing 8 and inspection.
9 To have a re-think of those regulations that 10 affect plants on a day to day basis and to do them 11 consistently and say, well, let's not leave one out just 12 because it didn't come out of some screening analysis, but 13 let's do them in on a comprehensive basis, I think has some 14 merit.
k-s 15 The Commission is still thinking through these 16 alternatives.
17 VICE CHAIRMAN POWERS: If the Commission is 18 thinking through these things, presumably they need advice 19 or would welcome advice. I wonder if instead of focusing 20 the PRA subcommittee on going through these SRP's line by 21 line and things like that, it might be interesting to 22- re-focus its activities in this general area.
23 DR. KRESS: I don't see why we can't do both.
24 VICE CHAIRMAN POWERS: I have several ideas on why 25 you can't do both.
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68 1 [ Laughter.)
A. 2 VICE CHAIRMAN POWERS: I'll defer to the chainnan.
3 DR. KRESS: I'm just temporary.
4- DR. BARTON: He's volunteering George, I think.
5 VICE CHAIRMAN POWERS: The trouble is he 6 volunteers the entire subcommittee.
7 DR. KRESS: My point is I think we have done this 8 1061 to the point that it's in pretty good shape. It's in 9 awfully good shape. We ha"e already -- we are 95 percent of 10 the way or something.
11 VICE CHAIRMAN POWERS: We have all the tables and 12 text. We just can't get the figures right.
13 CHAIRMAN SEALE: We don't even know what kind of 14 pen to draw the figures with.
(_f 15 DR. KRESS: I think the next big issue for PRA 16 might be just this one.
17 CHAIRMAN SEALE: I think you are right.
18 VICE CHAIRMAN POWERS: It seems to me if this has 19 been given some consideration both by the industry and the 20 Commission, we really can't stand on the side lines here.
21 DR. KRESS: Oh , no. I don't think we should.
22 CHAIRMAN SEALE: Timely is of the essence.
23 VICE CHAIRMAN POWERS: Maybe we need to either 24 augment or re-focus on that.
25 DR. KRESS: I don't think we are going to re-N 1 ANN RILEY & ASSOCIATES, LTD.
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1 69 1- focus but I think it's a good suggestion. -J; I. , .) 2- CHAIRMAN SEALE: Would you people be prepared'to N- ,
3 discuss this particular aspect in more detail with-us at l 4: some point?-
5 MR. HOLAHAN: I'm not entirely responsible for 6 this area,-but I think I can speak for the. staff and say, 7 yes, we'd be more than willing. I think, however, I would 8 suggest,.if I look at the pace of activities that committee 9 involvement in December would be useful, involvement in 10 February, I think, would be kind of late. I don't know-11 actually when the Commission is going to make a decision,
-12 but I see a fair amount of activity between now and 13 mid-December.
14 CHAIRMAN SEALE: This is a question we probably t
(,/ 15 need to bring up next week in our subcommittee meeting.
16 DR. KRESS: Once again, if there are no other 17 questions, I'd like to thank this crew for a very concise, 18 coherent and well done presentation.
19 MR. HOLAHAN. Thank you.
20 CHAIRMAN SEALE: Yes.
21 DR. KRESS: I will turn it back to you.
22 CHAIRMAN SEALE: Thank you, Tom. Thank you very 23- much. This was a good one.
24 We are scheduled to talk about the generic letter 25 regarding loss of reactor coolant inventory as our next p).
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-70 1 subject,.but for the moment, we are going _to take a 15
() 2 3
minute break until 10:35.
-then.
I look forward to seeing you-4 (Recess.}
-5 VICE CHAIRMAN POWERS: Let's come back into 6 session. We have now a presentation on the generic letter
. 7 in connection with shutdown events. I guess that belongs to
'S' 'Mr. Barton._Before you enter into that, I will remind the
-9 members that this is an area where we have had continuing
- 10 interest, shutdown events, and that we have had some 11 discussion of these shutdown events in yesterday's
- 12 presentation.
13 MR. BOEHNERT: Mr. Chairman, I'm informed that we 14 don t have a quorum here, 15 VICE CHAIRMAN POWERS: We_ don't have to take a 16 vote, so we don't have to have a quorum.
17 MR, BOEHNERT: Very good.
- 18. VICE CHAIRMAN POWERS: Let us proceed ahead. ,
19 DR. BARTON: Without a quorum, we will proceed.
_20 Thank you, Mr. Chairman.
21 The purpose of discussion with the staff today is 22- for the ACRS to review the proposed final version of the NRC 23 .
generic letter on loss of reactor coolant inventory and' 24 . associated potential for loss of emergency mitigation 25 functions'while in a shutdown condition.
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I 71 1 -Just as'a short background, the ACRS has had a
) 2 presentation on this in the past, just to refresh your 3 memory. This is the September 1994 Wolf Creek plant event 4 -during shutdown. It was a significant event whereby the 5- high probability that the ACCS pumps would have been 6 , disabled due to flashing of_ steam incapacitation caused by 7 'hct water in the suction header.
8 The staff has shown that this event was 9 significant, CDF on the order of ten to the minus three per 10 reactor year was assigned to this event.
11 -The committee received an info briefing in March 12 of 1995 on this event. It was also discussed in an ACRS 13 meeting on March 17. At that time, the committee decided to 14 have a discussion with the staff after public comments were 15 resolved on a generic letter, which brings us to today.
16 The staff is prepared to brief us today on the 17 final version of the generic letter. At this time, I'll turn 18 it over to Alan Levin, who will make the presentation for 19 the staff.
g 20 DR. KRESS: I believe that ten to the minus three 21 was conditional probability.
22 DR. BARTON: I'm sorry; yes. Thank you, Tom.
23 MR. LEVIN: Thank you. This w121 be a fairly 24 brief presentation on the current status of the letter. I 25 would like to acknowledge the people who have actually been
('~~).
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72 1 :most'cJosely involved-in the technical' work on.the-generic _ -!
_() !> letter.
3- The_ original:workfat the beginning_was doneLby-
=4L JLambros Lois, and more.recently, Muhammad Razzaque has=been-5 .the responsible person in the Reactor Systems Branch, for 6 shepherding this thing, and Marie Pohida, who is sitting at 7- .the table, was responsible.for doing some of.the PRA work,~ ,
8 the estimates of-conditional' core damage frequency on this.
-9 .If you have questions specifically on that, they best be 10- addressed to her.
- 11- I think'this is the first time I've come before 12- the committee to talk about'something other than advanced 13 reactors. A little' bit of a change of pace.
-14 What we are planning to do here is to issue a 15 generic letter. requesting that licensees provide information 16 to verify compliance with licensing bases under 10 CFR 17- 50.54 (f) .
18 To give you some background, to augment what Mr.
19 Barton just said,-the initiating event for all this was the 20 Wolf Creek drain down on September 17, 1994. The event 21 occurred at hot shutdown conditions. The reactor coolant
' 22- system was'at about 340 PSI'and at about-300 degrees F.
4 23 Operators were attempting to reborate one train of 24 .the. residual ~ heat removal system and were simultaneously
- 25. performing valve? maintenance an,d testing on the other RER -
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73
- 4 t A 1? train. -
( 2- -Concurrent activities-and possibly inadequate c3 communications resulte'd in'the: operators opening two 4~ + isolation valves, which created a: direct path for the:
' ~
~
5- reactor coo 1 ant system to drain from the hot leg to the 6 --refueling waterfstorage tank and approximately 9,000 gallons !
E7~ ofLRCS inventory. drained to'the RWST in a period of about 8- Lone minute.
9 DR. KRESS: .Ttcuse me,. Alan. Could you tell me a 10 little bit about'what the licensing bases is there out of 1 11 compliance?-. 50.54. .I'm not familiar with what that is.
12- MR. LEVIN: 50.54(f) is the provision that allows 13 the NRC to request information from licensees to verify 14- compliance with licensing-bases, and-I'll get to the >
15 regulatory basis:for the information request.
, 16 DR. KRESS: And which reg they are out of u
17 compliance with.
18 MR. LEVIN: Yes. This figure is the last page in
- 19 your packet of slides, and this shows the configuration of l
- l. 20- the system.-
21 Is there a portable mike? It would-be a little 22 easier.
23 VICE CHAIRMAN POWERS: Yes.
24 MR. LEVIN: Looking at this drawing,'the train of
- 25. RHR-that was being reborated.is this train here, and the
~
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74 1 flow path involved suction from the refueling water :orage 2 tank, which is up here, through this entire piping twork, (Vr) 3 and this containment spray pump-up here is used to c.eate-4 the low pressure point in the system so that you don't just 5 have stuff going in dnd out of the RWST. That comes back in 6 here.
7 This valve, 8717, is the one that was open to 8 permit reboration. At the same time, the testing was going 9 on on this valve, they opened this valve, the drain down 10 path was. created as shown by the arrows, going from the hot 11 leg into the refueling water storage tank like that.
12 The plant design that is significant about Wolf 13 Creek is there is a common auction header from the refueling 14 water storage tank for all ECCS systems. The drain down 15 could have put high void fraction hot water, because of 16 depressurization from the RCS, into that common suction 17 header within about three to five minutes, if it had not 18 been terminated, and the high void fraction liquid, had the 19 pumps then been required to come on, very likely would have 20 caused failure of the ECCS pumps due to steam binding and 21 subsequent loss of RHR function if the RCS level fell below 22 the hot leg.
23 There was also a potential for water hammer damage 24 to RHR piping and the RWST. That's generally fairly low 25 pressure piping. The tank is a low pressure system. Had t
' ')
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, 7'5 1 .that occurred =, ittwould have resulted in: containment bypass.
() 2 AEOD,'in reviewing ~ events for'1994, considered-1F that'as the most safety significant event--for.the' year. -
=
~4 ' There~was-an estimate of conditional-core damage frequency :
15 at about three-times ten to minus three.
6 VICE-CHAIRMAN POWERS: When you say conditional-7- core damage probability, conditional on this; configuration 8 of!the plant?
9 MR. LEVIN: Conditional in this initiating event. I 10 MR. HOLAHAN: Conditional-upon the initiating 11- event, with judgments made about the likelihood of recovery 12 and all that.
13 .VICE CHAIRMAN POWERS: Only if at a fraction of 14 the time --
15 MR. HOLAHAN: Even if it's 100 percent of the 16 time, it's because-you made a judgment that would happen 100 17 percent of the time. It's not -- it's a result of your 18 judgment. It's not an arbitrary assumption.
19 DR. KRESS: The containment bypass, do you have to 20 have damage the piping to get that or is the RWST already 21- outside the containment?
22 MR. LEVIN: The RWST is already outside the
, 23 containment.
24 We: view:the event as rather unique in that- it
-25 simultaneously has-the potential to cause an accident and to f
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-76 :i T .'cause-theiloss;offmitigating capability for the-accident.
N 2 VICE' CHAIRMAN POWERS: What:thisfsays-is that you
,31 -have had a loss of defense 1inEdepth here. -
,4: ' M R . > L L'V I N : That's correct. ;
MR. HOLAHAN: In~ numerous ways'. It removed
-6 diversity, redundancy ard containment. -
iMR; LEVIN:. Here we are th ee- years - later,f and I 8 think.it would be~useful to' review the history here. The '
_i 9 first action taken by the staff was to issue Information
- 10: Notice 9503:in January of 1995, alerting licensees-to the til- causes of the event and the potential vulnerabilities.
12 .- AEOD: released a' report.about two months.later _.
,- 13I . describing this event and further cataloging a total ~of 19-events involving loss of-RCS water to the RWST. I want to
-15 hasten to add here that not all of these, in fact, the large 16 majority of them.were not at elevated' pressure and .
17 temperature. However,-there were other events, at least one WC '
18 other event that occurred that was at elevated pressure-and 19' temperature.
20 An additional supplement to.that information-
_21 notice has been-issued,_providing further information about 22 the event and' discussing the AEOD report.
23 Since them time, since the time of the initial-2 4 -- 'information notice, the staff has been working on a generic.
25 ~1etter'to requestLinformation from licensees who may be ;
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77 1 vulnerable to similar types of events.
() 2 VICE CHAIRMAN POWERS: Do we now have some 3 estimate of what the probability of the initiating event is?
4 :MR. LEVIN: I think that the initial report 5 estimated the initiating event probability as something on 6 the order of ten to the minus three.
7 VICE CHAIRMAN POWERS: On the face of it, that 8 seems pretty-reasonable..You have 2,500 years of reactor 9 operating experience divided roughly half and half. You have 10 one event. It sounds like it's a ten to the minus three 11 event.
12 MR. LEVIN: Yes, that seems to be about the right 13 ball park. If you consider this as a containment bypass 14 potent.ial event, ten to minus six is sort of in the larger 15 range that we consider to be significant.
I6 VICE CHAIRMAN POWERS: I suppose that's not quite 17 a fair way to look at it to get a round number estimate, the 18 way I did it, because you should -- the devisor should be 19 the number of hours that you are in hot shutdown.
20 MR. HOLAHAN: No, I don't think so.
21 VICE CHAIRMAN POWERS: Per year.
22 MR. HOLAMAN: No. Then I think you have to also 23 account -- I think it comes out the same.
24 VICE CHAIRMAN POWERS: Yes, I think you are right.
25 You end up multiplying and dividing by that number. It's a
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T1_ 4 (2) MR HOLAMAN:- Whatsit_says-i's you may have.aL -
3! = spike =,: if!in fact-this plant has a vulnerability,_that you
[ J4- would have-a spike, but-it--would be a. narrow spike,-so you --
- 5; don't'run into this problem all that-often.
6 VICE CHAIRMAN POWERS:- One'of the issues to f
~
7 confront'is thatiwhen we go through and.do screening on 8 shutdown events, this particular mode of operation was 19- -judged on_the whole not to pose much risk. Yet, we have a 10 ten to the minus initiating event here.
11- It does not seem consistent with the analysis.
-12 MR..HOLAHAN: It's not. I think it's fair to'say.
13- 'it's-not consistent with our previous understanding of the 14- transitional risks. That's one of the. reasons that we think
-15 it needs some attention. I think'it was something of a 16 surprise.
17 MR. COLLINS: This event depended a lot on human :
18 error and-the uncertainty associated with human error, we- _
19_ all recognize that's a big uncertainty. This;just 20 reinforces that, a-21 VICE CHAIRMAN-POWERS: The analysis was done-on 22 which modes'of operation constituted the most risk. We'saw
-21 some point values. Had we looked at the uncertainties as we c24 should have, we would have-probably thought of this sort of 25; thing.
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79
~
~ 1" MR.- HOLAHAN:- In.principlet-or_at least having.not
[ : 2 ;- spotted.-it, wetshould__.be awareLof the fact <that we don't- -
L-3 :
know.as much as=we_ought:to;know about; transitional modes ,
14- and maybe even-shutdown. Weishouldn't be so surprised when- :
5; - weLare surprised. ;
6' MR.=RAZZAQUE: Ilam i'n;the PRA-Branch of NRR. I 1
7J just want_to_say__that we cannot pass judgment on the 8 numbers.
- 9~ -VICE CHAIRMAN POWERS: I understand. I-should .
- 101 tbavefpredicated it. _I said some sort of--an estimate,-and *
'll i
it's a-very crude estimate.' I understand that, and that's
- not' fair..
12L ?
13~ MR. HOLAHAN: I thought it was entirely consistent 14: with our previous session on point estimates and thinking 15- about their value and use, 16 VICE CHAIRMAN POWERS: Good point.
.MR. LEVIN: The initial. version of the generic
- 18. letter was an information request under 50.54(f) to 19 determine vulnerabilities-with possible future __ actions-20 . necessary.to correct the problems where identified.
g 21- The' regulatory bases cited for the information' 22 ' request _were general design criteria 34 and'35, which 23- address requirements for residual heat removal and for ECCS
- 24 performance.
E25: This version of the letter was taken to the
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8d 11 :committeel-toireviewigeneric requirements to CRGR. After (f 2' l discussion with them, theistaff modified the: generic letter-- -
-3~ .-to includela backfit that licensees correct' problems:when
.41 identified'and notify the.NRC_of what had been done. The 5 backfit's were justified as a compliance exception to 10 CFR 6 501109 and were justified-as necessary_for compliance with 7- -the-GDC's. ,
8 This version of the_ generic _ letter, the revised 9- version,-was put before1the Commission. The Commission
'10
. requested-that the staff modify some of the references to-
- ll' the GDC's=and granted permission.to-publish the draft 12 generic. letter in the Federal Register for_public. comment,
-131 and this'was done earlier this year.
14 DR. BARTON: Is it typical for an event that the b)
\ms 15- l agency consider significant such as this one, could take 16 three years to get to the point where we are now? That's 17 kind of bothersome.
~
18 MR. LEVIN: Yes. -We think that's bothersome, too.
19 We don't think it should have taken this_long, but there 20 have been a lot of changes in direction. There's not a good
' 21- reason for it. For something this significant, I think we -
22 'would have liked to have seen something get out-sooner.
23 MR. HOLAHAN: ?It's bothersome _to us as-well.
24 MR. LEVIN: I'm going to address that --
25~ MR. HOLAHAN: However, I'd have to say over the-g L
l
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81-1" "past;several-years,.the processes J for handling these sortfot
- r y-2 issuest-have'become more complicated and involved more.-
3] ~
3 committees"and levels of reviews..At' the-same time, IEdon'ti (4' want to use that as an excuse-for taking three years,_I I
5 think it'certainly is a complicating-facter.
6 MR; LEVIN:- I'm going to address a*.'.ittle bit that [
7 question.when-I discuss the new version of the generic 8 . letter as_well, because I think it's relevant, j
-9 Public' comments were received-earlier thic year, L10 within the:60 or 90 day period-specified in the Federal'
~
11 Register.- The comments were from the_ industry and they were 12 . fairly consistent in that they_took exception to the 13 citation of the-GDC's as regulatory _ bases and for compliance 14 -backfit 's based cn1 those requirements, the_ argument being 15 that GDC's are design requirements, the plants had been <
16 approved, the designs had been approved as meeting the 17 GDC's, and it was difficult to see the justification for 18 turning around and saying that now they didn't meet the 19 GDC's and backfit's were required. [
20 There-was no regulatory analysis justifying 21 backfit's and the amount of work was claimed by the industry
.22- to be anLexcessive burden on licensees.
23 We reviewed the comments and reviewed the content 24: of-the 1etter in light-of events over-the last three years 1
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82
_1
- Linsightsvland_we decidedtto substantially~modifyjthe bases-- *
!2: _for the generic letter.
3; 'We have gone back totan information only format 14 ratherJthan_50-109 exception. We are-requesting-information 1 di ' under: 50.54 (f) . ,
- 6 'The regulatory basis has been changed from the '
7 GDC'st to 10 CFR 50, Appendix-B, which is quality assurance- .
8; . requirements.
9 Wolf Creek occurredfas a result of operators 110 failing to follow documented procedures. This11s.the 1
.; 11 -citation that'was used to' fine them, to fine Wolf Creek-the
-12 ' civil penalty.
13- Similar events-that have been documented b' GEOD 14- have resulted either from a-failure _to follow procedures or
) 15 a failure to have adequate procedures.
16 GDC's and a lot of the other regulations address 17 design issues and exception criteria for systems 18 performance. They don't address operations related 19- activities and human performance. This, I think, is part of
.20_ the' problem and part of the reason it has taken three years.
21 We;have been looking around for the appropriate regulatory 122 basis on which to take action, based on improper activities 23 that were-conducted.
p 24( Appendix B applies to everything;_ design, 25: ; construction,-operation of_ plants, and Criterion V of
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1 Appendix B, which is entitled " Instructions, Procedures and j
() 2 3
, Drawings," states, and I'm quoting here, " activities
- ffecting quality shall be prescribed by documented 4 instructions, procedures or drawings of a type appropriate 5 to the circumstances and shall be accomplished in accordance !
6 with these instructions, procedures or drawings."
7 This appears to be the best and most appropriate 8 regulatory requirement to address the absence of procedures 9 or the failure to follow procedures.
10 oR. BARTON: You said this is part of why it has 11 taken so long. From my experience, my residents nc~er had a 12 problem finding that one when they couldn't find anything 13 c100, and in a very short time frame.
14 MR. LEVIN: But these sorts of requirements are 15 not often cited for generic letters. They are usually tied 16 to other parts of the regulations.
-17 VICE CHAIRMAN POWERS: On the other hand, this 18 requirement doesn't say don't drain the water out of your 19 reactor when you are in shutdown because you will lose the 20 ability to cool the core.
21 DR. KRESS: You have to have a broad definition.
22 VICE CHAIRMAN POWERS: You have to have an awfully 23 broad definition, but I think back to the proposed shutdown 24 rule which said during this mode of activity, we have a
- 25. completely adequate basis for regulation during that regime.
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l 1 We go searching'around in Appendix B for-something that l 2 quite frankly.-does not speak'to the' amount of coolant 3: inventory.
4- I mean, I'm confused here.
5 MR.-HOLAHAN: I don't see.an inconsistency. If we 6- had found difficulty in finding a regulatory basis for 7L citing Wolf' Creek because there were no requirements, then I '
-8' would say that's an indication that you need.an additional 9 rule. .
10 VICE CHAIRMAN POWERS: He told me it took three l 11 years to find this._
12 MR. HOLAHAN: No, we didn't take three years to 13 cite Wolf Creek. It took three years to make a decision 14 that a fundamental problem was not that. the plants needed to if be redesigned, which was not a forogone conclusion. ,
l 16 I think we could have come to the conclusion that '
17 this sort of fix would be placing too much reliance or.
18 operators and procedures to handle what is an inherently 19- poor design, ccme to the conclusion that the designs aren't ,
20 all that bad, in fact, they are entirely acceptable, that ,
i 21 they can continue to meet GDC 34 and all those-things and j 22 the licensing basis, buc that additional attention is needed j 23 on how activities related to those systems are conducted.
24 " I think it is entirely consistent with their 25 judgment about this mode of operation and whether it-needs ANN RILEY & ASSOCIATES, LTD.
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t 85 l
-t' 1 .to have more regulation. It just needs more. attention on
() 2 3
the existing regulations.
What we would say is that's why this is a i
{
4 compliance backfit or questions about a compliance issue, f l
5 because we don't see the need for more regulations, just
{
6 better_ adherence to the existing ones. .
.. ? DR. BARTON: I agree with that. Let me ask you a [
8 question and maybe you don't know the answer to this. At the 1 r
9 time of-thisLoutage, was the station utilizing NEI guidance i
10 on outage risk assessments, that very t
~ 11 detailed --
12 MR. LEVIN: I don't have any information on that.
13 MR HOLAHAN: I don't either but I would say that i
14 we know that it took place after the date at which those i
15 licensees were committed to do such.
16 VICE CHAIRMAN-POWERS: But in fairness, it would 17 have at best been a very new process to them.
18 MR. COLLINS: 91-06, guidance was issued three ,
19 years before the event.
20 MR. HOLAHAN: I think their implementation date 21 was December 31, 1992. ,
22 DR. BARTON: So, they.should have had that program 23 -ibplace.
24- MR. HOLAHAN -Yes. '
. i 25 DR. UHRIG: It might have been their first outage S
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l 86 1 after-the implementation date? ,
() 2 MR. HOLAHAN: It could have been.
3 MR. LEVIN: We do know that they recognized the !
4 potential. The licensee recognized the potential for this !
5 to occur and went ahead and performed the operations anyway. [
6 They-had a written procedure that basically forbade them !
7 from opening these two valves at the same time and they went i
8 ahead and violated the procedure, j 9 As I said, we are requesting information from 10 licensees and the specific information to be requested is to 11 ask licensees to assess whether they are Nulnerable to these 12 kinds of common cause failures.
13 There may be plants out there that because of 14 their designs do not have the same level of vulnerability O 15 such as a common suction header.
16 Further, to describe the features of their 17 Appendix B program, with consideration of the plant specific ,
18 design features, that provide assurance that safety related 19 functions of these systems will not be adversely affected by 20 activities of hot shutdown and hot standby. These sorts of 21 things would be training requirements, independent 22 verification of valve positions during these evolution's and 23 so forth, 24 Adequate training of personnel, indoctrination, is 25 required by Appendix B. It's part of Criterion II in the QA ANN RILEY-& ASSOCIATES, LTD.
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87 1 program, and it is specifically addressed there.
() 2 There'have been other modifications made to the 3 original version to reduce burden on licenseco, to focus on e i
4 larger diameter lines, where the drain down would be 5 reasonably rapid and core recovery or significant reduction 6 to inventory to take place in a fairly short period of time, 7 and also on those systems on those lines where there is a 8 small number, ten or fewer, isolation valves, where there 9 would'be more of a potential for being able to inadvertently 10 defeat the isolation capabilities of the system.
11 DR. KRESS: You are going to reserve judgment on 12 what you will do after you receive this information to see 13 what it says?
14 MR. LEVIN: Yes. I think we want to get the 15 information first, see how many licensees are vulnerable, .
16 what the level of vulnerability is, what they are doing to 17 address it, and then see where we are going to go from 18 there.
19 MR. Il0LAHAN : In the first instance, what we want i 20 is to have an effect on lice.1 sees' performance. That is to 21 remind them of their respons Oility and that they ought to '
22 be dealing with this situation. In fact, it's not the 23 answers to the questions that are as important as the 14 licensees focusing their attention on understanding their 25 design and being prepared to deal with it seriously.
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88 1 If the staff takes no other action with this
() 2 3
information, I think that might be acceptable.
What I suspect that we will do, since these people 4 work for me, I suspect it rather highly --
5 [ Laughter.)
6 MR. HOLAHAN: -- is that we will look and see l l
7 whether there are plants that are particularly vulnerable l 8 and whose answers don't indicate that they either fully 9 understand or appreciate or take it so seriously, and that 10 we might follow up with some plant specific inspection 11 activities to look into individual cases. ,
12 What it would do is allow us to use this
'13 information, to assure ourselves that licensees are thinking i l
14 about this issue appropriately, and allow us to focus on j
() .15 what is hopefully a few or maybe no cases, where we can 16 focus our attention on what looks like a potential problem 17 area, rather than go out and gec lots of information from 18 all licensees or to go out and do an inspection activity for 19 all licensees.
20 DR. KRESS: Let me ask you sort of a peripheral 21 question. The information that you are asking for in this 22 letter, it is asked for in a time frame of 120 days from 23 receipt or something like that. How did you arrive at that 24 number? What consideration goes into dotermining that --
25 DR. BARTON: As opposed to 90 or 180 days.
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i 89 l 1 DR. KRESS: 90, 180, 200 or-next shutdown or !
() 2 whatever. .
3 MR. HOLAHAN: Well, judgment in how hard the 4 questions are to answer, how much information it takes, how 5 serious the issue is, compromise.- !
6 I think we recognize that if you ask for something 7 in 30 days, you probably won't get it anyway.
6 DR. BARTON: Or you won't want what you get. !
9 MR. HOLAHAN: You'll get half a job.
10 If you say 180 days, you send a message to people, 11_ both to yourselves and to others, that you don't consider 12 this very important among the other things the licensees are 13 doing.
14 In general, I think we recognize that 60 days is a
( 15 sort of minimum for which things can be done well. 90, 120 16 are typical numbers picked for things that you'd like to put 17 some attention on.
18 I don't like numbers that are bigger than that.
19 You have to ask yourself why are we really doing this if we 20 don't consider it very important.
21 MR. LEVIN: We recognize that in this case that 22 the licensees are going to have to go through their 23 drawings, make sure they trace through the lines anu so 24 forth, and that's not an insignificant effort.
25 MR. HOLAHAN: And I think by the very nature of
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l 90 l 1- these sorts of requests, if a licensee happens-to be at tne l k) 2 beginning of a two year field cycle and doesn't intend to go -
3 in these modes and has'some reason to suggest some different I 4 date, there's a mechanism for them_doing that. We will {
5 -listen to reasonable arguments. l 6 DR. KRESS: That's what.I was getting at. If they 7- are not-going to.be in this' mode for quite a'while, there's l 8 no concern about that particular point.
9 MR. HOLARAN: Well, what we can know is they are 10 ~ not-planning on being in those modes. !
'11 [ Laughter.] ;.
12 MR. HOLAHAN: There's a standard part of these I 13 _ sort of letters, you know, for a good cause, if they want to 14 make an argument for some other date and there's some reason l
.15 for it, I think we will always listen to them. We might not 16 always agree, but we will always listen. _;
17 MR. LEVIN: I did want to also observe that this 3
18- generic-letter is part of a larger action plan and the 19 action plan includes development of an inspection module to
. 20 look at these kinds of issues, to help guide regional 21 inspectors and resident inspectors. ;
22- The current status of the-generic letter, we are 23 working with the Office of General Counsel to resolve some 24 minor comments'about. regulatory citations, make sure we-have 25 a good story on regulatory basis,'and we are going to have
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1 to go before CRGR one more time prior to the release of the
() 2 generic letter, and that is still to be scheduled, but once 3' we get comments resolved with OGC, we will do that in the f
4 near future.
5 DR. KRESS: Just a question. Do you think in your 6 opinion that this particular type of event would have been 7 uncovered by good shutdown PRA? l 8 MR. LEVIN: I discussed that with Marie, because 9 we did see your questions in advance. In her opinion as a ,
10 PRA expert, and she can elaborate on this more if she'd 11 like, she does not think that it would have been uncovered 12 by a good shutdown PRA, but the potential for the event i 13 might have been seen, but the potential for a common cause 14 failure at the pumps as a result of it prcbably would not O 15 have been seen.
16 DR, BARTON: That's the struggle I have, we keep 17 talking shutdown rules and the need for it because of these 18 events, but coming from that environment, I have a 19 difficulty seeing where a shutdown rule would help me as an 20 operator to prevent something like this.
21 I think the key here is do you really do good 22 shutdown risk management programs, do you really stay on it 23 hour by hour as to what the activities are. You have 24 configurations which you prohibit from occurring in this 25 plan, but you have to make sure.somebody doesn't do
()'
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I 92 1- something stupid and schedule something like a test dur!.ng
() 2 reboration. That takes a lot of attention. It takes hour 3 to hour attention during a shutdown period to assure.that 4 you are sticking to your shutdown plan and you don't deviate 5 and do something else'because it's a convenient time frame 6 to do it, and if you do the test on something while 7 reborating, it could be that kind of issue. I don't know I
8 how you predict those kinds of things.
9 DR. KRESS: It seems like there should be a set of 10 general principles, like when you are working on --
11 DR. FONTANA: iou hase procedures, 12 DR. BARTON: llow do you prevent people from i 13 violating a procedure, you are back to the human factors, ,
14 human performance thing again, which we are all struggling 15 with, how do you improve that and reduce those events.
16 If you look at what we have talked about during 17 shutdown, 98 or 99 percent of what we have been talking 18 about is people deviating from procedures or from a plan, i 19 even though they had a good plan. They are all human 20 performance related. Somebody screws up and it gets us into 21 these shutdowns.
22 VICE CHAIRMAN POWERS: Let me sg) back to the 23 statement that a good shutdown PRA might not pick up this 24 sequence. I would think that a good shutdown PRA -- I would 25' think the strength of it would be to point out the two ANN RILEY & ASSOCIATES, LTD.
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93 1 valves in question constituted an important pathway around ,
() 2 the reactor. Whether it would pick up all the other things 3 or not, you would see a relatively high risk worth.
4 MR. HOLAHAN: One would wish for that, but if you 5 think in practice, we have a hard enough time predicting the 6 past, which in effect what a lot of PRA really is, take past 7 experience and put it together in an integral fashion.
B Before the Wolf Creek event, I think it would have 9 been more than expected of even a good PRA analyst to say 10 the likelihood of opening tnese two valves is going to
,11 contribute to a ten to the minus three initiating event f
12 frequency of something that's never happened.
13 VICE CHAIRMAN POWERS: My offhand feeling is they 14 would come up with a ten to the minus four initiating 15 sequence on that, because they would do something like the 16 probability of one being open is ten to the minus three, the 17 next one is going to be a human error, common mode 18 combination, and they will probably get another factor of 19 ten out of that, so they'd come in low.
20 MR. COLLINS: There are more factors involved 21 here. It has to happen when the system is pressurized and 22 they also have to recogn; e that this drain down path has 23 the potential to knock out your mitigating systems. You 24 don't just have a drain down event. You would knock out the 25 mitigation systems at the same time. All those things would
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94 1 have to be recocinized.
2 VICE CHAIRMAN POWERS: When you are talking about 3 piping systems, PRA's are pretty good. They are good at l l
4 drawing out networks and things like that. Where they come l 5 a little weak is on the common mode and human error.
6 MR. LEVIN: From what I understand, the ,
I 7 configuration at the plant, they probably would have also i 8 come in low, because I think those two valves are basically 9 -in the same place. They are very close to one another. The 10 two separate teams that were working on these operations ;
11 were basically within visua? range of one another.
12 VICE CHAIRMAN POWERS: so, they'd come up with ten !
13 to the minus fifth. They'd get two orders of magnitude low.
14 MR. LEVIN: Maybe. I don't know. '
15 VICE CHAIRMAN POWERS: I'm just guessing how 16 they'd handle the human error. The probability of the 17 second valve opening, just guessing how it would be handled, 18 you are right. They'd probably come in and put ten to the 19 minus fifth on that.
20 DR. FONTANA: The important part is identifying 21 that path could occur and the important part is then putting 22 it in a procedure so you don't do some of those stupid 23 things.
24 DR. BARTON: But they did that.
25 MR. HOLAHAN: If a PRA analyst would have come ANN RILEY & ASSOCIATES, LTD.
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l 95 1 across this and wisely recognized that opening these two r~
f 2 valves while the system is hot could have this effect, 3 rather than model it as a ten to the minus three event, I !
1 4 think they ought to ring the bell in the operations i
5 department and say, you ought to get this thing down to ten l 6 I to the minus five so I don't have to model it. In effect, 7 that's what our generic letter is trying to do, to push down 8 the initiating event frequencies so this is not a dominant ,
9 thing that needs to be modeled for the future.
10 DR. FONTANA: It took three years for this generic L11 letter to come out. Is industry going to tell us later 12 about other ways of getting-this information':
13 DR. BARTON: NEI intended to talk to us about
,_ 14 this.
- k. 15 MR. LEVIN: That concludes my presentation. I'd 16 be happy to take any other questions.
17 DR. MILLER: I think the earlier question of 18 whether they are using the NEI guideline would be 19 interesting to find out. I think it goes back to John's 20 point. If they are using that guideline, that could give us 21 an idea of the guideline they are using.
~22 MR. HOLAHAN: I think that's an interesting point 23 but I'm not sure it would change the direction of our --
24 DR. MILLER: No.
25 MR, HOLAHAN: It's just information that would be
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i 96 1 valuable, i
() 2 MR. COLLINS: Also recognize there is very high 3 level guidance in 91-06.
4 VTEF CHAIRMAN POWERS: Yes.
5 MR. COLLINS: Saying that you are implementing ,
l 6 that guidance -- 2 7 VICE CHAIRMAN POWERS: Saying that you are ,
8 implementing ORAM might mean more?
9 MR. HOLAHAN: I don't believe it would cover the 10 situation.
11 DR. VHRIG: Do you have an estimate of how much 12 effort has to go into responding to this?
13 DR. BARTON: Their estimate is about 80 man hours.
14 MR. HOLAHAN: b' ell, there may be a technicality O)
(_ 15 here. The numbers that go in the generic letter are not 16 necessarily all of the engineering work that goes into 17 something.
18 DR. BARTON: What does it say about 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />?
19 Entire analysis?
20 DR. MILLER: We may hear differently from NEI.
21 MR. HOLAHAN: I wouldn't be surprised.
22 MR. LEVIN: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> might turn out to be an 23 average. There may be plants out there that can look at 24 their design configuration and say we are not vulnerable.
25 DR. BARTON: Just because of the design, sure.
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i 97 )
i 1 MR. LEVIN: There are others that-may have to go {
() 2 into some additional work; and this is an average over all
~
3 licensees. It's probably a fairly' wide range.
4 -
DR. BARTON:- Any other questions of the staff?
5 DR. KRESS: We are not asked to do anything? !
6 DR. BARTON: Well, yes. We need to prepare a-7 letter on this; yes. Hearing none,- thank you very much ;
i 8 At this time, wn will hear from NEI. ,
9 MR. HOLAHAN:- No charge.
10 VICE CHAIRMAN POWERS: This doesn't sound like an-11- arm's length approach here, does it?-
i 12 [ Laughter.) ,
13 VICE CIIAIRMAN POWERS: Let's see if he wipes them
- 14 off before he uses them.
'35 [ Laughter.)
16 DR. FONTANA: Let's see if he interprets them the i i
17 way we did.
18 MR.-PIETRANGELO: Thanks for the opportunity to 10 talk to the' committee-about this phrticular proposed generic 20 letter. We haven't seen it, obviously. We did see the 21 draft generic letter and-did comment on behalf of the 22- industry and I think a number of individual licensees also ;
23 provided-the NRC with comments. ,
j 24' Based on the staff's presentation this morning, it 12 5 'looks like there'has been-significant improvement to the- ,
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98 1 generic letter. ,
() 2 First of all, this particular scenario of RCS 3 drain down was addressed in NUMARC 91-06. Did it addresc the ,
4 potential for the common cause value with the ECCS suction 5 header? Part of what went into developing 91-06 was an-6 extensive review of past events and operating experience, as 7 Well-as any analytical insights we had from PRA, and I don't 8 think, at least if my memory serves me correctly, we didn't 9 describe an event where the ECCS header was rendered ,
10 inoperable. There was a 8pecific guideline addressing 11 inadvertent valve manipulations and potential drain down to 12 the RCS.
13 I guess, again, my understanding of the Wolf Creek 14 event was they did, at least from an administrative patrol 15 standpoint, had that in place and didn't follow their 16 procedure. I also take other similar events documented by 17 AEOD, I'm sure that's true. It may have been in fact from 18 inadequate procedures in that regard.
19 At least with regard to the regulatory basis that 20 the staff is citing, it's a lot more appropriate than what 21 was being cited before. I think that wan discussed 22 adequately this morning.
23 We stil' don't know the specifico. You can read 24 these words. This is a compliance backfit still, with these 25- words, basically saying that activities affecting quality ANN RILEY & ASSOCIATES, LTD.
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99 1 shall 1xs prescribed by documented instructions and so forth, !
-() 2 commensurate with the circumstances, just reading from the 3 slide.
4 That's what the compliance backfit is about, to 5- comply with that for that condition.
6- When you-get to the specific information 7 requested, the information requested has to demonstrate 8 compliance with that provision we just saw. It's still 9 unclear --
10 DR. BARTON: Your response needs to say you comply
(
11- with QA, the Appendix B program, right?
12 MR. PIETRANGELO: Yes. I'm stil'. a little bit 13 unsure about do I need to describe my whole ECCS system.
14 It's described in the SAR now. Do I simply need to show that 15 I have administrative controls or procedures that would 16 preclude such an event if I follow them.
17 This aspect of Appendix B deals with inadequate 18 procedures and doesn't deal with not following them.
19 I respect the staff's intentions for wanting to 20 send a message to licensees that this is an important 21 scenario here that we can't afford to mess up on. It's too 22 significant.
23~ I think the.information notice certainly brought 24 attention and all licensees treat information notices very 25 seriously. .I can't say with 100 percent certainty, but ANN RILEY & ASSOCIATES, LTD.
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- 100 1 pretty darn close that I'm.sure INPO issued a SOER on this
()
2 particular event, but.I don't know the number off the top of
, 3 my' head.
4- Does the staff xnow?
5 MR. HOLAHAN: I believe INPO did issue some 6 document. I don't-know at what level.
7 MR. PIETRANGELO: With regard to the question that 8 came up previously about what the industry has tried to do
-9= in response to this event, certainly INPO shares a 10 responsibility in getting-that kind of information out.
11 I_think the_ staff jumped on the information notice 12 appropriately and very quickly after the event, in fact ,
13 within a couple of months.
14 DR. BARTON: I think information notices do get i O' 15 treated differently than generic letters that require a )
I 1(i response.
17 MR. PIETRANGELO: They do. They do not require 18 specific action;and response to an information notice, but they are treated and reviewed by each licensee. l
- 20. Again, getting back to this slide, given that we 21 are_trying to show compliance with that particular portion
, 22 of criterion V of' Appendix B, again, not seeing what's in 23- the letter and what',s being requested, whether some of this I 24 stuff is necessary, I don't~know. ;
25 Description of the features of the QA program. I
]
4
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t 101 1 think what we need to show is that we have procedures and
() 2 administrative contrals that would preclude such an event, ;
3 and we should follow them. That'c the main thing here.
4 4 Gary talked about making sure the people knew how 5 important this was and that they understood their design. I 6 think that's a good message to send. I'm not sure how one 7 could convey that in response to the generic lett.er, given 8 that you are trying to comply with that portion of Appendix 9 B.
10 In any event, I think this is certainly a more 11 appropriate response from the staff to the event than what 12 was proposed earlier this year. I think it also confirms 13 the point that there is regulatory oversight and bases for 14 shutdown, and Appendix B is very broad and is interpreted
() 15 very broad and always has been to apply to shutdown as well 16 as some other regulations.
17 That's the only thing I wanted to share with the 18 committee today. Again, not knowing the specifics of what's 19 requested, I would ask that we focus on Criterion V of 20 Appendix B in terms of demonstrating there's administrative 21 controls in place to preclude another Wolf Creek 9 Vent.
22 DR. KRESS: Would that automatically include some 23 sort of description of the configuration?
24 MR. PIETRANGELO: I'm sure it would have to. What 25 bothered us about the first one is discuss all possible s
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i 102 1 permutations of errors of commission. That's pretty open
() 2 ended. I would just ask in your review, we won't have a 3 chance to see it, but that it's focused on Criterion V of ;
4 Appendix B.
5 The SAR expectation, I think, based on our 6 initiative in 1991, there are in fact procedures in place to 7 preclude these things and they need to be followed i 8- obviously.
9 Thank you very much.
10 DR. BARTON: Thank you. Any questions?
11 (No response.]
12 DR. BARTON: Thank you, Tony.
13 I want to thank the staff for theur presentations 14 and also the comments frou NEI. The committee having no 15 nare questions, I think we have enough information to 16 prepare the letter that we need to do. Bob, at this time, 17 I'll turn it back to you, or Dana.
18 CHAIRMAN SEALE: I think it's Dana. Dana has the 19 ball.
20 VICE CHAIRMAN POWERS: And I can turn it back to 21 the chairman.
22_ CHAIRMAN SEALE: You just came in to catch the fly 23 ball. Well, there's not anything at this point scheduled on 24 the agenda for the next few minutes.
25- Are there any questions that any of the members
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103 1 would like to bring up? Does the staff have anything else l 2 they want to say?
l 3- MR. HOLAHAN: I'll leave well'enough alone.
4 [ Laughter.) ,
5 CHAIRMAN SEALE: The dog is lying, he may not be !
6 sleeping, but.you are going to leave him there anyway-.
~7-I think that I will go ahead and.suggest that we :
8 acess at this time until 1:00, recognizing that several l 19 people have letters they want to be working on and preparing -
10 - for other events,-and we have some more interviews coming 11 .up.- We will reconvene _at.1:00 and meet with the Acting 12 Deputy Executive Director for Regulatory Effectiveness.
13 'Whereupon, at 11:25 a.m., the meeting recessed, 14 'to. reconvene at 1:00 p.m., this same day.]
15 i
16 i 1 *t i 18 19 20-21 122
-23 24-
-25 E
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104 l 1- AFTERNOON SESSION !
() '2
- 3- CHAIRMAN SEALE: We will go back on the record.
( 1 : 0 3 p . m '.')
4 Before we.get started there are a couple of :
5 -things. There is a reconciliation package we have here
~6- which.is imposing -- :
i 7 -VICE-CHAIRMAN POWERS: Monumental ;
8 CHAIRMAN SEALE: Monumental even, and so I would 9 urge the persons who are identified as being the --
10 DR. FONTANA: Reconciliators.
l 11: CHAIRMAN SEALE: Yeah, the reconciliators-to >
12 surreptitiously go take a look at those as we proceed so 2 .
13 we'll be able to dispose of those things'on a timely basis .
14 .when we get to that issue.
15 We're having a meeting at this time with Ashok 16 Thadani on the Acting Executive -- Deputy Executive 17 Director -- boy, I've had problems with that title all I
18 morning.
19 DR. BARTON: Maybe you ought to get another job 20 with an easier title.
21~ CHAIRMAN SEALE: - Yeah, that's-right. ;
22 -[ Laughter.)
-23 MR. THADANI: I have problems with that too. ;
24- CHAIRMAN SEALE: Well, I tell you, the one~that ,
~! S - really got me, at one-point'I looked at that real quick and
(- '
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e
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105 1 I' read Aging Deputy---
+
( w) . 2 [ Laughter.)
3 And I figured I was really in trouble, and maybe 4 you were too.
5 Anyways, we're going to hear more about the 6 regulatory effectiveness program. I think most of you will 7 recall we heard about this in the embryonic stage somewhat 8 earlier from Ed Jordan, and I think w9 all are looking l l
9 forward to being brought up to date on it, and so if you !
10 will, we're all ears. And you have an hour-and-a-half on 11 the schedule.
12 MR. THADANI: Do I come over here and -- )
13 CHAIRMAN SEALE: Yes, please, come up here where l l
14 we can look you in the eye. And you have an hour-and-a-
\s / 15 half, and even maybe more if you're eloquent.
16 MR. THADANI: An hour-and-a-half?
l 17 Let me first introduce my colleagues here. You ;
18 know them all. Billy Morris, who's the Act.ng Deputy 19 Director of Office of Research, and Tom Martin, who is right l l
20 now detailed to work for me on the Excellence Program, j l
21 Billy has been also spending a fair amount of his time 22 trying to help guide, direct this program, and I think that 23 the two of them have played in my view an invaluable part in 24 terms of making progress that I think we've made so far.
-25 I asked John Craig to join us also, because an
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106 1 element of this program-has to do with the role of the ;
() 2 industry, and I was going to ask at an appropriate time for-John to come on and talk a little bit about what he's doing 3
4 in that arena in terms of working with the industry to see 5 how we can take maximum advantage of their initiatives and 6 so on.
7 You've heard from Ed Jordan in terms of the 8 organization, the Deputy Executive Director for 9 Effectiveness. I have trouble as well, Bob, on trying to 11 0 say what this position is. But as you know there are four 11 offices thnt report to me, the Office of Research, then the 12 Analysis and Evaluation of Operational Data, Office of 13 Investigations, and Office of Enforcement.
14 The thinking as I understand behind this 15 organizational structure was that this brings together four 16 offices. The output that these offices come up with can 17 play a very important independent role in identifying where 18 we might be doing well, where we might not be doing so well, 19 and to take advantage of the outputs.from these offices and 20 try and enhance our performance. So two parts. Each office 21 has responsibilities that I believe you're quite familiar 22 with. And then to try and integrate some of the information 23 that comes from these offices, and taking, using that 24 information, taking a look at ourselves to see how well we 25 are doing.
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107 1 We had -- I thought I would try and devote much of
() 2 the discussion this afternoon to regulatory excellence, L
3 because we've had fairly extensive dialogue on research 4 programs, and I know Tim Martin was here talking to you 5 d about some of the AEOD initiatives, and in fact there is
., some of the work AEOD is doing I will talk about as how it 7 might relate to the concept of excellence, t
8 If it's okay with you, you have a handout. I 9- would just sort of try and go througn that page by page.
10 But if you would prefer that I use the viewgraph machine, I 11 would do that.
12 CHAIRMAN SEALE: It's not necessary.
13 MR. THADANI: Okay.
14 CHAIRMAN SFALE: Whatever you --
15 DR. FONTANA: Ashok, if you don't turn the 16 machine, could you turn it off, because it's a bright light 17 behind you -- so we can see you a lot better.
18 MR. THADANI: You want to look me straight in the 19 eye.
20 CHAIRMAN SEALE: Exactly.
21 MR. THADANI: So now the light is off.
22 At a meeting, at an earlier meeting with you I had 23 said-that I believe NRC is a learning organization, and I 24 happen -- I think that's certainly the case, but if I might 25 discriminate a little bit now, I would say we're a learning n
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108 I 1 organization, we are somewhat more reactive than proactive
/^N i ) 2 in terms of dealing with potential problems. And quite i 3 frankly it goes back many years. ;
4 I remember I was with the Agency during the March 5 of 1979 when the accident at Three Mile Island took place.
6 As I think many of you know, there were I think about 10 7 different investigations of the accident, and there were a 8 lot of reports written. A number of them identified some of 9 the lessons that could be learned from that accident and how 10 the Agent / might improve itself in terms of its activities. '
11 1 Many of you know of course some of the more recent issues on 12 Millstone and Maine Yankee that have led to internal self-13 assessments, trying to see how we can enhance our efforts.
14 Then e.here are some of the other organizations,
) 15 and here I would say the Advisory Committee provides input 16 on a number of issues which we -- it's important input in 17 terms of going back and taking a look to see if we're doing 18 the job that needs to be done. Your input is more I would 19 say in the technical areas, areas like risk-informed 20 approaches or human factors program plan where 1 know we 21 need to do better. But that's very, very important input in 22 the technical arena. '-
23 We also get input from General Accounting Office, 24 Office of-the Inspector General, and whenever there are so 25' many significant events that take place. But by and large ANN RILEY & ASSOCIATES, LTD.
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109 1 what this reflects is what I would call a more reactive (s,) 2 approach and not a proactive approach. And the Chairman of j 3 the Commission was very insistent that we need to have a i 4 systematic and proactive approach of self-assessment and 5 improvement, and that is really what led to the development j 6 of Direction Setting Issue 23, which is regulatory 7 excellence.
8 In Diret: ;on Setting Issue 23, regulatory 9 excellence wcs defined as it says here as a dedication to 10 safety, a commitment to the principles of good regulations, 11 and the pursuit of superior staff performance. That is, f
12 excellence is really an ideal that we all want to strive 13 for, that is to apply the highest standards of performance ,
14 to our regulations, to our processes, and to our people.
() 15 And I want to emphasize "and to our people." As you will 16 see, we are very cognizant of the need to pay attention to 17 grassroots, to cultural issues, and so on, we go on.
18 And there are two elements of regulatory 19 excellence as defined in Direction Setting Issue 23. The-20 first one is regulatory effectiveness, and that focuses on 21 the clarity, coherence, and consistency, and the technical 22 soundness of our requirements. Some of these words probably 23 sound very familiar to you because I've seen them in a 24 number of letters coming from you to us.
25 And really it just comes back to a bit of the
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110 1 discussion that we had during the time you were looking at
() 2 the research program the last two days. What's the role of 3 research, taking a look at regulations, for example, are 4 they appropriate, adequate, cr not. So this basically says 5 our regulations focused on safety, which is I think what you 6 were talking about, are they clear, are there cases of f
7 overregulation, are there cases of underregulation. I think 8 many of us believe that's probably true, that is, there are 9 cases of overregulation and perhaps a lot of burden on the 10 industry that could be reduced without impacting in a 11 -significant way the safety elements.
12 DR. KRESS: I hate to quibble, because these are 13 good words --
14 MR. THADANI: Um-hum.
15 DR. KRESS: But if I were to meet fulAy all of 16 these with my football team, I could still lose every game 17 if I don't have a very good team or very good players.
18 There ought to be something here about achieving some level 19 of something, don't you think?
20 MR. THADANI: Yes. Yes. And in fact -- in fact 21_ that's -- you're exactly right. I'll talk a little bit 22 about goals and strategies, and I will tell you, developing 23 goals and strategies was a lot easier than the next step, 24 which is developing some metrics.
25 I'll touch on it and I will tell you then as I am
-~
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111 1 telling you now,.that is hard to do, but we're working on 13
( ,) 2 it, . and I'll tell you what schedule we have to try to get 3 that completed on.
4 Anyway, in terms of again efficiencies, the focus 5 is, are we working on the right things ourselves? Are our 6- processes reasonable? Could they be improved nr not? I can 7 go on to the next page.
8 CHAIRMAN SEALE: Well, just a minute.
9 MR. THADANI: Okay.
10 CHAIRMAN SEALE: Efficient and cost-effective 11 manner for both the government and its licensees.
12 MR. THADANI: Yes.
13 CHAIRMAN SEALE: And if I would, that's the --
14 those are the marching orders that say to me that if we have O)
\ss 15 regulation that is not performing a safety function but 16 whcse -- but for which compliance is a requirement of 17 acceptable licensee behavior, then we are not providing or 18 facilitating the opportunity for the licensees to operate in 19 a cost-effective manner. And it strikes me that that's the 20 hardest thing we -- when we ask about actually succeeding on 21 these things, it's the idcntification and successful 22 disposition of those items that -- where we really just --
23 you know, we've really been shut out on that one. We don't 24 seem to have the ability to deliver on that part of it, and 25 I think we mentioned this somewhat yesterday, perhaps in
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112 1_ discussions after you left. -
.[ 2 MR. THADANI: I wasn't here yesterday.
\_ -)
- 3 CHAIRMAN SEALE: .But this whole question of 4 regulations that don't really contribute is a real serious ,
5 concern.
6 MR. THADANI: And I quite agree with you, and that 7 issue is just going to get --
8 CHAIRMAN-SEALE: It's going to get worse.
9 MR. THADANI: -- more and more challenging with 10 time because of the things we've talked about:
11 deregulation, economic pressures. And with a fixed budget 12 which is going _down, if --
13- CHAIRMAN.SEALE: So how fixed?
14 MR. THADANI: Well, when I say it's fixed now and 15 it's going down --
16 CHAIRMAN SEALE: Yes.
17 MR. THADANI: The pot of money, so to speak, is 18 not going to go up; it's going to go down. If they have to lL9 continue to distribute that the way they have to now, then 20 the time will come when -- and that may be here; I'm not 21 ~ sure. But the time will come when less attention will be 22 paid to what's more important to safety, and that's a real 23 concern that we have, and that is one of the motivations 24 behind what we're doing.
25 We have some strategies. I think it's actually a p
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113 1- little bit more than what you said, In my opinien, I think A
() 2 3
we not only have to look at regulations, we have to see what is it that we say--in our strategic plans, what are our goals 4 and what outcomes we want that will help us get confidence 5 that we're meeting those~ goals, and then we need to ask 6 ourselves all the activities that we're involved in, how do 7 they contribute to those outcomes.
8 I can tell you, as I said to Tom, we have just 9 begun. It is going to be very difficult. One area where we 10 indicated to you -- I might as well say this at the outset.
11 I think having an excellence plan is appropriate now, but 12' after a while, we don't need an excellence plan; we just 13 need all excellent plans wherever they may be. It's got to 14 get ingrained within the organization structure. So I don't G
k_,/ 15 know how long a life this program should have. It has to 16 have a long enough life to see that, in fact, the 17 organization is continuing to move in that direction.
18 One step we have taken, it's a very significant 19 step, is -- and we mentioned this when I was here day before 20 yesterday -- was Jim Blaha's efforts on -- Jim Blaha and the 21 chief financial officer, Jesse Funchees ---to try to have 22 cur program planning, program reviews, budgeting in a cycle, 23 and that should be driven by the points that I am talking
-24 about. How do those programs satisfy those outcomes?
25 I am a member of the program review committee, and
[I
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-1 I can tell you, it's a beginning.. ItLis going to take us a l
,m j
- t while. We have been saying one or two years. I hope we can JJ
- 3. 'get there. but it will take a while.
1 4- But in any case, I think this topic is so j i
5 important that it would probably be useful to ask Jesse and
-6 Jim to meet with you, and I think you indicated you were 7' . interested in that. I think it's a very important plan.
8 VICE-CHAIRMAN POWERS: Ashok, I'm a proud member 9 of that school of engineering that believes that you should i 10 look into stealing before you start inventing. !
11 MR. THADANI: I want to thank you, because that j 12 fits in nicely with what I was going to say, l i
13 VICE-CHAIRMAN POWERS: There's been a lot of !
14 thought given on how you efficiently plan any activity, any )
)
.(_,
/^%) 15 engineering activity. It's a discipline of engineering, and 16- it has achieved a certain amount of fame lately because we 17 keep running into this phenomena of why things don't work, 18 We lay out these grand schemes, we have these huge computer 19 networks and things like that, and it doesn't translate into 20 the bottom line, and some people have spent a lot of time 21 thinking about why things don't work and why innovations 22 don't work, and a discipline has evolved out of this. It 23 goes under a variety of different names, but basically 24 systems engineering and many government agencies adopted it.
25' MR. THADANI: Yes.
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115 1 VICE-CHAIRMAN POWERS: That's not the most ringing
['v)' 2 endorsement I can think of, but many industrial concerns are 3 becoming ferocious supporters of these concepts. The 4 Boeing-777 is often touted as one of the great examples of 5 where the systems engineering concept worked. Some of the 6 large-scale integration -- integrated c1&cuits that Intel is 7 forced to use is another example of where systems 8 engineering has worked.
9 I think lots of cther people can stand here and 10 cite a litany of things where it doesn't work and there's no 11 question about it, that it's -- it has documentation 12 intensive aspects to it. But it-has been adopted. We have 13 standards available to it. There's an IEEE standard, NASA 14 has a standard, Department of Defense has a standard in this
(_f 15 area.
16 Do you have anybody looking at this to see if it's 17 template?
18 MR. THADANI: Yes. As a matter of fact, it would 19 be very useful. As part of the effort that Jesse and Jim 20 Blaha worked on, they, in fact, visited a number of 1 organizations trying to understand, and they visited both 22 some other government organizations and private 23 corporations, places where we thought we could learn from, 24 -and I think they can probably give you much more information 25 than I could.
['
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116 i
1 What I would say,jand this is really going right
-gf~)\L -
- 2) into this next page, which is on key considerations, in- ,
- Y terms?of?how do we move forward, the-NRC -- we do not 4' -produce-any materials, goods;or anything like that, so we 5 have: people -- our resource really is our staff, and we 6- really do need to nurture our' staff and do whatever we can-7 to make sure that our performance is getting-better and 8 better. To that end, as you know, we're looking at-issues
~9 of core capability, what I would call -- not I - Tom Martin
'10- wil1~ probably call to see as is, where we are, and compare fil' -it to what-is desired, where should we be, is there a delta,
- 12. We also do, I think, a pretty good job of 13 training, providing training, and it's important to work on 14 tools for our staff, not just technical tools, but other L15 tools, and you will see there is fair amount of effort going 16 in information technology, information management systems, 17 so on, 18 We need to do all of these things, We need to .
19- create what ~I would call an environment that does encourage 20 ?and support superior performance by the staff, which means 4
21 constantly looking and seeing how improvements could be made 22 :in a very supportive fashion.
23; .VICE-CHAIRMAN POWERS: Just to interject here, I
~
24 think these things are-just absolutely right on. I-think-25- -that if-you guys are guilty of anything, _it's not
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. .- . . . .. - . - . - - -_ . . - . . . . - _ - . ~ - . - . - - . . - - -
117 e 1: 'apprf.'iating how good your staf f ~ is. And when you go out O
(,j 1.1 and go;around the government, as1I get-an opportunity-to do 3 _at--times, .I think you ---it would open=your eyes to what a 4; high 1 quality staff you are,-that you really have. working for.
-5 you.
6 MR. THADANI: -Yes.
-7 VICE-CHAIRMAN POWERS: And in that regard, there 8 is, again, a lot of industrial thinking about this, and you _
9, see a lot of moves and things flattening organization, that. <
10 --
-11 MR. THADANI: Yes. ,
12 VICE-CHAIRMAN POWERS: -- great words that mean 13 nothing like empowerment, that get abused by Mr. Dilbert and
- 14. company a great deal, but within them have a germ of an 15 ' idea. You are blessed by a tremendously professional and 16- qualified staff, and some of these ideas of empowerment and 17 flattening your organizational- structures may really be
'18' applicable simply because of the level of professionalism 19 that you have to work with here.
20 MR. THADANI: And I think they are applicable.
~21 CHAIRMAN-SEALE: I would argue with one comment 22 here.
23 MR. THADANI: Pardon me?
24 ' CHAIRMAN SEALE: I would argue with one comment 25- you made, i ANN RILEY & ASSOCIATES, LTD.
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118
[1- MR. THADANIs Okay. Let me_ finish --
2_ _ CHAIRMAN SEALE: Fine.
3 MR. THADANI: --
responding-and then-we'll come
.4 back.
5 LIn fact, Dan,fthereLare.some direction-setting 6 cissues which:are focused:on those points. Tom and some
- 7. ?others have had some workshops, actually_three workshops t
8- this summer and are rying.to get-some feedback from the 9 staff at various levels, including some management 10: participated in these workshops, and those are two of the
-11 issues that you mentioned that clearly are on the mind of 12- _ people;
=13 There are others. There are others. And our 14 intention is to work on developing surveys. We can't-do too
) 15 many surveys; otherwise, they lose their value, I think, We
- 16. have to be very careful. We're talking about ma,be 17 developing some vehicles to get feedback from the staff,-to 18 =get them involved and to see if there are, in fact, areas 19 that can be dealt with in the short-term or the long-term.
-20; Some-of the ieaues:-- a flat organization, for example, is 21- one. I think we're moving in that direction. We're not --
22 I don't think we're going to be there in the near-term. But
- 23- the reality ~is we-have to get to a ratio of eight staff to a 24 manager in-about a year's time frame, and I think that's 25 pushing and forcing us to think of the issue of layers, how
,~
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119 1 can we' gof to a dif ferent structure and try and meet this 8
~
-( y;-
-- 2 ' to' 1 -- .so ca13 ed 8 to 1 ratio.
3 But I think -- I agree, those are'some of the 14 issues, organization and people issues, that we have to work 5' on. EmpowerraentL is going to have to be a part of that.
We
~6 have talked about-it. We're slowly going I would say more-7 into the concept of teams, which seems to work better, and I 8 think with some experience, if those approaches that we're 9 embarked on now work, I think they will just expand, they'll 10 just increase.
11 VICE-CHAIRMAN POWERS: Yes. A few successen --
12 MR. THADANI: Yes.
13 -VICE-CHAIRMAN POWERS: I mean, success breeds 14 success in these areas.
Aj 15 MR. THADANI: Yes.
16 VICE-CHAIRMAN POWERS: And we certainly had an 17 excellent example of -- I think you were using a team concept in developing these in DG-1061 and in all of its 19 antecedents that went in there, and I think the successes 20 and failures in that example show you the strengths and
-21 weaknesses of some of those team concepts.
22 MR. THADANI: Yes, because quite frankly, we do 23 have difficulty sometimes when issues cross line functions 24 and that's why team concepts would work better, that's why 25- plans with clear indication of responsibility, authority,
- /m l(]'
\
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120 1 Lleadership, so on,'I find they help, and so I encourage
] ) ~2 wherever we are -- and I'll tell you, it's the same approach
.3 we're using here -- whatever we're doing has to be visible, 4 clear to everybody. It also has to be clear who is 5 responsible, who is to take ownership of whatever effort it 6 is. And in fact, I think we did that -- at the end, when 7 I'll touch upon some of the goals and strategies, you will 8 see we have identified a lead organization even though 9 issues may go cross lines and so on, and I'll come back and 10 talk about it some more.
11 You had some concerns.
12 CHAIRMAN SEALE: Well, I want to make a comment on 13 what you just said and then I want to make another input.
14 But I think one of the attributes of this team as you've 15 identified it on the 1061 and related issues is the 16 extraordinary sensitivity and scceptance or sensitivity to
-17 and acceptance of input, both from the external comment 18 period and also in our interactions with that team, that 19 they have demonstrated compared to some of the other 20 approaches to trying to do things. It has been a highly 21 interactive group that has had the ability to digest new 22 ideas and turn them into something useful.
23 You made a comment, though, earlier that the 24' product that the NRC uses is the talent of its people, and I 25 wouldn't argue with that, but I think there's something else
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121 1 we have to recognize.
( ) 2 A product that the NRC uses is the technical 3 analysis and other requirementa that we put upon-licensees
-4 to support the things they asked permission to do, and 5 that's driven largely by the requirements of the NRC.
6 MR. THADANI: Yes.
7 CHAIRMAN SEALE: That is a very significant trust, 8 and we ought to be very critical of the utility of some of 9 the things that we ask people to do.
-10 MR. THADANI: I will agree with you one more time, 11 because I think -- why are we working on these two key 12 elements of excellence. One is a process type issues, 13 efficiency issues; the other one is I think what you're 14 talking about -- effectiveness.
15 CHAIRMAN SEALE: Yes.
16 MR. THADANI: And I think you're right.
17 CHAIRMAN SEALE: Well, I've jumped up and down on 18 that one enough. I'll shut up.
19 MR. THADANI: Well, I think one of the comments 20 you made, Dan, is really what's reflected in this concept 21 that says almost -- don't take on so big a job that you're 22 bound to fail almost, and so it was very, very important to 23 make sure that we build on some of the things we're doing, 24 and this is, again, consistent with what I said. We are a 25 learning organization. We went to the offices and asked
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122-I what they were doing by way of self-assessments, and
(~) . 2 depending on the results of those self-assessments, what
\
.( 7 3 . improvements would be made. You would be surprised -- ;
4 there's a lot of effort actually that's going on at sel*- 1 5 assessments and improvements. So it was very important to 6 try and build on what was being done, and equally important I 7 was to make sure that somehow we were stepping back and E
8 trying to integrate the information that would come out of 9 various initiatives that the offices have.
10 As you well know at the agency, there is an awful l 11 lot on the plates for the offices, so it was important to 12 minimize disruption and not necessarily just to tack on some 13 additional things for them to do. So it was very important 14 to take a hard look at what was going on, and I think by and k_-) 15 large, as you will see, we found that the offices had 16 identified most of the critical areas themselves. There 17 were something like 134 initiatives. We thought that about 18 13 of them were very significant and crossed functional 19 lines and -- not 13 of them, I'm sorry. Nine of them were 20 significant, crossed functional lines, and probably ought to 21 have fairly high management attention ,n them sort of at 22 periodic intervals to see how things are going.
23 We did add I believe it was four additional 24 initiatives that we thought were important, and one of them 25 has to do with'the issue that you have raised, Bob.
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'123
- 1.
LIn any case,-I. don'towant to dwell too much-except
-2 sto note that<it'wasn'tEenough;to justisay what are these 1
3: ; good l ideas that'are:-coming from officesi:we_want to make 4- ;sure that.lthere=is grassroots involvement,1that the staff
'5' -has an' input _inithis process as well as-the stakeholders,
.and when John Craig comes over here, we'll talk about some:
7 of-the; workshops that we have planned to try to get 28- stakeholder. input =to whatlwe-do.
-9 Again, I just won't dwell on any of the other
- 101 poises on this. I almost-thought about bringing all the 11- NRC's principles of good regulation, nrganizational values
- 12 and so.on, but you know them very well.
13 A key _ question that=I know, Dana, you have asked I 14 -think leads us-back to -- we have strategic plans, we have
) 15 performance plans, we have operating plans. They go down.
16 LAn_ operating plan for an office should include everything 17 they do. But it's very important that that day-to-day work 18 should be aligned in some manner with the goals, objectives 19- that we have, and the work processes that we are involved in 20 -should have-input from the stakeholders so that what we're doing is now I think better knowledge-based than it might be
- 2 2:- otherwise. These plans have to be integrated with agency's s - 23 . planning and performance assessment measures.
- 24. I won't'say anymore except I really do hope you 25 hear more about it from Jesse Funchees and Jim Blaha.
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9 124 1 The process we went through I have already touched
,a
-t ). 2 on, but starting out our initial consideration we had was we N'
s 3' have to be sensitive to the-resources issue.
4 There are a lot of good things we are not doing 5 because-we don't-have resources, so whateser we do here has 6 to really be very important. By and large, what we had were 7 self-assessment and improvement initiatives that were 8 planned or were ongoing.
9 These were discussed with the Deputy Executive 10 Director for Effectiveness but mostly with Billy Morris and ,
11 Tom Martin really pulled a lot of information together.
12- This was prenented to the Program Review 13 Committee, which consists of the Deputy Executive Directors, 14 the Chief Financial Officer, Chief Information Officer, and (s
( 15 it's a pretty good mix of people.
16 PRC was selected. The 13 initiatives are at tl.e 17 end of the material you have and we used certain factors.
18 They were all pretty much judgmental factors as to why these 19 are the ones that need Executive Colmcil attention and
20 factors were like I described.
21 This is a pretty major effort. There are various 22 organizations involved, as there is significant cost benefit 23 potentially associated with these activities.
24 Each initiative didn't necessarily satisfy the 25 factors we were looking at but by and large they satisfied
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125 1 some of the more important considerations.
/Q- 2' Now what we pulled together here are what I would 3j -
3_ _ call goals-and strategies, and the goals and strategies list 4 is given to you in this package. What we don't have is what 5 Tom-Kress asked, is what are the criteria you are going to 6 use to measure success. How do you know, or do you know you 7 are going in the right direction? Is the slope right?
8 I said we strive for excellence, which means we 9 keep working but we need some measuret to know that we are 10 actually making -- doing something that has some real value 11 added hnd so currently we are working on that.
12 We have 13 program managers for these initiatives.
13 Tom Martin is l'd say in daily contact with them just about.
14 I try and meet with them. We are trying to meet 15 every two weeks or so. The reason for meeting together with 16 them is because we want to make sure if there is a good idea 17 within one group that that good idea is shared with all 18 other program managers to see if it is applicable or not, so 19 others can take advantage of that.
20 In addition to this. we owe the Commission 21 information on milestones, resources that these initiativec 22 are.taking and will take.
23 I indicated again the concept that I have in mind 24 is really driven by what I think is.the success of the PRA 25 implementation plan. I am trying to make sure we do
()
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126 1 something very similar to what we did there, but there l( ) 2 should be one place that says all the activities within the 3 agency that are going on in:that arena and shows Lehedules, 4' responsibilities, key milestones.
5 Again, the-Deputy Executive Director provides high 6 enough management level attention that if there are problem, 7 those problems can be brought forward and dealt with.
8 What I found in the PRa implementation plan was 9 the Commission in fact asked that managers be identified who 10 will be accountable and responsible for the PRA plan, and I 11 am obviously biased, and I am responsible for the PRA 12 implementation plan, and I think it is working well. That 13 was the thinking behind my saying we ought to try and do it 14 the same kind of way.
\s ,/ 15 We have had discussions with Commissioners, one on 16 one, by and large they have been fairly supportive of that 17 approach, I would say.
18 CHAIRMAN SEALE: To the extent that the steps you 19 are taking include technical matters, one of the attributes 20 of the PRA plan I think was a heavy or an intensive cross-21 talk with the ACRS as you went along, so I guess what you 22 are saying is that you propose to put on our plate that kind 23 of effort to go along with AP-600 and a few other things 24 that we seem to have looming behind the dam, so I guess we 25 are on notice?
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n; - -
127-MR. THADANI:'
~
_1- Yes. . When. John:Craig gets here,-
- ) i:21 ;we'll' talk'about even an expansion'of what'I-am talking ~--
~e 3, well',1 it is3not-:real.ly an expansion. =It is-an integration 4 of some of the efforts which have the same ultimate goal, so i
5- -we want to make sure we do them together rather than:
l
- 6 piecemeal.
]
7' We have a commitment-in the strategic plan. There 8- are-really two-parts-to-the strategic plan.
9 One is there is a' goal on excellence'and it iston f 10 page.22 of the strategic plan. I'know you don't-have it in
'11- front of you, but in addition to that -
, under each of the-other_ goals,_as I_said.in the program planning and budgeting 13_ process and review process,lwe have very explicit questions 14 on what initiatives individual organizations have to be more
( . 15- effective and efficient, so it is sort of attacking it on 16 .two fronts, so to speak.
17 In this strategic plan, the performance goals for 18 measuring results really says two things. It says implement
- 19 the: agency's-plan for regulatory excellence. What that 20 means is a plan that we are talking about today.
21 The second thing it says is-to evaluate and (22 implement needed improvements for five major NRC processes
.23 by July 1,-1999.
2-4 We?believe that we can meet that -- what I see as 25' :-a reasonable;--LI think it_might be a slight stretch but I
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%V 'l 128 Lthink it an' achievable objective _and;these11mprovements;we_.
~
1= j
! L2 believe_we come'out;of_.the-13 major initiatives we have 3L planned:in ourLfiscallyear.1998 plan, ,
4! Some of them arefself-assessment-plans, which '.
5 .means'that'it=will scill-take some time after the i
l6; Jassessments'are completed'to see what' improvements need to )
.be--implemented,Lbut nevertheless we think we can satisfy - - )
8- meet:what we-have told-_ Congress. j
- 9. VICE CHAIRMAN POWERSi I think what you are j 110- talking.aboutLa11ot here is what in other contexts is known
-J1 11 Eas'a: cultural shift.
12 There have been a lot of organizations trying that '
13 :in the last five years and_some have been very successful 14- 'and some have been notoriously unsuccessful. It has driven 15; Laome companies.to.new highs and soma-it has just absolutely 16L decimated.
17 There is an experiential database on these.
~18 ILknow I have personal experience with one 19 ' organization that is really pretty good. It sends down a
-20 now initiative about every six weeks, which guarantees that 21 _I pay no attention to them because I know that next week all I have to do is wait six weeks and there will be another
~
22 23= one, so there is no point on acting on any-of them.
~
24- CHAIRMAN SEALE: Have you read Dilbert?
25 _( Laughter.]
(
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129 1 VICE CHAIRMAN POWERS: If you just wait, they will I) 2 go away -- because quite frankly what happens is the j V
3 management is capable of attending to only one initiative at !
4 a time, just all their subordinates are capable of dealing 5 with only one initiative at a time, so every time they 6 create a new one, the old one goes away and, gee, I don't 7 have to do anything. It's really -- it's very nice. It 8 keeps them busy. It keeps me happy and we get along fine.
9 In fact, I think this experiential base says it 10 takes about two. years to make a cultural shift of even a 31 small magnitude.
12 I guess my question is have you got people looking 13 at some of this experiential base to knowing -- he says all 14 right, I am going to make -- I have got 13 initiatives here.
) 15 I am going to do five of them in a year and a half and I'd 16 do six in another two years. In some cases these are fait 17 accompli -- I mean they are guaranteed to work.
18 You could say I improved these things since it 19 doesn't say how much cr how well or anything like that. It 20 is guaranteed -- I've got it done. It's not very meaningful 21 at times.
22 The experiential base is worth examining, I think.
23 MR. TRADANI: Yes. Yes. Yes, indeed.
24 I think the comment you make is very relevant. We 25 have been worried about how long it is going to take to make
()
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130 1 the shift and, hey, this is yet-another -- another good es
( l 2 idea, it will go away after awhile.
%J 3 But I-tell you there is-a difference now, I.think.
4 Government Performance Results Act is an act. It is here to 5- stayfI think. I-don't think that is going to go away and 6 the kind of attention that Congress is giving and the OMB is 7- giving, I think it is here to stay.
8 MR. THADANI: s had on Monday, we were -- we=all 9 went -- not all -- all Deputy Division Directors and above, 10 managers, we went away. We were in Washington at the 11 Shoreham.Omni, and we had -- the Chairman started out, and 12 then the EDO, and then some of us spoke, and I can tell you 13 we're very, very. sensitive to that point, and the only way 14 this'll work, one, it's an act I think that means the b(_s/ 15 pressure will be on us to keep going in tilis direction.
16 But the other and probably the more critical part 3 11 7 is that there has to be a buy-in on the part of the staff, 18 the management and the staff, and so it was very important
,. 19 to have this one full day of dialogue and back and forth.
20 We probably needed another day, as it turned out.
21 And I think we are just going to have to keep 22 watching that -- trying to get support as we go forward. I 23 think the number of initiatives is not really the issue, I 24 don't think. What is important is are some of the 25 initiatives we're working on reasonable initiatives, and ANN RILEY & ASSOCIATES, LTD.
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131 1 '. then once we~getcsome of the results,-are we able to-q; l2 implement some of the_-improvements =that:may be indicated.
2- 'And:that's M*tito come. We have yet to see how far are we 4- :willing to.go.
5J VICE-CHAIRMAN POWERS: LI think I agree with you,
~
-6 :the number of initiatives is not important.. It is really 7- ,the management commitment, belief, faith in the thing. -I am
-8: reminded of the incident that I got to see was the chairman 9 of American Airlines,-Crandall, got in charge of cutting
-10 costs. He's going through the cafeteria thing where they 111 make these little salads that they put on an airplane, and i 12- he says cut the olives in half,'only put half of an olive 13- on, because .t's just a decoration and nobody eats it ;
-14' anyway. I mean, there's a man'that's seriously cutting-
\s / 15- costs,-and he's down to olives on the salads.
'16 I mean, it's that kind of commitment and saying 11 7 okay,.we put this initiative out, it is more than-when your 18 appraisal review comes up we can say'gotcha on this, that 19 -we're really' committed to it, and demonstrating-your 20- -commitment. 'You've got to find your olives 4 the salad, 21 youland other managers-have got to find the olives on the 22 salad to demonstrate to everybody. we' re behind this aad we 23- believe it and we're going to follow up on it more than just '
24 at the annual-appraisal time.
- 25 CHAIRMAli SEALE: There's a deeper .]uestion, i
'\-
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k r2 ali though. Why_-buy: California; black olives when they-taste- _
I '.2. Llike cardboard in thes first place?
VICE-CHAIRMAN POWERS: Because nobody's going to
--- 3 4- ' eat:them anyway. 1 Buy'the. cheapest ones you can.
5- - [ Laughter . ] -
6I MR. THADANI: But I think the other. question that
-._7 we do have to-keep working on, and that is if we're going to 8 _ spend resources to embark on'an: initiative, what is the l9 Lyalue. We're paying a price now. What am I going to get'in E10_ return? And we've got to keep doing that. And I have to 11 1; admitfwe've just started, and it's going to be a continuous 1
H 12 ongoing challenge, but we have to get there, I think, we' 13_ -have to.
14 Okay. Going on,-the next two pages are the what's 15 in this-SECY 97-225, I believe, which we sent to the 16 Commission,'and that had three goalt and then a total of 23, 17 strategies, and what you have in front of you is a listing, 18 the goals and the strategies under_each of the goals.
19 We clearly are not going to go through any of 20? these in any detail, but I do want to highlight some in view
-21 of the questions. And there is one that I wanted to bring 22 Tip,-and then I wanted John Craig to share'with you some of 231 'his-plans. ,
- 24. The No. 3 initiative, which is enhanced safety -
25 -decision: making,:more efficient use of NRC resources, and ANN RILEY & ASSOCIATES, LTD.
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-1 : reduced burden on licensees-through use of PRA insights.
- p
- This in DSI-12.--This is the PRA implementation plan. Here
-- we have already made a-fair amount of progress. We're-
- 41 obviously-going to keep working on-it,;but we actually have 5 made a fair amount of progress, at least some of the pilots 6 we have completed, and this -- I know you had a discussion 7 'only recently in terms of some of the new policy issues, 8- potential policy issues, that were identified as a result of 9 public comment of the regulatory guides and the standard 10 review plans. And we are in fact -- as after the discussion 11 with the ACRS -- we are preparing a paper and we'll be 12 getting it to Commission in the next few days on some of 13 these major issues that have been raised through public 14 _ comment period'at the workshops and subsequently.
() 15 There's one - _No. 5 is_ closer I think at lear,t in 16 my mind when we developed this one was I think what you were
-17 talking about, Bob, that is, develop a process and identify 18 candidate issues for improving the effectiveness and 19 efficiency of rules, standards, regulatory guidance, and 20 their application.
21 Two offices play a major role, and then others 22 will play a supporting role. The AEOD and Research will 23 play a very major role-in this, and other offices such as
.24 Inspection, Enforcement, Allocation, Agency Allocation 25 Coordinator, and'some others will play a part in that we ANN RILEY & ASSOCIATES, LTD.
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134 1 want to collect, identify some triggers and collect data, rm f 2 A lot of the information that I'm talking about
)
3 would have been collected as part of our senior management 4 meeting process, but this would have the added 5 characteristic of trying to use triggers to see which rules 6 are not focused on safety, or which processes are not clear.
7 F( r example, when we're going to enforcement issues, if we 8 see more than one licensee having trouble in the same area, 9 we really should ask ourselves maybe our requirement is not 10 . clear, rather than going, continuing to march on the way we 11 are, extract that information, put it in a data base, and 12 integrally deal with an identified issues for either 13 improvements or changes, radical changes in some cases, 14 particularly if it relates to some regulations.
O
(_,/ 15 This -- we are going to try -- a trial phase of 16 this will be in fiscal year '98 and see how well it works.
17 We have some ideas on triggers, all of us have some opinions 18 on where we should go in it, and it will include a number of 19 things like some of the_information that comes out of the 20 template that you've heard about for senior management 21 meeting process. It will include information that comes out 22 of iPEs and IPEEEs in an integral fashion to see if we need 23 to make changes.
24 This was a new initiative. It was not identified 25 initially in the responses that we got from the offices. So
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i 135 1- we--sat down and_we decided we_ wanted to do something like f 2- _this.
3 The next one, if-I can ask you, John, can you just 4 come on over here so they can look-you in the eye too?
5 CHAIRMAN SEALE: While he's doing that let me ask 6 a quick question.
7 MR. THADANI:- Yes.
s 8 CHAIRMAN SEALE: I'm not going to shut up after 9 all.
10 You had earlier indicated that these issues came 11 out of the planning process and all.- In the safety and 12 compliance paper that is attached to the Chairman's talk 13 that you referred to --
14 MR. THADANI: Yes.
O Q 15 CHAIRMAN SEALE: No. 4 is another statement of 16 this same idea, namely, where requirements exist that the 17 NRC concludes hLve no safety benefit, the NRC can, and goes 18 on. That's entirely consistent --
19_ MR. THADANI: Completely consistent.
20 CHAIRMAN SEALE: Was this subsequent to your 21 planning process?
22 MR. TRADANI: No. The safety and compliance issue 23 has been with us for quite some time.
24 CHAIRMAN SEALE: I mean, this particular 25 statement.
l' )
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~
11- I MR. THADANIs Oh, I.think that-it's hard forfme1to 4
- say -- the: Chairman: has seen _ the plan.- But'.it's1hard-for me
~
~ 2; l31 to__.say -- _
{
i4 CHAIRMAN ~SEALE: Okay.:
5 'MR. THADANI:. What'came---
6 CHAIRMAN SEALE:.. Clearly.this:islthe same' issue
- _7__
identified in a different context.
'8- , MR.-THADANI: lIt's not.only that'sLthe case but
- 9. .since'I spoke a little bit after the Chairman _at the get- *
?l0- .together we-had'on Monday, and-I heard her say this, I-
' 11 -
brought.it out-again, I said.that_is exactly what it is.
12 CHAIRM*d SEALE: Okay. q 1 31- -MR. THADANI: That has clear connection to what 14 we're talking about'.
M CHAIRMAN SEALE: Okay.
V- ' 15 .-
16 - MR. THADANI: Now the -- another major initiative 17- we've had has been the request by-the Commission through an 18' SRM --' there are two SRMs actually. One-on DSI-13-deals
-19 with industry initiatives and how we can give credit for 20; : industry initiative. :And there was another SRM that asked 21 -us-to see how we can be more-performance-based and at least
-: 2 2 - less prescriptive in terms of some of the rules that may 23 - already be on'the books. It was very clear to us that we 241 1.needed.to have meetings-with stakeholders as part of the.
-- 2 5 ? process that we would.go through, y ANN RILEY.'& ASSOCIATES, LTD.
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137 1 How it's also equally important that we try to
'C\
() 2 have meetings with stakeholders not just on those two 3- initiatives but on other initiatives that are described in 4 this plan. We want to make sure we get stakeholder input.
5 We also want to find out if there may be other issues that 6 we should be looking at. And that would be input coming 7 from the stakeholders. So we had planned to conduct some 8 workshops early next year after we get our plan to the 9 Commission and we have Commission support. We were going to 10 have workshops, which would probably be early next year, and 11 I thought it might be very useful for John to give you much 12 more information than I could on DSI-13.
13 The role of industry in particular, 14 DSI-13, Direction Setting issue 13, was one of the b
\_,/ 15 major issues that was identified as part of the strategic 16 assessment and rebaselining initiative. There are a number 17 of options discussed in that and the Commission directed the 18 Staff to take a number actions with respect to the role of 19 industry.
20 It's subdivided into two parts. One has to do 21 with industry initiatives that would be substitutes for 22 regulatory action, and the other one are a number of
- 23. activities related to codes and standards.
24' We formed an inter-office task group and we are 25 going through the final phases of the concurrence process
[)
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d 138
-1 now with the SECY that responds back to the Commission, in[ 2 The proposed approach will be-to conduct 'he 3- stakeholder meetings as Ashok mentioned, and as a result of 4 that review their comments and the information we have 5 gained, then finalize some plans, processes and procedures 6 in a subsequent SECY and then'following Commission direction
? implement those, and so it will be comprised of two major 8 parts, 9 I will talk a'cout initiatives to be used in lieu 10 of regulatory action first. That is a little bit of a 11 mouthful, but the Commission directed us to defino a process 12- .that we could use that would lay out the criteria that the 13 Staff could follow to determine whether or not it should 14 review initiatives and then provide general decision
( 15 criteria to be used to evaluate a proposed initiative that 16 would be a substitute for regulatory action.
17 It raises some very interesting questions.
18 We have followed the topical report model for the 19 process that if industry has a proposed initiative they 20 would come in, identify the safety issue, identify what they 21 believe the proposed regulatory action would be that this 22 initiative would be a substitute for, identify milestones --
23 those kinds of things -- number of plants affected, et 24 cetera.
'25 The Staff will look at it and make a determination
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139 1 as to whether or not it is worthwhile to pursue reviewing
() 2 3
that initiative.
there a number of' plants affected, et cetera.
Is it going to be worth the effort? Are 4 As part of the review, questions related to safety 5 significance arise. Should we in fact give credit for a 6 voluntary action which constitutes a question of adequate 7 protection?
8 As you know, the current guidance that we have and 9 the regulatory analysis which is NUREG BR-0058, Rev. 2, that 10 I believe most of the members of the committee heard about 11 as they reviewed the proposed shutdown rule, where it says 12 that we du not give credit for voluntary actions if it is a 13 matter of adequate protection, a safety issue.
14 Well, that then leaves open, if that is a given it
() 15 leaves open questions about those requirements that pass the 16 backfit test, where they are cost beneficial, maybe an 17 improvement to safety, but they may not be matters of 18 adequate protection.
19 Should we give credit for voluntary initiatives 3
20 there and if we do, how do we do it: When does an a 21 initiative no longer become voluntary? Once a licensee has 22 made commitments on his docket to implement something, the 23 extent or degree of voluntariness associated with it tends 24 to decrease.
25 If indeed we give credit for it, should the NRC do O ANN RILEY & ASSOCIATES, LTD.
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140 ;
I 1 follow-up inspections? If so, how much? So there are a ;
() 2 3
number of questions associated with initiatives, the extent of the commitment, where it ultimately will be found with 4 respect to its current licensing basis, et cetera. l 5 As we discussed these internally, it was quite ,
6 clear to us that we would be much better off to get the 7 views of a number of stakeholders associated with these [
8 various issues. By stakeholders I mean both internal NRC 9 stakeholders and external stakeholders. There is a wide 10 variety of Staff views on this, as you have heard on various 11 _ proposed rules over time, and there's also a variety of 12 views in the industry.
13 We contacted other Federal agencies to see if we ,
14 could glean anything from their experience on relying on
() 15 industry initiatives, and to be quite blunt we didn't get 16 very much information. By and large, regulatory agencies do i 17 not give credit for voluntary initiatives.
18 What they do do is what we traditionally do, and I 19 think somebody mentioned it a few minutes ago, is the* If we 20 have an existing rule and somebody proposes an initiative to 21 meet is, we can in a Reg Guide endorse that but behind that 22 is the rule that was there that existed to begin with, and 23 so you hc.ve an enforcement hook.
24 There's a clear need to comply, et cetera, so 25 while-a specific action may be voluntary, the need to comply ANN RILEY & ASSOCIATES, LTD.
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I 141 1 is not, and so it is then just a matter of choosing a !
() 2 3
method, but if there is not a rule that is existing, then there are other questions that arise, so we thought we would 4 meet with stakeholders, discuss a number of those questions, ;
5 and then go back to the Commission with the process, the j t
G general decision criteria for those initiatives. ;
7 The other aspect of the 3RM on DSI-13 relates to 8 codes and standards. We have taken the view that those are j l
9 consensus codes and standards. If it were for example an 10 EPRI document that was subniitted f or Staf f review, that ;
11 would fall under the initiative aspects. That la the 12 initial view on it now.
13 But in the context of consensus codes and 14 stsndards, there is a recent public law, 104-113, and OMB
() 15 Circular A-119, and we are required to do_a number of 16 things.
17 The Commission directed us to focus, increase our 18 focus and emphasis on codes and standards and utilizing 19 codes and standat-do, and as part of implementing or meeting 20 implementing procedures to comply with the public law and 21 meet the guidance in the OMB Circular one of the things says 22 that before you issue a new rule, a new Reg Guide, or-indeed f 23 an internal standard, you should determine if there is an ,
24 existing consensus standard that is out there that you-could 25 use instead.
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142 1 Well, one of the things that would be quite simple
() 2 3
to do would be to change the Federal Register notice that would accompany a proposed Reg Guide and/or insert language i 4 in the statements of consideration for a proposed rule that 5 ask that question to commenters: "Do you know or can you 6 identify a consensus standard that could be used in lieu of ,
7 or with some minor modification used, relied upon as an 8 alternative to the proposed rule or the proposed Reg.
9 Guide?"
.10 That would indeed allow us to focus our emphasis 11 on the consensus standards in the future.
12 One of the things we are required to do is to 13 review our agency rules and standards to determine whether 14 or not we can substitute a consensus standard.
() 15 The idea is that you go through all your ,
16 regulations and see if there is a standard that you could 17 use instead.
18 Now the origin of this was to open up procurement 19 fer selling things to the Government and meeting a standard 20 rather than a specific mill spec, et cetera, but it is 21 extended into and it is made applicable to all regulatory 22 agencies.
23 ~ As you know from the Standard Review Plan 24 discussions, there are thousands of references in our ,
25 Standard Review Plan to consensus codes and standards, so
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5 143 j 1 our agency has been at the forefront for years. j
() 2' 3
We were lucky the technology was evolving and the consensus standards filled in the technical detail that we !
4 could rely on. f:
5- Some of the other things that we are doing is to l t
6 define a process by which the Staff could identify where [
i 7 t'. tere is a need for a 1.ew standard and the Commission ;
8 specifically identified pro ~Tbilistic risk assessment :
9 standards,-and we had focused-on developing an internal 10 process that we would follow before we approached a :
t 11 standards development organization, and indeed in L 12 discussions with ASME and IEEE and others we have alerted '
13 .them to the upcoming stakeholder meeting so we can talk .
14 about just this process, as there is some confusion. k
() 15 There is some concern between the SDOs that they j 16 want to make sure that their interests are protected and the 17 Circular is not limited to domestic codes and standards. It 18 is international, and so for example I am a member of the 19 ASME Main Committee in QA. There is a fair amount of e 20- concern that the NRC would endorse an ISO standard on QA and .
21 the question then is, well, where does that leave the ASME 22 process -- so there are a number of quest. ions and concerns and interests in which standards organization we would 2 4 -- _ approach to develop a new or revise am existing standard and 25 some concern on the part of domestic standards development ANN RILEY & ASSOCIATES, LTD.
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144 -
1 organizations as to what the international scene would need.
() 2 3
MR. CRAIG: There is an interesting provision that requires that the head of every Federal agency report to OMB 4 every time they endorse an industry or a nonconsencus .
5 standard so every time we endorse an NEI document or an EPRI 6 document it requires us to report to OMB that indeed we 7 endorsed this nonconsensus standard because there wasn't a '
8 consensus standard that was appropriate. But it further 9 emphasizes our focus and interaction with the consensus 10 bodies.
'11 CHAIRMAN SEALE: But such standards do have status 12 then.
13 MR. CRAIG: Yes.
14 CHAIRMAN SEALE: Once you've made that report.
() 15 MR. CRAIG: Absolutely, yes.
16 But it shows the level of interest on the part of 17 OMB and Congress in the use of consensus standards in the 18 Federal Government. There's a group of regulatory agencies 19 that meet to talk about this, and it's caused as you would 20 suspect a lot of interesting concerns and issues, 21 particularly for the agencies that are used to writing their 22 own standards and imposing them on the regulated industry.
23 The other aspect of codes and standards is one 24 that's been particularly painful as we've tried to get out 25 of revision to-10 CFR 50.55(a), which endorses, as you know, ANN RILEY & ASSOCIATES, LTD.
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145 1 some ASME and an IEEE standard. And the Commission directed 2 us to try and expedite, simplify and expedite the process to i
[V'T 3 review, to endorce codes and standards in the regulations. ,
4 That's a significant challenge given the requirements of the l l
5 Administrative Procedures Act that we have to meet to 6 undergo rulemaking.
- 7. Nevertheless, we've identified a couple of 8 potential ways-to shorten the endorsement process, but it i 9 comes at a time when the SDos are implementing processes to 10 speed up the development of standards so it makes it much 11 harder to know what the current draft is of any given 12 standard. There are some challenges to us and some !
l 13 challenges to them, j i
14 One of the things the.t we identified in the i O( ,, 15 last -- we discussed a great deal, I think it's been 16 identified for years -- that we discussed in the last 17 revision of 50.55(a) was the number of changes that are made 18 to the various codes and standards which don't have a real 19 safety significance, they're administrative in nature. And 20 one of the things that we want to talk with the SDos about 21 is a process whereby they could identify administrative 22 changes as opposed to technical changes. And if we can get 23 the standards development organizations to put that focus on 24
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i 146 1 their revision process or the generation of a new standard 2 process.
3 So there are it number of questions and aspects of 4 both initiatives and codes and standards that we would want 5 to meet with the stakeholders, talk about, so we could 6 define a process that we would use, and hopefully create a 7 better forum and interaction with the key stakeholders so 8 that their questions about our processes or their processes 9 they feel free to contact us and interact with us. .
10 The initial discussions as I said that I've had 11 with ASME have been very positive, also with IEEE, and they 12 think it's a good idea, and I'm hopeful that it will result 13 in a periodic meeting of representatives from a number of 14 standards development organizations. There are about five
() 15 that the NRC utilizes and it's endorsed in its regulations 16 and reg guides. Periodic meetings between the staff and the 17 SDOs to talk about process issues and those kind of things 18 as we see a number of revisions focused largely on cost-19 cutting, reducing costs, but at the same time it improves 20 operations in a number of areas. So a number of the changes 21 have the potential to increase safety at the same time 22 they're cutting costs.
23 That sort of gives you a snapshot of where we are 24 in DSI-13.
25 MR. THADANI: Thank you, John.
[
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147 1 I asked John to come and talk about it because it
() 2 was an icoue that came up the other day when I was here, and )
3 I-thought might be of.some interest'to you to hear from him, l
4 I want to again note that two of the most 5 important people in addition to a number of other people 6- working on these initiatives really are here, Billy Morris-7 and Tom Martin. They're the key, I think, to this. They've i 8 devoted a great deal of time end effort. So let me ask them 9 if they-want to make any comments, Billy or Tom, on this i
10 program as you see? ;
11 MR. MORRIS:. One aspect -- this is Bill Morris, ;
12 Office of Research -- one aspect that is rather a low-key 13 and not a prominent element of tha paper that we developed 14 was that it's increasingly important among the Government 15 agnncies that we take a hard look at whether the outputs of 16 the Agency are producing the desired outcomes, and we are 17 trying to look into whether we can get -- gain more insights 18 into how that relationship may exist for various NRC 19 outputs, and if you look at the kinds of outcomes that are 20 indicated in the strategic plan, and the goals that are 21 stated there, and if you think about the kind of outcomes 22 that are inherent with a regulatory agency, where what we're 23 trying to do is achieve a low occurrence of undesirable 24 events, so low-in fact that you would never experience one 25' of these events,.then the question comes whether the things 1
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i 148 l 1 that the Agency is doing, the rules, the inspection !
() 2 programs, enforcement program, are indeed as effective as we would like with regard to achieving those outcones.
3' {
4 So far that has been a matter of judgment for the ,
{
5 most port. There is an intuitive judgment, an ir.tuitive 6 relationship that one will make between the things ws do in 7 achieving low probabilities of these undesirable events.
8 And so we're going to take a look at whether we can get a 9 better handle on that so we'll have a better basis for maybe i
10 making budget decisions or maybe even toning down some of 11 the things we do or enhancing some of the things we do. !
12 As we go forward with this, if we find that there 13 is any let's say viability to trying to get a handle on this 14 and articulating that connection between outputs and
() 15 outcomes in a more transparent way, we would probably like 16 to come and explain what we're doing to the Committee and 17 see what your thoughts are on that. And so it's, as I say, 18 it's not prominent in the program, but you vill see it in 19 the paper in one spot, and so we're planting a seed to do 20 that kind of thing, and we'll look forward to talking to you 21 about it if we are making any progress.
22 DR. FONTANA: There was one thing that wac ,
23 concerning me all along here is, you know, you judge a tree 24 by the apples that fall off it, and if you're producing 25 things, you can just measure them and weight them and that 4
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1 sort of thing,'but-in this-case you're producing a negative. f
() 2-3 I mean, you don't want things to happen, and like you're talking'about here. So that gives you a very difficult f
4- quantitative measure.
l.
5 Now what you-can do, of course, is back off and 6 identify those things that are productive in nature that -
7 lead to things not happening, like research programs. coming 8 out with useful information, that sort of thing. But the -- i
-9
~
and one thing that comes to mind, since you can't -- since f
10- you can't really allow the thing to happen, you have to --
11 you have to do it in a surrogate kind of way. ,
12 Now, the question is, does'PRA become useful here? [
13 Is there a way of predicting -- is there a way of 14 identifying like a leading indicator or accessing a ,
() 15 precursor and this sort'of thing, and do a lo. of drills and 16, identify people who have gotten into close calls arJ that 17 sort of thing, you know. Now that could be a measure. Can .
- 18 I do some of that. ,
19 MR. THADANI. In fact, in my view at least, right :
20 on the mark. When we started out and we had this -- with 21 this high-level goal of I think zero, deaths'from a severe 22 accident, so as I said the other day, I think -- I would 23 .like to think that's fairly easy to meet, and year by year 24- by year we canssay -- so really,that was -- that's critical, 25 but not-helpful in terms of day-to-day activities of the i
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l 150 1 agencies. So we said we need what we called an
() 2 3
intermediate-level goal before that high-level goal.
And the intermediate-level goal we said has to be 4 a precursor, an early warning of something that may not be 5 going well. And the intermediate goal we had was we should 6 not have more than one precursor event whose conditional 7 core damage probability is 10 to the minus 3 or so. We look 8 back at the data history to see, and it should be, as I 9 said, should be stretched, but not so stretched that we're 10 guaranteed to fail.
11 And in order to -- and it has to be measurable, it 12 has to be something, we have to have data, we have to have 13 methods, and it's the accident sequence precursor program, 14 for example, and it is tied clearly into making sure we have
() 15 understanding of risk assessments, we have the right 16 techniques that can be used to see how we measure up to 17 those goals.
18 But I'll be honest with you. I think when I go 19 through these PRC -- Program Review Committee -- meetings, 20 the linkages are sometimes extremely weak. We do 1,200 21 licensing actions, I said the other day. Well, how does 22 that relate to the goals that we have. We do so many 23 ,
inspections, so many inspection hours. Well, that's good, 24 but what's the measure? How does that really lead you to 25 achieve the goal you want?
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1 That's why whatever we do and in fact it would not
() 2 3
surprice me if the Office of Research would have to add some other strategies to show how the output from that office 4 plays into meeting these goals, and those strategies, some 5 of them, are I think in here, ber. I think there probably is 6 a need for others. But we're going through that learning 7 process now, and I think it's going to take a year or two ,
8 years.
9 CHAIRMAN SEALE: One of the concerns we always 10 have, of course, when you decide you're going to have a 11 hunting license on ruir, and regulations, is how do you 12 protect the ones that really do work, and I was wondering, 13 have you asked the people in AEOD, when they go through and 14 look at events, to identify the rules and regulations that
() 15 were significant in providing either intervention or 16 mitigation in the sequence that kept you from getting into 17 severe trouble?
18 MR. THADANI: I think that's a good question. We 19 haven't explicitly acked that, but we will.
20 CHAIRMAN SEALE: That may be a fruitful thing to 21 do.
22 MR. THADANI: Yes, it is. Thank you.
23 Well, my time is up, and unless you have 24 questions, I will head back and do some other things.
25 VICE CHAIRMAN POWERS: We're not doing anything -
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l 152 1 - we've been educated, and that's the end of our 7-( 2 responsibilities.
3 MR. THADANI The only thing is, I think we will.-
4 - once we get the plan put together, we get the Commission, 5 we want to come back and meet with you and go through some 6 of the details.
7 Maybe we can't go through each one, but I think l 8 some of the major ones, we'd like to make sure that, if 9 there are some things we could do better or change 10 direction, that we have the benefit of your thinking. ;
11 VICE CHAIRMAN POWERSs It might be well to pick 12 one and go through it in a substantial amount of detail, 13 because they all fall kind of in a consistent thrust. That ,
t 14 would be probably worthwhile.
15 CHAIRMAN SEALE: Something that would also tell us 16 the size of this elephant that we're going-to try to draw a 17 picture of.
18 MR. THADAMI: We owe the Commission information on 19 resources on each one of these also, and when someone gave 20 me an initial cut on resources on DSI-12, I sent them back, 21 I said, you know, this is a heck of lot more than 7 thought, 22 and so, we need to take a hard look, how much are we really 23 spending, and I think you will be surprised. We are 24 spending a lot of resources.
25 VICE CHAIRMAN POWERS: Part of this goes into the.
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153 1 regulatory policies and practices? l 2 CHAIRMAN SEALE: Uh-huh.
3 Well, I want to thank you for coming to see us on :
4 this particular issue. We would invite you to come and see 5 us en other issues when you feel that there is something 6 that we need to share with you. I want to thank your 7 colleagues for their help.
8 Thank you very much for the discussion on the 9 codes-and standards. I think it clarified some questions we 10 had that came out of our discussions earlier.
11 Do any of the other members have any comments or 12 further suggestions?
A3 VICE CHAIRMAN POWERS: I'd just comment that I 14 particularly appreciate the conversational style, the free, 15 frank discussion of where you stand and whatnot, rather than 16 waiting till you have a completely formal presentation, come 17 talk about how you're thinking and what you're thinking and 18- where you're going, even though it's not completely 19 solidified, I think, is very helpful to us, rather than 20 waiting till a)1 the view-graphs are in multi-color and 21 everything like that. That may be too late.
22 CHAIRMAN SEALE: I think, in fact, that style was 23 a part of the success of the PRA program. It's fostered 24 open and free discussion.
25 MR, THADANI: I think these are ideas and concepts (Oj . ANN RILEY &' ASSOCIATES, LTD.
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1 and there's no single ownership. Collectively, we can make l 2 'it:better, and=that's the thinking.
3- CHAIRMAN SEALE: Yes. Okay. (
4 Well, if there are no further comments, at this i 5 time I'm going to declare a recess until 2:50. ;
6 [Whereupon, at-2:33 p.m., the public-meeting was .
7 recessed, to reconvene at 8:30 a.m.,- Friday, November 7, 8 1997.] .
9 20
-- 11 12 13 14 15 16 3 17 18 19 20 21 22 23 .
24-25-
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REPORTER'S CERTIFICATE
() This is to certify that the attached proceedings before the United States Nuclear Regulatory _ Commission in the matter of:
NAME OF PROCEEDING: 446TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
DOCKET NUMBER:
PLACE OF PROCEEDING: ROCKVILLE, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to O- typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings, fl M ICVrr
-I Jon Hundley
~
3s Official Reporter Ann Riley & Associates, Ltd.
v 4 ___
J u 4r '
A f Q O
o is s:
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% % e/
l ACRS BRIEFING NOVEMBER 6,1997 lO REGULATORY EXCELLENCE i
ASHOK C. THADANI i
- 1 1 1 O '
1
i 0' '
i t
. Principles of Excellence ;
b i
- Regulatory Excellence (from DSI-23) ;
i
. is a dedication to safety, n commitment to the principles of good regulation, and the pursuit of superior staff performance i
- Regulatory EfTectiveness (from DSI-23) -
O
- denotes a regulatory framework for ensuring public health and safety that is clear, coherent, logical, consistent, reliable, and technically sound
. Regulatory Efriciency (from DSI-23) e directed at ensuring that NRC implements programs in an efficient and cost effective manner for both the government and its licensees 3
l O
9 l
-j
p LJ Key Considerations Guiding Formulation of Approach 1
. NRC management should nurture a commitment to excellence for all employees
. Initial efforts of program to enhance efTectiveness and efficiency will build on and integrate with existing initiatives O
. Focus on grass roots and stakeholder involvement
. Recognize existing NRC standards of excellence
. Principles of good regulation
. Principles of good financial management
. NRC organizational values
. Focus on meeting Government Performance and Results Act I
/
N
'k
O Start-up Phase in FY98 - BUILDING ON L
EXISTING INITIATIVES
- Self assessments and improvement initiatives planned, already underway, or contemplated were compiled and presented to the PRC The PRC selected from those presented, added others and with EC approval these goals and strategies were included in the FY 98 Excellence Plan
. The Excellence Plan will receive PRC/EC oversight O
- Detailed plans containing milestones and clear criteria for measuring success will be provided to the Commission in December
. The responsibility for the conduct of the assessments and improvements as part of this plan will be with the NRC office associated with the work
- Completion of the Excellence Plan activities will contribute to meeting the strategic excellence goal of five improvements by July 1,1999 Additional assessment and improvement initiatives outside the scope of the Excellence Plan will be conducted by the offices and be incorporated in office operating plans O
I
Ux EXCELLENCE PLAN GOALS AND STRATEGIES FOR FY 1998 Goal: Improve a manageable but broad range of NRC regulatory
' programs, rules, standards, and regulatory guidance.
Strategies:
- 1. Evaluate the reactor inspection program to determine ifit achieves its intended goals in an efficient and effective manner and make recommendations for improvement. Phase 1 ongoing in FY98, Phase 2 to begin in FY99. Lead NRit
- 2. Evaluate the licensing support and regulatory oversight of the operating
(]
reactors program to determine ifit achieves its intended goals in an efficient and effective manner and make recommendations for improvement. Lend NRR
- 3. Enhance safety decision making, make more efficient use of NRC resources and reduce burden on licensees through use of PRA insights.
- 4. Improve the medical regulatory program by modifying 10 CFR Part 35 to be more risk-informed and performance based. Lead NMSS
- 5. Develop a process and identify candidate issues for improving the effectiveness and efficiency of rules, standards, regulatory guidance and their application. Lead AEOD
- 6. Increase effectiveness and efficiency of the regulatory process by expediting evaluation ofindustry initiatives and promoting more rapid O
v adoption of consensus standards. Lead RES
t Goal: Improve the NRC's processes and management and support bc functions so as to enhance the efficiency and performance of the !
NRC staff.
Strategies:
- 7. Assess core capability needs by comparing requirements to current availability. Improve core competencies through recruitment, training, and development of staff and/or identification and acquisition of comractor services. Lead HR
- 8. Evaluate headquarters and regional support to determine ifit achieves its intended goals in an efficient and effective manner and make recommendations for improvement. Lead - Steering Committee (CFO/DEDM)
- 9. Assess the effectiveness, including integration and data sharing, of information systems supporting NRC.'s major business areas. Lead Os CIO
- 10. Improve information systems supporting resource management ,
- 12. Improve information systems supporting the reactor inspection and licensing programs (Reactor Program System - RPS). Lead NRR Goal: Create an environment that will promote enhanced effectiveness an'd efficiency ofNRC activities in an open manner with the support and input of our internal and external stakeholders.
Strategy:
l'~)
V 13. Assess the NRC organizational culture and make recommendations for improvement. Lead IIR
-- . . - . .