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May 22, 2013

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May 13, 2013 (nuclear.com) - New reactor designs have much greater safety, and this is reflected in much lower core damage frequency (CDF) values and much lower large early release frequency (LERF) values than the current fleet. Would it be appropriate to use the same kind of risk-informed reactor oversight process (ROP) for the new reactors as has been developed for existing fleet? NRC staff has developed a framework for new reactor ROP that combines risk-informed and deterministic approach. This framework was discussed at an April 15, 2013 public meeting. A pdf of the NRC project manager's meeting summary is available here.

Here's the bulk of the text of the meeting summary:

May 9, 2013

MEMORANDUM TO: Rani L. Franovich, Chief
Performance Assessment Branch
Division of Inspection and Regional Support
Office of Nuclear Reactor Regulation

FROM: Ronald K. Frahm, Jr., Senior Reactor Operations Engineer /RA/
Performance Assessment Branch
Division of Inspection and Regional Support
Office of Nuclear Reactor Regulation

SUBJECT: SUMMARY OF PUBLIC MEETING HELD ON APRIL 15, 2013,
TO CONTINUE DISCUSSIONS REGARDING APPROACH FOR
RISK-INFORMING THE REACTOR OVERSIGHT PROCESS
FOR NEW REACTORS

CONTACT: Ronald Frahm, NRR/DIRS/IPAB
(301) 415-2986

On April 15, 2013, the U.S. Nuclear Regulatory Commission (NRC) staff hosted a Category 2 public meeting with the Nuclear Energy Institute (NEI) and other interested stakeholders at the NRC’s Two White Flint North building in Rockville, Maryland. The purpose of this meeting, as noted in the meeting notice dated April 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13086A933) was to continue to discuss specific aspects of the Commission’s Staff Requirements Memorandum (SRM) to the Office of the Secretary (SECY)-12-0081, “Risk-Informed Regulatory Framework for New Reactors.” Prior meetings on the subject were held on February 5, 2013, and March 25, 2013. As a result of the meeting on March 25, 2013 (ADAMS Accession No. ML13100A226), the participants recognized the need to further discuss the deterministic aspects of the integrated risk-informed approach and the feasibility of the relative risk approach. The meeting attendance list is included as Attachment 1. The handouts that were distributed and presented by the staff are included as Attachment 2.

The staff presented a sample decision tree to illustrate a potential approach for measuring the deterministic aspects of the integrated risk-informed approach and provided a few examples. In this conceptual approach, each of the five qualitative factors currently being considered would be assigned a rating factor while progressing through the decision tree to arrive at an overall qualitative rating of not degraded, moderately degraded, degraded, or significantly degraded.

This overall qualitative rating would then be considered along with the quantitative risk rating using a significance determination table to arrive at the resultant significance/color in an integrated, structured, and predictable fashion.

As noted during the prior meeting, industry participants indicated general support for this approach and structure, but restated that if this approach were approved by the Commission then the details in the guidance and evaluation criteria would be critical. Specifically, participants noted that defense-in-depth, safety margins, and uncertainty are difficult to define, and that having a universal understanding of what these concepts mean and how they would be applied in this context would need to be clear and objective. Industry restated its concern with potential “double-counting” in the quantitative and qualitative evaluations, specifically noting uncertainty and cross-system common cause failures as examples. Industry also restated its concern that the qualitative measures seem to only worsen the outcome of a finding, and still not enough credit was being considered to potentially improve the outcome (e.g., a low White finding based on the quantitative risk analysis that becomes Green based on some qualitative credit given). The staff noted its intent to consider these concerns when drafting the paper.

Participants noted that it is important to focus resources on the most safety significant areas as an industry, and not increase inspection resources for new plants because they have lower core damage frequency (CDF) values. Industry also recommended adding an extra rating factor, such as “minor degradation,” to capture those instances where a performance deficiency could minimally degrade defense-in-depth but not to an appreciable degree. Participants also discussed the need to ensure consistency with other on-going efforts, such as Recommendation 1 from the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident and the related update to Regulatory Guide 1.174, which involve establishing an appropriate regulatory balance using defense-in-depth and risk considerations. Participants noted that this approach could work for the current fleet as well by applying current ROP thresholds in IMC 0609 Appendix A and revising Appendix M as a more structured framework for integrating qualitative considerations.

Participants then discussed the feasibility and utility of the hybrid approach to relative risk that was presented during the previous public meeting. Industry generally supported this approach if the total baseline CDF, including internal and external events (e.g., seismic, internal fires, internal flooding), is used for new reactor applications. If the total CDF were considered, the baseline CDFs for new reactors could be higher than 10-6; and since the slope changes from relative to flat at 10-6, there would effectively be no change to the existing framework when applied to new reactors. Participants concluded that the hybrid approach would essentially be the “use-as-is” option and would therefore not resolve the shortcomings noted in the ROP tabletop exercises as discussed in SECY-12-0081.

Industry then discussed the problems associated with alternate risk metrics and/or thresholds that were presented in the 2009 NEI white paper. Industry noted that while many of those problems would no longer be a concern with the hybrid approach to relative risk, some would persist. Specifically, the approach for new reactors would be different from the current approach used for operating reactors, which would be difficult to explain when communicating with internal and external stakeholders. Additionally, meeting participants generally acknowledged that the fidelity of risk tools is reduced at very low values. Consequently, prolonged analysis to achieve a higher degree of confidence in outcomes could impede timely regulatory responses to performance. For all these reasons, participants favored an integrated risk-informed approach (using deterministic factors) over a relative risk approach.

Participants agreed that additional meetings were not needed to specifically discuss this topic during the development of the SECY paper, but the staff also noted its intent to provide status updates at upcoming ROP Working Group meetings. The staff noted that a meeting has been scheduled with the ACRS Subcommittee on PRA and Reliability on July 22, 2013, and that industry will be given an opportunity to present its views. This meeting will likely be followed by a Full Committee meeting on September 5 or 6, 2013, and a letter from the ACRS to advise the Commission on this matter. The staff noted its intent to provide the ACRS with a draft version of the SECY paper prior to the Subcommittee meeting and plans to make that draft paper publicly available. The staff also noted that a public meeting will be scheduled to solicit feedback and comments from industry and the public on the draft SECY paper.

...

- - - - - end of excerpt

Here's info about the document from NRC's ADAMS database, where it was released on May 13, 2013

Accession Number: ML13126A166
Estimated Page Count: 8
Document Date: Thu May 09 2013
Document Type: Meeting Summary, Memoranda
Document Title: Summary of Public Meeting Held on April 15, 2013, To Continue Discussions Regarding Approach For Risk-Informing The Reactor Oversight Process (ROP) For New Reactors.
Author Name: Frahm R K
Author Affiliation: NRC/NRR/DIRS/IPAB
Addressee Name: Franovich R L
Addressee Affiliation: NRC/NRR/DIRS/IPAB
Keyword: axw7, nxp, SUNSI Review Complete, utsPARS
Related Date: Mon Apr 15 2013
Comment: cas3
Date to be Released: Mon May 13 2013
Contact Person: Ron Frahm
File Name: ML13126A166.pdf
Content Size: 149821.0

May 14, 2013 (nuclear.com) -- From AP story out of Los Angeles today: Friends of the Earth ... argued that the plan to restart San Onofre's Unit 2 reactor is a change to the plant's operating license, which requires an extended, court-like hearing.

The Nuclear Regulatory Commission's Atomic Safety and Licensing Board agreed. The three-member board concluded that the restart would allow Edison "to operate beyond the scope of its existing license."

There was disagreement, however, over the reach of the ruling, which came amid a series of complex investigations at the plant.

Friends of the Earth spokesman Damon Moglen said in a statement that the ruling is "a complete rejection of Edison's plan to restart its damaged nuclear reactors."

The group said the reactors cannot be restarted until NRC "holds a formal license amendment proceeding with full public participation."

But a statement issued by the NRC characterized the ruling by the panel, an independent arm of the agency, as only a partial win for the environmental group.

NRC spokesman Scott Burnell said the board found that the group hadn't provided enough information for the three-member panel to initiate a hearing and, accordingly, concluded its role in the case.

"They didn't give enough meat for the board to chew on," Burnell said. "At the same time the board says, 'Yes, there should be a hearing,' ... they said the hearing is terminated."

Source: Micheal R. Blood (AP), "Environmentalists Praise Fed Ruling on San Onofre", Associated Press via ABC News, May 14, 2013

Please consider RT@nuclearcom San Onofre - ASLB ruling characterizes 70% power plan as an 'experiment' http://adf.ly/P3qUX #nuclear

May 8, 2013 (nuclear.com) -- The Nuclear Energy Institute today briefed NRC on "Industry Actions to Address Counterfeit, Fraudulent and Suspect Items" (CFSI). A pdf copy of the presentation slides is available here.

Here's nuclear.com's transcription of the presentation slides:

[slide 1] Industry Actions to Address Counterfeit, Fraudulent and Suspect Items
NEI CFSI Team
NRC Public Meeting
May 8, 2013

[slide 2] Overview

* General status

* Planned revisions to EPRI CFSI guidance in response to SECY-11-0154 Items A-K

* Early returns from industry self-assessment

* Plans for post-implementation monitoring

[slides 3-4] NRC-Proposed Proactive Strategies

Strategy

A. Develop a plan for implementing proactive CFSI strategies
Industry Actions: Initiated – ongoing

B. Develop a method for sharing CFSI Information, including issues identified during receipt inspection and commercial grade dedication
Industry Actions: Clarify and enhance existing guidance

C. Develop an industry accepted practice for using the corrective action program and nonconformance programs for entering CFSI related to safety related components
Industry Actions: Clarify and enhance existing guidance

D. Develop an industry accepted practice for using the corrective action program to enter non-safety related CFSI into the corrective action program
Industry Actions: Clarify and enhance existing guidance

E. Establish an industry CFSI database
Industry Actions: Expand access to existing industry databases

F. Incorporate industry best practices for quarantining CFSI items and removing them from supply chain without returning them to supplier
Industry Actions: Industry self-assessment underway; results to inform enhanced CFSI guidance

G. Incorporate industry best practices for identifying and informing the industry of CFSI trends

H. Incorporate industry best practices for enhancing commercial-grade dedication, and receipt inspection practices to account for CFSI

I. Incorporate industry best practices for product authentication of complex items that will provide additional assurance for preventing CFSI

J. Incorporate industry best practices for using batch sampling with authentication testing

K. Incorporate industry best practices for the use of standardized anti-CFSI language in procurement documents

[slide 5] B. Develop a Method for Sharing CFSI Information
G. Best Practices for Identifying and Informing Industry of CFSI Trends

* Status: Complete

* Licensees use corrective action system to capture issues (including issues identified during receiving and CG dedication). Prompts appropriate reporting
- INPO Operating Experience
- EPRI Suspect Counterfeit / Fraudulent Item database
- 10CFR, Part 21

* NRC has access to licensee corrective action systems and may issue generic notifications

[slide 6] E. Establish an Industry CFSI Database

* Status: Complete

* EPRI Suspect Counterfeit/Fraudulent Item Database
- EPRI members

* INPO Operating Experience
- INPO members and supplier participants

[slides 7-11] Establish an Industry CFSI Database

* EPRI Suspect Counterfeit/Fraudulent Item Database
- Fully implemented and in use by EPRI members
- Capabilities include proactive notification to U.S. licensees known to have similar items (part / manufacturer-model numbers)
* Agreements with several commercial industry databases (stocked items, manufacturer-model numbers)
- Legal issues limit sharing to EPRI members
* Presently unable to overcome liabilities and risks of sharing unconfirmed incidents with a broader population of suppliers and the public
* Exploring quid pro quo sharing with other data sources (significant legal challenges)
- Recent IN 2013-02 on Fire Protection Equipment
* 2 of 8 items in the IN showed matches
* One at 4 facilities
* One at a facility that already had the stock code identified as “at risk” due to the UL notice
* Proactive notifications were made

* INPO Operating Experience
- Reporting of incidents of counterfeit and fraud in place since a February 2010 directive
- Licensees have standard practices for processing operating experience reports
- INPO Supplier participants (26) have access to read and submit OE (signed nondisclosures)
* Submittal is voluntary for suppliers
- INPO issued IER L4-12-86 in late 2012
* Not based on U.S. experience
- Additional Industry Experience Reports will be issued based upon trends
- Revised INPO Performance and Operating Criteria quality of procured items
* CFSI prevention is part of plant evaluation process
* INPO evaluators are taking EPRI CFSI CBT training

[slide 12] C & D. Develop an industry accepted practice for using the corrective action program and nonconformance programs for entering CFSI related to safety related and NSR components

* In-process

* Incident identified / entered in the CAP or equivalent process
- Safety
- Non-safety

* Quarantine CFSI as appropriate

* Evaluate and disposition CFSI incident

* Report as appropriate
- Potential deviation i.e., 10 CFR Part 21/10 CFR 50.55e
- Industry databases

[slide 13] F. Incorporate industry best practices for quarantining CFSI items and removing them from supply chain without returning them to supplier

* In Process

* EPRI TR 1019163 mark-up drafted to clarify expectations on when an item needs to be quarantined and then what actions can be taken
- Section 3.2 – brief mention of the need to “quarantine suspected CFSI”
- Section 7.9.3 – detailed guidance on potential actions and factors to consider when dealing with suspected CFSI (as previously presented)

[slides 14-15] H. Incorporate industry best practices for enhancing commercial-grade dedication, and receipt inspection practices to account for CFSI

* In Process

* Summary of recommended changes to EPRI 1019163 (CFSI Guideline):

- The information in EPRI NP-6629, Appendix C, “Identifying Substandard / Fraudulent Items,” should be included in procedures and training for receiving inspectors and warehouse personnel.
* Training should include photographs and hands-on examples of CFSI, where practical 14

- Additional receipt inspection practices to consider, as appropriate:
* Compare incoming items to known authentic items (or pictures)
* Consult personnel who are more knowledgeable of the product when suspicious conditions are observed.

- Consult with OEM/OES, as appropriate
* Look for abnormalities in labeling, product marking, and workmanship
* Ascertain and recognize both legitimate and suspicious manufacturer markings, trademarks, logos, etc. 15

[slide 16] I. Incorporate industry best practices for product authentication of complex items that will provide additional assurance for preventing CFSI

* In process

* Current strategy is to identify procurements which are “at-risk” and specify enhanced inspection and/or testing

* EPRI 1019163, Counterfeit, Fraudulent, and Substandard Items, Mitigating the Increasing Risk, will be revised to:
- Define the term “at-risk” procurement
- Define the term “Enhanced Inspection/Testing”
- Integrate these concepts into recommended practices for Purchasing and Receiving to prevent and detect CFSI.

[slide 17] J. Incorporate industry best practices for using batch sampling with authentication testing

* In process

* Existing industry guidance on sampling can be applied to enhanced inspection and testing for “at-risk” items.

* Capable individuals, typically procurement engineers or technically qualified personnel, can apply sampling when specifying the enhanced inspection/testing criteria for at-risk procurements.

* Receiving Inspection will implement the specified inspections/tests in accordance with the prescribed sample plans.

* EPRI 1019163 will be revised to reference industry sample guidance.

[slide 18] K. Incorporate “Anti-CFSI” language in procurement documents

* Status: In-process

* Boilerplate language is complete and included in EPRI 1019163 (available to public)
- Vetted by licensee and supplier legal staff who participated in development
- Can be adjusted to suit individual preferences

* Implementation by licensees is ongoing

[slide 19] Boilerplate Clause

Seller is hereby notified that the delivery of suspect/counterfeit items is of special concern to (Utility Name). If any items specified in this Order are described using a part or model number, a product description, and/or industry standard referenced in the Order, Seller shall assure that the items supplied by Seller meet all requirements of the latest version of the applicable manufacturer data sheet, description, and/or industry standard unless otherwise specified. If the Seller is not the manufacturer of the goods, the Seller shall make reasonable efforts to assure that the items supplied under this Order are made by the original manufacturer and meet the applicable manufacturer data sheet or industry standard. Should Seller desire to supply an alternate item that may not meet the requirements of this paragraph, Seller shall notify Purchaser of any exceptions and receive Purchaser’s written approval prior to shipment of the alternate items to Purchaser.

If suspect/counterfeit items are furnished under this order or are found in any of the goods delivered hereunder, such items will be dispositioned by (Utility Name) and / or the original manufacturer, and may be returned to the Seller in accordance with the warranty provisions applicable to the Order. The Seller shall promptly replace such suspect/counterfeit items with items meeting the requirements of the Order. In the event the Seller knowingly supplied suspect/counterfeit items, the Seller shall be liable for reasonable costs incurred by the Purchaser for the removal, replacement and reinstallation of said goods in accordance with the warranty provisions applicable to the Order.

[slide 20] Raising Awareness of CFSI Issues

* SECY-11-0154 and NRC Info Notices

* NRC public meetings

* INPO IER 4-12-86

* Industry CFSI self-assessment

* Issuance of updated EPRI CFSI guidance

* Industry forums and workshops

* Trending and communication
- NRC, EPRI, INPO

[slide 21] Ongoing Industry CFSI Activities

* Following industry implementation of updated CFSI guidance:
- Ongoing industry reporting/sharing of CFSI info
- EPRI activities
* Maintain CFSI database
* Training modules & other technical support
- INPO activities
* Collect CFSI info from Licensees and Supplier Participants as part of ICES (OE) database
* Issue IERs as appropriate based on CFSI trends
* Evaluate CFSI practices as part of periodic INPO Plant Evaluations

[slide 22] Next Steps

* Assess industry survey results and adjust guidance as necessary

* Provide draft revision of EPRI 1019163 for staff review and feedback

* Finalize CFSI guidance and provide for industry use

* Follow-up SECY paper to Commission

- - - end of presentation slides

Here's info about the presentation from NRC's ADAMS database, where it was released on May 13:

Accession Number: ML13130A346
Estimated Page Count: 22
Document Date: Wed May 08 2013
Document Type: Meeting Briefing Package/Handouts, Slides and Viewgraphs
Document Title: Industry's CFSI slides May 8 2013.
Author Affiliation: Nuclear Energy Institute (NEI)
Addressee Affiliation: NRC/NRO
Keyword: axw7, NRC-001, nxp, SUNSI Review Complete, utsPARS
Related Date: Wed May 08 2013
Comment: CMB3
Date to be Released: Fri May 10 2013
Contact Person: Pasquale D J, NRO/DCIP/CAEB, 415-2498
File Name: ML13130A3460.pdf
Content Size: 837429.0

May 12, 2013 (nuclear.com) -- Levy would require about 600 workers to operate — engineers to keep it running, specialists to handle the waste, security to keep it safe. A natural gas plant employs about 50 people, and they generally aren't paid as well.

Source: Ivan Penn (Tampa Bay Times staff writer), "Math guts nuclear myth | Levy nuclear plant would cost more than a natural gas facility, but Duke Energy profits would soar", Tampa Bay Times, May 12, 2013, p. 1A - top story