ML20138D674
| ML20138D674 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/1997 |
| From: | Palla R NRC (Affiliation Not Assigned) |
| To: | Holahan G NRC (Affiliation Not Assigned) |
| References | |
| FACA, NUDOCS 9705010208 | |
| Download: ML20138D674 (29) | |
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4 UNITED STATES l
j NUCLEAR REGULATCIRY COMMISSION t
WASHINGTON, D.C. 20665-0001 April 24, 1997 MEMORANDUM TO: Gary M. Holahan. Director Division of Systems Safety and Analysis THRU:
Carl H. Berlinger. Chief
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Containment Systems and Severe Accident Branch l
Division of Systems Safety and Analysis FROM:
Robert L. Palla. Senior Reactor Engineer / M A Containment Systems and Severe Accident Franch Division of Systems Safety and Analysis l
SUBJECT:
NEI SEVERE ACCIDENT MANAGEMENT IMPLEMENTATION WORKSHOP ON j
MARCH 11-13, 1997 l
On March 11-13. 1997, staff from SCS3, SRXB, PERB/DRPM, and HHFB/DRCH attended the NEI Severe Accident Management Implementation Workshop in Charlotte. North Carolina.
The purpose of the workshop was to provide a forum for utility personnel to explore and discuss alternative solutions to issues that have l
arisen during plant-specific implementation of severe accident management guidance (SAMG) and training. The workshop was sponsored by the Nuclear Energy Institute (NEI) and was open to the public. Approximately 200 persons attended, including utility staff (from operations, training, emergency preparedness, and engineering) res3onsible for implementing the various facets of severe accident management at t1eir plants, and representatives from each l
of the owners groups EPRI. and several foreign organizations. The list of l
attendees is provided in Attachment 3.
l Following introductory remarks by NE;. NRC provided staff perspectives and expectations regarding industry implementation and NRC inspection activities.
l The NRC presentation materi'als are provided as Attachment 2.
The balance of l
the meeting centered on the industry presentations on each of the major ekments of implementation, such as development of plant-specific SAMG, f
initial staff training. SAMG validation, conduct of A/M drills and tabletop
/ /
exercises, and use/ applicability of 10 CFR 50.59 in the implementation Industry representatives appeared candid and forthright in their presentations and discussions regarding plant-specific implementation
//e4 process.
approaches and issues. and plans and resources for completing im Key staff observations are summarized below:
The industry originally desired flexibility in the way in which A/M was implemented, but now seems concerned with the aerception that some programs are better than others and that the NRC may expect all licensees to meet the standards set by the best programs.
Hence, the industry
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The process and degree to which licensees incorporated.IPE insights into plant-specific SAMG was not a) parent from the presentations.
The staff recommended NUMARC 92-01. "A 3rocess for Evaluating Accident Management Capabilities." as one a)proach for confirming adequate A/M capabilities for sequences found to )e important in the IPE.
Most utilities do not think that changes to the Emergency Plan are necessary to acknowledge the implementation of accident management but expect to modify the Emergency Plan Implementing Procedures (EPIPs) to reflect new roles and responsibilities for A/M.
Some utilities are increasing TSC staffing and have modified TSC to accommodate SAMG evaluators: others expect to perform SAMG evaluations without any TSC staffing changes.
PWR licensees generally feel that 10 CFR 50.59 is not applicable to SAMG implementation, except where existing equipment is modified to allow for im)lementation of soine A/M strategies or E0Ps are modified.
In contrast.
BWR utilities intend to implement the BWROG Emergency Procedure and Severe Accident Guidelines (EP/ SAG) under 10 CFR 50.59 and are deliberating on alternative approaches for structuring the evaluation.
Two approaches' were described for categorizing and dispositioning the BWR EP/ SAG changes based on whether they are:
(1) addressed in staff safety evaluation reports (SERs). (2) covered by previous licensee 50.59 evaluations, or (3) outside the scope of 50.59.
Several changes in the EP/ SAG were mentioned that could reduce margins or increase risk relative to Revision 4 of the EPGs:
increased flexibility for drywell venting, overriding interlocks, and lowering water level to the minimum steam cooling reactor water level rather than the top of active fuel.
Some utility interest was expressed for. tasking the BWROG to develop generic evaluations that licensees could use in their 50.59 process.
These evaluations would show why certain changes that may appear to reduce margins or increase risk are actually beneficial or risk-neutral.
We should track any BWROG actions in this area to determine
' whether they can impact our review of the EP/ SAG.
A few utilities indicated schedules have/will slipped due to recent 50.54(f)-related generic letter and higher priority licensing issues.
Licensees were reminded that any changes to the committed completion date should be submitted to the NRC.
On the last day, the staff responded to questions raised by industry partici-pants.
The questions and staff responses are summarized in Attachment 3.
The staff indicated that further consultation with other NRC staff members including OGC would be necessary to adequately respond to the questions.
Staff agreed to consider developing a formal response to those questions where there are remaining concerns. if requested by NEI in writing.
Based on the workshop, the following actions are recommended:
Follow the regional BWR Joint Development Effort activities, and any BWROG activities to develop technical bases for 50.59 determinations, for
9 l possible impacts on the review of EP/ SAG and the development of inspection guidance for BWRs.
This should be discussed at the next scheduled
)
l NRC/BWROG Management meeting.
l Follow the WOG A/M drill scenario template project for possible impact on the A/M inspection guidance, and potential value to NRC in developing drills for emergency response training.
This should be discussed at the l
next scheduled NRC/WOG Management meeting.
Coordinate with AEOD concerning A/M training for NRC staff supporting the NRC Emergency Operations Center.
l l
DISTRIBUTION:
l
.SCollins SNewberry CThomas CMiller SMagruder SBasu JLyons RHasselberg i
SRichards I
Central Files PDR SCSB r/f (2) i l
l DOCUMENT ~NAME:
NEIWKSHP. SUM T3 receive a copy of this docurnent, indicate in the boa:
"C" - Copy without attachment / enclosure "E" = Copy wrth attachment / enclosure "N" - No copy 0FFICE SCSB:DSSA:NRR BC:SCSB:DSSA, 9 l
l l
l NAME RPalla:bwfjf CBerlingerL N l
DATE 4/9 /97
-4/V/97
/ /97
/
/97
/ /97 0FFICIAL RECORD COPY l
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9 d possible impacts on the review of EP/ SAG and the development of inspection guidance for BWRs.
This should be discussed at the next scheduled NRC/BWROG Management meeting.
i Follow the WOG A/M drill scenario template project for possible impact on the A/M inspection guidance, and potential value to NRC in developing drills for emergency response training.
This should be discussed at the next scheduled NRC/WOG Management meeting.
Coordinate with AE00 concerning A/M training for NRC staff supporting the NRC Emergency Operations Center.
DISTRIBUTION:
SCollins SNewberry CThomas CMiller SMagruder SBasu JLyons RHasselberg SRichards Central Files PDR SCSB r/f (2)
DOCUMENT NAME:
NEIWKSHP. SUM l
To receive a copy of this document. Indicate in the boa:
"C" = Copy without ottachment/ enclosure "E' = Copy with attachment / enclosure "N" = No copy QOFFICE SCSB:DSSA:NRR. l BC:SCSB:DSSA l
l
'8AME RPalla:bw fj f CBerlinger-DA F 4hA /97 4/:: /97
/ /97
/ /97
/ /97 T
0FFICIAL RECORD COPY l
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1 SEVERE ACCIDENT MANAGEMENT PARTICIPANTS LIST j
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NAME PLANT / ORGANIZATION TELEPHONE NO.
Michael Adelizzi Susquehanna (717) 542-3471 i
Joseph D. Anderson Perry (216) 280-5570
)
Kevin B. Appel Braidwood (815) 458-2801 Gordon Arent Cook (616) 466-2644 Robert Artus Peach Bottom (717) 456-7014_
Donnie J.
Ashley TVA (423) 751-7832 Nicholas Avrakotos FitzPatrick (315) 349-6773 Steve Banks P.alo Verde (602) 393-5257 Mike Barrett Duke (704) 382-6754 William M. Bartelme Kewaunee (414) 388-2560 Michael A.
Barton Brunswick (910) 457-2375 Edward K.
Bates WD Associates (315) 342-1222 James W.
Bauer Millstone (860) 444-5578 l
H. Tom B'aumgardner Catawba.
(803) 831-3125 l
Alan L.
Beaver McGuire (704) 875-4660 Ralph E.
Beedle NEI (202) 739-8088 Thomi;s B. Blount Oyster Creek (609) 971-4007 i
Chris E.
Boone Hatch (912) 537-1395 Dave Boyles Quad Cities (309) 654-2241 David W.
Bremer Cooper (402) 825-5673 Brian A.
Brogan Big Rock Point (616) 547-8193 O.
J.
Brooks NNP-2 (509) 377-8442 Rodney Brown Oconee (864) 885-3301 l
Nelson Brown TMI (717) 948-2073 David Burch FitzPatrick (315) 349-6311 Jason Chao EPRI (415) 855-8901 Stephen E.
Chapin Crystal River (352) 563-4711
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SEVERE ACCIDENT MANAGEMENT PARTICIPANTS LIST NAME PLANT / ORGANIZATION TELEPHONE NO.
Mary Ann Chaubard Indian Point
'(914) 736-8419 Donna M.
Christiansen Vogtle (706) 826-3938 Clifton R.
Coop Hatch (205) 992-7411 Marcia A.
Cooper TVA (423) 751-7665 Robert L.
Couture Seabrook (603) 773-7389 Howard Crawford TMI (717) 948-8412 James M.
Crum Beaver Valley (412) 393-5723 Michael Daus Operations Support (508) 747-3314 Services, Inc.
Harvey Deal McGuire (704) 875-5512 Giancarlo L.
Delfini Indian Point (914) 736-8337 David R.
Desaulniers NRC (301) 415-1043 Steve Deskevich Duke
( 704 )'
382-7128 William L. Detwiler Salem (609) 339-1435 Mary E.
Dieltz Monticello (612) 295-1568 Paul DiGiovanna Commonwealth Edison (815) 458-3411 Jack Dougher Oyster Creek (609) 971-2130 William G.
Dove ABB-CE (860) 285-3445 David M.
Draper Cook (616) 465-5901 Seth Duston Seabrook (603) 430-7639 Dennis M. Emborsky Millstone (860) 440-2044 Fred Emerson NEI (202) 739-8086 Larry Epstein Point Beach (414) 755-659'1 Ken Evans Clinton (217) 935-8881 John Favara New York Power Auth.
(914) 681-6523 Jim Feinstein Cook (616) 697-5140 Jan R.
Felice Peach Bottom (717) 456-7014 Tony Feltman Browns Ferry (205) 729-3666 _
SEVERE ACCIDENT MANAGEMENT PARTICIPANTS LIST NAME PLANT / ORGANIZATION TELEPHONE NO.
Leland E.
Finholm Prairie Island (612) 388-1165 James L.
Fisher Peach Bottom (717) 456-7014 Paul V.
Fleming Crystal River (352) 563-4796 Peter Francisco Nine Mile Point (315) 349-4065 Lou Frasson Fermi (313) 586-1335 Diana Fried Diablo Canyon (805) 545-3420 Edward L.
Fuller.
Polestar (415) 948-8242 David W.
Fuller Comanche Peak (817) 897-5283 Stan Gamble Limerick (610) 718-2844 I
Rick Garner Harris (919) 362-2505 Mike Godknecht Oyster Creek (609) 971-4189 Fernando Gonzalez Tecnatom (Madrid)
(011) 341-6516 l
Mark Greene ABB-CE (860) 285-2694 Susan M.
Gum NEI (202) 739-8032 Duane L. Haas Quad Cities (309) 654-2241 Mike Hall Prairie Island (612) 388-1121 Steven A.
Harrison Virginia Porter (804) 273-2769 Roy Harter Duane Arnold (319) 851-7424 Rebecca L. Has'ty McGuire (704) 875-4662 Robert W. Hayden Cooper (402) 825-5270 Scott A.
Henry Calvert Cliffs (410) 495-6989 l
Clay Hill Point Beach (414) 755-659'1 Mark Hoffman Braidwood (815) 458-2801 Jack Hoffman St. Lucie (561) 467-7252 Jeff Hollingsworth Palo Verde (602) 393-6522 D. Norman Hood Comanche Peak (817) 897-5889 Richard S. Hutchison South Texas (512) 972-8319 1
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SEVERE ACCIDENT MANAGEMENT PARTICIPANTS LIST l
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NAME PLANT / ORGANIZATION TELEPHONE NO.
Ed Jacks Arkansas Nuclear One (501) 858-5591 1
Alfonso Jimenez Tecnatom (Madrid)
(011) 341-6516 Dennis M.
Jones Davis-Besse (419) 321-7594 Robert E.
Kahler Beaver Valley (412) 393-5767 Jim Kalamaja Duane Arnold (319) 851-7968 Michael A.
Karney Limerick (610) 718-2045 Ellen P.
Karpe Palisades (616) 764-2160 Victor J.
Kelley Summer (803) 345-4464 Daniel B.
Kelley Davis-Besse (419) 321-7461 Bradley B.
Kelly Callaway (573) 676-8197 Tom Kerr FitzPatrick (315) 349-6257 1
MichaelA. Kiel Clinton (217) 935-8881 R.
C.
Kina Sequoyah (423) 843-4105 Michael Kline Millstone (860) 437-2597 Linda Kreuder Quad Cities (309) 654-2241 Rodney Krieger Cook (616) 466-2430 I
Tina Kuhr Duke (704) 382-3151 Jeffrey D.
Lancaster Callawlay (573) 676-4637 Walter H.
Lee Farley (205) 992-5627 Dan Lerch PECO (610) 640-6890 James L.
Lewis Waterford (504) 739-6624 Paul Linn Volian Enterprises (412) 335-3744 Mark G.
Luksic Watts Bar (423) 365-8794 Robert Lutz Westinghouse (412) 374-4946 l
A.
Scott MacAinsh PECO (610) 640-6700 Bruce D. MacKissock Monticello (612) 295-1069 N. Merrill Maddox Southern Nuclear (205) 992-6399 SEVERE ACCIDENT MANAGEMENT PARTICIPANTS LIST NAME PLANT / ORGANIZATION TELEPHONE NO.
Wilson R. Madison Virginia Power (804) 273-3704 John C. Maher River Bend (504) 381-4243 Robert D. Mandik PECO (610) 640-6843 Juan M. Martinez Nuclenor (011) 344-7349 Steve Mayhew Hatch (912) 537-9478 Lawrence Mayo Vogtle (706) 826-3356 Daphne Mays Ginna (716) 771-3104 Robbie L. McAnnally South Texas (512) 972-7316 Harold McCallum Surry (804) 365-2638 David McKinney Arkansas Nuclear One (501) 858-5467 Stephen R. Merrell Byron (815) 234-5441 Donna J. Miller Salem (609) 339-1517 Tassos Mironidis New York Power Auth.
(914) 681-6372 Gary L. Mitchell Catawba (803) 831-3235 David Modeen NEI (202) 739-8084 Fred J.
Mogolesko Pilgrim (508) 830-7832 Browns Ferry (205) 729-2545 Robert J. Moll E.
Lou Montalvo Millstone (860) 447-1791 Kevin Morgan Duane Arnold (319) 851-7283 Alan Nelson NEI (202) 739-8110 Terry L. Newman Watts Bar (423) 365-8967 James O'Brien NRC (301) 415-2919 Chuck Olson Arkansas Nuclear One (501) 858-6945 Jeff Olson Monticello (612) 295-1285 Robert L.
Palla NRC (301) 415-1095 Jerry Parchman Brunswick (910) 457-2711 Cathy Parillo NEI (202) 739-8038 -
4 SEVERE ACCIDENT MANAGEMENT PARTICIPANTS LIST NAME PLANT / ORGANIZATION TELEPHONE NO.
Doug Paul Duke (704) 382-3865 Walt Perks Arkansas Nuclear One (501) 85P-5961 Michael Phillips Salem (609) 339-5271 Peter Polfleit Ginna (716) 771-6772 Dean Porter Vermont Yankee (802) 258-5904 Dan K.
Powers San Onofre (714) 368-9155 Brian D.. Price Callaway (573) 676-8173 Robert Prior Westinghouse -
011-32-2-556-Europe (Belgium) 8965 Phillip E. Quarles Virginia Power (804) 273-2871 Bruce Rash Palo Verde (602) 39'3-5926 Rachelle G.
Reddick Hatch (912) 537-1395 James M.
Redwine Brunswick (910) 457-2571 William Remz Virginia Power (804) 273-3142 David R. Robinson Cooper (402) 825-5847 Andrew C.
Rodgers Mill' stone (860) 437-2669 Philip J.
Rogers St. Lucie (561) 465-3550 Ken Ross KLR Services (510) 449-4135 Gregory C.
Rudigier Calvert Cliffs (410) 495-4494 Robert Ruffe Limerick (610) 718-4016 Wayne Russell Grand Gulf (601) 437-2717 Joseph M. Salvo Yankee Atomic (508) 568-2885 Charles W.
Sawyer Duke (704) 382-3331 Rich Schliessmann Braidwood (815) 458-2801 Richard Schmidt Northeast Utilities (860) 832-4763 Dan Scukanec Vogtle (706) 826-3902 C.
Gary Seaman Watts Bar (423) 365-8899 John Silver McGuire (704) 875-4838
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SEVERE ACCIDENT MANAGEMENT PARTICIPANTS LIST 1
NAME PLANT / ORGANIZATION TELEPHONE NO.
Jonathan L.
Small McGuire (704) 875-5100 Johnie G.
Smith Crystal River (352) 795-0504 l
l David M.
Smith Susquehanna (717) 542-1853 l
Cynthia Smith Susquehanna (717) 542-3233 Sam Sowell Oyster Creek (609) 971-2249 Benjamin D.
Spencer North Anna (540) 894-2091 Robert L, Sprague Millstone (860) 447-1791 Frank B.
Stanaszak Kewaunee (414) 388-2560 William S.
Stanley TMI (717) 948-8695 1
Gary Statton Clinton (2170 935-8881 l
J.
E.
Staub Watts Bar (423) 365-1960 Gregory W.
Steiner' Nine Mile Point (315) 349-2008 Tricia Stevens Cooper (402) 825-5169 D.
W.
Stobaugh Commonwealth Edison (630) 663-6480 Chester S.
Sullivan Duane Arnold (319) 851-7212 Paul Sullivan Duane Arnold (319) 851-7191 l
Kent Sutton Cooper (402) 825-5112 E.
Douglas Swartz Commonwealth Edison (630) 663-7237 Mike Swartz Maine Yankee (207) 798-4240 Mike Tackett Cooper (402) 825-5666 George Thomas NRC (301) 415-1814 l
l Bryan M. Thompson North Anna (540) 894-2412 Mike Thorne Oconee (864)'885-3210 Nicholas A. Valos Zion (847) 746-2084 George Vayssier Nuclear Safety 011-31 Consulate, 3335543 Netherlands William R. Victor Cooper (402) 825-5818 C.
Kelly Walker Operations Support (508) 747-3314 Services, Inc.
7-
SEVERE ACCIDENT MANAGEMENT PARTICIPANTS LIST l
NAME PLANT / ORGANIZATION TELEPHONE NO.
Bruce Webb South Texas (512) 972-8994 Rick Webster Fermi (313) 586-4528 James D. Weeks Wolf Creek (316) 364-8831 H. Vann Weldon South Texas (512) 972-7087 Robert A.
White Palisades (616) 764-2860 Opal White Oconee (864) P.85-3605 Ginna (716) 771-3667 Terry A.
White Kermit Whitt Southern Nuclear (205) 992-6396 William B. Willaford North Anna (540) 894-255'4 Gary F. Winkel Catawba (803) 831-3125 Doug Winters Robinson (803) 857-1702 Norb Wisniewski Point Beach (414) 755-6591 Brian Wohlers Duane Arnold (319) 851-7400 David' Young Arkansas Nuclear One (501) 858-4767 R.
Hal Young Millstone (860) 444-5695 Toshiyuki Zama Tokyo Electric (202) 457-0790 l
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l ACCIDENT MANAGEMENT:
NRC FERSPECTIVES AND EXPECTATIONS Robert L. Palla Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Presented at NEl Severe Accident Management implementation Workshop Charlotte, North Carolina March 11-13,1997 I
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OVERVIEW i
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Accident Management (A/M) is an essential element of the NRC Integration Plan for Closure of Severe l
Accident issues (SECY-88-147, May 1988). Other l
elements include:
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Individual Plant Examinations (IPEs) l Containment Performance improvement (CPI)
Severe Accident Research Program 1
l Fundamental objective of A/M unchanged from that originally stated in SECY-89-012:
i To have each NRC licensee implement an A/M plan which provides a framework for:
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- Evaluating information on severe accidents j
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- Preparing and implementing severe accident i
operating procedures and guidance i
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- Training operators, technicalsupport staff, and l
managers m the procedures i
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OVERVIEW (cont?
A/M program is vehicle for assuring insights identified through IPEs and severe accident studies are incorporated in licensee emergency.
response capabilities Dialog with industry was considered essential to A/M program success and initiated early in the program A/M program has led to industry-developed products (guidance / methods / materials) for use by utilities in developing comprehensive A/M plans in view of industry support for A/M, NRC has e
agreed to implementation through an industry initiative in lieu of a regulatory action NRC remains committed to importance of A/M and the responsibility to assure high quality implementation across the industry Some level of inspection anticipated at each plant to develop confidence in program implementation
14:
i, NRC PHILOSOPHY REGARDING ACCIDENT MANAGEMENT A/M capabilities currently exist to varying e
degrees.NRC seeks:
Incrementalimprovements in good programs High quality across the industry e
No major hardware changes Minor modifications to take advantage of existing equipment, e.g., spool piece, jumpers No major equipment upgrades, such as severe accident simulators e
Minimal burden No utility submittal requested other than J
schedule & completion date for implementation No review to prescriptive requirements i -
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OVERALL VIEWS ON UTILITY IMPLEMENTATION i
Completed industry products are technically e
sound and can be implemented No SER on SAMG or other industry products j
Further dialog with BWROG on Emergency Procedure and Severe Accident Guidelines Utilities can implement industry A/M prcOcts e
without prior staff approval Review changes to EOPs and E-Plan, and perform 10 CFR 50.59 and 50.54(q) evaluations in accordance with site procedures Assure A/M implementation does not decrease effectiveness of emergency response Concerns identified by licensees during e
implementation for which further NRC evaluation is desired should be elevated for consideration on a case-by-case basis.
EXPECTED UTILITY STEPS IN IMPLEMENTING A/M 1.
Implement industry products Develop plant-specific A/M guidelines (and EOPs) based on owners group products Evaluate severe accident training needs and implement enhancements consistent with a Systems Approach to Training Systematically evaluate A/M capabilities to confirm effectiveness of implementation i
2.
Institutionalize the A/M plan to maintain capabilities and accept new information should it become available 3.
Perform periodic A/M drills and self-assessments
NRC PLANS FOR INSPECTING A/M IMPLEMENTATION Participate in industry-hosted A/M i
demonstrations at 2-4 plants to observe how elements of formal position are being l
implemented Evaluation of implementation guidance rather than acceptability of host-plant implementation Headquarters personnel, with Regional participation in 1ater visits Determine appropriate scope / depth of pilot inspections based on demonstrations, and complete the draft Temporary Instruction (TI)
Conduct pilot inspections at 4-5 plants using TI.
Additional plants if necessary Represent each NSSS type and NRC region Mix of headquarters and Regionalinspectors
i NRC PLANS FOR INSPECTING A/M IMPLEMENTATION (Cont)
Develop draft inspection Procedure (IP) based e
on findings from pilot inspections Abbreviated version of Tl Evaluation, of licensee self-assessment process expected to be key element i
e Hold public meeting / workshop to discuss results of pilot inspections and draft IP e
One-time inspection of implementation at remaining plants using IP i
e inspect A/M maintenance on a for-cause basis, as a Regional initiative Maintain oversight using modified EP procedure (IP 82301/82701)that recognizes SAMG Perform for-cause inspection usMg IP for one-time inspection t
OVERVIEW OF DRAFT Tl i
Objective: verify licensee has evaluated and i
implemented enhancements to A/M capabilities j
in accordance with formalindustry position and j
i Two-part evaluation addresses implementation process and. licensee performance during drill Inspection requirements keyed to closure process and implementing elements set forth in formal industry position 1.
implementation of plant-specific SAMG 2.
integration of SAMG with EOPs and E-Plan 3.
incorporation of severe accident information into training programs 4.
maintenance of A/M capabilities 5.
periodic A/M drills 4
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1 REMAINING NRC ACTIONS Develop comprehensive program description and e
provide training for Regional staff to assure consistent expectations / perspectives within i
NRC NRR/ Headquarters Emergency Preparedness inspectors Resident inspectors l
Continue dialog with industry regarding A/M o
demonstrations. Develop inspection guidance as appropriate e
Complete review of BWROG A/M products Continue to work with industry on methodology implementation details.
Clarify guidance to inspectors regarding training and examination on severe accident material (revisions to examiner standards, workshops) 9_
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SUMMARY
A/M program will enhance capabilities to e
prevent and to mitigate severe accidents i
Closure will be achieved on a plant-by-plant e
basis implementation ccmpleted iF occordance with industry initiative adequacy'of implementation confirmed by inspection A/M capabilities will be maintained "living" e
periodically exercised by conducting utility A/M drills periodically updated by utility to incorporate new information NRC will maintain oversight of utility capabilities e
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i Questions for NRC and Responses 1.
Is 50,54(x) used when entering SMG space?
RESPONSE
50.54(x) would generally be applicable.
However. all rules do not go out the window when SMG is used.
Each action taken under SMG should be considered individually with respect to 50.54 (x) and (y).
2.
Who is the. final authority for decision making at the plant?
RESPONSE: The Emergency Director or whomever is designated in the site Emergency Plan.
3.
Will NRC accept a diversity of approaches relative to the location and level of decisionmaking, and on strategy location?
RESPONSE
The staff agrees in concept with the BWROG methodology for relocating SM strategies and decisionmaking as indicated in previous correspondence. Thus, a diversity of approaches is possible.
NRC has some concern about introducing unnecessary plant-to-plant variability regarding locating SM strategies, and therefore expects to work with industry further in this regard.
4.
Please provide some human factors insights.
RESPONSE
In response, staff discussed the importance of the decisionmaking process, and cautioned utilities to pay attention to human needs to reduce the stress of the severe accident environment.
Staff noted that under stress, people lose sight of peripheral asks and information, short-term memory is affected, and decisions are polarized
.and teamwork is reduced.
With regard to training, thoughtful consideration or analysis of site-specific needs, not formal job and. task analyses, are important.
It was also recommended that-licensees review NUREG-1358 Supplement 1.
5.
Can the contrbl room operator.s be held liable for actions that they take that might-be contrary to their licensing basis when such actions are at the direction of the Em.ergency Director?
RESPONSE: The NRC would review the circumstances of the event and make a
-decision on a case-by-case basis.
6.
Will NRC ins)ections of SMG implementation be based on the Owners Group
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material? W1at other information will be required?
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RESPONSE
The details of the ins)ections have not been fully developed.
l The inspection procedure will be (eyed to the NEI 91-04. Rev.1 recuirements for SMG. and the major commitments contained in the formal e
I incustry position on SM.
The NRC does not. intend to re-open review of I
the Owners Group material during inspections.
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l t 7.
NEI said earlier that EP exercises are independent of SAMG use.
NRC said that IP 82301 will be modified. These two statements seem contradictory.
Which one is true?
RESPONSE
There is no requirement to use SAMG in EP exercises. However, the EP inspection procedures will be modified to reflect the existence of the SAMG.
No more detail in these inspection procedures is expected than exists currently.
8.
What is the point of the NEI participation when the NRC is going to inspect SAMG?
RESPONSE
NEI developed the standard (i.e.. the formal industry position on severe accident management) rather than NRC writing a generic letter.
NRC intends to inspect the licensee's implementation against the commitments contained in the formal position.
9.
What will be NRC's role in the NEI Demonstrations? What is the implementatior: guidance? Utilities would probably like to see some acceptability of host-plant implementation since there are no other regulatory acceptance guidelines.
RESPONSE
NRC participation in the NEI demonstrations will be to assess the adequacy of implementation guidance as opposed to an inspection. The specific implementation guidance is the formal industry position and supporting guidance in NEI 91-04. Revision 1. and the severe accident management guidance and EPG changes developed by the Owners Groups, and the training materials and guidance developed by INPO and the Owners Grou)s.
The NRC will look at whether the plant specific guidance and capa)ilities developed based on the generic guidance achieve the intended objectives.
- 10. Does the NRC plan to include the TI in a future revision of IP 82301 and 82701?
RESPONSE
The TI will address both process-and performance-based components of accident management implementation.
The TI will be used only for the pilot inspections.
Based on the insights from the pilot
. inspections, an inspection procedure (an abbreviated form of the TI) would be developed to guide the one-time inspection at the balance of plants.
The TI is not intended for inclusion in the two inspection procedures.
- 11. If SAMGs are referenced in the E-Plan and/or EPIPs. don't they (SAMGs) become commitments against further/ future routine EP inspections?
RESPONSE
Yes.
RESPONSE
The team makeup has not been identified.
Headquarters. staff (PRA. EP. Human Factors. Operations Center) will likely be at the NEI demonstrations and the NRC's pilot inspections.
There may also be some
i,.
regional inspectors in the later demonstrations and inspections.
In the longer term the responsibility for inspection of SAMG implementation at the balance of plants and for maintenance of accident management capabilities will be transferred to the regions.
- 13. Will assessment of SAMG mcterial be conducted only via A/M or mini-drills, and not during annual EP drills? Will utilities be forced or exoected to get into SAMG space for event mitigation during the annual EP drills?
RESPONSE: The current EP regulations provide the latitude for exercising SAMG during off-year EP drills, but this is and will not be required.
- 14. Will examination of licensed operators (initial and requalification) be limited only to their areas of res)onsibility during severe accidents?
Would the areas of responsibility ]e identified by the Owners Group or the individual utility?
RESPONSE
Staff views on operator training and examination on severe accident mar.,gement guidance are provided in the August 1.1995 letter to the BWROG.
In general, the training would be limited to areas of the operators responsibility. (i.e.. up to and including transition to the SAMG). but knowledge of broad topics such as the objectives and responsibilities once in the SAMG should also be included.
Detailed questions on specific SAMG strrtegies and guidelines are not expected.
~ 15. Discussions have been limited to ERO training (implementers, evaluators, and decision-makers).
Has consideration been given to either performing a SAMG scenario with offsite interface or giving overview training to offsite agencies (state, counties. etc.)?
RESPONSE
The NRC thinks this is a licensee issue.
In the longer term.
NRC expects to provide training an the generic SAMG to members of the NRC Incident Response Center teams, and to further consider entering into joint accident management-oriented drills with licensees.
- 16. With res)ect to the 1986 letter from NRC to Mr. Ken Berry at Consumers Power, t1is letter indicates that decisionmaking responsibility during severe accidents need not be a licensed SRO.
If I understand correctly, the decisionmaking responsibility rests with the senior line management member present and can be no less than an SR0 who would be the senior line management member present on back shifts.
Does the NRC concur that this was the message of the letter?
i RESPONSE: This question will need to be addressed after appropriate l
consultation within the agency.
- 17. What is the NRC view of table top drills, controller / observer intervention, and pass / fail criteria?
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RESPONSE
Table top drills are not graded exercises. Thus, flexibility in how licensees conduct such drills is reasonable.
The role / merit of controller intervention depends on the nature of the drill; intervention
,/
1 is reasonable for a training drill but should be minimized for an evaluation drill to preserve drill realism. Whether a licensee uses a pass / fail criteria or some other means of grading performance is not as imaortant as assuring that an unbiased self-assessment.is performed and l
su) sequent corrective actions are identified.
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