ML20059K737
| ML20059K737 | |
| Person / Time | |
|---|---|
| Issue date: | 01/24/1994 |
| From: | Palla R Office of Nuclear Reactor Regulation |
| To: | Thadani A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9402020239 | |
| Download: ML20059K737 (28) | |
Text
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WASHINGTOY D.C. 20555 0001 i s a... January 24, 1994 MEMORANDUM FOR: Ashok C. Thadani, Director Division of Systems Safety and Analysis THRU: James W. Johnson, Acting 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:
DECEMBER 21, 1993 MANAGEMENT MEET'NG WITH NUMARC REGARDING ACCIDENT MANAGEMENT ACTIVITIES i On December 21, 1993, the NRC staff met with representatives of the Nuclear Management and Resources Council (NUMARC). The purpose of the meeting was to discuss the status and direction of NRC and industry activities on accident-management. Specific agenda topics included: (1) disposition of NRC comments on the PWR owners group SAMG documents, (2) the acceptability of the BWR-owners group methodologies presented at the December 9 meeting, and (3) staff and industry expectations for implementation and performance-based evaluation of SAMG. However, only the first of these was discussed in any detail. A list of attendees is presented in Enclosure 1. A copy of the presentation materials is provided as Enclosure 2. Initial aistussions centered on NUMARC and NRC staff characterizations of the staff / contractor comments on the PWR owners group SAMG documents, as presented at the December 8 meeting with industry. The NUMARC view is that while a few of the staff / contractor comments are worthwhile, the majority call for having more information and guidance for use by utilities than originally planned by the owners groups. Many of the comments were also attributed to the reviewers not understanding the owners group documents. NUMARC indicated that although each of the owners group documents look quite different they would achieve the .same result. NRC staff (R. Palla) noted that the Westinghouse SAMG documents were considered to be acceptable with only a minimal number of changes, but that many areas warranting improvement were identified for the B&WOG SAMG documents. He acknowledged that certain of the improvements that were said to. be "needed" are less important than others, and that the comments could be reevaluated to remove those that are not critical. Examples of some of the o-perceived deficiencies were described. /p [ ; W. Russell (NRC) expressed concern that there had not been any management 00IO90 review of the comments, and that based on a quick-look, many of the comments do not appear critical, e.g., the comment that the B&WOG guidelines place an i undue emphasis on the boron and enthalpy content of injection sources. J M.7 0l//M,ij(j } 9 ^! N [#l @M 94020202 9 24 /]/Whyf PDR: REVQP ERONUNRC
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V i Ashok C. Thadani I However, he focussed and expanded on one particular review comment which called for the owners groups to provide further guidance to utilities regarding the development of plant-specific procedures for defeating interlocks and protective trips, indicating that such guidance would be appropriate. Industry representatives acknowledged the need for pre-planning, but also noted that the development (by either the owners groups or licensees) of numerous detailed procedures is unwarranted and places a regulatory pedigree on severe accident response that is inappropriate. It was generally agreed that what is more important than detailed procedures is a clear delineation of the flow of information during an event, identification of the decisions that have to be made, and up front consideration of the viability of implementing the more significant strategies. This would include developing lists of alternative system lineups for achieving various functions, interlocks and protective trips to be over-ridden, and any special equipment required, in lieu of detailed procedures. Such lists would number in the teens, not hundreds. The implication of staff comments on the proposed NUMARC initiative on accident management, and the need for NRC to provide a response to the November 2, 1993, NUMARC letter regarding the initiative were also discussed. W. Russell suggested that the staff response to the NUMARC letter should address the outcome of the management review of the SAMG comments. He also indicated that the initiative might be modified to provide guidance in those areas where all owners group SAMG documents were perceived to have weaknesses. T. Murley (NRC) acknowledged that the staff has reservations with certain aspects of the SAMG, but indicated that he was not aware of any problems significant enough that the owners group SAMG should not be implemented. He expressed a reluctance to further delay implementation in an attempt to perfect the SAMG, and a preference for proceeding with implementation, and revisiting the situation about a year after implementation. He noted that industry's concern seems to be that if this program is not nailed down there is a fear that it will blow up down the road, and said that the NRC staff should provide a response (to industry's proposed initiative) that would alleviate that fear. Cased on the meeting discussions, the following agreements and action items were established with regard to dispositioning of the staff comments: NRC management will further review the comments, and will determine whether any comments bear on the staff's response to the NUMARC letter of November 2, 1993. DSSA and DRCH will be responsible for coordinating this activity. DSSA will prepare a draft response to the NUMARC letter of November 2, 1993, with a target date of the first week of February. I
Ashok C. Thadani A division-level meeting with NUMARC will be held in mid-February, at which time the resolution of staff concerns on the SAMG, and the-staff's response to the NUMARC initiative would be discussed. Both'DSSA.and DRCH will be involved in this meeting. Original signed by: Robert L. Palla, Jr.. Probabilistic. Safety Assessment Branch. Division of Systems Safety and Analysis ~
Enclosures:
As stated -DISTRIBUTION: A/M Distribution List-AEl-Bassioni RPalla NRC PDR ) Central Files-WRasin (NUMARC) DModeen (NUMARC) SPSB r/f i ACCIDENT MANAGEMENT DISTRIBUTION FOR MEETING NOTICE TMurley,12 G 18 FMiraglia, 12 G 18 WRussell, 12 G.18 BBoger, 10 H 5-FGillespie, 12 G 18 AThadani, 8 E 2 MTaylor, 17 G 21 CMarksberry,.MNBB 3206 EJordan, MNBB 3701 Scanthal,' MNBB 9715 RBarrett, 8 H 7 deckjord, NLS 007 TSpeis, NLS 007 BSheron, NLS 007 RJones, 8 E 23 DHouston, P 315 JKudrick, 8 D 1 RErickson, 9 H 19 DDesaulniers,10 D 24 RGallo, 10 D 18 WPasedag, DOE OFC SPSB:DSSA:NRR' SC:SPSB:DSSA ABC:SPSB:DSSA NAME RPalla:bw / / AE1 ioni JJohnson N DATE 01/?v/94 01/ff/94 01/q/94 0FFICIAL RECORD COPY Document Name: AMDEC21. MET
1: 'I est - iC ~ Ashok C. Thadani A division-level meeting with NUMARC will be held in mid-February, at- .which time the resolution of staff concerns on the SAMG, and the staff's-response to the NUMARC initiative would be discussed. Both'DSSA and-DRCH will be involved in this meeting. Original signed by: Robert L. Palla, Jr. Probabilistic Safety Assessment Branch Division of Systems Safety and Analysis -t
Enclosures:
As stated DISTRIBUTION: A/M Distribution List AEl-Bassioni RPalla NRC POR Central Files WRasin (NUMARC) DModeen (NUMARC) SPSB r/f r.CCIDENT MANAGEMENT DISTRIBUTION FOR MEETING NOTICE TMurley,12 G 18 FMiraglia, 12 G 18-WRussell, 12 G 18 BBoger, 10 H 5 FGillespie,-12 G 18 AThadani, 8 E 2 MTaylor, 17 G 21 DMarksberry, MNBB 3206 EJordan, MNBB 3701 JRosenthal, MNBB 9715 RBarrett, 8 H 7 EBeckjord,.NLS 007 TSpeis, NLS 007 BSheron, NLS 007 RJones, 8 E 23 DHouston, P 315 JKudrick, 8 D 1 RErickson, 9 H 19 DDesaulniers, 10 D 24 RGallo, 10 D 18 WPasedag,. DOE ~ OFC SPSB:DSSA:NRR SC:SPSB:DSSA ABC:SPSB:DSSA nNP~f]. e fik */ NAME' RPalla:bw I AEl-Bassioni JJohnson 't ' s DATE-Ol/r /94 01/17/94 Ol/;,p/94 0FFICIAL RECORD COPY Document Name: AMDEC21. MET
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""E6# " " A s 4 ) NUMARC - NRC Senior Management Meeting on SEVERE ACCIDENT MANAGEMENT i Bill Conway, APS, Chairman NUMARC SAWG Dave Modeen, NUMARC December 21,1993 Rockville, MD
m e t DISCUSSION TOPICS Working assum ations Inc'u.stry Pers aective A33roac1 to SAM elements Formal inc ustry aosition Schec u e Issues rec uiring resolution anc/or clari'ication i l NUMARC 1
J WORKING ASSUMPTIONS Consic. era a e "ocus already exists on accident orevention - Emergency and Abnormal Operating Procedures (EOPs and AOPs) i - Training programs (including plant reference simulators) i - Safety Parameter Display Systems Consic erab'e focus already exists to imp.ement pu alic protective action recommendations - Emergency plan support organizations, response plans and pre-staged resources - Periodic, large scale exercises and mini-drills 2
T i WORKING ASSUMPTIONS Eac1 licensee to: - Evaluate information on severe accidents - Prepare and implement SAMG - Train personnel appropriately - Use existing resources N o licensee su amittal; review based on aerformance nsig1ts gained " rom IP'E and severe accident researc7 s1ould ae caaturec to aetter arepare utili:y staf to c.eal wit'1 severe accidents Flexiaiity in a aaroaca, format, etc necessary to accommodate varying Emergency Resaonse Organization (E RO) structures & existing e= orts Keea SAV in pro aer perspective - Provide a level of emphasis commensurate with other priorities NUMARC 3
l INDUSTRY PERSPECTIVE Considerations regarding guidance deve coment - If a severe accident occurs, it is unlikely to follow a previously prescribed (and tested) scenario - Recognize limitations in the current level of ) severe accident phenomenological understanding - Approach analysis of accident management with " success" in mind identify the functionally desirable action (e.g., add water, depressurize) Establish the reasonable range of conditions that could exist during which the action may be taken Evaluate the consequences of the action over a reasonable range of conditions i NUMARC 4
i INDUSTRY PERSPECTIVE Consicerations regarding utility im a ementation - SAMG requires flexibility; given a severe accident, actions will need to be taken regardless of the uncertainty in our level of knowledge - An effective method ofinterface between EOPs and SAMG is important - An effective method ofintegration of SAMG with Emergency Plans is also important NUMARC 5
APPROACH TO SAM ELEMENTS Written Guic ance - Major focus of the generic guidance development activitiy; will include instructions for plant specific implementation Computational Aics - Develop owners-group specific CAs to support usage of SAMG; No plans for sophisticated, analytical software In"ormation Needs - Specify those parameters which could be used to make decisions regarding implementation and effectiveness of various strategies; IQntify alternate means of measuring or inferring the parameters of interest, as necessary u l NUMARC 6
APPROACH TO SAM EL.EMENTS ( Training - Identify appropriate areas (tasks) and levels (methods, extent, etc.) commensurate with the SAM program objectives - Focus on personnel doing plant damage condition assessment and SAMG strategy determination and implementation - Target is to familiarize; not memorize - Plant reference simulator upgrades to severe accident regime is inappropriate Decision Vla<ing - SAMG structured to reinforce the current utility Emergency Response Organization - ERO personnel possess the necessary skills in decision making and teamwork based upon their experience and EP drills / exercises n Focus training on awareness and understanding of S/A considerations NUMARC 7
APPROACH TO SAM ELEMENTS MAJOR PRODUCTS 1 NUN ARC Report 9'-04, Severe Accic ent issue C'osure Guic e ines - Process to address how far to go in response to risk insights NUMARC Reaort 92-01, A Process For Evaluating Accic.ent Vianagement Ca aaaii':ies - General framework addressing personnel, systems & equipment, and information resource attributes EPRI Severe Accident Management Guidance Tec1nical Basis Reaort (TBR) - Addresses degraded core events - Identifies candidate high level actions (strategies) to be taken in response to given plant conditions (RCS, Containment) - Describes anticipated effects, including relevant analytical and phenomenological information NUMARC 8
m s APPROACH TO SAM ELEMENTS MAJOR PRODUCTS NSSS owners grou as guidance - Incorporate vendor specific considerations and information to generic strategies - Assist INPO and utilities in developing severe accident training materials - Conduct tech transfer workshop with NUMARC (NRC, INPO and EPRI) Institute for Nuclear Power O aerations (lh PO) guidance - Identify enabling objectives and learning activities for personnel with severe accident management responsibilities - Create generic lesson plans Mitigation strategies (what, when and effects) and overview Safety assessment overview (including i PSA insights and likely sequences) Accident assessment Decision-making - Create videotape to augment lesson plans (severe accident theory & phenomena) NUMARC i
d . A FORMAL INDUSTRY POSITION STRUCTURE-1 } Formal, ainding.on all NUMARC mem aers 1 - High level utility action statement to perform - an assessment and adopt any improvements. deemed necessary q - Completion date of July 1,1997 Revise NUMARC 91-04 to reflect i flexible riature of t7e guicance - Formal position in foreward - General description of relevant SAM " elements" and self-evaluation in Sec. 5 - Maintains utility flexibility in response to the formal position j - Accommodates flexibility required to fit within varying ERO structures - Reference associated industry guidance documents - Already contains definitions of key terms i NUMARC H 10 l
n FORMAL INDUSTRY POSITION BASIC BUILDING BLOCKS Exaectec Licensee Action - Assess existing SAM capabilities - Integrate insights with those from IPE and Owners Group-specific SAMG - PRIMARY: from core damage through-achievement of a stable condition, if possible - SECONDARY: enhance capabilities to prevent core damage (from IPE insights) - Identify target date to NRC staff for completion of assessment and l implementation of any enhancements - Perform reasonable, periodic self evaluation (with debrief with NRC oflessons learned) in lieu of NRC staffinspection of SAM capabilities NUMARC 11 o
'd. FORMAL INDUSTRY POSITION ASSESSMENT OF RESOURCE IMPACT ON UTILITIES SAMG Develoament - Strategies - - Computational Aids - Information Needs Integration with Emergency Plan - Command & control -iy - CR, TSC and OSC interface Training - Lesson plan development j - Table top or walk-through drills - Personnel Operations crew Technical support staff Decision makers J l NUMARC 12 i
SCHEDULE I NU VIA tC Board of Jirectors vote on position on Vlarc12,1994 Tec1nology transfer workshops: July ' 994 - Expectations and resource estimates - Training material development - Mini-drills and self-evaluation - Partially open to NRC staff Com1ete final guidance: Lta ctr 94 - Owners Groups SAMG packages l - INPO and Owners Groups training recommendations and associated materials l l - Utility SAMG mini-drill and self-evaluation suggestions Licensees como ete caoabilities assessment and make enlancements: July 97 I NUMARC 13
s AREAS OF AGREEMENT Limit control room o aerator burc en Severe accident training alaced in proper context wit 7in existing training program - Prevention is more important than mitigation Industry can implement SAM most e"iciently Licensee performance is t7e on y reasonable figure o" merit by w1ich to judge success Pursue a formal industry position NUMARC 14
ISSUES REQUIRING RESOLUTION and/or CLARIFICATION Acceptance of 3WROG SAMG pac < aces as t1ey essential'y exist - Need to take broad perspective on entire industry effort and guidance documents- - Each OG package reflects desires of owners and existing structure / philosophy of ^ EPGs/ ERGS - Larger, more diverse OG did not have direct involvement of all members; thus more documentation required - A couple changes will be made as a result of NRC staff comments; most considered out of scope, wrong, or a misunderstanding - One style / format cannot be picked over another with any degree of certainty; more i documentation does not guarantee. success - Need for flexibility in utility implementation-has been stated on numerous occasions - NRC staff unsure as to whether technical or safety. evaluation report may be necessry; industry does not need either - Suggested action: Move fonvard with implementation; assess performance a NUMARC 15 F s-
ISSUES REQUIRING RESOLUTION and/or CLARIFICATION Acceatance o' 3WROG flexile assignment metlodology for Emergency 3rocedure Guideine strategy assignment between control room EOPs anc technical supoort center - Is there a core set of strategies that NRC believes must remain in EOPs? What? - Suggested action: Endorse concept. Establish working level interaction a: ~ieng NRR, Regions and BWROG to ts.(e from conceptual level to implementation Who is to be involved? 1Nhere do templates fit? What can be reviewed / tested? When can this occur? NUMARC 16
ISSUES REQUIRING RESOLUTION and/or CLARIFICATION 1 Operator responsiaility for " severe accident" <nowlec ge - Acceptability of BWROG training prioritization methodology j - Time and resources expended on severe accident training relative to other priorities - Suggested actions: Clearly document that upgrading simulators to severe accident regime is inappropriate Endorse BWROG concept; Establish working level interaction among NRR, j Regions and BWROG to take from conceptuallevel to implementation Who is to be involved? Where do templates fit? What can be reviewed / tested? When can this occur? - Recognize that PWROG concerns are similar, yet not as sensitive due to structural differences in EPGs/ ERGS to date NUMARC 17
ISSUES REQUIRING RESOLUTION and/or CLARIFICATION On y licensee su amittal exaected is a statement o" intent to aer~orm an assessment anc ma<e any changes deemec aaproariate ay a giveri date - Agree that applicability of 50.59 & 50.54x is correctly described in NUMARC letter of 10/29/93 - Agree that 50.47 allows for unilateral licensee creation of SAMG as long as "no decrease in effectiveness" - Agree that SAMG, although possibly referenced in Emergency Plans (EPs), does not need to be forwarded to NRC staff as part of EP updates - Suggested action: State agreement with the above three bullets in the NRC staff summary of today's meeting ....,,.,c. NUMARC 18
s 1-ISSUES REQUIRING.. RESOLUTION an'd/or CLARIFICATION 1 i Create a mutua understanding of 1 the o a.'ectives, scope, and detail of the severe accident. training for g cognizant 'aersonnel - Training time and number of cognizant licensee personnel will be very limited I - Training enabling objectives and learning activities will be performance oriented; i success will be judged-in terms of ability to j utilize SAM materials, not necessarily selecting "the technically optimal strategy" - Suggested action: i NRC staff may contact INPO directly to i obtain more detailed understanding.of j draft INPO materials j n Finalindustry products to be made available to NRC staff for information j i 1 4 NUMARC i 19 f 5
q ISSUES REQUIRING RESOLUTION and/or CLARIFICATION i Re'iance on reasonable utility self' i eva uation as the performance-- based measure. 1 - In lieu.of routine NRC inspection / audit - Licensee focus on practice / mini-drills - Conduct lessons learned debrief with NRC-staff - Suggested action: Owners Groups consolidate insights-from SAMG trial application efforts Establish working level interaction among NRR,-Regions and OGs to discuss attributes to be judged, e.g. reflect in industry guidance or criteria NUMARC 20
.. -. - - - - -, - - - -, = - - - - - - - - - - - - Y,.' c c: ISSUES REQUIRING RESOLUTION and/or CLARIFICATION Wi'lingness and methods of NRR senior management to clearly communicate expectations to NRR, RES, AEOD, anc. NRC regional personne - Industry does not view SAM as a regulatory compliance issue, nor as an EPG Phase 2 effort - Not every strategy and implementing action will be validated - Suggested action: NRC staff participation in industry technology transferworkshop NUMARC 21 ~!
s ISSUES REQUIRING RESOLUTION. and/or CLARIFICATION Need "or a c ear understanding by NRC staff and industry as to what is 1 expected of a licensee j - Must be completed. prior to requesting a NUMARC Board of Directors vote j - How can that assurance be provided? 1 - Suggested action:
- j Formal NRC staff response to draft industry position letter of 11/2/93?
Other issues?? NUMARC 22 .}}