ML20154D794
| ML20154D794 | |
| Person / Time | |
|---|---|
| Issue date: | 05/04/1988 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Jordan E, Ross D, Sniezek J NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD), Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20153F028 | List: |
| References | |
| NUDOCS 8809160107 | |
| Download: ML20154D794 (15) | |
Text
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$ j WASHINGTON, D. C. 20656 May 4, 1988
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MEMORANDUM FOR: E. L. Jordan AE0D D. F. Ross, RES J. Sniezek, NRR J. Scinto, CGC C. Paperiello, RIII FROM: Robert M. Bernero, Deputy Directcr Office of Nuclear Material Safety and Safeguards
SUBJECT:
GENERIC LETTER FOR INDIVIDUAL PLANT EXAMINATION (IPE)
The draft minutes of our extended meetings on the IPE Generic Letter are succinct and reflect the consensus of the CRGR on this subject. Nevertheless, I would like to add some remarks of my own to emphasize the importance of CRGR Recomendation No. 2. The CRGR says "The staff should seek volunteers...whose plants have already been extensively analyzed...to participate with the staff in an expedited implementation of the complete IPE process in accordance with the Generic Letter."
In these IPE Generic Letter nieetings the CRGR was told that no plant had yet presented an acceptable severe accident risk analysis, and so all plants had to do further analysis. In addition, the documents and the briefings repeatedly touched on apparently intractable problems, particularly with uncertainties about post core melt behavior, issues such as direct containment heating, Mark I liner meltthrough, etc. One is left with the impression that the severe accident matter 4 not yet ripe for decision and action to assure or improve plant safety, i<ather, t' approach is more toward sending all owners out to do further analysis in the hope that somehow the troubling i
uncertainties can be overcome.
There were great uncertainties about severe accident behavior right after THI; there are great uncertainties toda uncertainties nine years from now.y,Severenine years later; accident anddecisions safety there willmust be great be made in the face of these uncertainties. Many should recall the post-TMI issue of hydrogen control in the Mark I and Mark !! BWR containments. The PRA wisdom of the time indicated that it was not worthwhile to inert these containments since simple overpressare failure was just as likely to cause early failure as hydrogen combustion. It was a regulatory decision that required inerting of those containments in spite of that uncertainty, Now, I doubt that anyone regrets that regulatory decision.
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Addressees May 4, 1988 And so the key issue here is not further, better analysis but the evaluation of the results of state-of-the-art analysis, and the decisions on what to do.
Just as the IDCOR process lingered for seven years, so will the IPE Generic Letter process linger unless the uncertainties are confronted and decisions made soon. I personally believe that the action on CRGR Recomendation No. 2 is urgently needed to bring closure on the severe accident issue in operating plants before a substantial part of tneir operating lives has passed.
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MEMORANDUM FOR: E. L. Jordan, AEOD D. F. Ross, RES J. Sniezek, NRR J. Scinto, OGC R. M. Bernero, NHSS FROM: Carl J. Paperiello, Deputy Regional Administrator, Region III
SUBJECT:
GENERIC LETTER FOR INDIVIDUAL PLANT EXAMINATION (IPE)
While I endorse the draft minutes of our extended meetings on the IPE Generic Letter, I agree with Mr. Bernero's memorandum of May 4, 1988, on the importance of CRGR Recommendation No. 2. I believe that the final guidance should tell licensees how the current unresolved issues such as direct heating, Mark I liner meltthrough, and others should be handled.
Carl J. Paperiello Deputy Regional Administrator
SUMMARY
AND ISSUE IDENTIFICATION for.
CRGR Agenda Item - Meeting No. 134 April 18, 19E,8 AGENDA ITEM Proposed Generic Letter and Guidance for Licensee Performance of Individual Plant Examination (IPE) Specified in the Commission's Severe Accident Policy Statement.
OBJECTIVE The staff has requested that CRGR review and recommend in favor of issuing a proposed Generic Letter requesting that each licensee perform an Independent Plant Examination (IPE) called for in the Commission's Severe Accident Policy Statement, in accordance with proposed guidance to accompany the Generic Letter. In essence, the proposed guidance would be for licensees to perform a Level I PRA (with what appears to be a significantly lower cutoff level for selection of "candidate" sequences that must be considered), and an evaluation of containment performance, excluding analysit of external events (for the present), to satisfactorily accomplish the search for risk outliers discussed in the Severe Accident Policy Statement.
BACKGROUND A. The documents submitted initially for CRGR review by the co-sponsoring offices (RES and NRR) were transmitted by memorandum dated March 30, 1988, E.S. Beckjord to E.i.. Jordan; the review package included the following documents:
- 1. Oraft Predecisional Generic Letter, dated March 25, 1988s "Individual Plant Examination for Severe Accident Vulnerabilities -
10CFR50.54(f)", with appendices and attachments as follows:
- a. Appendix 1 - Guidance on the Examination of Containment System Performance (Back-End Analysis)
- b. Appendix 2 - Criteria for Selecting Important Severe Accident Sequences
- c. Appendix 3 - Accident Management
- d. Appendix 4 - Documentation
- e. Appendix 5 - Decay Heat Removal Vulnerability Insights
- f. Attacbr snt 1 - HUi:EG/CR-4920, "Assessment of Severe Accident Prevention and Mitigation Features (5 Volumes)
Vol. 1, "BWR Mark I Containment Design"
)
m Vol. 2, "BWR Mark II Containment Design" Vol. 3. "BWR Mark III Containment Design" Vol. 4, "PWR Large Dry Containment Design Vol. 5, "PWR Ice Condenser Containment Design
- g. Attachment 2 - List of References of the 10COR Program Reports and Key NRC Reports
- 2. Oraft Evaluation (undated) of the IOCOR IriM for BWR
- 3. Draft Evaluation (undated) of the IOCOR ?.PEM for PWR B. Additional documents reque:ted for CRGR as r. result of preliminary review of the package submitted initially by RES/N4R:
- 1. Information Required by CRGR Charter,Section IV.B. , "Contents of Packages Submitted for CRGR Review"
- 2. Staff Response to CRGR Comments Regarding IPE Areas Needing Improvement or Clarification (See Attachment 1 to this Issue Sheet - Excerpts from Minutes of CRGR Meeting No.125 (Initial Briefing on IFE Letter)
NOTE: SUPPLEMENTAL DOCUMENTS B.1 AND B.2 HAD NOT BEEN RECEIVED IN CRGR STAFF 0FFICE AS OF COB 4/13/88, 50 RES COMMITTED TO TRANSMIT THEM DIRECTLY TO CRGR MEMBERS BY NO LATER THAN COB 4/14/88. SOME OF THE ISSUES AND QUESTIONS BELOW RAISED BY CRGR STAFF REGARDING THE PACKAGE SUBMITTED FOR CRGR REVIEW AT THIS TIME MAY BE ADDRESSED IN THESE TWO DOCUMENTS.
ISSUES / QUESTIONS A. Generic Letter
- 1. In its present form, the wording of the letter suggests too strongly that there is a serious question that the "adequate protection" standard is not being met by currently operating reactors. Because of the languwe in which 50.54(f) is framed, simply invoking that rule raises the spectre of having to revoke licenses and shut Pwn plants becam i they are unsafe. The general tone of the proposec letter shouid be modified to better convey that, while operating experience and numerous PRAs performed to date suggest that some severe accident vulnerabilities might be found by a systematic examination of each plant, only rarely would it be expected that an existing plant would have to be modified to achieve or maintain an adequate level of safety (i.e, so that a license could be "continued" in 50.54(f) context). On the other hand, experience to date indicates that cost effective safety improvements, pursuant to 50.109, can usually be identified as a result of such systematic examinations.
Also, in view of the large number of plant-specific t' ras that have now been comple*,ed or undertaken by individual licensees, the staff's posture could reasonably be that the systematic examination of individual operating plants has become the norm (i.e., it is now to be expected of responsible licensees) consistent with the intent of the Commission's Severe Accident Policy.
This would provide a better tone and balance for the proposed letter.
It seems more consistent with the intent of all the applicable exist-ing regulations (specifically, 50.54 and 50.109, as each applies in this case), and the intent of both thilafety Goal Policy Statement and the Severe Accident Policy Statement, all takea together as they should be. 50.54(f) is invoked for purposes of obta!ning inform-ation about severe accident vulnerabilities, consistent with the Commission's intent as expressed clearly in the Severe Accident Policy Statement. 50.109 should also be invoked conspicuously in the proposed Generic Letter to reassure licensees that in the conduct of the IPEs and the evaluation of IPE results, the staff will remain mindful of its responsibility not to cause unnecessary resource burdens by requiring backfits that are not justified by the stand-ards of 50.109 (i.e. , either to achieve or maintain adequate pro-tection, or to provide substantial and cost effective safety improve-ment). This is particularly important because the Generic Letter package as a whole still seems very sparse and weak in its treatment of the relationship between the IPE goals and the Commission's Sa'ety Goals.
- 2. In Section 3, "External Events" (at p. 3 of the GL), The wording of the last sentence should be revised along the following lines:
"The NRC staff intends to work with NUMARC toward development of an acceptable methodology for examination of external events and their contribution to overall severe accident risk."
- 3. In Section 7, "Severe Accident Sequence Selection" (at pp. 8-9 of the GL):
- a. Is it just me or are the definitions at the bottom of p. 8 unnecessarily complicated, bordering on the inscrutable? Are the.4 "standard" terminologies in PRA circles? Will they be widely understood by the licensees, especially those who have not yet been involved in PRAs? "Systemic sequence" is defined but is not used here; is the definition really necessary here?
- b. The wording of this section seems generally too open ended and could be misconstrued to indicate more work for licensees than is intended or than could be justified in performing the IPEs.
To correct this, the wording of this section should be revised along the following lines:
- First sentence on p. 8 l
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4
- First sentence on p. 8 of the GL "In performing an IPE, it is necessary to sort out the potentially important sequences that dominate or contribute most significantly to the probability of occurrence of a severe accident."
- A more useful footnote could then be added that ties thi-statement of objective or intent to a ters that has been widely used, and would perhaps be better understood in conveying the intent of the IPEs, i.e. , "outliers". The footnote would read as follows:
"The important or dominant sequences are also sometimes referred to as "outliers", and their consequence is the "vulnerability" of a plant to severe accident." Of the very large set of possible severe accident sequences that can be postulated for any plant, the cumulative results of the many PRAs performed to date indicate that there is usually a small number that will dominate the core damage frequency for a plant, and even fewer that will dominate the offsite risk of r facility."
- Last sentence on p. 8 and first full sentence on p. 9 "It is expected that during the course of the examination, the utility would carefully examine the results to determine if there are additional prevention or mitigation measures that might be reasonable and cost effective to reduce the core damage frequency and/or improve poor containment performance that could result in significant radioactive release. The determination of potential benefits is plant specific and will depend on the frequency and consequene.e of those accident sequences that contribute most importantly to the probability of core damage and/or containment failure."
- 4. In Section 8, "Staff Use of IPE Results" (at pp. 9-10 of the GL):
- a. Same comment as in 3. above with respect to "open-ended"ness of the wording here. This section should be improved along the following lines:
- F_irst sentence of the second paragraph on p. 9 "The NRC will evaluate...to obtain a reasonable degree of confidence that the licensee has analyzed... operations suitably to discover...given the dominant core damage accidents."
- Last full sentence on p. 9, and the following sentence "The consideration will include...and will use...as one factor in gauging the level of regulatory concern that should be given to identified vulnerabilities. Where the L
5 identified vulnerabilities raise serious question as to whether the plant design and operation provides adequate protection (in accordance with the statutory standard),
corrective measures will be implemented to achieve or maintain an adequate level of safety without regard to considerations of costs. Otherwise plant specific backfit determinations will be made generally in accordance with the standards set forth in 50.109. In some unusual cases, the NRC may determine, because of large or indeterminate analytical uncertainties, unusually poor human perfomance, and/or operational management deficiencies, some corrective measures must be taken to assure adequate protection, even though identified vulnerabilities may not seem of themselves to warrant any action. [Then delete all of p. 10.]
- 5. In Section 9, "Accident Management" (at p.11 of the GL):
- a. Similar concern regarding "open-ended"ness of some wording there, e.g.:
- Penultimate sentence on p. 11 Delete the word "all".
B. Appendix 2
- a. In the third sentence on p.1, what is the intended meaning of the words at the end of that sentence "...and behavior that can be used to determine consistency with the Commission's Safety Goal Policy."
This kind of vague reference to the Safety Goals does not respond adequately to the Committee': question regarding the relationship between IPE goals and the Safety Goals. Was it intended to do so?
C. Appendix 3
- a. The second sentence on p. 1 and the third sentence on p. 3, taken together, seem to strongly suggest requirements for degraded core /
severe accident EQ. Is that really the staff's intent? The Committee should request the staff to clarify this very important point.
- b. In the third line on p. 2, what are "leading accidents"? How are they related to the "leading accident sequences" in the first sentence of the Procedures and Training section on p. 3? What are the relationships between these terms and more common terms such as "dominant accident sequences", "dominant vulnerabilities", "core melt accidents", etc.?
- c. Appendix 3 calls for "consistency" and "smooth transition" between existing E0Ps and procedures developed under the new accident management plan. Does this imply that the accident management procedures to be developed by the licensees under the provisions of Section 3 of this Aprendix must be symptom oriented for compatibil-ity with existing EPGs/EOPs, even though the IPE results from which i
f
r 6-the licensees are expected to derive these procedures are principally event / sequence oriented (in accordance with the guidance in this IPE package)? Same question with regard to the accident management instrumentation referred to in Section 2 of the Appendix? In that same vein, is the containment venting guidance given in Appendix 3 and NUREG/CR-4920 compatible with existing EPGs/EOPs (e.g., BWR EPG Rev. 2, 3, and 4)? The Committee may wish to have the staff clarify what is actually intended here.
- d. In the third sentence of the second paragraph on p. 3, delete the word "all". Also change "the necessary functions" to "accident management objectives".
D. Appendix 4
- a. Item 2. should say "A list of initiating events that are considered by the licensee.. ." (surely not all initiating events are really expected to be listed here),
- b. Item 11 on p. 2 is too open-ended in its current form. It should be revised along the following lines:
"For those outliers or particular vulnerabilities identified in accordance with Appendix 2 and the additional guidance in Section 7. of the Generic Letter (as amended in A.3 above],
identify those that the licensee has already corrected or intends to voluntarily improve / correct by implementing equipment changes, by changes to maintenance, operating and/or emergency procedures, surveillance, staffing or training programs.
Provide a prioritized schedule for accomplishing improvements not already completed. Include a discussion of the anticipated benafit of these improvements. Sequences examined but not selected for improvement should also be identified."
The requirement for licensees to provide the rationale for not voluntarily implementing even cost effective improvements for a,1J candidate sequences (as is indicated by the current wording),
seems to turn the backfit rule on its head. The burden should be on the staff to make the case for further improvements if they believe they are warranted. The staff will at that point have information (obtained pursuant to 50.54(f) with which to proced (under 50.109) if they believe further action / improvement can be Justified. It seems relevant to recall in this context, however, that the yardstick applied by the staff for imposing backfits in two earlier well known severe accident contexts (i.e., ATVS and Station Blackout) was a 10E-5 core melt frequency (roughly an order of ragnitude higher than the corresponding proposed IPE screening criterion of 10E-6. The Committee should question the staff closely on this aspect of the IPE package; such a change would appear to involve a significant policy issue.
- c. The wording of Items 5. and 6. in their current form appear to require full analysis of core damage phenomena, core melt
progression, containment failure mode / tining, source term and release phenomea, etc. for all candidate accident sequences above the Appendix 2 screening criteria. It does not seem to allow for proven techniques that have been employed commonly in PRAs (such as binning, use of release categories, etc.) for consolfd6lon of saquences that are similar in some important respects, in order to minimize unneces-sary and expensive runs on the highly complex codes involved. The Committee may wish to discuss this matter in some detail with the staff to determine their actual intent. If the staff's intent is not as characterized above, then the wording of Items 5. and 6. should be changed to clarify that that is definitely not so. If the staff's true intent is as as characterized above, the Committee should require justification for the very substantial and increased resource burden that would appear to be involved for the licensees in this proposed requirement.
t
Enclosure 2 to the Minutes of Meeting No. 125 Briefing on Severe Accident Policy implementation November 25, 1987 TOPlc T. Murley (NRR), T. Speis (RES), B. Sheron (RES), and F. Coffman, (RES) brief ed the Committee on the status of the staff's efforts to develop guidance documen-tation for implementing the systematic examination of operating nuclear power plants and the plant-specific vulnerability searches called for in the Commis-sion's Severe Accident Policy Statement. T. Murley addressed the several major current activities within NRC that relate to the severe accident issue, sum-marized current NRR thinking and planning regarding actual implementation of the Severe Accident guidance being developed by RES, and identified the prin-cipal issues identified by NRR as a result of their review of the proposed IPl Generic Letter and associated guidance documents that have been developed by RES. T. Speis, and the other RES representatives identified above, summarized for the Committee the background for the development of the IPE Generic Letter and the details of the actual guidance documentation that has been developed by RES. Copies of the briefing slides used by NRR and RES to guide their presenta*
tions and the discussions at this meeting are attached to this enclosure. (See Attachments 1 and 2, respectively.)
BACKGROUND
.. A package of draft predecisional documents currently being developed by the staff for implementing a systematic examination of each operating nuclear power plant was provided to the Committee in connection with this briefing; that package was transmitted by memorandum dated October 2, 1987, from E. Beckjord to E. Jordan, and included the following:
- a. Draft Generic Letter, dated October 1, 1987, entitled "Individual Plant Examinations for Severe Accident Vulnerabilities," and Appendices and Attachments as follows:
- 1. Appendix 1 - Guidance on Containment System Performance (Not yet available - to be provided later)
- 2. Appendix 2 - Sequence Selection Criteria and Criteria to Determine the Adequacy of the ?.PE
- 3. Appendix 3 - Accident Management Plan
- 4. Appendix 4 - Documentation 5.
Attachment 1 - (As appropriate, transmitted to i MITvidual licensees):one of the following w
- HUREG/CR-4920, Volume 1, dated October 1987, "Assessment of Severe Accident Prevention Features: BWR, Mark 1 Containment Design"
- NUREG/CR-4920, Volume 2, dated July 1987, "Assessment of Severe Accident Prevention Features: BWR, Mark 11 Containmert Design"
- NUREG/CR-4920, Volume 3, dated July 1987, "Assessment of Severe Accident Prevention Features: BWR, Mark III Containment Design"
- NUREG/CR-4920, Volume 4, dated March 1987, "Preventfor and Mitigation of Severe Accidents: PWR, large Volume Containment Design"
- NUREG/CR-4920, Volume 5, dated March 1907, "Prevention and Mitigation of Severe Accidents: PWR, Ice Condenser Containment Design"
- h. Attachment 2 - List of References (IDCOR Program Technical Reports and Key NPC Reports)
(Not yet available - To be provided later)
- 2. Updated versions of documents listed under 1 above were previded by RES just prior to Meeting No. 125 and were distributed to CRGR rembers at the meeting, es follows:
- a. Draft Generic Letter and Appendices Nos. 1-4, dated November 19, 1987 b, New Appendix 5 to the Generic letter, "Unresolved and Generic Safety Issues (US! and GSI)"
- c. AUREG/CR-4920, Volumes 1-5, dated November 1987 NOTE: For purposes of completeness of record, the package of updated documents listed above will be designated as Attachment 4 to this enclosure, and will be maintained in CRGR files with the record copy of the minutes of Meeting No. 125. Due to the bulk of this package of documents, they will not be distributed with the minutes, but will be available to interested /
authorized parties for inspection and copying.
O!SCUSSION/ COMMENTS Tric general thrust of the Cemittee's coments and ouestions to the staff in this briefing was concern regarding the uncertainty and confusion evident at this stage over the definition of IPE and the scope and schedule of the overall effort that will be required by both licensees and NRC in implementing the IPE program. The general feeling of the Comittee was that the IPE package had considerable maturing to do before it would be ready for formal i
l review by,CRGR. More specifically, the Committee identified the following areas in which it would expect to see improvement or clarification when the IPE package was sent forward for formal CRGR review:
- 1. A fundamental concern of the CRGR was whether this effort is worth the resources to be expended in view of: the diversity of expected licensee IPE.submittals; the existing uncertainty of the risk / safety improvements expected to be realized from the IPE program; the lack of clear defini-tion of NRC's goals in undertaking the Individual Plant Examinations; and the an.:ertain relationship between the IPE goals and the Commission's safety goals.
- 2. The proposed generic letter specifies several options that can be used to satisfy the ,x?mination requirements. These vary from an abbreviated In addition, an PRA, i.e., 10COR IPEM, to a full scope level III PRA.
option is presented for licensees to use other systematic evaluation methods. CRGR raised questions regarding what scope and depth of analysis is needed and expected of licensees, and what are the differences (weak-nesses and strengths) of the IDCOR methodology vs. that for PRA. Concerns were expressed that it was difficult to see how such a wide range in scope (from an abbreviated level 1 PRA to a full scope level III PRA) could all be acceptable and consistent with NRC's goals. Further, the options on methodology were of concern in the absence of staff analysis of the possible differences in the completeness and acceptance of the results.
For example, there were indications that staff and 10COR containment analyses produce substantially different results. Further, there was uncertainty whether a Susquehanna-type IPE would be considered acceptable now by the staff. If generic procedures are acceptable and in fact desirable, why would generic IPEs also not be an acceptable approach?
Also, would an external (seismic) event evaluation methodology, based on a mechanistic (rather than probabilistic) treatment of seismic hazard, such as the EPRI Seismic Margins evaluation method, be considered acceptable to the NRC staff?
- 3. The staff guidance on such subjects as containment failure mechanism and timing is not well specified; for example, how direct heating is to be treated. The CRGR expressed concern that, since the staff has not given definitive guidance, the resulting analysis may result in different answers even for sister plants, and the potential lack of consistency and uniformity of the submitted analyses could pose a significant problem in attempting to achieve uniformity in plant procedures and plant fixes to cope with severe accidents. Further, it was not clear to CRGR the extent to which staff guidance has been discussed with licensees, and whether the language of this guidance will be clearly understood and, thus, correctly implemented by each licensee.
- 4. The proposed staff position was that external events, such as seismic, tornadoes and floods are excluded from the scope of the IPE at this time, and efforts will continue to reach agreement with industry on methodology for external events. However, PRAs have been developed which include external events (e.g., Indian Point) and for IPEs, licensee's can submit a full scope PRA that includes external events. CRGR expressed concern that, as a result of this approach, staff resources will likely
4 be spent reviewing some PRA with external events, but not all. It appeared that this approach of different scopes at different tines could result in inefficient use of staff and licensee's resources, e.g., more than ene plant walkdown may be necessary.
- 5. The staff proposal is to send the proposed generic letter te all plants, whether or ret the plant has a PRA. Many PRAs have been completed, and since a number of these completed PRAs are level 3, which may be more in-depth and complete thar, the IDCOR IPEM cption in the proposed gereric letter, the CRGR raised the ouestion whether there may be already some plants that have been sufficiently well analyzed in the severe accident enntext that, rather thar require additional analysis, it would be appropriate to proceed to the next phase involving the need for plant specific corrective actions, including accident management plannino.
- 6. The staff should be prepared to present arturrents for/against goirg ahead with th FRA/ISAP option exclusively. Similarly, the staff should be prepared to discuss in greater detail wty it is necessary or critical to rank document accident sequerces or to treat in the IPEs doninant plant sequences that do not represent outlierr, as indicated in the proposed sequence selection and IPE adequacy criteria. With regard specifically to the proposed guidaace on containnert systems performance, how are licensees expected to apply the proposed guidance regarding redundancy and diversity for dominant accident accident sequences in this aspect of the IPE for their plant? If this guidcnce i'; reflected in NPC staff IPE review criteria, this would represent substantial beckfits for some plants. And it is not clear how such backfitting would be justified, if the IPE goals are not somehow related to the Connission's safety goals in the proposed IPE guidance package.
- 7. There shoulo be a clearer understanding and discussion of the intended scope and depth of NRC review of licensees' IPE submittals and the inter.ded schedule for completing the associated plant fixes that may flow from this effort. Consideration should be given to an IPE implementatier, approach that does not put NRR or the critical path for completing IPE implementation, e.g., the "50.59 implementation approach proposed in connection with USl A-48, Station Blackout. .it is not clear that the risk / safety improvements expected to be realized from the IPE program warrant major NRR resource expenditure in reviewing licensee's IPE submittals. (See Connent No. I above in this context.)
- 8. The staff should be prepared to discuss whether NRC could/should start now on development of generic Severe Accident Management procedures. Do we know enough now from severe accident studies to date to begin knowledgeably that process. Some were of the view that the staff could have ready in December a useful compendium of severe accident management infonnation that would effectively serve that purpose. This question should receive detailed treatment at the time of the Comittee's formal rev1ew of the IPE guidance package.
- 9. The regulatory basis for the proposed approach, a 50.54f letter, should be clearly articulated in the context of other options such as ruler'aking.
The staff should discuss actions they would take if a licensee refused to
i l
t cooperate with proposed approaches cr to impicinent the fixes indicated by i
the IPE results, The staff acknowledged the Comitter.'s comments and suggestions and indicated that they would be addressed in a revised IPE package.
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r MEMORANDUM FOR: R b rt M. Bernero, NMSS
- Carl J. Paperiello, RIII Denwood F. Ross, RES April 5, 1988 4SNb A
Joseph Scinto, OGC James H. Sniezek, NRR FROM: Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
CRGR MEETING NO. 134 The Committee to Review Generic Requirements (CRGR) will meet in the afternoon on April 18, 1988, in Room 6507 MNBB. The agenda is as follows:
1-5 p.m. B. Sheron (RES) will present for CRGR review a proposed Generic Letter, "Individual Plant Examinations for Severe Accident Vulner-abilities" (implementation cf the Commission's Severe Accident Policy Statement). The Cormittee was briefed on this matter earlier at Meeting No. 125. (Review material is enclosed.)
If a CRGR member cannot attend the meeting, it is his responsibility to assure that an alternate, who'is approved by the CRGR Chairman, attends the meeting.
Persons making presentations to the CRGR are responsible for (1) assuring that the information required for CRGR review is provided to the Committee (CRGR Charter - IV.8), (2) coordinating and presenting views of other offices, (3) as appropriate, assuring that other offices are represented during the presenta-tion, and (4) assuring that agenda modifications are coordinated with the CRGR contact (J. Conran X29855) and others involved with the presentation. Division Directors or higher management should attend meetings addressing agenda items under their purview.
In accordance with the E00's March 29, 1984 memorandum to the Commission con-cerning "Forwarding of CRGR Documents to the Public Document Room (POR)," the enclosures and other material to be distributed to CRGR members for consider-ation at this meeting, are conside.*ed predecisional information and will not be released to the POR until the NRC nas considered (in a public forum) or decided the matter addressed by the information, w .I S c .d 6 g L Wdea Edward L. Jordan, Chairman Committee to Review Generic Requirements
Enclosure:
Distribution:
As stated Central File (w/o ene.) B. Doolittle POR (NRC/CRGR) (w/o enc.) S. Treby (w/o enc.)
cc: See next page CRGR CF (w/o enc.) 7. Rehm (w/o enc.)
CRGR SF M. Taylor, OEDO E. Jordan J. Heltemes J. Conran " C.:Sakenas
@ 7 'l// /-/ 7G@-fhf 2[/> R. Fraley
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NAME :/ onranic'g : CJHeltemes : ,t3 rdon : : : :
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DATE 4/$'/88 4/ /88 : 4/
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.l cc w/ enclosures:
SECY V. Stello, Jr.
cc w/o enclosure: '
Coonission (5)
J. Lieberman S. Ebneter W. Mcdonald Regional Administrator W. Parler T. Speis
- 8. Sheron i t-