461st Meeting - April 8, 1999

UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
***
461ST ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
(ACRS)
***
USNRC
11545 Rockville Pike, Room T-2B3
Rockville, Maryland
Thursday, April 8, 1999
The subcommittee met pursuant to notice, at 8:30 a.m.
MEMBERS PRESENT:
DANA POWERS, Chairman, ACRS
GEORGE APOSTOLAKIS, Member, ACRS
JOHN BARTON, Member, ACRS
MARIO FONTANA, Member, ACRS
THOMAS KRESS, Member, ACRS
DON MILLER, Member, ACRS
ROBERT SEALE, Member, ACRS
WILLIAM SHACK, Member, ACRS
GRAHAM WALLIS, Member, ACRS
MARIO V. BONACA, Member, ACRS
ROBERT E. UHRIG, Member, ACRS. P R O C E E D I N G S
[8:30 a.m.]
DR. POWERS: The meeting will now come to order. This is
the second day of the 461st meeting of the Advisory Committee on Reactor
Safeguards. During today's meeting the Committee will consider the
following: the insights gained from the risk-informed pilot
applications, proposed final revision to 10 CFR 50.65, paragraph (a) of
the maintenance rule and the associated draft Regulatory Guide, proposed
approach for revising the Commission's Safety Goal Policy Statement,
proposed ACRS reports.
The meeting is being conducted in accordance with the
provisions of the Federal Advisory Committee Act. Dr. Richard P. Savio
is the designated federal official for the initial portion of the
meeting.
We have received no written statements or requests for time
to make oral statements from members of the public regarding today's
session.
A transcript of portions of the meeting is being kept, and
it is requested that speakers use one of the microphones, identify
themselves and speak with sufficient clarity and volume so they can be
readily heard.
Now, the members are reminded that today during the lunch
hour, we will get a briefing on the ethics that govern our actions as
special government employees, and the procedure you should follow is to
grab some lunch and come back to this meeting room. Again, I encourage
you to think about your personal situation and any questions that you
might have to pose to the speaker. I do believe he has some prepared
remarks, but I think he would be most happy to address particular
situations in an extemporaneous fashion.
We are going to begin today's meeting with a much
anticipated presentation on the insights gained from risk-informed pilot
applications. Dr. Shack, I believe that you are acting as the Cognizant
Member on this extensive program?
DR. SHACK: Yes, I am. We are going to hear today, I guess,
from Rich Barrett on lessons learned from the risk-informed pilots. We
got about a two inch stack of SERs on pilots covering a wide range of
activities, and I thought they were rather interesting reading myself.
It was an attempt to see just how 1.174 would work in practice. Got to
look at how people handled the incompleteness in PRAs and the fact that
the PRAs frequently didn't cover all the components of interest, and I
found it interesting to see how those problems were addressed. I guess
Rich is going to start this off.
Was that correct yesterday, you have now moved to the PSA
Branch?
MR. BARRETT: Well, it has always been the PSA Branch, it is
the Probabilistic Safety Assessment Branch, although we sometimes call
it the Risk Branch or the PRA Branch. We have a little bit of an
identity crisis in that respect, but it is all the same thing.
DR. POWERS: I guess one of the things that always interests
me about pilot applications is they are essentially experiments. And
when I think about experiments, I think about experimental error.
Looking at a particular plant in a particular period of time, and I am
wondering how you translate the data you gather from these experiments
and extrapolate them forward in time, recognizing that there can be
experimental error. So to the extent you can touch upon those ideas, I
would appreciate knowing.
MR. BARRETT: Yeah, I think we will touch upon those ideas,
because part of the effort, as Mark will point out, is to try to
understand how you go about making the transition from a pilot or
topical/pilot to the copycat type of applications that you would get
from other licensees.
If I could just take a few moments here, we requested this
briefing some months ago because -- I guess for a couple of reasons.
One is that we know that we have come before you on a number of
occasions to give you individual briefings on a wide range of issues.
You know, you have seen individual slices of the salami, we thought it
would be useful for you to see the big picture and get an idea of how it
all kind of hangs together, and where our successes have been, where our
-- I won't say failures, but where we think we still need -- have to
work to do and we have not yet achieved success. So that is really the
one reason.
The other reason is that I think we have stood or sat before
you on a number of occasions and talked about some of these issues in a
very abstract and conceptual way, and it is difficult sometimes to
understand, when you are just sitting, talking about abstractions and
words that end with a-t-i-o-n, how it really will be implemented in the
real world. And so today Mark Rubin, who is one of the two Section
Chiefs in the SPSB Branch, and has been very heavily involved in it, in
the lead for much of the work that we have done in terms of bringing
this, a lot of these concepts into reality, is going to give you an
overview of what we think we have accomplished and what we think we have
learned. Mark.
MR. RUBIN: Good morning. As Rich said, I am Mark Rubin,
one of the Section Chiefs in -- is it the PRA or PSA Branch?
MR. BARRETT: Oh, come on Mark. PSA.
MR. RUBIN: PSA, okay. We also have a number of the
technical reviewers who are involved in the individual pilot risk-
informed review, so if there are any questions directed specifically at
some of the technical evaluations, we have a number of the people here
who might be available to provide more information.
As Rich said, we are here to talk about lessons learned a
little bit, where we have come and where we are going, some of our
successes, some of the challenges that are still remaining and things
that are still going to need some additional attention and refinement.
But we want to leave the clear message that we think we have
successfully completed the first phase of risk-informed regulation, and
that was a phase after all the methodology development that went on for
the last 20 years, but this is the phase, the beginning of the
implementation, significant implementation of risk-informed regulation.
We think we have completed the first phase, is the end of the beginning
-- hopefully, not the beginning of the end -- and we are ready to move
on to a lot of additional applications and areas for risk-informed
techniques for licensing safety evaluation reviews and licensee actions.
The first phase that is essentially complete is that the
staff -- as shown up on the viewgraph that I will put up right now -- is
that we have completed the evaluation of the first industry proposals,
which really evolved into the pilots. A number of the areas that we
jumped into, in fact, the majority of them, at the beginning, were
originally industry proposals, industry suggestions, GQA, ISI, IST and
they evolved into the pilot activities and the staff evaluation process.
The guidance documents, Reg. Guides, SRPs that ACRS was
heavily involved in the development of have been complete, finalized,
except for ISI, which is issued as a draft for trial use to get us a
little more experience, since we hadn't finished the industry topical,
the EPRI or WOG reviews at that time. But it is out for use and any
tweaks that we need to do to it as we finalize the industry topicals
will be incorporated in a final final to be issued in the future.
And, of course, an area of great interest to the industry,
as well as to us, is that we completed the body of first pilot
applications in a number of areas, and we think we completed them
successfully, though with some challenges and a few issues still
remaining that we will get into.
Well, since we finished the first phase, what is the second
phase? Where are we going now? We are really going into, in a sense, a
production mode. More and more risk-informed applications are coming
in. This is not to say that every licensee request is risk-informed or
relies on risk in either a significant or even a tertiary manner, but we
are seeing an ever-increasing number in a wider variety of areas, and we
are completing reviews in a number of areas.
We also -- and ACRS again was significantly involved in the
development of the risk-informed Part 50 revision options paper that
went up to the Commission at the very end of last year and the staff is
currently awaiting Commission guidance through an SRM on which
combination of the options to go forward on.
And there also is a much more broadly based risk-informed
standard tech spec program that is currently being embarked on which
would look at a much wider variety of tech spec AOTs and look a more
risk-informed basis for more extensive changes, rather than just the
piecemeal treatment that was given in the original tech spec pilots, SIT
tanks, LPCI, things of that nature.
Well, where do we review the successes? There was a lot of
startup cost to get the guidance documents out, and there was some
concern from industry that it took too long, cost too much, delayed the
pilots. There was a benefit for getting the guidance documents out and
I think we have reached the point where we are really getting the
payback now from the documents. The pilots that we did, I think have
validated the approaches used in the Reg. Guides, SRPs. The follow-on
reviews that risk-informed are following the Reg. Guides and SRPs.
A key issue is the guidance and the process for blending
probabilistic with deterministic methods in doing staff safety
evaluations. Early on, as you are well aware, there was some concern
that this was going to be a risk-based approach, that we were going to
look at bottom line risk numbers. It was going to be above or below,
yes or no, go or no-go.
Clearly, the staff identified in the guidance documents that
that was not the approach being used, that it was going to be an
integrated approach and that was delineated in the guidance documents
and, in fact, reading the Safety Evaluation Reports, looking at the way
the staff has done the reviews, the RAIs that go out, the interactions
with the licensees, clearly, this is not a risk-based approach, it is an
integrated approach. It includes a lot of engineering, deterministic
considerations as part of the safety determination. The qualitative
risk insights is part of the determination, as well, of course,
quantitative findings is part of the decision process.
We think it has been successful, and I think it has proven
that it is possible and very feasible to have an integrated,
deterministic PRA engineering approach to decision making.
One of the key focuses of the risk-informed approach,
specifically in the guidance documents, is the use of risk
categorization. It was called originally risk ranking, but as Dr.
Scheron indicated, on a briefing a year-and-a-half or two years ago,
small differences in ranking aren't meaningful. Categorization, broad
robust categories is the guidance that is useful in making decisions on
the areas that are more fruitful, more robust for risk-informed changes,
relaxations and some requirements that may impose unnecessary burden,
GQA heavily used, risk categorization process, it was also used in IST.
It is useful even in areas where you can quantify to some degree the
impact of the proposed change, such as IST, looking at increased
surveillance intervals, as well as areas such as GQA where we really
don't have models for the impact of a QA program on equipment
reliability.
So the categorization process and the experiences with it, I
think has proven to be a success. It was an early focus of the staff
and it was an area that industry also focused on early, and I think it
has been quite successful.
The end result of our activities is that unnecessary burden
is being reduced in a number of areas. It is varying, depending on the
application. There are some difficulties with -- difficulties may not
be the correct word, but some residual issues that reduce the amount of
burden reduction to somewhat less than the licensees had originally
desired in some areas. We are working on some of those issues and I
will be getting to them in just a few viewgraphs further down the road.
Clearly burden reduction can be very significant on the
current risk-informed processes in areas such as ISI. GQA offers some
potential with some difficulties I will get into in a moment. IST is
allowing changes to surveillance intervals, as the committee is well
aware of. There are issues on how much follow-up and feedback and root
cause analysis that should be performed on low, very low importance
equipment -- that is something the Staff is still considering and I'll
also get into that briefly a little later too.
A further area of success, at least in our view, is improved
efficiency and effectiveness of our safety review process. The guidance
documents for all the time and the money it took to develop them now
provide the foundation for us to go forward in a structured way -- Staff
guidance, industry guidance. It makes all future applications, now that
we have paid the start-up cost, much more efficient, much more focused.
DR. POWERS: What are the measures that you used for
efficiency and effectiveness, especially effectiveness?
MR. RUBIN: I'll have to admit to a qualitative assessment
at this point.
DR. POWERS: Okay. How do you do a qualitative assessment?
MR. RUBIN: The measures --
DR. POWERS: You look around and say what you are doing is
good? The guys that did it the old way said that they were doing is
good.
MR. RUBIN: Well, compared to the efforts that went into the
pilot reviews and the effort that are going into follow-on reviews, much
less Staff resources, more focused reviews, more complete submittals,
less need for follow-up RAIs, less need for interactions, redirection,
corrections in the technical approach taken by licensees.
The ISI reviews through the pilot program were very lengthy.
There was a effort at the completion of it to develop a standardized
format to attempt to negate the need for a lot of additional requests
for information back and forth between the licensee and the Staff. That
has been worked on with EPRI. I believe it is almost finalized and the
new follow-on ISI submittals are going to be using it.
The difference is a few months of review versus what was a
year, a year and a half review, as we were feeling our way through the
first-of-a-kind technical review.
Providing the technical guidance on what should be the key
elements of a submittal. Hopefully we'll broaden out into other areas
and we will get much more focused submittals that will require much less
back and forth between us and the licensees.
MR. BARRETT: Mark, if I could add a word.
MR. RUBIN: Sure.
MR. BARRETT: I think a lot of what Mark said relates to the
efficiency of our reviews and I would add to that that we actually have
been gathering some statistics on how our reviews relate to the reviews
that are being done in purely deterministic ways and they are becoming
much more -- more and more comparable in that respect.
The question of effectiveness may be a different question,
and that is how good of a safety result are you getting, how good of a
result are you getting when you compare it to the criteria that we have
been using in NRR to evaluate everything we do, maintaining safety,
reducing regulatory burden, public confidence.
I think that the biggest issue there is that when you do a
risk-based review you have a quantitative or at least semi-quantitative
way of evaluating where you were and where you got to, and that to me
the biggest effectiveness gain from all of this work.
DR. APOSTOLAKIS: Could the same decisions that you reached
using risk information have been reached using traditional methods?
MR. RUBIN: Could they have been reached? Possible. Would
they have been reached I think is another question --
DR. APOSTOLAKIS: Well --
MR. RUBIN: -- but -- excuse me --
DR. APOSTOLAKIS: Go ahead, go ahead.
MR. RUBIN: The traditional methods had a lot of tradition
behind them, a lot of history, regulatory feeling of confidence. The
risk perspective folded into the process allowed an alternate way of
providing confidence in areas that were nontraditional approaches or
stretching out beyond, as Gary Holahan used to say, we are now looking a
little out of the box, going beyond the areas where we traditionally
have accepted proposed changes.
A good example would be the hydrogen instrumentation
monitoring time. That was one of the phase zero NEI pilots that had
been in maybe three times previously and rejected three times. Would it
have been allowed by traditional methods? Maybe. But it wasn't -- and
when we folded it into the risk-informed arena, the sort of
comprehensive look that was taken in the environment of trying to probe
the severe accident strengths and weaknesses part of the decision
process was enough to sway the decision and reversed it.
DR. APOSTOLAKIS: For example, what would be the equivalent
in the deterministic framework? What would be the equivalent of ranking
SSCs using importance measures? Would it be based on judgment or the
issue would not come up at all -- we'd just go with declared safety-
related categories and nonsafety related and then take it from there.
MR. RUBIN: Certainly the first approach would be just what
you said. It's safety-related or it's not. But clearly over the years
it's been looked at more finely than that and it is judgment. The
safety importance of equipment of course has been judged. System
engineering assessment would let you decide if a component, certain
component, was actually in a success path required for system functional
performance to meet the goals. Small bypass pathways, drain valves,
mini-flow loops that if they fail to open didn't defeat the required
flows -- clearly you can make deterministic judgments in cases like that
and perhaps provide longer AOTs or some enforcement discretion, but the
structure is missing to some degree that the risk perspective provides,
but clearly some of that has been done in the past but I think we are
able to do it better now.
One of the early concerns was, oh, risk-informed regulation
we are going to give away the store. Risk is going to go way up.
Safety is going to go way down. Well, that hasn't happened, to the best
of our knowledge. Most of the applications have been either risk-
neutral, risk-beneficial to the best of our ability to assess with
perhaps some very small increases in some cases.
DR. APOSTOLAKIS: But again are these increases in the
quantitative part of the risk? I mean were there any unquantified
benefits?
MR. RUBIN: Oh, yes.
DR. APOSTOLAKIS: Okay, so I think you should be a little
careful when you say that, to make sure that you include those. Maybe
the overall change in risk was not a positive one.
MR. RUBIN: You mean the overall changes in risk --
DR. APOSTOLAKIS: You calculate risk, okay, and maybe you
have a delta CDF, a delta LERF or one or the other --
MR. RUBIN: Yes.
DR. APOSTOLAKIS: -- which is positive, small. You say
okay, in this case we accepted an insignificant increase in plant risk
but does that include perhaps the benefits that have not been quantified
yet?
DR. SHACK: In the Texas Utilities case, they actually
computed increases in risk and then made the argument that because of
the unquantified benefits --
MR. RUBIN: Yes.
DR. APOSTOLAKIS: And that is part of the Regulatory Guide
as I remember, 1.174. We said there that we have to include the
unquantified benefits as well.
MR. RUBIN: Right. You will see that in the Staff safety
evaluations. When I said that we had a risk-neutral risk benefit
application with possibly some increase, some of the individual
applications showed both potentials -- a very small worst case upside
but a likely expectation of risk neutral or risk benefit, and so your
statement is very true.
There may be other applications. Power uprate for example,
the only change is higher power, even though they weren't submitted as
risk-informed, Reg Guide 1.174 submittals, a very limited perspective,
risk perspective, was taken and in fact you have higher inventory, less
operator response time. Those were looked at. They were very small
impacts but it would be slightly up because there's no compensating
elements --
DR. APOSTOLAKIS: I understand that.
DR. FONTANA: In the baseline value, do you compare the
effect of the action against -- is that the plant like it was or the
plant like it would have been had you used deterministic methods or
implementing a certain change?
MR. RUBIN: It's the plant like it was before the requested
change.
DR. FONTANA: Okay.
MR. RUBIN: As built, as operated when the papers supposedly
came in the door requesting the license amendment.
DR. FONTANA: Okay.
DR. SHACK: One of the things I did note was that in many
ways this seems to increase Staff discretion in making these judgments.
If you have a deterministic rule you either make it or you don't. Here
none of these PRAs are in a sense ipso facto adequate to compute the
risk that you are interested in typically, and the Staff is making lots
of judgments that they can, you know, accept the fact that the baseline
PRA is incomplete, there is no low power shutdown analysis but you argue
the ORAM -- a number of things, so, you know, is this becoming much more
an eye of the beholder kind of evaluation?
MR. RUBIN: Well, I wouldn't say that all the deterministic
evaluations are without the application of judgment over the last 30, 35
years. Is more judgment being used now? I don't know if more judgment
is being used -- perhaps different judgmental tools that are both
quantitative and qualitative are being applied and I don't mean to give
a gobbledegook type of answer.
It's not you can get any answer you want. I mean I firmly
believe that. People have argued that. Critics have argued that and I
don't believe that is the case at all.
You're able to analyze impacts for some of the applications
quantitatively. In some cases not able to model the potential benefits
that Dr. Apostolakis mentioned, such as IST improved testing methods
that would increase the probability of detection of a fault that might
not have been captured by an earlier testing method. So it can't
quantify that, but you're able to look at in some cases the upside risk
given some -- I don't want to say, conservative, but given some bounding
or some, you know, a little bit pessimistically derived assumptions and
see how bad could it be at worst with reasonable, you know, reasonable
pessimism, but not totally ridiculous approaches. And then look at
areas of uncertainty, the things you're not modeling, be it shutdown, be
it improved methods in some cases, and then attempt to decide if the
decision is a robust decision. That's what we have to determine.
We don't have to determine a quantitative result with any
exact certitude, but is the decision a prudent one given what we know.
Yes, judgment is going into that, but that's judgment based on a lot of
quantitative, qualitative risk-assessment information and a lot of
quantitative and qualitative engineering deterministic assessment folded
together.
So I don't view it as that different from what has been done
the last 35 years. It's just that there are some new tools coming into
play aiding the judgmental process. And judgment is just part of it, a
small part of it. There is a lot of analytical basis behind the
decisions.
One of the key benefits that we've seen, you know,
maintenance of plant safety, improved safety, low risk, is that we're
seeing industry much more focused to a large degree on severe-accident
issues. There's increased risk-awareness. The maintenance rule
certainly was a driving force on that. But we're seeing more and more
consideration of risk in proposals from the licensees, support for
responses to potential violations, enforcement actions.
So clearly industry is also becoming much more applications
oriented, also moving out of their first phase, which I would call
probably the IPEs, into real decision-making, operational safety
management of their plants.
DR. POWERS: You mentioned operational safety, which is a
bit different than severe accidents, high-risk endeavors. It really
speaks to a variety of regulations that exist that probably govern or
worker dose than anything else, at least as an immediate consequence.
And we have at our plants residents who are geared much to this
operational safety, conduct of ops we would call it in another context.
Do they have a similar feeling of increased focus by the licensees on
safety?
MR. RUBIN: I probably shouldn't speak for the residents.
You know that they are being trained in the techniques. They are
getting additional guidance in the current inspection manual on applying
risk-informed techniques, and there's of course a much more focused new
assessment inspection process that will be much more finely honed
towards risk. As far as what they believe, I can't speak for.
DR. POWERS: You try to collect that data? I mean, does
anybody ask them?
MR. RUBIN: I honestly don't know, but we have -- our points
of contact are the SRAs, and I don't see an SRA here today. In fact
ours we had to loan out to Region IV. We could certainly inquire. I
don't know what form there might be, but we do have interface meetings,
and there's a lot of interaction.
DR. POWERS: I mean, isn't that an important data point to
derive from these experiments?
MR. RUBIN: If they believe the plants are more --
DR. POWERS: What their overall experience with the process
is.
MR. RUBIN: Well, I think that's being incorporated in the
assessment and inspection process. They're key players in the task
force.
Briefly to identify a few other what we construe as success
elements of the process. Clearly from the licensee's standpoint these
techniques are providing improved operational flexibility, more online
maintenance --
DR. APOSTOLAKIS: Has anybody used 1.174 to argue that they
should be allowed to do online maintenance? Has anybody done these risk
assessments?
MR. RUBIN: Well, online -- they don't need to use 1.174 to
do online maintenance unless they have a tech-spec prohibition, which
some plants may have in a few cases, perhaps diesels. If they meet the
AOTs that they do the maintenance rule, A3, assessment of configuration
risks, soon to be the A4 if the Commission accepts the proposed rule
change, they can go forward and make those -- do that online
maintenance. It doesn't require --
DR. APOSTOLAKIS: So why do you say then there is increased
ability to do it? Why is that relevant to our discussion? I don't
understand. You just said that there is no reason to use 1.174 to be
allowed to go to online maintenance, so where did the conclusions that
there is increased ability to do it come from? I mean, have you seen
any studies, even though they didn't have to use 1.174, has anybody done
a risk assessment with and without online maintenance so we can compare?
MR. RUBIN: The ability to do online maintenance doesn't
require permission in most cases. What online maintenance you do and
the ability to fit it into the allowable AOT in a number of cases did
require 1.174 applications. For example, the diesel teardowns. They
couldn't be done in the original AOT intervals. The ISI inspections are
being done -- normally you wouldn't do those on line, so that's probably
not a good example. But mostly it's an issue of extending intervals
beyond the current allowed specification, such as IST going from
quarterly or 30 days to 18 months, perhaps six years in the case of some
check valves.
You're stretching out maintenance requirements. It can be
done on line because of the maintenance rule flexibility if the A3
assessment is done, so the tech spec changes enable the increased online
maintenance to be done. In a sense it is a bit of a side issue, but
there is a lot of commonality.
DR. BONACA: So the bullet refers only to the cases where
you supported changes in tech specs to allow longer times?
MR. RUBIN: Well, those are the cases where they can do
things that they couldn't do before, but I'm not -- I guess I meant --
MR. BARTON: They weren't submitted through 1.174, they were
submitted in a deterministic approach and they got a bunch of RAIs that
were risk-informed RAIs, and then they made utilities put in a
configuration management risk program to be able to do that. But they
didn't submit license amendments in accordance with 1.174. That's the
way the staff has been handling these increased outage times.
MR. RUBIN: We meant this statement more broadly than just
1.174. It's meant in the context of the increasing risk-informed
approaches. And the maintenance rule certainly is a key part of that.
Without the maintenance rule type of assessment, online maintenance
could very well be imprudent, and even if it perhaps was allowed, it
really wasn't implemented by many licensees, and the increasing use of
it is what really has required the maintenance rule, A3, soon to be A4
determinations. So sort of the totality of the maintenance rule
activities plus the risk-informed approaches in pilots I think is what
gives you this ability for increased online maintenance, not just 1.174.
MR. BARRETT: Mark, if I could just say a word. I want to
make sure we don't leave the wrong impression. There are a number of
plant-specific submittals that have been brought in under 1.174 that
have requested these allowed outage increases. Specifically to make
online maintenance possible there have been a number of owners' group-
sponsored topical reports for a variety of systems from a number of the
owners groups that basically are trying to do the same things. And
referencing 1.174 is the basis.
The other point I'd like to make is that our experience is
that even though we might give an allowed outage time of 14 days to make
sure that there's enough time to do a diesel online maintenance, the
licensees are not taking the entire 14 days. There's a lot of
experience that they're actually completing these things in a much more
expedited fashion.
MR. RUBIN: Well, having the extended AOTs will prevent
unnecessary plant shutdowns in some cases. It's directly tied to the
issue that you've just mentioned, increased flexibility in performing
tests on pumps and valves. I also mentioned that previously. IST
program, extending the intervals. ISI changes. Certainly from an
operational safety standpoint directing to the issue that Dr. Powers
raised on plant worker exposure a big reduction in worker exposure, cost
of doing the inspections, and better inspections because they're focused
on more safety-risk-important locations.
And also the ability to modify QA controls commensurate with
safety, which the rule allows, but there hadn't been really guidance on
how to do it and what it meant to do it. So overall, a lot more
flexibility. Some limitations.
That we still have to work on, especially in the GQA area.
Also, an issue that is of great interest to the industry is
the potential reduction for the need for submittals to the NRC for prior
review and approval in all cases. Both the IST, GQA programs reviewed
risk-informed processes for changing program elements, not an absolutely
final list of equipment that was treated according to various
requirements within the program. Therefore, once the process has been
appropriately reviewed, approved, appropriate feedback mechanisms are in
place through the licensee, the need for Staff approval in some cases
will be negated.
Also, the proposed change to 50.59 will make it possible --
the minimal change -- and future changes to make the entire 50.59
process more risk-informed concerning severe accident issues -- if that
is one of the areas endorsed by the Commission SRM -- would also allow
more licensee flexibility, ability to go forward without Staff review
and approval in areas where there is no safety risk significant impact
from them doing so.
DR. APOSTOLAKIS: I must say I don't understand very well
the first statement there. I thought the Staff approval, the need for
Staff approval was a different regulation -- 50.59. How can this
approach reduce the need for that? Isn't that what happened in South
Texas, that you approved the GQA program they had but then when they
implemented it and they wanted to remove some components from the high
risk category then they hit on 50.59, which did not allow them to do
that without approval from the Staff.
MR. RUBIN: Not from high risk category. From the other --
EQ -- code requirements --
MR. BARTON: I think it was the code requirements.
MR. RUBIN: Yes. Your statement is very true. Those
limitations are impacting the ability of South Texas to make the
changes. If we can overcome that, and there are some processes in place
to do that, making changes to the specific elements in the QA program
would be within the purview of the licensees if they met the basic
process.
DR. APOSTOLAKIS: But right now this is not true, is it?
MR. RUBIN: It is true as long as they don't run up against
other regulatory limitations.
DR. APOSTOLAKIS: Ah.
MR. RUBIN: And they won't in some cases.
DR. MILLER: But they did in South Texas?
MR. RUBIN: For a number of components.
DR. APOSTOLAKIS: Can you give me an example, Mark? I want
to understand this better. Does an example come easily to mind?
MR. RUBIN: You mean what they can change?
DR. APOSTOLAKIS: Yes, without staff approval.
MR. RUBIN: They can change ISI locations. Steve, correct
me if I am wrong, they -- Mr. Dinsmore?
DR. APOSTOLAKIS: I see.
MS. DINSMORE: This is Steve Dinsmore from the Staff.
What this means is again if they go through and they do the
process and they select the welds to inspect, later on if they have new
information they can change the welds to adjust for the new information
that they have without coming in beforehand and saying we would like to
do this, can you re-review our process and reapprove?
With the QA stuff, if they move stuff from high to low, they
can adjust the QA controls depending on where it is and again they don't
have to come in and say we have moved this thing from high to low, can
you tell us that's okay?
DR. APOSTOLAKIS: But they were not allowed to change the
welds before? What is the --
MS. DINSMORE: We had a list of welds.
DR. APOSTOLAKIS: Oh, you had a list.
MS. DINSMORE: And the QA stuff they couldn't change at all.
DR. APOSTOLAKIS: So now South Texas is allowed or
whoever -- I'm using that because I know they have to approve their
program -- they can move a component from the risk-significant category
to the, say, targeted QA category without prior approval?
MS. DINSMORE: That's right. Then they adjust the controls
which they are using.
MR. RUBIN: But the process to do that is very well defined,
plus the feedback loop, so if there is degradation they didn't expect,
they can reassess the importance of the equipment.
DR. APOSTOLAKIS: So what was the problem then, John? Some
codes?
MR. BARTON: I guess they got hung up in -- they had
commitments to the IST program -- Section 11 --
MR. BARRETT: This question is still in play and we haven't
gotten to the bottom of this yet, but basically we gave them approval to
take a graded approach to quality assurance, which can be a big
operational impact from their perspective, but what they found was that
when they went to implement it, say in procuring something, they still
had, even though something was found to be in a low risk significance
category -- perhaps it was a drain valve on an important system or some
local indicator on an important system, something that would not really
be important to the functioning of that system -- but it was still
labelled as a safety-related component, and as such it was still subject
to a lot of qualification requirements, so even though it had a low QA,
it could be graded down in QA, it still had to be procured in a way that
would not really result in any particular savings in money and in cost.
So the question is is there a mechanism for taking something
like that, a very low significance component in an important system, and
reclassifying it from safety-related to nonsafety-related, and that is
where the question, the 50.59 question came up. Would they have to
submit 23,000 license amendments to have these things changed? -- and I
can tell you that question is still in play. It may very well be that
they do not have to do that, that we can find an efficient process --
and there should be an efficient process for reclassifying equipment
that was probably overly conservatively classified in the first place,
but the jury is still out on that.
MR. BARTON: Then by enabling them to do that, they would be
able to get out of some of the other code requirements like the ASME
IST.
DR. APOSTOLAKIS: The categorization of components as risk-
significant and the middle category and significant does not affect
their classification as safety-related or nonsafety-related, is that the
message?
MR. BARRETT: Not necessarily, no. That is one of the
issues to be addressed in the Part 50 rulemaking.
DR. APOSTOLAKIS: But you say when they want to buy
something that has been declared safety-related even though it may
belong to the targeted QA category, it still is safety-related right
now?
MR. BARRETT: That's right, so it still has to meet
environmental qualifications. It still has to be seismically
qualified -- not seismically capable. You certainly want it to be
seismically capable but it has to be seismically qualified. It has to
be environmentally qualified. It has to have all of those pedigrees on
it even though we found that it is not risk significant. That is an
issue to be resolved and we are making progress on it.
DR. MILLER: Can you describe in more detail about the
progress you are making? I don't understand. It seems like a fairly
straightforward thing.
MR. BARRETT: Let's see. I guess this is a long story. We
have requested that, as Mark will tell you, we have requested that the
Commission give us authorization to go forward and change Part 50 as it
relates to these questions.
We have requested the Commission authorize us to give wide-
ranging exemptions to a few plants so we can get some experience on how
this might work, and one of those plants that has come in quite early is
South Texas.
In discussing their proposals for exemptions to things like
the IST and ISI requirements and other requirements, we have begun to
examine whether these exemptions are really required in order to do what
they want to do, and we are now examining the possibility that South
Texas could request a regulatory finding from us that there is another
approach that can be made. That finding, of course, is going to require
NRR, the General Counsel and others to bring the best information we
have to bear, but there may in fact be a more efficient way of meeting
the regulations and allowing them to do what they want to do -- that
would for instance allow them to make some of these changes without
specifically requesting a license amendment for hundreds or thousands of
pieces of equipment that have no risk significance at all.
MR. RUBIN: The licensee, South Texas, has suggested that
they can recategorize a number of safety-related components still
meeting the regulatory requirements, the definitions that they have to
meet, the tests that they have to meet for it not to be safety-related,
but they are proposing that an additional test would be a risk-
importance test before they declassify.
There are some early discussions that have taken place and
we are talking to them some more. We will also be talking to our Office
of General Counsel on what flexibility there is to do that, but
declassification has occurred in the past if it is not necessary that
they retain the safety classification.
As you just discussed, there was more impact in South Texas
on GQA implication than people had expected. The ultimate solution,
hopefully, is to revise the regulatory requirements so they can
accommodate regulatory treatment based on appropriate elements of risk
and safety importance. But, hopefully, in advance of that, we can go
forward with exemptions or this reclassification process, and we are
working now with South Texas to achieve that.
DR. MILLER: You said that it was not expected. I thought
when we looked at the GQA, there was discussion about if you had a
safety-related component and it were indeed non-safety significant, that
that would require some reclassification. I think that was discussed a
year-and-a-half ago.
MR. RUBIN: What I recall from a year-and-a-half or two
years ago --
DR. MILLER: Or to the GQA Reg. Guide.
MR. RUBIN: Yeah. There clearly was a recognition on the
part of the industry and the utility that there would be limitations
that they bumped up against under the regulatory requirements. I think
what happened is they under-estimated the extent of the bumps, so they
expected to be limited to some degree. It turned out they were limited
significantly from what they wanted to change the QA requirements on.
But I don't believe they were originally planning reclassification.
That might have been held out as something to consider in the future.
If they had folded that into the original submittal, it
could have been considered, but it was not part of it.
DR. MILLER: Isn't that going to be a generic problem with
the GQA --
MR. RUBIN: Definitely, yes.
DR. MILLER: This is not a once in a lifetime issue.
MR. RUBIN: No, and that is why we are trying to deal with
it not only on a one-to-one case in South Texas, but that it be an
important focus of the Part 50 change process, to accommodate these
types of issues.
DR. FONTANA: Would you backup a viewgraph, please?
MR. RUBIN: If I can find it, I can do it. Let's see.
DR. FONTANA: Well, anyway, the one that says NOED.
MR. RUBIN: Two.
DR. FONTANA: Well, I just want to know what NOED is.
MR. RUBIN: Notice of Enforcement Discretion.
DR. FONTANA: Thank you.
MR. RUBIN: Sure. Stepping back one or two meters, where
are we? What have we learned, what have we accomplished? We have
improved the staff review processes. Through this risk-informed
activity with the Reg. Guides, SRPs and the experience we gained in the
pilots, we have developed a process to expedite review of risk-informed
submittals, each one is not one of a kind, with more application of the
judgmental issues that were questioned earlier, but more formalized,
guided sentence criteria, both for the submittal process for the
licensees and the staff review. The issue of scope and depth of review
has been dealt with at the office level, with office letter 830, to
provide guidance to the staff that the scope of the review should be
commensurate with the potential safety significance of the issue. RAIs
should be focused on the technical issues that are related to safety.
The potential impact of the request should guide how much safety review
is conducted.
The interactions with industry on PRA quality are a key one.
Certainly, PRA quality has been an important concept, an important issue
hanging over this entire process. Resolution, of course, is needed.
Industry took a leadership position early on with the BWR PRA
certification process. The staff was also involved through the Office
of Research with the national consensus standard process. Those two
processes are going on somewhat in parallel right now, and there is an
effort to attempt to draw them together and help identify what role each
will play in use and staff assessment and review of PRAs in our safety
review process.
DR. APOSTOLAKIS: Was the issue of quality important enough
in some cases to become an issue, so you had to go back and forth, you
know, arguing about certain assumptions perhaps, or calculations, or was
it minor?
MR. RUBIN: For the most part, it was minor, but the depth
of the quality review varied considerably, from sending a team of five
or six experts down to a site for a week, which was done on Comanche
Peak, to reviewing a national lab performed review of one of the PRAs
and then following up issues or weaknesses that were identified there,
to very focused reviews on such things as EDG AOT requests where the SBO
modeling was looked at in some detail, but the whole content of the PRA
didn't need to be looked at because it wasn't as pervasive through the
plant as something like GQA would have been. So there was a large
variety. But we generally did not get into arguments on small quality
issues because, from the applications that were underway, those
questions, or those answers didn't become key to making the decision.
DR. APOSTOLAKIS: Well, perhaps, also, the submittals you
received were a little biased towards better quality, because, you know,
they are first of a kind, so the licensees made sure that their PRAs
were very good.
MR. RUBIN: Yes, it is self-selection to some degree since
the stronger PRA licensees were the ones who were involved in the pilot
activities.
DR. APOSTOLAKIS: Exactly.
MR. RUBIN: And that is something we are very aware of and
want to make sure that sufficient quality continues as there is much
wider applications. A very good point.
DR. BONACA: Although, I mean in some of these SERs, there
was significant criticism that your staff made regarding the limitations
of the PRA and yet a lot of arguments were made to explain why those
shortcomings would not affect the conclusions of the SER. You know,
that surprised me, too, that somebody would go in with certain
applications and then you would have to do that kind of -- a lot of
jumping around to justify why you could still support the application,
although, you know, there were shortcomings in the methodology. Isn't
that true?
MR. RUBIN: Well, there are a couple of issues here. First
of all, these were our first of a kind reviews, too. Just as the
licensees put a lot of effort in ensuring the quality, we put a lot of
effort into reviewing quality issues to gain knowledge in the process
and experience, and to ensure that these pilots were fully completed
adequately. But looking at weaknesses in a PRA, I think is an important
part of the review process in a number of cases because there is not
necessarily a requirement that the perfect PRA is the minimum
requirement for a risk-informed decision. They will be of varying
qualities and varying completnesses in scope.
Does that mean a moderately complete PRA? Perhaps it is a
Level I study, perhaps it doesn't have shutdown treatment in it, as most
don't at this point. Does that mean we can't use it to make some
decisions? Well, no, we don't believe so, but you still have to probe
what the obvious weaknesses are to test the robustness of your decision
process. And I think that concept is described fairly completely in
Reg. Guide 1.174.
DR. MILLER: So, Mark, even though we would expect these to
be the higher quality PRAs, we did still see a substantial variation in
the quality of the ones in the pilots?
MR. RUBIN: Certainly, we saw a variation. I think all of
them were pretty good. I think it would be more scope issues at this
stage. But there are clearly OPRAs out there that the quality issue has
become much more relevant.
DR. MILLER: So when we get farther in, we get this more on
a routine basis. There is going to be PRAs out there whose quality are
not nearly as good as the ones we have seen here in the pilots.
MR. RUBIN: I would certainly expect that, but I think that
is the reason for the industry certification process and our activities
in the standards process. Hopefully, these will drive --
DR. MILLER: That is going to take a while to catch up to
quality. I mean if the standard -- let's say the standard is issued
another year, how long is it going to take for the industry to catch up
on quality on their PRAs?
MR. RUBIN: That's a very valid point vis-a-vis the
standard. For industry certification, though, most, if not all, of the
BWRs have been done, and the other vendor groups are jumping on board.
Now, the industry certification and the standard are not one and the
same right now, but a strong peer review is certainly an important
element to help achieve quality and will be a good focal point for the
staff's evaluation. In the case --
DR. MILLER: Isn't the certification process partly focused
on just the limited scope of the PRAs?
MR. RUBIN: I think it is pretty broad. I think they look
at quite a bit. They rate the various elements for --
DR. MILLER: It seemed like there was different gradations
in that certification process.
MR. RUBIN: Yeah, sure.
DR. APOSTOLAKIS: Now, you have reviewed many so-called
deterministic requests over the years, right?
MR. RUBIN: The staff or me personally?
DR. APOSTOLAKIS: Well, --
MR. RUBIN: Yeah, sure, of course.
DR. APOSTOLAKIS: Did the quality vary there?
MR. RUBIN: Yeah, absolutely.
DR. APOSTOLAKIS: All right.
DR. POWERS: But we hold PRA to a much higher standard,
George.
DR. APOSTOLAKIS: I noticed that.
DR. MILLER: Mark, I had a question. Earlier, you made a
comment on the graded depth of, I guess, reviews.
MR. RUBIN: Yes.
DR. MILLER: Historically, that has always been done. Do
you think this is providing a lot more guidance in those, is that what
you are saying there?
MR. RUBIN: I think, historically, it is a good concept, but
perhaps, historically, it has not always been achieved. And now the
guidance at the office level is clear, that resources should be focused
commensurate on the safety importance. And an insignificant impact
request should certainly receive less resources than a request that
potentially has significant.
I mean it is obvious, but in the past there have been, you
know, review activities that perhaps have been excessive, and we are
trying to make sure that they are properly focused on safety and the
guidances come from Mr. Collins, the Office Director, through an office
letter to ensure that that is the way business is carried out. That
RAIs that are issued are appropriate and necessary. You know what you
are going to do with the answer because you send them. You don't need
the answer, why are you asking the question?
DR. UHRIG: One quick question. The RILP abbreviation, what
is that?
MR. RUBIN: Risk Informed Licensing Panel. Did I skip that?
My apologies.
DR. UHRIG: Okay.
MR. RUBIN: Part of the process to improve the Staff
effectiveness is to have an early, fairly senior management level body
to bring issue to for resolution, for guidance, and a number of Division
Directors are on this panel and issues such as South Texas, issues such
as configuration risk management, how that should be treated in the tech
specs or an administrative procedure, issues that are raised by industry
get early senior management attention to help keep the Staff focused on
the success path.
Where are we going now? The future is here, so to speak.
We are working to process risk-informed licensing actions. We have a
number of them in-house in a number of areas. The new IST proposals
came in, some new ISI proposals are coming in-house. We are continuing
to work with industry groups on topical reports such as the EPRI ISI
report still under review and a number of code cases, at least three
related to ISI. I am sure there are others -- an IST code case under
Staff involvement.
We are continuing to incorporate the insights from lessons
learned into the guidance documents, though we have not yet had an
update cycle. I think the first one towards the end of this year we'll
be considering comments from industry as we get more experience
conducting the individual reviews.
There have been some suggestions perhaps in the IST area
that the requirements for monitoring and feedback of low important
equipment is somewhat excessive, and the Staff is considering that, and
that may be reflected in the future change to review guidance.
We are standing by on our marching orders on Part 50, risk-
informed process, and we expect to be receiving SRM very shortly, and we
are working rather intensely with South Texas to try to get some sort of
interim relief or resolution to the impediments on the GQA process.
There is also the significant interaction with the risk-
informed tech spec activity that I mentioned at the very beginning of my
briefing. The Owners Group tech spec committees are working with the
Staff to flesh out a much more broadly based program. We expect a lot
of stakeholder interactions in many areas -- the SECY 98-300
specifically mentions that we plan to proceed with pretty extensive
interactions, meetings in that area but they are ongoing in numerous
areas with frequent meetings with Owners Groups, with NEI, to keep
pushing these issues.
When problems are fleshed up, then both the RILP, the
licensing panel, and the PRA steering committee, which is chaired by Mr.
Thadani and crewed by the office directors, is also certainly in the
loop, very much so, in providing policy guidance on how to proceed, so
there is involvement at the very highest levels of agency management, a
lot of interaction with the public, and quick routes to mid to senior
level office management to provide guidance in resolution of problems.
DR. UHRIG: Has this gotten rid of the backlog of tech specs
that keep accumulating?
MR. RUBIN: I should probably ask our risk-informed
licensing manager, who I don't think is here today. I think the backlog
is decreasing but I am sure it is not zero.
MR. BARRETT: I think there are two answers to that
question.
The overall backlog of licensing actions, I don't think that
the risk-informed program is central to reducing that backlog. There is
a major effort in place to try to reduce that backlog and to reduce the
Staff's performance, the overall Staff performance, on timeliness of
review. I think we are having a lot of success as an office in doing
that, but I would not attribute very much of that to this particular
program.
Now the subset of tasks, of licensing actions, that fall
into this category, which are of the order of 10 to 15 percent
perhaps -- I don't have good statistics -- but it is of that order, we
have very good performance on turning these around. Once we get them,
we turn them around. We took some statistics for one quarter, for the
first quarter of this fiscal year, and I think the average time,
residence time, was eight months, between from when it arrived to when
we completed the review and the average Staff effort for routine
licensing actions was about 30 hours of review, so these are good
statistics for this particular subset of actions.
MR. RUBIN: In conclusion, I would just like to repeat,
reiterate that we have stepped out beyond the start of this process. We
have the guidance in place. It's being used successfully by the Staff
and by industry with some areas of difficulty that we are giving a fair
amount of attention and industry is giving attention to, and I think we
see some success potential there.
We are seeing an increasing stream of risk-informed
licensing actions, but that is not 100 percent. Everything in it isn't
risk-informed, just a small percentage, but it is definitely increasing
in risk awareness of the industry in dealing with regulatory safety
issues, very obviously increasing, and clearly we want to send the
message that we are receptive and flexible in expanding the use of risk-
informed techniques to a wider variety of our safety decision-making
processes.
We have certainly seen that in the assessment inspection
process, changes to the enforcement process, and we welcome new
initiatives by industry in other areas that are amenable to these
techniques, making better decisions.
That concludes my remarks.
DR. APOSTOLAKIS: One of the areas that caused some
apprehension when the Guide was published was the detailed discussion on
uncertainties and model uncertainty and completeness uncertainty and all
that.
Did you have any issues related to these in the actual
submittals you reviewed or it was more or less routine, because people
read these things and say, my god, you know, what they want.
MR. RUBIN: I don't think it has in an operational sense
turned out to be a problem. I could in the future, depending on a
particular application that would be more sensitive -- the decision
would be more sensitive to the fundamental uncertainty issues.
Here the areas of uncertainty don't seem to be driving the
decisions. The programs include so much in addition to the risk
elements into the integrated process that we haven't been constrained by
those issues.
DR. FONTANA: Do you see any potential revisions to Reg
Guide 1.174 as a consequence of the experience that you have had here?
MR. RUBIN: We have a cycle due and our colleagues in the
Office of Research are the leaders in that revision cycle, even though
certainly NRR is heavily involved.
I think we have a cycle towards the end of the summer. I am
seeing a nod from the back -- no, not the end of the summer. I am off
on my date.
Right now we haven't identified specific changes to it. We
are considering potentially some in the IST area but we think it is too
early, but for 174 I am not aware of anything that we feel needs to be
changed at this time.
Mark Cunningham from Research.
MR. CUNNINGHAM: Yes. The cycle now is about the end of the
calendar year basically.
DR. APOSTOLAKIS: And there were no problems related to
maintaining the philosophy of defense-in-depth and safety margins?
MR. RUBIN: I think that has been one of the big successes
of the process. No, no problems. I think it's been achieved. It was
certainly in the top of everyone's thoughts as the reviews were going
forward.
DR. APOSTOLAKIS: Was defense-in-depth affected by any of
these actions?
MR. RUBIN: I don't believe so.
DR. APOSTOLAKIS: So maybe that is why there was no problem.
MR. RUBIN: Good point.
DR. SEALE: Mark, you have undoubtedly learned a lot of
specifics to replace some of the unease that may have existed going in
as to what constituted an adequate PRA treatment of the kind of detailed
issues that were involved in this kind of risk assessment.
We talked earlier about what constituted an adequate PRA and
all. I think we all recognized that none of these submittals were done
doing a bare bones IPE submittal. Rather, there was a lot of addition
and so on.
You have now gone through and done a combing of those
efforts and you had an opportunity to make a value judgment on how
successful these modifications have been in addressing the issues
germane to this kind of treatment. What kind of feedback mechanism do
you have to let future applicants know what turns you on and what turns
you off when you get a PRA submittal in support of one of these things?
MR. RUBIN: Well, there is the traditional approach where
the next submitter reads the RAIs and the staff safety evaluation.
Nothing new there. It's always been done. If we put out --
DR. SEALE: You can see when you smile and when you frown.
MR. RUBIN: Yes. You can tell that. But there are some
other things going on. This standardized format process is sending a
clear message, this is what we want to see when a submittal comes in,
and we expect it to be very successful in ISI and hopefully in other
areas. The interactions with industry that we plan to continue,
everywhere from maintenance rule to the meetings on the ISI submittal
guidance approach that I just mentioned.
There's a lot of talking going on, but between the standard
format and seeing what the staff findings are in the SE, I think we do a
fairly good job of it, but, you know, we're always available to talk and
give thoughts.
One of the key elements is out of the new staff review
process 803 it encourages early interaction back and forth verbally,
face-to-face meetings, don't just send in a submittal and expect to get
RAIs in 14 months. If there are issues that pop up from a quick staff
look, the guidance from the Office of Management is quick feedback to
the licensee in the areas that don't look too good, and perhaps it's our
misunderstanding of the issue, perhaps there's an incompleteness on the
submittal. So we're going to try to do a lot more face to face and
provide much earlier feedback than in the past to help it along.
DR. SHACK: We're running a little bit behind schedule, so
unless there's another burning question, I'd like to give Mr. Biff
Bradley from NEI a chance to give his perspective on pilots.
MR. RUBIN: Thank you.
DR. SEALE: Thank you, Mark.
MR. BRADLEY: Good morning. I'm Biff Bradley of NEI. I
appreciate the opportunity to discuss some of the lessons learned from
the risk-informed pilot applications, and I have a few slides on some of
the specifics from the industry perspective.
But before I do that, I wanted to say that I think the
biggest lesson we've learned is that change is possible. Last year was
a real banner year for actually achieving change, and I have to say
prior to last year I think there was a lot of skepticism in the industry
that we'd ever reach fruition with a lot of these approaches and
actually achieve real change in the field. And we have seen that
happen.
There is -- I can tell you from working at NEI -- there's a
considerable amount of momentum and much more interest at the executive
level and at all levels in the industry in proceeding with risk-informed
applications and regulatory improvements. We have formed a new
executive working group to oversee and provide strategy direction in
this area, and we had to turn away applicants. We had so many
interested utilities that in order to limit it to a workable-size group,
and we still have about 22 or 23 people on there. So that's a positive
indication that there's real interest out there.
I wanted to give you a little bit of information about some
specifics -- get my maintenance-rule slides out of the way here.
MR. BARTON: And maybe we can resolve your concerns on those
while you're at it.
[Laughter.]
MR. BRADLEY: That would be nice.
MR. BARTON: It would shorten the staff briefing.
MR. BRADLEY: I wanted to talk about some of the areas we
perceive as most successful, and in all these cases where we've had
success, some of the credit for that success should go to the NRC staff
for being proactive and helping us to develop processes to make these
changes work, and one of those is ISI. And, as you know, this effort's
been under way for a number of years, and there is a significant burden
reduction associated primarily with the reactor coolant system, ISI,
scope. By focusing the weld-inspection scope based on known degradation
mechanisms and risk insights are you able to achieve a narrower scope of
inspection without any risk decrement. And, as you know, this can be
done on a full-plant basis or on a partial basis. That is just the
Class 1, the RCS, ISI.
DR. POWERS: When you say that you reduce the scope and you
go -- get no risk decrement?
MR. BRADLEY: That's correct.
DR. POWERS: It seems remarkable to me. I mean, I would
think that there must be some risk decrement.
MR. BRADLEY: There are a number of reasons for that. The
previous scope was not focused. It was essentially somewhat random.
This is a targeted focused scope based on a lot of industry experience
about --
DR. POWERS: So you might even say there's --
MR. BRADLEY: It's a risk improvement for some plants.
DR. POWERS: Risk improvement.
MR. BRADLEY: There's also improvements in testing methods,
in the NDE methods that are picked up as part of this that also result
from a lot of experience.
DR. POWERS: Well, it's probably true in the full scope
implementation because there in fact you add --
MR. BRADLEY: Right.
DR. POWERS: I mean, you actually may add some -- you've
reduced many, but you add others that are significant.
MR. BRADLEY: It's true even in a Class 1 partial scope.
These are either risk-neutral or a risk improvement in the ones we've
achieved so far.
Just to give you some ballpark numbers on actual burden
reductions, as you can see, the -- and there is a lot of plant
variation, plant-to-plant variation on this because of differences in
design, the amount of radiation exposure involved, how old the plant is,
accessibility, et cetera.
But for a typical plant we're looking on the order of a
quarter of a million dollars per year or per cycle, which essentially
will pay for the implementation costs in one cycle. And more
importantly there is a significant occupational radiation exposure
reduction typically on the order of 25 person-rem per year or per cycle.
These should probably be per cycle --
DR. SHACK: Per cycle.
MR. BRADLEY: Per plant. And that is a not insignificant
proportion of the whole occupational exposure burden that we face.
DR. SHACK: Just out of curiosity, at our Materials and
Metallurgy Subcommittee meeting an NEI staff person estimated the cost
of a ten-year update to the ISI at a million bucks, and you're going to
do the whole risk-informed ISI implementation for 250K?
MR. BRADLEY: Yes, well, this is just a fraction of the
whole program. I can't speak to that other number.
DR. POWERS: When you quote 250K burden reduction, does that
include some evaluation of the worth of 25 person rem avoided exposure?
MR. BRADLEY: No. You can attribute a certain cost
reduction to the exposure reduction, but this is not included, so
there's actually a greater benefit there.
Another thing that the industry and staff have I'd like to
say successfully worked together on, and we talked -- Mark talked about
this previously -- is a process to expedite the review and approval of
these changes for follow-on plants after the pilots, and luckily for us,
10 CFR 50.55(a)(a)(3) is a unique regulation in that it provides right
there in the existing regulation for the use of alternatives that can be
approved by the Director of NRR, and because of that you don't need
rulemaking in order to come up with a -- or use a different approach.
And it would be nice -- if there were other regulations with
those types of provisions I think we could move forward a lot faster in
risk-informed, because rulemaking, regardless of everyone's intentions,
is always a slow, slow process, and -- however, we were able to work
with that provision, and we did develop for the Westinghouse owners'
group method and will be doing this also for the EPRI method what we
called a template submittal.
With a series of meetings with the staff we determined
exactly what information the staff needed to facilitate an expedited
review, and we agreed up front on what needed to be in that submittal.
And in addition to that there was an information notice that provided an
extension of your ten-year interval to allow plants to incorporate the
improved programs, the ones that were running up to the end of their
intervals.
So I'd like to say we've worked very positively with the
staff in the ISI area, and that's been very productive.
IST I'll just briefly note. There has been one approval and
I think a number -- several other plants are docketed or about to
docket. And this one is a -- it's a risk ranking, risk application, and
does allow some extension of your pump and valve testing for low-safety-
significant components in a stepwise fashion from the existing quarterly
requirement up to ultimately a six-year requirement, although not at
this time. For the plant that was approved -- for Comanche Peak that
allows elimination of 1,500 tests in the initial cycle.
Additionally another cost benefit for this is that for some
plants IST can be part of your critical path, depending on how your
outage planning is conducted.
DR. POWERS: Numbers that I have seen for the cost per test
always astound me, because they're so high. The dollar savings here
must be extraordinary.
MR. BRADLEY: Well, interesting, the numbers that we got
from Comanche Peak I thought were quite low. I mean, it was on the
order of just several hundred dollars per test.
MR. BARTON: That doesn't make sense.
MR. BRADLEY: That's, you know, that's all I can tell you
from the numbers that we got from them. However, plants such as San
Onofre that are going to be docketing this in the near future estimate
they can save two days off of critical path outage, and there are
significant --
DR. POWERS: You save a lot of bucks there.
DR. APOSTOLAKIS: What's LSSC?
MR. BRADLEY: Low safety significant component. That's sort
of a maintenance-rule terminology, but that's basically the lower half
of your risk ranking.
DR. MILLER: What kind of dollars per test -- back to Dana's
question -- dollars per test would you have expected to see, even though
South Texas is quite low?
MR. BRADLEY: I don't --
DR. MILLER: Hundreds of dollars seems -- I can't believe
you can do any tests for hundreds of dollars.
MR. BRADLEY: Well, that's why -- I mean, I can tell you,
we've explicitly asked that question, and that's what they have told us
at that plant. That's the only data I have at this time.
DR. POWERS: And they actually may be right, because they're
working with LSSCs, and, you know, some tests just are literally
plugging a meter into the back of a board.
MR. BRADLEY: Right.
DR. POWERS: And --
MR. BARTON: Two electricians stroke a valve. Maybe the
$200 is labor costs.
DR. POWERS: The average test that's done by a plant is
pretty expensive.
MR. BRADLEY: Another area I'd like to talk about, and I
think this is another area that I would call a success, and again this
is due to proactive and good work on the part of the NRC staff. They
deserve some credit for this in the whole area of tech specs. I think
the tech spec branch has been very forward looking and willing to accept
change, and has actually put proposals on the table for their own ideas
of how to risk-inform tech specs, which is somewhat unique for the staff
as a whole.
There have been in the last year or so a number of AOT
extensions approved, as you see here. The CE plants went in as a group
submittal for the SITs and LPCIs, and some of them have also gotten the
AOTs on the diesels. And as you can see a number of other plants have
come in and received approvals for diesel generator AOT extensions.
Again, this was due in part to NRC taking the initiative to
make some internal changes to facilitate timely reviews and approvals,
and this resulted from a stakeholder workshop that occurred last July.
And there was an elevation in the priority of risk-informed tech spec
requests from near the low end of the spectrum to near the high end of
the spectrum and, generally, a targeted six-month approval schedule for
these types of applications.
As Mark mentioned, there is a new effort underway by the NRC
staff in conjunction with the Owners Groups and NEI to look beyond just
AOT extensions and look at some of the form of tech specs, the form of
the action statements, the end states. Tech specs are very conducive to
risk-informed improvements because in a lot of ways they are not real
risk smart, the way they are set up now. You may have end states that
are less safe than the operating state for your action requirements.
For instance, if you lose an RHR function or something, the
action requirement may be to shut the plant down, where you are really
challenging the system that is not there or degraded. Also, end states
where you go to cold shutdown. It may be preferable in a number of
cases to go to a hot shutdown where you maintain steam pressure to drive
turbine driven makeup sources.
So we are well into that effort now. We are expecting,
again, this is one that you can do without rulemaking. 50.36, which is
the controlling rule for tech specs, doesn't appear to need to be
changed in order to accommodate these types of changes. We can put them
into the improved standard tech spec. So, again, anything that can be
done without rulemaking, you know, is well worth pursuing and there is a
lot of interest in the industry in this effort.
I wanted to talk a little bit about some overall lessons we
have learned from all these applications. What we have seen, I think,
over the last year, while we have had a lot of improvement, and I guess
it shouldn't be unexpected that you are not always going to have an easy
road to hoe on these things, and I guess I would state, you know, it
hasn't -- we haven't seen consistent execution of the PRA policy
statements, you know, which says, you know, that you should be able to
use risk insights to reduce burdens.
And as Chairman Jackson has said, the staff should be
willing to let go of what is not important once it is really determined
that it is not important. I think the situation is getting better and
better, but there are isolated instances where the NRC staff, you know,
will appear to just really have -- try to raise obstacles rather than
look for resolution paths. I don't want to, you know, overly emphasize
this. I think it is getting better, but there is still some of that.
We have seen very effective -- you know, the Commission's
directions to the staff, the EDO tracking memo and the internal panels,
all those things have been very effective at making this situation
better. I think when we talk later today about the maintenance rule,
maybe, you know, and the idea that the a(4) assessment needs to be
performed against the entire scope of the maintenance rule, that is one
area where we could talk about this.
Also, of course, we have some lessons on the industry side
and, you know, just like on the NRC side, where you need strong
management support, you have to have strong management support on the
industry side as well, especially for the pilot applications, where
these were multi-year efforts and the resource expenditures became much
larger than anticipated. It really took involvement of the top utility
management continuously to achieve that. An example of that I think is
the STP graded QA implementation where just, you know, years and years
of effort were required.
Clearly, we have to have complete, credible proposals. None
of this is going to work if we don't do it right. I think that goes
without saying. And I think another lesson, and this is, again,
obvious, is that the schedules, the issues -- you need as much upfront
understanding as possible because you tend to get into a sequential
identification of new issues as the process proceeds, and, again, that
is to be expected to some degree, but it is extremely important to have
upfront understanding of what the sticky points may be, and at least to
have that in your plan, and in your decision, you cost benefit decision
as to whether it makes sense to proceed.
A couple of more slides. Relative to PRA, I think this came
up in Mark's presentation. Before I even get to that first bullet, I
think one of the things we have learned is that when you get down at the
detail level on something like graded QA and some of these other
applications, much of what you are doing at the component level is not
in the PRA. If you look at South Texas, they have evaluated 23,000
components for graded QA. Only 1,200 of those were modeled in their
PRA. So for approximately 95 percent of that total set of SSCs, they
are having to use basically a set of risk-informed kind of questions and
an expert panel process, a whole set of expert panels to run those
components through and make that determination.
So, you know, I think maybe that was something that we
didn't really recognize when we went in, but much of what we do does not
involve -- you can make a lot of risk judgments and risk insights
without having the component explicitly modeled. Now, you will have the
function, the system or the train modeled, but how that component
relates to that is something that is not explicitly modeled or
quantified.
We talked about PRA quality. I would mention on
certification, at this point all four Owners Groups have funded large
amounts of resources to support certification. Out of the 104 operating
plants, 100 of those will undergo the certification process by the end
of 2001, and we hope to be up to 104 very shortly. So that is an
indication of the recognition, I think, on the part of the utility
management that there is real benefit and a real need to address the
state of your PRA.
We have a lot of effort going on now. Mark mentioned the
need to reconcile the draft ASME standard with the certification
process. That is of paramount importance for the industry because of
the large investment we have in certification now, and we will be
meeting with NRC next week to discuss how we do that. We are actually
funding through EPRI a significant amount of technical work to reconcile
those two processes, and we will be demonstrating one section of how we
believe that could be done at a meeting next week with NRC.
DR. MILLER: On that area, the industry strongly believes
there is a necessity of having both the standard and the certification,
as long as they are reconciled, is that what I am hearing here?
MR. BRADLEY: The industry, you know, clearly, obviously,
supports that there has to be appropriate treatment of PRA quality as a
function of application. We believe those efforts should be reconciled,
that we shouldn't have a standard that somehow does not recognize what
we are doing with certification. And if there are additional elements
that need to be addressed, you know, we are willing to consider those,
but we don't want to reinvent the wheel with the standard versus what we
have done so far in the certification process.
DR. MILLER: Now, I know you have just gotten into that and
the standard is just basically available in the past few months. Do you
see a problem with the reconciliation at this point, or is it too early?
MR. BRADLEY: Well, I would like to -- you know, I would
like to think there is not a problem. I will say that I think the
current form of the draft standard does not comport very well with the
certification process.
The technical elements of the PRA are similar, but the
approach is somewhat different and the certification is like a four step
grading process on each of the technical sub-elements of the PRA,
whereas, the standard uses a reference PRA with about 900 requirements
and is basically binary. You either meet it or you don't, and when you
don't meet it, I think -- and in its current form, it basically leaves
open the question of what you do. Whereas, with the certification
process, you are left with -- you know, it is versus a binary. It is
sort of a four level thing that gives you, in my mind, a better
understanding of the ability of your PRA to support a given application.
And that -- actually, the work that EPRI is doing right now
is to take the standard, the draft standard and take the criteria from
the certification process and superimpose that so that we bring the two
together.
DR. MILLER: Well, one reason to ask that question, as you
are probably aware, we are moving into phase two of that standard.
MR. BRADLEY: Right.
DR. MILLER: Which is going to be -- of course, ANS is going
to take the lead there. Should the ANS group look at what is happening
here with this reconciliation process?
MR. BRADLEY: Absolutely. It is extremely important. I
think there is some concern that, you know, that effort -- well, I will
just say, it would benefit greatly from looking at the lessons that have
been learned through the development of the ASME standard, yes.
But we are still hopeful that that final product, the final
standard will reflect the current practice, and with whatever
improvements may be deemed appropriate. And we, you know, industry
supports the concept of a standard.
DR. MILLER: Now, both standards groups, ASME and ANS, I
believe both have NEI representation on them.
MR. BRADLEY: I know for sure the ASME one does, and I would
assume that the ANS does.
DR. MILLER: So it should happen automatically, or maybe --
does somebody have to drive, make certain that does happen?
MR. BRADLEY: Yes. One last -- the second bullet here. I
think what we have seen is, relative to quality, the more difficult
issue that we often grapple with in trying to put submittals together,
and that also comes up in the review process, is, you know, the
integrated decision making process where you are trying to combine
deterministic and risk insights, often which give different answers to
the question and how do you bring, you know, what may be sort of bipolar
kind of insights together and mesh them into some solution or decision
that makes sense.
And George mentioned defense-in-depth as an element of this,
and this is an area, in my mind, if we were to do some more work to try
to expand 1.174 or, you know, industry put together additional guidance
on how to make this successful, this is an area that could use some more
work.
Now, I think this is somewhat obvious. 1.174 has been
instrumental in allowing these changes to move forward, and I think
everything we are working in the industry is within the envelope of
1.174. We have reevaluated the whole plant study and trying to fold
that into the prototype for the Part 50 reform effort, and we are really
looking to try to work within the constraints of 1.174 to do that,
whereas, previously, we had been sort of in Level III space with that
effort. But we do acknowledge that that has provided a good framework
and a method to achieve success.
And that concludes what I had to say.
DR. APOSTOLAKIS: I would like to have copies of the slides.
MR. MARKLEY: Yes.
MR. BRADLEY: I will get those for you.
DR. SHACK: If no more questions, it is --
DR. MILLER: I had one kind of broad question. I was going
to ask Mark to -- Mark had on his slide the stream is increasing. Biff
gives me the viewpoint the stream is going to definitely increase. Do
you think the capability of staff at NRC and individuals at plant, their
capability is going to keep up with this stream? Right now it has been
focused primarily on people who really know what PRA is and so forth is,
both at the plant level and the NRC level. As this stream increases,
there is going to be a lot more people who have to be up to speed, so to
speak.
MR. BRADLEY: I can speak, I guess, -- I am not comfortable
speaking the NRC.
DR. MILLER: You can't speak for the NRC.
MR. BRADLEY: But for the industry, I think, yes, I mean we
have more, you know, more volume of resources to bring to bear with
this, both people and money, and it is a market-driven kind of process.
I mean once we see success occurring in the field, it creates an
incentive for more applications and more interest. I think the answer
to that is yes.
Just trying to do the certifications for 100 plants and put
those kind of teams together to do that, you know, is requiring us to
build our expertise to some degree.
DR. MILLER: So you don't have any reservations about the
expertise being -- following very rapidly with the -- or not being a
limitation, in other words?
MR. BRADLEY: I would like to think it isn't. I guess I,
you know, -- as we talked about earlier, the plants we have worked with
thus far are sort of the leaders of the pack in terms of having pretty
good PRAs.
DR. MILLER: Well, they had a good group to start with.
MR. BRADLEY: Right. And I don't have thorough knowledge
of, you know, beyond there is a certain set of plants that have been big
players in this, and now we are down to another tier which now has a lot
more interest than they did. So, you know, that is really a question
that remains to be fully answered, but I would like to think we can, you
know, pull it together.
DR. MILLER: It was a year ago we heard -- at least we heard
that some plants were bailing out, so to speak, and reducing their PRA
groups and so forth. With this renewed interest, that means you are
going to have to return the pendulum, so to speak.
MR. BRADLEY: I don't hear about anyone bailing out these
days.
DR. MILLER: I don't think so. But are they going to be --
when are the tier three plants, not the tier two, tier three is going to
be able to catch up?
MR. BRADLEY: Right. Yeah. I mean the fact that we have
100 out of 104 plants scheduled for certification is an encouraging
sign, because that is going to basically -- you know, if you don't have
a good PRA, it is certainly going to tell you that it is not good and
provides you the road map to how to make it better, so.
DR. MILLER: Mark, could you make a comment on that same
question? If the stream becomes a river, so to speak, or a flood, is
the staff going to be able to keep up? Because right now you have been
focused on those who have been involved in this for maybe several years.
Not all the staff of NRC has been involved.
MR. RUBIN: Not all the staff has been involved, and if the
floodgates open, definitely, the knowledge base for PRA implementation
is going to have to be spread more widely.
DR. MILLER: Very rapidly.
MR. RUBIN: As rapidly as we can. But I would note that
that has already occurred to a fairly significant degree. The PRA
Branch did not run these pilot reviews, did not do these pilot reviews.
They are run by the technical groups. Nan Gilles ran the tech spec
activity with support from us. The Geosciences Branch ran ISI. MEB ran
IST.
There is significant involvement in buy-in. Now, it is not
100 percent, but compared to where it was 30 months ago, it is rather
impressive. But it will have to be even more. Can we do it? Sure.
DR. MILLER: Okay. We heard that, he said sure.
DR. POWERS: Are you done? I am going to take a recess till
10:30.
[Recess.]
DR. POWERS: Let's come back into session. Our next topic
is the proposed final revision to 10 CFR 50.65, the famous maintenance
rule. John, I think you are the cognizant member on that.
MR. BARTON: Thank you, Mr. Chairman. The purpose of this
session is to hear presentations from and hold discussions with
representatives of the NRC Staff and NEI regarding the proposed final
revision to the maintenance rule and associated Regulatory Guide, which
would require licensees to perform safety assessments prior to
performing maintenance activities.
At the 459th ACRS meeting in February the Staff did brief us
on the final revision to the maintenance rule. I don't believe there's
been much, if any, changes to the rule that we are going to hear today
from what we were briefed on in February.
The intent of the revision to 50.65 is to require licensees
to perform assessments before maintenance activities are performed on
SSCs covered by the maintenance rule and to manage the risk that may
result from the proposed activities during all modes of operation
including normal power operation and shutdown conditions.
Staff has provided a copy of the draft associated Regulatory
Guide and will brief the committee on this Guide today. We did not have
a briefing in February on the Reg Guide.
The committee is expected to prepare a report on this matter
and I believe we will also hear from NEI, Biff Bradley, to get
industry's perspective on the rule change as well.
At this time I will turn it over to NRC Staff and Rich
Correia will take the lead.
MR. CORREIA: Thank you very much. Good morning. Again, I
am Rich Correia, Quality Assurance Vendor Inspections, Maintenance
Branch of NRR. With me today are my Division Director Bruce Boger, my
Branch Chief Ted Quay, and Wayne Scott, who is in my section, and Dr.
See Meng Wong from the Probabilistic Safety Assessment Branch of NRR.
Thank you for describing my intro, that we were here in
February. We did present to the committee why we were changing the
rule, responses from the public on the proposed rule, our proposed
reconciliation of those comments, and our revised rule language based on
those comments. You are absolutely right, nothing has changed since
February 4th regarding the rule language.
We have, however, drafted regulatory guidance for this rule
change and we will present that today. It is the same information that
I gave Mr. Singh last week.
For purposes of comparison, the existing language, which is
not a requirement in what we are sending up to the Commission soon,
right now the rule says that an assessment should be performed before
maintenance activities are conducted, essentially. Obviously it is not
a requirement because it says "should" and it also doesn't state what
the licensee should do with the assessment. It just says do the
assessment.
Modified language changes the "should" to a "shall" do an
assessment and then it tells them to manage the risk that may result
from the proposed maintenance activity -- so it is a more complete
package.
Originally the Commission gave us different language than
what we are sending back up but based on the comments we received from
the industry and public on the concerns they had with the new language
we revised it, as we told you in February. This is a reflection of
that. Nothing has changed since then.
DR. SEALE: Actually it is to manage the increase in risk.
MR. CORREIA: Yes.
DR. SEALE: So there is an acknowledgment that there can be
an increase, and that is an important difference.
MR. CORREIA: Yes. Oh -- I'm sorry. There was one word
change since February. Previously we had "assess and manage any
increase in risk." We change that to "the increase in risk" -- that was
the only change.
As we told you in February, these are our plans.
To let you know what the current status is, we go into the
final stages of putting the package together, getting all the right
concurrences. We have drafted a Regulatory Guide for this rule change.
We hope to have it out soon for public comment, incorporate any changes
and then have it issued by July timeframe.
One important point here that isn't on this slide, our
proposal back to the Commission is that the final rule, if and when
approved, will not go into effect until 120 days after the Regulatory
Guide is final. Initially the Commission said change the rule, deal
with the Regulatory Guide and it's after the fact. Public comments were
that they should work together simultaneously. We are doing that. We
are proposing that the Commission agree with that position.
MR. BARTON: I think based on the rule change and some of
the industry's concerns, I think it is essential that you do get the
Guide out ahead of the rule.
MR. CORREIA: We had a meeting with NEI Tuesday where we
presented the Guide and our thoughts on it to at least open the door
with them and the industry so they can start understanding where we are
going with this, and I think it will help in the long-run to calm some
of the fears that may have been out there with reading a rule, part of a
rule, and not understanding what the Staff's expectations were. We are
doing that.
That is essentially where we are with the rule. If there
are any questions or comments on that, we could take them now.
DR. SEALE: Yes. I am perturbed. On the previous slide you
have what purports to be the existing language and then the modified
language and we commented about managing the increase in risk and then
you indicated that the actual language in the previous version talked
about any change in risk.
MR. CORREIA: Any.
MR. WONG: In February.
DR. SEALE: Yes, in February, right. That is not in this --
I mean that language is embedded someplace else in the February thing,
but that has been completely changed now, eh?
MR. CORREIA: No. This modified April language is what we
presented to the committee in February with the exception of the word
"any" --
DR. SEALE: Okay.
MR. CORREIA: That's all. That's the only difference.
DR. SEALE: I've got you now.
MR. CORREIA: What we showed you in February also was the
language the Commission gave us to put out as a proposed rule.
DR. SEALE: Right.
MR. CORREIA: Which we modified to this to reflect public
comment. We still believe this meets the intent of what the Commission
told us to do but it is just using different words.
DR. WALLIS: Are you going to tell us what "manage" means?
I think he is going to tell us what "manage" means.
MR. CORREIA: Yes -- assess risk and manage --
DR. WALLIS: Because I am trying to imagine what it might
mean.
DR. POWERS: It is a very interesting thought, isn't it, but
it is also an article of faith within the nuclear community that one can
manage risk -- and even accidents on top of that.
DR. SEALE: And herd cats.
DR. POWERS: That is an article of faith within the NRC's
management structure.
MR. CORREIA: Dr. See Meng Wong, who is here today, will
present the draft regulatory guidance. He was certainly instrumental in
drafting it. He was also involved with many of the maintenance rule
baseline inspections reviewing this part of the rule. Even though it
wasn't a requirement, we did evaluate doing the inspections and what
essentially this guide does is capture those good practices we saw
licensees implementing during the baseline inspections, and we hope that
because of that this is not anything new. They have seen it before.
They understand it and hopefully will agree with it.
MR. WONG: Good morning. My name is See-Meng Wong of the
NRC branch NRR, and in support of the proposed revision to the
maintenance rule (a)(3) paragraph, we in the PSA Branch and in
coordination with Rich Correia's staff have prepared a draft reg guide
DG-1082 to provide guidance and to lay out the expectations of -- the
staff expectations for the implementation of this requirement if it goes
into effect.
Consistent with the modified rule language, we have titled
this draft reg guide as "Assessing and Managing Risk of Maintenance
Activities at Nuclear Power Plants."
We have stated before the intent of the 10 CFR paragraph
(a)(4) is to require licensees to assess and manage the increase in risk
from proposed maintenance activities. For the assessments for
maintenance activities the main steps are essentially that we expect the
licensee to review the current plant configuration and any changes
expected to plant configuration from the proposed maintenance
activities, and in this process determine the risk-significance of the
proposed activity, whether it's going to be a high-risk or low-risk
activity.
DR. POWERS: What constitutes the boundary between high risk
and low risk?
MR. WONG: Okay. We will go into the definition of the
risk-significant, because one of the -- the intent of this is to ensure
that the plant is not inevitably placed in risk-significant
configurations. And there are comments from the industry requesting us
if this rule requirement is going into effect, how do you define it.
Okay? And as you look at the definition that I'm presenting in the next
slide, the risk of a maintenance activity depends on the configuration
and also the duration in which that configuration is going to be in.
And I'm jumping one step ahead. Okay?
DR. POWERS: Well, you're going to jump ahead, but -- maybe
I should wait. But I think I'm going to be asking you more quantitative
questions than you have on the slide.
MR. WONG: Yes. Yes. We have that.
Now our expectation is that the licensee perform the
assessment commensurate with the complexity of the maintenance
configuration, and what we mean by this is that the detail of assessment
can vary from an informed judgment for simple SSCs that are taken out of
service to using an online PRA tool, like a risk monitor, to evaluate
multiple SSCs that are out of service. So we're trying to cover the
spectrum of the practices that are in place right now.
DR. POWERS: You used the word "complexity."
MR. WONG: Complexity meaning the size of the configuration.
DR. POWERS: I guess that's exactly what I'm asking. If I'm
doing maintenance on seven systems that are largely independent of each
other --
MR. WONG: Yes.
DR. POWERS: There's no interconnection, electrical or
hydraulic, versus two systems that are interconnected, what is the
relative complexity of those two possibilities?
MR. WONG: Okay. If there are interdependencies, one would
have to look and say what are the possible recovery actions that need to
be taken and to credit in the calculation of the risk of that
configuration. So it is independent -- configuration risk say
calculation on a methodology that we have done through pilot studies is
that we will look into what is really the delta risk increase that one
would see, varying say from two to say five orders to seven. So there
are what I call calculational considerations that need to be addressed.
DR. POWERS: Okay. If I did these calculations and I ended
up with a delta CDF of 2 times 10 to the minus 5 --
MR. WONG: Okay.
DR. POWERS: Is that good, bad, or indifferent?
MR. WONG: Okay. Let me say if I were to do a calculation
and come up with a number, say 2 E minus 5. Okay. An in-depth
configuration, what we're talking about is that the site say preventive
maintenance activities, the surveillance activities that take a plant
out of service, and we have gone through the process of, say, reviewing
this calculation say with a person of operational experience at the
site, and he would say if I take this component out of service for
surveillance purposes, I could be able to recover it within a certain
time. And so that's the credit that one needs to address say to reduce
that delta CDF value that you get. And that is the number after you've
gone through that analysis to determine whether it's risk-significant or
not.
MR. CORREIA: So it would be a combination if you are using
a risk tool --
MR. WONG: Right.
MR. CORREIA: Of the probabilistic risk versus the other
actions the utility would take to compensate or try to reduce that risk.
Even though you may not be able to quantify it, I think we would agree
that those kinds of actions occur all the time in work planning -- in
scheduling.
DR. KRESS: Aren't those things amenable to the original
calculation? Don't you put those into the PRA -- those other actions?
Don't they show up in the PRA?
MR. WONG: Okay. What we're talking about here is that say
for multiple SSCs that are in a configuration we have identified say
five, six, seven, whatever it is, okay? And we use the -- run it
through the PRA calculations. Okay. There are credit or recovery
actions that are already embedded in the PRA model.
But further to that, if you consider the operational aspects
of that configuration, and the example I gave is that in some
surveillances where the components are taken out of service, but their
functions are not defeated. So after the first cut, then you take this
credit into account, you come up with what I call a much better CDF
increased number.
DR. APOSTOLAKIS: Do you mean CDF or CDP?
MR. WONG: CDF, then afterwards, then you integrate over the
time.
DR. APOSTOLAKIS: So the ultimate criterion is CDP?
MR. WONG: CDP, yes.
DR. BONACA: But those kind of for example credits you
have --
MR. WONG: Yes.
DR. BONACA: They are in the PRA, but the operator in the
control room doesn't know that. So managing risk means to pull out
those kind of pieces of information, make them available to him.
MR. WONG: Yes.
DR. BONACA: Okay.
MR. WONG: Yes.
DR. BONACA: It is important.
DR. APOSTOLAKIS: They are not necessarily in the PRA,
though. I don't think --
DR. BONACA: Certain recovery action.
DR. APOSTOLAKIS: Yes, but, I mean, they are more general, I
would say, than specific actions that the licensee might take for
specific maintenance activities.
DR. BONACA: No, but I'm saying the PRA can identify what is
the most important equipment to recover first, should you get in a
certain situation, and also identifies -- so there are certain
perspectives about the equipment to recover first and the equipment to
protect as you are in a certain --
DR. APOSTOLAKIS: Sure.
DR. BONACA: And that's information which is in the PRA but
is not in the control room. So what you want to do in managing the risk
there is to pull out this information, make it available to the operator
so that he knows what it is.
DR. APOSTOLAKIS: But in the process of managing risk,
though, for a particular activity, they may decide to do certain things
that have not been modeled baseline PRA. That's what I'm saying.
DR. BONACA: Absolutely.
DR. SEALE: Could I ask if you have a configuration that is
complex by virtue of the fact that you're doing maintenance on two
systems, and they are I won't say certainly but perhaps interconnected,
where do you go to confirm whether or not an interconnection exists?
MR. WONG: Okay. One of the things that you would do is we
would go to the PMIDs, and before we do the calculation, we review that
process with the senior reactor operator, and to have a better
understanding of what we are calculating.
DR. SEALE: You don't go to the PRA to find out whether
they're interconnected.
MR. WONG: No, we don't do that.
DR. SEALE: Okay. Fine.
MR. WONG: Okay.
DR. WALLIS: I would think that rather than just planning
some maintenance and then assessing its risk significance, that you
would actually use what you know about risk in order to plan the
maintenance activities in an intelligent way.
MR. CORREIA: Certainly to identify those systems that are
most critical to plant safety.
DR. WALLIS: An important thing is that in designing your
maintenance activities and planning them that you bring in risk as a
criterion for how you go about it.
MR. CORREIA: Absolutely.
DR. WALLIS: I just didn't see that in the slides.
MR. CORREIA: I guess that's a utility determination. What
we're trying to do here is when they do do that, consider the risk
impact of the proposed maintenance and then assure reasonably that you
can manage it, and make sure that you get the equipment back in service
back to the level of reliability that you need.
DR. POWERS: During what period of plant operations is most
of the maintenance done on safety-related systems?
MR. WONG: I think that depends.
MR. CORREIA: Are you talking about during an operating
cycle?
DR. POWERS: Yes.
MR. CORREIA: We found that it varies plant to plant. Some
plants are very conservative and do very little, and hold it to the
refueling outage. There aren't many left, though. Most plants have a
rolling 12 or 13-week cycle that they plan to do maintenance on the same
sets of systems, maybe train A one week, train B the following week, or
C or whatever. But it's typically at full power, which is the driving
force behind this regulation with the increase in online maintenance and
the -- in order to achieve shorter refueling cycles this in our mind
is -- this regulation is very important.
DR. KRESS: At any given time there might be some important
equipment out of service.
MR. WONG: Yes.
MR. CORREIA: Yes.
DR. KRESS: Is that normally reflected in the PRA that
calculates the CDF? Is that normally reflected in the PRA when you
calculate the CDF?
DR. APOSTOLAKIS: What? Is that a piece of equipment that's
out?
DR. KRESS: Piece of equipment would be out for maintenance.
MR. WONG: Yes.
DR. POWERS: It's reflected in an annualized sense.
DR. KRESS: Yes.
DR. POWERS: The point value of PRA during the period that
it's out would not appear in an ordinary probabilistic risk assessment,
but the annualized effect, if the thing was out one week out of every
12 --
DR. KRESS: So each plant has to predict what equipment's
going to be out of service when, what frequency, in order for that to be
reflected in the PRA.
DR. APOSTOLAKIS: Well, I don't know about that.
DR. KRESS: Otherwise you can't reflect it.
DR. BONACA: But that's an important point you're making,
Tom. What I mean is that in the IPEs and the PRAs to date it was
reflected in historical unavailability of systems, okay? When in many
cases online maintenance wasn't done much. Now when you go to a much
more aggressive one, you have to trace exactly that.
DR. KRESS: Update the PRA.
DR. BONACA: Absolutely. How are you affecting --
DR. KRESS: But you have to have data on when and how much
equipment is going to be out of service.
DR. APOSTOLAKIS: That's right. I think what you see
typically in a PRA, at least the last time I looked, was that, you know,
you have a system, you have a two-train system, it has periodic
maintenance requirements and so on, so you do the calculations for that
system and you average over time. So you take one cycle and average
over time.
DR. KRESS: I see how you do it, but you have to have that
data base.
DR. APOSTOLAKIS: But you don't ask, though, whether during
the time that this component is down something may be happening in
another system.
DR. KRESS: You don't.
DR. APOSTOLAKIS: No. Not in a typical PRA. Now when you
go to online maintenance, you may start asking those questions.
DR. KRESS: It seems to be something you ought to ask.
DR. APOSTOLAKIS: Yes.
DR. BONACA: And in fact --
DR. APOSTOLAKIS: And you will ask it.
DR. BONACA: And those computer programs to do that,
typically they had to be modified to be able to account for multiple
system -- because originally they were unable to do that. In fact --
but then if you do that, then you begin to trace your unavailability.
Now based on that you find that you have different kind of trends for
the one you represent in the IPEs insofar as, you know, CDF plus
unavailability included in it. So there is, you know, there is a lot
of -- yes.
DR. KRESS: Now that leads to the question I was getting to.
If those online maintenances are already reflected in the PRA, why the
hell do we need a delta CDF? It's already in the CDF.
DR. APOSTOLAKIS: The combinations are not reflected.
DR. KRESS: It's the combinations you say that are needed.
DR. APOSTOLAKIS: They are not.
MR. CORREIA: What you have just described is paragraphs
(a)(1) and (a)(2) of the maintenance rule, which requires establishing
some type of goal or performance criterion for each of the SSCs,
reliability and availability. Licensees have to monitor each one of
those measures, goals, and if they exceed them, they have to take some
appropriate action, including the impact if it's modeled in PRA of what
that does to risk. But that's individually.
MR. WONG: Right.
MR. CORREIA: But what this part does is integrate those
reliabilities and unavailabilities and shows you what the potential risk
could be.
DR. APOSTOLAKIS: But also now you are calculating the core
damage probability even that the piece of equipment is out.
The PRA doesn't do that. It says we are going in time and
then this component goes down, okay, and then this one goes down, and we
are averaging now the unavailability of the whole system in time. So if
it is down, say, for an hour-and-a-half every month, then there will be
a contribution of 1.5 over 720. That's it. There will not be a
separate calculation saying if this is done, then the rest of the system
has this probability of failure, for different calculations.
DR. BONACA: But if you do it instantaneous, however, if you
do --
DR. APOSTOLAKIS: But we don't do that in the current PRA.
DR. BONACA: Not in the current PRA.
DR. APOSTOLAKIS: These guys want to do that.
DR. BONACA: Absolutely.
DR. APOSTOLAKIS: Maintenance.
DR. BONACA: But, you know, to give you a sense, when you
look at some of these results and you take two or three systems, it is
not unusual to have a CDP going up by a factor of 20 or 30.
DR. KRESS: For a short time.
DR. BONACA: For a short time. But that tells you why, I
think, there is I think an intent in managing that, because you may have
actually much higher increases than that.
DR. KRESS: But I was maintaining that is already reflected
in the --
DR. BONACA: No, because this is for multiple components
that you assume simultaneously to be failing.
DR. APOSTOLAKIS: There are two fundamental differences the
way I see it. One, that you are looking explicitly now at combinations
of components from different systems, right?
MR. WONG: Yes.
DR. APOSTOLAKIS: And, second, you are saying if these are
down, what is the conditional probability of failure, which PRAs don't
do right now.
DR. KRESS: I see no reason why they couldn't do it.
DR. APOSTOLAKIS: Oh, they could. Yeah, sure. Sure. The
baseline model can be used to do these calculations.
DR. WALLIS: If you could plan all your maintenance ahead of
time, you ought to be able to work all that out and put it into the PRA.
That is a proper assessment of --
MR. CORREIA: And we have seen licensees do exactly that.
MR. BARTON: And most people do have their maintenance plan
out for a whole cycle.
DR. KRESS: Now, the next question is, do we need -- is
there some sort of cap on the short time delta CDF?
DR. APOSTOLAKIS: Well, you remember we discussed that when
we were talking about the allowed outage times, and the staff came back
with --
DR. KRESS: I mean if you are going to make some judgment on
what is acceptable.
DR. APOSTOLAKIS: Yeah, they made a judgment that delta CDP,
core damage probability, should be less than 10 to the minus 7, or
something like that, which is the integral of the conditional times the
interval.
DR. POWERS: There was actually a pretty rational reason for
taking that number.
DR. APOSTOLAKIS: Yes.
DR. POWERS: I thought it was a pleasing aspect.
DR. APOSTOLAKIS: They had an example. But that was for --
yeah, it was for temporary changes --
DR. BONACA: No, just, you know, I am interested, in fact,
in hearing -- because I mean taking out a component out of service of
system is not a big issue. I mean for multiple ones, certainly, there
has to be some understanding of, you know, when do you stop? Okay. And
I haven't seen --
MR. BARTON: Are you going to cover that? All right.
Continue with your presentation.
DR. APOSTOLAKIS: Page 7.
MR. WONG: Okay. The last bullet here, we want --
DR. APOSTOLAKIS: Yeah, we --
MR. WONG: You understand that. Okay.
DR. WALLIS: A repeatable, if it is somebody's informed
judgment, as you said before.
MR. WONG: Yes.
DR. WALLIS: I am not sure that is always repeatable, if you
ask somebody else.
MR. WONG: Well, repeatable I think is for the purposes of,
you know, when we go and inspect.
DR. WALLIS: You mean recoverable and that you can actually
trace --
MR. WONG: The trace, yeah to trace.
DR. WALLIS: Repeatable, if somebody else did the same
assessment.
MR. WONG: Yes. That is what we mean.
DR. WALLIS: That is a different kind of repeatable.
MR. WONG: Okay.
MR. CORREIA: The expectations the licensee would have a
process, describe adequate training for the people involved.
DR. WALLIS: Traceable. You mean you can track it.
Investigate it. But you don't mean that if some independent person did
the same assessment, they would come up with necessarily exactly the
same answer.
MR. CORREIA: I think he means close.
MR. WONG: Close. In the ballpark.
DR. SEALE: Horseshoes, close.
DR. WALLIS: It would have to be a big ballpark.
MR. WONG: Okay. The next slide is the considerations that
we expect the safety assessments to have, and we expect the assessment
of the plant maintenance activity would be to cover the SSCs there in
the scope of the 10 CFR 50.65.
In response to the concerns from NEI and industry that we
may be having to deal with a big and unmanageable set of SSCs, so within
this population, we expect licensee to focus on the risk impact of
maintenance on system, or at the train function level. For example, if
they just look at the assessment for the EDG train, you have to -- train
B and so on and so forth.
To my mind, if they do that, we are not looking more than,
any more than 150 to 200 types of systems or SSCs that need to be
considered, as opposed to going to the component level where, you know,
the licensees may be forced to look at, say, instrumentation, you know,
transmitters.
MR. BARTON: Thousands of components.
MR. WONG: Thousands of things, right. So this is in
recognition of the fact that we would like this to be a reduced burden
on the licensee.
One of the things that we expect the licensee to consider is
that, to my experience in the maintenance rule baseline inspections,
there are one or two SSCs that are considered as low safety significant,
but under certain conditions, it may become high risk significance. The
examples that I have seen, and I have got three examples one is
instrument air in the service air compressor. But artifact of the PRA
model, it sometimes is categorized as low safety significance because
there is redundancy and there is, you know, backup nitrogen bottles.
Yet, at the same time, there are some -- in some accident sequences, the
air pressure valves becomes important and the instrument air or the
service air supply is needed.
So these are the kinds -- this is one example.
DR. APOSTOLAKIS: How were you handling these situations
before the maintenance rule?
MR. WONG: Okay. Before the maintenance, typically, the
licensees have got, say, the 12 week ruling maintenance schedule, okay.
And the 12 week ruling maintains schedule, say, in this week A, in week
A, all this first week, period.
DR. APOSTOLAKIS: Right.
MR. WONG: I am going to do all the maintenance on, say, all
the train A systems.
DR. APOSTOLAKIS: Right.
MR. WONG: Somewhere before, you know, what we call the free
state in which, you know, they are going to do the maintenance, all the
selected systems. There may be a failure in a component that is in
another train. And it is this small set that we think, if the licensee
do a one time assessment, set it aside, and they don't have to do, you
know, recurrent calculations every time.
DR. APOSTOLAKIS: No, no, that is not what I meant.
MR. WONG: Okay.
DR. APOSTOLAKIS: What I meant was, before the maintenance
rule, how did the agency control these complex configurations?
MR. WONG: They use the tech specs.
MR. CORREIA: The tech specs.
DR. APOSTOLAKIS: Tech specs according to the document I
have here were developed to address random single failures of plant
SSCs. Evidently they don't deal with combinations.
MR. BARTON: They don't deal with this very well, but that
was the only way that the agency could control it. Also, there was
nothing else other than the tech specs.
DR. APOSTOLAKIS: The agency felt that they could not
control them, right?
MR. BARTON: The tech specs aren't good enough to do this.
DR. APOSTOLAKIS: The maintenance rule is intended to apply
to proposed maintenance activities that will directly, or may
inadvertently result in equipment becoming out of service, so the tech
specs don't prevent those things. Right?
MR. CORREIA: Right.
MR. BARTON: They do on individual components, but they
don't handle it.
MR. CORREIA: They don't handle --
MR. BARTON: They don't handle online integrated maintenance
very well.
DR. APOSTOLAKIS: So we are imposing additional -- I mean we
have imposed additional requirements, right, additional regulations.
DR. BONACA: But these plants were not designed to be
maintained online.
DR. APOSTOLAKIS: Online. So that was the benefit.
DR. BONACA: There was a debate going back 30 years where we
said we don't maintain online these plants, and that is why the
technical --
DR. APOSTOLAKIS: So if you do it offline it doesn't matter.
DR. BONACA: Well, and then, of course, we understand that
offline, when you are shut down, you have also high risk. So, I mean
here there is an evolution of understanding, it seems to me, that, you
know, makes it appropriate to transition here to where you can allow
online maintenance, with proper understanding.
MR. BARTON: Yes. In fact, tech specs did a worse job in
shutdown because tech specs weren't written for shutdown.
DR. BONACA: That's right.
MR. BARTON: So then the problem was worse at shutdown, when
they just had the tech specs.
DR. POWERS: Well, it seems to me that we also have this
problem that we come along and we say, okay, doing the maintenance
online has this delta CDF or change in risk. And we don't have the
capability of going in and saying, you know, if we did this when we were
shut down, what would be the delta CDF? So we really don't know whether
we are making an optimal selection of maintenance by going online. We
know that we are saving costs, because we shorten the outage time.
And I am certainly willing to defend the belief that cost
savings do contribute to safety because they make resources available
for safety, but we just don't have any quantification on it.
DR. WALLIS: But if all your maintenance were somehow
figured into your PRA, and you could plan it to reduce your CDF for the
year, and maybe if there was a prize for reducing your CDF, there would
be some incentive to reduce the risk.
MR. CORREIA: There may be something close to that in the
new assessment process. I am not saying it would be based on risk
numbers, but, certainly, in my mind, doing the right kind of maintenance
during power will -- should keep the reliability of the equipment at a
better level than waiting until you either have a random failure or
hoping you make it to the next outage to do the maintenance.
DR. WALLIS: Is there an incentive now to do it better, or
just to stay within some limit?
MR. CORREIA: I think the maintenance rule, and the fact
that it requires licensees to monitor unavailability and reliability,
has really heightened the awareness of licensees.
DR. WALLIS: This is some incentive to optimize.
MR. BARTON: This is a big incentive to do it better.
DR. POWERS: Yes. There is a big time incentive, because
you have got to meet your goals --
MR. BARTON: You have to meet your reliability goals and all
that stuff, so you do better maintenance.
DR. POWERS: You get rewards for meeting it.
DR. WALLIS: Yeah, but you could actually increase your
economic return by an optimum strategy which might actually end up
increasing your CDF.
DR. POWERS: Sure.
DR. WALLIS: More than some other strategy.
DR. POWERS: Sure.
DR. WALLIS: And you don't get a prize for the reduction of
risk, but you get a prize for saving money for your company.
DR. POWERS: Well, I think that is clearly possible.
DR. WALLIS: So there is no tradeoff.
DR. POWERS: I think there is. I think there pretty much
is.
DR. APOSTOLAKIS: Remember, you are already in the
acceptable risk area, so it is okay, it seems to me, to optimize
operations. You don't necessarily have to keep reducing risk.
DR. BONACA: As long as you understand the risk, that is the
whole issue.
DR. APOSTOLAKIS: Yes.
DR. BONACA: And the other things is that, you know, the
understanding of the risk is a key support to the operator, because he
understands what he has to do in the circumstances. So, I mean it is a
positive initiative.
MR. WONG: Okay. In response to comments from the industry
and through interactions with NEI representatives, there was a request
to ask the staff to define, you know, what do you mean by risk
significant configurations. And our definition here addresses
configurations of multiple SSCs that are concurrently out of service,
whose incremental contribution to annual risk is substantial. And the
word here I mean is that it will put them into what we call the red
zone. And any gradations below that, that is going to be determined by
the licensee. This reflects --
DR. APOSTOLAKIS: What do you mean by contribution when I do
this? You mean the conditional probability --
MR. WONG: Conditional --
DR. APOSTOLAKIS: If you are in that -- configuration is
high.
MR. WONG: Right. The delta increase in the conditional
probability. Okay.
DR. APOSTOLAKIS: That is related now to the number that the
staff has proposed in Regulatory Guide --
MR. WONG: 1.174, there is --
DR. APOSTOLAKIS: No, no, 74 doesn't have that. It was the
one on tech specs.
MR. BARTON: 76 or 77.
MR. WONG: 77, yes, 1.77.
DR. APOSTOLAKIS: So you have that in mind.
MR. WONG: That's right. And as I have stated before, the
risk of the maintenance activities depends on the configuration and its
duration. And the risk matrix we expect licensees to use would be the
increase in core damage probability or the increase in the large early
release probability.
DR. APOSTOLAKIS: The first bullet puzzles me a little bit.
MR. WONG: Okay.
DR. APOSTOLAKIS: Why do you have to put "or would
significantly affect the performance of safety functions"?
MR. WONG: Okay.
DR. APOSTOLAKIS: If it does that significantly, wouldn't
you see a significant incremental contribution to annual risk? Because
risk is really CDP and LERF.
MR. WONG: LERF, yes.
MR. CORREIA: This was to addresses the cases where
licensees were not using PRA.
MR. WONG: Right.
DR. APOSTOLAKIS: Oh, we are trying to do everything here.
MR. CORREIA: This does not -- this rule change does not
mandate a use of PRA. It is strongly preferred. And if they have it,
use it, but --
DR. APOSTOLAKIS: I wonder whether it makes sense to have it
in the same sentence.
MR. CORREIA: Oh.
DR. POWERS: You are right, it appears to be redundant. On
the other hand, my reading of the document is that they have done this
several times, for exactly the reason he is saying, that they wanted to
cover the case where there was no reliance on PRA or they had a PRA but
it just wasn't used because the system was fairly simple. So I mean it
is on this viewgraph once, but it is several times in the document that
I read anyway.
The main thing that I need to wrestle with is what do I do
during shutdown.
MR. CORREIA: We are going to address that.
MR. WONG: One of the things that the modified language
here -- and there is a preamble that it will apply to shutdown
conditions and as you are well aware, there are not very many shutdown
PRA models or studies that has been developed or are being used by a
licensee, and so the statement here is that if you don't have a shutdown
PRA model then you look at, say, the degradation of the key safety
functions that are required to be maintained in a shutdown condition.
DR. POWERS: Many of the licensees have a thing they call
ORAM.
MR. WONG: Yes. We are aware of that.
DR. POWERS: ORAM provides an output, a lot of output, but
among the outputs it provides you is a chart with various colors on it.
MR. WONG: Yes.
DR. POWERS: And if those colors are all green, that's good,
but it also provides colors that are orange and red. One of the things
that perplexes me when I try to go through this logic is suppose that I
have a situation where I have three oranges and the rest are green
versus the situation where I have one red and the others for argument's
sake are green. Which one is the more risk-significant?
MR. WONG: I think this process is still being looked on and
the reactor oversight process is coming up with, you know, like how
many, say, whites is considered as a yellow and so on and so forth.
DR. APOSTOLAKIS: Wouldn't it be easier to have a PRA, for
heaven's sake?
DR. POWERS: I could actually like this, George. I think
you are too narrow in your thinking. You like these numbers and I like
these colors.
[Laughter.]
DR. POWERS: I can trade you three oranges for one red and a
white --
DR. WALLIS: Is there agreement on what is significant, what
you mean by significant?
MR. WONG: I said significant means putting them entirely in
the red zone.
DR. WALLIS: That's entirely in the red zone?
MR. WONG: Yes.
MR. CORREIA: Which is really addressed in the last bullet.
DR. APOSTOLAKIS: Now the last bullet really tells us what
is risk significant if you have a PRA.
MR. WONG: Yes.
DR. APOSTOLAKIS: So you have a similar bullet for the "or"
part, for the significantly affect the performance of safety functions?
Do you have something that gives guidance there?
MR. WONG: I don't think we have reached a --
DR. APOSTOLAKIS: Why not? Then why would I have an
incentive to do a PRA if it is free for all if I don't have a PRA but if
I have a PRA I have to have predetermined levels?
DR. BONACA: But I think on the slide you are saying that
for more than two SSCs you should have a PRA.
DR. APOSTOLAKIS: Which number is this?
DR. BONACA: Page 8.
MR. BARTON: We are jumping ahead of the presentation here.
DR. POWERS: I think we are going to have to move along,
because we have a "drop dead" time. We've got more presentations.
DR. WALLIS: Well, I had a very general question. How
predictable is all this, when they are going through all these motions,
but can you predict what you are going to find when you do maintenance?
I take my car to be maintained. They say it will take me an hour and
then they say oh, no, you have got to leave it for a week. We found
something. Is this the sort of thing that happens?
MR. CORREIA: It probably happens all the time.
DR. WALLIS: So you can't really assess --
MR. CORREIA: I think most licensees are very conservative
when they assume a certain maintenance duration. Most I think strive
for -- if it is a tech spec system -- they have to be LCO.
MR. BARTON: That's right.
MR. CORREIA: And have contingency actions in place to read
or restore or I have something else available. That is all part of the
planning process.
DR. WALLIS: To look at the uncertainty of it.
MR. CORREIA: Absolutely.
DR. POWERS: I think your concern is not really founded but
I think that just the way the safety culture that exists -- actually, it
is not the safety culture but the reward culture that exists among the
engineering staff that does this is such that penalties accrue
significantly to the individual for underestimating the amount of time
that it is going to take for the maintenance activities.
DR. WALLIS: You've got to be careful. You don't want to
give the guy an incentive to take the thing apart and say, oh, this
thing is worn, I ought to fix it, but my manager wants it buttoned up by
10 o'clock so I will button it up by 10 o'clock.
DR. POWERS: I don't think that is a problem.
DR. WALLIS: Not a problem?
DR. POWERS: No. I think the culture is such that it cures
that problem.
MR. WONG: Okay. Moving along, the next slide is laying out
the expectations when the licensees are doing maintenance. On a single
SSC what do they thing they should be doing and I put here for single
SSC -- for a simple SSC, by that I mean, say, a service water pump or a
valve in one train of a four-train system that's got no interactions
with other safety-related SSC trains or a drain pump or a drain valve.
We think the qualitative assessment by a licensed operator trained in
the maintenance rule implementation is sufficient.
The operator should be aware of the SSCs' risk significance.
They should also be aware of potential impacts of external conditions
such as maintenance in the switch yard or inclement weather that may
increase the potential upset or some great instability. Those are
examples of --
DR. APOSTOLAKIS: Now for power operation you still allow
them not to have a PRA? Somebody can come in there and say we are
implementing this without the PRA?
MR. WONG: Yes.
DR. APOSTOLAKIS: Even though the IPEs exist?
MR. WONG: Yes.
DR. APOSTOLAKIS: So how would I do then all this if I don't
have a PRA? How could I re-evaluate the risk impact due to emergent
failures if I don't have a PRA?
DR. POWERS: By qualitative assessment by a licensed
operator trained in maintenance rule implementation.
MR. WONG: Through their experience and their knowledge.
MR. CORREIA: I hope it would go back to whether or not he's
maintaining the safety function. Does he have enough capability to
protect the fuel, the reactor coolant system pressure boundary, water
level, electric power. I think that is fundamental to safe operations.
DR. POWERS: Right.
MR. CORREIA: What we are saying here is in this simple case
that is adequate.
DR. POWERS: And I think you have good reason to believe
that operators are pretty good at that for single SSCs. I think they do
it all the time.
MR. BARTON: Right, they do.
DR. APOSTOLAKIS: But they don't re-evaluate the risk. They
just make sure safety functions are available.
DR. POWERS: I think they literally say --
MR. BARTON: I think they re-evaluate risk.
DR. POWERS: I think they literally do. I think they sit
there and they say do I have the capabilities now or have I gotten into
a problem here? I think they actually do that.
DR. APOSTOLAKIS: That's not an evaluation of risk.
DR. SHACK: That's risk impact which he is talking about.
He doesn't have to come up with a number, but he has to know the impact.
DR. POWERS: Now I think when you go to the next one, which
has an unfortunately closeness to the first one -- I think when you have
got two SSCs then you are starting to get beyond the capabilities of
anyone to do the mental integrations.
DR. SEALE: Get an expert panel.
MR. WONG: In the case of the two SSCs, we think they could
use either qualitative or quantitative assessment or they could use what
we call pre-analyzed configurations. There are two-dimensional matrices
that have been developed. They will specify, say, if I take Component A
or SSC A and SSC B, they are prohibited for some reason. The same thing
is that the operator should be aware of the potential impacts of
external conditions, and also to evaluate the risk impact.
Now in the case of the -- if they are using a PRA assessment
tool and if that tool does not capture, say, the SSC that is taken out
of service, then typically the process we expect of them is to refer it
back to, say, a risk analyst or an expert panel to tell them whether
it's okay or not to perform that maintenance on, say, the two SSCs.
DR. APOSTOLAKIS: Now, given what Mr. Bradley has said
earlier today, that there will be in a year or so a hundred plants
certified, their PRAs will be certified by the industry itself, --
MR. WONG: Yes.
DR. APOSTOLAKIS: -- why bother to talk about cases where
they don't use the PRA? I mean I don't understand that. The PRA is
there now, and it will be certified. We will reconcile it with --
DR. SHACK: It may not be certified for this purpose.
MR. WONG: We are still in an evolving --
MR. BRADLEY: Can I make a comment?
MR. WONG: Yes, go ahead.
DR. APOSTOLAKIS: Of course you can make a comment.
MR. BRADLEY: Thank you. Biff Bradley, NEI. I think, in my
mind, the vast majority, if not all, licensees are using PRA or a PRA-
based tool to make these determinations for power operation. But given
that the scope of rule is being explicitly extended to shutdown, where
it is not modeled, you do have to maintain these -- well, revisions to
cover that area.
I am not personally aware of, you know, any -- the way the
maintenance rule is set up, there were some systems that were added by
expert panels that may not be reflected in the PRA. It is really not,
in my mind, I don't think -- I would hope the plants are going to be
making these determinations without the use of a PRA. But there may be
instances, and when you write rule language and regulatory guidance, you
have to be very careful because it has legal inspection and enforcement
implications, and you do have to cover those areas where the PRA may
just not cover the situation.
MR. WONG: Okay.
MR. CORREIA: The very short answer is we don't have a
requirement, but I personally believe we are getting close.
DR. APOSTOLAKIS: You don't have a requirement for?
MR. CORREIA: For a PRA.
MR. WONG: For a PRA.
MR. CORREIA: We certainly encourage its use. And every
maintenance rule baseline inspection that we did, every licensee had one
and used it to some varying degrees. So, again, --
DR. APOSTOLAKIS: But in real life, okay, you don't have to
have a requirement.
MR. CORREIA: Right.
MR. WONG: Right.
DR. APOSTOLAKIS: In real life, though, when you ask the
licensee, did you reevaluate the risk impact due to emergent failures,
or so on, or what is your awareness of potential impacts of external
conditions, the guy who has the PRA should have an easier life.
MR. BARTON: Yes.
MR. CORREIA: Yes. Absolutely.
MR. WONG: Yes.
DR. APOSTOLAKIS: Okay.
MR. CORREIA: And we would hope to hear those kinds of
answers.
DR. BONACA: You know, the value of that is even when you
don't have a quantitative assessment, the PRA allows you to see the
dependencies much better, the core systems, and that is really where is
the value.
DR. APOSTOLAKIS: I know the value.
DR. BONACA: Well, just the information.
MR. WONG: Okay. In the next slide, I think we have
discussed this a lot previously. It addresses the expectation on the
maintenance on single and two SSCs, on multiple SSCs and we expect
licensee to use a PRA or a comparable analysis, and here I put in --
DR. APOSTOLAKIS: Yeah, that is a misnomer there.
MR. WONG: Okay.
DR. APOSTOLAKIS: Drop the word "comparable."
MR. WONG: Comparable.
DR. APOSTOLAKIS: Some other --
MR. WONG: Some other.
DR. APOSTOLAKIS: Mickey Mouse thing.
[Laughter.]
DR. POWERS: I guess I just can't help but wonder, you know,
we are insisting that PRAs go through some -- have some standard of
acceptability or some certification. I wondered if the theory of
barrier analysis is something that I can go to, and if one had to do a
barrier analysis in some certified way?
MR. WONG: Okay. The reason we suggested or we put in a
barrier analysis, that if I don't have a PRA, if I have taken several
components out, I want to evaluate, say, what are the defense-in-depth
elements that may be degraded.
DR. APOSTOLAKIS: No, but the question is, if you have a
PRA, immediately the issue of quality comes to mind, and so forth.
MR. WONG: Yes.
DR. APOSTOLAKIS: If you do a barrier analysis, --
MR. WONG: Yes.
DR. APOSTOLAKIS: -- is there an ASME standard for barrier
analysis? Or by abandoning PRA, my life becomes so easy now I don't
have to convince you that I have a quality analysis, life is great? It
should be difficult. Difficulty must be conserved here.
MR. WONG: Okay.
DR. APOSTOLAKIS: As it conserved in all other walks of
life. So if I spend resources to make sure the quality of my PRA is
good, then the other guy who does a barrier analysis has to pay the
price someplace.
MR. CORREIA: And I think he would have significant
challenges from us.
DR. APOSTOLAKIS: Okay.
MR. WONG: Right.
MR. CORREIA: Because, in my mind, once you get beyond two
or more, it gets very complex and integrated, it is a difficult argument
to say I did it deterministically and be credible.
DR. BONACA: But you don't ask any documentation of these
decisions, it seems to me, later on and, therefore, --
MR. CORREIA: Well, it is the description of the licensee's
process. I would hope that --
DR. BONACA: Well, I am saying, therefore, either control
it.
MR. CORREIA: No, we don't control it, but we inspect it.
Yes.
MR. BARTON: It is a performance-based rule, Mario.
MR. CORREIA: Right.
DR. APOSTOLAKIS: No, it is not. It is not, for another
reason. But would you please drop the word "comparable"?
MR. WONG: Okay. We will do that.
DR. APOSTOLAKIS: Try to find another one. I gave you a
suggestion, but I am sure you will not take it.
DR. SEALE: Third rate, something like that.
DR. APOSTOLAKIS: Something comparable to that.
MR. WONG: Okay. The guidance that we have put in a draft,
we think it will apply to the methods that are commonly used to evaluate
the risk of maintenance configurations, and we just essentially listed
the various methods in a graded order. Typically, most of the -- a lot
of licensees are using two-dimensional matrix, and then there are also
licensees like South Texas in which they have developed a database of a
precalculated set of configurations. They means they have analyzed
three, or four, or five SSCs and analyzed the risk. And so if they
think they are going to be doing maintenance on those, they will, you
know, take action to avoid going into that situation.
MR. CORREIA: And it is something that is repeatable. They
can use it again and again and again.
MR. WONG: Over and over again.
DR. KRESS: Is the second sub-bullet a subset of the third?
MR. WONG: Yes. Yes. And then a lot of the utilities, as a
result of the maintenance rule, is evolving to implementing, you know,
risk monitors in place and that is the current state of affairs. Okay.
Okay. The guidance here also we wanted to make sure during
shutdown conditions, if there is a shutdown PRA model we expect the
licensee to use it. Otherwise -- because you use qualitative assessment
of the degradation of the key safety functions, and the key safety
functions that are needed, decay heat removal, reactor coolant inventory
control, electrical power availability, reactivity control, and
containment closure, primary and secondary.
DR. APOSTOLAKIS: So in this case, then, one cannot
calculate a delta CDP and delta LERF. Right?
MR. WONG: Yes.
DR. APOSTOLAKIS: In which case there are no performance
criteria anymore. It's really not -- I can't have any performance
goals -- not criteria, it's goal.
DR. KRESS: Goal, yes.
DR. POWERS: Well, you end up goals that say I'm not going
to be in red for longer than six hours.
DR. APOSTOLAKIS: Yes.
DR. POWERS: So you mean I'll have no more than three
oranges.
DR. APOSTOLAKIS: Yes. And five apples.
DR. POWERS: But, I mean, how you come to that conclusion is
beyond me.
DR. APOSTOLAKIS: That's a point, yes. So that nice bullet
you had earlier on slide 7, you know, that the configuration risk-
significant when delta CDP and delta LERF exceed a certain value, we
cannot do anymore here. In fact, that's a good point, that if you have
a PRA, you are really penalized.
DR. POWERS: Sure.
DR. APOSTOLAKIS: But that's not the way it should be.
DR. POWERS: Well, if you don't know, you get lucky.
DR. SEALE: Well, I guess I -- my view of --
DR. APOSTOLAKIS: Because what you don't know won't hurt
you.
DR. SEALE: I think a PRA will help because -- a PRA will
certainly help the licensee to do more online maintenance or maintain
more systems simultaneously. Without that I would really question
whether or not they really understood the impact on risk of safety, and
maybe they shouldn't do more than one or two at a time.
DR. BONACA: I am not concerned with the people having the
PRA, I'm concerned about those that don't have a PRA.
MR. BARTON: That don't have a shutdown PRA?
DR. APOSTOLAKIS: Well, appropriate to the configuration,
yes.
DR. POWERS: I guess what you ask is -- and I see lots and
lots if AIPs on events that occur during shutdown, and they come from a
variety of causes, but I often see things that have occurred because of
conflicts between two or three maintenance activities going on at the
same time.
Has there been an effort to look at that somewhat
systematically and say okay, these combinations of events have caused
problems in the past, and so when I get -- it's not just the number of
oranges I get on this ORAM screen that I've created, but if I get an
orange in decay heat removal and electrical power availability, that's
okay, but if I get one on decay heat removal and reactor coolant
inventory, orange in both of those, that's not okay?
MR. CORREIA: I can't imagine how it could be. And I hope
using this tool will tell licensees the situation that they could be in
and to avoid it to take other actions to change that orange to a green.
DR. POWERS: I've had licensees show me ORAM sheets that say
look, and we didn't get a single red, the worst we got into was four
oranges. Okay.
DR. MILLER: Four oranges don't make a red?
DR. POWERS: Apparently not.
MR. CORREIA: Personally I'm not that familiar with what
orange means, if it's a cautionary statement, be careful here, have
heightened awareness, have contingency plans in place versus if it were
green maybe not to be as concerned, and red, maybe you shouldn't do it
at all. I would hope that's the thinking behind this. It's a tool,
it's an aid.
MR. BARTON: I think it is. I think you've pretty well
described it.
MR. CORREIA: Right.
DR. SHACK: I think there's a certain amount of due
diligence that goes on here. I mean, the big risks come from the
inadvertent ones. You know, I don't think people really deliberately
get themselves --
MR. BARTON: No, it's inadvertent or it's a human error,
even though you've got this thing laid out and you've got the risk
assessed, somebody goes and screws up.
MR. CORREIA: Okay.
DR. SHACK: I mean, whether this limit should be, you know,
5 times 10 to the minus 6 or 6 times 10 to the minus 6, but you want to
make sure that it isn't 10 to the minus 3.
MR. CORREIA: And to be able to cope with reasonably
unexpected failures if they occur.
DR. APOSTOLAKIS: Do you really see your approving plant
configurations that are fairly complex without a PRA?
MR. WONG: I don't think so.
DR. APOSTOLAKIS: As a matter of practice, and that if the
thing becomes too complex and you don't have a PRA, you might say well,
gee, I don't really think you understand this.
MR. CORREIA: That would be my personal view.
DR. APOSTOLAKIS: Yes.
MR. CORREIA: Maybe they shouldn't be taking on --
DR. APOSTOLAKIS: Right.
MR. CORREIA: Such complex configurations --
DR. APOSTOLAKIS: Yes.
MR. CORREIA: Without --
DR. APOSTOLAKIS: That's a nicer way of putting it. Yes.
MR. CORREIA: A risk tool.
DR. APOSTOLAKIS: Yes.
MR. CORREIA: Right.
DR. APOSTOLAKIS: Yes.
DR. POWERS: I mean, the problem is that -- if I was sitting
up there I'd give you the same answer. I'd say oh, no, no, no, don't do
that. When I'm at the desk looking at something and the guy says over
and over again to me we've done this a hundred times, we've always done
it this way, it looks good to us, it poses no significant risk, it can
be very complicated, it can be a highly risk-significant thing in
reality, but no one's ever calculated it, so we don't know.
DR. APOSTOLAKIS: Yes.
DR. POWERS: And yes, you can do it a hundred times and not
have an event. That doesn't help us if it's a 10 to the minus 3 event.
MR. CORREIA: Right.
DR. APOSTOLAKIS: Yes. Yes.
DR. SEALE: Would you expect it any other way? If it's a 10
to the minus 3.
DR. POWERS: I mean, yes, that's right. I've got 100 of
them under my belt and didn't have a problem, I wouldn't expect to if
it's a -- but a 10 to the minus 3 event is a very significant event.
MR. CORREIA: Yes.
DR. APOSTOLAKIS: Sure.
DR. BONACA: See, but where I have a conceptual problem,
okay, in general is that for risk-informed application there is a very
clear understanding that you will allow risk-informed applications
commensurate to the capability of your PRA. And it seems to me that OSP
should allow online maintenance of commensurate complexity with your
capability to assess --
DR. SEALE: To assess the risk.
DR. BONACA: The concept should be that one. And I don't
see, however, any teeth here when you go beyond two or three, because
management still has the ability of managing that by moving activities
slightly off by a day or two, and that's done all the time, so that you
avoid the most complicated -- it's not a huge penalty, you just still
allow it to do, but you don't allow it to happen simultaneously. That's
the whole issue. Move it by a day and do the same activity on line and
reduce your risk. And I'm not sure that I understand, you know, where
the limit comes in that says you can't do that.
MR. BARTON: What limit are you looking for, Mario?
DR. BONACA: Well, I am trying to understand when you go
beyond two or three components or systems, okay, and you don't have a
PRA here, how -- you know, the point that George was bringing up.
DR. POWERS: Well, it may cure itself as we move to having
fewer and fewer people in the operational forces, can't do more and more
activities all simultaneously.
MR. CORREIA: Yes, there are limits, you're right, on
operating crews, maintenance crews, just having the equipment and the
time to do all this. You're right. It's true, it's an operational
limit.
MR. WONG: Okay. Now if the PRA model is used for the
assessment, this is the seven attributes that we think the PRA model
should have in order to assure some fidelity of the results, the PRA
model should reflect the as-built and as-operated plant. I think Mark
talked about this in the earlier presentation. They should reflect
actual plant performance, meaning that changes in say in the reliability
or the availability, if there are improved operational practices, they
should be reflected. And they should have an administrative process in
place to update the PRA at some frequent intervals.
And that it meets the industry standards as in the PRA
process, because when we go to the sites we don't have a lot of time to
go to every detail of the PRA that is being used. We are taking that at
face value.
DR. APOSTOLAKIS: But you will have time to review the
barrier analysis?
MR. WONG: We may not have the --
DR. APOSTOLAKIS: So your next slide will tell us what the
requirements of the barrier analysis are?
MR. WONG: Well, we --
MR. CORREIA: Maybe we'll choose a different analysis.
MR. WONG: We'll choose a different analysis.
DR. POWERS: You can do anything you want to in their
analysis, George. It is a much superior --
[Laughter.]
MR. WONG: Okay. The last slide is on managing risk. What
we expect is that the licensee --
DR. APOSTOLAKIS: Just out of curiosity, does anyone ever
come before the NRC and argue that yes, it would be nice to have done a
thermohydraulic analysis for this problem but we really haven't done it,
so we will use judgment. Is that something that is accepted?
DR. SEALE: It's called a bounding analysis. They do it all
the time.
MR. WONG: It's not yet.
DR. POWERS: Bob's right.
DR. APOSTOLAKIS: Judgmental bounding analysis.
DR. FONTANA: There's a couple of things on this viewgraph
that kind of jump out at you. The second big bullet says if the
proposed configuration exceeds risk acceptance guidelines, then it says
the management should be around before you enter the configuration.
That means you know you are going to enter a configuration that exceeds
risk acceptance guidelines, which just kind of looks funny.
MR. CORREIA: In reality, jumping ahead a little bit, there
may be cases where a licensee for a safety benefit needs to go into a
short duration, high risk situation to restore certain equipment to
reduce that risk, and what we are saying here --
MR. BARTON: And they have no other choice, so this needs
senior management's approval.
MR. CORREIA: Right.
MR. BARTON: Before you can enter that situation.
MR. CORREIA: If you are in a certain configuration,
something else fails in it, and it causes that risk to go way up, these
are the kinds of things we would expect the licensee to do.
DR. FONTANA: The second sub-bullet looks a little funny.
It says minimize duration of the maintenance activity by preplanning and
prestaging the necessary equipment.
It seems like on the basis of economics that is what they
would want to do all the time.
MR. WONG: Right.
MR. BARTON: And it says if you are going to get into a
situation that refers to the bullet above that, then you had better make
sure that you have got proper preplanning and prestaging necessary
equipment.
MR. WONG: These are prudent practices or actions that you
think the licensee should have if they have to perform the maintenance
activities involving a high risk configuration.
DR. BONACA: What is missing there again I think is the most
important, is shifting the activities -- that is what you really do.
MR. CORREIA: I guess that would fall into the third sub-
bullet generally, compensatory actions.
MR. WONG: Compensatory actions.
MR. CORREIA: Move things around, delay, cancel.
MR. WONG: Stagger, you know, testing in redundant trains,
yes.
MR. CORREIA: These are just we think good management
practices that we have seen that should be implemented to manage risk.
Industry has, and I am sure you will hear from Biff Bradley
soon, the general concern with all of this is the scope of the
assessment process. Again, we believe it should be done at the system
minimum train level, which is again a much-reduced scope than thousands
of components, but the decision to risk-inform this rule and any other
is still before the Commission and I have not yet heard what the
decision has been, so that remains to be seen.
It doesn't mean we are against it. We are going forward
with this rule as directed by the Commission. That may change next week
or next month. I don't know -- but these are all plans.
MR. BARTON: Thank you. Any questions?
Let's hear from the industry.
MR. CORREIA: Thank you very much.
MR. BARTON: Thank you. Do you have a question? Go ahead.
All right, I'm sorry. There is a question.
MR. CORREIA: We're back.
DR. APOSTOLAKIS: On page 9 of the proposed rule, I guess,
it says that the licensee's assessments of management process
considerations should include (a) the likelihood that the maintenance
activity will increase the frequency of an initiating event. The
probability of the activity will affect their ability to mitigate the
initiating event.
Is this a requirement? If it is then how can you do this
without a PRA? This says probability.
Maybe I am not reading it right.
MR. BARTON: Federal Register notice, page 9.
DR. SEALE: That is 9 at the top of the page.
DR. APOSTOLAKIS: Oh, you don't have it?
MR. CORREIA: Don't have it, I'm sorry.
DR. APOSTOLAKIS: Okay.
MR. BARTON: It has to do with performing assessments. That
is a response to an NEI comment.
DR. APOSTOLAKIS: See -- the bottom third of the page --
"The NRC considers" --
MR. BARTON: The lead-in is bottom of page 8.
DR. APOSTOLAKIS: So are the licensees supposed to do these
things and if so then that would seem to be a little inconsistent with
what you presented here, which allows them not to do PRAs.
MR. CORREIA: It is. These are, and I guess they have to go
back, if a licensee were to use a PRA these are the kinds of items --
DR. APOSTOLAKIS: Oh, there is a big condition in some of
those I hadn't seen.
MR. CORREIA: Right.
MR. BARTON: Yes.
MR. CORREIA: Considerations should include.
DR. WALLIS: Well, you spend a lot of time on assessing risk
and almost no time on managing it and I just feel that the amount of
risk which is actually incurred by the public is probably quite
sensitive to how it is managed and that just doing a lot of assessment
and meeting guidelines doesn't reduce the risk of maintenance as much as
perhaps the way it is planned and managed.
MR. BARTON: And that is the licensee's responsibility, to
manage it.
DR. WALLIS: Right, but it is interesting to me that you
spend almost no time on managing, which actually could have more
effect -- that's a significant effect on the actual risk to the public.
MR. SCOTT: The purpose of the rule is not to make the
licensees manage their plants. They are already doing that. The
purpose of the rule is to require the licensees to assess the risk.
That is the main purpose.
DR. WALLIS: I thought the purpose was to protect the public
safety.
MR. BARTON: By assessing and managing --
MR. CORREIA: -- risk. Identify and control, yes.
DR. WALLIS: But then how it is managed is going to be
important in that.
MR. CORREIA: This may sound like somewhat of a cop-out, but
it is a performance-based rule. We don't prescribe what a license
should do, only what results they should achieve. We leave that up to
the licensee. The rule is intended to give licensees that flexibility.
We could prescribe how to do an assessment, what it should
include, what management steps they would have to take.
MR. BARTON: In a deterministic rule.
MR. CORREIA: Yes, that's right, and what this does though
is it gives us a significant challenge in inspection space because
licensees do have this flexibility.
DR. WALLIS: No, I am just trying to take it to a bigger
view of things, and it is interesting to me --
MR. CORREIA: Agreed.
DR. WALLIS: -- and it is interesting to me that the purview
of your activities covers something and then something else is covered
somewhere else. What is the total sum for society? But anyway, I won't
press that.
MR. BARTON: I again thank you. Biff, you're on.
MR. CORREIA: Thank you.
MR. BRADLEY: Biff Bradley of NEI again.
I will try to be brief here and I want to show one slide
that you did get just handed but we'll take care of that.
Industry had three major concerns with the rule as proposed
originally and the first of those was that the original proposed rule
language basically required a judgment of risk significance and now that
has been changed to address the need for awareness and action, which we
think is the appropriate approach for the rule language, so that concern
has been addressed I think in the language that the Staff has proposed.
The second had to do with the NRC's policy that the
implementation guidance for a rule should be issued concurrent with its
promulgation as a proposed rule and that has sort of been met half-way
in that we now have a draft Regulatory Guide that would discuss how the
rule would be implemented. However, that is not going to get issued
until shortly before the SECY goes up for the final rule, so it still
puts us in a little bit of a difficult position of trying to structure
our comments on the rule, which is already a done deed and now we are
seeing the guidance for the first time.
The final area and the one I wanted to discuss at a little
more length had to do with the provision of the (a)(4) assessment to the
entire scope of the maintenance rule.
I want to preface this by saying that industry has agreed
with the concept of this rulemaking. We do, even though the "should" is
legally interpreted as a recommendation and not a requirement, every
plant has established a program to assess the risk impact of maintenance
activities. We recognize the importance of that process.
We understood, and I think the regulatory analysis for the
rule stated that it was to codify existing practice, and we have had a
lot of discussion with the industry, those involved in implementation of
these activities, as to whether they believe what they see in the rule
language does codify existing practice.
I think the one are where we see a significant delta has to
do with the proposed scope of the assessment.
As you know, the maintenance rule scope is unique in all the
regulations. It is both deterministic and has a series of additional
requirements for scoping that involve risk insights, and so it is
basically a deterministic plus risk insights, and there is for many
plants up to 85 percent of the total SSCs in the plant have been scoped
into the rule. It is a vast scope at the component level for many
plants, and this is a result of a five or so year implementation
inspection and enforcement process that preceded where we are today.
It actually involved some what we believe were changes in
interpretation with regard to the time the rule was initially
promulgated through the pilot inspections into where we are today where
all the plants have been through the baselines. I think the
expectations originally were that the scope would not be quite as large
as it has become.
Because of the very large scope there is concern that it is
not a practical approach to write a regulation that would apply the
configuration assessment to that entire scope. As you know, the
maintenance rule does have a risk ranking provision in the guidance,
NUMARC 93.01 and Reg Guide 1160, which endorses it, and there already
has been a categorization into two categories of what we call in the Reg
Guide high safety significant components and low safety significant
components.
Rich talked about the need to assess this at the system
train level and I guess I would offer that we believe that assessment
has already been made and that it has been reviewed, inspected, and we
know which components affect the function of the systems and trains and
which ones don't and those are the high safety significant and the low
safety significant components.
The tools we have in place right now in the industry to do
these assessments, particularly the quantitatively driven tools, the
risk monitors, the PRA based tools, the matrices typically are looking
at the high safety significant components or the scope of the PRA. They
are not looking at the entire scope of the maintenance rule.
We have work control processes in place that do look at all
maintenance activities and this really becomes a question as to what is
the proper scope of regulation? At what point is it appropriate for the
regulator to have requirements regarding these assessments? We believe
the proper point is for the HSSCs or the SSCs modelled in the PRA.
We have a concern that the rule language as proposed there
is a single paragraph that would cover everything from doing maintenance
on a very highly safety significant component down to something that has
literally no safety significance that has been scoped in because of some
of the provisions in the maintenance rule.
Our past experience with regulations, and the words of
regulations are very important, and they have to stand the test of time,
and we have seen this in some degree with 50.59 and also with 50.65, the
maintenance rule, where the expectation with regard to what the words of
the regulations say has evolved and changed over time and created very
large problems for the industry.
We really feel compelled to try in this case to avoid that
kind of situation arising again in the future.
Therefore we believe it is important that the rule language
itself would differentiate this HSSC and SSCs, LSSCs with regard to the
need for this assessment. There are a number of other reasons why this
is appropriate.
Reg Guide 177, which is the tech spec Reg Guide, implements
a configuration risk management program. This was explicitly
implemented because the "should" provision of (a)(3) did not require the
assessment and there was a concern that going into a risk-informed AOT
there should be a requirement, a hard requirement, to do a risk
assessment before you entered that, so Reg Guide 177 states that the
intent of the CRMP is to implement Section (a)(3) of the maintenance
rule, and there was a lot of discussion about the scope of that CRMP
with the Staff, the tech spec branch, and other branches and the final
content in that Reg Guide states that the scope of that CRMP is the
HSSCs as described in the maintenance rule or the scope -- and/or the
scope of the PRA.
We don't understand why there is a different scope being
proposed now for the maintenance rule revision, given that that
determination has already been made.
MR. BARTON: Well, maybe the Staff can answer that, because
this issue keeps cropping up and Staff thinks it is resolved by going to
a train level. Industry keeps saying it's not resolved, it's an extra
burden.
I thought the CRMP program was going to go out when the
maintenance rule, revised maintenance rule was issued, that licensees
would request that CRMPs be removed from tech spec, so I guess I am
confused as to where we really are on this issue.
MS. GILLES: This is Nanette Gilles from the Technical
Specifications Branch. In our branch we work with the industry in
development of the configuration risk management program for risk-
improved technical specifications.
I guess I'll just make a couple of comments as to why we
ended up where we did on the scope of the CRMP.
One, we realized that we were working in a voluntary program
for risk-informed tech spec improvements and so the industry would not
be compelled by force of a regulation and we wanted to encourage people
to come in with risk-informed tech spec improvements so we did work in
concert with the industry to reach the scope.
In addition, we were very conscientiously trying to
encourage the use of PRA in these assessments and because we were trying
to encourage the use of PRA we felt that the scope that we arrived at
was the appropriate scope for where we were at.
DR. POWERS: Let me ask you a question, Biff. When the
categorization between HSSCs and LSSCs was made, was that done
considering that one or more other systems could have been out for
maintenance, for other reasons not be available?
MR. BRADLEY: I don't think it generally was. However, the
expert panel determinations and the work control process and the tools
we have now do address that. I guess we talk about this as sort of a
needle in a haystack of some very few potential combinations of LSSCs
that may be risk-significant, and I guess the concern is that it seems
that writing an all-encompassing rule that will require this assessment
every time you do a maintenance activity on any SSC in the scope of the
rule seems an impractical approach to try to address that.
MR. BARTON: But can't you do some of these in advance once
and go look at the low level safety significant components and systems
and say these configurations lead you to the three or four that you are
worried about so stay out of them, and then you don't have to do it
again?
MR. BRADLEY: But when you have at the component level, you
know, over 20,000 of these, and it's really a question of if it's simply
an issue of how it affects safety function, I think we could do that.
If you are having to look at all the permutations of all possible
combinations of these maintenance activities, that cannot be done in
advance since --
MR. BARTON: Is it your interpretation if you take one valve
or one detector or something that is a low -- LSSC out of service for
maintenance you are going to have to do a complete assessment on it, one
of these 20,000?
MR. BRADLEY: Well, in combination with whatever else may be
out at that time, yes.
DR. APOSTOLAKIS: Well, I think you will probably have to do
the assessment at the train level.
MR. BARTON: That is what the Staff is saying.
DR. APOSTOLAKIS: The trains have components in series and
then you can easily infer from the train configurations what happens
when the components are down.
In fact, Mark Rubin told us this morning that some
configurations the ranking changes, right? Would you say that something
that may be risk insignificant under certain conditions may become risk
significant --
MR. RUBIN: Sure.
DR. APOSTOLAKIS: But you will catch those without doing the
combinations. If you start taking combinations of 20,000 components, I
mean, boy, that's going to blow up -- but of course then there is always
a solution of going to barrier analysis where you don't have to do any
of that.
[Laughter.]
MR. BARTON: Rich, do you have a comment?
MR. CORREIA: Yes. Commenting on Biff's comment, when
licensees followed the guidance in 9301 to risk rank SSCs it was done at
the system level. It was based on a static PRA. The issue here is
given the licensees' authority if you will to take out SSCs in
combinations that weren't analyzed, what happens to risk at that point?
That is our concern with the rule.
We do recognize that there is a population of low-risk
significant SSCs that as they do an assessment or already have
recognized through this other process won't have a big impact or any at
all, that in itself serves as the assessment and our Reg Guide addresses
that, this one-time assessment, once they have done it and recognized
it, they don't need to do it again.
I think both from a tech spec perspective and a plant
operational perspective, combinations of 25,000 components out of
service simultaneously is impossible.
DR. APOSTOLAKIS: True.
MR. CORREIA: So we are looking at a fairly, I think -- not
fairly, a very controlled environment where tech specs, just in order to
keep the plant operating you can only have so many different
combinations of SSCs out of service at one time.
MR. BRADLEY: Right, and you mentioned, Rich, the scope, you
know, that the PRA is static but our proposal is that the scope of the
PRA would be the scope of this assessment so I think that would address
that.
We are talking about SSCs that are not modelled and are not
reflected in the tools, and that is the concern.
MR. CORREIA: It's just the issue of what happens when you
now take combinations out of service simultaneously that the previous
analysis didn't cover.
MR. BRADLEY: Right.
DR. APOSTOLAKIS: I think the word "modelled" the way you
just used it, Biff, sends the wrong message. I mean -- and we discussed
this when we were reviewing the Regulatory Guide -- one of those.
MR. BRADLEY: Right.
DR. APOSTOLAKIS: GQA, where people were concerned that a
lot of the components are not modelled in the PRA, but there is a reason
why they are not modelled. They are not left out because they are
important.
If it is not in the PRA maybe the component does not
contribute to risk.
MR. BRADLEY: Yes.
DR. APOSTOLAKIS: So that is a starting point.
DR. SEALE: But that is a decision that may have been made
on the expectation that the PRA would be applied to full power
operation.
DR. APOSTOLAKIS: Well, for whatever purposes the PRA was
done.
DR. SEALE: Right, but now let's suppose you have --
DR. APOSTOLAKIS: But if you say they were not modelled and
put a period after that, I think you are sending the wrong message.
DR. SEALE: Yes, okay.
DR. APOSTOLAKIS: Now of course there are others that are
not in the PRA, like the passive components, because their reliability
is much higher and so on -- and then you really have to do something.
In fact, Westinghouse came up with a surrogate component idea, so don't
put a period after it -- they are not modelled.
MR. BRADLEY: That was just a comment.
The other point I would like to make, as SECY 98-300, and I
know the Commission is still -- well, I guess the votes may be in but
the SRM isn't out yet -- the recommendation of the Staff in that was
that the scope of the maintenance rule should be the first priority in
readdressing the regulated scope with regard with Part 50 reform, and
that the priority regulation identified in that SECY was the maintenance
rule.
If we establish this assessment provision on the entire
scope of the rule, and believe me, given the inspection history of this
rule, that will have major programmatic impacts on the plants and if we
subsequently change the scope of the rule in the near future, I would
like think to be truly risk-informed there is a disconnect there, and
that is why we originally proposed putting this rulemaking under that
other one.
But that's an additional concern we have with regard to the
scope issue.
So I guess that completes what I wanted to say, but we do
have a concern with whether this is codifying existing practice or
really establishing a fairly new level of regulation, and that is a
function of the scope to which it's applied, and we'll be interested in
looking at the regulatory analysis for the final rule to see how that's
been treated. And we remain hopeful that the Commission will determine
that this should live up to the original intent of being a risk-informed
performance-based rule, and this is the perfect place to start to risk-
inform the maintenance rule and all of Part 50.
MR. SCOTT: I have maybe a question of Biff.
Could you comment on the results of NRC inspection activity
of maintenance rule since the programmatic baseline inspections have
been completed?
You expressed that the industry has great concerns about
this sort of thing, and I just wondered what you see happening in the
field in the nine months since July 10 last year when the inspection --
the programmatic inspection --
MR. BRADLEY: I think there's by a significant improvement
in the inspection environment. However, we've got to remember that this
rule will live for years, just like 50.59 has lived for years, and which
we really are trying to learn the lesson here of making sure the rule is
correct and clearly captures the intent, and that interpretations won't
be changed at some future time. I would agree that the inspection
experience has improved over what we saw early on.
MR. BARTON: Thank you, Biff.
Any other questions or comments?
If not --
DR. BONACA: I just -- my one question was on the safety
significance, to some degree it's relative, in part depends on now this
possible complicated grouping of systems being taken out of service.
But I take back my comment. I understand where you're going.
MR. BARTON: Having heard no other comments, do you have a
comment?
DR. POWERS: I'm going to take it over from here.
MR. BARTON: Oh, thank you.
DR. APOSTOLAKIS: It was a coup.
MR. BARTON: Missed a coup.
DR. POWERS: We have a benefit. Commissioner Diaz has
joined us to hear this, to emphasize his interest in this particular
rule, which is indeed very significant, and I'd like to ask Commissioner
Diaz if he'd care to share some thoughts with us on this subject.
DR. SEALE: It's wired for sound.
COMMISSIONER DIAZ: Well, I kind of feel almost looking
around like the proverbial lamb brought into the lions' den.
DR. POWERS: I will comment that Commissioner Diaz did say
that we could treat him just like one of the colleagues, so you're in
big trouble, sir.
COMMISSIONER DIAZ: I didn't say that.
[Laughter.]
No, I just wanted to stop by because I'm very interested in
your deliberations, and sometimes we get a little separated and filtered
from it, and I just wanted to let you know that we're very interested in
what you're doing, that, you know, sometimes multiple inputs do
converge, although we are having a hard time doing that. I think we're
trying to get there, and at this time I was wondering whether you have
any comments that will remove the clouds from a Commissioner's mind on
the age of the maintenance rule, but I've been listening to it, and I
guess you're still deliberating.
If there's something that we should know, we should know it
soon, because we're still working on that process, and like very soon.
I just heard something that it's really -- it's very consistent with the
way that I've been trying to work in the Commission is that I believe
rules should be as complete and as clear as possible. That guidance is
indispensable and guidance is very good, but sometimes if the rule is
not as thorough and as complete and as clear as it should be, it might
tend to be changed later on, or it might be not interpreted properly.
So I do believe that we need to more and more make the rules
as clear and as self-contained as possible so that the direction to the
staff is thorough. And that's something that I don't think we can
longer afford to have rules where the guidance actually becomes the rule
de facto, and that's really the key point I wanted to make. But if you
have anything that I should hear before, you know, I go and do some
work, I'd be happy to hear, specifically on the maintenance rule.
DR. APOSTOLAKIS: How much did you hear?
COMMISSIONER DIAZ: I heard the last 20 minutes or so, so it
gave me a reasonable flavor, but I didn't get the rest of it, and
sometimes, like I say, there's a lapse time, and sometimes things are
properly filtered, and sometimes they're too filtered. And so --
DR. POWERS: I think there's no question that there are a
lot of issues came up in this rule, and based on our discussions to this
point, I think it's fair to say that the scope of the rule is an issue.
The Commission passed the original maintenance rule, yes, there was a
deliberate attempt to expand the scope, and the question, of course, is
have we gone too far.
There is a -- clearly an interest in the guidance here
focusing on risk-assessment tools, but our tools are limited. We like
to say let's go to the PRA, but not everybody has a PRA and not every
PRA is that good, and even the best of them don't cover everything. And
what do you do there? What is the guidance for this? And that same
question comes up that PRAs were intended for one function.
They were designed for a function, and that was to really
estimate what's the operating risk. Now you're asking this PRA to
estimate conditional risks, and they can do it in principle. Our
concerns are do they do it in principle -- do it in fact, as well as in
principle. Those are the kinds of things that went on I think before
you came in, and they're going to figure in the deliberations here. I
don't know, do other Members have things that they --
DR. APOSTOLAKIS: Well, yes. It seems to me -- I don't know
again whether you were here when this was discussed --
COMMISSIONER DIAZ: That's okay, George, you can stamp it.
DR. POWERS: He does that, and my writing takes a beating
here.
DR. APOSTOLAKIS: It seems to me that the moment people say
PRA, immediately the issue of quality and so on comes up, but when we
talk about other methods, they are not scrutinized to the same degree.
And that really bothers me.
COMMISSIONER DIAZ: You mean there are uncertainties in
other methods?
DR. APOSTOLAKIS: No.
[Laughter.]
DR. POWERS: Well, George, I think that's true in the
viewgraph, but I think --
DR. APOSTOLAKIS: The reality is not.
DR. POWERS: The reality of the matter is that when the
staff gets a submission based on other methods, I think that often those
other methods are simpler and do in fact get a fair amount of scrutiny.
I would think that --
DR. APOSTOLAKIS: Well, one would hope.
DR. POWERS: I mean, one of the reasons we have to go to
concepts like a certification or standards process is it's really
impractical for the staff to look at an entire PRA and come away and say
yes, that's very good. Whereas a barrier analysis, they're very famous
and what not, but they typically can be read in a few sheets of paper,
and I don't -- they do get excluded.
DR. APOSTOLAKIS: No, but ideally one would have to rely or
should rely less on a barrier analysis than on a PRA. Okay?
COMMISSIONER DIAZ: But in reality, you know, we are in a
phase now in which we have to use a combination of things.
DR. APOSTOLAKIS: True.
COMMISSIONER DIAZ: We cannot rely on any one thing. And I
think what I heard from both the industry and the staff, and I was
reading some of the staff slides, is that we realize that this, quote,
assessment, or even how you, you know, risk, you know, rank a system,
structure, or component, that there's more than one way of doing it, and
that people have been doing it.
Everybody has some type of configuration risk management.
Some are very sophisticated, some are simpler. But they all do it. And
they all do it, okay, and in doing it they compensate. If it has little
less PRA, then maybe the senior reactor operators look more at it, you
know, and work with maintenance. And so there is a combination of
things.
We have a very heterogeneous industry and a very
heterogeneous way of regulating them, and I think right now we are in a
phase in which we need to start prioritizing which tool serves for what
better. And I think that's what we're doing right now. But it still --
for several years it will be a combination of things, not one thing.
DR. APOSTOLAKIS: That was my point. I mean, what I was
trying to do, that I don't want people to get discouraged from using PRA
because of all these conditions that it has to be quality and so on, and
then you resort to another method, and then all these requirements
disappear.
COMMISSIONER DIAZ: No.
DR. APOSTOLAKIS: In real life probably they don't. I
agree.
DR. SEALE: George, when you put down a number, you
invite -- there's a bull's eye that's implicit with it when you put down
a number. There's something to question. So you're just asking for it
when you write down a number.
[Laughter.]
COMMISSIONER DIAZ: I just want to again repeat that we take
what is happening very serious. This is a very important deliberation,
and I know that you know the Commission is looking at it to make
something that is as good as we can do right now, and your report is
valuable, and we thank you for it.
DR. APOSTOLAKIS: Thank you.
DR. SEALE: Thank you a lot.
DR. POWERS: Thank you.
With that I'm going to recess for the lunch break, and we
should get back here promptly for our ethical training.
[Whereupon, at 12:16 p.m., the meeting was recessed, to
reconvene at 1:30 p.m., this same day.]. A F T E R N O O N S E S S I O N
[1:30 p.m.]
DR. POWERS: Let's come back into session. Our next topic
is to come back to the general discussion of our Subcommittee meeting
earlier this week, the proposed approach for revising the Commission's
Safety Goal Policy Statement. George Apostolakis and Tom Kress are the
Cognizant Members on this subject. Dr. Apostolakis is in the flesh here
before us, ready to go.
DR. APOSTOLAKIS: Okay.
DR. POWERS: Chomping at the bit. So I will let you
introduce our esteemed speakers.
DR. APOSTOLAKIS: Thank you. We had a Subcommittee meeting
yesterday where we discussed the staff's plans regarding the revision of
the Safety Goal Policy Statement and the whole Committee was here, so
there is no need to summarize it. But what we agreed --
DR. POWERS: The Chairman was not present for much of the
time.
DR. APOSTOLAKIS: Oh, you were not. Oh, okay. So what --
DR. POWERS: He was dealing with a far more important
subject called the reactor fuel.
DR. APOSTOLAKIS: Okay. What the staff proposed, and they
plan to propose to the Commission, is that they be given another year to
work on this, and the primary reason is that they would like to expand
the scope and develop a Safety Goal Policy Statement that would be
applicable to all the activities of the agency, not just reactors, and
that would have to be a combination of qualitative and maybe
quantitative goals for individual activities, or classes of activities,
it is not clear at this time.
So what we suggested was that perhaps they should come up
with a more specific timetable that would involve deliverables in less
than a year, because some of us felt that that would add credibility to
their request, and come back today, in fact, they offered to do that, to
come back today and tell us what their preliminary thoughts on that are,
what they can do in six months, or in nine months, or whatever. So that
is where we left it. We asked them not to repeat the presentation of
yesterday and, you know, I guess we can -- you can go over the
viewgraphs, Dana.
But the main idea is that they want to expand the scope and
really cover all the activities of the agency, including those of NMSS
in general statements regarding the policies of this agency with respect
to safety goals, I suppose.
So, Tom, Joe.
MR. BARRETT: And Rich.
DR. APOSTOLAKIS: And Rich.
MR. BARRETT: And the other guy.
DR. APOSTOLAKIS: And the other guy. Oh, you are the other
guy.
DR. POWERS: I guess, you know, as you find your places up
there, I understand pretty well, I think, why it is desirable to have
the grand, all-encompassing goal that covers all things for all men at
all times. I understand that there are challenges to do that. And I am
wondering, has there been -- if you can summarize the considerations
that say, yes, we should have one set of goals that cover everything, as
opposed to a reactor safety set of goals, and a repository set of goals
and a special nuclear material user set of goals. I mean why is that
irrational to do that? I mean maybe you are talking about six instead
of two, or something like that.
MR. KING: Well, one, we are not proposing -- maybe I ought
to, for the record, state our names. I am Tom King from the Office of
Research. With me at the table is Joe Murphy from Research, Rich
Barrett from NRR, and Seth Coplan from NMSS. We are not proposing one
set of goals that covers everything.
What we are proposing is there are certain goals that cut
across the agency, reactor/non-reactor things. Some of those
considerations are in the current reactor safety goal policy, some
aren't. What we are proposing is let's take those that cut across
everything and raise them to a higher level, and then under that, you
can have some reactor-specific things and non-reactor-specific things.
Not everything has to be the same when you get down into
some of the implementation and some of the details, because the
population at risk is different. The purpose of the activities is
different. So there would be some -- when you get down particularly
into the quantitative measures, some differences that should show up in
differences in goals and criteria.
MR. MURPHY: I see it almost as over-arching principles that
we then develop specific goals from. But by having a consistent set, we
can try to keep what we do in the various areas coherent with each
other, although not necessarily the same.
MR. KING: So, in effect, you know, what we are proposing is
this high level safety policy, as the first bullet says, under which
specific reactor and non-reactor elements could be included.
DR. POWERS: I guess I am really attracted to Joe's
language. Rather than saying high level safety policy, say high level
safety principles.
MR. KING: Okay.
DR. POWERS: And just -- it is because the baggage you carry
from the current safety policy, you know, leads to some specific goals,
whereas, principles, I can imagine principles being of the nature of we
don't want -- involuntary risks should be very small relative to other
risks in society. I mean that would be an over-arching principle that
would cut across all things. Maybe it is not one you are thinking of,
but it could be. Whereas, a goal tends to have some quantitative or
qualitative guideline to it that uses a language that is going to be
peculiar to a field, it seems to me. And I guess I have enough
interaction with our brothers in the ACNW to understand that their use
of words and our use of words are enough different that it causes
confusion, but I don't think they would argue with an over-arching
principle.
DR. WALLIS: Are you suggesting they should avoid
quantitative statements entirely?
DR. POWERS: No. No. What I am saying is that if I am
looking for something that cuts across the agency, I like the language
of high over-arching principles rather than over-arching safety policy,
because of the baggage that that safety policy takes along.
DR. WALLIS: Yeah, but suppose they start with your
principle that the risk should be comparable or less than some other
risk or something. Are they then restrained from putting numbers on
that risk?
DR. POWERS: No, what he is saying is that you would have --
I think what he said, correct me if I am wrong, you have these over-
arching principles -- I will use my language, or Joe's language, and
then within the reactor community, they are very likely to come out with
something that is very quantitative, because they are moving in
quantitative directions.
DR. WALLIS: So your thrust is exactly the opposite of the
one that I thought -- that I was taking, which was figure out what you
need to do in order to do risk-informed decision making and do it. That
is exactly the opposite of standing why back from everything and doing
something grand. That is actually getting a job done, and that is a
completely opposite idea.
DR. POWERS: I guess I don't think so. I think that the
problems that you frequently run into in trying to engineer a specific
task is the difficulty of tying it to a hierarchy of requirements, and
with the existing safety goals, you tie it to requirements that are
impractical to implement. Okay. So when you come down into the
development of a regulation or, worse yet, into a Regulatory Guide, you
haven't got a steady set of consistent sets of requirements coming from
the very top, you have got a disconnect, usually called CDF.
DR. KRESS: I see what you are saying he says is basically
equivalent. Because he says figure out what you need to do to risk-
inform the regulation. What you are saying is the right way to figure
it out.
DR. POWERS: I think that's right.
DR. WALLIS: Yeah, I think there is an agreement, but as
long as -- my concern was, and I think some other members of this
Committee, was that if you take too grand a view, you become so vague
that it is not useful, it can't be implemented, risk-informed
regulation, that there is a whole new job of work to be done afterwards.
DR. KRESS: Well, there would be, but the presumption is
that that is the right way to go. That you would do that extra work.
DR. APOSTOLAKIS: I think the very top level principles will
be useless in that way.
DR. KRESS: Oh, yeah. You will have to further -- you will
have to translate them further down.
DR. APOSTOLAKIS: Right. I mean until you reach some
numbers, you will not be able to do what --
DR. POWERS: I mean when we engineer any project, we begin
with top level, top tier requirements, that very seldom by themselves
would be of any use to machining or bending metal. And that you start
asking the question, okay, if I have to assure that involuntary risk is
small compared to other risks faced in society, your next question is,
what the hell do you mean by small, and what are the rest of the risks
in society? Then you start building up a pyramid of things here.
DR. APOSTOLAKIS: For example, the high-level principle
might say, in fact I believe it was said yesterday, that you want the
risks to be small with respect to -- compared to risks from comparable
activities. It would be interesting to see what the comparable
activities are when you go to NMSS.
DR. POWERS: Right.
DR. APOSTOLAKIS: But if you don't say that there, then they
have to do something that may be different. It leaves it open. So the
principles are important. There is no question about it.
MR. KING: Yes. We're not proposing to stop work on the
specific items in the reactor safety goal policy that we identified for
update, and we're not proposing NMSS stop work on implementing their
SECY paper, assuming the Commission agrees.
DR. APOSTOLAKIS: I think it's worth trying. It's worth
trying to do what you want to do, because if we don't try, then we may
be accused later that we never tried.
DR. BONACA: One of the things that I have the frequency
with is that for a long time, goals up here, whatever we say is very
high level, it's all PRA-based, and all the regulation here we lived
with is all deterministic. So if I understand it, you're trying to now
merge somewhat, go from the level up there down to translate some of
those high-level goals into more specific.
DR. APOSTOLAKIS: But not at this stage. At this stage they
are supplementing the high-level goals.
DR. BONACA: I understand that, but I'm saying are you
attempting also to make some kind of bridging down?
MR. KING: My view is that you could have a second tier to
this high-level document that would bridge down to reactors and
nonreactors and get down in to QHO, CDF, temporary increases in risk,
whatever makes sense to put in at that level for, you know,
quantitative-type goals.
DR. BONACA: So it's not yet at that.
DR. KRESS: What happens if you do it just as if you didn't
have a regulatory set of regulations out there? And then you figure out
how to make the regulations -- see if they're consistent with the
regulations you have after you end up getting to that point.
DR. BONACA: Yes, but you see why -- for a long time, I
mean, this decoupling that, you know, it just troubles me, you know --
DR. APOSTOLAKIS: But that's --
DR. BONACA: I understand. That's the way that the world --
DR. APOSTOLAKIS: Don't you think that's part of other
activities like risk-informing Part 50 and all that?
DR. BONACA: That may well be, but --
DR. APOSTOLAKIS: I think so.
DR. BONACA: But --
DR. APOSTOLAKIS: Because -- they are talking about very
high-level --
DR. BONACA: I understand that, but still you are working
here with all these regulations to make your plants -- and then the only
connection you have to that is to make a PRA to see whether or not you
meet those goals. Okay? But that PRA --
DR. APOSTOLAKIS: You want to work backwards.
DR. BONACA: Yes, I would like to --
DR. APOSTOLAKIS: That's what risk-informing --
MR. BARRETT: It's not necessary that these overarching
goals be risk-related, entirely risk-related. It's entirely possible
that some of these goals would be risk-related --
DR. APOSTOLAKIS: Of course, if they're rational.
MR. BARRETT: Others will be rational but not risk-related.
DR. APOSTOLAKIS: Have a significant element.
DR. POWERS: I don't know. They could be based on barrier
analysis it seems to me.
DR. APOSTOLAKIS: You missed that discussion this morning.
Some of you did.
[Laughter.]
Joe Murphy is smiling. He knows about barrier analysis.
[Laughter.]
I think we've exhausted this subject. Do you agree, Graham?
I mean, clearly they are not doing what you thought they were doing.
DR. WALLIS: No, I think they should do both. I was just --
DR. APOSTOLAKIS: And they said they would.
DR. WALLIS: I was just concerned that they don't get lost
in the morass of --
DR. APOSTOLAKIS: Yes, but --
DR. WALLIS: Political-type goals and they get on with
something practical.
DR. APOSTOLAKIS: They have a timetable later, which it
probably will guarantee that this will not happen.
DR. WALLIS: Oh, they actually have some deliverables by a
certain date?
DR. APOSTOLAKIS: Yes.
DR. WALLIS: Good.
DR. APOSTOLAKIS: Yes.
MR. KING: Okay. We talked a little bit yesterday about why
are we doing this, and I want to rehash everything we said yesterday,
but I think there was a general thought that a lot of the things we had
on the slide were really facilitating implementation of risk-informed
regulation, they weren't separate items, and so we tried to restate a
little bit what the purpose or objectives or advantages of doing this
are.
I think, one, it would provide a framework under which
things like the goals in the strategic plan and the regulatory analysis
guidelines could be written, provide some consistency with those,
facilitate implementation of risk-informed regulation, particularly
consolidating scattered guidance, seeing if there's any gaps that need
to be filled in, providing a framework for consistency between reactor
and nonreactor activities. That doesn't mean they have to be the same,
but some of these overarching principles ought to guide both.
And if you do all of that, it will promote public
confidence.
DR. APOSTOLAKIS: In fact, speaking of public confidence --
well, you guys don't need to be convinced of that. The Chairman had
some comments on that, didn't she, recently, on public confidence? But
that is a given that we want to have it here.
MR. KING: Yes. That is one of the --
DR. APOSTOLAKIS: You don't need additional ammunition for
that.
MR. KING: Now, as we go through the self-assessment process
in the various offices, that is one of our goals, is to have -- do
things that promote public confidence.
DR. APOSTOLAKIS: Right.
MR. KING: And just one quick summary slide to refresh your
memory. The kinds of things that would be considered to be put in this
high level safety policy would be qualitative goals for public and
worker protection, possibly qualitative for goals for environmental
protection.
DR. POWERS: Why do you take on the task of worker
protection?
MR. KING: The agency has already taken it on. Worker
protection, we have got a Part 20 that deals with worker protection.
Maybe in the NMSS area, there may be other things also. But, you know,
it seems to me -- for example, in the reactor area, you have the ALARA
principle. Except where does ALARA show up? It shows up in an appendix
to Part 50. Should that be some higher level kind of principle that
applies across the board? Those are the kinds of things that I think
this --
DR. POWERS: I think you run into a problem doing this. I
will grant you that ALARA is in there. I will grant you that when I
look at the Part 50 regulations and the Part 20 regulations, that I see
a lot of things that relate to worker protection. I will grant for you
that I see a lot of the activities of residents enforcing good practices
of workers. But I think you have a hard time tracking that from your
founding legislation with those rules.
MR. KING: You don't think the Atomic Energy Act applies to
workers?
DR. POWERS: Well, I guess what I am asking is, are you
tracking the Atomic Energy Act through the work force?
MR. KING: It seems to me this is the kind of activity that
would face that question. We do regulate now for worker protection. I
guess I have always been under the impression the Atomic Energy Act
covers that. Assuming that is true, what should be our high level over-
arching principles for that? I mean that is where I am coming from. I
don't have an OGC person here to help me out on the legalities of that,
but --
MR. MURPHY: It would seem, just as a pragmatic matter, that
Part 20 would not exist in the current form if it wasn't clearly tied
back to the Atomic Energy Act. Somewhere along the line, someone would
have --
DR. KRESS: Well, it make sense for some agency, government
agency, to protect workers, and in this area, it might as well be the
NRC. It seems like that --
MR. KING: OSHA doesn't set radiation standards.
DR. KRESS: No. So it sounds like there shouldn't be
anything wrong with it.
MR. MURPHY: Now, in talking about worker protection, it
would be radiological protection, with the possible exception we
mentioned yesterday of the chemical hazards. But for us to get into --
and I am thinking in terms of UF-6 in particular, where the hazard is
the F-6 and not the U. But the way we get into that is if there is a
memorandum of understanding between NRC and OSHA giving us
responsibility in that area. It is really OSHA's responsibility, which
they then delegate to NRC. Correct me if I am saying this wrong, Seth.
So, clearly, there has to be a tieback to enabling
legislation. But, as you say, that may not be apparent to everyone
right now. One of the things we do in this is to try to make that more
apparent.
MR. COPLAN: Worker safety is a very important part of NMSS
activities. In fact, the principal cancer risk in most cases comes from
normal exposure to workers, and I am not positive of this, but I am
pretty sure that we do have a responsibility under the Atomic Energy Act
for that aspect of worker protection.
I know that we have a memorandum of understanding with OSHA
to deal with accident situations, protection of workers from accidents.
So there is a lot of stuff in place, at least with NMSS,
right now, and I guess my understanding of the reactor situation is that
Part 20 has to apply there as well. So that under at least normal
operation of reactors, again, you have worker protection as an issue.
DR. POWERS: There is an absolute fundamental principle, and
any time you engineer something, you cannot use low level criteria to
justify high level criteria.
MR. COPLAN: That's right.
DR. POWERS: Okay. You cannot come in and say Part 20
exists, ergo, I have to have a high level criterion to do that. So you
have to track that. I would suggest that in your items, to separate the
first one into qualitative goals for the public, qualitative goals for
the worker, because I think you have got a problem finding your
hierarchy here. It may be found, but I think it is a problem, and I
wouldn't, ipso facto, equate those.
MR. KING: No, I didn't -- by putting them in one sentence,
I didn't mean to imply that they would be the same goals. That's true.
DR. FONTANA: I have a question just for clarification. Who
looks out for X-ray machines?
DR. POWERS: States. Nearly always run by the states.
DR. FONTANA: That is states. Radiation sources are NRC,
right?
MR. KING: Radioactive material is NRC, but not an X-ray
machine.
DR. FONTANA: The source. That's right.
DR. SEALE: Well, it is mixed. Most states -- or many
states have a license -- or an agreement such that they enforce the
regulations with regard to sources. And some states have enhanced
jurisdiction to also monitor the operation of artificial accelerators,
X-ray machines and so on. So the states' purview has got a lateral to
it, just a little bit, in some cases.
MR. COPLAN: Radioactivity that is generated by either
source materials or byproduct materials are regulated by the Nuclear
Regulatory Commission. In some instances, we have an agreement with the
states to do that regulation, in effect, for us. Machine generated
radiation is not NRC's bailiwick unless it is a nuclear reactor. That
is the only instance. Otherwise, it is states, in some instances FDA,
but never NRC.
DR. KRESS: The radiation of foods, that is under NRC?
MR. MURPHY: Irradiators, yes.
MR. COPLAN: It depends how it is irradiated. If it is
byproduct material, yeah. If the source is byproduct material, it is
NRC. If it is an accelerator, it would be probably the states.
DR. APOSTOLAKIS: Coming back to this viewgraph, since you
want to list the issues, it seems to me that you will have a major
problem handling the different time scales that are involved in some of
these activities, even in a qualitative way. So I would put a sub-
bullet, the same way you have there under Approach, the three regions,
risk-informed, and so on, under the top bullet.
And I mean Dr. Powers mentioned the involuntary nature of
risk, I mean that is one dimension. I mean how you compare risks is not
obvious, I mean if you really think about it a little bit. And time
seems to me, the time scale will be important.
MR. KING: No, I agree. We just came up yesterday. I just
didn't have time to think about where to fit it in.
DR. APOSTOLAKIS: No, I understand. I am just offering a
suggestion.
MR. KING: Okay.
DR. APOSTOLAKIS: There may be other elements as well that
--
DR. KRESS: Yeah, well, under the fourth bullet, I think I
would have expected to see the words defense-in-depth, although that may
be part of the treatment of uncertainty.
DR. APOSTOLAKIS: The treatment of uncertainty.
DR. KRESS: That may be where you mean for it to be.
MR. KING: Yeah, I just didn't try and list --
DR. APOSTOLAKIS: If you can avoid the words defense-in-
depth at this high level, that would be great.
DR. KRESS: It is probably a good idea.
MR. KING: I am not sure you can.
DR. POWERS: I would think that --
MR. KING: That is an over-arching principle possibly.
DR. POWERS: I think that would appear at that level.
DR. APOSTOLAKIS: Not as an over-arching principle, I hope.
DR. POWERS: I would hope.
DR. APOSTOLAKIS: Oh.
DR. POWERS: Now, that you have gotten some consistent
advice from the Committee.
[Laughter.]
DR. FONTANA: Going back to the second bullet, is the intent
of that environmental protection from things like reactor accidents, or
is that an intent to modify or maybe supplant that great big long list
of allowable releases that I think are in Part 20? I think. I know 10
CFR has in it a whole list of allowable concentrations.
MR. KING: Yeah, that can be released. You know, levels
below that can be released. There is, you know, other things in terms
of decommissioning that are being worked on, dose levels. I mean
there's a lot of things that affect the environment that we work on.
DR. FONTANA: Would you think of maybe making those kind of
risk-informed in a way, or is that what you have in mind up there?
MR. KING: I am thinking about what should our overall
principle or philosophy be for setting those kinds of release levels,
whether it is from a repository, which has a long timeframe, or whether
it is from a decommissioned site, which has a short timeframe, or
whether it is from a reactor accident, which has an immediate timeframe.
I don't think we have any guiding principles as to how to deal with
those things.
We have standards, we have set them.
We are working on others for different things.
MR. MURPHY: I may be wrong, but my recollection, going back
many, many years, the last time I really looked at Part 20 in detail, is
that the standards that are set there for acceptable concentrations are
based on a rather consistent set of principles telling what the risk to
the public is, but I don't know whether those are clearly articulated in
a policy that makes it obvious to everybody that that is so.
That is the kind of thing I would expect to see here. I
think it has been articulated by people like the ICRP and NCRP. I am
not sure --
MR. KING: Yes, and those only cover gaseous and fluid,
liquid releases. There is nothing in the regulations that deals with
solid materials. We are working on that now but there's an area there's
a gap in the regulations and what should the principle be for setting
that.
DR. POWERS: On this slide you speak of qualitative goals,
the approach to achieving the goals, and then you have treatment of
uncertainties.
I can understand that there could be uncertainties in
connection with a qualitative goal, but it certainly appears that there
is something quantitative that has appeared somewhere here, without
actually saying something quantitative appears here.
MR. KING: Well, what I had in mind were things like using
defense-in-depth to try and deal with uncertainties.
DR. POWERS: A second order, application of defense-in-
depth.
DR. WALLIS: I would like to see defense-in-depth approved
to be the appropriate strategy, particularly with uncertainties, rather
than assumed to be.
DR. KRESS: That's quite a policy statement.
DR. WALLIS: If you can prove that from a policy statement
in some truly logical way, hopefully mathematical, that would be a great
contribution, so we would have to just assume this thing in a religious
sense, a belief rather than actually having it derive from something
more fundamental.
MR. KING: I don't know if we are going to have mathematical
derivations in here.
DR. WALLIS: Oh, I will look for something rigorous.
DR. APOSTOLAKIS: At this level, the way I read the slide,
we will have qualitative principles and the way i read that sub-bullet
there, treatment of uncertainties, is that you will draw attention to
the fact that all these things are highly uncertain and maybe offer some
principles again as to what one should do about the uncertainties.
In fact, just by raising the issue, you are making a
contribution.
DR. WALLIS: Oh, but you are going to come to reality after
this.
DR. APOSTOLAKIS: But then after that, when they come to
reality then of course they will have to be more rigorous --
DR. WALLIS: You've got to come up with some really hard,
useful criteria.
MR. KING: Start setting numbers like the QHOs, then you
have to start thinking about these mean values, do you set some
confidence value on that.
DR. APOSTOLAKIS: But at this stage, I mean --
DR. WALLIS: Don't get stuck too long in this stage.
DR. APOSTOLAKIS: No, they have a --
MR. KING: Let's talk about what we are proposing to do.
DR. APOSTOLAKIS: Can we have an extra copy of it?
MR. KING: The handout?
DR. APOSTOLAKIS: Yes, of the handout.
MR. KING: There is one on the table.
DR. APOSTOLAKIS: The Chairman doesn't have a copy. I may
be just as well -- with his views on defense-in-depth.
[Laughter.]
DR. SEALE: Keep that puppy in the dark.
DR. APOSTOLAKIS: Have we looked at Number 3 enough, do you
think? Shall we go on?
MR. KING: Yes, we have looked at Number 3 enough. Let's
talk about what we are proposing to do.
We owe the Commission a paper at the end of this month, and
what we would like to do is make that paper a recommendation to the
Commission that we take some more time and take a step back and develop
these overarching principles and give them in that paper some ideas as
to the topics that these overarching principles would address, the
issues that need to be dealt with in putting together this higher level
document, not to give them a draft set of principles but really just to
give them an idea as to what the scope and the concept is and get them
to say yes or no, and if they say yes, then what we would proceed on
is -- think about proceeding on is shown on Slide 4.
DR. POWERS: Now does Slide 3 the one that tries to tell me
what this high level document does?
MR. KING: Slide 3 is a condensation of about four slides we
showed yesterday that I just put in here. There's certainly going to be
more detail in a SECY paper than what's on Slide 3.
DR. POWERS: The problem I am having here is that when I
look at Slide 4 I say I am getting something called a high level policy,
and now I am having Graham's problem. Am I getting something that I can
use or am I getting something I can admire?
MR. KING: Hopefully both.
DR. POWERS: Well, I guess I am looking for something a
little more specific than that.
When I got the Commission's existing safety goals I got
something I could use. I mean there was something I could actually
interpret. Am I going to have something here or am I going to have
overarching principles?
MR. KING: At the end of April you are not going to have
either.
DR. POWERS: I understand, but by the time they come down --
MR. KING: By the time they come down to July of 2000 what I
would envision would be a document that has these overarching principles
and hopefully would have at least on the reactor side the details filled
in, QHOs, do we elevate CDF, do we put something in for temporary
increases in risk -- that kind of thing -- and for the NMSS side, I am
not sure what the timeframe would be, but ultimately --
DR. POWERS: It can be commensurate with the need of Yucca
Mountain, which means that you go on to 2040.
DR. APOSTOLAKIS: It is a different timescale.
[Laughter.]
DR. POWERS: Geologic timescale.
DR. APOSTOLAKIS: So the year 3000 -- now NMSS though does
have some activities now to make their activities risk-informed.
MR. COPLAN: Yes.
DR. APOSTOLAKIS: And you are doing this without the benefit
of a high level principle?
MR. COPLAN: That's right.
DR. APOSTOLAKIS: And so does that show us how useful the
high level principles are or what does it say?
MR. COPLAN: I think it shows you that they are useful
because one of the first things that we started to realize as we started
to take risk assessment more seriously across the office and started to
think about areas where we can implement it, that we did not have any
kind of a set of metrics or goals that are comparable to the reactor
safety goal, we don't have those types of principles, and then it
becomes something of a question of how much use you can actually get out
of the tools and applying the tools when you don't have some kind of
targets in mind, and so part of what we had come up with in the paper
that Tom mentioned is that we were going to need to do this -- what is
being described here at least within the NMSS universe of things.
DR. FONTANA: This, what I was going to ask, I think relates
to that.
This paper that develops the high level principles, will it
have somewhere in it support of some kind where you are thinking how you
go from these principles to application?
You have to have thought of it.
MR. COPLAN: Yes.
MR. KING: Yes, in the sense of how are things to be used.
DR. POWERS: I guess I don't, Mario.
DR. FONTANA: You can have a high level principle but high
level principles in theory could be stated in such a way there is not a
linkage between that high level and what you are actually doing down
here.
DR. POWERS: What he is telling me is I am going to have
this high level principle and then I am going to have under the reactor
side -- he's going to say, well, we'll have something like a QHO. Maybe
it's the same ones we have got now. I am willing to bet they are --
something that says, yes, CDF is a goodie to have --
DR. FONTANA: Linkage -- I think it's like for example at
some time in the past you developed a linkage between allowable LERF and
allowable site doses or QHOs. Somebody did those.
MR. KING: Yes.
DR. FONTANA: I think you came and did those combinations on
that.
MR. KING: Yes.
DR. FONTANA: Well, is the intent to have this linkage
eventually shown for all of these areas?
DR. APOSTOLAKIS: Yeah, but not at this time.
DR. FONTANA: Not right away.
MR. KING: We could conceivably put, say, the LERF number in
the policy level at the right location as a subsidiary objective to meet
the QHOs. Now what we put in the calculations that show how you went
from QHO to LERF, no, I wouldn't put that in.
DR. WALLIS: This linkage is not a trivial matter. I mean
there are different extremely. There's something like the Constitution
of the United States, which has some principles and overarching
principles but it requires an immense amount of interpretation in order
to be practiced, and the interpretation changes as society's values
change.
There is the other kind of principle, like the second law of
thermodynamic, which actually can be expressed in some rigorous form,
and used without a tremendous amount of interpretation as to what it
might mean, so you have to think very carefully about how to formulate
these overarching principles so that they are usable without -- with
minimum quibbling so there is some sort of law of minimum equivocation
and interpretation that you want to apply here.
DR. KRESS: I think their intention is not to stop at the
overarching principle but to make that interpretation themselves and get
to some sort of a lower level.
DR. WALLIS: Sure, but I am saying that you have got to be
careful. It's not a trivial matter.
DR. KRESS: It won't be misinterpreted, their intent,
because they are going to do it.
MR. MURPHY: I think we have an idea, dealing with what Dr.
Wallis was saying, for reactors. We have done enough work on there that
we have an idea as to how to develop these linkages and put them in, and
I think that can be fairly robust. We are going to have to think a lot
more on the materials end. We haven't done that thinking yet. We can't
describe it to you today, but clearly in developing the process we are
in an entirely different ball game and that Seth has already said, the
risk may come more from normal operation than it does from accident in
at least some of the devices that are considered. The worker may be
much more important than the member of the public. There's a lot of
considerations that have to go into that.
We have sort of a collection of those in our mind. I think
Seth has done a very good job of expressing that in the Commission paper
but we put it all together -- you know, I can't tell you we are there
yet.
But our hope would be to have the same sort of coherent
approach that I think we can get to without too much difficulty in the
reactor end.
DR. POWERS: I mean, it seems to me that the safety goal
that we have now for the reactor -- a useful thing. Don't have any
trouble applying those at all. Got a problem, real quickly, and that my
technology is not so good that I can use them routinely, quickly found a
surrogate, almost as quickly found out the surrogate was a little bit
more conservative than the safety goals. Said gee, still like my
surrogate, elevate it.
That's all we need from this exercise on the reactor side.
We can decorate it with some esthetics, but the fact is that at the
working level all we need is to say that CDF is indeed a goal, gee, it
might even be nice to have a cap on transient periods of risk, I could
use that, I mean, I could make use of it if it was given to me, but I'm
going to have to wait to get all that while you sort out this NMSS
problem.
MR. MURPHY: I don't think you have to wait under what we're
proposing.
MR. KING: No, if you look at the last bullet here, we're
not proposing to stop work on the things we identified on the reactor
side. I mean, those are still valid questions. They still ought to be
worked on.
DR. WALLIS: When all is said and done, the only thing that
matters is does it work, and it doesn't have to look pretty or sound
good as long as it works well. So that's going to be my criterion. I
mean, you may write the most wonderful constitution for the Agency, but
if it's difficult to use it, it's not as good as something else could
be.
MR. KING: Is it worth doing?
DR. WALLIS: Right.
MR. KING: What's going to improve or be more efficient or
effective if you do this? That's a valid question.
DR. WALLIS: Well, it gets back to the question we asked
which -- I know we asked today is why are you doing this and what's the
payoff if it's really intangible. And if you have to sell it to someone
who's skeptical, you may have to work on that.
DR. SEALE: The cosmetics of public acceptance still should
have some attention.
MR. KING: Yes. To me from the public confidence, public
acceptance transparency of how we do our business, this would be
valuable.
DR. WALLIS: I just wondered how you would present this if
you were presenting it to some Senators, for instance. Would it be
exactly the same presentation?
DR. MILLER: Well, the principles should be sufficiently
transparent that the Senators would be able to understand it.
MR. KING: I think it would make a good framework for a
presentation to somebody like a Congressman. This is what we're all
about, you know, in language they can understand. Maybe when we get
down to QHOs, they don't know what you're talking about, but you've got
to start at someplace they do.
Okay. Schedule. We thought a little bit more about what
should we do and how long would it take. It seemed to me if we get a
paper to the Commission the end of April, it's probably a month before
they get back to us, assuming they say go ahead, what we're proposing is
let's take a couple of months and get some people in a room and draft
something up.
DR. APOSTOLAKIS: Who are these people, Tom?
MR. KING: Joe.
[Laughter.]
DR. APOSTOLAKIS: Joe and Murphy.
Well, but you need -- an NMSS and --
MR. MURPHY: Definitely this table will be involved.
DR. WALLIS: Could we have Joe paired with some young
skeptical person who is unfamiliar with jargon? Isn't there a Joe, Jr.
or someone you can bring in.
DR. APOSTOLAKIS: There is no Joe, Jr.
MR. MURPHY: But I think the suggestion of a young,
skeptical person is a very good one.
DR. APOSTOLAKIS: How young can he be and know as much as
you know?
DR. KRESS: Young is --
DR. APOSTOLAKIS: You're going to give him stories about
1976, Joe, and the guy's going to feel so small.
DR. KRESS: Young is 50 years old.
DR. MILLER: Somebody who doesn't know anything about this
business, willing to --
DR. APOSTOLAKIS: That's what we need now, somebody who
doesn't know anything.
DR. MILLER: I think you take somebody who's like in the
Agency just a few years or less.
MR. MURPHY: There are people in the Agency who I think have
the kind of inquiring minds that you're talking about.
DR. APOSTOLAKIS: Or your senior advisers.
DR. MILLER: See, young people aren't tainted by all the
knowledge that you have.
MR. MURPHY: I have to admit, you know, young means somebody
younger than I am. I mean --
DR. POWERS: That's covering a significant portion of the
United States.
DR. KRESS: They just need to have an inquiring --
DR. APOSTOLAKIS: So you will not have contractors do this.
It will be done in house.
MR. KING: This is not a job for contractors. This is a job
for staff, legal people certainly need to be involved, and people from
the program offices.
DR. APOSTOLAKIS: So it will be a working group or you will
call on people as you see fit?
MR. MURPHY: I don't think we've thought it through enough.
MR. KING: I don't envision a dedicated group. I don't
think this is a full-time job for five or six people. I think one
person having the lead and having the right interactions with other key
people can do the job, and we're saying take a couple of months to come
up with a draft and a list of issues that we can then start presenting
to States, to this Committee, to others that --
DR. APOSTOLAKIS: So that happens before August.
MR. KING: Yes. Between -- I think in the months of June
and July this drafting would take place. I'm assuming we get a go-ahead
from the Commission the end of May.
DR. WALLIS: Well, I'm sure that Joe could actually draft
for this review by whoever's going to work with him something almost
immediately. It's not that far away.
MR. KING: Before we bring it to this committee, we want to
have some internal review and discussion.
DR. WALLIS: Oh, yes.
MR. MURPHY: I would hope that, you know, I agree with you,
I think for the initial draft is not a long-term event. If we get the
right inquiring people involved in this, the next draft might take a
little longer than I would hope, and that would be good. You know, I'd
prefer it that way. But I think within the time scale we're talking
about, there's no problem.
MR. KING: Then the next step would be -- I put down a
period of about six months where we'd have some meetings with outside
stakeholders, you know, like States, like industry folks, public
interest groups, maybe just have a general public workshop, this
Committee, ACNW. We haven't laid out the details of --
DR. APOSTOLAKIS: But you will be interacting with us
before, though, right? Before September. Or not?
MR. KING: I wouldn't envision us coming back here until
after this initial drafting is done. So maybe we come back in August or
September with something you can look at.
And then based upon that, put together a final draft for
Commission consideration.
DR. FONTANA: These workshops would have basically one cycle
and one set with each. It is not a case of having a workshop, getting
feedback and having another one with the same people, that is one cycle.
MR. KING: Yeah, one set. Maybe one with the states, one
public. Probably, you know, probably a couple of times with this
Committee, I don't know how many times with ACNW.
DR. APOSTOLAKIS: So, for reactors, it will not be just a
high level safety policy statement, it will be more than that. Is that
what you said earlier?
MR. KING: Say that again. For --
DR. APOSTOLAKIS: For reactors, you will go beyond a high
level policy statement.
MR. KING: Yeah, it will be dealing with the issues in the
SECY from last year.
DR. APOSTOLAKIS: But it doesn't say that there, does it?
MR. KING: Including recommended --
DR. APOSTOLAKIS: Oh, down there somewhere.
MR. KING: Yeah. And then the last slide is what we would
like from this Committee at this point in time. We would like your
feedback on is it worthwhile to do this.
DR. KRESS: Do you want a letter or do you just want --
MR. KING: I would like a letter, but if you don't want to
write a letter, you know, your verbal feedback is valuable, too.
You know, do we have any thoughts on --
DR. SEALE: Thoughts are organized if it is a letter.
MR. KING: That's true. And, you know, any thoughts you
have on the scope level of detail and the schedule and approach we have
put together for proceeding.
DR. APOSTOLAKIS: Well, is possible to have -- to go back to
the previous slide -- and do things sooner than July?
MR. KING: You mean do things with this Committee sooner
than July?
DR. APOSTOLAKIS: No, no, no. Instead of saying that you
will provide to the Commission recommendation and so on, July of 2000,
can you do that sooner than that?
MR. KING: It depends how these workshops go and meetings
go, what kind of comments we get. What kind of internal consensus we
get. And to go from, say, having the last workshop in March of 2000,
then put together a package, probably have to run the final package
through this Committee, probably run it through CRGR, get the
concurrences. That takes time. I mean, practically speaking, it is not
something that happens in a matter of weeks.
DR. APOSTOLAKIS: Why do the workshops have to be spread out
over a period of six months?
MR. KING: Well, it seems to me we are going to have
probably at least four get-togethers.
DR. APOSTOLAKIS: Why four?
MR. KING: One with the states, one with --
DR. APOSTOLAKIS: Separate?
MR. KING: One with the public, where that would include
industry and any public interest groups, anybody else. We are going to
come here once. We are going to come to ACNW once. Maybe we want to
come here twice.
DR. KRESS: What is your concern, George?
DR. APOSTOLAKIS: Well, --
DR. KRESS: It is not that big of a hurry. You don't want
to rush.
MR. BARTON: You want a good product here.
DR. KRESS: Yeah, you don't want to rush an artist. Let him
--
DR. APOSTOLAKIS: But this is on top of a year that has
already passed.
MR. BARTON: But not much work was done in this past year.
DR. FONTANA: Those are the kind of things that just take a
lot of time, these workshops, meetings, feedback, all that sort of
thing. That takes a lot longer than actually doing it.
DR. APOSTOLAKIS: I think it is a matter of perceptions,
that, you know, we are really making progress and taking it seriously.
Because you really want to get into the linkage with the high level
goals as soon as you can, and start doing something, you know, beyond
the high level principles as soon as you can.
DR. MILLER: A question on the first bullet. Does that mean
the principles, or that is beyond the principles?
MR. KING: No, the first bullet is these over-arching
principles.
DR. MILLER: It would seem to me that we could do that maybe
more quickly than August.
DR. POWERS: It is the most difficult job you can do.
DR. MILLER: I understand it is the most difficult job, but
I would like to see -- I think we can develop the principles for the
Reg. Guide like 1.174. Having involvement of this Committee in its
principles, I think was a critical factor.
DR. KRESS: I think we ought to leave the schedule up to
these guys.
MR. BARTON: Let them, they have got to do the work.
DR. KRESS: Yeah, they know what their workload is and what
they need to do.
MR. KING: Yeah, I don't think it is -- I mean it is not --
I don't envision it as a long document, but, you know, the fact that is
a long document, I think is going to make it tougher to write. The fact
that it is dealing with some pretty -- everything in it is going to be
pretty fundamental, that is going to make it tough to write.
DR. KRESS: These are pretty fundamental principles.
MR. MURPHY: I suspect there will be a lot of internal
debate over this.
DR. KRESS: Yeah, I will bet. Yes, sir.
MR. MURPHY: I suspect when we get something concrete down
on paper, we will not be able to satisfy this Committee in an hour.
DR. KRESS: I wouldn't be a bit surprised.
MR. KING: Let alone four or five office directors and the
head of OGC.
DR. POWERS: So the question comes up, immediately to mind,
gee, I have got a lot of things that, from a societal impact point of
view, have more impact that I could be doing than this. Why do I -- and
this is great, I have a nice, logical, consistent, aesthetically
pleasing hierarchy that covers everything, and that would be great.
There is no question that would be very useful and make me smile when I
thought about it. But, quite frankly, I can make progress without it.
There is an awful lot of progress than needs to be made.
We were moving into risk regulation, and you can't calculate
what may amount to two-thirds of the risk that exists at your plants.
You have got gillions of little things that you would like to change.
Clearly, one of the things that could have the biggest impact I can
think of is changing Appendix K over to a more risk-informed, more
realistic kind of analysis. Why not do those things, rather than to
engage in this relative luxury of debating over the fine points of the
Talmud here?
DR. WALLIS: Are you coming around to my point of view?
DR. POWERS: I have always been with your point of view, you
know that.
DR. KRESS: It doesn't seem like an either/or thing to me.
It is not like you do this or that.
MR. KING: I don't think this is resource-intensive in that
we are talking a lot of people and throwing them on this. I think it is
intellectually intensive. I think it is going to take some, you know,
careful consideration by some --
DR. SEALE: Wise people.
MR. KING: Senior people, wise people and senior people.
That, to me, is not going to detract from working on 50.46 and some of
these other things.
DR. SEALE: Well, if I may make a comment to that question,
it strikes me that yesterday one of the things we heard from you was
that, as you go into this endeavor, you are going to find yourself
moving further into the area of the things associated with reactor
activities.
Because as you've looked at the things, as you've applied
risk-informed methodology to other things like performance assessment
and so on, you found that there were -- that you had an incomplete set
of principles that were guiding you, and you had to go find out or
fabricate or dream up or something, those additional ideas in order to
flesh out how risk-informed decision making processes could be used in
doing those things. That was one of the things you said yesterday. It
strikes me it would be a shame to not take the steps to harvest and
document those insights as you go through that process, and that's
really what you're doing.
MR. KING: Some of the lessons learned --
DR. SEALE: Some of those lessons are being -- well, one of
the criteria for the lesson is to be able to put it into the context of
this kind of set of principles, and in fact one of the objectives then
would be to identify what other guiding principles are -- maybe not
overarching, but detailed principles you'd need in order to do, say, a
risk-informed Part 50.
MR. KING: Yes, I agree with that. I think also these
lessons learned now that NMSS is starting to head down this path, I
think these lessons learned are -- probably will have a bigger impact on
the way they proceed than --
DR. SEALE: Yes.
MR. KING: Than sort of our, you know, somewhat trial-and-
error approach at the beginning.
DR. SEALE: So it's the harvesting of these things rather
than allowing it to kind of get diffuse again before you go back and ask
yourself.
MR. BARRETT: You know, one of the principles we've tried to
apply at least recently is that when we talk about applying NRC
resources to any initiative, whether it's an existing or a new
initiative, we try to run it past four filters that we've been using,
and the four filters relate to maintaining safety, reducing unnecessary
regulatory burden, increasing the effectiveness and the efficiency of
staff processes, and enhancing public confidence. And I think that as
we do this activity, we ought to keep those four filters in mind.
Dr. Wallis keeps trying to bring us back to the question of
what is it about this effort that will be necessary to allow us to do
risk-informed regulation or allow us to go as far as we can reasonably
go. You know, that should be something that informs the way we actually
implement this. What you're seeing in front of you is a very much of a
broad outline of a program. It doesn't have much meat on it. Clearly
there is a connection to public confidence.
There are many voices out there that have in one way or
another said that the NRC should make the effort to define safety or
what's safe enough. So, you know, in deciding how to go forward with
this and what detailed steps we should take between now and say August
and how this should be steered, those are the four filters, and I think
those filters relate to a lot of what we've heard here the last couple
of days.
DR. APOSTOLAKIS: When did you receive the SRM last year
that the Commission -- in which the Commission asked you to look at the
safety goal policy statement?
MR. KING: We sent a paper up in May. We got an SRM back
June 30 of last year saying okay, go look at those issues.
DR. APOSTOLAKIS: Okay. So June 30. Now you're going back
up at the end of April. I think you're going to get a question what
have you done the last, you know, ten months, just came up with the idea
of having a high-level safety policy statement?
MR. KING: And we did put together some -- maybe we should
make an attachment to the April paper that talks about what we did on
those specific issues.
DR. APOSTOLAKIS: See, that's why I'm concerned about the
July 2000 deadline. You have to show progress. You can't come a year
later and say well, maybe we need a different kind of principle. It
took you ten months to figure that out?
DR. BONACA: Realistically, though, I think that it seems to
me all you can commit is the walking to the workshops. That's the whole
issue. I mean, there is something in that control right now up to the
workshops and the interactions with the industry, and then the schedule
is hard to control and to commit to, it seems to me from that point on.
Because you don't know how --
DR. APOSTOLAKIS: Yes, but, see, I'm putting myself now in
the shoes of a skeptic who says, you know, at some point we have to have
some progress here and do something, you know, high-level principles are
okay, and so on, but, you know, I sent you an SRM last June and you come
back ten months later and you tell me you have to do something bigger.
That's all you're telling me?
DR. KRESS: You sound like a boss I used to have.
DR. BONACA: The reason why I interjected was mostly because
there is a question here to ask: What should be the scope and level of
detail? That's what they're asking us to answer. And I have trouble in
answering that question because of this issue how far are we expecting
them to go before you, you know --
DR. KRESS: Don't think, George, about how long has passed
since the SRM. Our job right now is to look at these numbers and what
they have before them to do and say are these realistic. I mean, that's
past.
DR. APOSTOLAKIS: Well --
DR. KRESS: That shouldn't enter your thinking at all. The
question is are these reasonable or is something wrong with them.
DR. APOSTOLAKIS: It may enter the thinking of the people
who have to send the new SRM approving this.
MR. KING: But let's go back to your question.
DR. APOSTOLAKIS: Yes.
MR. KING: I think it's not -- you've got to realize that
these are the issues that were in the May SECY paper from last year.
The bottom two-thirds of those issues are issues when you look at them
are really things that are at a higher level than just the reactor area.
And part of working on these 11 issues was coming to the realization
that you can't just deal with some of these things in isolation, you
really ought to step back and deal with them agencywide.
DR. APOSTOLAKIS: Well --
MR. KING: The top four are, yes, they're reactor-specific
and we can talk about what we've done in those so far.
DR. APOSTOLAKIS: But maybe then I can push my negativism a
little bit and say why did it take you ten months to figure this out?
Why didn't you come back in October and say gee, we tried to work on the
bottom third and we realized we need a higher-level principle?
MR. KING: Well, I think the things that sort of pushed us
over the edge started with the congressional hearings in July of last
year.
DR. APOSTOLAKIS: So you were doing other things. Is that
what you're saying?
MR. MURPHY: The schedule for this has been delayed by the
Commission a couple of times because of the pressures of --
DR. APOSTOLAKIS: Ah. So why did you correct me then? I
said what have you been doing the last ten months. The answer is we
have not been working.
MR. KING: We slipped this four months because of the
followup to the congressional hearings.
DR. WALLIS: Your customers would seem to be the Commission
and the public, but it seems to me that down the road the real
customers, the real people who benefit from your work, are all those
people that NRC and the utilities are trying to do a good job of making
reactors safe, and obeying regulations and setting regulations, and if
you can set forth some principles and some logic for applying risk which
helps all those folk, then that's where I see the real payoff is. You
have to convince the Commission and the public --
DR. APOSTOLAKIS: Let me add my --
DR. WALLIS: But that's where the real payoff is.
DR. APOSTOLAKIS: But you said yesterday, Graham, that --
you quoted the Chairman that the train has left --
DR. WALLIS: Yes, and I said these guys are --
DR. APOSTOLAKIS: It's not clear -- and I suspect you're
going to have some skepticism from the Commission when they say they
want to have a risk-informed Part 50, risk-informed this, risk-informed
50.59, and so on, and in July of the year 2000, which means 14 months
from now, they're going to have general principles.
And some work on the reactor side -- isn't that sort of
discouraging? Wouldn't you like to have something sooner?
MR. KING: Don't forget, we have told the Commission to
risk-inform Part 50. It's a four to eight year effort too. I mean it's
not like you are going to have Part --
DR. APOSTOLAKIS: Not all Commissioners get excited by that,
right?
MR. BARTON: No, but some of them get upset by that.
MR. KING: We got five votes and I didn't see one vote sheet
that questioned the schedule.
DR. KRESS: If you're going to risk-inform Part 50 I
maintain you have to do this first or you are not going to do it right
and you are just worried about how fast it gets done and that's these
guys' job.
DR. APOSTOLAKIS: Okay.
DR. KRESS: But you have to do this first if you are going
to do Part 50 right.
DR. APOSTOLAKIS: We are entering another time here. Yes --
MR. KING: If you don't like the schedule --
DR. APOSTOLAKIS: Well, what I propose to do, and if you
don't have anything more important to do, please stay, I want to go
around the table here and get some advice. In other words, we are
entering now, with 10 minutes delay, that table over that says Safety
Goal Policy Statement. We have to discuss it and you have to give me
advice, what to put in the letter, because I think -- well, first of
all, we do agree we will write the letter?
DR. KRESS: Yes, let's write a letter.
DR. APOSTOLAKIS: We write the letter.
DR. KRESS: I think we agree on that.
DR. APOSTOLAKIS: And if you gentlemen stay, maybe you can
help us with the discussion. I think it will be about 20 minutes.
So shall we go around the table or you want to speak as you
are willing to speak? Already I got a written statement here.
[Laughter.]
DR. POWERS: I wrote your letter for you.
DR. APOSTOLAKIS: Bob, you want to start, or Bill?
DR. SEALE: Sure. I think Tom's point that this process of
a risk-informed Part 50 being sort of the cornerstone of where the
Commission wants to go in the long-run is very appropriate. The fact
that it takes eight years is lamentable maybe, but the fact also that
this is the first thing that ought to happen by way of the formal
building the framework for doing that kind of effort is also true.
I think you have to do it. I would like to see you be able
to do it sooner, but I think it is more important to do it right. I am
just glad you are willing to consider taking it on, because it's going
to be a big job.
I hope you can build language into this which gets rid of
this continual tug-of-war between deterministic and probabilistic
assessment, make the point that they are part of the overall process,
and let's grow up. That is really what it amounts to when you do this,
so I am all for you.
DR. APOSTOLAKIS: Graham?
DR. WALLIS: Well, I feel that you have sort of asked us,
you have said to us this is a good thing to do, trust us to do it, and I
think it is a good thing to do and I trust you to do it.
But eventually we have to clearly see how this helps the
Agency do a better job of regulation and how these principles really
will have an influence on better regulation, better benefits to the
public or something -- there's going to be some real payoffs -- and I
think you can't do one without the other. You can't just go out and
annunciate principles and hope that things will happen.
This is often a fault. Just having the right intentions is
okay. The actual mechanics are not so trivial and I do think you
cannot -- although the committee seems to like the top-down, you also
have to work bottom-up. You have to say here is the guy in the trenches
trying to regulate. How is what you are doing going to help him do a
better job.
DR. APOSTOLAKIS: So what is your advice to me regarding the
letter? What should I say? That is a high level concern -- another guy
down in the trenches.
DR. WALLIS: Condense the transcript of these meetings.
DR. APOSTOLAKIS: What?
DR. WALLIS: You know, I have said the same thing about 10
times here --
DR. APOSTOLAKIS: Yes, but the transcript will be available
in three days and I am the guy in the trenches now. I need guidance.
DR. WALLIS: I think I still stick to my original view, that
the reason this came up at all was because of the push to risk-informed
regulation and the statement that the train had left the station and we
are now on this track, and then there was a realization that, well, the
train has left the station but it doesn't have a track laid out.
DR. APOSTOLAKIS: It's on the road.
DR. WALLIS: It doesn't have a terminus to go to and it
doesn't have the hazards along the line surveyed and all that, and this
has to be worked out.
DR. APOSTOLAKIS: So this is --
DR. WALLIS: So I would say that if you have to make a
decision one way or the other, you have to have a sort of a guidance or
a beacon or something that tells you where to go, say does it help me to
do good risk-informed regulation.
DR. APOSTOLAKIS: So then the advice then that I get from
you will be advice to the Staff that this is very important to do, but
don't forget why you are doing it, that eventually you have to ask
yourself is this helping me on the road to risk-informed regulations.
Right?
DR. WALLIS: And not just that. I mean you don't just do
something out of the blue. You do it because you have already
identified things that you need to do in order to do risk-informed
regulation.
DR. APOSTOLAKIS: Yes.
DR. WALLIS: So maybe it requires -- they have probably done
it already -- but evaluating seriously what it is you would have to have
in place if you were to do this really good risk-informed regulation,
from the top down, that envisions the whole tree, not just the top, but
all the links down the way as well as you can.
DR. APOSTOLAKIS: Anything else, Graham?
DR. WALLIS: Well, I'll have another shot at the letter when
you write it.
DR. APOSTOLAKIS: Oh, you will have many shots, yes, but I
am trying to minimize the frequency of shots. This is one of my
cornerstones.
Dr. Kress?
DR. KRESS: I say if the train has already left the station
it can just stop and wait on us. I am highly enthusiastic about this.
I think it is long overdue. It is something that has been needed and it
is absolutely essential that they do this if they are going to
properly -- and I put the word properly -- risk-inform the regulations.
I am enthusiastic about their approach. It's the right way
to go about it. I had a little early concerns about the full extent of
the overarching but if they can handle it I think that is the thing to
do because we need to address the full NRC mission. It needs to be put
on a basis that is coherent, consistent, and that you can deal with and
derive -- the intent of this policy statement is to be able to derive a
set of coherent, consistent risk-informed regulations. That is the
objective.
It is apparent to me. I don't see how you can miss its
value. I don't see how you have to articulate what its value is. It's
just apparent and I do think you might want to think about early drawing
the full tree in a sense of conceptually drawing it so that you know
what parts you do have to work on and where they are going to fit in,
but that is, you know, that is just a conceptual way to go about it.
I think you got the right elements to look at in your things
that you have to consider. I think they are the right ones. I am
particularly interested in how you are going to come up with handling
uncertainties, how you are going to deal with things like means and
confidence levels and how you are going to deal with defense-in-depth in
that concept, but you guys know those are the issues and you know you
are going to work on them, so I am really enthusiastic about this.
DR. APOSTOLAKIS: And all three of you, I take it, are
satisfied with the schedule?
DR. KRESS: Oh, the schedule doesn't bother me. These guys
know how to set schedules.
DR. APOSTOLAKIS: No comment on the schedule or you think it
is reasonable?
DR. WALLIS: Well, I am naturally an impatient person.
DR. KRESS: So that's it.
DR. APOSTOLAKIS: Within the constraints of your
personalities, you are happy with it?
[Laughter.]
DR. APOSTOLAKIS: This is not -- is this supposed to be
recorded? We are discussing the letter now.
DR. POWERS: That's fine.
DR. KRESS: That's all right.
DR. APOSTOLAKIS: As long as these guys are -- because they
might say something.
MR. MARKLEY: Well, it also helps them to reconstruct the
messages that were derived.
DR. POWERS: But I do wish they would keep the snickering
down.
[Laughter.]
DR. APOSTOLAKIS: Anything else, Tom?
DR. KRESS: No.
DR. APOSTOLAKIS: Okay. Dr. Fontana?
DR. FONTANA: Well, I am fully supportive of the approach,
the people. They have got the right people working on it. The schedule
doesn't bother me.
DR. APOSTOLAKIS: The right people? The right person?
[Laughter.]
DR. FONTANA: Well, whatever young person they are going to
find to work on it -- and the only thing, and it's been said before, is
that these high level statements have to be done in such a way that they
are implementable, and I know you have given that a lot of thought, so I
am supportive of what you are doing.
DR. APOSTOLAKIS: Great.
DR. MILLER: I am going to draw a little analogy, as I had
earlier, with the principles that were set up for the Regulatory Guides
on risk-informed regulation.
I think about a year ago we did that, right?
DR. APOSTOLAKIS: We did what?
DR. MILLER: The principles that you drew up?
DR. APOSTOLAKIS: No, that is more than a year.
DR. MILLER: More than a year ago? We saw part of the
success today. By starting out, Dr. Kress said it right, by doing the
job right the first time even though we are later than we would like to
be, is the right way to go.
I realize setting up principles for this task will be far
more challenging than probably the risk-informed regulation, but I think
we saw today -- I am overwhelmed with the success we have had so quickly
in risk-informed regulation.
DR. APOSTOLAKIS: Because we did it right.
DR. MILLER: There is an old axiom in engineering, "If it's
worth doing, do it right the first time." I think this is the right way
to do it.
The only thing about schedule that I would like to see, I
think the overall schedule is fine, I would like to see I think a first-
round thought process on some of these principles might be done more
quickly than August and come back to this committee, not necessarily the
almighty advisors, but I think we did provide good input on the
principles. Come back and let us give you input some time.
MR. KING: You would like a progress report sometime between
now and August.
DR. MILLER: Sometime between now and August.
DR. APOSTOLAKIS: And this time you have to go to the ACNW
too, eh?
DR. MILLER: I'm sure they'll provide you good input too.
DR. APOSTOLAKIS: That'll teach you. No, that's fine. If
you -- I would support what Dr. Miller just said. I mean I am really
anxious to see the first set of principles but scheduling a subcommittee
meeting and I know you guys have to prepare for it anyway, even if we
say this is informal and all that --
DR. MILLER: We could just have a brainstorming session,
more or less.
DR. APOSTOLAKIS: But that is my point. I don't know
whether that makes any difference to them. They still have to prepare
and get some approvals I suppose.
MR. KING: It takes time.
DR. APOSTOLAKIS: It takes time to come before the ACRS.
DR. MILLER: Only one other comment -- I definitely support
Dr. Wallis's idea of getting a couple young guys in that aren't, as I
say, tainted by the baggage that you guys are carrying and it might give
you some -- open some different avenues or perspective.
DR. APOSTOLAKIS: This is not a subject for young guys, in
my opinion.
DR. MILLER: I think they would contribute.
DR. APOSTOLAKIS: Younger than Joe, yes.
[Laughter.]
DR. MILLER: That's easy.
DR. WALLIS: I would say half the age.
DR. APOSTOLAKIS: Half the age of Joe?
DR. WALLIS: Half the age and one percent of the experience.
DR. MILLER: I find that the university is just more
challenging when people come in with fresh ideas. It forces the older
guys to think differently.
DR. APOSTOLAKIS: Dr. Powers?
DR. POWERS: Well, at first I thought I was writing George's
letter for him. Obviously I am writing the additional comments.
[Laughter.]
DR. POWERS: I am going to try to get these older folks to
think differently. I would of course be delighted to see a completely
consistent, logically organized, high level safety policy that covers
all the regulatory activities of the NRC.
With respect to the regulation of nuclear reactors,
development of such a high level policy now is luxury. With respect to
the other regulatory activities, the NRC development of a high level
policy may be premature. Development of the high level policy will
necessarily involve the diversion of some of the more talented and
capable resources in the Agency.
An objection-free, consensus policy that treats all the
regulatory activities of the agency may be more difficult and more time-
consuming than is now anticipated. What is needed now is a modest
enhancement to the existing safety goals for nuclear power reactors to
recognize a practical reality, core damage frequency is a more useful
measure of safety than are the risk measures.
This should be easily accomplished if it is unencumbered by
the manufactured requirement for consistency with safety measures yet to
be defined for non-reactor regulatory activities.
I see more pressing needs for the resources of the agencies
that would be devoted to this effort. Development of tools and
techniques to carry out risk-informed regulation for nuclear power is a
more urgently needed activity now than an aesthetically pleasing policy
that treats reactors and all other agency activities. I am against it.
DR. SEALE: We gathered that.
DR. POWERS: No kidding.
DR. APOSTOLAKIS: Other than that, do you have any other
comments? Bill.
DR. SHACK: Well, I personally think that this is a luxury,
that, you know, there are more important things to be doing. It seems
to me, changes to be made simply to deal with getting a risk-informed
exemption in Part 50 is much more important to a practical
implementation of risk-informed regulation at this point. I think 1.174
is a good tool to work with.
DR. KRESS: When will this not be a luxury?
DR. POWERS: I can tell you exactly when it won't be a
luxury. It will be -- it won't be a luxury when NMSS has explored
enough into the applications of risk-informed regulation to hone its
ideas down to the point that it gets some conception of how it is going
to do this. I think that is easier to do within the repository than it
is within the user community. I think they got a real headache within
the user community, because I think they are going to react to risk-
informed regulation about the way they react to leprosy. Risk-informed
regulation within the user community is going to be an agency tool and
not a user tool. And they have some refinements in their thinking and
how they would do it.
Once they have had a chance to explore this, and I think
that is about a year, to explore it and get some ideas of what their
needs are, and to come up with some candidates for what they think
useful safety goals would be, and recognize that there is a risk
inconsistency between those and that got defined by the reactors, then
it will no longer be a luxury, because when they go to articulate their
equivalents of the QHOs and there is a safety inconsistency between the
two, then it will not be a luxury for the agency, because the agency
can't tolerate that.
But those guys over there are in the inception phase, and
they have not had the benefit of a protracted period of argument and
debate and exploration of possible alternatives. And they need to have
the opportunity to do that, because they have got a tougher nut to crack
than the reactor guys did, a much tougher nut to crack.
DR. KRESS: If the NMSS were not part of this exercise, then
would it not be a luxury? Is that the only thing that is making this a
luxury to you right now?
DR. POWERS: Right now what I see is that we are beginning
to pick the cherries off the risk-informed regulatory tree here, and we
have done a pretty good job. I mean I think you guys have done a
fantastic job. I just love the stuff that you are doing on risk-
informed inspections and risk-informed enforcements. I am stunned by
it. I am very impressed. And I sit here and I say, yeah, but you
haven't got the tools to follow through. You haven't got the tools to
follow through. You are going to have all kinds of headaches on this.
And I think you ought to sort those things out.
I think Bill brings up a couple of things where there are a
few more cherries to pluck off this blossom. I am not enthusiastic
about a wholesale conversion over to Part 50. I am very pleased with
your suggestion of kind of going slow and trying things on this.
DR. MILLER: They are developing a set of principles.
DR. POWERS: This hierarchy -- I see nothing wrong with the
existing safety goals except that we found out that there is a big
computation hurdle to go from Level I to Level III.
DR. SHACK: I mean we said that CDF should be a fundamental
goal and that part, I will stick with.
DR. POWERS: Stick with.
DR. SHACK: And once I do that, I don't think I have a
practical problem.
DR. KRESS: Well, you have to reconcile.
DR. SHACK: I have a conceptually inelegant problem.
DR. POWERS: Yes. Aesthetically unpleasing.
DR. KRESS: Well, you have to reconcile that they really
don't have a societal goal in there, and that is one of the issues they
are going to deal with. It really doesn't tell you anything about how
to deal with defense-in-depth and, in fact, it makes defense-in-depth a
safety goal policy, and you have got to deal with it some way.
It doesn't tell you anything about how to deal with the
uncertainties except that you consider the uncertainties. The Safety
Goal Policy Statement we now have is just inadequate, that is the
problem.
DR. APOSTOLAKIS: But, Tom, should the effort be then
focused on fixing the existing statement for reactors and putting all
these considerations there, without bothering about NMSS at this point?
DR. KRESS: Well, that is a debatable point. Now, that I
could -- you know, I could buy that.
DR. APOSTOLAKIS: The NMSS thing, first of all, I agree with
what Dana said about the office needing more time to adjust to this new
-- I mean it took the reactor guys 25 years, let me repeat that. Right?
The reactor safety study was in '74, '75 and now it is 1999, and we
started this in '97, perhaps '96. And in NMSS you haven't had the
benefit of that long history, except in their high level waste area.
The other problem I see with that is that there are some
real roadblocks. The time scale is not just something to think about, I
mean it is a real major problem here. On the one hand, you are talking
about systems that you have now and you know that you will have for the
next 20, 30, 40 years, something like that. On the other hand, you are
talking about thousands. Again, that is a high level --
DR. WALLIS: I always think that what they have to do is
they have to show a short-term payoff.
DR. APOSTOLAKIS: Well, I don't know. You are offering --
DR. WALLIS: Within a year, that if we do this along the
lines that we have indicated, this will be your reward.
DR. APOSTOLAKIS: But my argument is --
DR. WALLIS: Not say it is 10 years down the road someplace.
DR. APOSTOLAKIS: My argument is that developing the
qualitative high level principle that would apply to all agency
activities may be a problem that is damn near unsolvable, because the
comparability of different risks is something that people have been
investigating for the last 20 years, and I am not sure they came up with
a solution.
DR. BONACA: But, you know, we can argue about this forever.
Let them start.
DR. APOSTOLAKIS: No. But that is my point. If we feel
that we can argue forever, perhaps we can advise them to do those
wonderful things that we want to see in the QHO side, because we know
these can be done, and wait on unifying all the activities under general
principles, because then we may end up discussing it forever.
DR. BONACA: And that is fine by me. You know, maybe it is
true that we are focused more in on reactor regulation and my thinking
has been there, but from my perspective, you know, I still believe that
it is essential that for a structured and orderly transition to Part 50
-- risk-informed Part 50, you need to have -- at least I need to have in
my mind something of what you are proposing to do. And if you don't do
it, I will have to spend some time at home thinking about how this thing
all comes together, it will be complete.
DR. APOSTOLAKIS: What you need to have, Mario, is what Tom
mentioned for reactors.
DR. BONACA: Sure.
DR. APOSTOLAKIS: You have to have a statement regarding the
handling of uncertainty, a statement regarding --
DR. SEALE: Defense-in-depth.
DR. APOSTOLAKIS: Defense-in-depth and so on. And those
things I think we can handle in a year. But when we start broadening up
the scope, I am not as against it as Dana is, but I really have serious
doubts.
DR. KRESS: I was surprised at Dana because he once told me
when we were talking about how you write a severe accident computer
code, he said what you do is you put every phenomena, every equation,
every correlation you know in there, make it complete, and then just use
the parts of it you want to for your problem.
But, anyway, --
DR. POWERS: That is how I build computer codes. I
evidently agree with you.
DR. APOSTOLAKIS: But they didn't promise to put down all
the phenomena and the issues. They promised to do more than that, to
integrate.
DR. KRESS: I am just using an analogy.
DR. APOSTOLAKIS: Seth wants to say something. And I will
come back to Dr. Shack soon, by the way. Don't think that I forgot.
MR. COPLAN: I wanted to jump into this for a second,
because I think that to some degree the situation with materials is a
little bit different than the way it is being described here.
Certainly, for high level waste, we have been involved with risk
analysis for a long, long time. In the other areas, that has not been
the case. But I think that once we get into this, we are going to find
that the highest level kinds of principles for talking about what kind
of risk the agency is prepared to accept, general kinds of qualitative
statements from which quantitative concepts can be derived, I think that
we are probably as prepared to address that in NMSS as from the reactor
side.
I think that Dr. Powers very correctly points out the NMSS
licensees are going to react to this very differently than reactor
licensees. They are going to react to this very differently from one
activity to another to another. I mean, there are 40-plus different
activities that NMSS regulates. What I would suggest, though, is that I
think we're going to find to be the case, is that it's how we end up
implementing through regulation risk-informed concepts that would be
derived from the general principles.
In other words, for NMSS I don't think we can expect a
radiography licensee to do risk assessments. But we, the staff, can
look at Part 34 from the standpoint of risk assessments that we have
done and alter Part 34 consistent with the general principles that are
articulated. And that's a big step ahead for us.
DR. APOSTOLAKIS: Are you leaving out --
MR. COPLAN: I think we can do that. I think we're ready to
start doing that.
DR. APOSTOLAKIS: Are you leaving out the waste depositories
from this?
MR. COPLAN: Oh, no. No. No.
DR. APOSTOLAKIS: You know, risk -- to make statements about
safety and risk and goals --
DR. POWERS: George, let me interrupt you enough to ask how
much longer you think this should go, or should we break or what?
DR. APOSTOLAKIS: Maybe five, ten minutes.
DR. POWERS: Fine.
DR. APOSTOLAKIS: I think we should give a chance to the
Members to -- but this is important, though, because it defines, it
shapes the letter.
DR. POWERS: That's not the part I'm worried about.
DR. APOSTOLAKIS: Is it possible -- you see, I'm really
worried that these concerns about intergenerational equity and all that
stuff will lead us to where we are today a year from today. I'm really
concerned about that, that we will fail to come up with qualitative
statement of high-level principles that will cover all the possible
activities. Because risk is multidimensinal, and we are used to working
with certain dimensions in the reactor area, and you guys in the high-
level-waste area work with different dimensions, and now you want to
find out what the dimensions are in the other activities. But the
dimensions are not the same.
DR. WALLIS: Would that slow them down? It seems to me that
they can move much faster in the reactor area, and they should.
DR. APOSTOLAKIS: But that's the thing.
DR. WALLIS: Will those other things slow them down in doing
that?
DR. APOSTOLAKIS: No, but the point is this --
DR. WALLIS: To take a broader view?
DR. APOSTOLAKIS: Should --
DR. WALLIS: To be aware of a broader view?
DR. APOSTOLAKIS: Well, but we can recommend in our letter
that the emphasis be placed on fixing the existing QHO statement for
reactors and in parallel think about the other thing. In fact, now the
more I think about it, I like Don's idea, maybe the other one should be
conditional, come back in two months, three months, and tell us what
your ideas are and whether you think -- you the staff think that you
will eventually get something useful out of this, trying to unify
everything.
I think Einstein himself could not come up with a unified
field theory, right? So let's see whether there is any hope, instead of
saying no, you have a year to do this, and then next July we say well,
gee, it didn't work.
Now let's come back to Dr. Shack. Do you have any other
thoughts to offer?
DR. SHACK: Well, I was just going to say, you know, I
really don't think that you and Tom are ever going to be able to
convince me that defense in depth is not a high-level principle, and I
don't think that they'll ever be able to reevaluate --
DR. APOSTOLAKIS: This has nothing to do with this.
DR. KRESS: You misheard me. I think defense in depth is a
high-level principle.
DR. APOSTOLAKIS: It's just -- it depends on whether you
call it principle or something that serves management of uncertainty.
Anything else?
DR. SHACK: Well, my point is that defense in depth is a
high-level principle and CDF is a fundamental goal. I have what I need
to get on with the job.
DR. APOSTOLAKIS: Okay.
DR. KRESS: You think CDF, LERF, and defense in depth is all
the goals you need?
DR. SHACK: For the foreseeable future.
DR. APOSTOLAKIS: For the reactors he will be happy. Right
now he doesn't care about the other --
DR. KRESS: You don't care about Mario's worry about land
interdiction? You don't care about my worry about societal --
DR. APOSTOLAKIS: Societal risk?
DR. KRESS: Risk?
DR. SHACK: If I don't melt the core, I don't worry about
land interdiction, I don't worry about societal risk.
DR. APOSTOLAKIS: But he worries about defense in depth,
balance of prevention and mitigation.
He doesn't want to melt the core, but on the other hand,
defense in depth --
DR. SHACK: Defense in depth is going to be a high-level
principle.
DR. APOSTOLAKIS: Okay. And we shall stay there.
Dr. Uhrig.
DR. UHRIG: I think we need to move ahead with what's
proposed here.
DR. APOSTOLAKIS: Proposed by whom, Bob? By the staff.
DR. UHRIG: The staff. It may have taken us 20 years to get
here at the reactor business, but it's not going to take 20 years for
NMSS to catch up. Within the time frame that Part 50 gets made risk-
informed, they will be caught up. And I think you need to move ahead.
If that part lags, so be it, but it won't lag forever. I don't worry
about the time schedule, whether it's off a couple of months one way or
the other. That's irrelevant to me.
MR. BARTON: Okay. I agree with what Bob just said. That
was my comment. And also what Tom Kress said earlier.
DR. APOSTOLAKIS: You agree with Kress too?
MR. BARTON: Oh, yes.
DR. APOSTOLAKIS: But you can't agree with both.
MR. BARTON: Sure, I can.
DR. APOSTOLAKIS: Well, Dr. Bonaca, do you agree with
everybody?
DR. BONACA: Well, you heard me yesterday, and today again.
I totally agree on this effort, and it may very well be shown that you
cannot easily have an overarching goal for it, and you may decide months
from now that you're not going to do that, but without some minimum
exercise I think I cannot provide an answer, so is it worthwhile, I
think it is, and as I said, it is essential to a good transition to Part
50. They asked us some question about scope and level of detail, and
you may appreciate maybe an answer in a particular area.
My sense is that scope should be sufficient that as a
minimum we would see a path to future further expansion at a lower
level, for example, to include cornerstones or issues of that nature
that are important now in direct regulation. Again, you don't have to
address those now, but it seems to me that it should go far enough that
you can see how the path is going to move to more specifics.
It shouldn't be so high-level that you don't know how to
make the next step. I don't know if that helps, but that's my sense of
what -- as a minimum you would keep in your mind some idea of how you
would go there, and that would make it visible, I think.
And insofar as the third question you had, which was
schedule and approach, I would reverse it. To me the approach is
important, what you're doing now, but schedule, maybe it's less, and I
wouldn't offer any comment on the schedule.
DR. APOSTOLAKIS: Okay. Let me offer a compromise.
DR. BONACA: Okay.
DR. APOSTOLAKIS: Would the Committee be willing to see a
letter that says this is a very noble task, it's important, it needs to
be done, point number 1.
Point number 2, the Committee has serious reservations as to
whether this can be done in a year, given that NMSS, you know, is not up
to speed in some respects, given the real issues of intergenerational
equity and all that.
Third, the Committee then would like to see -- the Committee
would not like to see this potential problem impede progress in the
reactor area because of the reasons Dr. Kress mentioned. So the
Committee recommends that the work start in parallel, updating the QHO
statement for reactors, bringing up these issues that we have mentioned
in other letters, and at the same time start this noble effort, but then
have a progress check two, three months, whatever the staff feels is
appropriate, where they will tell us whether they feel that this effort
will lead to something useful.
Then if they come back and say yes, we already have a first
cut at the principle, you know, look at it, then we say go ahead. Or if
they say well, gee, you know, it doesn't really look like it's going to
work, then we drop that part, but we have not been penalized, we keep --
we have started and we keep working on the QHOs, bringing CDF up and
doing the things that, you know, really will make a difference in the
reactor area.
DR. WALLIS: Well, I wouldn't use your second paragraph
there saying you have serious reservations about whether they can do
something. You don't set people off to do a job starting off by saying
well, we've got serious reservations.
DR. APOSTOLAKIS: No, but you have to explain why you are
making the distinction. I mean, I'm not going to say I have
reservations about Joe.
DR. WALLIS: We should show some faith and hope and realism,
but we should --
DR. APOSTOLAKIS: Maybe state some issues?
DR. WALLIS: I think that they may surprise you. They may
come up with something damn good in six months.
DR. APOSTOLAKIS: That's why I'm giving them three months,
to come back and say yes, there is hope. And it's not only me, by the
way. I mean, we have two gentlemen of the jury here that need much more
convincing than I do, but in other words I'm not saying drop it right
now, as some of my colleagues are suggesting. I'm saying it's so
worthwhile that even though I have serious reservations, and the letter
of course will use the right words, I'm willing to give you three
months, four months.
DR. WALLIS: The fact that they've fiddled around for a
while is all the more reason why they should hurry up now and show
something -- show a return on this as soon as possible. Six months is
not unreasonable. You've got what, four months from now you're going to
give us a preliminary -- so that's great. I'm looking forward to it.
DR. BONACA: We are going to give a few months to come up
with something. At that point we can kill it if you --
DR. WALLIS: Yes, that's what I'm saying.
DR. APOSTOLAKIS: I don't want to have to kill it next --
no, it's not a matter of killing it, it's a matter of seeing whether we
are getting somewhere. And the staff will be the first one to tell us
yes, we think we are getting somewhere, or we think it's hopeless at
this time. But for the reactor side, it is not hopeless. We know what
we need, we know we can do it, it's a matter of time, and it will have a
tangible benefit.
DR. KRESS: I would be willing to sign off on such a letter,
but I would want to change the wording of the serious reservations.
DR. APOSTOLAKIS: I am sure that you will, Tom. I'm just
giving you the major points.
DR. FONTANA: Let's not forget that one of the real purposes
of this is to across all activities that humans are involved in, only
reactors and high-level waste and all are being imposed with safety
requirements that are way in excess of what the risks are. We put up
with bigger risks in a lot of other areas, and I think something like
this is important to try to equalize the risk process --
DR. APOSTOLAKIS: Okay. I suggest, because of time, that we
keep that discussion when we meet again. Before we leave, though, does
the staff have heartburn regarding a letter of this type? Would you
feel that this is something that you really don't want to see, or you
think that's one idea?
DR. BONACA: There was a question on their part on scope,
and I don't understand --
DR. APOSTOLAKIS: Well, I'm changing the scope now.
DR. BONACA: Only a couple of people -- I think we should
talk about, you know, what are we going to suggest insofar as --
DR. POWERS: I'm going to take over the meeting at this
point and declare a break for 15 minutes. We're recessed.
[Whereupon, at 3:16 p.m., the meeting was recessed, to
reconvene at 10:45 a.m., Friday, April 9, 1999.]

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