Meeting of the Joint Subcommittee on Reliability and Probabilistic Risk Assessment - December 16, 1999
227 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 *** 4 MEETING OF THE JOINT SUBCOMMITTEE ON 5 RELIABILITY AND PROBABILISTIC RISK ASSESSMENT 6 *** 7 8 9 U.S. Nuclear Regulatory Commission 10 11545 Rockville Pike 11 Room T-2B1 12 Rockville, Maryland 13 14 Thursday, December 16, 1999 15 16 The above-entitled proceedings commenced at 8:33 17 a.m., pursuant to notice, the Honorable Dr. George 18 Apostolakis, chairman, presiding. 19 20 MEMBERS PRESENT: 21 GEORGE APOSTOLAKIS, ACRS Chairman 22 MARIO V. BONACA, ACRS Member 23 ROBERT E. UHRIG, ACRS Member 24 ROBERT L. SEALE, ACRS Member 25 . 228 1 P R O C E E D I N G S 2 [8:33 a.m.] 3 DR. APOSTOLAKIS: The meeting will now come to 4 order. This is the second day of the meeting of the ACRS 5 Subcommittee on Reliability and Probabilistic Risk 6 Assessment. I am Dr. George Apostolakis, Chairman of the 7 Subcommittee. 8 ACRS members in attendance are Mario Bonaca, 9 Robert Seale, and Robert Uhrig. 10 The purpose of this meeting is to discuss NRC 11 Staff efforts in the area of Risk-Informed Technical 12 Specifications and associated industry initiatives proposed 13 by the Risk-Informed Technical Specification Task Force. 14 The Force is risk-informed? 15 SPEAKER: Risk-Informed Task Force. 16 The Subcommitte will gather information, analyze 17 relevant issues and facts and formulate proposed positions 18 and actions as appropriate for deliberation by the full 19 Committee. 20 Michael T. Markley is the Cognizant ACRS Staff 21 Engineer for this meeting. 22 The rules for participation in today's meeting 23 have been announced as part of the notice of this meeting 24 previously published in the Federal Register on December 25 1st, 1999. . 229 1 A transcript of the meeting is being kept and will 2 be made available as stated in the Federal Register notice. 3 It is requested that speakers first identify themselves and 4 speak with sufficient clarity and volume so that they can be 5 readily heard. 6 We have received a request from Mr. Jim Riccio of 7 Public Citizen to enter a written statement into the public 8 record related to risk-informed technical specifications. 9 Mr. Riccio may offer oral statements later in the meeting as 10 time permits. 11 Mr. Riccio's statement is as follows: 12 "Statement of James P. Riccio, Staff Attorney, 13 Public Citizen's Critical Mass Energy Project, before the 14 U.S. Nuclear Regulatory Commission's Advisory Committee on 15 Reactor Safeguards, December 16, 1999. 16 Good morning. My name is James Riccio. I am the 17 Staff Attorney for Public Citizen's Critical Mass Energy 18 Project. It is a pleasure to once again present our views 19 to the Advisory Committee on Reactor Safeguards. 20 You are here this morning to discuss yet another 21 deregulatory effort focused on reducing the technical 22 specifications that govern the operation of the 103 nuclear 23 reactors still splitting atoms across the United States. 24 While I'm sure that NEI and the NRC have been working 25 hand-in-glove in order to deregulate what remains of the . 230 1 technical specifications, we, the public, have been able to 2 find precious little information regarding this deregulatory 3 effort. 4 In fact, the only reference to technical 5 specifications I have been able to find in the deluge of 6 deregulatory paperwork being generated by the NRC actually 7 argues against a further diminution of technical 8 specifications. Public Citizen opposes any further 9 reduction in the technical specifications. 10 The NRC's new-and-improved technical 11 specifications were never intended to improve safety, only 12 the economic viability of the nuclear industry, by reducing 13 the limiting conditions of operation by 40 percent. After 14 NEI has successfully colluded with NRC to reduce LCOs by 40 15 percent. They now want to risk-base the remaining 60 16 percent. The argument that this will somehow improve safety 17 in the long-run is at best sophist. 18 NRC rightfully argues that the industry can expect 19 little in the way of burden reduction due to the previous 20 deregulation that occurred during the last technical 21 specification rewrite. However, since this effort is 22 apparently being driven by NEI, perhaps they will share 23 their deregulatory plans with the public. I am sure they 24 have already shared them with the NRC. 25 However, with less than a page of information . 231 1 buried in the middle of a 90-page SECY paper, the public is 2 left with little to comment on. 3 If the NRC wants to garner any public confidence, 4 it is going to have to provide opportunities for more 5 meaningful participation. Allowing the public to comment at 6 ACRS hearings is virtually meaningless if we do not have 7 prior access to the information." 8 This is the end of the statement. 9 We will now proceed with the meeting, and I call 10 upon Mr. Beckner and Mr. Barrett of NRR to begin. 11 MR. BECKNER: Thank you. My name is Bill Beckner. 12 I am the Chief of the Technical Specifications Branch in 13 NRR. I would like to thank the subcommittee for having us 14 this morning. I am going to give a very, very brief 15 introduction by way of just introducing who the players are 16 here today and also indicate what we would like to try to 17 accomplish this morning. 18 First of all, Rich Barrett is here, Chief of the 19 Probabilistic Safety Assessment Branch. He will be making a 20 brief opening remark. Also Biff Bradley from NEI is here. 21 This is a presentation that we have coordinated with NEI. 22 It was discussed and planned at the public meeting in 23 October. I will let Biff introduce some of the industry 24 players. 25 Our main presenters today will be my Section . 232 1 Chief, Bob Dennig and my staffer, Nan Gilles, here, and of 2 course Mark Reinhart, who is the Section Chief in the PSA 3 Branch and a former tech-spec'er, so he's been involved in 4 this effort for some period of time. 5 As far as what we would like to do today is I 6 understand it's been almost two years since we have talked 7 to you, and we have accomplished a lot. That has been 8 primarily in the area of risk-informed AOTs. That effort is 9 evolving now. We would like to tell you where we think we 10 are going, provide the ACRS with an opportunity to comment 11 early in the process. 12 We are asking for nothing specific at this point 13 in time other than to let you know what we are doing and to 14 give you a chance to provide any guidance or counsel that 15 you may have. 16 With that, let me go ahead and see if Rich wants 17 to make some comments. 18 MR. BARRETT: Thank you, Bill. I will be brief. 19 I just want to make a couple of points. 20 This is an initiative that the Staff is very 21 excited about. It is one that I think it's fair to 22 characterize as one that grew from the thinking that went on 23 within the NRC Staff, and I think basically where it comes 24 from is our thinking about what is it that controls risk. 25 We know that there are many different things that . 233 1 control risk -- reliability and availability certainly being 2 one of them. We think that controlling the configuration of 3 the plant is something very, very important to risk -- 4 controlling the availability of equipment one at a time but 5 also in combinations is very, very important to controlling 6 the risk of nuclear plant operation. 7 I think you are all aware that the new, revised 8 maintenance rule -- (a)(4) -- is an attempt to control the 9 risk associated with voluntary changes to the configuration 10 of the plant, and that change to the rule was made in the 11 context of the existence of the technical specifications, 12 and with the knowledge that there was always -- the 13 technical specifications were there as a backstop to any 14 changes that were made. 15 The effort that we are going into now is to try to 16 bring this risk-informed thinking into the technical 17 specifications today. What you are going to hear about 18 today is rather broad-ranging. You are going to hear about 19 seven specific initiatives which vary from some relatively 20 mundane proposals that are being looked at in the nearest 21 term to more sweeping proposals that would be phased in in 22 the somewhat longer term. 23 You will also be hearing about a vision that goes 24 more to the heart of the specifications and the philosophy 25 of the specifications themselves. . 234 1 The idea of all of this is to present the NRC and 2 the industry with a range of options that will provide all 3 of us with the flexibility to go in small steps in the 4 direction of risk-informing the technical specification or, 5 for those that are prepared to and want to, to make a giant 6 leap toward risk-informing the technical specifications. 7 But in sum, we believe this is an effort than can enhance of 8 NRC's pillars in terms of maintaining safety, improving 9 public confidence, improving the effectiveness and 10 efficiency of regulation, and reducing unnecessary 11 regulatory burden. I think you are going to find it a very 12 interesting presentation today. 13 I would like to introduce Biff Bradley, who would 14 like to make a brief -- 15 DR. APOSTOLAKIS: Of the seven initiatives that 16 you mentioned, a giant leap or something else is a giant 17 leap? 18 MR. BARRETT: Well, I think a plant that would 19 want to go all the way from (1) through (7) all at once, I 20 think you would call that a major leap, but the option is 21 there for plants to take smaller steps. 22 DR. APOSTOLAKIS: Okay. Thank you. 23 MR. BARRETT: Any other questions? 24 DR. SEALE: I have one after Biff gets through. 25 Go ahead. . 235 1 MR. BARRETT: Biff, would you care to talk? 2 MR. BRADLEY: Thanks, Rich. I would just like to 3 reiterate Rich's remarks and we will talk about this when we 4 get a chance to make our presentation. We do believe the 5 congruence with the (a)(4) rulemaking is a timely 6 opportunity to make some fundamental changes to risk-inform 7 tech specs. 8 What I would primarily like to do now is just 9 introduce the industry people who will be here along with 10 myself today to discuss this. We do have an active industry 11 group that involves all four Owners Groups, EPRI, NEI, and 12 it is a cohesive effort to try to achieve this on an 13 industry-wide basis. 14 Today we have Tom Hook from Southern California 15 Edison, which as most of you know, is one of the plants that 16 are more further along with a lot of PRA applications; 17 Sharon Mahler, from Nebraska Public Power District; and 18 Wayne Harrison from South Texas, another of the plants that 19 is heavily involved in a lot of the risk-informed 20 activities. Thanks. 21 DR. SEALE: Rich, in the statement that we heard 22 from Mr. Riccio, there seemed to be considerable pain 23 expressed over the unavailability of information as to what 24 was going forward and so on. Now you told us that your 25 intent at this point is as a progress report, to get input . 236 1 from us, and at some point down the road there will be a 2 more formal I guess presentation of what all of this implies 3 and so on. 4 Do you have any plans as a part of your progress 5 as you move forward to assure that the public as represented 6 by Mr. Riccio will have better or access to what your plans 7 are and be in a position to comment in an informed way? 8 I have a hard time being able to respond to 9 generalities in this area. 10 MR. BARRETT: Well, the answer to your question is 11 yes. I think that the NRC more and more has an emphasis on 12 making sure that we bring stakeholder input into the process 13 at every stage of the game, and I think to the extent that 14 there is a perception we haven't done that so much this far, 15 then I think that means that we should do even more in the 16 future, and so the answer is absolutely yes. There will be 17 multiple opportunities for the public and other stakeholders 18 to have input at various stages along the way and perhaps 19 Bob could give you more details about that. 20 MR. BECKNER: Yes -- Bill Beckner again. 21 We have had a number of internal concerns about 22 the standard tech specs in general about how the process to 23 changing the standard tech specs is really not a public 24 process in the sense that we have public meetings and we put 25 information in the public document room, but we do not . 237 1 solicit comment in general. 2 We have made a decision at this point in time that 3 following issuance of the next formal -- issuance of the 4 standard tech specs, which will be within a few months, that 5 changes such as this will go out specifically for public 6 comment and again in our meeting we had in October, which 7 was a public meeting at the end of a long series of public 8 meetings, I think I made the statement that we would be 9 putting these seven items out specifically for public 10 comment, so hopefully there is a chance as we go along with 11 meetings like this and other public meetings for people to 12 know what we are doing, and then there should be a chance 13 for formal public comment at this point in time. 14 MR. MARKLEY: Bill, is your December 14th letter 15 to NEI in the PDR? 16 MR. BECKNER: What is the subject here? 17 MR. MARKLEY: The meeting summary. 18 MR. BECKNER: I don't know if it is today. It 19 should be. It will be. 20 MR. MARKLEY: Okay, fine. Would you have any 21 objection to us putting this on the back of the transcript? 22 MR. BECKNER: Absolutely no objection. 23 MR. NEWBERRY: Scott Newberry, NRC Staff. We 24 weren't aware of Mr. Riccio's concerns and I plan to take an 25 action item based on this letter to contact Mr. Riccio . 238 1 personally to chat about this and inform him of the process 2 improvements and make sure he gets all the information that 3 we have available. 4 DR. SEALE: The Commission has also considerable 5 sensitivity towards this problem of garnering real public 6 comment and we have thought -- I think the subcommitte 7 chairmen will agree -- we have had the impression that these 8 meetings in fact provide some opportunity for public 9 awareness, not only of the written word but also of the 10 mindset that in many cases is behind the development of some 11 of these things. 12 So we would be interested and we are interested in 13 ways -- in what you are doing and we are interested in ways 14 that we can make our process as well more responsive to the 15 needs of the public. 16 MR. BARRETT: I guess I would like to add a word. 17 I think this is a case where a Staff initiative has met with 18 such enthusiasm and progress has been made so fast that I 19 think we would have to go back and look at the record of our 20 public workshops and other meetings to see if we have 21 touched all the bases in terms of stakeholders and make a 22 commitment to be certain we do so in the future. 23 I think as an example we would rarely have gotten 24 to this stage in any program without having had a full 25 discussion with the ACRS, so I think that is evidence to the . 239 1 fact that this is a program that has kind of tumbled forward 2 with a great deal of enthusiasm, but we are totally 3 committed to having input from all the stakeholders 4 including the public interest groups. 5 MR. DENNIG: Just one last word. With regard to 6 the subject matter of this particular meeting, the Staff did 7 meet with the Risk Informed Task Force on November 10th and 8 basically what we are going to talk about today is a reprise 9 of the material that was discussed at that meeting. That 10 meeting was a publicly-noticed public meeting that would 11 have afforded the opportunity to see all of the 12 decision-making and the input and the thoughts and the 13 process over a number of hours. 14 MR. REINHART: If I could just add one other 15 thing -- this is Mark Reinhart in the Risk Assessment 16 Branch -- one of the initiatives that our branch is trying 17 to do, get underway, even as we speak is to put a website, 18 publicly available, that has not just this initiative but 19 all of the risk initiatives that are going forward along 20 with the status and whatever information we can provide. 21 It is readily obvious a person comes onto the NRC 22 site they can get to the risk site and just see really what 23 is going on there and have some contacts, people they can 24 get in touch with. 25 DR. APOSTOLAKIS: Okay. By the way, is the Staff . 240 1 Requesting a letter? 2 MS. GILLES: No. 3 MR. BECKNER: This is Bill Beckner. We are 4 requesting any comments that you may want to provide. 5 MR. MARKLEY: We do have one logistic problem 6 here, and that is anyone who uses the speakers, you are 7 going to have to walk up to the table or go to the head of 8 the table with the microphone. 9 MR. BECKNER: This is Bill Beckner. We are not 10 specifically asking for endorsement, but we would welcome 11 any comments that you might have in whatever form you want 12 to give them to us. 13 DR. APOSTOLAKIS: Okay. 14 MR. BECKNER: If that is a letter, we would 15 appreciate it. 16 DR. APOSTOLAKIS: Thank you. 17 MS. GILLES: Good morning. I'm Nannette Gilles 18 from the Technical Specifications Branch in NRR. 19 This morning, I'm going to try to help remind you 20 where we were when we were last before this Subcommittee. 21 That was two years ago. 22 And then I'll tell you what progress we have made 23 since then in the area of risk-informed technical 24 specifications. 25 Our last briefing before the PRA Subcommittee was . 241 1 in February of 1998, and at that point in time, we were here 2 to present you with the final risk-informed Regulatory 3 Guides and Standard Review Plans. 4 And also, we were in the final stages of wrapping 5 up the risk-informed technical specification pilot 6 applications. 7 The risk-informed pilots were in their final 8 approval stages, and at that time, the pilots and the 9 guidance only addressed risk-informing technical 10 specification, allowed outage times, and surveillance test 11 intervals. 12 Also at that point in time, the industry 13 participation was limited. You really had one of the owners 14 groups as the main participant, and a few individual plants 15 applying for these risk-informed applications. 16 Since then, we have issued over 30 tech-spec 17 amendments to risk-informed allowed outage times, using the 18 guidance in Regulatory Guides 1.174 and 1.177, which is the 19 specific guide for technical specifications. 20 And we have 10 amendments currently under review, 21 so there has been wide industry interest in pursing these 22 risk-informed improvements. 23 In addition, the principles in the Reg Guides have 24 been applied to other types of amendments, some one-time 25 amendments, some amendments to actually remove some . 242 1 requirements from tech specs. 2 Most of the allowed outage time improvements that 3 have been made have included the implementation of what has 4 been called the Configuration Risk Management Program. 5 And that is a PRA-based assessment to look at the 6 risk of being in multiple equipment outages at the same 7 time. 8 And you'll hear this term, this risk assessment 9 term, and risk management program used throughout today's 10 presentations, and that is essentially the equivalent of 11 what the Maintenance Rule A-4 now requires. So those are 12 really synonymous programs at this point in time. 13 DR. APOSTOLAKIS: Excuse me, the CRMP, is that the 14 predictive tool, or is it something like the risk monitor, 15 which gives the current state of the plant? 16 MS. GILLES: It is to look at the configuration 17 you intend to enter. 18 DR. APOSTOLAKIS: Okay. 19 MS. GILLES: So predictive in that sense, and also 20 if you are performing some maintenance and some other event 21 occurs, another piece of equipment becomes inoperable, it is 22 used at that time also to look at the immediate 23 configuration you are in. 24 DR. APOSTOLAKIS: So somebody sitting in an office 25 and does calculations, and says, if I take these things out, . 243 1 then there are all these possibilities that are part of the 2 CRMP? 3 MS. GILLES: It varies from the range of an online 4 risk monitor to a matrix type of tool, to using the base PRA 5 to do calculations. 6 DR. APOSTOLAKIS: The online risk monitor would be 7 different, it seems to me. Because you know what is going 8 on at that instant. You're making projections. You have to 9 include the possibilities of human error and this and that. 10 If you are looking at the plant now, you know what 11 the status is, you know that people have not made any 12 mistakes, perhaps. 13 So they are two different things. So I was 14 wondering whether Configuration Risk Management Program, is 15 somebody going to talk about it later? 16 MR. REINHART: Maybe if I could just offer it, I 17 think the way the program was written originally, it was 18 written in Reg Guide 1.177, and it was not prescriptive. 19 There are some principles, and certain licensees, 20 as Nannette said, would implement it, very much real-time. 21 Others would pre-analyzing configurations they 22 intended to go into. So it wasn't prescriptive, per se. I 23 think as time goes on, and these applications get more and 24 more sophisticated, we'll see the licensees that have the 25 more flexible tool will be qualified for the more flexible . 244 1 applications. 2 DR. APOSTOLAKIS: But is anyone going to talk 3 about it in more detail later, or this is something that 4 we're supposed to know? 5 MR. DENNIG: I think perhaps as far as how this 6 may be implemented on an individual plant basis, maybe we 7 have some people here from industry that have experience and 8 know how they're doing it at their facility. That might 9 help if they can get into that. 10 DR. APOSTOLAKIS: Okay, thank you. 11 MS. GILLES: If there are no questions, I'll turn 12 it over to -- 13 DR. APOSTOLAKIS: Yes, there is a question. 14 MS. GILLES: Okay. 15 DR. APOSTOLAKIS: Can you explain the 19 and the 16 12 there? What, exactly do these mean? 17 MS. GILLES: That just means 12 plants, some of 18 them might be a unit plant, so that there were actually 19 19 units getting the change. 20 DR. APOSTOLAKIS: Oh, I see, okay. 21 MS. GILLES: Bob Dennig is now going to give 22 information about the current risk-informed tech specs. 23 MR. DENNIG: Thanks very much, Nan. I'm Bob 24 Dennig, a Section Chief in the Tech-Spec Branch. 25 We thought we'd start at the top. My purpose is . 245 1 to outline for you, some of the principle elements that are 2 underpinning staff thinking as we further evolve and develop 3 in the area of risk-informed tech specs. 4 So we have sort of a vision statement or a vision 5 slide to begin with. The first major point is that what we 6 envision is an evolution to fully risk-informed standard 7 tech specs. What does that mean? 8 That means that in addition to using risk 9 technology, reliability analysis, to improve various 10 parameters that appear in tech specs such as allowed outage 11 times or completion times, and to optimize in some 12 instances, surveillance intervals and so on and so forth. 13 What we're talking about is taking the 14 configuration risk management concept that's present in the 15 AOT work that we've already done, and emerges again in the 16 revision to the Maintenance Rule, and explicitly marrying 17 that into the technical specifications and moving in the 18 direction of having risk-informed decisionmaking for the 19 actions taken within technical specifications. So that's 20 the real big picture that we have in mind, eventually going 21 to that kind of arrangement. 22 DR. APOSTOLAKIS: At some point, develop an actual 23 sentence that describes that vision, not today, perhaps, but 24 that would be very useful. 25 MR. DENNIG: I'll take that as an assignment. . 246 1 Another part of the vision is that this is a 2 phased approach, just echoing Rich's comments earlier. It's 3 phased in time, phased in extent, in that we mentioned 4 already the seven initiatives. 5 Those are meant to be things that plants may pick 6 up all or some or none; that will be a function of their 7 situation, and their PRA capabilities. 8 And that ties into the notion of the degree of 9 reliance on PRA in these different initiatives. 10 There are varying degrees of reliance in 11 qualitative and quantitative ways on PRA technology 12 underpinning some of these initiatives. But our vision 13 accommodates that kind of a structure. 14 Finally, we're premising this on voluntary 15 adoption. We have an established process for making changes 16 to the standard technical specifications. That's the Tech 17 Spec Task Force process. 18 Mr. Beckner, Dr. Beckner, mentioned that earlier. 19 So we can feed the changes that we envision through that 20 process. We will be getting public comment on these 21 modifications to the standard. 22 And also we intend to focus on those areas where 23 there is interest in the industry in implementation. I 24 think we share a goal with industry of having things 25 actually eventually getting done and implemented in the . 247 1 field, and that's where we're going to focus. 2 DR. APOSTOLAKIS: I must say that I'm confused, 3 maybe because I don't understand the concept of standard 4 technical specifications. 5 Are you preserving anything by moving from the 6 current system to a risk-informed system, and what is that 7 something, if you are preserving it? Is it risk or what? 8 I mean, what does it mean to have a fully 9 risk-informed standard technical specification? 10 How will that -- how will it be different from 11 what we have now? 12 MR. DENNIG: Again, current technical 13 specifications were written with a set of LCOs, Limited 14 Conditions for Operation. 15 DR. APOSTOLAKIS: Right. 16 MR. DENNIG: They have a fairly prescriptive 17 structure. If you find yourself in this configuration, then 18 you will take this action. If you find yourself in this 19 configuration, you will take this action; if you find -- 20 with time limits and so on. 21 DR. APOSTOLAKIS: Right. 22 MR. DENNIG: Okay? That structure can't -- 23 obviously does not anticipate all the configurations that 24 plants can be in. It was constructed, for the most part, 25 with the notion of one piece of equipment at a time, a . 248 1 particular system performing a particular function being out 2 of service. 3 We're now in an environment where there are 4 multiple concurrent equipment outages for planned reasons 5 and unplanned reasons. 6 The prescriptive actions that are written in the 7 script that's in tech specs don't always put you in the 8 safest or least risky situation. 9 And the objective is to use what we've learned 10 since the concept of structured tech specs were first set 11 up, to improve the ability to assess plant state, take all 12 the factors into consideration, and go in the safe direction 13 where there is decisionmaking that's informed by risk 14 technology. 15 DR. APOSTOLAKIS: I understand that, but the 16 current system, the prescriptive system, implies a certain 17 core damage frequency, right? I mean, I can calculate that, 18 the PRAs, that's what they do, because they use the plant 19 and so on. 20 It also implies a certain unavailability for the 21 diesels, trains, for all kinds of things. 22 Now, as I move to the new system, am I going to 23 try to keep the core damage frequency the same, or increase 24 it a little bit according to 1.174? Am I going to try to 25 make sure that the unavailability of the trains are the same . 249 1 or increased a little bit? 2 What is it that I'm preserving? That's not clear 3 to me. 4 MR. REINHART: I hope we're going to get into this 5 in a minute, but the thought is that if you look at a given 6 configuration the way the tech specs would put the plant 7 now, like I said, we could calculate a given core damage 8 frequency. 9 DR. APOSTOLAKIS: So it is the CDF? 10 MR. REINHART: That's a measure. 11 DR. APOSTOLAKIS: A measure. Okay. 12 MR. REINHART: You could also look at that 13 calculated core damage frequency in a state to which you 14 might go, compare those two, and you might also calculate 15 the risk of the transition, and you might put in some 16 compensating factors and try to overall determine what is 17 really the safest thing we could do with the plant right 18 now? 19 I think what the industry is proposing are some 20 steps that are leading us in that direction, and as we go 21 down the path and get a better feel, more practice, if you 22 will, we're going to be able to come up with a more refined 23 system. 24 DR. APOSTOLAKIS: Well, CDF is, of course, a major 25 measure in our metric in 1.174, 1.177, and so on, which use . 250 1 that. But we can also think in terms of the cornerstones of 2 the new oversight process. 3 MR. REINHART: Yes. 4 DR. BONACA: I hope you are going to try and 5 preserve those, I mean, whatever it was before, we want it 6 to be the same in the future. 7 There are certain things that you leave unchanged. 8 You still have a protection system that is in tech specs. 9 MR. REINHART: Yes. 10 DR. BONACA: You have settings, you have a number 11 of things that define your level of action, okay, for 12 mitigating systems. So those are some of the things that 13 you are probably not going to touch. 14 MR. REINHART: I agree. I think right now -- 15 DR. BONACA: Let me just finish. So what you're 16 going to talk about is the level of configuration that you 17 are going to allow by tech specs in relation to those 18 protection systems, okay, to allow you more latitude to do 19 certain things on a risk basis, knowing now that you are not 20 affecting, really, risk significantly by having a certain 21 component out of service for a longer time, in relation, 22 again, to something that doesn't change. 23 I mean, you're not planning to change set points 24 and things like that. 25 MR. REINHART: No, no. The set points would stay . 251 1 the same. Really right now, the function, I think is where 2 you hit the configuration in which the plant should be or 3 should go to do the safest thing. 4 DR. BONACA: But I think the question that Dr. 5 Apostolakis raised is very good in the sense that it will be 6 certainly helpful to have almost like a conceptual model, 7 you know, presented on how you're going to move on this, and 8 understand what is not changing there. 9 You know, again, what is changing? Because 10 oftentimes when I look at these presentations, I'm left with 11 a lot of questions about what are they going to come with 12 next week to change? I would like to understand if it falls 13 within a certain pattern. 14 DR. APOSTOLAKIS: It may be obvious to you guys 15 because you're working with it, but to a third party, it 16 would be nice to have these things up front. 17 MR. REINHART: Maybe as the industry goes through, 18 they're going to lay out these seven pieces in a time line, 19 and I think that will put into perspective, at least the 20 thinking today. 21 Like Dr. Barrett mentioned at the outset, we'll 22 see the long range vision as it is today in one of the 23 pieces. 24 DR. BONACA: That kind of information, however, if 25 you made an effort to develop it conceptually, would go a . 252 1 long way also for the concern we have for the public. 2 Because it would indicate what you're trying to 3 do. All the messages I get is that, for example, you have 4 the next slide -- I'm sorry. 5 DR. APOSTOLAKIS: Let's go to the next one. 6 DR. BONACA: Yes. You're talking about --here 7 you're talking about necessary -- the theme is always 8 producing a conservatism. It seems to me that you're really 9 making a better tech spec. That's really what I see coming 10 out of this. 11 I think that should be a better communication, a 12 better tech spec from a safety standpoint. 13 MR. REINHART: That's a good comment, and I 14 believe that's our concept. 15 DR. APOSTOLAKIS: Can you explain the words, 16 emphasizes the Commission's nuclear reactor safety 17 performance goals? 18 MS. GILLES: I think those are the next couple of 19 slides. 20 MR. DENNIG: Yes. 21 DR. APOSTOLAKIS: Okay, let's go to the next 22 couple slides. 23 MR. DENNIG: And there they are. 24 DR. APOSTOLAKIS: So I guess we've been discussing 25 the first bullet for the last few minutes; is that correct? . 253 1 MR. DENNIG: Yes. 2 DR. APOSTOLAKIS: To maintain safety? 3 MR. DENNIG: Yes. 4 DR. APOSTOLAKIS: And how do we define that? 5 MR. DENNIG: Let's just go to the next slide. 6 DR. APOSTOLAKIS: Okay. 7 MR. DENNIG: We'll be getting into this in a 8 little more detail. It's a little more useful. 9 What we've done is take what we want to achieve 10 and parsed them amongst the pillars or the filters or the 11 safety program, reactor program safety goals. 12 We believe that the direction that we're headed in 13 will allow us to maintain or enhance safety by balancing 14 transition, shutdown risk with the risk continued degraded 15 operation. 16 There is a premise that was built into the 17 original construct of technical specifications that if 18 something is out of service to a certain degree, you begin 19 shutting down. You go to cold shutdown. 20 That was just the default. We think we know 21 better, we know how to do better. So we think that -- and 22 what we're trying to do is, we're going to be able to make 23 an improvement in that area. 24 Part of that notion should be going to a safer end 25 state, if you will. Why should we go to cold shutdown if . 254 1 that's not what we know is the best place to be from our 2 experience over 30 years? 3 So we're reexamining the premise of where tech 4 specs arrive at, too. We've already touched a couple of 5 times on addressing multiple equipment unavailabilities. 6 DR. APOSTOLAKIS: This leaves something basic out, 7 in my view, because I don't understand. Let me tell you 8 what I would do with this, if this was the only thing: 9 It's clear to me that the risk is, let's say, CDF, 10 or even the two cornerstones or three cornerstones, 11 initiating events, the integrity of the primary systems, and 12 so on; is the NRC telling me that all they care about is 13 preserving, maintaining those that I already have calculated 14 in my PRA, say, the core damage frequency, for simplicity? 15 So I can go back and develop a revolutionary, 16 entirely different system that I will spend a lot of time 17 arguing that it preserves the core damage frequency, and now 18 we come here and upset everything you've been doing for the 19 last 40 years. You're not going to accept that, are you? 20 So there is much more to this than what you say 21 there. In other words, I'm coming back and I'm telling you, 22 look, I'm going to -- if I do a much better job on this 23 system, you know, I can do the probabilistic calculations, 24 you know. 25 Then I make sure that the CDF remains the same, so . 255 1 I can neglect something else that for the last 20 years I've 2 been taking care of by following the allowed outage times 3 and so on. In other words, I create an imbalance within the 4 Level I PRA, whose results, however, are still the CDF that 5 I have. 6 I'm not sure you will accept that. You probably 7 want a gradual change. You probably have other goals that 8 you are not stating there. 9 And that's why I think a crisp statement of what 10 you want to do would go a long way towards explaining these 11 things to the public and maybe to this Committee as well. I 12 mean, what does balancing transitional shutdown risk mean? 13 What does addressing multiple equipment unavailabilities 14 mean? 15 These are words that take many -- can accept many 16 interpretations. This is so important that I think we need 17 that, we need a vision statement with goals, this is where 18 we're coming from, and this is what we want to do. 19 Is there somewhere where I can find it, or is that 20 something that you will have to develop? I don't think it 21 was in 1.177. 22 MR. DENNIG: No. Again, let me just go back to 23 Dr. Beckner's opening remarks. 24 The purpose of coming and talking today was to lay 25 out a concept that has a lot of work to do as far as the . 256 1 details and implementation and the kinds of things that 2 you're talking about. 3 And the list of questions that you're giving us, 4 and the things that you're pointing to that cry out for 5 additional information, is very useful to us, and it's the 6 essence of why we're here, in a sense. 7 DR. APOSTOLAKIS: Good. 8 MR. DENNIG: So keep them coming. And where there 9 is something that just is like you guys are smoke and 10 mirrors, you know, we recognize that there are a lot of 11 boundary conditions on what we're doing as far as transition 12 from where we've been to where we want to get to. How do we 13 do -- the phrase that comes off of people's tongues very 14 easily, blending the deterministic and complementing it with 15 the risk and what does that mean, in essence, when you're 16 really doing something. 17 To a certain extent, that's going to emerge from 18 the doing part of this, but, again, we're getting good value 19 for our effort from your questions, so please continue to 20 ask. 21 DR. APOSTOLAKIS: So this is something that you 22 think would be useful? 23 DR. BONACA: Yes. It would be good if it started 24 by explaining what the tech specs are all about. 25 DR. APOSTOLAKIS: I was about to ask that . 257 1 question, but I was -- 2 MR. DENNIG: The purpose of the tech specs -- 3 DR. APOSTOLAKIS: Can you tell me what the tech 4 specs -- 5 MR. DENNIG: Funny thing. 6 DR. APOSTOLAKIS: Oh, you have it. 7 [Laughter.] 8 MR. DENNIG: This statement was the most succinct 9 that we could find. It comes from a statement of 10 consideration and states essentially what at the highest 11 level tech specs are supposed to accomplish. 12 MS. GILLES: It's the backup slide. 13 DR. APOSTOLAKIS: We don't have it? 14 DR. SEALE: The ghost of Tom Kress walks. 15 [Laughter.] 16 DR. APOSTOLAKIS: Oh, boy. 17 MR. DENNIG: So that is the mission statement, if 18 you will, for tech specs, and interestingly enough, if you 19 go back to the law itself it becomes even less specific as 20 far as what tech specs are supposed to do. 21 DR. BONACA: My suggestion was more to go into 22 more specifics. You know, you can come a step below and 23 explain how the specs are structured. You don't have to go 24 through -- you know what I'm saying? You don't have to do 25 it today. I am only saying that it would be satisfying to . 258 1 say how it's structured, you know, there is a protection 2 system, a discussion of the conditions that you are allowing 3 the plant to have in configurations, and then you can go and 4 show some of the deficiencies tied to the deterministic 5 assumptions because we did not know really whether this -- 6 you know, that the design showed the improvements of the 7 tech specs. 8 DR. APOSTOLAKIS: Can we have those slides, by the 9 way -- since we showed them now? 10 MR. DENNIG: Sure, absolutely. These are the 11 basic subsections of 50.36, which is an implementation of 12 the statement. 13 DR. APOSTOLAKIS: Again, coming to the previous 14 slide, in spite of calls from groups outside this agency, I 15 am not sure that adequate protection can be quantified. 16 That is a personal view, not the ACRS, so maybe you can 17 start with this and then in stating what you plan to do, I 18 guess you can say that the big change between the early days 19 and now is that part of the risk can be quantified, okay? 20 The challenge here is to use that quantification 21 in combination with other things that create adequate 22 protection for public health and safety to change the tech 23 specs so that the adequate protection to the public health 24 and safety is still there. 25 Now this is very high level. Then you have to go . 259 1 down and start explaining what these things mean, but this 2 is really the major change, that now we can quantify part of 3 the uncertainty, right? There are still other 4 uncertainties, which is the same thing that we said about 5 defense-in-depth and everything else. 6 Anyway, I think we spent enough time on this and I 7 am glad to see that your guys agree. We have done this, 8 haven't we? 9 MR. DENNIG: Reducing unnecessary burden. We 10 think that this is unnecessary regulatory burden. We think 11 the congruence with the maintenance rule principles 12 50.65(a)(4) is a worthy goal. We would like to have, I 13 believe, utilities working off of one construct as far as 14 the configuration for their plant and we would like to at 15 least understand in a detailed way how the (a)(4) concept 16 works with tech specs. 17 It has been said that they are a backstop. In 18 some cases they would keep you from going someplace that 19 your configuration risk management program would let you go 20 and in other cases the tech specs would allow you to go 21 places that your configuration risk management program won't 22 let you go. We would like to not have two regulations out 23 there that are battling each other depending on what the 24 situation is. 25 DR. SEALE: There is a point here that you haven't . 260 1 made yet and I think has considerable impact here, and that 2 is when the technical specifications in their traditional 3 statement evolved the assumption was that maintenance would 4 be done on a shut down plant. This in part was accepted 5 because of the generally held, if as it turns out possibly 6 incorrect assumption that a shut down plant is the safest 7 plant. 8 Now we find that we can do certain maintenance 9 under operating conditions and in fact because of the active 10 condition of certain systems and so on in that configuration 11 it is actually a preferable way to do it. The maintenance 12 rule is the articulation of the process by which you go 13 about doing that maintenance whether the plant is active or 14 shut down. It almost seems necessary the to re-examine the 15 tech specs to ask yourself if this new mode of maintenance, 16 that is, with an operating plant, will have impact on those 17 tech specs since they were in fact originally conceived 18 under the notion that the plant would be shut down during 19 maintenance. 20 So the tie-in here is almost more intimate than 21 you have inferred here. 22 MR. REINHART: You're right. It's been a driving 23 thing that -- an age driving force in this program. 24 DR. SEALE: Yes. 25 MR. REINHART: It's recent -- it's 1994 -- so a . 261 1 tie with the maintenance at power versus shutdown and the 2 maintenance rule is certainly there. 3 DR. APOSTOLAKIS: I have another comment on this 4 slide. As you know, the agency has been emphasizing the 5 need to communicate with the public more and better, in 6 better ways, and it seems to me I know you didn't intend 7 that, but if you put bullets like that, you are really 8 separating the safety issues from the unnecessary burden, 9 and as you recall perhaps from Mr. Riccio's statement he 10 also believes that the NRC's new and improved technical 11 specifications were never intended to include safety, only 12 the economic viability of the nuclear industry, he says. 13 Now as I recall, when we were preparing or 14 reviewing the 1.174 regulatory guide there was an argument 15 that was made that reducing unnecessary burden does in fact 16 contribute to the enhancement of safety, especially the 17 last -- well, all three, but say providing operational 18 flexibility to the plant. 19 So perhaps when you prepare slides like this or 20 documents to be released to the public, these subtle points 21 need to be made, in my view. Now I am not saying that by 22 reducing any kind of burden you enhance safety, but the key 23 word is "unnecessary" -- then, you know, the utility can 24 utilize its resources in a more efficient way. Operational 25 flexibility is enhanced, therefore safety is enhanced. . 262 1 One thing that sometimes is lost is that in 1.174 2 even when we calculate the change in CDF and LERF we can 3 still make a case that the overall change is in fact 4 negative, but there are qualitative factors that we cannot 5 quantify it at this time, or at least it is not as much as 6 we calculated, so if we calculate that three 10 to the minus 7 5 -- no, you can't have that -- ten to the minus 6 8 increasing CDF, I think it was our collective belief that 9 most of the time it is not going to be three 10 to the minus 10 6 because of these other nonquantifiable benefits you are 11 getting from this, so I think this is a key point, because 12 if we keep talking about reducing unnecessary burden without 13 making this connection, it is not -- we are not really 14 communicating very well. 15 MR. DENNIG: Your point is well-taken. 16 DR. APOSTOLAKIS: We are falling desperately 17 behind, so let's see -- I think maybe you can go to #9 18 unless you feel that you have something very important to 19 say on #8. 20 MR. DENNIG: I think your decision is a wise one. 21 The way that we are conducting this effort, the 22 vehicle underlying the effort is a joint NRC-industry effort 23 that originated in July '98 at a Licensing Managers' 24 Workshop. 25 The Risk Informed Tech Spec Task Force includes . 263 1 representatives of all the NSSS owners, NEI, EPRI and 2 supporting contractors. We have had five meetings held to 3 date. Those have been public meetings. In one we plan a 4 trip and that lead plant is San Onofre. Let's go on to the 5 next slide. 6 By the way, we have a lead-in to the 7 presentation-discussion here from industry after the break. 8 The Risk Informed Tech Spec Task Force is currently pursuing 9 seven initiatives that were initially identified and we have 10 just binned them here into some -- throwing the seven into 11 some larger categories, and they basically break down to 12 risk-informed plant maneuvering, elimination of shutdowns 13 for low risk situations, and risk-informed surveillance 14 testing. 15 These initiatives take advantage of and 16 incorporate the concepts of configuration risk management 17 and consistent with the maintenance rule concept. Perhaps, 18 a very important point, we feel that we can make a great 19 deal of progress and largely get to where we envision going 20 without any changes needed to 50.36. 21 It is flexible enough that we can use the existing 22 structure. 23 That concludes my presentation. I would like to 24 turn it over to Mark Reinhart from Risk Management. 25 MR. REINHART: If I could start maybe to put this . 264 1 in perspective, I'm Mark Reinhart from the NRR Probabilistic 2 Risk Assessment Branch, the Section Chief in that Branch. 3 Maybe to put it in perspective, at least to help 4 me interact, if I view tech specs, I look at a couple 5 pieces: 6 One piece I have is an operating envelope, you 7 might say, power, temperature, pressure flows, some limits, 8 some margins, in which we want to the plant to operate. 9 We have configurations of equipment that help it 10 stay in that envelope or bring it back, given some 11 initiating event or transient, bring it back where it is in 12 a safe envelope. 13 And then we have some administrative controls that 14 help balance that. 15 I think what we're doing is looking at that middle 16 piece, we're looking at what equipment should be operating, 17 how redundant it should be, how diverse it should be under 18 different operating conditions. 19 And when the industry proposes a change and we 20 review it, we're going to look at these five principles in a 21 risk-informed manner. 22 We're looking to make sure we comply with 23 regulations, we're looking for defense-in-depth, safety 24 margins, and then we get into the 1.174 piece where we're 25 looking for a risk decrease if we can do that. . 265 1 Risk-neutral, okay, and if it is, the calculated 2 risk is an increase, we're going to look into Reg Guide 3 1.174 for some guidelines on how much to allow that 4 calculated increase, but at the same time -- and I'm going 5 to get to this in the next slide -- we're going to be 6 looking for some compensatory measures to account for that 7 delta. 8 And the fifth principle: We're going to be 9 looking for subsequent ways to monitor that plant's 10 performance. I think that if we see, starting with some 11 fundamental proposals, moving to the more sophisticated over 12 a time line, we're going to be looking not only to the 13 staff, but also to the industry to be able to articulate how 14 they're doing this, how we're doing this, and what are some 15 ways to monitor performance. 16 I'd like to comment about the cornerstones. One 17 thought is some sort of performance indicator that would 18 indicate where we are in that program. 19 DR. APOSTOLAKIS: It's much more involved than 20 that, though. 21 MR. REINHART: Yes. 22 DR. APOSTOLAKIS: Because, no, no. 23 [Laughter.] 24 DR. APOSTOLAKIS: The cornerstones, you see, our 25 statement of defense-in-depth, now if you go to 1.174, they . 266 1 give a list of bullets there with what defense-in-depth 2 means. So there is a lot of flexibility here on how you 3 interpret these concepts, all right? 4 MR. REINHART: Right. 5 DR. APOSTOLAKIS: And I understand the staff is 6 working now on a new risk-informed Part 50 to try to see at 7 what level defense-in-depth should be recommended. 8 So, this is -- there is a lot of flexibility, a 9 lot of latitude here, how to do it. 10 Now, one question: Of the seven initiatives, when 11 we look at the seven initiatives, each one will be subjected 12 to the is process separately from the others? 13 MR. REINHART: Yes, as applicable. I think you 14 could say some are going to be, particularly in the fourth 15 bullet, more risk information will be available to be 16 brought to the table than in others. 17 In a couple, the industry is going to make their 18 proposal that some of their risk information is going to be 19 after the fact. 20 DR. APOSTOLAKIS: Again, going back to the days of 21 the development of the Regulatory Guide, as I recall, the 22 idea was that the licensee submits a request. 23 MR. REINHART: Yes. 24 DR. APOSTOLAKIS: The staff reviews it and so on, 25 and if it is approved, there will be the monitoring of the . 267 1 subsequent performance. 2 MR. REINHART: Yes. 3 DR. APOSTOLAKIS: Now, in principle, the 4 Regulatory Guide does not forbid the submission of a new 5 request next Monday. 6 MR. REINHART: That's true. 7 DR. APOSTOLAKIS: So we don't have to wait to see 8 what the subsequent performance will be, due to the first 9 request, right? They can come back and request something 10 else. 11 MR. REINHART: They can make the request, 12 certainly. 13 DR. APOSTOLAKIS: So these seven then will be 14 submitted in seven consecutive Mondays or altogether? 15 MR. REINHART: They have a time line. It's over 16 several years. 17 DR. APOSTOLAKIS: Several years. 18 MR. REINHART: That they are proposing to make 19 those submittals. Some, I believe two. Are there two that 20 are inhouse? 21 MR. DENNIG: Two. 22 MR. REINHART: Two are inhouse, just recently, and 23 the others will be coming in over a period of time. 24 Again, they're proposing to tell you what that 25 time line is. I think we can all have a different view of . 268 1 how ambitious that time line is. 2 DR. APOSTOLAKIS: Now where under these five you 3 would evaluate -- five bullets -- Dr. Seale's statement 4 earlier that perhaps our notion of what is a safe state now 5 is different than it was assumed to be before? Shutdown may 6 not be a safe state. 7 I mean, changing that falls where? 8 MR. REINHART: Could I go to the next slide and 9 show you that? 10 DR. APOSTOLAKIS: Of course you can. 11 MR. REINHART: Particularly under Bullet 4, and I 12 want to preface this. We're talking right now with 13 operating within the current rule that we have, 10 CFR 14 50.36(4), the tech specs. We're not looking at rule changes 15 to what we're looking at. 16 But, if you will, define an integrated minimum 17 risk locus, which would include the risk of the at-power 18 configuration, versus the risk of that configuration in some 19 other mode, plus considering the transition risk to get from 20 one mode to the other, valve lineups, et cetera, that a 21 plant would have to go through. 22 At the time, placing on top of those, whatever 23 appropriate compensatory actions we come up with, say what 24 is the safest thing to do with the plant, given the 25 situation? That's the goal. . 269 1 Some of it is going to be quantitative. Some of 2 it's going to be qualitative, some of it's going to have to 3 account for uncertainty. 4 Some of it's going to be single component, some of 5 it's going to be multiple components. But what we're trying 6 to do is, rather that second-guess today, where that plant 7 is going to be tomorrow, once the plant gets there, what's 8 the safest thing to do to get to where we want to go, and 9 can we identify some particular areas that we want to avoid? 10 If we can do that, we do have a safe plant. We 11 likely have a safer plant than we have today. 12 We've allowed flexibility to the operator, and we 13 fully intend to be public, and I think you've made comments 14 about we need to be crisp and clear in what we're saying so 15 that people catch on to where we're going. 16 DR. APOSTOLAKIS: I think what you just said makes 17 perfect sense. 18 Now in terms of the availability of tools in order 19 to do your third bullet there. Will the licensees be 20 required to have decent PRAs for power transition, all 21 specific? 22 MR. REINHART: Outstanding question, and the way 23 we're viewing that today, is there are some plants that 24 could probably approach that right now. They have very 25 nice, high-quality PRAs. . 270 1 To give a plant that flexibility, we would be 2 looking for that type of a PRA. We're looking at a 3 voluntary program. 4 If some plant doesn't have the PRA, doesn't want 5 to play in this arena, they're not going to be forced to, 6 but the plant that does want to play in the arena, we need 7 to make sure they have a quality PRA that justifies what 8 they're doing. 9 And I think the ones that can go there today are 10 going to be able to demonstrate to the industry that this is 11 a safe, cost-effective, reasonable way to operate a nuclear 12 power plant. 13 DR. APOSTOLAKIS: Okay. 14 MR. REINHART: That's really my presentation, just 15 those two slides. 16 DR. APOSTOLAKIS: So what's next? 17 MR. REINHART: We'd propose we take a break, and 18 then the industry will come and present to you, their view 19 of risk-informed standard tech specs. 20 DR. APOSTOLAKIS: So let's take a break. Till 21 when? 9:55? 22 DR. BONACA: Why not? 23 [Recess.] 24 DR. APOSTOLAKIS: Okay, we're back in session. 25 Mr. Bradley? . 271 1 MR. BRADLEY: Thanks. I'm Biff Bradley from NEI. 2 I wanted to proceed with the industry presentation today. 3 As you know, there are a lot of risk-informed 4 initiatives underway now. As a matter of fact, the industry 5 is nearly deluged with trying to make a lot of changes in a 6 lot of areas at the same time: Oversight process, the 7 regulations themselves. 8 And the tech specs are a high priority for us, for 9 a number of reasons. I just wanted to mention some of those 10 here today. I know the ACRS hasn't been hearing a lot about 11 this up till now, and I did want to mention the priority. 12 As we talked about, I think a lot of these things 13 are a rehash of what the staff already discussed, but there 14 are significant plant operational benefits. 15 The tech specs are really an artifact of a 16 previous era in the history of the plants, and there is a 17 much greater state of knowledge now and additional things 18 going on with risk-informed, particularly the Maintenance 19 Rule that we'll talk about, that really allow greater 20 operational flexibility of the plant and the ability to use 21 risk insights to get the plant into the safest state, and to 22 make decisions on configuration control and mode changes, 23 using a lot of insights that the tech specs didn't really 24 bring to bear when they were created back at the inception 25 of the plants. . 272 1 Another nice thing about this activity is that it 2 doesn't require rulemaking. And because of that -- 3 rulemaking even with the best of intentions, is always a 4 multiyear effort, and the ability to make some changes, some 5 really significant changes that impact the way the plants 6 are operated without having to wait out a rulemaking effort, 7 is a great benefit. 8 At the executive level, when we discuss the whole 9 set of risk-informed initiatives with the industry, there is 10 a lot of interest in this because it's something the plants 11 believe they can achieve and get into place in the next year 12 or two, a lot of these changes, and we'll see that in the 13 schedule. 14 Finally, those of you that are familiar with all 15 the discussions we're having on Option 2 and Option 3 of 16 Part 50 reform, it's a very ambitious effort. There are 17 some very thorny issues that we have to overcome. 18 I'm confident that we will, but in some ways, the 19 tech specs are more directly amenable to be able to use the 20 risk tools we have now to get some changes without having to 21 spend years trying to, for instance, determine what the 22 impact of special treatment is on equipment reliability and 23 availability. 24 Tech specs typically are changing things that are 25 like equipment out of service times or mode changes or . 273 1 whatever, where there are generally ways to address that in 2 a risk-informed way, without hypothesizing what kind of 3 impacts there are of these softer regulatory programs. 4 Next slide. 5 As has been discussed already today, I just want 6 to reiterate this; this is a timely effort, because in the 7 middle part of next year, the rulemaking to (a)(4) of the 8 Maintenance Rule, which is the configuration control 9 provision, will be implemented at every plant in the 10 country. 11 The Committee has already reviewed the 12 implementation guidance for (a)(4) a number of times, and I 13 think, George, you were asking about the CRMP earlier. In 14 my view, the (a)(4) implementation guidance and the CRMP are 15 essentially one in the same, so you can go back and look at 16 what you've reviewed previously on (a)(4). 17 I'll just mention that (a)(4) essentially does 18 what a large part of the tech specs do. Now, the tech specs 19 do lay out safety limits and some other things, but in terms 20 of the configuration control, which is a bit chunk of the 21 tech specs, that is essentially being duplicated by the 22 (a)(4) regulation. 23 And it's doing it in a risk-informed way; the 24 scope of equipment involved for (a)(4) is the scope of the 25 PRA. It's the large of scope of equipment in the tech . 274 1 specs, and the general concept of (a)(4) is that, as we 2 talked about today, is to manage the risk around your 3 baseline value. 4 And that's what we have. As you know from 5 reviewing the guideline, configurations of specific risk, 6 the temporary risk increases, cumulative risk, all those 7 issues are addressed in the (a)(4) guidance. 8 Basically it's using the tools that we have in the 9 smart way to manage configuration control. When you look at 10 what tech specs does, being something that was developed 11 prior to the risk-informed era, it's more aligned to the 12 deterministic licensing basis of the plants. 13 So what we're doing in (a)(4) is looking at larger 14 set of components and systems in the plant, and making 15 configuration control decisions based on that larger scope. 16 Just a note that in our comments on the (a)(4) 17 rulemaking, industry did support that rulemaking, even 18 though it is a fairly significant new requirement, because, 19 as we talked about, tech specs weren't really designed to 20 address multiple equipment out of service conditions. 21 However, we did note that ultimately the tech 22 specs needed to be reconciled with that. As was mentioned 23 today, in a lot of cases, tech specs will constrain you. 24 The (a)(4) evaluation may tell you that one in-state or mode 25 change or what have you is the right way to go, but tech . 275 1 specs will say, no, can't do that. 2 Of course, the tech specs are the mantra for the 3 operators. It's part of the licensing basis of the plant, 4 and you can't, unless you go in for an enforcement 5 discretion or -- I mean, whatever the provision is to get 6 temporary relief, you're pretty much locked into what your 7 tech specs are. 8 And just to conclude on (a)(4), much of what is in 9 (a)(4), Rich talked about voluntary configuration changes, 10 and (a)(4) addresses more than just that. It addresses 11 emergent conditions, corrective maintenance, surveillance 12 testing. 13 If you look at the list of things in the (a)(4) 14 rule, it's very duplicative of what tech specs are there to 15 address now. And it's important for the industry that this 16 activity go forward, and that we can achieve some synergy 17 between this and (a)(4). 18 The timing is perfect. If we can meet the 19 schedule for this activity, it will fit perfectly with the 20 (a)(4) implementation schedule. 21 And the (a)(4) is not an insignificant rulemaking 22 for the industry. We did issue -- PRA quality came up, and 23 (a)(4) does include specific discussions of those areas of 24 your PRA that have to be addressed, references the industry 25 peer review process as a means to address areas such as . 276 1 treatment of dependencies and support systems that are 2 important for these types of considerations. 3 Clearly, as was suggested here, PRA quality is an 4 element of being able to make these tech specs changes, and 5 being able to implement (a)(4), so everyone is going to take 6 advantage of the limitation of the scope of (a)(4), using a 7 risk-informed process as the rule allows. It's going to 8 have to address those PRA quality issues. 9 So at this point, I'd like to turn it over to 10 Sharon -- I'm sorry, to Tom, Tom Hook, who will proceed with 11 our presentation. 12 MR. HOOK: Good morning. My name is Tom Hook, and 13 I'm the manager of nuclear safety oversight at San Onofre 14 Nuclear Generating Station, which is owned and operated by 15 Southern California Edison, primarily. 16 I'm going to speak briefly about the risk-informed 17 tech spec goals. These are goals that were established by 18 the industry/NRC task force that's been developing the 19 proposed changes to the technical specifications. 20 These are also goals that were established by the 21 Combustion Engineering Owners Group as a part of their 22 risk-informed license changes that have been developed over 23 the past several years. 24 The first major goal is to establish a framework 25 for this particular project for decisionmaking that utilizes . 277 1 risk-informed tools, as well as traditional engineering. 2 That framework would be different than the 3 framework that we have right now at plants; that is, 4 deterministic-driven and rule-driven in the present tech 5 specs. 6 This framework would rely more heavily on a risk 7 management, a configuration risk management program, and the 8 (a)(4) for providing the boundary conditions for 9 decisionmaking. 10 It would integrate the Maintenance Rule (a)(4) 11 decisionmaking, the revised reactor oversight process, the 12 significance determination process, as a part of the NRC's 13 and the industry's toolbox for assessing the significance of 14 deviating from the technical specifications, missing 15 surveillance. 16 It would also provide a means to look at the 17 existing technical specification allowed outage times, the 18 end-states, and how the Maintenance Rule decision criteria 19 in the NEI Guide would allow us to place the plant in the 20 safest operational state. 21 Moving to the next slide, in terms of goals, the 22 additional goals were enhancing plant safety and reducing 23 unnecessary burden. And I acknowledge the earlier comment 24 from the Committee that a blending of these and 25 acknowledging how reducing unnecessary burden also enhances . 278 1 plant safety is an appropriate comment. 2 And these are the similar types of bullets that 3 were in the staff slides in the earlier presentation: 4 Eliminating unnecessary mode transitions; and determining 5 the appropriate end-state when equipment is inoperable; 6 integrating risk information into the maintenance and 7 operation of the plant more fully, and for some plants such 8 as San Onofre, we feel we have gone to great lengths to do 9 that right now. 10 And this project here is an ability for us to move 11 that decisionmaking process into the technical specification 12 area more fully, and take advantage of it in terms in terms 13 of maneuvering the plant. 14 Monitoring and controlling plant risk to 15 acceptable levels, and those levels are defined in the 16 (a)(4) NEI guidance, Chapter 11. And there are goals there 17 for work. 18 There are acceptance levels for cumulative risk 19 and core damage frequency, and also in Reg Guide 1.174, for 20 increases in core damage frequency and large early release; 21 and, lastly, selecting the appropriate actions when 22 equipment is inoperable in terms of maneuvering the plant, 23 taking compensatory measures, providing a framework for 24 making those decisions in a predictable, repeatable, and 25 appropriate program. . 279 1 And lastly, reducing unnecessary burden, reducing 2 occupational exposure. We're going to a lower mode to a 3 cold shut down that may create the potential for unnecessary 4 occupational exposure due to in-containment or radiation 5 activities. 6 There is the reducing the costs of operating the 7 unit by increasing the availability of the unit, and adding 8 resource allocation flexibility to promote the attention to 9 the equipment that is most important, most significant to 10 safety where currently that is not possible due to limited 11 resources. 12 I also wanted to speak specifically relating to 13 the configuration risk management program that we have at 14 San Onofre, based upon an earlier question from the 15 Committee, and describe how that program is evolving into 16 (a)(4) and the rigors of that program at San Onofre. 17 We have a safety monitor at San Onofre. It's the 18 Scientech Safety Monitor that is utilized to predict, 19 calculate the risk of future plant configurations, and that 20 tool is actually in the hands of the NRC. It was purchased 21 by the NRC and the NRC has our safety monitor model, as of a 22 number of months ago, that included at-power and shutdown 23 risk calculation capability. 24 Since then, we've added transition risk and 25 additional interim mode calculational capability, as well as . 280 1 the external event fire and seismic initiator models. 2 DR. APOSTOLAKIS: Has the staff reviewed the 3 models that are used to develop the risk? 4 MR. BECKNER: We've looked at it. 5 DR. APOSTOLAKIS: Here. You can speak, whatever 6 you want. 7 MR. BECKNER: We've looked at it, but we haven't 8 done a formal review, but we've been at San Onofre, we've 9 worked with it there, we've had lots of discussions, and 10 we've looked at the software capabilities. 11 But as of yet, we've not sat down and done what 12 you would call a review that we would write a safety 13 evaluation on. 14 DR. APOSTOLAKIS: But you plan to do this, to 15 review it? 16 MR. BECKNER: That's a good questions, and I think 17 one of the open questions for us is just to what extent does 18 the staff go when a licensee provides a PSA, they do their 19 cross-comparisons, their independent reviews, what part do 20 we have to do and how deep should it be? 21 DR. APOSTOLAKIS: I looked a little bit at the 22 concept of this monitoring, and it seems to me because its 23 intent is different from the PRA, you can't just take the 24 plant's PRA and computerize it. 25 MR. BECKNER: I agree. . 281 1 DR. APOSTOLAKIS: So I think, and I don't recall 2 ever discussing these issues with the staff. Maybe we ought 3 to have a supplemental meeting to discuss this. 4 For example, if a piece of equipment is out, what 5 do you do to the PRA, just set the unavailability over to 6 one? Or are there other things you have to do to reflect 7 the fact that this equipment is out of service? 8 In fact, I would say that there are several terms 9 that are affected by that fact, so if the risk monitor is to 10 play such an important role in configuration risk 11 management, it seems to me that we ought to do this, and 12 make sure that we understand what the models behind the 13 pictures we see are. 14 MR. BECKNER: We agree. As we said, as the 15 industry starts to develop this capability and wants this 16 flexibility, we have to move with them. We're talking about 17 it, and I think a discussion with the Committee would 18 provide valuable insights and help in that arena. 19 DR. APOSTOLAKIS: Okay, that's something that I'm 20 very much interested in. We already have a comment that -- 21 not directly on the monitor, but in the context of 22 risk-informed in Part 50 on importance measures in our 23 letter of -- do you remember when it was? Last June. 24 MR. MARKLEY: No, it was this Fall, it was like 25 October. . 282 1 DR. APOSTOLAKIS: So a lot of the comments we made 2 there, I think would apply to a risk monitor, because there 3 the issue was what happens to the risk importance measures 4 when you change configuration? Right? 5 DR. SEALE: Do you really have the detail to 6 capture all of the changes that are implicit in certain 7 equipment being out of service in your risk, so that you can 8 really tell what the change is? 9 DR. APOSTOLAKIS: That's right. So I think we 10 should do that work at some point. 11 MR. HOOK: And as most nuclear stations, we have a 12 proceduralized control process for modifying the safety 13 monitor of the PRA model that is in the risk tool. We have 14 certification efforts underway in the owners group as the 15 other owners groups have to review all the living PRAs at 16 nuclear stations. 17 We also have internal controls to make sure that 18 the plant staff understands the limitations of the tool. We 19 have external peer reviews that have been conducted, and 20 we've submitted a significant amount of detail and results 21 from our PRA as a part of the prior risk-informed allowed 22 outage time changes, including cut sets and such, to the 23 staff for their review. 24 So we feel that we have a very high quality PRA. 25 We're also embarking upon additional activities that are not . 283 1 specifically a part of this. 2 That includes developing a plant risk trip model 3 that would be incorporated into the safety monitor as a few 4 other nuclear stations have developed, and we're developing 5 that for economic reasons, as well as safety reasons, to 6 address the cornerstone regarding initiating events, as well 7 as looking at the mitigating systems. 8 I don't have anything else on the San Onofre, so 9 that concludes my part of the presentation. 10 MR. HARRISON: Good morning. My name is Wayne 11 Harrison. I am from STP Nuclear Operating Company and I am 12 also wearing two hats today. The other hat -- I am going to 13 primarily be representing the Westinghouse Owners Group in 14 my discussion. 15 Before I go into this slide, I'd just a comment, a 16 follow-on to what Tom was saying on configuration risk 17 management programs. South Texas also has a configuration 18 risk management program that based on our probabilistic risk 19 assessment that is done using risk man. -- and we have 20 quantified several, a number of thousand, of plant states 21 into a risk assessment calculator that we call RASCAL that 22 we can readily quantify plant configurations and the risk 23 associated with plant configurations. We use it on weekly 24 maintenance and assessing plant configurations. 25 This slide kind of puts into pictorial format the . 284 1 vision, and what we are really looking for here, to try to 2 put this somewhat into words, is to develop a set of better 3 engineered risk-informed technical specifications that 4 facilitate safe and effective plant operations. We want to 5 base this on early successes and a phased approach and have 6 a set of products that can be applied across a wide range of 7 PRA capabilities. 8 I agree with Dr. Apostolakis in that we really 9 need to refine that statement and get it focused, because I 10 think a good vision statement really does keep a task in 11 focus. 12 I think this does complement the NRC vision that 13 was articulated earlier in Bob Dennig's presentation. 14 What you see across the top is an estimated 15 timeline. This is certainly not cast in concrete. This is 16 just our best guess of what the timeline would be for these 17 set of initiatives and to the left of the little vertical 18 dotted line you see our current initiatives and Sharon is 19 going to talk about those a little bit later as we go into 20 the follow-on slides. I am not going to really go into 21 those in any degree of detail. 22 The next three boxes are our future initiatives, 23 which are the risk-informed surveillance requirements, the 24 risk-informed surveillance test intervals, risk-informed 25 allowed outage times with risk-informed actions, and then . 285 1 the fully risk-informed technical specifications that after 2 Sharon talks about the seven existing initiatives I will 3 talk a little bit more about those, which are very 4 conceptual at this point in time. 5 You can see what these do as you go across from 6 left to right on this slide is the degree of complexity and 7 the demands on the PRA increase. What we would like to be 8 able to do -- I think we have alluded to this earlier -- is 9 that as you go across these set of initiatives, it gives the 10 people who are implementing them or the Licensees who are 11 implementing them a cafeteria, if you will, of options. 12 People who may not have quite as sophisticated a 13 probabilistic risk assessment or some of the older plants or 14 what have you may implement those line item changes that you 15 see there on the left. 16 As people have more sophisticated PRAs you can see 17 that they will be able to implement the things further to 18 the right on the chart. 19 What we are looking for here in the items, these 20 first six or seven items is some early successes that we can 21 apply across the board. We feel that is important for the 22 continued support of the industry. 23 For instance, I will just speak in terms of the 24 Westinghouse Owners Group. The Westinghouse Owners Group 25 has been very supportive of risk-informed regulation. We . 286 1 have had a number of initiatives that Sharon will talk about 2 in 4(a) for line item improvements that the WOG has funded 3 and supported and they have been very supportive of that. 4 We need to show them that these things are going 5 to progress, that they will continue to be supportive of 6 these risk-informed initiatives. 7 We are looking for a phased approach here that 8 builds one items on the other, and I think you can see that 9 is what we have here. We are talking about the consistency 10 with the overall regulatory approach and Biff talked a 11 little about that with 4(a) of 50.65, the maintenance rule. 12 We think this fits in very well with 4(a) of 50.65 of the 13 maintenance rule. It fits in with the new inspection 14 process and we feel that it fits in very well with 15 risk-informing Part 50, where we could really focus on those 16 things which are really important to our plants. 17 The allowed outage times and risk-informed actions 18 but not the exceed times are really the first, I would say 19 the first complex step in this, where I think, I would say 20 that you really get to the new generation of technical 21 specifications and certainly the risk-informed, fully 22 risk-informed technical specifications represents a very 23 significant change in technical specifications, and we need 24 to assess as we go through this do you get 90 percent of the 25 benefit at the risk-informed allowed outage times and . 287 1 risk-informed actions and is it fully risk-informed with the 2 rule changes and so forth -- is that going to be worth it to 3 us for that incremental increase in effort and cost? 4 I guess the only other thing I would point out 5 here, just as sort of a final statement, is we are working 6 within the existing process for generic technical 7 specification changes. We used the technical specification 8 task force to process these changes, so we are working with 9 a framework both the industry and the Nuclear Regulatory 10 Commission is familiar with. 11 That basically concludes my discussion of the 12 overall vision. 13 DR. APOSTOLAKIS: I have two questions. 14 MR. HARRISON: Sure. 15 DR. APOSTOLAKIS: We keep talking about burden 16 reduction. Can you give us an idea what kind of burden we 17 are talking about here that would be eliminated? 18 MR. HARRISON: I think one example I like to use 19 on burden reduction is primarily with regard to the 20 surveillance requirements and the surveillance test 21 intervals. 22 I think that the surveillance requirements and the 23 surveillance test intervals were basically put into the 24 technical specifications based on the best judgment, best 25 engineering judgment at the time, and the surveillance test . 288 1 intervals may or may not have, and I think in many cases do 2 not for instance have a statistical basis for how frequently 3 you do them. 4 I think if we can identify those surveillance 5 requirements that really are important to the safe operation 6 of the plant, and separate them from the ones that we use 7 for routine assurance of reliability, and then relocate the 8 surveillance test intervals to a Licensee-controlled 9 program, that allows a Licensee to have realistic 10 surveillance test intervals. It allows a Licensee to 11 determine what resources they need to put on surveillance 12 test intervals and that can translate to actual burden 13 reduction for each licensee. 14 It adds to safety, as we discussed before, because 15 you very well may be adding to the availability and 16 reliability of that particular component, so that is I think 17 a good example of where you have a regulatory burden 18 reduction and an increase in safety. 19 DR. APOSTOLAKIS: But how much would the burden 20 reduction be in terms of dollars? 21 MR. HARRISON: That's very hard to quantify. 22 Sharon thinks that she can talk to that. 23 DR. SEALE: Could I ask a question in that regard? 24 The kind of test intervals you are talking about 25 would -- let's say in the initial establishment of what the . 289 1 test interval would be, you might take into account the kind 2 of equipment that were involved, whether it was analog or 3 digital or so forth. Let me ask the Staff or whoever, if 4 you make a change to a different technology equipment, is 5 that question of test interval open for redefinition or has 6 it remained at the old frequency? 7 MR. BECKNER: This is Bill Beckner again. 8 That is I think one of the reasons we have the 9 relocation of intervals up here. A tech spec number is a 10 license requirement that must be met -- 11 DR. SEALE: Yes. 12 MR. BECKNER: -- unless they come in for a tech 13 spec change, and if Licensees change their hardware of 14 course they could come in with a license amendment request 15 and convince the Staff it is the appropriate thing to do. 16 DR. SEALE: They could do that? 17 MR. BECKNER: Correct. Another way to do it, if 18 we can convince ourselves that within the rule this can be 19 the type of information that can be put in the Licensee 20 control document, controlled under 50.59, that provides the 21 Licensee with the flexibility again, but with hopefully no 22 reduction in safety given that 50.59 is an adequate process. 23 DR. SEALE: Well, in general I think the more 24 modern technology is less susceptible to the kinds of things 25 that your surveillance program is designed to capture, so . 290 1 you need that flexibility whether it has been there in the 2 past or not. 3 MR. BECKNER: I think we are in agreement. 4 DR. BONACA: But on the issue of cost savings, if 5 I look at the current initiatives alone, I mean there are 6 opportunities for millions of dollars of savings on 7 individual decisions. 8 MR. HARRISON: That's correct. 9 DR. BONACA: I mean you have conditions where you 10 may not shut down where today you would shut down. 11 MR. HARRISON: That is correct. 12 DR. BONACA: There are conditions where you stay 13 in hot standby where today you have to go to cold standby. 14 I think those are big -- 15 MR. HARRISON: That is correct. You are 16 absolutely correct. 17 I would also point out on the surveillance test 18 intervals there is a certain amount of precedent that we 19 have already begun with that, with the inservice testing for 20 the test intervals are now being placed under Licensee 21 control and risk-informed inservice testing. 22 DR. APOSTOLAKIS: Now two more questions. Are all 23 these changes quantifiable in the PRA? Let me explain that. 24 We have found that the requests that have come in 25 for the changes, you know, when the Regulatory Guides were . 291 1 developed, fall into one of two classes. 2 In one class you can actually quantify the change 3 in CDF and LERF -- for example, if you change the test 4 intervals. We have equations for those things. You go back 5 there and you get a number. That is one class. 6 The second class you can't quantify the change and 7 a good example is quality assurance. In that case we went 8 around it and said, well, we will develop categories for the 9 components and systems and structures that will be based on 10 risk measures, importance measures, and then we will change 11 the QA requirements to the low risk significant category or 12 the non-risk significant category. In fact, your 13 organization has done a lot of work in that area. 14 Then the assumption is that it really doesn't 15 matter if you remove those requirements or relax them 16 because we can quantify the impact but it stands to reason 17 that because of the relative unimportance of these SSCs it 18 is a good thing to do. 19 Now are we going to have any situation like that 20 here with the seven initiatives or all of them can be 21 quantified and give a delta CDF and delta LERF? 22 MR. HARRISON: It varies. Some of these don't 23 very well lend themselves to quantification. We'll see that 24 as we go through -- 25 DR. APOSTOLAKIS: Okay. . 292 1 MR. HARRISON: -- the individuals and some do. I 2 think in most cases you can at least do a risk assessment of 3 a confirmatory sense to at least say yeah, from what we know 4 and are looking at we can satisfy ourselves that it is not 5 risk significant. 6 DR. APOSTOLAKIS: So we will have to go back to 7 these categories of SSCs in those cases and make a judgment 8 there, okay. 9 The last question has to do with a timeline you 10 have there. You are starting in January of '99 -- right? 11 MR. HARRISON: No? 12 DR. APOSTOLAKIS: That's what it is. 13 MS. MAHLER: That is intended to be 1999 through 14 2001. 15 DR. APOSTOLAKIS: Oh. 16 MS. MAHLER: 2000 through 2001. 17 DR. APOSTOLAKIS: Okay. Shall we move on now? 18 MS. MAHLER: My name is Sharon Mahler, and I work 19 with NPPD. My intent is basically to run through the 20 concepts of the seven initiatives that the industry has 21 undertaken. We are trying to stay at the conceptual level. 22 Some of these have been more fleshed out than others of the 23 issues, but since this is your first introduction we wanted 24 to sort of lay them all out for you. 25 The first initiative -- . 293 1 DR. APOSTOLAKIS: Don't assume we know much. 2 MS. MAHLER: The first initiative is called end 3 states. As we spoke earlier, one of the fundamental 4 presumptions in current tech spec space was that it defined 5 cold shutdown as your safest end state or for what we call 6 the default action, to go down to cold shutdown. 7 What this particular initiative is doing is really 8 looking at that presumption with the new risk tools that we 9 have available. Let me back up. 10 What we are finding and basically even before we 11 started using the risk tools one of the things we found, 12 discussing it from a traditional engineering standpoint, is 13 actually hot shutdown is a more resource-risk state. 14 For example, we have RHR and aux feed available 15 for PWRs versus just RHR in cold shutdown -- those kinds of 16 things -- so that is sort of what led us to, hey, we need to 17 be looking at this. 18 SONGS has drafted, has a draft analysis, which 19 supports that indeed hot shutdown may be the less risky 20 place to be, so that is basically what we are looking for in 21 this initiative, what we are looking at. 22 DR. APOSTOLAKIS: Can you explain the last 23 statement there -- being hot standby in six hours or would 24 go to hot standby in six hours? 25 MS. MAHLER: That is how the standard tech specs . 294 1 are set up. It basically says that if your required action 2 and associated completion time is not met be in -- they use 3 "modes" -- but we tried to use normal terminology, if you 4 will -- be in hot standby within six hours and be in cold 5 shutdown within 36. That is what the current specs say. 6 What we are trying to show you is how it would be 7 revised. 8 DR. APOSTOLAKIS: Oh. 9 MS. MAHLER: It would now say be in hot standby in 10 six hours or be in hot shutdown in 12 hours. 11 DR. SEALE: And how long could you stay in hot 12 shutdown? 13 MS. MAHLER: Indefinitely. 14 DR. SEALE: And that is PTS is one of the things 15 you avoid if you stay in hot shutdown. 16 MS. MAHLER: Yes. 17 DR. BONACA: So you feel this may be one situation 18 where it is a win/win situation? 19 MS. MAHLER: It basically represents a risk 20 decrease. 21 DR. BONACA: You may actually have a reduction in 22 risk but you also have the benefit? 23 MS. MAHLER: It does save time and cost relative 24 to the additional testing that comes into play when you go 25 into cold shutdown as well as once you get the thing fixed, . 295 1 time to come back up. 2 DR. APOSTOLAKIS: So you would apply Regulatory 3 Guide 1.174 to this? How would you review it? Or is it a 4 matter of just agreeing? 5 MR. REINHART: Again, we would go back to those 6 five principles in the review, have an integrated review, 7 but in doing this look at a comparison between the risk in 8 the operating mode versus risk in shutdown or maybe risk in 9 cold shutdown versus risk in hot shutdown, and there would 10 be quantitative as well as qualitative arguments. 11 San Onofre has already submitted and had approved 12 one change. It was on the diesel -- where they made a case 13 for it was safer to stay in a mode other than cold 14 shutdown -- by the Staff. 15 DR. APOSTOLAKIS: Do you plan to come before this 16 committee as you review these initiatives or after you 17 approve them? Are we going to see the process at work? 18 MR. REINHART: My expectation is that as the 19 improved standard risk-informed tech spec work goes on that 20 there would be periodic visits to the ACRS. 21 Let me as, Tech Spec Branch. 22 MR. BARRETT: Always. 23 MR. REINHART: Yes. That's the expectation. 24 MR. BECKNER: I think that is a good question. I 25 said earlier that we would definitely put this out for . 296 1 public comment, and it is a good question. 2 Does the committee want to also -- you obviously 3 can see them, but do you want to be explicitly asked to 4 review them? I think we would like to hear -- 5 MR. MARKLEY: I think the committee needs to 6 decide that today. That's part of the mission of this 7 subcommittee is to, you know, sort it through whether they 8 want to evaluate the risk assumptions and analysis that goes 9 with each one of these proposals and which ones of the 10 meetings they want to set up down the road and whether it 11 even goes to the full committee or whether they just keep it 12 in the subcommittee for awhile. 13 DR. APOSTOLAKIS: So at the end of today's 14 meeting we will discuss it with our members what the 15 recommendation to the full committee will be. Okay. 16 But the Staff is willing to come and talk to us? 17 What did you say? 18 MR. BARRETT: Always. 19 MR. MARKLEY: Barrett is the ultimate politician. 20 [Laughter.] 21 MS. MAHLER: The next initiative is associated 22 with what you do when you find a missed surveillance. 23 Today in current tech specs when a Licensee finds 24 that they have missed a surveillance, they have 24 hours to 25 perform the surveillance and in that 24 hours, depending on . 297 1 what the surveillance is and that kind of stuff, you may 2 have to write special procedures. You may have to call in 3 your maintenance people, get your plan together, get it 4 approved, and also perform the surveillance. 5 If you don't get it within that 24 hours and/or in 6 some case try and get an NOED, if you don't do it within 7 that 24 hours then you have to declare the LCO not met, 8 enter the actions, and proceed down that way. 9 Generic Letter 8709 indicated in the vast majority 10 when you do find a missed surveillance that when you finally 11 do perform it that the surveillance is passed, and in 12 looking in current Licensee performance that still holds the 13 case. 14 The concept is to allow the Licensee to have time 15 if they find a missed surveillance to systematically look at 16 when is the first reasonable opportunity, and that 17 determination of reasonable opportunity includes the 18 consideration of risk if it is a surveillance that you would 19 actually have to change mode to perform and that kind of 20 stuff, is that the appropriate thing to do balancing the 21 importance of that particular surveillance. 22 One thing I do want to emphasize is that missing 23 these surveillance and that kind of stuff does not happen 24 very often. Typically what it is when you are going through 25 the paperwork and comparing it in detail to the specs, you . 298 1 may have had to look at five contacts and you found in this 2 particular case that you only looked at four, and those 3 kinds of things. It is not just that you did not perform 4 the surveillance. That is Concept or Initiative 2. 5 The next initiative hast to do with mode restraint 6 flexibility. Again, current tech specs in some cases does 7 not allow you to go into a mode of applicability without 8 having the LCO met, but if you were at power and all of a 9 sudden a particular component went inoperable, you are 10 allowed to stay in that mode for a certain period of time 11 defined by the actions, so what we are looking at is to 12 allow a Licensee to value the risk of going up in that 13 particular mode and if it is acceptable enter the mode and 14 go ahead and enter the associated action. 15 You were talking about examples of cost savings. 16 In the November meeting with the Staff we provided a couple 17 of examples, and in this particular case there was a CE 18 plant that had containment spray pump that was inoperable. 19 Everything else was going along fine. Everybody was working 20 to get the plant online. The containment spray pump -- they 21 were doing some repacking on it, which it was the best place 22 to do that was in Mode 4 before they proceeded up to Mode 3. 23 However, there were a few difficulties with that, and in the 24 November meeting we showed that we potentially could have 25 saved 48 hours worth of critical path time on the outage, . 299 1 which equated to $2 million, so there are a couple of 2 examples in the November meeting minutes on cost saving 3 relative to both Initiative 2 and Initiative 3. 4 DR. SEALE: If I could make a comment on the 5 Initiative 2. You earlier stated that this wasn't a regular 6 occurrence. It was relatively rare. I might suggest that 7 the reason it is relatively rare is that no one wants to go 8 through the black and blue spots associated with declaring 9 that a limiting condition of operation has not been met, and 10 so you make sure you get these things done, and the question 11 then is if you make this modification are you getting rid of 12 the goad that pushes you to do these things at the time and 13 I don't expect you to say anything about it right now. 14 It is just that that is the kind of question that 15 might come up. 16 MS. MAHLER: Obviously when you miss a 17 surveillance with the new reactor oversight program and all 18 that stuff and even before then we would be entering that in 19 our corrective action program, and if trends were showing up 20 it would manifest itself in there. 21 MR. HARRISON: I would add that you are still 22 going to have to some extra planning and work that you 23 weren't otherwise going to have to do. 24 We do these things in a very structured manner. 25 DR. SEALE: Sure. . 300 1 MR. HARRISON: And I really think that will be the 2 case. 3 MS. MAHLER: Initiative 4 has to do with 4 risk-informed allowed outage times. The first portion of 5 that the industry has been and will continue to submit 6 individual AOT extensions utilizing the risk Reg. Guides. 7 Successes have been diesel generator allowed outage times, 8 LPSI pumps, safety injection tanks, and where possible, why 9 those typically come in on an Owners Group basis, individual 10 industry Owners Groups are sharing that information to 11 maximize our benefit there. 12 The second portion, the concept is that the 13 allowed outage times in the specifications would be 14 dependent upon information from the risk management program 15 with a not to exceed time limit. This is certainly one 16 place where (a)(4) and the tech specs, we are looking at 17 bringing the things closer together there. 18 DR. APOSTOLAKIS: So what exactly does 4b mean, it 19 would be dependent on information from the risk management 20 program? 21 MS. MAHLER: To give you an example, if your 22 condition required action, then completion time would look 23 something like this. Pump A is inoperable, your required 24 action would be restore pump A to operable status. Your 25 completion time would be something of the nature of as . 301 1 determined by the risk program and 30 days from discovery of 2 failure to meet the LCO. 3 So you would basically have, if your risk 4 management program said, for the configuration that the 5 plant is in at that particular time, you needed to restore 6 it within seven days, then you would need to restore it 7 within seven days. If your configuration risk management 8 program said you could potentially have that out for 60 days 9 with the configuration that you are in, then the not to 10 exceed limit of 30 days would say you still had to have it 11 restored within 30 days. 12 DR. APOSTOLAKIS: And how would the not to exceed 13 limit be determined? 14 MS. MAHLER: That would be by the risk management 15 program, similar to the (a)(4) and the configuration -- 16 DR. APOSTOLAKIS: No, but I mean you just said 17 that the risk management program might say 60 days is okay, 18 but the not to exceed limit might be 30 days. So I was 19 wondering where the 30 days came from. 20 MR. DENNIG: One of the things that Mark Reinhart 21 mentioned earlier in a balanced review of these things, I 22 think he touched on the need for the time. Part of what 23 goes into this is a justification. If previous experience, 24 repair experience with a particular piece of equipment would 25 show that you can do a total repair/replace, whatever, the . 302 1 most it has ever taken is 15 days or 20 days or whatever, 2 that there is no practical reason to push it out 3 significantly beyond what experience has shown is the needed 4 envelope to get the equipment restored. 5 So as far as factoring in where does that 30 days 6 backstop come from, I think operating experience and the 7 actual evolution that is being envisioned, given the state 8 of the plant, of the equipment, circumstance comes into that 9 determination. 10 DR. APOSTOLAKIS: Why would this be so important 11 in this case? I mean if the risk management program says 12 that 60 days can be allowed without increasing risk, I mean 13 you are bringing now into the argument a separate kind of 14 thinking. You are saying, well, you know, we really don't 15 want it to go beyond 30 days, and we have observed in the 16 past that within that time period, all these activities have 17 been completed, but they have been completed under 18 assumptions on the part of the licensee, which now we are 19 changing. I thought you would give us a defense-in-depth 20 kind of argument. 21 MR. HARRISON: I can give you a little bit of a 22 risk insight kind of argument. Your risk management program 23 is going to be looking at the configuration of the plant at 24 that moment in time, which may be at that moment in time 25 very -- maybe pristine, that you have completed all your . 303 1 maintenance, everything is 100 percent operable and so 2 forth. So, based on what your risk management program looks 3 at that point in time, it says 60 days is fine. Well, over 4 the course of that 60 days, the configuration of that plant 5 may change, something else may change state or 6 what-have-you, so that is another thought of looking at a 7 shorter backstop time, it kind of, in a sense, takes into 8 account the changes in state that may occur. 9 DR. APOSTOLAKIS: But it seems to me that it would 10 be a good to determine these limits also using risk 11 arguments. 12 MR. BRADLEY: Yeah, just to reinforce your point, 13 I mean the point Wayne made, if you have an emergent 14 condition of a change in mode, or what-have-you, that 15 changes the risk evaluation you previously made, the (a)(4) 16 guideline is going to require you to reassess that. So that 17 is -- in my mind, I mean would tend to agree with you that 18 this would seem to be arbitrary. I mean the (a)(4) guidance 19 we developed certainly doesn't include imposing some 20 additional time limit beyond what all those insights are 21 telling you. I think this is something worth further 22 discussion. 23 DR. APOSTOLAKIS: Yeah. I mean if we are to 24 change things, I think we should be careful not to inject 25 into the new process bad elements from the past. So if . 304 1 there is a risk argument to be made, or as Mr. Harrison just 2 said, other considerations, I think there should be some 3 reason why a particular limit was chosen. And, in fact, I 4 mean based on risk arguments, you may not even have a limit 5 for every single AOT. 6 MR. BRADLEY: This is also an example I think 7 where the (a)(4) type approach, the risk management approach 8 is a much smarter way to address AOTs than tech specs, 9 because tech specs looks at AOTs individually, it is not 10 looking at cumulative risk. The (a)(4) evaluation of the 11 configuration risk management program is looking at it in a 12 much more integrated fashion and there is really, as you 13 know, nothing in tech specs to preclude you from repeatedly 14 entering an AOT, whereas, under the (a)(4) program, you do 15 have to consider that impact. So it is just a smarter way 16 to go. 17 MS. MAHLER: As we talked earlier, Initiative 5, 18 the concept here is basically to optimize the surveillance 19 requirements that are in the tech specs, and that is broken 20 into two parts. The first part includes relocating out of 21 the tech spec some of the surveillance requirements, and 22 then relocating the surveillance test intervals out of the 23 tech specs to a licensee controlled program such that the 24 surveillance test intervals could be modified based on risk. 25 And this is very similar to what has been done in . 305 1 risk-informing the IST intervals. 2 DR. APOSTOLAKIS: Excuse me, let me go back to 3 Initiative 3. Would that be a candidate for the second 4 class that I mentioned earlier, where we cannot really 5 quantify the impact to risk -- on risk? 6 MS. MAHLER: In some cases, you may be able to 7 quantify it, in other cases, you may not. It all depends on 8 what the nature of the component is that is out. In the 9 particular example we showed in the November meeting for 10 containment spray, the people were able to, for the purposes 11 of the meeting, run some risk numbers and show that it was 12 extremely small. But there may be other cases for 13 components in the tech specs that you wouldn't be able to 14 quantify them. 15 DR. APOSTOLAKIS: But in all other initiatives, it 16 seems that we can quantify it, is that correct? 17 MS. MAHLER: You may have some difficulty on the 18 missed surveillance one. 19 DR. APOSTOLAKIS: Yeah. 20 MS. MAHLER: Issue 2 and -- 21 DR. APOSTOLAKIS: Well, okay, probably not, but -- 22 MR. HARRISON: The missed surveillance was similar 23 to what Mark Reinhart was talking about earlier where some 24 of the initiatives, you can sort of quantify on the front 25 end, but others, it is really you do the quantification or . 306 1 the judgment perhaps on the back end after implementation. 2 MS. MAHLER: Initiative 6 is similar to Initiative 3 1 in that the current technical specifications have buried 4 within, if you will, the original presumption that if you 5 came up on a condition not covered by the actions, or you 6 lost function, or as you were directed by the spec, that the 7 safest thing was to commence a shutdown within an hour. The 8 concept of this initiative is basically to allow time to 9 initiate and develop a risk-informed course of action if you 10 find yourself in a situation where you have lost function or 11 you don't have a condition in the specifications already 12 specified. And this is where potentially you are talking 13 about a risk decrease again in implementing this concept. 14 And Initiative 7 is basically to provide 15 appropriate actions for equipment that is inoperable but 16 still functional. 17 DR. APOSTOLAKIS: Can you elaborate a little? 18 MS. MAHLER: In some cases you may find where 19 there is what we refer to as a paper problem and/or it may 20 have missed, its surveillance acceptance criteria was 61.1 21 and you found yourself at 61.1. -- you know, 61.15 kind of 22 thing, where there are still conservatisms in that set point 23 or in that particular acceptance criteria, and so you know 24 you are still functional, but from the way the tech specs 25 are set up, you are necessarily fully operable. . 307 1 DR. APOSTOLAKIS: And how will these appropriate 2 actions be determined? 3 MS. MAHLER: This is one that is still in the very 4 conceptual stage. 5 And now I will let Wayne talk about the fully 6 risk-informed specifications. 7 DR. APOSTOLAKIS: So long-term here means beyond 8 '03, 2003, is that what it means? 9 MR. HARRISON: Yes, sir. 10 DR. APOSTOLAKIS: Okay. 11 MR. HARRISON: Sharon talked about conceptual. 12 Certainly, the long-term intiative the fully risk-informed 13 technical specifications is very conceptual at this point. 14 We have just barely started to put pen to paper on it. And 15 it essentially builds on the 4b initiative which is the one 16 we just discussed that had the backstops, if you will. In 17 the case, the limiting conditions for operation would be 18 dictated by the plant specific PRA safety functions. This 19 is a situation where I think we would envision this as 20 probably not having a backstop implemented or involved. 21 I think the key point to the LCOs being dictated 22 by the plant-specific PRA safety functions is that they are 23 not necessarily driven by the design basis accident as we 24 know it now, it is really to look at the risk significance 25 of that particular state. . 308 1 The plant's risk management program would control 2 the allowed outage times at the system or train level, and I 3 think that, again, is consistent with the implementation of 4 (a)(4) of the maintenance rule. And Dr. Apostolakis asked, 5 well, how is this different or how is from our existing tech 6 specifications? And I think it preserves or improves our 7 existing level of safety. But it is going to be defined, as 8 we mentioned earlier, or these states would be defined by 9 the core damage probability, and that might be defined by 10 the core damage probability on a yearly basis or on a weekly 11 basis, where you would quantify the plant risk. 12 Our actions would be specified based on a risk 13 criterion in traditional engineering. Certainly, it is 14 going to be -- there would be some things that we are still 15 trying to identify as to how we would handle them under risk 16 and maybe they won't be, for instance, the safety limits of 17 the technical specifications, where you specify, well, you 18 will never have your reactor coolant system go over 27 -- I 19 think it is 2735 PSI. And I think the other things that we 20 keep within the -- we would probably keep the limiting 21 safety system settings like the reactor trip set points and 22 so forth. And perhaps we would look at keeping the activity 23 within the reactor coolant system at a certain level, 24 because these sort of form a foundation or an underpinning 25 of your basic assumptions that are not necessarily . 309 1 risk-informed, although I may stand to be corrected as we go 2 through and actually do this evaluation. 3 DR. APOSTOLAKIS: A question. Can you give us an 4 example of something that you will be able to do when you 5 have fully risk-informed specifications that you will not be 6 able to do, assuming that all seven initiatives are 7 approved? 8 MR. HARRISON: Well, that is a good question, 9 because if you said except for -- 10 DR. APOSTOLAKIS: The only ones we ask you. 11 MR. HARRISON: Well, that is why we are here, so 12 we can get these good questions. If you could say the first 13 six initiatives, I can answer that question. 14 DR. APOSTOLAKIS: Oh, this is the seventh, I'm 15 sorry, the first six. 16 MR. HARRISON: The first, well, this is -- no, 17 this is Number 8. 18 DR. APOSTOLAKIS: Or 8. 19 MR. HARRISON: And there may be some -- and that 20 will, that was what I mentioned earlier, that we need to 21 look at the incremental improvement over the 4b initiative 22 on the other risk-informed allowed outage times. This, how 23 much, what can you do with this that you wouldn't be able to 24 do with that? I think the answer to that is, well, you are 25 not going to have a backstop that you have to contend with . 310 1 probably, but I don't know how of benefit that would be. 2 DR. APOSTOLAKIS: That limit we discussed. 3 MR. HARRISON: Right. Or the limit we discussed. 4 DR. APOSTOLAKIS: Okay. That doesn't sound like a 5 major change. 6 MR. HARRISON: Right. But what this will allow 7 you to do over the other seven is that it really lets the 8 licensee manage the configuration of the plant. With this, 9 I think it is really hard for me to envision a situation 10 where we would ever have to go back to the Nuclear 11 Regulatory Commission and request enforcement discretion for 12 technical specifications, if the licensee were to implement 13 this, because the risk management program basically tells 14 him where he needs to be. 15 DR. BONACA: But still, I mean you would have -- 16 you are assuming a world where you still have your accident 17 analysis in the FSAR, that represents the phases, that comes 18 in the tech specs as initial conditions. You have your 19 safety system settings. I mean it is in EPRI. 20 MR. HARRISON: Well, it goes beyond -- but it goes 21 beyond that in this case. 22 DR. BONACA: But I say there is a hybrid that you 23 are looking at, right? 24 MR. BRADLEY: I think this is somewhat analogous 25 to the issue, but less the difference in Option 2 and Option . 311 1 3 of Part 50. I think what we are looking for here is more 2 -- one reason this is long-term is you are probably talking 3 about rulemaking to 50.36, to look at those four criteria. 4 Here you may even be able to show that some of the things 5 that have current, you know, requirements coming out of your 6 deterministic design basis wouldn't need to be in the tech 7 specs at all, whereas, there are other things that maybe 8 aren't there that would be. It is basically just bringing 9 the tech specs fully into the realm of risk management, you 10 know, whereas, I think with the other stuff, you would have 11 some vestigial framework of what you have now. 12 And you can't really change that until you change 13 50.36 because you are required by the first three criteria 14 to have specs for all your design basis considerations. 15 DR. APOSTOLAKIS: Do the first seven initiatives, 16 do they affect safety margins at all? In terms, you know, 17 of the safety limit. 18 MR. HARRISON: I think we would say, no, they 19 don't. 20 DR. APOSTOLAKIS: No. Would the fully 21 risk-informed specifications do that? You will start 22 attacking now other areas? 23 MR. HARRISON: Yes. 24 DR. APOSTOLAKIS: So that would be a major change. 25 DR. BONACA: It gets into Part 50. . 312 1 MR. HARRISON: It would get into Part 50. In 2 other words, as we say the DBA, or the design basis 3 accident, for instance, a double-ended break would no longer 4 be the defining event for a number of these technical 5 specifications. So would you affect the margins to that 6 particular event? Yes, but there would be certainly 7 improvements in other areas. 8 DR. BONACA: But then in the case -- it is not 9 really a changing tech spec, it is changing your FSAR. You 10 are changing your accident analysis, you are changing then 11 -- and then, because of that, then you have a step to this. 12 So that is really a jump. 13 DR. APOSTOLAKIS: This would have the fully -- the 14 long-term initiative would have to be combined with other 15 long-term initiatives like Option 3 that Biff mentioned. 16 MR. BRADLEY: Specifically, if you look at 17 SECY-264, which is the staff SECY on Option 3, there is a 18 discussion in there of Option 3 changes to special treatment 19 regulations. And I think you consider to be 50.36 to be one 20 of those. And it basically talks about just generally the 21 philosophy that things like Maintenance Rule 84 tends to 22 overlap tech specs. 23 You can change some of that in Option 2, but to go 24 to Option 3, you can fully realize that, which I think is 25 what this is all about. And there are other issues, too, . 313 1 you know, where as like the monitoring programs of the 2 Maintenance Rule can be viewed to overlap QA, where you are 3 building in the same assurance on the front end or the back 4 end, and it may be possible to integrate those two. 5 But the SECY-264, in Option 3, I think discusses 6 the type of change to tech specs that we are talking about 7 here. 8 MR. GRANTOM: George, if I could. Leading 9 directly into -- 10 DR. APOSTOLAKIS: You have to come to the 11 microphone. This is the microphone, right? 12 MR. GRANTOM: Well, leading into what Biff -- 13 DR. APOSTOLAKIS: Who are you? Who are you? 14 MR. GRANTOM: Rick Grantom. What -- this fully 15 risk-informed thing pulls in a number of regulations, and 16 Biff is talking about, into one integrated set. And what it 17 does is it allows the utility the flexibility to work within 18 a threshold, a risk threshold and that can be tied to safety 19 goals. So all the equipment, all the unavailabilities, all 20 the performance aspects are rolled into an integrated 21 pictorial view that the utility operates under a given 22 threshold. 23 Everything that you have seen on the lefthand side 24 is, in a sense, subsumed by going to this fully 25 risk-informed method, and it puts it into a context and a . 314 1 much abbreviated and shorter version. I mean we have talked 2 about these conceptual one page tech specs, but it is very 3 much abbreviated. At that point in time still conserves all 4 the defense-in-depth aspects, but now provides a pictorial 5 and actual measure of risk, quantifiable measures of risk 6 that can be used to operate a weekly threshold and, 7 cumulatively, under a yearly threshold. 8 So at this point in time, then you are getting to 9 the situation to where now you can actually start to risk 10 manage a nuclear power plant. The regulator can risk manage 11 a fleet of plants at that point in time, and this is the 12 segue that allows a fully risk-informed approach here. 13 DR. APOSTOLAKIS: So we are talking really about a 14 truly risk-informed regulatory system. 15 MR. GRANTOM: Exactly. At that point in time, 16 combined with some of the other deterministic things we 17 talked about. 18 DR. APOSTOLAKIS: Very good. Thank you. 19 MR. HARRISON: There would be very few limiting 20 conditions for operations that would be left. We mentioned 21 the safety limits. We still have to figure out what are we 22 going to do with the fuel limits. There may still be 23 limiting conditions for operations for those kind of things. 24 DR. APOSTOLAKIS: Are there any documents that 25 describe these initiatives in more detail, like you gave us . 315 1 a few example and so on, that we -- 2 MR. HARRISON: I think we had given some examples 3 of that in the handouts from the November meeting. I can 4 show you a couple of things where we basically corrected 5 some typos in those, but those are fundamentally where that 6 is at this point. 7 MR. REINHART: The two submittals. 8 DR. APOSTOLAKIS: We have not seen those, right. 9 We have not seem them. 10 MS. GILLES: Right. The industry has submitted 11 Initiative 2 and 3 to the staff for review and we are 12 working on the other ones. So, as we progress, we will be 13 submitting to the staff under the TSTF process. 14 MR. GRANTOM: Rick Grantom again. But we do have 15 conceptual slides of how this would work. It hasn't been 16 endorsed yet on the list, but at South Texas, we have 17 actually looked at some of these things with actual risk 18 numbers where one can actually postulate and show that. And 19 there is information out there that can be looked at along 20 that line. 21 MR. REINHART: Would you like copies of the 22 submittals? 23 DR. APOSTOLAKIS: Let's wait and see what the 24 subcommittee will decide to do, and at that point we will 25 decide that. . 316 1 Now, you were going back to the time here. 2 MR. HARRISON: I was going back to the timeline 3 basically to sum up, to recap. What we have gone through 4 here is a phased approach. We have seen the increasing 5 demand on the probabilistic assessment as the initiatives 6 progress. And as Biff has pointed out as we have gone 7 through here, it is consistent with the overall 8 risk-informed strategy. 9 DR. APOSTOLAKIS: Do you think we have the 10 infrastructure to implement this? 11 MR. HARRISON: I think that is part of what we are 12 doing as we go through here, Dr. Apostolakis. We are 13 developing the infrastructure. I think the infrastructure 14 exists to varying degrees at certain plants, plants like 15 South Texas and San Onofre. I think we could probably go 16 straight to Initiative 4 Bravo or even the fully 17 risk-informed technical specification. We have the 18 technology. I think the staff probably has the technology 19 to do that review. 20 Do we have the regulatory infrastructure within 21 the rules as they exist right now? No, we do not. I think 22 we can probably get to 4 Bravo within the existing 23 regulatory infrastructure. 24 DR. SEALE: I wrote myself a note here that said 25 that Biff used the word, deluge, and it was -- and my . 317 1 comment was that one man's deluge was another man's April 2 shower. 3 [Laughter.] 4 DR. SEALE: And I think that's really true. Some 5 utilities have the kind of PRA organization that could field 6 a large part of this effort rather rapidly, whereas other 7 utilities are essentially off the chart. I mean, they 8 really haven't started looking at this with any kind of 9 self-imposition of these things at all. 10 MR. HARRISON: Personally, I'm kind of speaking 11 for the rest now, since I think that some of the owners 12 groups are of the same opinion. We may be able to use 13 owners groups to address that to a certain extent, and take 14 advantage of what some plants are developing, some generic 15 applications that the others can take advantage of. 16 DR. SEALE: I have another question, and it's to 17 the staff: I notice here that there are a lot of things 18 which are being transferred to the licensee control program, 19 things that no longer would be within the tech specs or 20 whatever normally, but would rather be a surveillance 21 interval program or whatever it would be, up to the licensee 22 to control according to the ground rules. 23 That means then that those activities come under 24 the purview of the inspection program. Are you keeping a 25 list of all of the things you're dumping on the inspectors . 318 1 as you go through this? 2 Have you done a job task analysis in the old sense 3 that we did when we looked at what the requirements were for 4 a licensed operator, or an inspector that would have to live 5 in this environment? 6 And have you decided whether or not your 7 inspectors are, a) have enough time in the day, and b) have 8 the skills, personally, at the level they need in order to 9 field your half of this program? 10 MR. BARRETT: Well, I think there are a couple of 11 different answers to that question. That's one of the 12 biggest questions right now related to the entire oversight 13 process. 14 But the answer to your question is yes; as we go 15 into more and more applications regarding risk-informing the 16 regulations, the regulatory process -- I'll take this as an 17 example: Let me give you an example of decommissioning. 18 In the area of decommissioning, as we are defining 19 what we think will be the new regulatory requirements there, 20 we're trying to define specific performance measures that 21 are risk-informed, that can be monitored by the licensees 22 themselves, and can be reported to the NRC so that hopefully 23 it won't be necessarily an increased inspection burden, as 24 much as an increase -- as an effort to audit the licensee's 25 oversight and monitoring, their own monitoring and reporting . 319 1 requirements. 2 DR. SEALE: But the virtuosity of your inspector 3 has got to increase as you dump these different kinds of 4 things in his lap. 5 MR. BARRETT: That's certainly true. As I look at 6 this, for instance, we're talking about taking specific 7 surveillance test intervals. There can be a quantitative 8 basis for surveillance test intervals, and so that's 9 something that could be monitored quantitatively, possibly, 10 as Biff said earlier, through compliance with the 11 Maintenance Rule, reliability and availability. 12 There you're basically making a tradeoff between 13 reliability and availability. So it may not be as much of 14 an inspection burden as a new quantitative -- I want to use 15 the word, performance indicator, and perhaps that's too 16 grand a term to use. 17 But your concern is well understood, and you're 18 absolutely right; the skill set of the inspectors and the 19 burden on the inspectors is a very important consideration 20 in all of these areas. 21 DR. APOSTOLAKIS: Are you done, Mr. Harrison? 22 MR. HARRISON: Yes, sir, I am. 23 DR. APOSTOLAKIS: Okay, I have a few questions on 24 the meeting summaries that the staff developed, and then we 25 have to discuss the future, so I propose we take a break now . 320 1 and then come back and do it, and we'll try to finish 2 everything before 12:00. Is that all right with the 3 members? 4 How about 15 minutes? Okay. 5 [Recess.] 6 DR. APOSTOLAKIS: We are back in session. Before 7 we discuss the future course of action, I will ask whether 8 the staff has any comments to make. Mr. Barrett obviously 9 does. 10 MR. BARRETT: Mr. Chairman, we thought it would be 11 useful if we took a minute and summarized some of the major 12 messages we heard today, and make sure that we've heard what 13 you think is most important for us to know. 14 This is the first chance we've really had to 15 discuss this initiative with you, and so a lot of the issues 16 that you brought up are -- or that have been brought up, are 17 very high-level issues, and I just wanted to summarize them 18 and make sure we've covered the key ones. 19 Going back to the beginning of the meeting, we 20 heard a very strong message about the need to turn up the 21 gain on interaction with the public, interaction with 22 stakeholders. 23 We're certainly going to take a look back and see 24 whether we've done a good enough job of that up to this 25 point. But more importantly, Scott and I and others, all of . 321 1 us on the NRC management team, are committed to do that. 2 We will make the commitment now to make sure that 3 as we go forward, there is complete opportunity for all of 4 the stakeholders, including the public and public interest 5 groups, to participate at all levels in this effort. 6 The second message we got very early on in the 7 meeting was the need for us to better articulate the vision 8 that we have for this effort, and how that vision relates to 9 the strategic goals of maintaining safety, reducing 10 unnecessary burden, efficiency and effectiveness, and public 11 confidence. 12 And related to that also is to give some thought 13 to how we will measure success, what measures we will use, 14 and possibly even what criteria we would use for measuring 15 success as we move forward in this thing, to be more 16 specific, so people can monitor how well we're doing. 17 And a corollary to that was to have maybe a little 18 more discussion about the purpose and the structure of the 19 technical specifications. I don't know if the Subcommittee 20 was satisfied with that discussion today. 21 Another issue that came up and I don't think was 22 fully examined, but was something that was going through my 23 mind as I listened to some of the discussion was that there 24 -- we're pursuing a lot of risk-informed initiatives in 25 parallel. Now, this shows promise of growing into a . 322 1 relatively strong initiative. 2 It's running in parallel with the initiative to 3 risk-informed Part 50. You heard of a number of places 4 today where those paths might cross, would definitely cross, 5 and I think that we need to do a good job as we go forward 6 in articulating better and better, how these various 7 initiatives relate to each other, and tying them together. 8 And then there are a couple of issues that relate 9 to -- well, first of all, the quality of PRA, there was a 10 lot of discussion today about how PRA quality, the quality 11 of licensees' PRAs, and, I would say, the quality of 12 licensees' capabilities, because as the Chairman pointed 13 out, it's not just the PRA, it's the risk monitor. And it's 14 also the people running the risk monitor. 15 So how that relates to each of the levels we're 16 going to step up into here, even the final level, Level 8 or 17 Option 8, Step 8, or whatever it's called, where you go to a 18 fully risk-informed framework for technical specifications. 19 It's not only important that the licensees have 20 the capability, but it's important for the staff to be able 21 to put a stamp on that and say that we have confidence in 22 the capability and we can assure the public that we have 23 confidence in the capability. 24 That's the challenge that we have in front of us. 25 Finally, the last message that I have written down here is . 323 1 the question related to infrastructure, the NRC's 2 infrastructure, and that is what capabilities, what 3 challenges does all of this represent for the staff in terms 4 of our methods, our staff, our training, our inspectors, and 5 that we need to keep that in the forefront of our minds and 6 make sure that that doesn't become a limiting issue for this 7 issue and other risk-informed issues. 8 Those were the main messages I think I heard 9 today, and have been discussing with some of the other NRC 10 participants that we felt we heard. Are there any comments 11 or questions or additions? 12 DR. APOSTOLAKIS: Good summary. The industry 13 group, Mr. Bradley, Ms. Mahler, Mr. Harrison, Mr. Hook, do 14 you have any final comments? You don't have to have some, 15 but if you do, we'll hear them. 16 [No response.] 17 DR. APOSTOLAKIS: No? Any members of the audience 18 who would like to say anything? 19 [No response.] 20 DR. APOSTOLAKIS: Members of the public? 21 [No response.] 22 DR. SEALE: Can I ask a question? 23 DR. APOSTOLAKIS: And now we're coming to you. 24 [Laughter.] 25 DR. SEALE: How can we anticipate how big or how . 324 1 intensive this effort is going to be over, say, the next 2 year or so, as we try to figure out how we integrate our 3 interests and suggestions into this program? We need to 4 know what kind of effort we're talking about. We need to 5 know how many Subcommittee meetings we're going to hang on 6 Sam here. 7 DR. APOSTOLAKIS: This is definitely something we 8 want to follow, right? 9 DR. SEALE: Right, I think there's no question 10 about that. 11 DR. APOSTOLAKIS: And it's very, very important. 12 Now, there are already two initiatives that have been 13 submitted to the staff. 14 I think that related to Dr. Seale's question is a 15 question of how many Subcommittee meetings we want to have, 16 at which point do we go to the full Committee, at which 17 point do we write the letter? 18 Do we want to write an interim letter at some 19 point, raising perhaps a few issues or praising people. I 20 mean, we can write letters that say a job well done. 21 Let's see, in terms of the effort, what can you 22 tell us today about how fast do these things move? 23 You have those two initiatives, and what are the 24 plans? 25 MS. GILLES: Nannette Gilles from the Tech Spec . 325 1 Branch. I think if you looked at the industry's vision 2 slide, you see that over the next two years, they're 3 planning to pursue basically the first four initiatives. 4 So I think that those would be our area of 5 concentration to our inhouse and, I think, the next two will 6 be coming in probably sometime next year, closer to the 7 middle of the year. 8 And I think our review process, we are, as we 9 mentioned earlier, planning to implement a new process for 10 review of changes to the standard tech specs that actually 11 would involve a public comment period and things like that. 12 So we are kind of working on the timeline for that 13 process now. 14 DR. APOSTOLAKIS: Now, you have already two 15 initiatives, right? 16 MS. GILLES: Yes. 17 DR. UHRIG: Are these specifically individual 18 utilities, or are these owners groups? 19 MS. GILLES: These are changes to the standard 20 technical specifications for all owners. 21 DR. UHRIG: All owners? 22 MS. GILLES: Yes. 23 DR. SEALE: Do you expect that there might be a 24 trailblazer effort by someone in the same vein as we had the 25 pilots in some of the other areas? Would you expect a pilot . 326 1 or a group to move forward with, say, five or something like 2 that? 3 MS. GILLES: San Onofre has identified that they 4 are willing to be a pilot for many of the initiatives, and 5 I'll let either Tom or Sharon address that -- six of the 6 seven, so San Onofre has identified them. 7 DR. SEALE: And that would be earlier than this -- 8 it would still be within this two-year time period that 9 she's talking about? 10 MR. HARRISON: That's correct. This is Wayne 11 Harrison, South Texas Project. In response to Dr. Seale's 12 question, we would -- STP will expect to be submitting some 13 or our risk-informed technical specification changes. We 14 had not yet submitted our improved technical specifications, 15 and I think we're going to look at going to something along 16 the lines of the four Bravo initiatives or perhaps a little 17 step closer toward the risk-informed to see how far we can 18 go without challenging the -- having to request an 19 exemption. 20 Maybe we'll request an exemption. We've been 21 rumored to have done that before. 22 DR. SEALE: Well, the pilots are certainly have 23 proven, I think, to be an effective way to look at these 24 things. And I would like to see us go that way. 25 MR. HOOK: Tom Hook from San Onofre. I have a . 327 1 match with executive level commitment to pursue as a pilot, 2 the first six initiatives. However, to pursue those in 3 concert with the joint NRC/Industry Task Force, and just to 4 process. 5 So we'll be following with plant-specific 6 submittals as soon as the process works for those particular 7 six initiatives. 8 DR. APOSTOLAKIS: Okay, let me ask the staff, when 9 do you think would be a good time for you to meet with the 10 Subcommittee again regarding the Initiatives 2 and 3, and 11 then go to the full Committee? -- 12 MR. DENNIG: Okay, we've got 2 and 3 inhouse. 13 We're basically doing the turnover to the technical review 14 apparatus, which is fundamentally the Risk Assessment 15 Branch. We are expecting additional materials from the 16 industry in support of those submittals. 17 The reason for that is because we've stepped this 18 up a notch during the public comment. We expect to write a 19 safety evaluation. Historically in this process, we haven't 20 done all those things. 21 So, how quickly our review moves is somewhat 22 dependent on that additional information, and perhaps 23 contingent on that, someone from Risk Branch would speculate 24 on the range of times that we might be looking at to make 25 some progress on those submittals. . 328 1 MR. REINHART: Not having received the submittals 2 yet and having the opportunity to look at them, I wouldn't 3 -- I don't know exactly, but I'm going to throw out -- and 4 shoot me if you want -- that we don't have to be through 5 them before we come here; we can just get familiarized with 6 them, and come and talk. 7 So probably, would early February be a reasonable 8 timeframe? Or is that too soon? 9 MS. GILLES: Six months. 10 MR. REINHART: Do you want to make it six months? 11 DR. APOSTOLAKIS: Well, if you want us to come 12 into a work-in-progress, so you will have a chance to adjust 13 the way you're going based on our comments, then we should 14 do it before you finish your SER. 15 MR. MARKLEY: The ideal time, I think, is at the 16 draft SER stage where you haven't finalized it but you're 17 willing to share what you plan to do with it. 18 MR. REINHART: Let's go for April. 19 DR. APOSTOLAKIS: Okay, and then perhaps we can 20 schedule or try to schedule a meeting with the full 21 Committee at the May meeting. 22 MR. MARKLEY: Right. 23 DR. APOSTOLAKIS: Okay. 24 MR. MARKLEY: Just to ask also, this is going to 25 compete with other activities, and Part 50 is just one of . 329 1 them, and license renewal and lots of other things, so if 2 there is some way we can get a more integrated schedule than 3 this block of a two-year time period or whatever it is 4 you're dealing with, or one year, how each one of these is 5 probably going to sequence in, and when it might be best to 6 fit it into what we have would really help a lot. 7 MS. GILLES: That's something we're going to have 8 to come up with. 9 MR. REINHART: Before we leave this first 10 submittal, I want to really caveat that. I'm proposing that 11 we'll show up in April where we are. 12 We might be at the draft stage, we might be 13 getting more information. 14 DR. APOSTOLAKIS: That's fine with us. 15 MR. REINHART: We want your input. 16 DR. APOSTOLAKIS: Okay, now, something related to 17 an earlier discussion: Since San Onofre would be a pilot 18 for six of these initiatives, when do you plan to look at 19 their risk monitor and the models and make a judgment? 20 That's not going to be a trivial thing. 21 MR. REINHART: I think that's a good question, and 22 I think we need to give an answer to it, but I don't know 23 what we're ready today. 24 DR. APOSTOLAKIS: Is it part of reviewing 25 Initiatives 2 and 3, or you're going to have a separate task . 330 1 for that? 2 MR. BECKNER: This is Bill Beckner. I don't think 3 we would do that as part of these first two initiatives. I 4 think we would try to approve these based on generically 5 coming to risk conclusions, along with whatever 6 plant-specific things we would have to with a plant-specific 7 amendment. 8 DR. APOSTOLAKIS: If it's plant-specific, though, 9 and they rely on their risk monitor -- 10 MR. BECKNER: No, these first two, I don't think 11 -- 12 DR. APOSTOLAKIS: They don't? 13 MR. BECKNER: No, they would not rely on it. 14 DR. APOSTOLAKIS: What are they again? 15 MR. BECKNER: These would have to rely on insights 16 where we could say they're generically applicable. 17 DR. APOSTOLAKIS: That's fine. 18 DR. SEALE: Do we want to see their risk monitors? 19 DR. APOSTOLAKIS: I don't know. I mean, that's 20 looking at the screen. 21 DR. UHRIG: The alternative is to have some sort 22 of presentation, either by one of the utilities or perhaps 23 the vendors. 24 DR. APOSTOLAKIS: That's good, that 2 and 3 do no 25 rely on an extensive review of the risk monitor, but it . 331 1 seems to me you ought to start planning for it now, so when 2 the other initiatives come, you will be in a better position 3 to judge. 4 Now, Mr. Hook told us that the PRA, which I assume 5 is a basis for the monitor, has been reviewed. Has the 6 models of the monitor itself been reviewed by peers? 7 MR. HOOK: The answer is -- this is Tom Hook -- 8 the answer is portions of the model have been reviewed by 9 peers. The risk monitor model that we have is based upon 10 our IPE and IPEEE with enhancements to make it more useful 11 and more specific to risk monitoring. 12 And those models are going to be undergoing 13 certification by the CE Owners Group early next year, as 14 well as those models are being utilized by our contractor as 15 the basis for other risk monitor models of other similar 16 types of plants, and are being reviewed by those other 17 plants. 18 And the Combustion Engineer Owners Group, we have 19 a cross-comparison activity where we compare initiating 20 events and major contributors to risk from all the 21 Combustion Engineering PRAs as a means to ensure consistency 22 and validity, and that there are no major mistakes in any of 23 the PRAs that would produce invalid results. 24 So it's been subjected to that type of review at a 25 relatively detailed level over a number of years. . 332 1 DR. APOSTOLAKIS: Okay, that's good to know, but 2 still the staff has to somehow convince itself that the 3 result of this process is acceptable for the intended 4 purpose. 5 So it seems to me you ought to plan for something 6 like this in addition to the six or seven initiatives you're 7 going to get. And the Committee is certainly interested in 8 this. 9 DR. SEALE: In line with Mr. Markley's remarks, 10 too, about this not being the only thing that's going on, 11 this question of keeping sort of a cumulative score of the 12 kinds of things that will impact on the inspection and plant 13 evaluation process, so that we don't suddenly wind up one 14 day realizing that we've got a problem that we hadn't 15 anticipated, I think would be something that we'd like to 16 hear about occasionally, that, as of now it looks like these 17 are the things that have changed, and these are the things 18 that are going to be necessary in order to keep track it and 19 that sort of thing. 20 MR. REINHART: If I could address two pieces that 21 you brought up there, the second one, programmatically, 22 licensees that have risk-informed improvements are supposed 23 to be required to keep a cumulative track of changes to 24 their risk. 25 DR. SEALE: Okay. . 333 1 MR. REINHART: So you have to be able to see what 2 it is to tie it in. At the same time, we're developing a 3 database to do that for ourselves so that that should 4 provide a basis for that information. 5 The second piece: I was just talking with Rich 6 Barrett. We recognize we need to come up with an approach 7 and a structure to review PRAs. And so we need to, without 8 making a commitment as to exactly how we're going to do 9 that, we need to pursue that. 10 Likely, in the sense SONGS is going to be a pilot 11 and we're probably going to learn -- 12 DR. APOSTOLAKIS: There are two things you have to 13 review, the PRA and the monitor. There are differences and 14 there are sometimes important ones. 15 MR. REINHART: I see what you're saying. 16 DR. APOSTOLAKIS: If they propose to use the risk 17 monitor, then you really have to review the risk monitor, 18 not the PRA. 19 MR. REINHART: I think if I understand Tom, the 20 PRA is the basis for the monitor, and then the monitor, 21 i.e., the process, the program for evaluating risk. 22 DR. APOSTOLAKIS: Well, there are non-trivial 23 changes that they want us to make to the PRA in order to 24 make it real-time risk monitoring, so I think the staff 25 should be aware of it. . 334 1 MR. REINHART: Okay, good point. 2 MR. LEVISON: Stanley Levison. In talking about 3 whether to or how to evaluate the PRA, it seems that the 4 staff has two things to review: One is the actual process. 5 Regardless of what the PRA looks like, you're going to be 6 looking at the process for evaluating these things. 7 Irrespective of whether you have the mechanism to 8 look at the PRA or not, you can endorse through an SER, a 9 process of how the utility should submit something without 10 even looking at the quality of the PRA and set up the 11 framework for that. 12 Then, of course -- and I'm not saying that it 13 doesn't need to be done -- then separate SER document 14 process for how you are going to deal with the PRA quality. 15 So if you haven't finished how you're going to do the PRA 16 quality issue, that wouldn't impact the ability to review 17 and look at how the tech spec changes are done. 18 And Dr. Seale, concerning the issue about 19 cumulative changes in risk and the certification process and 20 the ASME standard, both address those items in requiring the 21 utilities -- said the NRC requires them, but the utilities 22 themselves are aware that there are, you know, cumulative 23 changes as they do risk-informed activities, and as they 24 change their PRA, some of them actually have procedures in 25 place that require them to go back and reevaluate the . 335 1 applications that they've done to make sure that changes in 2 the plant that might change the PRA doesn't change, the 3 results that they go when they used that to support an 4 application. Thank you. 5 DR. SEALE: Thank you. I want to make a note that 6 I'm also concerned about the cumulative changes in the 7 regulatory process that accrue to these changes. 8 MR. BARRETT: If I could just comment on that and 9 raise a question? I believe there was talk about meeting 10 with the Subcommittee on the subject of possible barriers. 11 I forgot what the word was. 12 DR. APOSTOLAKIS: Impediments. 13 MR. BARRETT: Impediments to the implementation of 14 risk-informed strategies, and that that might be scheduled 15 in February. 16 MR. REINHART: It is. 17 MR. BARRETT: I think that some of the issues 18 you've brought up today about the impact on staff resources 19 and training, questions related to staff assurance of PRA 20 quality and quality of PRA methods, might be good topics to 21 discuss at that meeting. 22 DR. APOSTOLAKIS: Dr. Uhrig, do you have any 23 comments to make now? 24 DR. UHRIG: Well, I have a continuing interest in 25 the predictor, the PRA meter. As I told you at the break, . 336 1 15 years ago, we played around in Jerry Fussell's simulator 2 of a PRA on an IBM XT as I recall, or AT. And the results 3 were rather fascinating, although probably not very valid. 4 But I would be very interesting in getting up to 5 date on what's going on and finding out more about it. I 6 actually corresponded with Mr. Hook on this on a couple of 7 occasions. 8 It seems to me, though, that there are, what, 9 three vendors that provide these now? Scientech, PLG, and 10 SAIC. It might be useful somewhere along the line to get a 11 picture of how they operate, how they differ, what the 12 features of these are. That might ge a subject for a 13 Subcommittee meeting at some time in the not-too-distant 14 future. 15 And it might be joint with the INC part of the 16 ACRS. So maybe we'll think of that as a joint Subcommittee 17 meeting. 18 DR. APOSTOLAKIS: Before I forget, Mark, I said 19 earlier that we have to review both risk monitor and the 20 PRA. Several of our comments that would apply to the 21 changes from the PRA to the risk monitor or PRA in the 22 October letter on risk-informed Part 50 in connection with 23 the risk achievement worth measure, because there you change 24 a component. You assume it's down, right? So it's a very 25 similar situation with a configuration change. . 337 1 And we raised a few concerns, gave a few 2 references, so that would be a good place to start to 3 understand where I'm coming from. 4 MR. REINHART: The ACRS letter? 5 DR. APOSTOLAKIS: The ACRS letter to the Chairman 6 on risk-informing Part 50. 7 MR. REINHART: Right. 8 DR. APOSTOLAKIS: Okay? 9 MR. REINHART: Okay. 10 DR. APOSTOLAKIS: Dr. Bonaca? 11 DR. BONACA: First of all, in general, I think 12 that this is a great initiative, just 20 years late. 13 [Laughter.] 14 DR. BONACA: But I think it's great that it's 15 taking place. Now, there are a number of points: One is 16 that in many cases, really these are improvements to the 17 current tech specs. They're not really evolutionary in any 18 way, just because current tech specs have a lot of -- for 19 example, AOTs, they have no basis oftentimes. And so 20 finally we have a technology that we have had for awhile, 21 and we can use it to put a reasonable time into tech specs, 22 and that's just an improvement. 23 I wouldn't sell it is as risk initiative, it's 24 just an improvement that is there. 25 In some other cases, like for example, Initiative . 338 1 Number 7, I would like to hear more in the next presentation 2 about how you go to talk about functional. I don't 3 understand that. 4 I mean, functional versus operable seems to me 5 that we're talking about functional and you're still going 6 in a deterministic way, and maybe you have some ideas about 7 how probability can come in, and I would like to hear about 8 that. 9 That's a fundamental issue that it's so critical 10 we'd like to hear about what the concepts are. And maybe 11 that's too far ahead of time, because you have a couple of 12 years before you're getting there, I think, two or three 13 years. 14 The third point that I would like to make is that 15 when you talk about a one page tech spec, tech specs have 16 always been seen by the overwriters in the control room as 17 the contract, okay? -- and now there is no more contract, so 18 it would be just one sheet of paper, and I would like to 19 understand how this new world is evolving to that because I 20 think it has an impact in the control room. 21 All those commitments that the NRC has required 22 were very much taken care of -- would create attention. 23 Those that were not required, well, it was always, you know, 24 we are sorry but, well, corrective action will take place, 25 so I would like to understand how this new world is coming . 339 1 and the point the Dr. Seale brought up, that the whole 2 burden now is placed on inspection and inspection really has 3 a lifetime. I mean there is a lifetime between -- so that 4 is the third point I would like to make, that we have to 5 reflect on that. Again, I am extremely supportive of what I 6 see. 7 DR. SEALE: In that regard we have to recognize 8 and maybe even marvel at the fact that the tradition of an 9 NRC-imposed and conducted individual licensing examination 10 for licensed operators and the tech specs, which was largely 11 the basis for that examination, at least for the 12 operational, some of the operational parts of it, related to 13 an idea that the contract was personal between the 14 individual operator and the NRC -- and that was a personal 15 challenge. It wasn't a company challenge. We have to be, 16 you know -- that is an important point and we want to be 17 sure we don't lose that personal commitment that is 18 implicit. 19 DR. APOSTOLAKIS: So what you are saying it may be 20 an impact on the safety culture. 21 DR. SEALE: It could, and so we have to ask 22 ourselves what do we do to preserve that? 23 DR. BONACA: Or what do we substitute for it? 24 DR. SEALE: Yes, right. 25 DR. BONACA: Maybe commitments which are internal . 340 1 but are shared with the NRC that, you know, maintain that 2 kind of level of personal relationship -- with regulation. 3 DR. UHRIG: But I think what you are doing here in 4 many respects is shifting the guidance here over to 5 technology and the risk meter is probably a much better 6 judge of some of these outage times and other things that 7 have been in tech specs for years and years, because there 8 were some gross inconsistencies in tech specs. 9 Very often, certainly in the early days, it was 10 whatever you could negotiate that you get wound up in the 11 tech specs -- having been on the other side of the table. 12 MR. MARKLEY: That is still true. 13 DR. UHRIG: Having been on the other side of the 14 table for a number of years, the tech specs were always the 15 hardest part of getting a plant online as far as I was 16 concerned. Once you have essentially got it finished, then 17 negotiating the tech specs were a big item. 18 The guidance now is going over to a rational 19 basis, whereas before it was judgment -- 20 DR. SEALE: Irrational basis. 21 DR. UHRIG: -- and sometimes irrational decisions. 22 DR. APOSTOLAKIS: Okay. The members have finished 23 their comments? 24 DR. UHRIG: Yes. 25 DR. APOSTOLAKIS: I have a couple comments on the . 341 1 summary, for Mr. Beckner -- and Mr. Hooks. 2 It says here the industry stated during the 3 meeting of -- I don't know -- the industry stated it was 4 their general philosophy to use qualitative risk assessments 5 where they believed the benefits of a proposed change were 6 obvious and to use quantitative assessments where the 7 outcome was not obvious. 8 The Staff reserved judgment of such an approach, 9 noting that benefits that are obvious to one person or group 10 might not be obvious to another, so what does qualitative 11 risk assessment mean? Can someone from the Risk Informed 12 Technical Specifications Task Force enlighten us? 13 MR. REINHART: This is Mark Reinhart. I guess my 14 comment on that was really the thought of what might be 15 obvious to one is not obvious to the other and I would like 16 to see some proof that what is qualitative is really 17 qualitative and maybe it does need some quantitative 18 support. I don't know. 19 DR. APOSTOLAKIS: That's why I am asking the 20 industry what they mean by qualitative risk assessments for 21 cases where the benefits of a proposed change are "obvious." 22 We have a willing speaker. 23 MS. MAHLER: Willing -- maybe. In that meeting it 24 was given in the context of I believe we were talking about 25 Initiative 1, where we are talking about having a more . 342 1 resource-rich state, okay? -- for where mode hot shutdown is 2 a more resource, qualitatively -- just think about it -- hot 3 shutdown is a more resource-rich state than cold shutdown, 4 and that was the context in which we were talking about 5 that, where we have for Initiative 1 the tack that is being 6 taken right now is SONGS in their draft analysis has looked 7 at their end states and has quantified things. 8 The question, again in the context of that 9 meeting, was okay, do all of the other CE plants have to 10 quantify their transition risk, or can they qualitatively 11 assess the risk and compare it to SONGS in that manner, so 12 that was the context in which those statements were made. 13 Does that answer your question? 14 DR. APOSTOLAKIS: Well, yeah. That context was 15 not given here. It says that the context here was a 16 discussion of the meaning of the term "risk-informed" as it 17 related to regulatory applications, which is much broader 18 than what you just said, so in that context, in the context 19 that is in the writeup, it created questions in my mind, 20 although what you just said, it can be quantified, but what 21 you are saying is it is so obvious I mean let's not spend 22 time to do it. 23 DR. SEALE: Except that then, you know, there is 24 no question I don't believe but what the hot shutdown 25 situation is the more resource-intensive, as you have . 343 1 characterized it, but are the resources the same, and are 2 the resources that may not be common to both sets ones that 3 are crucial to the capabilities that you need in the event 4 of a problem. Are there things that are available with cold 5 shutdown that you don't have with hot shutdown that really 6 go to the heart of a difficulty. That is why you have to be 7 quantitative to a degree anyway. 8 DR. BONACA: That is why I think at times it is 9 hard to come from a specific insight to a generic 10 application to everybody that says, oh, sure, because I mean 11 conditions may be different, and the other thing, there is a 12 benefit in the process of quantification. The utility that 13 goes through the process of quantification understands why, 14 and typically also it reinforces those things which are 15 considered important for the quantification. It puts them 16 into guidance. It puts them into procedure. 17 For a utility to simply say all right, yes, since 18 you gave it to Plant X, this truth is applicable to all the 19 other plants -- that is not necessarily true. In some cases 20 it may be and may be obvious maybe, but -- 21 DR. APOSTOLAKIS: Okay, thank you. There is one 22 paragraph here that I think needs some attention -- 23 representatives from the South Texas Project presented a 24 concept of a fully risk-informed set of technical 25 specification that essentially relies on a configuration . 344 1 risk management program as the backbone of the technical 2 specifications. They likened the proposed risk limits in 3 their concept of radiation protection limits -- that is 4 ALARA limits. 5 The NRC regulates ALARA limits at a high level and 6 Licensees control limits at a lower level administratively. 7 The group also discussed whether there was a need for an 8 instantaneous risk cap for technical specifications. The 9 Task Force stated that the major question is the cost 10 benefit of going to this extreme. For example, if plant 11 PRAs essentially become the technical specifications, then 12 Licensees would have to control changes to the PRA model to 13 the same degree as technical specification changes are 14 currently controlled. 15 The question is why is that bad? 16 MS. GILLES: Nanette Gilles from the Tech Spec 17 Branch. 18 I don't think -- the implication was not 19 intended -- I am Nan Gilles from the Tech Spec Branch. I 20 don't think that -- the implication was not intended that 21 that was bad. The only thought there was that once you did 22 the first seven initiatives that the Task Force in general 23 had a question about whether going the next step to the 24 fully risk-informed tech specs was going to be cost 25 beneficial if you already had the benefits of the first . 345 1 seven initiatives. That was the thought that was trying to 2 be conveyed. 3 But then the example is that PRAs would have to be 4 controlled for changes to the PRA model to the same degree 5 as technical specification changes. 6 MS. MAHLER: This is Sharon Mahler again. In that 7 context the concern was you had developed your PRA, you were 8 controlling your plant configuration in accordance with your 9 PRA, and you did some other modification where you wanted to 10 enhance your PRA model. Would that then involve you going 11 back to the NRC with your full-blown model to again get 12 approval of your PRA model? 13 DR. APOSTOLAKIS: Your PRA model is the main tool 14 that allows you to reap all the benefits of going to a fully 15 risk-informed set of technical specifications. Wouldn't 16 that be a reasonable price to pay? 17 I see Mr. Grantom there willing to make a few 18 comments. 19 MR. GRANTOM: Yes. Rick Grantom, South Texas. 20 In the process of approving these types of tech 21 specs that go to that level, the process by which the PRA is 22 updated is also going to be included in that the change 23 control process has to be there, so in that regard what I 24 would anticipate that we would do is that the PRA 25 configuration control process is a part of the approval that . 346 1 happens when you go to a fully risk-informed regime. 2 Therefore, the Staff has already approved the mechanisms by 3 which we evaluate changes to the station, by which we 4 implement those changes, and the mechanisms by which we 5 implement changes. 6 I want to emphasize that rolling out a PRA model 7 is not an insignificant effort. It has to be controlled. 8 There's other risk-informed applications that are going to 9 be affected that people have to get together and meet about 10 assessing any changes, so it will be in my personal view -- 11 it should be included as part of the approval that the PRA 12 change control process is part of that approval, and it 13 would be handled in that regard. 14 DR. APOSTOLAKIS: So you are willing then to 15 accept this? 16 MR. GRANTOM: Yes -- the process, yes. I probably 17 would be hesitant to say I am going to roll out a new PRA 18 every day because somebody -- 19 DR. APOSTOLAKIS: No. 20 MR. GRANTOM: -- changed the procedure, but I 21 would be not opposed at all to be saying here is the 22 configuration control process. Every 18 months or some 23 period of time we collect data, we look at procedure, we 24 roll out a new model from that. We have in a sense an 25 effective model that is in effect right now versus a working . 347 1 model that we may be collecting changes. That process I 2 think is workable in that regard and if it is approved as 3 part of this tech spec effort there, I wouldn't be opposed 4 to that personally. 5 From a PRA manager's point of view and being able 6 to control my process it is not really any different than 7 what I am doing currently. 8 DR. APOSTOLAKIS: And that would include changes 9 in the model that are being done because the 10 state-of-the-art advances. Let's say the NRC now is 11 launching or has already launched a research project on fire 12 risk assessments, so if this comes up with something better 13 than what we have now, you have to change your model and 14 that kind of change would have to be controlled under these 15 conditions. 16 MR. GRANTOM: There's two processes involved. 17 There's internal changes, and you can liken that to 18 procedures, design modifications -- those types of things 19 that happen internal within the plant itself, and then there 20 may be external changes that occur where someone says, gee, 21 we'll handle fires differently than that. 22 As long as the process allows us to properly 23 schedule those changes and to do that, then I think it can 24 work, but there are those two facets that have to be 25 compared in. . 348 1 DR. BONACA: But you have also a significant plant 2 change process that takes place, right? 3 MR. GRANTOM: Oh, yes. That's why I said there is 4 the internal plant changes that occur. We do a 5 modification. That is all part of -- 6 DR. BONACA: Okay -- I thought you were talking 7 about the PRA -- 8 MR. GRANTOM: -- of the internal. What Dr. 9 Apostolakis was talking about is the methodology for 10 evaluating some phenomena changes. That is a little bit 11 outside -- 12 DR. APOSTOLAKIS: So they are both -- yes. 13 Am I to assume that the line that is forming here 14 is -- 15 [Laughter.] 16 MR. FRANK: If I might just comment on this? 17 DR. APOSTOLAKIS: Sure. Would you please go to 18 the microphone, Frank? 19 Tell us who you are again. 20 MR. RAHN: Well, for the first time, this is Frank 21 Rahn from EPRI. 22 DR. APOSTOLAKIS: See, that is the importance of 23 language -- "again" -- 24 MR. RAHN: I wanted to make a brief comment in 25 terms of the ASME and the PRA standard which is in the . 349 1 process of being developed and configuration control will be 2 an integral part of that PRA standard I hope that will be 3 adopted by the NRC once it is complete. Thank you. 4 MS. MAHLER: I wanted to help perhaps put it in 5 perspective. I relate it very much to the similar process 6 for the Kohler, where the Staff has approved a methodology 7 and an individual plant change you can go and revise your 8 curves that are in your Kohler and not come back to the 9 Staff for approval of those changes in those curves, but if 10 you change your methodology then you do need to come back to 11 the Staff, so that was more along the lines of what we were 12 originally thinking. 13 DR. APOSTOLAKIS: Also, as a side remark, would 14 you please stop using the word "instantaneous" risk? It is 15 conditional on that particular configuration. There is 16 nothing instantaneous about it. It is a temporary 17 situation. All risk estimates are conditional. This 18 happens to be conditional in a particular configuration but 19 it is not of long duration, because instantaneous confuses 20 people. 21 DR. SEALE: George, is it fair to say based on the 22 remarks that we have just heard that if we are going to have 23 a risk cap, we ought to get on with it and let people know 24 what it is and -- 25 DR. APOSTOLAKIS: I think we will have to face . 350 1 that, yes. Yes. 2 DR. SEALE: And we ought to do that sooner than 3 later because it has a front-end impact. 4 DR. APOSTOLAKIS: Now risk cap -- what, on CDF? 5 On what? 6 DR. SEALE: That is part of the question. 7 DR. APOSTOLAKIS: Is it a goal? I mean the Staff 8 is already working on a set of goals and I understand in 9 fact there are some exchanges with the Commission's 10 assistance yesterday. 11 DR. SEALE: Yes. 12 DR. APOSTOLAKIS: So certainly that issue will 13 come up when we discuss this, because it is a broader 14 issue -- the safety goals of the Commission. 15 Are there any other comments from anyone? 16 [No response.] 17 DR. APOSTOLAKIS: Well, silence tells me that this 18 is the end of this subcommittee meeting. Thank you all for 19 coming. It was very useful to us, and we will see you again 20 some time in April -- preferably late April. 21 [Laughter.] 22 [Whereupon, at 12:08 p.m., the meeting was 23 concluded.] 24 25
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