ML19224B309
| ML19224B309 | |
| Person / Time | |
|---|---|
| Site: | 99902012 |
| Issue date: | 09/20/2019 |
| From: | Ross-Lee M NRC/NRR/DLP/PLPB |
| To: | Grubb J GE Hitachi Nuclear Energy |
| Joseph Golla, NRR/DLP/PLPB, 415-1002 | |
| Shared Package | |
| ML19224B382 | List: |
| References | |
| Download: ML19224B309 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 20, 2019 Mr. John C. Grubb, BWROG Chairman GE Hitachi Nuclear Energy, P.O. Box 780, 3901 Castle Hayne Road, M/C A-55, Wilmington, NC 28402
SUBJECT:
STAFF ASSESSMENT OF REVISION 4 OF THE BOILING WATER REACTOR OWNERS GROUP GENERIC SEVERE ACCIDENT GUIDELINES
Dear Mr. Grubb:
The purpose of this letter is to document the U.S. Nuclear Regulatory Commission (NRC) staff assessment of Revision 4 of the Boiling Water Reactor Owners Group (BWROG) generic Severe Accident Guidelines (SAGs) dated June 1, 2018. The BWROG generic SAGs Revision 4, was made available to the NRC staff through an electronic reading access portal and is considered proprietary information. The NRC staffs approach for the review of the BWROG generic SAGs, which are not a requirement, is outlined in a memorandum to the Nuclear Energy Institute (NEI) dated February 23, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16032A029).
As discussed in the February 23, 2016, memorandum, the NRC staff was directed by the Commission in a staff requirements memorandum dated August 27, 2015 (ADAMS Accession No. ML15239A767), to update the Reactor Oversight Process (ROP) to explicitly provide periodic oversight of industrys implementation of the severe accident management guidelines (SAMGs).
By letter dated October 26, 2015 (ADAMS Accession No. ML15335A442), the NEI informed the NRC of an industry initiative to maintain SAMGs. This letter stated that each licensee will send a letter to the NRC docketing its site-specific SAMG commitments by December 31, 2015.
The NRC has received SAMG commitment letters from each licensee that are consistent with the commitments outlined in NEIs October 26, 2015, letter. The licensees SAMG commitment letters include commitments to update the site-specific SAMGs based on the BWROG generic SAGs in a timely manner after the generic SAGs have been published by the BWROG.
NOTICE: The attachment to the enclosure transmitted herewith contains Proprietary Information. When separated from the attachment, the enclosure and transmittal document is decontrolled.
J. Grubb The February 23, 2016, memorandum informed you that the NRC staff intends to update the ROP by December 31, 2020, to allow for oversight of the site-specific SAMG incorporation of generic guidance revisions. Under Inspection Procedure (IP) 71111.18, Plant Modifications (ADAMS Accession No. ML19070A127), the ROP has since been updated to allow for oversight of the site-specific SAMG incorporation of generic guidance revisions.
Deviations from the generic SAGs will be evaluated as part of the inspection of the site-specific SAMGs. These inspections are expected to take place in 2022. In conjunction with the ROP update, the NRC staff is providing the enclosed assessment of the BWROG generic SAGs Revision 4.
If you have any questions concerning this letter, please contact Ngola Otto of my staff, at (301) 415-6695, or via email to Ngola.otto@nrc.gov.
Sincerely,
/RA/
Mary Jane Ross-Lee Acting Director Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No.: 99902013
Enclosure:
Staff Assessment
ML19224B309 (letter & enclosure);
ML19224B362 (proprietary attachment);
ML19224B382 (Package)
- via email OFFICE NRR/DLP/PLPB/PM NRR/DRA/ARCB/BC NRR//DLP/PLPB/LA*
NAME NOtto KHsueh* DHarrison DATE 09/6/2019 9/16/2019 08/29/2019 OFFICE NRR/DIRS/IRIB/BC NRR/DLP/PLPB/BC NRR/DLP NAME THipschman DMorey MJRoss-Lee DATE 09/9/2019 09/16/2019 09/20/2019 NUCLEAR REGULATORY COMMISSION STAFF ASSESSMENT OF REVISION 4 OF THE BOILING WATER REACTOR OWNERS GROUP SEVERE ACCIDENT GUIDELINES
1.0 INTRODUCTION
By letter dated October 26, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15335A442), the Nuclear Energy Institute (NEI) informed the U.S. Nuclear Regulatory Commission (NRC) of an industry initiative to maintain Severe Accident Management Guidelines (SAMGs). This letter stated that each licensee will send a letter to the NRC docketing its site-specific SAMG commitments by December 31, 2015. The NRC has received the SAMG commitment letters from each licensee that are consistent with the commitments outlined in NEIs October 26, 2015, letter. The licensees SAMG commitment letters include commitments to update their site-specific SAMGs based on revisions to the Boiling Water Reactor Owners Group (BWROG) generic Severe Accident Guidelines (SAGs) in a timely manner after the revised generic SAGs have been published by the BWROG.
The NRC staff will perform inspections of licensee commitments to update their site-specific SAMGs to be consistent with Revision 4 of the BWROG generic SAGs as part of the Reactor Oversight Process (ROP) as directed by the Commission. Performance deficiencies from the periodic inspections of the licensees SAMGs will be assessed using the ROP.
In conjunction with the ROP update, the NRC staff is providing the enclosed assessment of the BWROG generic SAGs Revision 4. This assessment documents the NRC staffs review of Revision 4 of the BWROG generic SAGs dated June 1, 2018.
2.0 REGULATORY EVALUATION
The regulatory basis for SAMGs and associated history can be found in SECY-15-0065, Proposed Rule: Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49) (ADAMS Accession No. ML15049A201). Enclosure 2 of SECY-15-0065 noted that at the time of the SECY papers issuance, SAMGs were not an NRC requirement. However, SECY-15-0065 proposed making SAMGs a requirement. The Commission did not adopt this position, and directed the staff to remove SAMGs as a requirement from the proposed rule in an August 27, 2015, staff requirements memorandum (ADAMS Accession No. ML15239A767).
The Commission further directed the NRC staff in the August 27, 2015, letter to update the ROP to explicitly provide periodic oversight of industrys implementation of the SAMGs.
The SAMGs are well established guidance documents that have been developed by the nuclear power industry with substantial NRC involvement, have been implemented by every operating nuclear power reactor licensee, and are the subject of a license condition for combined licenses.
Following the Three Mile Island accident, the nuclear power industry revised its Emergency Response Procedures. In the mid to late 1980s, the NRC and the nuclear power industry identified a need to consider plant conditions that could lead to a severe accident. These efforts led to the nuclear industry voluntarily initiating a coordinated program on accident management ENCLOSURE
in 1990. Section 5 of NEI 91-04 (formerly NUMARC 91-04), Revision 1, Severe Accident Closure Guidelines, describes the elements of the industrys severe accident management closure actions.
The program involved the development of: 1) a structured method by which utilities could systematically evaluate and enhance their ability to deal with potential severe accidents,
- 3) guidance and material to support utility activities related to training for severe accidents. In 1992, the Electric Power Research Institute (EPRI) developed the SAMG Technical Basis Report (TBR). Volume one of this report covers general actions that could be taken to manage a severe accident (referred to as SAMG candidate high level actions) and their effects, and volume two is a detailed report on the physics of accident progression. By letter dated June 20, 1994, the NRC staff accepted the industrys approach for mitigating the consequences of severe accidents, including licensee regulatory commitments to implement plant-specific SAMGs, using the guidance developed in Section 5 of NEI 91-04, Revision 1, by December 31, 1998.
The NRC assessed the ongoing implementation of SAMGs at a select number of plants during the 1997-1998 time frame as discussed in SECY-97-132, Status of the Integration Plan for Closure of Severe Accident Issues and the Status of Severe Accident Research, and SECY-98-131, Status of the Integration Plan for Closure of Severe Accident Issues and the Status of Severe Accident Research, and concluded that the results of the voluntary initiative achieved the NRCs overall objectives established for accident management in SECY-89-012, Staff Plans for Accident Management Regulatory and Research Programs. In 2012, the EPRI revised the TBR to account for the initial lessons learned from the Fukushima Dai-ichi accidents, as well as enhanced understanding of severe accident behavior gained from additional research and analyses performed since the original report was published.
Following the events at Fukushima Dai-ichi, the NRC staff again inspected the implementation, ongoing training, and maintenance of licensee SAMGs at all power reactor sites, except those that had permanently ceased operation, through performance of Temporary Instruction 2515/184, Availability and Readiness Inspection of Severe Accident Management Guidelines (SAMGs). The NRC staff found that some licensees had not maintained the SAMGs in accordance with the latest revisions of the applicable industry generic technical guidelines nor conducted training in a consistent and systematic manner. The NRC inspectors attributed the inconsistent implementation and training on SAMGs to the voluntary nature of this initiative.
As discussed above, the Commission directed the NRC staff to remove SAMGs as a requirement from the proposed rule and to update the ROP to explicitly provide periodic oversight of industrys implementation of the SAMGs. The BWROG generic SAGs, Revision 4, was made available to the NRC staff through an electronic reading access portal and is considered proprietary information. The NRC staffs approach for the review of the BWROG generic SAGs is outlined in a memorandum to NEI dated February 23, 2016 (ADAMS Accession No. ML16032A029).
3.0 TECHNICAL EVALUATION
The NRC staff performed a high-level assessment of Revision 4 of the BWROG generic SAGs.
The NRC inspection will verify that the licensees site-specific SAMGs have been updated to be consistent with Revision 4 of the BWROG generic SAGs.
The BWROG generic SAGs, Revision 4, was made available by the BWROG in March 2019, to the NRC staff through an electronic reading access portal and is considered proprietary information. Overall, the NRC staff considers the industry position to be consistent with NRC views and expectations regarding severe accident management. However, a number of areas were identified where the position should be expanded to provide additional clarification and guidance to utilities. The NRC staff comments and views in these areas are provided in the attached proprietary table.
Attachment:
Staff Comments Table (Proprietary)