ML20153B860
| ML20153B860 | |
| Person / Time | |
|---|---|
| Issue date: | 08/23/1988 |
| From: | Martin T Office of Nuclear Reactor Regulation |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8808310125 | |
| Download: ML20153B860 (4) | |
Text
19018 o ne go, UNITED STATES
[
g NUCLEAR REGULATORY COMMISSION r,
- e WASMG TON, D. C. 20666
\\..... p AUG 2 31988 MEMORANDUM FOR: Khomas E. Murley,11 rector Office of Nuclear Reactor Regulation FROM:
Thomas T. Martin, Acting Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation
SUBJECT:
VPDATE ON E0P ACCELERATED INSPECTIONS Our original schedule of 16 inspections (EOP-1) is now complete. Our review of Mark I BWRs is ongoing 'and is due to be completed by early October. A meeting was held on August 3 to gather together E0P-1 team leaders and regional branch chiefs for a debriefing session. Tentative conclusions that were drawn during that meeting were:
1.
There was great variability in our sample in both the procedures upgrade programs and the quality of emergency procedures themselves. However, we did not in any case identify a plant that could be pointed out as a model of good practice. Every plant suffered from some programmatic flaw that could cast doubt on the ability of the plant to assure that emergency 1
procedures have been developed in a systematic, controlled manner, or that they will continue to be maintained in a technically correct and useable form, or both.
2.
Although most of the licensees provided evidence that they can safely operate their plants, it was obvious that, in some cases, they would be operating in spite of the fact that they have poor procedures--the training and experience of the operating crew being the stopgap.
3.
B&W plants suffer from a lack of approved generic guidance--this fact along with other related concerns leads to the conclusion that the remaining few B&W plants should be given priority in any follow-on program.
4.
Since Revision 4 of the BWROG gerieric guidelines may soon be approved and implemented by plants, we should consider putting BWR inspections on
")ause' until Revision 4 is fully implemented. The focus in the interim s1ould be on assurance that effective training on the revised E0P's is carried out.
CONTACT:
G. Lapinsky, HFAB:DLFQ F
~
49-21028 5q$
f i
i h5 fp.
l Thomas E. Murley,
5.
The CE generic guidelines, to a greater degree than any other vendor i
guidelines,retainedasignificantrelianceonevent-basedproceduresas i
an optimum approach to sate shutdown when the event was diagnosed or identified. They also, of course, include symptom-based procedures which are meant to provide the principal approach, particularly in the early stages of an incident.
There emerged a generic concern with CE plants regarding the lack of emphasis given to symptom-based E0Ps--this, coupled with other related issues such as training duration and frequency, may require additional generic guidance from the CE Owners Group and plant specific attention on the part of utilities operating CE plants to re-orient operator training programs in order to meet the original intent of the TMI action ple). At the present time a disproportionate amount of time is spent trainir)g operators to use the event-based procedures. Some operators in car sample of CE plants were not confident that they could j
mitigate an accident using functional (symptom-based) recovery procedures.
6.
Some plants failed to recognize the value of our guidance regarding the systematic and controlled processes necessary for the development and i
maintenance of emergency procedures.
For example, Supplement 1 to NUREG-0737 calls for a programatic element of procedure validation.
It was obvious from the large numbers of deficiencies in the procedures that an effective validation of the E0Ps was not done at some plants.
7.
Some plants were unresponsive to operator feedback about E0P problems.
8.
The kinds and numbers of deficiencies identified by our inspections retlects a lack of management comitment to the E0P upgrade effort. Some identified concerns were:
a) rarely was a comprehensive organizational approach taken--in several cases station engineering was not involved, in many cases QA was not involved, and in a few cases utility personnel were not directly involved in the development of their E0Ps at all--the task was delegated to outside consultants
- b) inadequate review of E0Ps that led to inaccuracies, errors, omissions or E0P steps that could not be executed;
\\
c) lack of oversight and control by management and Plant On-site Review Consnittees, both during original developent and during subsequent j
revisions of E0Ps especially evidenced by the weak V&V programs that j
existed at some plants; i
d) often only one person was responsible for every aspect of upgrading E0Ps--this sometimes resulted in unrecognized problems being perpetuated from beginning to end of the upgrade process; i
e)
E0Ps suffered from "sloppiness" and inconsistency bect.use of inattention to detail--especially during the revision process; this led, in some cases, to references to steps and/or equipment that no longer existed; 9c.
, _. _ _ -. _ _ _ ~. _
Thomas E. Murley '
f)
A few plants failed to provide effective training on all procedures that are expected to be used during emergency conditions.
9.
With a few exceptions, most notably Vemont Yankee, the BWR plants inspected thus far have not demonstrated the ability to vent containment under postulated accidont conditions. The licenseas typically rely on venting through the Standby Gas Treatment System, usually via a 2 inch hard pipe, discharging into 18 inch or larger sheet metal ducting which is not expected to withstand the resulting pressure. Detailed engineering evaluations substantiating the containment venting approaches have typically not been available, leaving unanswered questions relating to the ability of the downstream piping to handle the gressures anticipated during the conduct of vent operations, the ability of tie chosen vent path to pass flow at a rate sufficient to depressurize and maintain containment given the assumed core residual heat levels, the ability of isolation valves to open and reclose against anticipated pressures, and the ability of operators to manually operate required valves under station blackout conditions or with post-LOCA radiation levels present. Licensees generally have made little effort to identify viatle alternative vent paths and to incorporate them into procedures.
This is not a full recounting of all of the important findings and conclusions ciscussed at the August 3 meeting. The Human Factors Assessment Branch is currently writing a comprehensive internal report that will describe the E0P-1 results and provide staff conclusions and recomendations. We are targeting that report to be on your desk by August 31.
It apr that follow-on will likely include extensive comunications to the industry (NUREG, generic letter and regional meetings), some further inspection effort, with B&W plants getting the most imediate attention, and some method for assuring that effective training programs will be put in place for the new E0Ps resulting from Revision 4 of the BWR guidelines.
~
Thonis T. Martin, Acting Associate liirector for Inspection and Technical Assessment Office of Nuclear Reactor Regulation I
i l
i[
i,6c
_ [,$._ _ _ _ _ _ _
i i
8 FIh, 8[,g6
'o, UNITED STATES NUCLEAR REGULATORY COMMISSION o
1)
W ANU NGTON, D. C. 20M6 (o..,*,/
l August 29, 1988 NOTE FOR:
J. Rathje NRC Public Document Room H Street Lobby DocumentControlDesk{
i P1-137 FROM:
Hazel Smith, NRR
SUBJECT:
PUBLIC AVAILABILITY OF MEMORANDUM DATED AUGUST 23, 1988. FROM T. MARTIN TO T.'MURLEY ENTITLED ' UPDATE ON E0P ACCELERATED INSPECTIONS" 1
NRR is expecting to give the captioned memorandum (copy enclosed) to several members of the public in the near future. Therefore, this is to request that the enclosed memorandum be put on public display insnediately. Please contact me on extension 21287 if additional information is needed.
d QH el
, NRR j
Enclosure:
Memorandum dated j
8/23/88 from T. Martin to T. Murley cc: w/ enclosure T. Murley F. Gillespie C. Thomas i
G. Lapinsky
- 1. Bailey, Central Files
,a 9E.
i
.