ML20012G608
| ML20012G608 | |
| Person / Time | |
|---|---|
| Issue date: | 02/24/1993 |
| From: | Palla R Office of Nuclear Reactor Regulation |
| To: | Thadani A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9303100123 | |
| Download: ML20012G608 (23) | |
Text
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UNITED STATES n
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NUCLEAR REGULATORY COMMISSION o
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WASHINGTON, D.C. 20555
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February 24, 1993 MEMORANDUM FOR: Ashok C. Thadani, Director Division of Systems Safety and Analysis fy.h[ [
THRU:
William D. Beckner, Chief Probabilistic Safety Assessment Branch Division of Systems Safety and Analysis FROM:
Robert L. Palla, Jr.
Probabilistic Safety Assessment Branch Division of Systems Safety and Analysis
SUBJECT:
SUMMARY
OF FEBRUARY 2, 1993, MEETING WITH BWROG/NUMARC ON ACCIDENT MANAGEMENT On February 2,1993, the NRC staff met with representatives of the BWR Owners Group (BWROG) and Nuclear Management and Resources Council (NUMARC). The purpose of this meeting was to discuss:
(1) owners group concerns regarding the impact of potential accident management-related E0P changes on operator burden and (2) a BWROG proposal on managing the-increased burden.
The impact of accident management on operator requalification was previously identified as a BWROG concern during the September 25, 1992, meeting on accident management.
This memorandum summarizes the most significant results of the meeting. A list of attendees is presented in Enclosure 1.
A copy of the meeting handouts is provided as Enclosure 2.
Following introductory remarks, F. Emerson (BWROG) described the BWROG philosophy for development of accident management strategies and discussed emerging BWR concerns.
W. Berg (BWROG) followed with 2 examples of EPG changes being considered for implementation.
F. Emerson concluded by outlining the BWROG proposal for dealing with increased operator burden. The following is a summary of the major topics of discussion and observations concerning the owners group presentation.
The specific details are provided in Enclosure 2, and are not repeated here.
The industry concern it, that implementation of accident management will increase operator burden and subject operators to requalification examinations on new severe accident information in i
the E0Ps. The term " operator burden", as used by industry, refers i
to operatnr training requirements and operator exposure to 0 9 0 0 22
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The thrust of the industry proposal for managing operator burden is o!
that operator requalification training and examination requ should be prioritized using some importance measure based on risk f
or beyond-design-basis considerations.
Details on how this would SE TO EWAE ESIL E 0 9 <"
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I Ashok C. Thadani I be done have not yet been developed, but the BWROG indicated a willingness to further develop the proposal if the staff would I
seriously consider it.
In developing the proposal for dealing with operator burden, the i
BWROG chose between two options:
(1) placing severe accident related material in the SAMG for the TSC, even though it involves elements of response which are more appropriate.for the control room and (2) prioritizing the requalification training responsibility of the operator for the new EPG/EOP material. A third option was also recognized but not pursued:
programmatic evaluation of accident management capability at a facility or crew
'i level rather than at the individual operator level. This third I
option will be considered further.
Also, in developing the proposal, industry had not attempted to
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distinguish between requirements for initial licensed operator i
training versus requalification training. This was noted as an area that might be explored further by industry.
The issue of increased operator burden appears to principally affect BWR plants because of decision by PWR owners groups to place most of the responsibility for accident management with the technical support staff rather than the control room operators.
Individual utilities have expressed some concern regarding resources associated with increased training of technical support staff.
Establishing the proper scope, approach, and expectations will be important in order that this not become an issue for either BWRs or PWRs.
In concluding discussions, the staff indicated that NRC would be open to alternate means of examination and receptive to use of a prioritization scheme for this purpose. The BWROG committed to further develop their proposal, including the basis for making judgements on what should and l
shouldn't be included in training and examinations. NRC staff suggested
.l that this be an integrated proposal which addresses not only licensed i
operator training and requalification matters, but the question of responsibility and training for TSC staff, and the role of emergency preparedness-type exercises as well.
F. Emerson indicated that the BWROG-might be in a position to support a followup meeting with staff on this subject by late March 1993.
l L. fA E Robert L. Palla, Jr.
Probabilistic Safety Assessment Branch t
Division of Systems Safety and Analysis
Enclosures:
As stated
Ashok C. Thadani.
i be done have not yet been developed, but the BWROG indicated a willingness to further develop the proposal if the staff would seriously consider it.
In developing the proposal for dealing with operator burden, the
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BWROG chose between two options:
(1) placing severe accident related material in the SAMG for the TSC, even though it involves elements of response which are more appropriate for the control room and (2) prioritizing the requalification training responsibility of the operator for the new EPG/EOP material. A third option was also recognized but not pursued: programmatic evaluation of accident management capability at a facility or crew level rather than at the individual operator level. This third option will be considered further.
Also, in developing the proposal, _ industry had not attempted to distinguish between requirements for initial licensed operator training versus requalification training. This was noted as an area that might be explored further by industry.
The issue of increased operator burden appears to principally affect BWR plants because of decision.by PWR owners groups to place most of the responsibility for accident management with the technical support staff rather than the control room operators.
Individual utilities have expressed some concern regarding i
resources associated with increased training of technical support staff.
Establishing the proper scope, approach, and expectations will be important in order that_ this not become an issue for either BWRs or PWRs.
i In concluding discussions, the staff indicated that_NRC would be open to alternate means of examination and receptive to use of a prioritization scheme for this purpose. The BWROG committed to further develop their proposal, including the basis for making judgements on what should and shouldn't be included in training and examinations. NRC staff. suggested that this be an integrated proposal which addresses not only licensed operator training and requalification matters, but the question of e
responsibility and training for TSC staff, and the role of emergency preparedness-type exercises as well.
F. Emerson indicated that the BWROG might be in a position to support a followup meeting with staff on this t
subject by late March 1993.
Robert L Palla, Jr.
I Probabilistic Safety Assessment Branch Division of Systems Safety and Analysis 1
Enclosures:
As stated DISTRIBUTION:
1 See next page 0FC SPSB:DSSA:NRR SC:SPSB:DSSA BC:SPSB:DSSA 7
.</h NAME RPalla:bwM AEl-BassTo"ni WBeckner DATE_ g /2pf93 1 /M/93
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0FFICIAL RECORD COPY Document Name:
FEB2 MEET
l DISTRIBUTION FOR FEB2 MEET:
i GHolahan WBeckner AEl-Bassioni i
RPalla i
NRC PDR Central Files-WRasin (NUMARC)
DModeen (NUMARC)
SPSB r/f AM Distribution List i
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i ACCIDENT MANAGEMENT-DISTRIBUTION FOR MEETING NOTICE f
TMurley, 12 G 18 FMiraglia, 12 G 18 j
WRussell, 12 G 18 FCongel, 10 E 2 i
BBoger, 10 H 5 FGillespie, 12 G 18 l
AThadani, 8 E 2 MTaylor, 17 G 21 i
MDrouin, NLS 324 MSolberg, 12 D 22 EJordan, MNBB 3701 JRosenthal, MNBB 9715 RBarrett,-8 H 7 EBeckjord, NLS 007 TSpeis, NLS 007 BSheron, NLS~007 LShotkin, NLN 353 FCoffman, NLN 316 NLauben, NLN 353 DHouston, P 315 JKudrick, 8 D 1 RErickson, 9 H 19 i
I DDesaulniers, 10 D 24 MRubin, 8 E 23 RJones, 8 E 23 RGallo, 10 D 18 DMarksberry, MNBB 3206 WPasedag, DOE ALevin, 81E 23 9
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ENCLOSURE 1
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ENCLOSURE 2 A
PROPOSAL FOR MANAGEMENT OF OPERATOR RESPONSIBILITY RESULTING FROM IMPLEMENTATION OF SEVERE ACCIDENT MANAGEMENT 1
Dave Modeen (NUMARC) l Fred Emerson (BWROG)
Bill Berg (BWROG)
February 2,1993
AGENDA 1300 Background on industry efforts Modeen 1315 BWR severe accident strategy development Supporting philosophy Emerson Emerging BWR concerns and current activities Summary of discussions with NRC staff Expectations for this meeting Operator responsibility issue I
Example of impact Berg i
Proposal Emerson 1345 Discussion with NRC staff All 1500 Adjourn
1 BACKGROUND o
Considerable utility focus already exists on providing a strong accident management capability oriented toward core melt prevention.
o Considerabig utility focus already exists on providing a strong capability to implement public protective action recommendations.
Agree with NRC staff objectives stated in SECY 89-012, o
" Staff Plans for Accident Management Programs and Research," that each licensee:
Evaluate information on severe accidents Prepare and implement severe accident guidance Train personnel appropriately Be reviewed based on performance; not submittals o
insights gained from IPE are necessary prior to implementing enhanced accident management capabilities.
o industry should develop appropriate guidance; utility responsibility to implement.
OBJECTIVE AND FOCUS i
o Objective: Optimize the existing plant capabilities to terminate severe accidents and minimize any off-site releases.
o Focus of generic industry effort.
Utilize existing hardware and personnel resources Enhance utility capabilities to take the necessary actions within the plant to respond to severe accident conditions (typically between where EOPs leave off and emergency planning (E-plan) offsite protective action recommendations begin)
Flexible enough to allow plant personnel to deal with scenario progressions different from those previously described or analyzed Provide a level of emphasis in balance with other plant staff priorities t
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TRAINING AND DECISION-MAKING P
o Focus should be on personnel responsible for plant damage condition assessment and SAMG strategy determination and implementation.
Complex calculational aids and the upgrading of plant-o reference control room simulators to operate in severe accident regimes is not necessary, and probably unwise.
o Severe accidents should not be the focus of licensed operator requalification examination.
Existing interfaces between control room, technical o
support center and operational support center are structured to support decision making in response to severe accident conditions.
Keep severe accident management in proper perspective.
o Provide a level of emphasis commensurate with other plant staff priorities Application of new technology is tempting, but should be tempered 4
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BWR STRATEGY DEVELOPMENT i
-BWROG SUPPORTING PHILOSOPHY o
- 1 priority: MINIMlZE (AVOID IF POSSIBLE) INCREASE IN OPERATOR BURDEN FROM SEVERE ACCIDENT MANAGEMENT o
EPGs/EOPs currently are the primary vehicle for managing entire severe accident response; are the default mechanism for controlling plant without i
assistance from the TSC o
SAMG to provide guidance from TSC to Control Room; guidance should include interpretation of plant conditions trending / prediction of parameters prediction of equipment availability calc aids; revising EOP operating limits tracking EOPs; verifying plant response o
TSC responsible for SAMG; Control Room should be knowledgeable but not responsible for knowing o
Interface, not transition, between EPGs and SAMG
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EMERGING BWR CONCERNS / CURRENT ACTIVITIES BWROG AMWG MEETING, DECEMBER 8 -9, 1992 Formats and potential strategy changes (from Rev 4 o
EPGs) discussed o
Some additions to EPGs appear likely o
To limit additional operator burden, need to place certain actions in TSC or limit operator responsibility for knowing BWROG GENERAL MEETING, JANUARY 14, 1993 Current status / principles underlying strategy changes o
described o
Concerns expressed:
significant increase in operator burden significant new training requirements for TSC large cost and resource impact to implement for limited safety benefit C_URRENT ACTIVITIES Entire BWROG SAM effort to be formally reviewed o
in early March Proposal on management of operator responsibility to o
be discussed with NRC staff
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-l DISCUSSIONS WITH NRC STAFF SEPTEMBER 25, 1992 MEETIN_G o
Concern raised that BWRs will increase operator burden and subject them to requal exams on new severe accident info in EOPs l
JANUARY 12, 1993 PHONE CALL i
o Outline of BWROG proposal discussed l
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Proposal has enough merit for additional discussion with cognizant NRC staff t
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EXPECTATIONS FOR THIS MEETING o
Achieve mutual understanding of issue and possible avenues for resolution Obtain preliminary NRC Staff feedback on BWROG o
proposal o
Ou!!ine additional steps needed to resolve issue I
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OPERATOR RESPONSIBILITY ISSUE l
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Potential safety issue:
BWR EPGs go well into severe accident space Knowledge and training requirements for BWR l
operators already at upper limit If addition of severe accident response imposes an increase in operator responsibility, choices in appropriate use of limited training time could be forced on utilities Could result in reduced training in some areas important to safety l
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OPERATOR RESPONSIBILITY ISSUE o
Most feasible ways to address:
Place severe accident response materialin the SAMG for TSC application, even if it involves elements of severe accident response which are more properly in the Control Room under current-EPG philosophy OR Prioritize by some measure of importance the training /requal responsibility of the operator for knowledge of new EPG material related to severe accident management Y
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i IMPACT t'
o Any EPG change would result in some operator impact impact could be significant if the operator was held o
responsible for not only knowledge (awareness) but also performance (implementation) b l
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i EXAMPLES OF IMPACT i
o Steam cooling o
Pool cooling by mass addition 9
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STEAM COOLING Initial Condition No injection available e
Current Strategy Boildown to Minimum Zero injection RPV Water Level e
Emergency Depressurize e
IF WHILE EXECUTING THE FOLLOWING THER STEP EMERGENCY RPV EXIT THIS PROCEDURE DEPRESSURIZATION IS AND E5iiER EMERGENCY DEPRESSURIZAllON QR RPV WATER LEVEL CANNOT BE DETERMINED
.O_3 ANY SYSTEM, INJECTION SUBSYSTEM OR ALTERNATE INJECTION SUBSYSTEM IS LINED UP FOR INJECTION WITH AT LEAST 1 PUMP RJA]NG U
WHEN - RPV WATER LEVEL DROPS TO MZIRWL (=2/3 CORE KICHT)
THEN EMERGENCY DEPRESSURIZATION IS REOUIRED
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POOL COOLING BY MASS ADDITION Initial Condition High suppression pool temperature e
Current Strategy a
Maintain level in the LCO band Add mass for containment flood (level < TAF)
CANNOT MAINTAIN MAINTAIN BELOW STPLL
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BELOW HIGH LCO y
CANNOT MAINTAIN ENTER RPV CONTROL GL
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BELOW STPLL AND EXECUTE CONCURRENTLY V
CANNOT MAINTAIN TERMINATE INJECTION BELOW STPLL FROM EXTERNAL SOURCES, ACC PERMITTING y
EMERGENCY RPV CANNOT DEPRESSURIZATION RESTORE / MAINTAIN
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BELOW STPLL IS REQUIRED l
l SUPPORTING POINTS i
o Widespread agreement in BWR community that operator responsibility cannot be increased o
Training on the routine operations which, successfully performed, prevent accidents from even beginning is more important than training on severe accident scenarios o
Training on accident prevention in the early stages of a transient is more important than training on accident mitigation once the core has been damaged o
Major contributors to core damage fr6quency are more important to train on than insignificant ones o
Proposal makes effective use of IPE insights o
Severe accident training and requal responsibility for operator not eliminated, but given appropriate safety priority and placed in proper context o
Precedent exists in use of NUREG-1123 (Knowledge and Abilities Catalog) to prioritize operator actions o
Uncertainties make severe accident training harder
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PROPOSAL i
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Objectives:
Operator responsible and trained for managing appropriate elements of accident response Training and responsibility more heavily weighted i
in areas more important to safety Operator's ability to prevent accident or respond successfully is maximized I
e Place appropriate actions in the EPGs for control of
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plant throughout accident o
Prioritize training requirements and operator exposure for requalification exams I
Use importance measure based on risk or beyond o
design basis considerations j
UTILITY IMPLEMENTATION f
o Utility implementation of BWROG product will vary in plant control and decisionmaking i
FUTURE ACTIONS o
Preliminary NRC Staff feedback on proposal o
More formal avenue for resolution NUMARC letter clarifying intent of Statement in draft Generic Letter Other o
Action items NRC Industry l
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