ML20198R711

Transcript of 971107 ACRS 446th Meeting in Rockville,Md.Pp 155-251.W/presentation Slides

ML20198R711
Person / Time
Issue date:	11/07/1997
From:	Advisory Committee on Reactor Safeguards
To:
References
ACRS-T-3015, NUDOCS 9711130368
Download: ML20198R711 (132)

Text

6 .. Y .

,9,.' h.. . - , . 4.'*( '""- -

' ; & ,1. -

. *. .' . ~ -3)1' . -

/ 9) .);.M f% +"' I'

'- g

.., - g .<. ,., ..,". . e*gys ',." ,' f , , ; ' , ! [ , ...-

-,. ,. , ,y. .

., * .r ..  :^

n

r. 3 ~ , .  ;. . .> e

. 4.,.. . _7,, . .:

..;., .; .4. . ? 3:.7 . . 4,7.m 4

_. .3. .,, . - .- .. , ..,t,

....s,-._ ..

., g-_._.-

y., 9..

. 9, -.

a ; ;; -

w g 3, pg

• i ,

s .

' _ y y ,;9.;*g. p, . :j

$ 'T h . y .% o ' '

'. '.g

_j , .;

. .&f,f"' *'fl$?, _

_..' V

..'k

~

s

_. g ,

i.'.  ;

g .r y. - . -

e g ,. a 3

)

t

. . '9 ft a f.fyp hs . .&..; ,-

- =

L

gspp.cy.

.,b 3 h

' 'I ' @ i .f [e!1.h , aj l [ ... ~; d k ' ~~ ~

' ~

\ $ ;

'a' '

4

.? ' Q

.4  ; '. .a4 ..

.: , . ' .... ,, - 3

.* M;i-

.V , .. s

, 9 , , - f.

o . :

r,

()

., r e . .

9,_a', :.;j;[+* ip', -:n.

. .- d p2 f

• '._ -_ - -- , j-f- . g g

4 ,- ,.

t 4 .

.U. .. ,h@ . , . I N ' .) '. '

j  :

a.n. . .

9 '. t -

..y \

p . - . .. - ..

' ... _ . h.y.p./i . ;,4.,?f W.

e - . .

f ,y .o . '. .. _

.' ' . .,^ 3 Q ~ /, ' , f 'jg '

1. . j.' y '

f$r $. ~ '. $ 1. ' ' - :, LW. i'}

~ '~

c

~* -

. 6

'. .' .L I , S , "l 4 ee e

^

y' .-'. .: g, .a . . ,[.J. [. _ , ;. I ' .

4 . .- , .

c4g E ' .

f ) # g y. g ,;d

, s .

s'  ; .,t* 4, t.f

• in D =

l, b: ." $ .$ @,M

.t ,4 ;, . . y-  ; d. .- Q.W s v.

. . ._ , , = .

sg  :. -

w,,._ ,

o.

,5-

./ ' .

i, '

- **.. $ . M' **

.r.f. y'* I. (

[' ; * ),

, . , '*f. . .- , , -

't ' .

. . . . d :S ,, 4 . . .. -

l.. ).gf.g.:lv .

e. - , _ - -

r .y >--. s .

a ,

• -_1--- .

• 7. n s,,,p , .:;g!i ,f'.f.

it. + t .- . -

. g

- . e

./ ..yg ' 2

f. 4% ' .

?.

h _ ,-

• _

_, ' _ 1 ' , -' ' .,

.::;....:;-l.), . :p t

j)*,p .' f. _.1 .g M,

.. .,]..*'a .a .

,(,.,

-A' ," ' .

,c-up -',,,

y . ' ~. ,5 ; . [ . - t . , ,;, , #,. , . . g.

es I 'B. .,..m,

. y=,- -[ ,, ,. ', ; -

. . . .,,, *J. 3,'

g , .. .g -

E * .f '

~

1-4 e

'f s;.g y'b-f . ,

fU

,+s./ :: .. -) ..? ,

,N

_fl

.,,.' ' k'-

q .# */

C 'l , 9 .

O 9 ; . ( ' e[ ,,3b,p y. [ .. (

- - .' 'g .f . y-,' ,. Ti Jii ',A g . . : y,

'p -

5 ; . ,. . . ;~ _; .

ed f . .

O F g _

~

,y'l'....-.....i*W

's .

, g

..p.1,+,..,

e , a m- ,. A .-

g , q y,.

e.

,. .s, ..

g%' , , '_:. : - , . , s. s. . . .g ; . p,,.%g.s , w,

-- . F.. .......D; y . t+'

.. - 4

• Q.

n ,

%' s . L.~ v '.

'q.,-d-

. r- , . . .

.s._ , , y.9 .

_ , .:3. y::;,4:_y y _ ; g ;.{

&-  % j ' ', . - e .

f -- "s . 5 : ; , .,3 4.,.g .g ,

-g;.,,'-

p- ,

c.

.} . - .44 ' -

j'

. : ,; ,.g., 4y 6- . ,, . . .

g 9' ..

7.. y,,3.,2.i  ; .p . f.,

,' . g. @ . ' - ,

g,,

,.. ,Q -

p. .,', 3 . ,y.,,..

',4

. 4 = y

. . . - . . . . - . . . '.. .- ., 7 *- .

,* ., .::a t> h, . s 3 y ..

e.

• O  ; , ' ' '.

'e._

L

. _ , , , j*f .

' g'1y,z...

e.g;  % *

, : .H. ::

. . $ ;g , , . ' [' . . i: 3 y. .,

y , t

,O, ..

g -

~ . .

,h

. .. '. ,]. ' 4.' y ,' 6 ', eq

d

'. [ '. ._ '. ... . . y,

'h ,

].j p ; jgj yp j

'% ' ~ \ .

. O ' g.

s.

. N' . , ._ . ' . . , ', , . . . . .

,'l_  ;, -y}.'y'

,- .3  :- M .. ;.

e

/

S. 6,_ .

,, c 7."xy> ,y]3,..m. y;:y

. . . , . \ . .

' . , . ' ~ }' *.-

I J

• . g ,'r f, . . . .-

4'i,s m 1

Q

.. . . . . . S ;. 4 y a

• . 't,

.[' '(. .'

'.W.

'f y' y ,.

.w [,' gg 3 p ,4

~

..- . . ga-

, , . 2.'% .y.. ,-9%.

. q' \, " . .

-3 ' .' , , y') % 'i,,.,, ,.. ; , f -

., . * ', ,.g ,. . . ' ' -

y . f*y"

.~

o-

,1 h, . .qO.

. 9, . , . .

Em 3< c w

*- - - y;.,y.).

~

' ^

f. - .~ _ . .

7_~ . ;' . .

.} Q

- m . .. . . - .

.4 1 ,. . , . . . ...g .. ,. .

' -...,. .. e #

w . x~ggw. w .m.

y' m .. .

hg:--4

- ;. .,, ;f . f. .....,3..

't N. ' %. , ;

F p

.s.

..*'w ,.

.'-@' -'1 '

s . . .,;

'. W  ! .y j ' ,,M;,n' g

_. . .:.. .. Z .c ' ' .-  ; a .. ; ; .. ' ;, - [',,,.._.'3 .: .;. z . ,,_

. a  :.

b * - , :. .C [. ; -

g g . .p y'/ J' .; f. - [,.l.3:v;s.:<. .

-

• s 1

. . . .. . . . . . 'V. a/ " , .  :

_ ')y

_[

_f l,,-

.- - '[

.' 3

-_ [ :_ - g . ' .. g . .- y . ., . g .

v, .4 .c . . .;.. ,

. .( a - +.

i? , . . g. ,-  :

..' ;.. -: 7 - ;* '.; ,:: ; " ,p.

7

p,1, a. . . . 'N c -: /

, ; .. -.,A g .a :. ,. ty

' ' . ' - ' :.* ;. 0

. Gf. i.1, j )l .fj

.  ; :y,. s.

~'

s. _y ' .?. ;.. f _; . .

. .;_ i. p Zd

t. .-.  ?.S  %, - - ,.....

e s.w . 7 .7. y 1 1. m.j,'01.E M, W .K . D( ,

r.

rk.

w" #.#. . s ,.*'N.- .T..+-

? -

. . .. a

.p* f k. , . .. .. -' . ' ' 4 3 ..g' . e' . . - . - -

.4

,, i- -

,  ; ' ' . [, \ , . . .

'

• N . , -' b ,. [

,.,, [f, . *, .. , 4 ,

[ ,' . , . *,','

~

$.y ( f. g, p,- .. , 7, - -'i

h 3 3 N A _. t#5T-30 /5 n OFFICIAL TRANSCRIPT OF PROCEEDINGS Q

NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l

1

Title:

446TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)

Ts : .; A xs R ErRN ra:a:xA:

BTrGi ' T E Docket No.: (( i jf" Tusvi ~

O Work Order No.: ASB-300-34 0

i LOCATION: Rockville,hlaryland DATE: Triday, November 7,1997 PAGES:155 - 251 9711130368 971107 T 3015 PDR

'9 ANN RILEY & ASSOCIATES, LTD.

1250 I Street, NW, Suite 300 e* Washington,D.C. 20005 (202).442-0034

(( (( kk kkk { { ((

I h s r '- r i n - '

20r ThC ;dio 0[Ina 00m T IE'qe8

,\ e q)

DISCLAIME' UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS NOVEMBER 7, 1997 The contents of this. transcript of the proceeding.

l of the United States Nuclear Regulatory Commission Advisory L ,O I (_ ,/ Committee on Reactor Safeguards, taken on November 7, 1997,

=as reported herein, is a record of the discussions recorded at the meeting held on the above date.

This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.

l V

o

.~. - -. . . . . . . - . - . ~ .-. .-. . . . - . . . - . - . . - .

155 3 1- UNITED STATES NUCLEAR ~ REGULATORY-COMMISSION

-2_ ADVISORY-COMMITTEE ON REACTOR-SAFEGUARDS 3: '***

4 '446TH ADVISORY COMMITTEE ON REACTOR' SAFEGUARDS -

5 (ACRS)-

6 7 U.S. Nuclear' Regulatory' Commission ,

8- Two White Flint North 9 11545 Rockville Pike'

!10- Rockville, Maryland -20852-2738

-11 12 Friday, November 7, 1997

-13 14- The Subcommittee met pursuant-to notice at 8:30 O

V 15 a.m.

16 17 MEMBERS PRESENT:

-18 ROBERT L.LSEALE, Chairman, ACRS 19 DANA A. POWERS, Vice-Chairman, ACRS 20 JOHN J. BARTON, Member, ACRS

21. WILLIAM J. SHACK,--Member, ACRS 22 DONALD W. MILLER ~-Member, ACRS

, 23 MARIO H.~FONTANA, Member,-ACRS 24- THOMAS-S. KRESS, Member, ACRS l 25 ~ ROBERT E. UHRIG, Member, ACRS l

1 ANN RILEY & ASSOCIATES, LTD.

j- Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C.-20005 (202) 842-0034

156.

• 11 P R-O C E--E D,I N G S.

2 [8:30 a.m.] ,

- 3 '- CHAIRMAN SEALE: The meeting will now come to:

4 order. -This is'the second day ofsthe-446th meeting-.of the 5 Advisory Committee on Reactor Safeguards. '

6 During-today's meeting, the committee will 7 ,considering the following: severe accident management; 8 staff actions rel'ated to the development'of a revised fire 9 protection rulei future'ACRS activities; reconciliation -- I 10 _ guess we did that yesterday, didn't we? Report-of the  ;

i ll Planning and' Procedures Subcommittee, and we will' finish up -

12- on our-ACRS reports for this meeting.

13 A portion of today's meeting may be closed to-

.- 14 discuss organizational and personnel matters that related 15 solely to the internal perronnel rules and practices of this 16 advisory committee, and information the release of which 17 would constitute a clearly unwarranted invasion of personal

18. privacy.

19 This meeting is being conducted in accordance with 20 the provisions of the Federal Advisory Committee Act.

21 Mr. Sam Duraiswamy is the designated Federal 22 official for the initial portion of this meeting.

23 We have received written statements and requests- ,

1 24 for time to make oral statements from Messrs. Paul Gunter, 25- Nuclear Information'and Resource Service, and David

-ANN RILEY & ASSOCIATES, LTD.

Court Reporters

- 1250 I Street, N.W.,-Suite 300 Washington, D.C. 20005-(202) 842-0034

157 1 _Lochbaum, Union of Concerned Scientists, regarding the item h 2 on staff actions for developing a revised fire protection 3 rule.

4 Also, we have received a request from Mr. Fred 5 Emerson, NEI, for time to make oral statements on the same 6 subject matter.

7 A transcript of portions of this meeting are being 8 kept and it is requested that speakers use one of the 9 microphones, identify themselves and speak with sufficient 10 clarity and volume to that they can be readily heard.

11 Before we start, I noticed that we all got our 12 note regarding the fee for the Christmas party next time, 13 and I hope everyone is taking care of that.

14 Are there any other special con.ments or issues at 15 this time that we need to take note of?

16 [No response.]

17 CHAIRMAN SEALE: If not, the first item is the D

18 severe accident management discussion. Dr. Mario Fontana is 19 the chairman of that subcommittee. Mario?

20 DR. FONTANA: Tom Kress is going to do it.

21 DR. KRESS: We have r3 aligned some things, so I'll 22 introduce it.

23 CHAIRMAN SEALE: Well, in principle, I'm not 24 against fusion.

25 VICE CHAIRMAN POWERS: But they are usurping your I ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

)

158 l' authority.

(in) 2 CHAIRMAN SEALE: No, that's all right.

3 .VICE CHAIRMAN-POWERS: I thought subcommittees-4 were exclusively the province of-the chairmen.

5 DR. KRESS: I'd like to remind the committee 6 before we start of something. called severe accident 7 management guidelines, that's what we are going to discuss 8 -today. These are written actions-to be taken by a licensee 9 in the event of a severe accident.

10 They are separate entities from the emergency 11 operating procedures. One of the questis e is how are they 12 related to each other, when do you leave emergency operating 13 procedures and go into SAMG's.

14 I also remind the members that if the severe O

(_) 15 accident programs disappears, this may be all we can rely 16 on, so they are pretty important things.

17 The development and implementation of these is at 18 the moment strictly voluntary on the part of the licensee 19 and NRC's role appears to be to inspect, observe. They l.

20 don't approve, I don't think. They take the form -- these 21 SAMG's take the form of what can be done mostly using 22 existing capabilities in the plant, maybe with some minor 23 realignment of things or minor revisions.

24 The goals appear to be to keep the core and core 25_ debris covered with water, to avert reactor bottom head

. (\'

O)- ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 i

(202) 842-0034 L _ __ _ - _ _ . .--

l 159 1 failure, to-restrict or contain ex-vessel reactions, to  !

/~  !

(m) s_-

2 promote removal ~of fission products within containment, and J

3 to-prevent in general,.any uncontrolled release from- l 4 containment. l 5 This voluntary approach has given the licensees-6 flexibility, and as you might expect, there appears to be a 7 number of divergent approaches to these, to the actual 8 guidelines. These are developed in general by the working 9 groups, like owner groups, like BMW, CE.

10 Your package contained a report on a review of the 11 various approaches taken by these owner groups. This review 12 was sponsored by NRR and conducted by mostly INEL, I think, 13 but PENNL is involved and so is COMEX. Take the time later 14 or sometime to read it. I found it to be a very good (O) 15 report.

16 It noted the differences between these divergent 17 approaches, pointed out a number of deficiencies and made 18 recommendations for fixes.

19 This report was put out in 1994. A lot has 20 happened since then. Today, I think we are going to hear a 21 status report on the implementation process for SAMG's.

22 I think the committee should focus on what is the 23 status of the recommendations of the 1994 report, is the 24 . implementation program actually a sufficient program to deal 25 .with severe accident, and what does the staff think about

\-}

( ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

160 1 that'. Are the'SAMG's risk informed or do they need to be?

2 LM aybe they don't need to be. I guess the final thought--is

3 view this from the standpoint'of is there any need.for us as

4 a committee to look for additional information or is it 5 something we are going-to be briefed on and think it's in-6 -good shape and don't see a problem.

With that, I'll ask Mario, do you want to add 8 anything?

-9 DR. FONTANA: No.

10 DR. KRESS: I'll turn it over to Bob Palla.

11 MR. PALLA:' Good morning. I'm Bob Palla. I'm in 12 the Containment Systems and Severe Accident Branch of NRR, 13 I've been involved with the accident management program l 14 since its inception nearly ten years ago, when we started to 15 work with industry in this area, at about the same time

, 16 period as the generic letter on the individual plaat 17 examinations was being prepared.

18 Accident management --

I'm just going to go 19 through some background here very quickly. I think most of l

20 the committee members are probably aware of it, but this 21 shouldn't-take too long. It might be of some benefit for 22 others that are not that familiar with it.

l

'23. In the plan for closure of severe accident issues, 24 accident management was identified as basically the vehicle

. 25 -for implementing insights from the individual plant ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250-I Street, N.W., Suite 300 Washington,-D C. 20005

.(202) 842-0034 i

I . - , _ _ _ - . - . - - - - - - - . - - . . . . , . . _ _ _- - -- - - . - - . .

l 161 1 examinations, to make sure that these insights are not lost

- (. ) 2 within the organization, that an emergency response 3 organization, should they ever be called on to have to 4 respond to an accident, would be aware of the capabilities 5 of the plants.

6 Basically, don't just throw away the insights from 7 the IPE but try to make maximum use of them within the 8 organization.

9 The fundamental objective of this program is 10 basically unchanged from what we had described back in 1989, 11 which we basically, as Dr. Kress has indicated, were trying 12 to evaluate information on severe accidents, prepare severe 13 accident management guidelines and procedures, and I'll say 14 there's a difference between guidance and procedures.

O

\s / 15 Procedures would basically be more prescriptive and would 16 lay out a more detailed course of action, whereas guidance 17 in a more general sense lays out at a higher level, some 18 strategies that one would have to consider and consider the 19 pro's and con's and make choices in deciding which of the 20 strategies to implement. What we have is basically guidance 21 that could in some cases be proceduralized.

22 And then finally, training of operators, technical 23 support staff and decision makers in the guidance and 24 ' procedures, so that this does not come as news to them 25 during an actual event.

) ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

l 162 1 The training, as I can describe in more detail,

-l

) 2 and we have some resident experts here on'the training 3 aspect of_this, but the concept _is that the training would 4 be commensurate with responsibilities in an actual event.

5 The way that the PWR owners group had approached

-6 this, they have developed severe accident guidance, 7 principally for use by the technical support center. The 8 rasponsibilities for the management of the accident would 9 transfer formally from the control room to the technical 10 support center, in the course of an accident, consistent 11 with the emergency preparedness and planning.

1. In the actual event, should you get to the point 13 of core damage, you conceptually should have already l

l 14 transferred responsibility for the PWR's to the technical 15 support center and they would be using the severe accident 16 guidance.

17 Therefore, when I speak of training commensurate 18 with responsibilities, the training for the technical y 19 support staff wou'.d be the greatest incremental change that 1

20 we will be making as part of accident management.

21 There is some additional training for the control 22 room operators, but it is somewhat less.

23 DR. BARTON: What are the boilers chose to do?

24 MR. PALLA: Well, the boilers is a different case.

25 They have chosen to incorporate the severe accident-l

( ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

163

11 guidelines into a: companion part ofLthe emergency procedure

() 2 . guidelines. Basically, they havefa two part document that~

3 consists of-essentially emergency preparedness, an EPG .

4 section, and then there is a severe accident guidelines-

5 section_that they would transition into.

1 1

6 The' default responsibilities would be in the 7 -control room still. I have a brief slide on that later.

8 DR. BARTON: Okay; fine.

9 MR. PALLA: There is some flexibility in how they 10 partition responsibilities.

11 The NRC had initiated dialogue with the industry, 12 as I indicated, back in the late 1980's, at the time frame 13 -when we were putting the IPE generic letter together. Thero 14 . was a recognition that we did not yet have a full 15 understanding of the scope and content of accident 16 management,-so it was decided to separate it from the IPE 17 generic letter and to work the details more with industry.

18 We worked with NUMARC at the time and subsequently with NEI 19 and we continue to work with the industry today, NEI and 20 each of the owners groups.

21 The products of these interactions has been 22 basically a set of guidance. Each of the owners groups have i

23 developed severe accident management guidelines and to 24 varying degrees, supporting training materials that the 25- individual utilities would draw upon when they construct ANN RILEY &-ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300

• Washington, D.C. 20005 (202) 842-0034

164

- 1. their actual plant specific training programs.

() 2 These are the products. I'll talk briefly about i

3 the implementation process later. l 4 .Our interactions with industry were generally good 5 and cooperative and there was a decision made, particularly

]

6 in recognition of a lack of a clear requirement for 7 additional-guidance in this area. We decided to proceed in B. _a cooperative fashion and ultimately we accepted that the 9 industry would implement accident management pursuant to a 10 voluntary industry initiative. We did this in lieu of a 11 regulatory action such as a generic letter.

12 We had originally considered that we would use a 13 generic letter to implement the program, but because of the 14 success with the interactions with industry and the lack of G

k,,) 15 a clear requirement, we proceeded in this voluntary 16 approach.

17 Nevertheless, I want to point out here, we remain 18 committed to the importance of accident management. We 19 intend to assure that each licensee lives up to their 20 commitments to in fact implement a program and to assure 21 reasonable and quality level of implementation across the 22 industry.

l l 23 Accordingly, we do intend to conduct some level of I

24 inspection at each plant to confirm that the implementation 25 has been completed.

l l

-t ANN RILEY & ASSOCIATES, LTD.

l

\- Court Reporters l 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 l

l

1 165 1 DR. KRESS: Do any of these show up in the

() 2 maintenance rule as systems important to safety?

3 MR. PALLA: Well, no. What we are doing here is 4 programmatic and putting in place the severe accident 5 guidelines, making adjustments to training programs and 6 licensees, as part of the initiative, part of what's called 7 the formal industry position, it's a statement of what the 8 industry would do, within that, there's a commitment to 9 conduct on a periodic basis, accident managemenc drills.

10 Those are the three major pieces.

11 I don't think that you would find they trickle 12 3tto the n.aintenance program.

13 MR. HOLAHAN: Gary Holahan. Let me add something.

14 The program itself doesn't -- as Bob said, it's not putting

() 15 more systems into the plant. It's using what are already 16 there. Some of the systems that are there are within the 17 scope of the maintenance rule, but I think they are not 18 within the scope of the maintenance rule because they are 19 used in severe accident management.

20 DR. KRESS: Just because of the nature of the 21 systems.

22 MR. HOLAHAN: Yes, either it was a safety system 23 or it's in the emergency operating procedures or it could 24 cause a reactor scram. The other reasons that it was put in 25 the maintenance rule scope.

( ANN RILEi' & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

_. .- _-. .. - - - -. _~-. . - . . . . . . - . . , ~ . ~. .

i 166  !

'1' DR . - UHRIG : : _Do-they getjinto the emergency _--

"G 2l management as part df the_ emergency drills?-

MR,1PALLA: l

-3 Emergency preparedness drill?.

'4 DR. UHRIGi- 'Yes.

51- MR. PALLA: -Yes. In function, what the accident- l 6 '_ management guidelines do is improve the ability'of the:

7 _ technical support _ center-to perform the function that-they 8' . exist for. They are there to back up the control room 9 operators- . 'These' guidelines? provide the technical suoport 10 center some structure forL the way they would do their job.

11 Itlprovides the strategies in a logical format that one.

12 -- could' progress through it and select wisely which of these- l 13 -strategies they should implement.

14 It helps them to do their job, their emergency 15 preparedness type jobs better. It fits conveniently under 16 the umbrella of emergency preparedness.

17 The development of the' guidelines itself involved

-16 _ EPRI at -t he earlier stages and.what EPRI did is pull

'19 together insights and conclusions of various analyses of 20 severe accidents that existed at the time.

21 They packaged this up in a form that laid out --

22 that categorized things according-to the-condition of the 23 plant,-the core, and the containment, and then within each' 124 of those--damaged states, they identified various actions 25 that were possible and they provided an assessment of pro's

^

i-l ANN RILEY.& ASSOCIATES, LTD.

Court Reporters l _1250 I-Street, N.W., Suite 300

_W ashington, D.C. 20005

'(202) 842-0034 i

t l

l 167 1 and con's and cautions ofitaking those various actions with ,

7 %y  :

( j 2- the plant and the containment in those various conditions, 3 under those conditions. ,

i 4- CPRI information was documented in something that '

5 had referred to as a technical basis document and 6 subsequently re-packaged by each of the owners groups.

? When-I'm talking today, I'm talking primarily 8 about the PWR owners group. BWR is different.

9 I think in concept, these strategies that are in 10 the EPRI document also apply to boiler stuff. The statement 11 is true across the board that the EPRI document was used as 12 a basis for the owners group guidelines, but what the owners 13 groups did was package that information in a way that they 14 felt comfortable with and that they felt it was useful for (s,) 15 their member utilities with their emergency operating 16 procedures.

17 One of the reasons to get the owners groups into 18 this game was to be assured that we weren't introducing 19 conflicts with the emergency operating procedures and that 20 these guidelines were properly interfaced, a clean process 21 for stepping from the emergency operating procedures into 22 the severe accident guidelines and making that transition.

23 It was important to involve each of the owners groups.

24 They came into the program a little bit later in 25 the early 1990's. This is one of the reasons that this

, -( ) ANN RILEY & ASSOCIATES, LTD.

Court Reporters 12501I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 l

168 2J: program has taken so long, because:each of these activities

- () 2 _ occurred;to-some degree in a sequential manner and there was 31 = time involvedlin getting_the. owners groups' funding. _

They

-4 apparently, as-all-organizations of-that sort, would do- +

15- advanced planning, had the budget for-this in_ advance. They o 6 joined the effort several years after it had been initiated. ,

7- Finally, the Institute for Nuclear Power  ;

8 Operations was also involved. The; role of INPO was to 9' develop severe accident training concepts, not so much the 10 detailed training materials, but what INPO had come up with

=11 was a classification scheme that the owners groups 12 subsequently used.

13 That scheme basically identified plant staff in 14 terms of whether they would be evaluators, implementers or .

15 decision makers, and based on how you classified the various 16 positions, that carried with it a certain level of training.

17 INPO involvement was basically a very high level 18 task analysis which resulted.in a classification scheme that 19 can be used to determine the level of which various l

20 categories of personnel would be trained.

21 Just real quickly, the products of this whole 22 industry effort-is severe accident management guidelines.in 23 the case of the PWR's for use by the technical support 24 center's staff.

25 For the BWR's, we have severe accident related

( ANN RILEY & ASSOCIATES, LTD.

Court Reporters

1250 I Street, N.W., Suite 300 Washington, D.C. 20005

-(202) 842-0034 1

.m--. . - - _ , , - , , - - . . - - , - --=,4-.- --,m--- , . . - ~ . - - - - . . , - .- , - _ ---.4---_4 .~. .. .-

.._._._._s_ _ _ _ _ . _ _ _ . - _ _ _ - _ . _ _ . -

a 169.  ;

1. emergency procedure guideline changes, and when I say that,

-2' I_mean there.lwere some adjustments made.to the emergency.

3 3- procedure guidelines as we know'them today, but principally,_ l l

4 the owners groups supplemented-the guidance in the-late'part e 5 :of the procedures. What they-did is_they appended it.with-  ;

6 the severe accident guidelines.- They created-a transition 7: from the EOP's into the severe accident guidelines, 8- They have aise developed the methodology by which 9 an utility could' consider certain actions, certain-severe 10- accident strategies, and based on consideration sdch as the cil. time that-these actions would be needed-relative to the time 12 that the technical support center could be relied upon to be 13 acti vated . Timing was_one consideration.

14 Ic considers 'ehether the licensing basis is

() 15 impacted by moving the strategy from the control room to the 16 techndmal support center, and it also considers the risk 17 significance.

18 Now, it's a methodology that we have not yet seen 19 how it works. We have agreed in concept _that this makes 20 sense, it could be a rational way to determine whether a 21 particular strategy should remain as a control room

. 22 responsibility or whether it's more appropriate tcr assign

!' 23' that to the-technical support center.

24 We just haven't seen how utilities would use that 25 criteria yet. This is an item that we-have identified as l

1004 RILEY & ASSOCIATES, LTD.

L Court Reporters 1250 I Street, N.W., Suite 300

Washington, D.C. 20005 (202) 842-0034 L

90

1. something that we would work the details with the industry

( '. 2 later.

3 That time is-coming because the industry is 4 implementing -- the boilers are finishing their 5 implementation later than the other plants, as I will 6- indicate on the next slide, but we will be looking closer at 7 the way that criteria for relocating strategies from the 8 control room to the technical support center is being 9- implemented. ,

10 Finally, severe accident training materials and 11 lesson plans have been developed to varying degrees by the 12 various owners groups.

13 DR. UHRIG: Where is that implemented, within the 14 operator re-training?

() 15 MR. PALLA: There's some subtleties there for the 16 control room operators.- That is an option but what we have 17 seen, we've done two demonstration visits so far where we 18 have met with utilities that have completed their 19 implementation, and it seems like there may be familiarity 20 training that may be something separate than the actual 21 operator licensing training. It may be a separate vehicle.

22 We haven't quite yet pinned down and taken a 21 position on how that training for the operators will be and what the vehicle is.

25 DR. UHRIG: Will it be done on a simulator or will i ANN RILEY & ASSOCIATES, LTD.

k/ Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

t

171 1-- it be doneLin a classroom?- .i

() 2. MR'..PALLA: Simulators have been used up'to the 31 degree that"their-simulation is' valid, but you.have'tobstep 4- off-to basically stop the simulation.

=5- -For the' technical support center, the two plants 6 that we< visited were Westinghouse plants. Naturally, the .

7- responsibilities-of severe accident guidance are in the 8 technical support center.- The' training in that_ case would ,

9 be provided within the context of the emergency preparedness 10 _ training.

11 DR. MILLER: A couple of places in the report, ,

12 there were comments on training. I-just picked out one that n

13 I highlighted, where it said that training did not appear to 14 _addrer. 's c ral key elements. That's just out of one 15 report.

16 MR. PALLA: Is that the report on -

17 DR MILLER: I happened to have picked out one.

18 There are a-couple of places in these reports that appear to 19 be that there are some negative commen.s toward implementation of the training.

21 Is that an' issue that the training is not 2 .' proceeding along as it should?

23 MR. PALLA: Well, there are a lot of issues that 24 haven't ! been pinned down. There isn't really an agreement 25 on - .let's take-for example the frequency of training,-

ANN RILEY'& ASSOCIATES, LTD.

Court Reporters =

1250 I' Street, N.W.,-Suite 300

Washington, D.C. 20005

-(202) 842-0034-

~

__.-_._--_.._.-..__.2_ _._._ __ _ _ . _ - _ .

l l

172 1 refresher training. Within the industry, if you talk to the

'3

(

( j 2- -utility, there is a difference of opinion as to what type of 3 training is necessary.

4 What we do have agreement on is that a systematic 5 approach to training is the method by which one should 6 determine the appropriate level of training and the method 7 of training. That sounds good but there is a lot of 8 flexibility in how you implement this systematic approach to 9 training.

10 Issues like frequency of training are definitely 11 something that we have not yet --

12 VICE CHAIRMAN POWERS: The impression from the 13 same reports I think Don was looking at, there was concern 14 on the part of the staff that the training was not being

(_,/ 15 organized in a fashion similar to the way we organize 16 training for the usual operations of reactors and things 17 like that, that it was not as rigorous and systematic.

18 MR. PALLA: Yes. The degree of rigor is an area 29 -- what we have seen to date indicates that it's a less i

20 rigorous application of the systematic approach to the 21 training. In fact, NEI and the industry have attempted to 22 --

I guess to coin a term -- in lieu of the systems approach j 23 to the training, which is what we rely on for operator 24 licensing, they refer to it as a systematic.

25 There's a distinction that they draw. What we are l

l l

t l

f' l 'l '

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 l (202) 842-0034

l 173 1 looking for is to get the same elements of the SAT process,

/7N i j 2 which are clearly laid.out. The degree and the rigor to 3 which you carry out the various elements varies, 4' VICE CHAIMCui POWERS: We seem to have here a 5 dichotomy of judgn.ent on the kind of training that you have, 6 whether you do the systematic or the systems level approach.

7 Do we have any mechanism -- does anyone have any 8 mechanism that says okay, we've tested this training, we've 9 tested these people and they are adequately trained. In the 10 end, one of these judgments has to be demonstrated to be the 11 better judgment or at least an adequate judgment. I guess 12 it doesn't have to be the better judgment. It has to be an 13 adequate-judgment in that you have two positions, systems 14 versus systematic. How do you test? Is that part of these i

V 15 tab'e top exercises?

16 MR. PALLA: In concept, that would be part of both 17 of those. I think the distinction is the level of detail.

18 Dave Desaulniers may be able to help here. The Human 19 Factors Branch has been looking at the training for severe o

20 accidents.

21 MR. DESAULNIERS: David Desaulniers with Human 22 Factors Assessment Branch, NRR.

23 Before we go into a discussion of differences 24 between a systems approach and a systematic approach, I 25 think we need to have further conversation with NEI and E () ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005

(202) 842-0034 l

1 .

i l

174

_1-  : industry on this-matter _because it'may beilargely a=

f2? differJnce'of semantics._

3 .The systems approach is' defined in regulation.

4 Since.this?is a voluntary' industry. initiative, it's my 5: understandingithat'the-industry has chosen the word-6~ ~ " systematic" to differentiate it from a program ~that's 7 clearly defined by regulation'and-has_certain requirements 8L attached to it.

t 9 -The implications _for what is actually done in-10 terms of the methods of training and_the element of

' ll- -developing a training program, there may be little or no 12- difference. I think those subsequent conversations will 13 -bring out if there_are in fact any substantive differences 14 with the way a training program is developed and implemented

~( ) 15 between these two approaches.

16 CHAIRMAN SEALE: I might recommend a rock you 17 might want to look under.

.18 Over_the years, the people at INPO have used 19 industry workshops to examine the appropriate content,-

L 20 approach, scope, whatever, however you want to characterize i

21 2 it, of specialized issues that have evolved, chings like the 22 -implementation of the-maintenance rule, digitcl I&C, those 23: kinds of things.

i -24 Generally, those are judged to have been'quite 25 productive. It may be worthwhile to try to determine f~

ANN RILEY & ASSOCIATES, LTD.

Court' Reporters 1250 I Street, N.W.,JSuite 300 Washington, D.C.'20005

, (202) 842-0034 L * .

l 175 l l

1 whether or not -- this area as yet been the subject of

( 2. similar kinds of workshops -- to find out what the results 3 of those looks have been.

4 They have used groups of people from different 5 utilities and other appropriate groups to do this. That may 6 be a resource that would be worthwhile to look at in 7 evaluating the extent to which the INPO contribution is 8 really making a significant impact here.

9 MR. PALLA: That's_a good point. We have been 10 involved through NEI. We did attend a workshop that NEI 11 sponsored, not an INPO sponsored workshop. Training was 12 relatively --

13 CHAIRMAN SEALE: It's a key part.

14 MR. PALLA: It seemed to take on a pretty dominant

) 15 role in the discussions. To some degree, it may be a bit 16 too premature to try to collectively look at the picture and 17 try to see if there's some kind of a commonality there, but 18 I think this is a good idea.

19 CRAIRMAN SEALE: You may want to keep track of it.

20 You may even want to see if you could participate or at 21 least audit, if you will, some of those discussions.

22 MR. PALLA: The reason I say it may be a little 23 premature at this point is because the utilities are still 24 in the process of implementing it.

25 MR. HOLAHAN: Let me add something before you

[\

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

176 1 leave the training point, From my point of view, it's n

( ). 2 important to address these issues and the processes, trying 3 to get good quality information through the accident 4 management guidelines and all that, but what I'll really be 5 looking for,-you know, when our staff goes out and observes 6 drills and other activities is to see what the end product 7 is like.

8 Do licensees' staff really appear to be dealing 9 with severe accident situations, not in real plants but in 10 the drill situations, better than they did before, and are 11 making more appropriate decisions.

12 If they are not doing that, then something is 13 broken in the process.

14 CHAIRMAN SEALE: Well, I think the historical

( \

N/ 15 record though, for example, in the maintenanco rule area, 16 those discussions had impact on what happened in the plants.

17 MR, PALLA: Each licensee has formally committed 18 to implement an accident management program consistent with 19 the formal industry mission. They have provided these 20 commitments on the doc..at. Of course, they are voluntary and 21 subject to change still, but each licensee has indicated 22 they will implement the formal industry position.

23 The actual implementation guidance is contained in 24 a section within NEI 91-04, which is a document that 25 discusses closure of severe accidents which includes closure 73-t / ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300-Washington, D.C. 20005 (202) 842-0034

- . . . - . . . . . .-- -. , _ . - . -- ., .- . . _ - - ~ . . - . - . - . ~ - . - . . . . . . -

177 1-- 'of IPE and.~dispositioningtof IPE, IPEEE insights,,and it-

~

~ 2= =also. lays out'the scope of activities that should be done in >

3- the area.of_ accident management. _

4 -The_way that the' formal industry-position was - ,

5  ? worded, licensees were to communicate their' completion dates 6- ;to their__ counterparts-at the NRC and at a schedule-to be-7 determined on a pla".t_ specific basis, but in no event any.

8 later than December 31, 1998. ,

'9 -The way that things have stacked up, within the

10. next month, before the end of the year, we should have-11' completed implementation at 37 units. These are 12 . predominately Westinghouse plants.

13 In the first half of next year, there's a few more 14 plants that will complete. implementation, but by and large,

( 15 approximately two-thirds of the plants will not be done 16 implementing until the latter half of next year.

17 _ Interestingly enough, mostly Westinghouse up front

18 and mostly GE plants at the tail end.

i I 19 In defense of the BWR utilities, one of the 1

20 . reasons that.they committed to less aggressive schedules is 121- that the severe accident guidelines developed by the owners

! 22 group were still not in hand at the time the commitments t

23 were being asked for. They naturally conservatively came in 24 with late dates.

.25 I can explain where those guidelines -- the' status l-() ~

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N . W .. , Suite.300 Washington, D.C. 20005

, (202) 842-0034 L

- . _ . _ . . . _ . _ _ _ _ . _ . . . _ _ . . m _ _ _ . _ _._.m. _ _ _ . _ _ _ _ _

178 j

. . l

< 1 of those in a: moment. .

t 2_ TThe actual implementation: process =-as_I alluded to 3_ before, fit basicallylinvolvesitaking the generic _ documents 4 -developed by the owners group, fiaalizing them, adding any.

5 'IPE-insights,. changing out parameters, parameter values-6 .withinJthe generic document,'and-basically = emerging'with a

'7' plant' specific set of severe accident guidelines.

8 The second major step is to take the existing

'S -training programs and to basically re-sisit those and modify 10 the. training'as appropriate, .onsistent with the systems-

-11 approach to the training, to provide the appropriate level 12 of: uraining on the severe accident guidelines. ,

-13 Finally, there is an element of the formal 14 position, quite an important-element, that involves 15 conducting exercises on a periodic basis. This is really 16- where you would exercise the guidance, try to put it into 17 place, in a simulated drill or accident context.

g 18 This could be done on a periodic basis, but 19 naturally, you'd want.to do this up front, just to make sure 20 that the guidelines are actually useful, that the training 21' is effective. This would also be done on an ongoing basis.

22 The second major item here is that t.he accident-23 management -- I'll call it.a plan, but what we are looking

.24 :forLis conmitments administratively, a program that ensures

25. that the accident: management capabilities are maintained l_

j ANN RILEY & ASSOCIATES, LTD.

=

. Court Reporters 1250 I Street, N.W.,_ Suite 300 Washington, D.C. 20005

-(202) 842-0034 i-

. -. . .- - . . - - . . - . - ~. , -. - ., -- - .-. , ,- - ~ -

l l

179 l

~

1 current, updated if new information should become available, T2 such as information they might derive from the severe

_(v[

3- accident program and assessment of other phenomena, 4 challenges, resolution of issues.

5- We want to be sure that this information is 1 6 factored into the accident management plans and adjustments 7 are made as appropriate, and finally, performing periodic 8 accident management drills and-self assessments on an 9 ongoing basis, a key aspect of maintaining the capabilities 10 in the long term.

11 With regard to our plans for inspecting, we-were 12 planning a phased approach. The initial step, we are really 13 at step one right now, midway through it, but it is to 14 participate in what we-term accident management O 15 demonstrations at selected volunteer plants, to ebserve how

( ,/

16 the elements of the formal position are actually being 17 implemented, 18 If you look at the formal position and you look at 19 the NEI 91-04 report that tries to lay out what it is that 20 utilities should do, there's flexibility there. It's not 21 all that specific. To a large degree, we are getting 22 calibrated to the industry's perception of what they 23 committed to in that formal position, getting up the 24 learning curve.

25 We have done two of these accident management

[\- i ANN RILEY & ASSOCIATES, LTD.

Court Reportern 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

180 1 demonstrations and we plan to do additional. We have been

() 2 3

out to two Westinghouse plants. We see a definite need to also look at huw B&W and CE guidance are implemented by 4 FWR's, because this guidance is substantially different.

5 The training materials that each owners group developed is 6 different. Naturally, the training process would be expected 7 to be different, as well as possibly the results of the 8 implementation.

9 We want to get out there and basically look at a 10 plant of each reactor design, including boiler, and maybe 11 more than one boiler, too.

12 The second step. determine the appropriate scope 13 and depth of pilot inspection. We do intend to do some 14 inspections. The number is actually to be determined later.

) 15 About four or five is what we have been thinking.

16 The demonstration visits will help us adjust the 17 temporary instruction. We have a temporary instruction. We 18 described it the last time about a year ago, described it to 19 the committee. It still exists in the same form that it did 20 then.

21 As soon as we complete the demonstrations, we will 22 update the temporary instruction and proceed to conduct 23 pilot inspections at a handful of plants using the temporary 24 int *,ru c t i on , then we will re-look at the inspection 25 ptwccdures.

ANN RILEY & ASSOCU~ LTD.

O" Court Rrm' 1250 I Strcet, c: uite 300 Washington, D.C :0005 (202) 842- 4

181 1 We currently have inspection procedures in

() 2 emergency preparedness. What we were looking at doing is 3 making some adjustments perhaps to one of these procedures.

4 We hopefully would be a lot smarter when we reach this 5 point. We'll know what are the more important things to 6 look for, so we wouldn't have to do full blown inspections, 7 but we can focus on those pieces that we think are most 8 essential to providing capabilities.

We would incorporate that into a draft inspection 9l 10 procedure revision and possibly a revision to an existino 11 procedure. We would air that out at a public meeting or a 12 workchop to incorp) rate the industry and possibly involving 13 participation of some of the plant people that had been 14 involved in the demonstrations. It may well be that the 15 industry has a lot of input to this workshop.

16 Finally, we would emerge with the inspection 17 procedure which we would use to conduct an one time 18 inspection at each plant to confirm that the commitments 19 have been met, and then on a for cause basis, as deemed 20 necessary, should things be observed in the field to be 21 deteriorating, for example, if there was an emergency 22 preparedness inspection years from now that observed 23 perceived weaknesses in the technical support function out i

24 of PWR, it might be a reason to dust of f the pro :edure, go 25 in and look in more detail about what is actually being done ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

182 1 at this plant to train people, do drills and so on.

l' 2 We retained the option to go in there and do a

() <

3 more detailed examination should the need present itself.

4 VICE CHAIRMAN POWERS: This is how you are going 5 to inspect the licensees. My question is this is a fairly 6 elaborate undertaking on severe accident management. Is 7 there a plan to inspect NRC in the sense of trying to 8 ascertain if there is a risk worth to this whole 9 undertaking?

10 MR. PALLA: No. It's not currently planned to 11 re-look at this. This is an industry initiative. It's 12 thought to be the right thing. It's been the subject of 13 many discussions which have led us to an agreement with the 14 industry that this is worth doing.

'xO,/

15 We hadn't considered re-looking at why we are 16 doing it, if that's what you are speaking of.

17 VICE CHAIRMAN POWERS: The reason I'm suggesting 18 it is that although it's an industry initiative, NRC is 19 devoting now staff resources to it that's at least a finite 20 effort.

21 There is a continuing inspection effort on it, 22 which is going to cost some amount.

23 MR. PALLA: Yes. If you are referring to the 24 longer term, if you are looking at this, the resources is 25 definitely a key issue. Resources is the name of the game l

r) ANN RILEY & ASSOCIATES, LTD.

\ Court Reporters 1250 I Strett, N.W., Suite 300 l Washington, D.C. 20005  !

(202) 842-0034 I

_ _ . . _ _ , . _ > _ _ _ ._.___..______..__,___._____m ___ _ ._. _ _

183 l 1- now. We realize that to expect to go out and to do in depth j

() 12 3

inspections would be difficult and probably unwise to even ask for.

j l

4 What we are thinking is that we al' ready have

5 inspections that we do in emergency preparedness and with j 6' some adjustments there and perhaps on a periodic basis, just 7 a slight're-focusing of what an inspector looks at during  ;

8 one of the routine visits, that we would perhaps just be.  !

9 looking in this area a little bit more.

i 10 We are pretty attuned to the resources question l

.11 and thinking that we are going to have to-walk a fine line 12 in how are you going to do this, are you going to do it at 13 every plant. It has to be pretty focused and pretty careful- l 14 about how much resources it takes.

()

15 VICE CHAIRMAN POWERS: My question is borne of l H16 this. Right now, the emphasis that you are ascribing to 17 this, the willingness that you are going to inspect and 18 consider what the licensees are doing in this area, it is a ,

19 judgment. If it were exclusively your judgment, of course, 20 I'd have implici. faith in that, but it's not. It's a 21 collective 'judgtaent among a lot of people.

22 It seems to me that we now have the tools to get 23 some insight on whether this is about the right level of 24 inspection on the maintenance, too much, too little, in a L '25 more dispassionate and objective fashion.

L i] ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N . W .. , Suite 300 Washington, D.C. 20005 (202) 842-0034

184 1 It may be that it's not cost effective to do that,

,m

( ) 2 that it's cheaper to just go ahead and do the inepection w/ ,' l 3 than it is to try to do a quantitative analysis of it. 4 4 On the other hand, it may be better to do the 1 5 quantitative analysis, since I think the tools may be 6 available or if not available now, possible to have in the 7 near future.

8 MR. HOLAMAN: Dr. Powers, let me answer your 9 question from a different direction, which is as the NRC 10 management -

11 VICE CHAIRMAN POWERS: From the right instead of 12 the front?

la MR. HOLAHAN: Well, from the management direction 14 as opposed to the --

O (g 15 CHAIRMAN SEALE: Wherever that is.

16 MR. HOLAHAN: -- technical reviewer direction.

17 In a sense, there is a plan to reconsider how much 18 resources and how we should approach this issue. It's not 19 an accident management plan. It's an operating plan for our 20 whole division, which is how do you decide, you know, what 21 issues and how much resources and what approach to use on 22 any issue.

23 As a division, we do have an operating plan.

24 Unfortunately, this is the first year that we've had a 25 formal operating plan. Like a lot of first time efforts, I (d

\ ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

185 l A *hink it needs a little more work.

( .

[ What I see is we are not simply reviewing 3 everything put on our plate. We are nec inspecting i 4 everything put on our plate. We are in a process of making 5 conscious decisions with right now an informal priority 6 system, which we are moving towards formalizing, which looks 7 at what is the value added for this activity, why are you 8 doing it, is it a high, medium and low risk item.

9 In that context, every quarter that we test what 10 are we doing and why are we doing it and every year when we 11 put together a budget, we are reconsidering all of our 12 programs.

13 VICE CHAIRMAN POWERS: When you say you are 14 re-examining all your programs, is that in a judgmental

) 15 sense or in a more objective sense?

16 MR. HOLAHAN: Well, it's always going to be 17 subjective but we are developing written guidance as to how 18 to make those judgments.

19 One of the elements is safety significance and 20 using the guidelines similar to what we talked to the 21 committee about yesterday on 91-06. I think there are other 22 elements of a regulatory program that also have to be mixed '

23 in with that, in deciding where to put your resources.

24 DR. FONTANA: Since this is voluntary, what's the 25 regulatory basis for doing the inspections?

f"'\;

N/

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

186  !

=1 MR. PALLA: Well, what we are inspecting is j

() ;t inspecting against commitments, the degree to which each of i

3 the ele-ents of the formal pos!. tion have been accumplished.  ;

4 DR. KRESS: The commitment being the NEI Jetter.  :

1 5 MR. PALLA: The NEI letter and the report that 6 incorporate 0 the --

7 DR.:FONTANA: With respect to the question of 8- whether this is worth doing or not, it seems this is the-l 9 only really practical thing that can be done with respect to .

10 severe: accidents or really one of_the few.

11 Secondly, it seems to be if you have all the 12 activity going on for evacuation studies and that kind of 13 stuff, evacuation drills and that sort of thing, it seems i 14 that if you are going to do that and not this, it doesn't 15 make any sense. '

16 2n other words, if by implementing accident t 17 management you can reduce the probability and the amount of le release to the environment, it seems that you ought to do 19 that even before you go out and do evacuation drills, t

20 If you are going to do one, it seems logical you 21 are going to do_the other, but maybe logic doesn't always 22 apply. ,

23 MR. PALLA: We agree, but we have approached-it in

-24 the mechanism is voluntary. If it doesn't pan out, if we 25- see a. lot of difficulties and a-lot of weaknesses, and if i

?

-ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250-I Street,-N.W., Suite 300 Washington, D.C. 20005. ,

(202) 842-0034  !

- - ~ . . _ . - ~ . - - - _ . . _ . . _ . _ _ _ - _ . . - . - . . _ . _ _ _ . _ _ _ _ _ _ _ _ _ . _

187 1 the industry is not able to meet the expectations, we can 2 reconsider this, whether it's viable or not, whether we need 3 to procced with some other regulatory action.  :

4 At this point, this voluntary approach was judged 5 to be the offective way to do it, but we will be looking at i 6 it.

') CHAIRMAN SEALE: In a sense, the very fact that 8 they voluntarily are doing this suggests that in looking at 9 their emergency response plans and so forth, they felt there 10 was an element missing, namely, the definition of what the 11 problem was and how the plant was evolving to be the source 12 of the emergency. That's kind of what this --

13 MR. PALLA: This is filling a gap.

14 CHAIRMAN SEALE: It's filling a gap.

15 MR. PALLA: Basically, the gap between EOP's and 16 the E plan. I think there is no argument'there.

17 CHAIRMAN SEALE: In a sense, there's a vacuum that 18 this is filling that was perceived by the people that were 19 working in that area, 20 MR. PALLA: I think the issue really becomes a 21 matter of degree, the degree of rigor, the degree of 22 resources that are dedicated to training, the drills, and 23 simply that. I think in concept, we're in agreement about 24 the major elements, but it's when you get down to the 25 details and the actual implementation and the things that ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

i 188 1 you do on an ongoing basis, the level of resources that you

() 2. dedicate to that.

3 It comes from some place else and you have to make 4 those kinds of judgments as to if I'm going to train on  :

5 this, I train on something else less, whether I want to make j

6 the tradeoff or net.

7- I want to very.briefly describe-two accident _

8 management demonstrations that we participated in. These 3 9 were organized by NEI. Basically, they-identified a number >

10 of licensees that were substantially completed with their.

'11 implementation at the time, willing to present to us the-

• 12 results of that implementation.  !

13 It was a two day visit at each site. What.our 14 objectives were were to try to better understand the ,

) 15 licensees' implementation process, specifically how they 16 took the owners group guidelines and developed their plant

, 17 specific guidelines based on thet, the manner in which they 18 identified personnel that would be trained and the level to 19 which they provided training for the various categories of personnel.

121 We wanted to also see how these guidelines would  ;

22 actually be utilized during an accident. A piece of this 23 demonstration visit involved an exercise, the drill, which 24: - the-plant staff did have to get into severe accident ,

25 ' guidance and we observed that.

't ANN RILEY & ASSOCIATES, LTD.

O- Court Reporters f

1250 I Street, N.W., Suite 300 Washington,;D.C. 20005 (202) 842-0034 '

w-,- ,--+.w-,,.,,rmsv,-,vv-,ww.,w.,--,--,-,,- , ,,-w,s - .+,w

189  ;

1 Finally, a key piece of this process, if you are

() 2 3

going to hand this issue to the industry and they are going to see after it for the long term,* utility self assessment 4 is a key process. The way that emergency preparedness is 5 done today, a key element is the utilities being able to l 6 critique their own performance,-identify the need, i 7- strengths, weaknesses, the need for improvements.

8 This same proceas was part of the formal industry 9 position, that'when the licensees would do periodic drills .

10 and exercises, they would critique their performance to 11 identify where the areas were for improvement.  ;

I 12 One of the other objectives here was to identify, 13 make some kind of observation about how that self assessment -

1 14 process appeared to work.

k 15 Another object'ive is to just get a sense as to how 16 close does it look like our TI in its draft form comes to 17 what we think is needed. We went into this thinking based i

18 on what we learn here, we-will identify areas that we need 19 to re-visit in the draft TI.

20 Finally, as I laid out that seven step process 21 before, we plan to do some level of inspection at each 22 plant. By going through these demonstrations, we can 23 identify any apparent need to re-visit that or modify that 24 planned. approach for inspection.

25 Basically,-the demonstration visits, and a day and ,

O ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 I

Washington, D.C. 20005 '

(202) 842-0034

.=. - - _ .- - -. -

190 1 a halt is really all we took on these things, so there was a

() 2 limit to just how much information you could get out of 3 this, but it consisted of an overview of the itaplementation 4 process, a series of presentations by plant staff that were 5 responsible for implementing the key pieces of the program, 6 and then it was followed by an accident management table top 7 drill or a scenario.

8 DR. FONTANA: Who is normally there for these 9 demonstrations?

10 MR. PALLA: Who is there from --

11 DR. FONTANA: Yes, both from the NRC side -- well, 12 primarily from the NRC side.

13 MR. PALLA: From the NRC side, we had myself, 14 George Thomas. Well, George hasn't come to demonstrations 15 yet, but George will be involved in the BWR's. We had Human 16 Factors people. We had Emergency Preparedness people, 17 because of the emphasis on training, because of the way this 18 program actually fills a void in emergency preparedness, we 19 had Emergency Preparedness representation.

20 DR. FONTANA: And the region people were there?

21 MR. PALLA: We had a regional person from each 22 region. In each of the demonstrations, we had like out of 23 the EP shop in the region, we had the branch chief there.

24 In a way, to start to educate them on what the industry is 25 doing in this area. That was quite beneficial, I think. It h

\/

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005

'(202) 842-0034

t 191 '

1 actually involved some limited involvement of the regional  ;

() 2 folks.

3 The status is we completed these for two plants, t i

4 North Anna and Comanche Peak were the plants. We plan to  ;

5 have additional demonatrations, a demonstration for a'B&W 6 _ plant, a CE plant and at least one PWR.-  !

i 7 -VICE CHAIRMAN POWERS: I came away from reading i 8 your reports with the impression -- well, I guess you are  ;

9 - going to get into the observations from these demonstrations 10 now.

11 MR. PALLA: Real quickly, yes. I was going to 12 just recap what they were. Ask your question first.

13 VICE CRAIRMAN POWERS: I came away with the 14- impression that there was a difficulty in the transition

\ 15 from emergency procedures to severe accident management  ;

16 procedures, that was persistent, where to make that  ;

17 transition.

18 MR. PALLA: Yes. What we noticed -- I don't know 19 .f i it's a difficulty or a problem area. We did notice 20 differences in the way -- even for the same set of guides.

21 .These are Westinghouse e,uidelines and that transition 223 fundamentally should be the same.

23 We did notice some differences in how the 24 operators basically -- how their responsibility was 25 transferred out. To some degree, I believe that the way the

() ANN RILEY.& ASSOCIATES, LTD.

Court Reporters 1250 I-Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 >

m s- 1, -- , "vn-v_-+sw- va-c -

m e gg, w A.e-- c wwa= ---ene -ww . vv v v se,w-- y e v .1p -,-r-wny- re yvy w erw' gv

192 1 drill was set up led to some of T..ose differences.

() 2 I think the key difference was in the second 3 demonstration, the transfer of responsibility did not occur 4 - promptly upon the technical support staff being activated.

5 I think the deliberate decision was made-that the l 6 control room staff wouldn't relinquish control until the h 7 technical support staff was up to speed and actually making i 8- recommendations about severe accident strategies.  :

9 In contrast, in the first demonstration, the i

10 transition appeared to be made basically by road, kind of an i t

11 almost automatic transition, and then the observation, kind 12 of judgment again, within the control room, it looked like '

13 the operators left the guidelines and didn't have anything {

14 to do. .

( 15 I don't believe that the difference occurred

-16 because of first observation. I do believe as utilities 17 become more experienced with this, they will be looking more 18 closely at how that transition is made and they will be i

19 working out the rough edges.  ;

l 20 I think a lot of these things -- you can sit there 21 and look at paper and you can perhaps critique and criticize 22 one approach over the other, but you don't know -- all may

• 23 be viable provided they are effectively implemented, if you 24 work.on the transition, you do the drills, you see problems 25~ and take care of them. It will work itself out. ,

() ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street,~N.W.,-Suite 300 Washington, D.C. 20005 ,

(202) 842-0034

,m-.%._,, , . , . ,~n-- -v-m- , .--,...w..-e,..--n ..w. .y..,,,, ,.-,w,,we,w. ,,,,-.w-,,w..s -,..,w- ...,---,.v,,,--,--,,-nm,,saw, ..-,ww.--.,w--- . - . - . - . --

i 193  !

~

1- DR. MILLER: The-transition problems that Dana  !

() 2 reflects are not'ones of use of the different types -- you  :

3 go from emergency procedure guidelines to severe accident  !

4 guidelines. That wasn't the problem, it was just a matter 5 of transition from one team to the next team?

6 MR. PALLA: Yes. The way the Westinghouse ,

t 7 guidelines are set up, the. control room has some -- it has 8- basically two guidelines. They are called severe accident 9 control' room guideline one and two. Basically, guideline one r

10 is for use betore the technical support center is ready, and 11 then the second guideline is after that.

12 It's a question of when do we set from control 13 room guideline one to control room guideline two.

, 14. VICE CHAIRMAN POWERS: But it's that whole 15 question of ready. You go from one to two, according to 16 what's said, once the TSC is staffed. But in the second 17 demor.ntration, it was once the TSC was ready. There's a 18 difference between those two.

19 'DR. BARTON: It must he a fine line. Say a TSC is I

L 20 staffed, people show up at the TSC, get up to speed and they 21 are now saying the TSC is staffed and. ready to do its thing.  ;

22 It seems to be that because it's staffed, that doesn't mean 23 it's ready to do anything.

24 VICE CHAIRMAN POWERS: I think that's what Bob is i 25_ saying. -

l

()

.I ANN RILEY & ASSOCIATES, LTD.

, Court Reporters l 1250 I Straet, N.W., Suite 300 Washington, D.C. 20005 ,

(202) 842-0034

_ _ _ . ~ _- ..-~_._.___.__.._._...____._,_.._-....__._...,._.___._,___.__.,-,.__.,.J,.,-_ . _ _ . ,

-. - . . .~ _. -. .- - -. - _ -

L 194 1 14R. PALLA: They decided to defer until the TSC

() 2 was actually ready to add.something to the situation.

l 3 VICE CHAIRMAN POWERC: I think that's the rough 4 edge that's getting worked off.

5 CHAIRMAN SEALE: Yes.-

6 MR. PALLA: I think this maybe something that we .l 7 come up to time and time again. Maybe it should be something l i

8 that's on a case by case basis, are we ready to make the 9 transition. It's hard to judge it in advance. l 10 Some quick observations here. Essentially,- the key 11 elements of the implementation appeared to have been carried it out. The plant specific severe accident management i 13 guidelines were developed. It appeared that the utilities  ;

14 followed the owners group guidelines very closely with a I 15 minimum of deviations.

16- Training was administered to a wide range of r

17 personnel. At the demonstrations, they described who was 18 trained and what type of training they had, you know, t

19 classroom hours and scope, which of the guidelines were they '

20 trained on. That differed from category of person to 21 category, becauso for example, the control room operators 22 don't need to know the' nitty-gritty details of each of the

23. particular strategies, so their training tended to be more L

24 of an overview type of training.

.25 Initial training and drills were carried out, We i

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 '

Washington, D.C. 20005  :

(202) 842-0034 J, . , , , -. . . - _ _ , - , - -..... ., a , ~ , . e_. a_ - ~ . . . . . - - - - . , ~ , - - - - . . ~ - - _ ~

. - _ _ . _ . . - _ _ . _ _ _ . ~ . _ . _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ . _ _ _ -

ISS l 1 . observed'one of those. Separately,-the licensee had already

() 2 carried out a series of these drills.

3 - The administrative program to maintain  !

4 capabilities appears to have been put in place. The degree l 5 to which it works is a subjee- for further evaluation. It  ;

6 does seem like administrative procedures were developed to  !

7_ maintain the capabilities, ]t 8 Based on the observation of the drill, and these l t

9 . are really subjective, because you can be sitting, this j 10 whole series of people sitting watching the same people,  ;

11- trying to overhear the discussion and the dialogue that goes 12 on, and youLall come away with a different perception. In 13 Lgeneral, our sense was that the guidelines did seem to make 14 the technical support staff more aware of the strategies.

) 15 They did seem to be systematic in the way they 16 assessed the implications of implementing certain ,

17 strategies, the cautions and the considerations that went 18_ into that. As they made recommendations for implementation i

19 of the strategy, it seemed to be well founded and well 20 considered recommendations.

21 It appeared that the guidelines helped them ,

22 prioritize actions. Of course, these are all judgments made j 23 without really having a good baseline to begin with. Our i

24 perception is the guidelines were useable and appeared to ,

25 contribute to the. ability to respond to the event -

0

, ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 washington, D.C. 20005 (202) 842-0034 i

f

-._ree-..

-aw..wn.

-,...,.m r or -w. m. e ------c--ve w--ww--..+.. w. , , , -.-,.,:,.--e ----r-- .-- ,r-_,mrr-

---m - g , ycr=.,-

_ . . , _ ~ . _ . _ _ _ . _ _ _ _ . . . _ . . _ _ _ _ . . _ . _ _ . . -

t I

196  !

1 effectively, i

() 2 We did identify a number of concerns. Several of 3 them dealt with the way the trainirg -- not so much the way f 4 the training was developed and implemented the first time 5 around, but it seemed like there were issues that weren't-6 _quite yet dealt with by the utilities.  !

7 There were questions about refresher training _and l 8 the way that it would be done. We heard discussions and i 9 plans about relying on work book training. We had some

-10 questions about whether that-would be effective. What we 11 had observed at one of the demonstrations was that it -

12 appeared that certain elements of the systematic approach to 13 training had not'really been implemented.  ;

14 The second item here is feedback processes. It 15 didn't seem like they had put together the whole program 16 yet, that they were able to effectively evaluate the 17 training, the whole systems approach to training seemed to 18 be missing the feedback mechanism and the evaluation 19 mechanism.

20 An interesting observation relates back to how the 21 owners group guidelines were developed. In each of the 22 demonstrations, the utilities did not claim to have added 23 any additional strategies or IPE insights to their plant 24 . specific documents. lThey indicated that the generic ,

25 documents adequately-bounded all-of the' insights that-they_

() -ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 l

Washington,'D.C. 20005 (202) 842-0034

i 197 j 1 had from their IPE's. We didn't see any additional plant (O) 2 specific details being added.  ;

3 DR. FONTANA: With regard to that topic, in 4 looking through the 1994 staff review of the severe accident l 5 management guidelines that were done by the various owners 6 groups, one of them showed I think a somewhat disturbing 7 inadequate knowledge about severe accident phenomenology, '

8 and I was real pleased to see the staff has caught those ,.

9 things. 1 10 It brings to mind two things.11as that been fixed, 11 and the other question is there sufficient, what we could 12 call level two type knowledge, in the -- I know it exists in 13 part of the industry, but has this level two knowledge 14 showed up in the severe accident guideline; adequately?

( 1; MR. PALLA: To address the first question, what ,

16 have we done with the findings from the review conducted, 17 completed in early 1994. That information was forwarded 18 back to NEI for consideration by the industry. We have not 19 followed up with the individual owners groups to determine 20 which of those recommendations they acted on and which ones 21 they did not. We have slot had that follow up.

22 23 Let's say, for example, I guess the vendor you are 24 talking about is B&W. B&W had a lot within the review. We 25 identified a lot of areas for improvement for the B&W l

f\

'd ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

i i

198 1 guidelines. It may be that when we look at a' demonstration 2 at a B&W plant, we can look at that closer, and maybe if 3- _ they didn't fix it, it would manifest itself. ,

4- DR. FONTANA: And you would see it then. ,

5 f1R . PALLA: But that's by chance, you know. These I 6 are just a single -- if you are just in one drill and you l 7 are looking at one particular progression of events, you msy 8 not pick up on a fundamental weakness in some area of the 9 guidelines _that wasn't even invoked-in that drill.  ;

10 The answer-is we didn't follow up. We recognize -

11 that-we need to. Realize that the two demonstrations that l .

12- .were done.were done at Westinghouse plants and the '

13 Westinghouse guidelines were judged -- I 14 DR. FONTANA: Were okay.

15 MR. PALLA: -- to have basically no needed 16 improvements. I think one improvement was recommended. l 17 They were clean, basically, and thought to be well ,

18 structured and obtain all the essentials.

19 MR. DUDLEY:. Mr. Palla, we have about five minutes 20 left in the session. Let's make sure we get the important 21 points.

22 MR. PALLA: I'll do it in less than that.

23 DR. FONTANA: We've been slowing them down.

24 MR. PALLA: We saw no new IPE insights added. We 25 saw no new strategy; implementing procedures. One of'the ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005  ;

(202) 842-0034

/ i

i. . _. . . _ _..A. ..-.-c -.. ,,..;.. ---,m. . . ..e , , 7 . . _ , c...r--.

199 f 1 t)ings that we expected to see is that if you've identified l

() 2 J

some additional strategies, that there would be certain ways to carry these-strategies out at your plant, the actual nuts

[

z

.4 &nd bolts. How would I make the alignments needed to connect  !

S the fire pumps to the core sprayer, whatever yea have.

6 In both cases, the utilities indicated that they  ;

• / had adequate procedures, that the implementing procedures 8 they had in place already adequately covered the strategies {

9 that they were now addressing in the' guidelines. That's an 10 area that we think we would need to look at closer.  !

3 I

~11 ', In the context of the demonstrations, we didn't 12 foll&.! up on thht, but that's an e ea that I would want to 13 be convinced that's actually true, that there wasn't 14 anything additional that they should have been  !

() 15 proceduralizing.

16 There was an issue raised, and it's something we 17 want to look at closer also, whether the emergency plan 18 needs to be modified to reflect the changes in 19 responsibi]ities, a question about transferring e

20 responsibility for decision making from the licensed control 21 room operators to the technical support steif clat are b2 unlicensed and whether there is somo kind of a change that 23 is-needed, some kind of further thinking about this transfer  :

24 and whether it needs to be articulated in any way in the 25 emrrgency plan. .

ANN RILEY & ASbOCIATES, LTD.

O< -

Court. Reporters 1250 I Street, N.W., Suite 300 1 Washington, D.C.'20005 .

(202) 842-0034

200 j

'}

1 l- Finally, we thought that based on those two  !

() -2 demonstrations at Westinghouse plants, that we esset.tially 3 have met the objectives of the demonstration visits as they  ;

l 4 pertain to Wostinghouce plants, and any further l 5 demonstrations,- we want to have the other vendor and some f 6 other B&W or CE plant, to cover the range of guidance.  !

7 Remaining actions, the BWR accident management 8 guidelines. We've had them for -- I have another slide that i

9 I'm not even going to, but we looked at the emergency 10 procedure and severe accident guidelines submitted by the  :

11 owners group. We identified numerous areas that we thought i

12 there could be risk implications. In fact, things like l 13 ic. creased flexibility for containment venting was something [

i 14 that you see. If you look at the guidelines, you realize j

( 15 they are now providing a lot more flexibility for venting.  ;

I 16 There are numerous changes that we needed to have 17 additional information and better understand the bases for i

18 the changes.

19 We have A series of questions that were sent out

20 back in April that we have not yet gotten a response to. We  ;

21 expect a response by the end of this year. We plan to i 22 complete the review in the early part of next year.

23 We have the support of Oak Ridge National

24. Laboratory, Steve Hodge., in particular, helping us on this  !

25 review. We are in pretty good shape with it. I think that ANN RILEY & ASsnrTATES, LTD.

Couri Reporters 1250 I Street, N.W., Saite 300 Wothington, D.C. 20005-l

~

(202) 842-0034 l.

l -

201 1 the issues raised are the pertinent ones. It's taking quite

() 2 a while for the owners groups to put the answers together, 3 We are hoping to get that review completed by --

4 VICE CHAIRMAN POWERS: Do we have a copy of those 5 requests for additional information?  ;

6 MR. PALLA: I can make sure -- I thought I sent 7 that letter.

8 VICE CHAIRMAN POWERS: It would be useful to see 9 what those questions are.

10 MR. PALLA: We can provide that. I've sent it a 11 few times. Accident management demonstrations at the other 12 plants, still need to carry them out. Because we want to 13 reflect the range of -- we want to understand what the range 14 of implementation looks like at these other types of designs 15 before we modify the temporary instruction. We want to have 16 a pretty complete view of the world. We don't want to base 17 anything on what we saw at Westinghouse plants.

18 We realize we have a responsibility to training 19 ourselves. This whole program has been basically carried 20 out within NRR. It very definitely involves other staff.

21 The emergency operations center, for example, would be 22 responding to events and would be interacting with utility 23 staff that once the severe accident guidance is in place, 24 the utility staff would be following it. There would be 25 discussions about where they are in the procedures or if l

l ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

202 -

l' they entered the severe accident guidelines. We have to get l

() 2 our own people up to speed on what these guidelines look

3. like, how they are structured, what kind.of strategies are 4 involved, so should an event occur or a drill occur in which i

5 they are being used, we know what's going on.

6 Emergency preparedness inspectors are going to be. l

.1 7 seeing severe accident-guidance during drills. They need to ,

t 8 understand where that came from and what's expected, how l 9' it's expected to be used. Resident inspectors also.

10 We hear periodically from the industry, from 11 utilities as well as NEI, that NRC inspectors are scratching 12 ~ around, asking questions, and they don't quite understand 13 what we are doing here, and we do recognize.that we need to 14 bring then up to speed. l 15 Finally, as I mentioned, once implementation is 16 done, we want to perform inspections at the balance of 17 plants.

i 18 I think that's it. I have a real quick summary 19 slide. Our expectation is that when we are done, we would [

20 have enhanced the capabilities to prevent or mitigate the 21 severe accident challenges.. I aon't think we are going to l 22 be able to quantify it so we can do a risk assessment. It's 23 going to be a judgment call as to the degree to which that 24 is effective.

25' Closure will be achieved on a plant by plant 1

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005- i (202) 842-0034

i 203  !

i 1 basis, each utility completing it in accordance with their l 2- own schedules. We will look at these at least once when the f

3 commitments are met.  !

4 One'of the key elements of the formal position is "

5 that the capabilities will be maintained living. This will r 6 be done principally by refresher training and periodic 7 exercises that utilities would conduct on a continual 8 ongoing basis. They will have a process in place so that 9 they incorporate new information, should it be developed.  ;

10- Finally, we will keep our oar in the water by 11 observing EP exercises.and the way the guidance might be 12 used in an EP exercise, and should the need arise, should it f

13 appear that there's deficiencies, maintain an option to go 14 and do some sort of a more in depth inspection.

15 DR. FONTANA: The benefits of this are more than 16 just one. For example, back in TMI, that hydrogen bubble 17 non-issue, I think a better-appreciation of severe accident i

18 phenomenology would have helped and not have scared a whole 19 I bunch c: people needlessly.

20 MR. .PALLA: 7 think to a large extent, the 21 training that this program provides will assure that kind of '

22 basic information is shared. It's something that I don't 23 know that you could count on being there otherwise.

24 DR. MILLER: I have kind of a generic question 25 relating to instrumentation. When I went through this O ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I; Street, N.W., Suite 300 Washington, D.C.'20005 (202) 842-0034

i 204  !

1 -- I'm not-on this particular subcommittee, but I went f

() 2 3

through this report. I looked for instrumentation issues and I anked the question, try to answer the following .

4 question.

5 Is there training going on for somebody in the  !

6 plant,uat least a small group, to understand instrumentation 7 that is available and understand what it is saying, and also

-8 understand what it may be telling you that might be not ,

9 expected..

10 I think at Three Mile Island, for example, if you l 11 look at the Three Mile Island scenario, if you understood -

12 the instrumentation, it was all told by the ex-core ,

13 instrumentation during the entire scenario, if you 14 understood what it was telling you. But of course, most

) 15 plant people don't understand that.

16 Is that part of the severe accident management 17 guidelines, instrumentation?

18 MR. PALLA: Yes. Instrumentation is embedded 19 within the formal industry position. It's something that is 20 expected to be looked at. What we intended to do in at-21 least the draf t temporary instruction was to look at how the 1

22 _ licensee selected the instrumentation, based on its 23' .vailability,. expected performance in a severe accident.

24 _One thing that we didn't look at but we would 25_ expectLar.d hope to-find at least'in the training materials

![

ANN RILEY & ASSOCIATEC, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C.-20005-(202) 842-0034

f 205  :

o 1 is how is the behavior of instrumentation reflected within  !

() 2 3

the training. I believe it's there.

that at the. plant specific level to see what type of We'd have to look at j 4 information is being communicated to the TSC people in this 5 area. It is-very' definitely one of the elements of the 6 program.

7 DR. MILLER. For example, with Three Mile Island,  ;

8 when you had the void, when no one understood, you could .

9 look at that instruction and tell you-did have a void. I i

10 know there was training implemented for the operators on how 11 to understand those kinds of things. Of course, you have all 12 the instrumentation to follow in the course of an accident.

13 MR. PALLA: Instrumentation that you rely on in 14 alternative instrumentation to back up what night be

() 15 questionable. That's also supposed to be covered.

16 DR. KRESS: Mr. Chairman, we are fortunate to have 17 Fred Emerson from NEI, who would like to make a few comments 18 on the industry viewpoints.

19- CHAIRMAN SEALE: Fine.  !

20 MR. EMERSON: I'll be very brief. I'm tne project 21 manager for severe accident issues at NEI. Prior to joining 22 NEI, I was the chairman of the BWR owners group committee 23 for six years which developed severe accident management 24 guidance and worked with NEI extensively since the late '

25 1980's in their: activities to develop generic' stuff for the

(\

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite'300 -

Washington, D.C. 20005

, (202) 842-0034

.mm v. .-%- --- ,,c- , . - - - ,+-3-r 4 - ~-,w-- , . , ,,w#,. -m. . ,-----..,-,,w.-- .,,we-- - - - , - . , . - . , . . , , , - - ----rv-,,

206 1 industry.

() 2 3

I'd just like to offer three general perspectives.

First, I agree with almost everything that Bob and Gary said 4 earlier. Generally, severe accident management is designed 5 to be mitigative in nature. We already have EOP's in place 6 to prevent accidents.

7 The guidelines that we are developing, as was 8 stated earlier, fill the hole. This goes to the priority of 9 what do you do with the guidance versus what you have in 10 place for preventing accidents.

11 In terms of plant priorities, we feel it's more 12 important_for a plant to prevent an accident from occurring 13 than to mitigate it onceHit occurs. Relative importance 14 should be placed on implementing and training on EOP's

() 15 rather than severe accident management guidance.

16 The second aspect is that severe accident 17 manage.nent was supposed to be an enhancement of existing 18 capabilities. We already have E plans in place which 19 address the management of accidents and SAM guidelines are 2C intended to provide additional tools to enhance T,1 communication and assure that decisions are carried out 22 properly during this -- with this additional problem of 23 being in a severe accident egime or a core damage regime.

24 The third and follr. ling up on what Gary said 25 earlier, we view the inspect..on or self assessment of I\s'l ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

^

207 i'

1 accident management capabilities-at the plant that should be

() 2 done on a performance basis. We feel that the effectiveness 3 of training and procedures or guidelines is best indicated 4 by how well they performed during the periodic inspections 5 or assessments that they perform. .;

i 6 Thank you.

7 DR. KRESS: With that, I think I'll turn it back }

8 to you, Bob.

9 CHAIRMAN SEALE: If there are no further 10 questions, my geriatric knee is telling me that we all.need j 11 .to stretch just a little bit. Fortunately, it turns out we 12 have a little bit of room in our schedule. I hope this is  !

13 not an inconvenience for the people:who are going to be 14 involved in the next presentation. '

15 Let's try to get back at 10:05 and we will resume 16 the meeting at that time.

17 (Recess.)

18 CHAIRMAN SEALE: We'll come back to order. The 19 next presentation is on staff actions relating to the 20 development of a revised fire protection rule. Dr. Powers is 21 the chairman of that subcommittee, so I'll turn the chair to 22' him.

23 VICE CHAIRMAN POWERS: Thank you, Bob. The 24 members will recall that last meeting, we had an alert to 25 the-effect that there were going to be some ferocious ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street,- N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

,.,,..y, , _ . ,.y --#ev-,r+,m... ,..,5,. . - . , ----m-mvrw,,y.,-r-,.vy,.,- mmr.-.mm_.,-w,, v--y---.-me. , , - - - . , - w

208 1 activity in the area of fire protection.

2 The Fire Protection Subcommittee has had some 3 informal meetings with the staff to discuss how we were 4 going to accomplish what appeared on the face of it to be an 5 impossible cht.re and an exacting time schedula.

6 Those informal discussions were sufficiently 7 interesting that I thought it might be worthwhile to provide 8 the committee with a heads up on what's going on in the fire 9 protection rule making activity.

10 In fairness to the speaker, I remind the committee 11 that these plans and what's going on are in an evolving 12 state and may not have solidified completely and there are 13 probably lots and lots of questions that we could have that 14 the speakers are going to defer answering because their 15 thinking is still being solidified.

16 The discussions on fire protection is going to 17 enlarge. We are going to have beyond this heads up and in 18 connection with what the staff's going to have to do, we 19 will also have the benefit of some thoughts on the general 20 subject of fire protection rule making from the Nuclear 21 Energy Institute.

22 Then we are going to go from these overall 23 activities into a far more specific issue that has, by my 24 recollection, been on the committee's agenda since the 25 sccond or third meeting in which I've been a member, and ANN RILEY & ASSOCIATES, L"D .

Court Reporters 1250 I Stree., N.W., Suite 300 Washington, D.C. 20005 )

(202) 842-0034 l

l 209 3 that is on the issue of fire penetration seals. That has

() 2 3

appeared in some of the news notes the members have gotten.

It is our anticipation that we will have more 4 detailed discussions of the specific issues in a Fire 5 Protection Subcommittee meeting that we are having a little 6 difficulty scheduling, but right now, it looks like it will 7 take place some time in January, 8 With that intrcduction, I'd like to turn the 9 platform over to Ed Connell, who will give us an overview of 10 how his life has become hell lately.

11 MR. CONNELL: Not hell, very busy; very busy, 12 Thank you, Dr. Powers. I appreciate the 13 opportunity to come and discuss with the committee the 14 preliminary overview of the fire protection rule making 15 effort.

16 I'm Ed Connell, senior fire protection engineer in 17 our Plant Systems Branch in NRR.

18 Before we talk about where we are going, a little 19 bit about maybe where we have been. It's not a new issue.

20 In SECY 92-263, the staff identified three areas for rule 21 making, Appendix J, the 50.44, combustible gas control, and 22 fire protection.

23 The recommendation from the staff was to try to 24 use a less prescriptive, more performance oriented rule, use 25 PRA as appropriate, and address inspection enforcement.

O I ANN RILEY & ASSOCIATES, LTD.

Court Reporters i 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

1 210 t

1 That hasn't changed in five years. Basically the same F 2 thoughts in 1992, we are still having today.

[/

w 3 In 1993, we had the fire protection reassessment, 4 a result of the thermal lag issue. Staff went back and 5 re-looked at the entire fire protection program. The staff 6 recontmended revising the current NRC fire protection 7- regulation, 50.48, and recommended eliminating Appendix R 8 and replacing it with something that was more flexible, more 9 reactor safety oriented, tighter ties to shutdown and 10 specifically addrecsed the role of fire barriers and 11 limitations. It hasn't changed a whole lot since 1993.

12 More recently,96-134, the staff recommended 13 rejection of the Nuclear Energy Institute's Appendix S 14 petition for rule making, and recommended to the Commission A

(_) 15 to revise 50.48 and modify or remove Appendix R, and then 36 modification or elimination would allow the implementation 17 of risk informed and performance based methods as they are 18 developed.

19 There is some consistency you can see throughout 20 the history of this issue.

21 This past Summer, the staff issued 97-127 and this 22 was the staff's rule making and research plan describing the 23 proposed staff actions for developing a performance based 24 risk informed fire protection regulation.

25 The staff requirements memorandum that followed

(

ANN RILEY & ASSOCIATES, LTD.

\-- Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

-211 1 onto-97-127 was issued this past September. -It directed the

() 2 3

staff:to-complete the research activities /noted in 97-127 by the=end of this year; obtain industry feedback on the 4 interest in a'new rulei prepare an expedited schedule.for

'5 rule making; shift the responsibility from the Office of 6 Research to NRR, and they were also directed to coordinate 7 additional research 'fith industry as necessary for longer 8 term action.

9: That's: pretty much the background information.

10 What do we want to do? Well, what we want to do is-11- first and foremost is ensure public health and safety.

12 That's the whole recson why we are here.

13 -The old rule, we believe, does that fairly well 14 and we would ensure that any new performance based risk 15- informed rule that we embark upon wouldLdo the same thing.

16 The other thing we'd like to do is establish an 17 uniform licensing basis for all the plants. I'm sure you 18 . are aware we have the Appendix R pre-1979 plants and the 19- post-1979-plants that are not required in 50.48 to comply

[ 20 with Appendix R. They are required to comply with-their 21 license condition which incorporates a lot cf the guidance 22 from Appendix R, but it is not a specific regulatory 23 -requirement.

24 In. addition, there are some other differences. Not 25 'all aspects of Appendix-R are applicable to all the pre-1979 ANN RILEY & ASSOCIATES, LTD.

, Court Reporters 1250 I Street,:N.W., Suite 300

! Washington, D.C. 20005 (202) 842-0034 L . . . _. . , . .- .-.-. . ..

212 1 plants. G, J and O were the only ones that were specifically n

( ) 2 backfitted. Some other elements of Appendix R are applicable 3 if those plants had open items in their Appendix A SER when 4 Appendix R was' issued.

5 The other thing we'd like to do, und this is under 6 Commission direction, is eliminate the need for the 850 7 exemptions from Appendix R that are currently outstanding.

8 There has been a lot of talk about what the number 9 is. I'm fairly confident in this number. When I'm talking 10 about exemptions, I am talking solely about grants to a 11 license, topic four, January 1, 1979, which Appendix R is a 12 requirement. I am not referring to the schedule exemptions 13 that were issued under 50.48 that many of the plants 14 received. I am not including deviations from s" ff guidance

(

\ 15 that many plants have, specifically those plants that were 16 licensed after January 1, 1979. Those are not exemptions in 17 a literal sense.

18 There are approximately 850 exemptions of Appendix 19 R for the operating plants today, and that does not include 20 plants that have recently ceased operation, such as Main 21 Yankee and Haddam Neck.

22 The last thing we'd like to do is allow for 23 application of performance based and risk informed methods 24 as appropriate. As the tools mature, fire modeling, risk 25 assessment, whatever, addressing the uncertainties, we'd A

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., St.ite 300 Washington, D.C. 20005 (202) 842-0034

. .. . . - - - - _ . - - . ~.-. - - - - .-- -- . -

q 212 1 . plants.1G,-_J and'O-wereithe~only.ones that were specifically

() 2l _backfitted._.Some_other_ elements _of' Appendix:R are_-applicable-3 -if_those plants-had open items in'their Appendix A SER.when-4: Appendix R wasLissued.

5- The other thing we'd like tas do, and this is under -

6 Commission direction, is eliminate the need for the 850 7- exemptions from Appendix R that are currently outstanding.

8 There has been a lot of talk about what the number 9 i F .1 I'm fairly. confident in this number. When-I'm talking 10 about exemptions, I am talking solely about grants to a 11 license, topic four, January-1, 1979,-which Appendix R is a 12 requirement. I am not referring to the schedule exemptions 13 -that were issued under 60.48 that many-of the plants 14 received. I'am not including deviations from' staff guidance 15- that many plants have, specifically those plants that were 16 licensed after January 1, 1979. Those are not exemptions in

17. a literal sense.

-18 There are-approximately 850 exemptions of Appendix 19 R for-the operating plants today, and-that does not include 20 plants that-have recently ceased operation, such as Main-21 Yankee and Haddam Neck.

22 The last thing we'd like to do is allow for 23- application of performance based and risk informed methods 24 as' appropriate. As the tools mature, fire modeling, risk 25 assessment, whatever, addressing the uncertainties, we'd 1

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005

_(202)-842-0034 Q[ )

213 1 like to write a rule that does not ieed revision in the

~

-2 future to allow these tools to be used when we have an 3 adequate comfort level with their use.

4 The two months that NRR has been assigned primary 5 responsibility,_let me tell you what we've been doing. Most 6 of the time, we have been working on developing the 7 expedited schedule with detailed milestones that the 8 Commission directed us to do. That's in process.

9 The staff attended the NEI fire protection forum a 10 couple of weeks ago in St. Petersburg to get some feedback 11 from the industry about what their feelings are for a new 12 rule, addressing the concerns they have with potential new 13 requirements, and what their involvement could potentially 14 be in development of the new rule.

15 We have also participated on the NFPA's Technical 16 Committee for Atomic Energy. That committee is developing a 17 performance based standard for fire protection for nuclear 18 power plants. I'm a member of that committee. We had a 19 meeting a few weeks ago.

20 The NFPA committee's effort right now, at the 21 earliest, they will complete their effort in the Spring of 22 the year 2000.

23 This past Wednesday, we had a meeting with NEI and 24 some industry representatives. The Nuclear Energy Institute 25 sent out a survey to all the licensees to kind of get their ANN RILEY & ASSOCIATES, LTD.

N- Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

214 l

1 feeling for a rule. It looks like industry at this time is

,~') 2 not in favor of pursuing a rule making effort. They did (J

3 indicate they would participate if the staff decided to 4 continue with the effart, but right now, they are not going 5 to support it. They would like to maybe fix what we have.

6 VICE CRAIRMAN POWERS: Did they explain to you why 7 they were changing --

8 MR. CONNELL: There is uncertainty with new 9 requirements, some other areas. They are going to write us 10 a letter by the end of the year explaining the results of 11 the survey and expand on the reasons.

12 This is something the Commission has directed us 13 to do, so we are briefing the Commission in February of next 14 year.

(%

(_) 15 VICE CRAIRMAN POWERS: They anticipated getting 16 feedback that was supportive of a new rule.

17 MR. CONNELL: The information that we had from 18 industry prior to this past Wednesday was industry was e

19 supporting the staff going forward with a performance based 20 risk informed rule.

21 If you look all the way back to 1992, industry has 22 generally been supportive of that approach. Now, we see a 23 change.

24 MR. MARSH: This is Ted Marsh from the staff.

25 There was an explicit statement that asked for the staff to ANN RILEY & ASSOCIATES, LTD.

[\ >) Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 1

. . ~ _ - _ . - . . _ - _ _ - _ _ _ _ . _ ._ ._ _. _ - .. . _ _ _. .

215 lI .

1- _go and'get feedback from the industry as to.the desirability 31 2 and willingness for a new rule.

%f 3 I think the Commission was wanting information as

4; t'o-whether'the industry had changed-its mind.-

5 VICE CHAIRMAN POWERS: I think-I understand. I

• 6 'was just1 wondering if'in an earlier briefing to the 7 Commission on the substance of thisimight not be prudent, 8 because I think they are presuming a positive-response to a 9 new rule, and now you are getting a negative response, and .

-10 that may change their opinions on time schedules and things

-11 like that.

12 MR. MARSH: We do have plan on going back.to the-13 Commission with schedules. In that paper, we don't have-14 this feedback. This is. brand new feedback. We do have a

() 15 presentation planned for them early next year and we did ask 36 to get the feedback received early in writing from the 17 Commission. We suggested or Gary suggested that it be sent 18 to.the Commission so that the Commission gets this feedback j 19 directly through the. industry.

l 20 I think you are right. I think they need to-hear 21 this feedback and the reasons for the change in thought.

22 CHAIRMAN SEALE: Yes, if-they had that answer, l

23 they could decide what-they wanted to-do.

24 MR. MARSH: Right; exactly.

1.

25- MR. CONNELL: The path forward is we are going to O ANN RILEY & ASSOCIATES, LTD.

\w I Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 l

, _ . a , -

216 1 solicit public industry input into the rule making- if the

(~s i

v) 2 Commission directs us to proceed. We had a meeting last 3 Wednesday. I did indicate that NEI has committed to provide 4 us a letter by the end of the year, to have the results of 5 . that survey.

6 What we are doing in the meantime is we are 7 looking at all of the existing requirements and guidance, 8 and this might be useful even if the new rule making does 9 not go forward.

10 There is a lot of guidance in the standard review 11 plan, in Appendix A, in the regulations, some generic 12 letters and information notices and internal NRC memo's.

13 _ We'd like to go through all that stuff.

14 VICE CHAIRMAN POWERS: I'd like to be able to get t' N

'(,) 15 all thiough all that stuff.

16 CHAIRMAN SEALE: A noble objective.

17 MR. CONNELL: What we'd like to do, even if we 18 don't go forward with the rule making is at least maybe make 19 a scrub of the existing guidance with possible input for 20 maybe a reg guide for fire protection.

21 There was a draft reg guide issued many, many 22 years that was never formally issued. Maybe that would be a 23 good idea even if the rule making does not go forward. If 24 the rule making does go forward, we propose that some of the 25 existing guidance be used as the basis for the prescriptive

/ ANN RILEY & ASSOCIATES, LTD.

\~ I Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

217 1 option for complying with the new rule.

() 2 New requirements.

3 VICE CHAIRMAN POWERS: Do you need a separate 4 approach, a separate activity for eliminating the 5 prescriptive requirement? Probably. The answer probably is 6 yes to this question. I'll ask it anyway.

7 With DG-1061 coming along down this pike, I mean 8 presumably somebody could if they were really heroic say 9 okay, we're going to change all this and go to a risk 10 informed approach to fire protection, but it would be a 11 pretty heroic undertaking. 8 12 MR. CONNELL: You could do that now. You could do 13 that under 50.12. You can do that under the exemption 14 process. It does put you into the exemption process. I

/9

(_ / 15 don't see 1061 allowing you -- the regulation calls for a 16 three hour barrier. If you say I have a 30 minute barrier 17 because I did risk significance, I don't have to do that any 18 more, 19 VICE CHAIRMAN POWERS: This would be a heroic 20 undertaking.

21 MR. CONNELL: But you could do it under the 50.12 22 exemption process. Of course, there's concerns with having 23 exemptions to the regulations.

24 VICE CRAIRMAN POWERS: Presumably, the Commission 25 is positively disposed to a rule simply because the O

' I' ANN RILEY & ASSOCIATES, LTD.

'~ Court Reporters 1250 I Str3et, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 l

218 1 magnitude of the exemptions and their viewing of exemptions g

2 is an anathema.

(]

3 MR. CONNELL: Right. My understanding is 4 exemptions _are really a way of alternatively complying with 5 the intent of the rule.

6 The backfit.96-134 ider.tified 12 areas that the 7 staff thought were candidates for-the rule making effort to 8 add some additional requirements if we went forward with the 9 new rule making.

10 Based on the information and the insights we have 11 from the IPEEE and looking back at some of the licensee 12 event reports for the past 10 or 15 years, there may be some 13 additions to those 12 that the staff is going to consider, 14 if the Commission directs us to proceed with the rule

[)

\_/ 15 making.

16 VICE CHAIRMAN POWERS: Are there any of the fire 17 analyses done for IPEEE that were done with a probabilistic 18 risk assessment methodology as opposed to things like FIVE 19 methodology and what not?

20 MR. CONNELL: Yes, about maybe between a quarter -

21 and a third of the submittals were PRA's. Most submittals 22 used some aspects of FIVE methodology and some aspects of 23 the PRA methodology. -The FIVE methodology was typically 24 used for screening areas that didn't require further 25 analysis, f

) ANN RILEY i ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

-- 219

'The FIVE:modeling propagation analysis was used.  ;

1

'2: --Many of,the: assumptions in:the'FIVE; methodology were used. A t

3 few plants did fullEblown PRA's. There-is one or two-that 24- 'did a level two-PRA. That's very unusual.

5- -Based on that,.we've reviewed _about 40 of the-61 submittals thus far. There-are.scmezthings that kind of pop 7 out, areas that we think need to be-looked at in a little 8 more detail. Some of the issues, for instance, with' Quad 9- . Cities, come to mind.

91 0 - MR. HOLAHAN: Mr. Connell, just for completeness, 11= who is reviewing those IPEEE's?

12 MR. CONNELL:. I am.

13 MR. HOLAHAN: Thank you.

14 MR. CONNELL: -The other thing that we will do, of'

) 15. course, is to continue research activities. The Office of 16 Research is coordinating this effort with NRR. They are 17 looking at several areas for a longer term research project, 18 -- fire initiation, fire environment, fire containment, 19 hardware and human performance,-fire scenario assessment, 20 Land the analytical tools, to see how they can be improved.

121 That completes the presentation. I'd be happy to 22 answer'any questions that I can.

23 VICE CHAIRMAN POWERS: I think the presentation

24. .has done what it was. intended to, which was a heads up on 25- all of this. I'll ask. members if they have any questions to t

ANN RILEY & ASSOCIATES, LTD.

A -Court Reporters 1250 I_ Street, N.W., Suite.300

. Washington, D.C. 20005 (202) 842-0034 n w e e s,,1 m _v.,- w r - r~~n -- w ww

- . . , _ .. _ _ - . . - . _ . - . ._ _ ... _ . , . . _. _m . __ _ _ . . _

220

^

11- pose.-

() 2i

- 31

-[Noiresponse.)

VICE CHAIRMAN ' POWERS :: Seeing none= thank_you very- ,

'4 much. -

.5 MR.-jHOLAHAN:~ May;a non-member make'a comment?

6- VICE CHAIRMAN'?OWERS: Absolutely.

7 MR. HOLAHAN: I'believe I went on record inl1993 -

i 8 'of,beingiin. favor of rule change for a number of reasons, 9 several of which'Ed. mentioned earlier in his presentation.

11 0.. I heard NEI's concerns about being. supportive =of a 11; rule change earlier.-this week.. I recognize that it is

., ,12 easier to do a rule change-and perhaps even likely to be 13L more-effective if the industry is in favor of it.

114 I didn't hear anything recently that changed.any

-15 ; of the' fundamental reasons-that I was in favor of a rule 16' change four years ago. End of heads up. ,

17 VICE CHAIRMAN POWERS: That's throwing down the c 18 gauntlets. At this point, I'll call on Fred Emerson to provide some input:from NEI concerning the industry 20 -positions'on fire protection rule making. Fred, feel' free to 21 throw down gauntlets as you see fit.

'22 MR. EMERSON: The scheduling of these two topics I

~

23 -was;very fortuitous because severe accident management and -

24 fire protection are my two primary --

p-We do our best to minimize

251 -VICE CHAIRMAN. POWERS:

' ANN.RILEY & ASSOCIATES, LTD.

.b - Court Reporters 1250 I Street,EN.W., Suite 300 Washington, D.C. 20005

, -(202) 842-0034

_. . _ _ ~ . _ _ . . _ .

211 1 the impact. We heard you coming.

g

/ 2 MR. EMERSON: My background in fire protection is V}{

3 not nearly as extensive as Ed's but I do share the workload 4 that he has. I-think fire protection offers a great many 5 challenges these days.

6 My background prior to joining NEI, I was with 7 Carolina Power and Light Company. My expertise that I claim 8 in the area of fire protection derives from the fact that I 9 did a fire PSA for the Brunswick plant about eight or nine 10 years ago, prior to the time that the IPEEE's were being 11 developed.

12 VICE CHAIRMAN POWERS: I'd be interested in the 13 off the top of your head thoughts that you have on the 14 quality of tools that are available for doing fire PSA's, f

(_3

,/ 15 MR. EMERSON: I would have to defer that to the 16 people who are more current in the practice of fire PSA's.

17 VICE CHAIRMAN POWERS: I don't think it's changed 18 much.

19 (Laughter.]

20 MR. EMERSON: I appreciate the opportunity and I 21 understand that I have about ten minutes, so I'm going to 22 try to convey to you fairly quickly the reasons for the 23 positions that were stated by Gary and by Ed on Wednesday.

24 The introductory material has been pretty well 25 provided by --

O,' ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

222

-l' VICE CHAIRMAN POkdRS: Mr. Emerson, don't~ feel (n -_). 2- : rushed. ,

3 :MR;. EMERSON: -Don'tifeel-rushed?- ,

4- 'VICE CHAIRMAN' POWERS: No . -  ;

5 MR; EMERSON: The introductory material has been 6 _ pretty _much provided by Ed. .I don't see a need to re-visit-.

7 that very much. _I'll'also indicate the steps'that we have  ;

8 taken;to put in place the capatility for responding to the rule making ~ issue.

~

9 The fact taat we prefer not to have one '

10 doesn't mean that we aren't prepared to support it and we 11 -don't think it's an important activity if it'does proceed.

12 VICE CHAIRMAN POWERS: You don't think it's'an lL3 important activity in the risk impact sense or do you think 14 the situation is already well covered?

O(s/ _15 MR. EMERSON: We believe -- I'll get'to this in a 16 little bit, later in the presentation as to our activities 17 atui why we think it's important, then I'll summarize the 18 industry positions that we presented to NRR on Wednesday and 19 close by indicating what we propose as industry involvement 20- in the short term and long term activities that are taking

-21 place'to support rule making.

22 _As I say, Ed has pretty well described the

. 23 background behind this, so I don't see a need to elaborate-

'24 further. We understand that this is a very high priority for_the Commission in terms of rule changes that may be

()

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

l 223 1 necessary.

rx (s/ i 2 We have in place two groups within NEI that 3 support our activities in the fire protection area. In 4 1994, back when thermal lag was a very important issue, we 5 formed a fire protection working group comprised of a 6 combination of executives and senior fire protection 7 professionals to offer us advice and counsel on the impact 8 of fire protection issues, a chief of which at the time was 9 thermal lag.

10 This group is still in existence and it is still 11 providing us overall policy direction on where we need to go 12 with specific fire protection issues, of which there appears 13 to be a resurgence lately.

14 Specifically in reLponse to the SRM,97-127, it I

(m,) 15 became very clear that the staff was proceeding on a fast 16 track to develop a rule or at least provide the suppcrting 17 elements to brief the Commission on the development of a 18 rule, and we felt it necessary to devote a specific group to 19 that activity. This group is charged with the process of 20 developing specific policy matters directly involved with 21 fire protection rule making, interacting with the staff as 22 the rule making activities proceed, again, assuming that 23 they do, and providing direction on the necessary tasks to 24 support rule making, if we do proceed with this.

25 The people who are involved in this group, this (p)

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 l

.. . .- - ~ .- - _ _ . - - . - . . _ - . .. . - . . . . . -

-l l

I 724 l

.1 - maybeLa slightly: lower management level'within'the NEI

() 2

! 3 --

1 structure, we-have--fire protection expertise,1:PSA, licensing,-engineering and-legal-representation, to_try to: >

4 ' cover all of tiie aspects that will impact an industry ,

5 decision on how to support this best.

6 Another element of the response to the SECY was 7 the need to detail what industry concerns lwere,:to what 8 extent industry would support fire protection-rule making. ,

9 Several of our information. forums, fire protection

-10 information forums, which we hold semi-11_ annually, a number'of fire protection-professionals from 12 around the country had expressed significant reservation 13 about the desirability.

l- 14 We felt it necessary to go through the chief 15 -nuclear officer level to determine what the official utility 16 positions-were to help guide us in_what directions we should 17 follow.

18 The survey wasn't designed just to say, yes, we 19 want it or no, we don't. It was designed to say if we go 20 ahead with-it, what do we think are important elements to 21 reflect. If we go ahead with it, what are some potential 22 impacts that we need to avoid, specific things that we need 23- to steer clear of, and if we don't go ahead-with it, what 24 ;are some possible alternatives that accomplish some of the 12 5 same goals that rule making might.

) ANN RILEY & ASSOCIATES, LTD.

[~'/

A- - Court Reporters-p 1250 I Street,;N.W., Suite 300 Washington, D.C. 20005 o (202)-842-0034 l

l . - - _

225 1 -Before I co any farther, I'll say it's no secret rmj 2 that people in industry are not real crazy about the current

.v 3 rule, but we do have a large body of experience built up 4 over the last 15 to 20 years in dealing with it, and to a 5 large extent, people have become comfortable in dealing with 6 it, even though it does have certain draw backs.

7 VICE CHAIRMAN POWERS: But we did listen to a full 8 and lengthy presentation of something called Appendix S.

9 That certainly didn't sound like everybody was very familiar 10 and comfortable with the existing regulations and felt no 11 real need to change things. It certainly smacked of wanting 12 change.

13 MR. EMERSON: Are you asking me why we are flip 14 flopping?

13

( ,) 15 [ Laughter.)

16 VICE CHAIRMAN POWERS: Without using those words.

17 (Laughter.)

18 MR. EMERSON: Appendix S, I might say that was 19 then and this is now, but Appendix S was written -- it had 20 specific elements that industry wanted to see in a rule. It 21 was also at the time when we were perhaps a little more 22 optimistic about the availability of risk and performance 23 bases to be used in a new rule than we are now.

24 We are a little less comfortable with the idea 25 that we are going to be better off with rick and performance I ANN RILEY & ASSOCIATES, LTD.

's '

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 l

- . .- - - _. - - -.- .-. . . ~ . . . - - . _ , . - - . - .. _ .- -

226

'1 - bases'as;the; basis, for-a new rule. As I'll get to later, we-i 2 'certainly support increased use of_ risk and performance

])

3 measures for activities, including the-fire protection area,

{

'4 butfI think we can embody that in theicurrnt rule, in'our 5 Leompliance with the current-rule in the exemption process.as 6 well as undertaking a new rule.

7 I'm getting a little bit ahead of myself.

8 VICELCHT.IRMAN POWERS: It's always. wise .tx) De'

.5F careful about what'you ask for, I suppose.

10 MR. EMERSON: We are just a little less 11' comfortable with the directica that we see and what we see 12 coming-out of a new rule than.we are at the time we proposed 13 Appendix S.

14 ~ The fact that we received responses from every 15 single utility that has an operating nuclear plant indicates 16 the significance that utilities place on this issue. I 17 -think it's one that potentially has a high impact en the 18 utility industry and we received a lot of careful and 19 thoughtful responses with some very good suggestions for 20 what we should do.

21 I'm not going to spend a lot of time on this.

22 This is a summary of our four principal points. I'll go 23 through each of these in slightly more detail in the 24- subsequent: slides.

25 First of all, our principal position is that it's ANN RILEY & ASSOCIATES,-LTD.

's- L Court Reporters 1250 I Street, N.W., Suite 300

. Washington, D.C. 20005 (202) 842-0034 l

227 1 not desired or necessary to assure or improve safety. Having (f 2 said that, however, it's certainly in our best interest to 3- proceed and to utilize the experience that industry has 4 developed in complying with the current rule over the last 5 15 to 20 yecrs to make sure a new rule is useful, workable 6 and accomplishes the goal of compliance with fairly 7 understood regulations.

8 As I indicated ectlier, we have already put in 9 place some infrastructure designed to help support that, if 10 it proceeds. We have undertaken some projects that will be 11 able to help support that, again if it proceeds, out I'll 12 elaborate a little bit more on that later, 13 We feel that the schedule needs to allow adequate 14 time for completion of support elements. I'll elaborate on ,

\ 15 what those support elements are in a minute.

16 Finally, to reemphasize the fact that we are 17 certainly not opposed to the use of risk performance 18 techniques. We are not sure that this rule is the right j 19 place or time to do that with respect to fire protection.

l 20 VICE CHAIRMAN POWERS: The staff has recently 21 issued for public comment, I believe, a regulatory guide in 22 connection with fire safety for plants that are permanently 23 shut down and undergoing de-commissioning, which they 24 characterize as performance based.

i 25 Have you examined that and ao you feel like that's

() ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 l

l

228 -

1: afpromising direction or unenthusiastic about that?1

.f) 21 MR. EMERSON: I have not_ personally ~ examined-that-3 regulatory = guide that:they have. issued.  !

4 MR.-CONNELL: -Dr. Powers,-that draft-guide has not.

'5 'been issued'yet foripublic comment. It,'s_.stillLhung up in 6 the' CRGR ~ review process .

7 VICE CHAIRMAN POWERS: I'm sorry, you haven't-had-8 a' chance to see that.

9 MR. EMERSON:--There's a good reason I haven't'seen 10 it. With respect to your question about the shutdown rule,.

11- I was here during a previous briefing the subcommittee had 12: on that. Tony Pietrangelo was explaining NEI's position 13 generally on the shutdown rule. I don't-know that I have 14 anything in particular to add to the-comments he offered at 15 that time, 16 To get into the basf.s for the four positions that 17 I outline in this slide, first of all, as I.said, although I 18 don't think you would find too many people who really are 19 fana of the new rule throughout the industry. The fact-is 20 Lwe have a large body of experience built up in dealing with 21 it.

22 We know how to use the exemption process to tailor 23- compliance with the rule to' plant specific concerns. We 24 have developed what we consider to-be effective and safe

! 25 shutdown-and fire protection programs nader the current ANN RILEY & ASSOCIATES,-LTD.

Court Reporters 1250 I Street,.N.W.,_ Suite 300 Washington, D.C. 20005 (202) 842-0034 i . - _ u .- _

- .. -. - ._. .- ~. - - . _ _ . .. . _ .

k 229 3 trule;. Generally, we know how to deal with it.

! .2 VICE CHAIRMAN POWERS:. When you_say. industry has

3 effective fire. protection and-safe shutdown programs, the-4-  ! word " effective" has some meaning to it. Is there a 5: l quantitative _ basis for this?

'6 MR. EMERSON: I would say it's more a regulatory ,

7 basis. The-examinations, NRR has been examining ---the -

8 regions have been examining these programs for years. Of 9'- course, I have pointed out certain weaknesses of individual' ,

10 plants, plants have taken steps to correct the weaknesses q-11 that have been found and generic issues that have come up 12 during this process and have been addressed through existing ,

13 mechanisms. -

14 I think current methods are adequate and we don't

) 15 . gain a-lot by jumping off into a new rule. We don't see an 16- additional level of safety being added by doing that.

17 As I indicated, the industry and the NRC processes 18 are_ generally effective in addressing emerging issues.

19- There have been some issues that we have been working 20 through lately. We have interacted with staff and the staff f

21 has taken steps to bring these to the attention of the 22 industry. The industry has taken steps to address their 23 concerns about staff positions to them, the dialogues have

24. been established,-and generally, the pathways that have been

- 2!L worked out for dealing:with this we think are working.

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 L Washington, D.C. 20005 (202) 842-0034 l - - . . -

.. - - .. - - - - - - .-. -~ ~.. - .- . ..

_230 J11 --

VICE CHAIRMAN-POWERS: Some of-them are__ generally-2- ,l effective,'it's:not a word that'I think at:least one-3 Commissioner ~would useLin connection with things like-4- i thertal= lag l and maybe even1 penetration; seals.=

MR.-EMERSON: =There certainly_have been rough 6 spots.

7E [ Laughter.)

8 MR . M EMERSON.: One of the most strongly held 9 industry beliefs is that if we go to a new rule, because.of ,

10 -the experience that we have built up, I think that almost 11 all plants believe it an option for plants, that the-12 existing provisions of the current rule should be maintained 13 as an option.

14 Utilities thould have the option to not have to go O(,,/ 15 -in and spend a great dealoof money just to re-16' examine current existing programs that have been found to be 17 generally effective without it being driven by the promise 18 of a significant safety benefit.

19 Jus an option, we would like to see in any new 20 rule, a plant being allowed to continue to comply with the e

21 exemptions that they have-in place, whether they are called 22 exemptions or_not, the provisions those exemptions allowed, 23 before they-have to go off and spend a lot of money to 24 essentially baseline their existing programs.

25' VICE CHAIRMAN POWERS: We are right now in the-

[ \ ANN RILEY & ASSOCIATES, LTD.

ls I Court Reporters 12505I Street, N.W., Suite 300

Washington, D.C. 20005 (202) 842-0034

231 1 middle of a lot of hectic activity and it may not be

[I v

2 possible for you to comment, but Mr. Connell mentioned 12 '

3 areas of added requirements, possible backfits, and went 4 onto say that based on IPEEE examinations, he may have a 5 longer list than that. Are you familiar with the list? I 6 don't know that it's been made available to you or anyone 7 else.

8 MR. EMERSON: Generally, yes. It was discussed at 9 our information forum.

10 VICE CHAIRMAN POWERS: When you say the option for 11 compliance with the current rule must be preserved, you are 12 saying current rule and any of these backfits or less these 13 backfits?

14 MR. EMERSON: I think generally we are looking at n

k ,) 15 where things stand now. It might be more difficult to 16 address new issues under the current rule, but that's an 17 area we would have to talk about and examine to see how 18 easily we could fit that in under the current rule or what 19 types of interpretations we are looking at.

20 Those are the basic reacons why we feel that a new 21 rule is not necessary, and just a quick summary, we just 22 don't see a significant safety gain going through the 23 trouble it would take for a plant to put itself in 24 compliance with a new rule, even if there were no new 25 requirements.

\

n i i ANN RILEY & ASSOCIATES, LTD.

\/ Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

, . - - - - - ~ . . . .. - . - . - . . . - . - . _ - ~ . - ..- - . . - . . .

232

1 -Industry.-will participate extensively-if rule 2- making proceeds'. There'are no two. ways-about it. It is~in 3 our.best-interest"to'have a rule that! works not only for the 4 regulator butt for'the industry. .Those two' goals are=not-

-5 mutuallysexclusive.

61 -We would hope-to be able to work with: staff about 7- putting in provisions that areuinspectable, enforceable, to 8 at least understand clearly what is required for compliance,

-50 so that both the NRC and-the utilities are working offsthe 10 same page. Sometimes that's been our difficulty with the 11 current rule,-that the interpretation of the rule has not

-12 always been clear and there have been differences in 13 interpretation. We would hope to avoid those kinds of 141 . difficulties if a new rule is put into effect.

15- We have a lot of years of experience complying 16 with the current rule and those years of experience not only 17 mean we're not anxious to change but they also offer a great 18 deal of support for what the impact is of a new rule if you 19 put it in place.

20 When I say " rule," I'm going to expand that a

21f little bit to. include the supporting regulatory guides.

VICE CHAIRMAN POWERS: That's fair. I do that 23 myself.

24 MR.: EMERSON: .The people that I represent, you 25' know, many of'them have 10, 15, 20 years of experience'in l

l-ANN RILEY & ASSOCIATES, LTD.

Court Reporters

_1250 I Street, N.W., Suite 300 Washington, D.C. 20005

-(202) 842-0034 L.

l ., , ..-. .- - - .- ., .- - . , . - - , - _ - _ - - , - - -, .- .- . . - - -

- _ . .. - _ - ~.__ _ . . _ - _ . _ . _ _ _ _ . . . _ _ _ . _ _ . _ _ . .. _ _ _

(

233 I

- dealing with' Appendix R. They know how a rule reads and'how l

() 2, it's going to play:out in their plants. -They haveLa pretty- $

'3 good idea of what'NRC inspectors are going toibe looking.for -

Sin; complying.with that. Thus, they_are in a position 'o t 5: provide useful' input to making a rule more workable for NRC -

6 andL the utilities. I 7 I indicated earlier that we have some projects 8 underway, _These weron't entered into with the specific idea 9- of supporting rule making but.I think will be used in that

-10 direction.

-11 By these projects, I mean some studies that EPRI

- 12 1has underway. We have some improvements in fire protection 13 databases that are being dr.veloped. We have some 14 examinations for lessons learned in the IPEEE's, and sort of -

15 in-parallel with the work that Ed is doing in reviewing them 16 from NRC's vitspoint.

17 We have some activities which evaluate some of the 18 fire modeling codes that are going on.

19 None of these are going to be finished in time for i

20 the Commission briefing to have definitive answers, but we 21 have put in place a process by which we can support research 22 and perhaps work cooperatively with NRC to define what the 23 research needs are if rule making does proceed.

[ 24- Again, the fact'that we did have an 100 percent response-to this survey indicates that industry will fully

_ 25

, () ANN RILEY & ASSOCIATPS, LTD.

Court Reportet:;

L1250'I~ Street, N.W., Suite 300 h -Washington, D.C. 20005 (202) 842-0034

%,w,.

v e v o, w w. , .- v.----,--v,-,,w.-,- ,, ,--w--ew ,y,,c,,,,m,w. ,-,-,,-v.-,-w,---,,,3-,,,,-,.,,y. . , - - - - --e, , y 2, - , - . , . , -4 +c-.,.,,--,

, i,---,-r-r-- e--,

234 1_ support NEI and the committees thht have been established in

p 2! going forward'with it.

e:

3 In consideration-of the schedule,.I'll. describe 2

4~ some of the support elements that:I-alluded to earlier as 5 needing to be factored into the schedule.

t 6 Oneiof the reasons why a new rule might want to be 7 put.in place is because there seems to be some deficiency in 8 . safety under the current rule.

9 The NRC has in place pilot inspections _that are 10- called fire protection functional inspections, and they_have ,

11 a series of-four pilots' going on, of which they are in the 12- process of completing the second one as we speak. These 13 inspections are very thorough examinations of plant fire

-14' protectionLandEsafe shutdown' capability and would be a good 15 way to determine if there are any generic safety issues 16 which are not being adequately covered by the current rule.

17 We think that it would be. helpful to allow these 18 four pilot inspections to be completed'and any insights 19 gained to see whether there are safety issues which drive a 20 new rule as well.

21 The IPEE3's-that Ed is reviewing are almost~

22 complete. A number of them have been reviewed and a number

.23 -of insights have been gained which can be used, but we would 24 like to allow for completion of that process and the 25- ~ insights gained 1from.the rest of~the reviews that the staff b1

^A-  :

ANN RILEY & ASSOCIATES, LTD.

Court Reporters l 3'GO I Street, N.W., Suite 300 L  : Washington, D.C. 20005 l (202) -842-0034 o

1 is doing to be factored into driving the need for the new 2 rule as well.

3 Ed referred also to the NFPA code committee 4 activities, which will be in place by the year 2000. NRC is 5 represented on that committee. NEI is represented or; that 6 committee by a couple of fire protection professionals from 7 utilities.

8 The year 2000 is probably not a time frame whicn 9 is useful for supporting the case of rule making that the 10 staff is embarking on, but the committee activities in 11 developing tnat standard, developing the elements of that 12 standard, the insights that they are gaining as they work 13 through that process are ones that we can use even if the 14 foriaal rule itself is not on the street until the year 2000.

15 The exemption process is a very high visibility 16 question with regard to rule making. The fact that there 17 are 850 exemptions, and Ed, I'm not going to dispute you on 18 the number, are seen as I thin). evidence that a rule is not 19 effective.

20 Nhether or not that implication is true, the fact 21 is that an awful lot of effort has gone into developing 22 those exemptions and inspecting against these exemptions, 23 and we need to really be vety careful how we treat those 24 exemptions under any new rule, whether we throw them out or 25 whether we encompass them in the language of a new rule or O ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

l l

236 1 regulatory guide. That has to be dono very carefully or we (n) 2 are going to have a significant adverse impact on the fire 3 protection programs the plants have developed over the last 4 15 to 20 years.

5 VICE CilAIRMAN POWERS: When you are saying adverse 6 impact, are you speaking of an economic impact or are you

? speaking of a safety impact?

8 MR. EMERSON: Principally, one would hope that 9 there would not be a safety impact. Principally, an economic 10 impact. Obviously, you would want to be sure that the safety 11 implications of an exemption are adequately considered as 12 well. I'm certainly not indicating that's secondary to 13 economic, but I'm assuming that would go almost without 14 saying in the staff's consideration of what a new rule would m

k,) 15 say.

16 Finally, I'd like to reeniphasize that while we 17 don't think a rule is necessary, we certainly support the 18 further development of risk and performance techniques.

19 I think it's fairly common, a shared understanding 20 between the staff and the industry that the status of fire 21 databases, IPEEE methodologies and fire modeling is not 22 adequate at this very day to support a new rule, but if a 23 new rule proceeds, we'd like to be sure that we have a 24 framework in place for allowing the development of these 25 tools, to the point where some day, they can be used to (q

j ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 I

! 237 1 support an effective rule, a really effective risk and

()

,-~

2 performance based rule if one is deemed to be necessary.

On un utility specific basis, utilities would like 3

4 to be able to use these techniques more. They see value in 5 being able to address issues which they do not deem safety 6 significant. As Gary pointed out, this is a two edged sword 7 because sometimes unfety significance can tell you that you 8 need to take more stringe.it action as well, and we certainly 9 accept that, but we would like the opportunity to use these 10 more.

11 We think we can do that within the context of the 12 existing rule and the exemption process. We don't think 13 it's necessary to embody a new rule in order to make them 14 effective for fire protection issues.

O(_/ 15 Where would we like to go from here? In the short 16 term, and by short term, I mean between now and the time of 17 the Commission brief, we would like to continue to talk with 18 NRR as they work through their schedule and the evaluations 19 they have underway, and make sure that we contribute 20 effeevively to the process of formulating a conclusion on 21 whether rule making is necessary and if so, what it should 22 accomplish.

23 For the longer term, if rule making proceeds, 24 again, we would propose to work closely with NRR staff --

25 NRC staff, including the Research staff, to develop process O)

(', ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

- -. _ _ - - - - . - - - - = - . _ _ _ . - - - _ _ . .

)

I 238 1 contributions and a schedule by which we could contribute.

2 As I indicated earlier, we could contribute to the s

3 pilot studies and research through these and the other three 4 activities that I mentioned that EPRI is undertaking and i

5 others that could be embarked upon, and provide documents as 6 needed to support it, regulatory guides or comment on NRC 7 activities as they are developing.

8 In the longer term, if rule making is deemed not 9 to be the right pathway, we would certainly continue to work  ;

10 with staff on useful alternatives. As I say, there were a

-11 number of those that were suggested by our utility survey.

12 That concludes my briefing. I'd be happy to 13 entertain any questions.

14 VICE CHAIRMAN POWERS: You've raised a couple of

) 15 questions that I don't know whether they are in our domain 16 to even ask, but I'll ask them ar.yway.

17 One et the-points that you made was that we have 18 the reviews, the IPEEE's still underway, a concluding 19 document coming out of that is some time in the future, I 20 suppose. Our experience with the IPE's has been that the 21 concluding document really did prove to be eye opening and 22 useful in thinking about rule making.

23 Presumably, the summary of insights that you get 24 out of IPEEE's and especially the fire protection aspects of 25 it would be illuminating, i

l ANN RILEY & ASSOCIATES, LTD.

! \- Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

._ . _ _.m._--__..____ ___. _ ._ _ _ _ _ _ _ _ _ . _ - - _ _ _ _ _ . -

239  :

1 We do have these pilot projects going on. They,  ;

() 2 3

too, should be illuminating.. They are looking to see if there are any generic issues. It's not obvious that we 4 would have the benefit of all that information in ,

5 formulating a rule on any kind of expedited pace.

6 The second point that you made that causes some 7- interest is that the world is on a pace to develop a -;

8 consensus standard in this area, and that of course has l 9 interesting ramifications because of a public law.

- 10 -That public-law right now-is not applicable 11 because that standard doesn't-exist,-but it's going to be.  ;

12 You get into a conundrum,- it seems to me, if we are going to i

l 13' have a consensus standard,-do we go through-an accelerated 14 rule making to beat the bell on that and then have to change -

() 15 over to the public law? There is an interesting question 16 there but I don't know whether it's in my domain.

17 On the other hand, I know that sometimes schedules .

18 for these consensus standards are at the outset extremely 19 optimistic.

I 20 It gives us some food for thought.

21 MR. EMERSON: Any questions?  ;

22 -[No response.) i 23 MR.-EMERSON: Thank-you.

24 'VICE CHAIRMAN POWERS: At this point, we will go 25 from the general subject of rule making to a more specific  ;

i O ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W..-Suite 300 '

Washington, D.C.:20005 (202) 842-0034 3

W s-w me wwMee+u-ww 3+*-V +-N -redaum+4 & w' mmM'W-Ww-yyM'-N

% *ivv iWamWowMT w vvn HP- f'guur N 9 ' 4='F e sy ww' *tTF*-W D m 3'u rCW - mvv a g Mrywww y w1y g ty gvw ywu-ty3 V

240 {

1 issue, and some other insights on risk informed fire

() 2 3

protection regulations. I call upon David Lochbaum David, simply because you do not appear regularly in front of this 4 body, you might begin your presentation by giving us a  !

5 thumbnail sketch of your background and interests and the i 6 like, f f

7 MR. LOCHBAUM: Good morning.~ My name is David 8 Lochbaum. I'm the nuclear safety engineer-for the Union of 9 Concerned Scientists. I'm also here today on behalf of Paul 10 Gunter of the Nuclear Information Resource Service.  ;

11 A brief summary of my background, I have-a 12 Bachelor of Science degree in nuclear engineering from the 13 University of Tennessee. For 17 years, I've worked in the 14 nuclear power industry. About half of that time was at

() 15 various plant sites, reactor engineering. I was the chief 16 technical advisor for a while, STA supervisor. I've worked 17 in design engineering, some licensing experience. Just under 18 half of the experience has been spent as a consultant at 19 vurious licensee sites working on things like some design i 20 basis documentation projects and so on.

21 I appreciate the opportunity this morning to 22 address the ACRS with three concerns that we have on fire ,

23 protection regulations. Those three concerns -- I do have 24 handout's. I don't have any slides.

25 VICE CHAIRMAN POWERS: Perfectly adequate.

ANN RILEY & ASSOCIATES, LTD.

i O'. Court Reporters  !

1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 i

l i

., ..,.;-.-_..----._,,-....,_-._._.._._...-.__.,.,._;-,......____-~._.,__..,,,,,_. . . . . . . . - - . . , - - . . . . _.

241 1 MR. LOCHBAUM: The three concerns that we have in

() 2 3

a nut shell are that the complex plant specific licensing bases for fire protection regulations make conformance to 4 these regulations by the licensees and enforcement of these 5 regulations by the NRC staff exceedingly difficult.

6 Our second concern is that some if not all of the 7 p'jnt risk assessments prepared by licensees are 8 non-conservative estimates, and our third concern is that 9 the NRC staff has not adequately determined the technical 10 bases for the existing fire protection regulations. We see 11 that as a hindrance to any rule making process.

12 VICE CHAIRMAN POWERS: Thank you.

13 MR. Lot *HBAUM: To amplify --

14 VICE CHAIRMAN POWERS: Excuse us.

() 15 MR. LOCHBAUM: A little background on the concern 16 about the current licensing basis or complex licensing 17 basis. The recent experience with thermal lag and now fire 18 penetration seals demonstrates that the NRC staff and its 19 licensees do not have an easily retrievable record of fire 20 protection licensing bases for each plant site, 21 We would also point out that while a mere handful 22 of plants have to meet Appendix R, subpart 3.M. which is the 23 non-combustible fire penetration seals requirement, Brown's

24. Ferry does not have to meet this requirement, which started 25 the whole deal.

O' ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

.- - -. - - _ . _ _ . . ~ . . . _ . - . - . - _ _ . , _ ~ - - . _ . - . . _ _ . _

i 242 1 Our recommendation based on this, to get out of

() - 2=

3 this box, would be to adopt a single fire protection rule that is applicable to all licensees.- We refer to that as i

- 4 - the one hazard, one rule approach.  !

l

, 5 -

Our second concern was on the possibly non-  !

6 conservative risk assessments. In the last decade, there 7 have been numerous reports of missing or deficient and '

8 deficient fire barrier penetration senis. Within the last ,

9 few years, the past few years, licensees have been required ,

10 to develop plant specific risk assessments. Some if not all .

11 of these~ risk assessments assume that the fire barrier 12 penetration seals are 100 percent successful in preventing 13 propagation of a fire. In other words, there's a zero 14 percent chance that-the fire propagates across the seal.

( 15 'VICE CRAIRMAN POWERS:- That's surprising.  ;

16 MR. LOCHBAUM: It can't be any higher than that. '

17 - Based on the evidence and the fact that in reality, the fire 18 penetration seals are sometimes not even there, and a lot of 19 times they are deficient, 100 percent integrity just cannot 20 be realistic. We are not going to say it's zero percent.

21 - We don't know what it is. It's non-conservative to assume ,

' 22 it's 100 percent.

23- Our recommendation then based on this knowledge is 24 that a risk informed fire protection rule cannot be based on 25 deficient risk assessments. .

() ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington,-D.C. 20005 (202) 842-0034

_U , ,;7,y.I-,,-.%.s-. -...w..., , - , . - ...er. + , a-[ m,,--%;m.,_. s,., _. ,, , , , . , , . 9_,, ,.w,,, , .,c.7, - ,,p-3, -e ..n.,,,, ,,

- . - . _ _ _ _. - _ . .. - - - _ _. .. - ~

243 1 VICE CHAIRMAN POWERS: When you say given the

() 2 documented history of fire penetration seal problems, that 3 is the existence or deficiency in function, it is not a 4 documented history of fire actually penetrating through the 5 protected --

6 MR. LOCHBAUM: That's true. That's based on the 7 configuration problems, not an actual event.

8 VICE CHAIRMAN POWERS: Are you aware of the 9 existence of a database concerning fire propagation through 10 defective or flawed penetration seals? .

11 MR. LOCHBAUM: I'm not aware of a database per se.

12 We have looked at information notices, et cetera, to try to 13 find that information and haven't found any.

14 VICE CHAIRMAN POWERS: I'm thinking it may well 15 not exist within the nuclear industry and may have to go 16 more afield to find that information.

17 MR. LOCHBAUM: We scanned some of the AEOD 18 reports. That's the closest type of database. I didn't see 19 anything in there. If a database exists, I would suspect I

i 20 that AEOD may have it, if it's within the NRC's --

21 VICE CHAIRMAN POWERS: Yes, they may not go into 22 the steel industry. We have similar kinds of problems.

23 MR. LOCHBAUM: I hope not. Our final concern was 24 on the inadequate determination of technical basis for

! 25 regulations. In NUREG 15-52, which was issued in July of

1. \

ANN RILEY & ASSOCIATES, LTD.

~-

ourt Reporters l 1250 I creet, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

244 1 last year and in the response to Representative Markey's 2 questions and also in a meeting in September of this year s

3 with NIRS and UCS, the NRC staff stated that the technical '

4 basis for the non-combustibility requirement for penetration 5 seals in 10 CFR 50, Appendix R, Section 3.M, was not known.

6 They had no clue as to why that requirement got into the 7 final rule.

8 We learned after that meeting that the technical 9 basis was explicitly specified by the NRC Commissioners 10 themselves during the promulgation of the Appendix R rule.

11 We refer you to the transcript of the October 16, 1980 12 meeting, Commission meeting, when the final draft rule, 13 draft final rule, was discussed.

14 At that time, the commission specifically refused h 15 an industry recommendation to require that penetration seals 16 simply n,et the same fire rating as the barrier in which 17 they art installed.

18 This Commission specifically required that the 19 fire penetration seal's material be non-combustible and the 20 concern expressed in a section called technical bases was 21 that the material penetrating the seals or through the 22 penetrations, the cable insulation or what not, is 23 combustible, and that combustible material may act as a wick 24 to conduct a fire through the penetration seal, so 25 therefore, the Commission thought it would be a good idea to ANN RILEY & ASSOCIATES, LTD.

O- Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

I 245 I have non-combustible fire penetration seal material, j 2 That very basis is. identified quite specifically 3 or explicitly in Appendix R, Section 3.N, which was at that l t

4 time called fire _ barrier cable penetration seal  !

5 qualification. It became Section 3.M in the final rule 6 through re-numbering.

-7 VICE CHAIRMAN POWERS: When the Commission  !

i 8 discusses things, they sometimes use non-specific language j i

-9 in their general discussions, and there are a variety of  !

10 terms within this field, non-combustible, non-11 flammable, inflammable. They all have very specific 12 meanings.

13 I have certainly net looked at this transcript.

14 In your examination of the transcript, was the commission 15' using language specifically here on the non-combustible or 16 were they being loose in their nomenclature?

17 MR. LOCHBAUM: I don't think they had any specific la definitions. It seemed to be loose, from what I gathered.

19 I think the point we wanted to make was that the 20 current regulation in subpart 3.M of Appendix R, which was 21 specifically placed in there at the Commission's specific 22 direction, is contrary to the current position advocated and .

23 taken by the NRC staff in NUREG 15-52 and in responses to 24 Representative Markey and what not.

25 It also concerns us quite deeply that having all d'

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 t (202) 842-0034

- -- . . __ _ - - - - _ _ _m . . _ _ _ _ _ - . _ _ _.

246 1 the work that was necessary in preparation of NUREG 15-51

() 2 3

and advanced this f ar down proposed rule making through five years of SECY papers and what not, the NRC staff did not 4 know technical basis for the fire penetration seal 5 requirement, and y3t was ready to throw it out the window.

6 I guess I don't really understand that concept.

7 We are somewhat concerned that as you proceed into 8 a rule making process, if you don't really understand the 9 technical basis for the existing rules, simply to throw them 10 out and proceed with something new is not a prudent 11 practice.

12 In summary, we feel that the NRC should pursue 13 rule making aimed at implementing fire protection 14 regulations that apply to all its licensees. We feel that

() 15 risk informed fire protection regulations should not be 16 adopted if they are based on deficient risk assessments. We 17 feel that the NRC staff must fully document the technical 18 bases for the existing fire protection regulations as part 19 of the rule making process.

I 20 More importantly, we feel that until any final 21 fire protection rule is adopted, the existing fire l 22 protection regulations must be rigorously enforced. There

(

l 23 is no use doing rule making unless you stop the rule 24 breaking.

25 With that, I'd like to entertain any questions or O ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 840-0034 l____ _ _ - . . _ . . _ _ _ . . _ _ ._ _ _ _ .__ _ _ - . _ _ _ _ _ _ _ , - _ .

247 1 comments.

() 2 VICE CHAIRMAN POWERS: Let me come back to this 3 fully document the technical bases for existing fire t

4 protection regulation. One could imagine rule making being  ;

5 undertaken because you could not fully document the 6 technical bases for existing fire protection regulations or i 1

7 you might find that technical bases had been flawed.

9 I guess I'm wondering is is this kind of a 9 defective exercise if you are undertaking a revision to the 10 existing regulations, that it's better to understand the 11 technical bases for any replacement regulation than to spend 12 a lot of time and resources understanding what you are 13 trying to replace, when you already have evidence that it 14 must be inadequate or deficient in some respects.

15 MR. LOCHBAUM: . agree with that concept. You 16 don't want to waste resources. I guess the concern we have 17 is that unless you fully understand the technical basis for 18 a requiremenc and why that requirement came to be, you may 19 be missing the technical arguments for having or not having 20 that regulation. Simply because you couldn't find it or you 21 don't know what it is, just to simply assume that it has no 22 technical basis --

23 DR. KRESS: If you have a technical basis for the 24 new requirement, then that_seems like it should be 25 sufficient. There may not even be a technical basis for the ANN RILEY & ASSOCIATES, LTD.

Court Reporters

-1250 1 Streat, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

248 1 old one.

() 2 VICE CHAIRMAN POWERS: It's difficult, with all 3 respect to the Commission, I'm not sure their discussions 4 and changes in wording constitutes a technical basis.

5 DR. KRESS: That's right.

6 VICE CHAIRMAN POWERS: Loose language and what 7 not. Deficient risk analysis is another area we might 8 discuss a little bit. I think I basically agree or at least 9 the deficiencies of the risk analysis have to be pretty well 10 understood. I'm not sure we can do a risk assessment right 11 now that doesn't have some sort of deficiencies in it, but 12 at least we understand the thinking in terms of errors of 13 commission. If we leave them out, all of our risk 14 assessments are deficient in that respect because we just 15 don't know how to handle them.

16 MR. LOCHBAUM: I understand that.

17 VICE CHAIRMAN POh'ERS: You have to know what the 18 deficiencies are. I think you were using loose language 19 here yourself when you said what you don't want is things 20 that are flawed that can be corrected.

21 MR. LOCHBAUM: That's correct. Getting back to the 22 question of technical bases, I think the other place that 23 comes into play is with the 850, or whatever the number of, 24 is of exemptions. It's difficult to believe or have 25 confidence in 850 exemptions granted to regulations where ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 -

_ - . _ - - . . = - . _ -. - - _ - _ . - _ - - _ - _

249 1 the technical basis may not be fully understood.

() 2 3

It calls into question that whole process.

leads back to the second concern we had with -- the first It  !

4 concern with the complex regulation on fire protection.

5 It's exceedingly difficult for licensees to conform with and 6 NRC to enforce.

7 VICE CRAIRMAN POWERS: The licensees that spoke  ;

8 just before you, their representative, indicated they were 9 comfortable and happy with the existing regulations, 10 suggesting that they have overcome this complexity.

11 We haven't had similar assurances on the 12 inspectability and enforceability of these, but it appears 13 that the licensees are comfortable with this.

14 It is a mixed bag to be sure because not too long

) 15 ago, I had the licensees telling us to scrap Appendix R for 16 an Appendix S. It's a mixed bag cn how comfortable they 17 are.

18 Right now, they are comfortable with them.

19 MR. LOCHBAUM: Check back next week.

20 I guess as far as our comfort level, I guess the 21 position we take, we don't establish the bar for safety.

.22 That's in NRC's clear purview. No matter where it is, our 23 concern is it's not being conformed with, it's not being 24 met.

25 Whether it's the existing rule or a new rule, 1

i

() ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Weshington, D.C. 20005 (202) 642-0034

250  !

1 that's somebody else's determination. Our concern is l 2' whatever rule that is, whatever standard it is, it's not  ;

3 being met. It's up to somebody else to set -- if we find. ,

4 deficiencies and it's not being met, that concerns us, f 5 That's where we are today. That_needs to be fixed, j 6 VICE CHAIRMAN POWERS: dound point. Thank you ,

7 very much. Are there questions that the rest of the {

c 8 committee would like to pose?  ;

9 [No response.) '

10 VICE CHAIRMAN POWERS: Thank you very much for ,

11 taking the time to come here. I will remind you and the 12 rest of the members P. hat we do anticipate having a i

13- _ subcomnittee meeting in-the area of fire protection. Our 14 schedule is a little bit up in the air right now. It should QO 15 be an interesting discussion on all aspects of this already 16 growing complicated exercise.

17 I'll turn it back to you, Mr. Chairman.

18- CHAIRMAN SEALE: I would just reiterate that the  ;

i 19 industry and the Cc:cerned Scientists' representatives are 20 certainly invited to come to any of those subcommittee i

21 meetings an they occur. In fact, we would be very 22 appreciative c,; *tting your input.

23 VICE CHAIRMAN-POWERS: I concur. We will take 24 - steps to make sura that all the current present presenters ,

25 are aware of our schedule.

ANN RILEY & ASSOCIATES, LTD.

Court Reporters ,

1250 I Street, N.W., Suite 300  :

Washington, D.C. 20005- .

(202) 842-0034 l

--, , ,m ,--2-, -

251 1 DR. KRESS: I'd like to add that we all heard what

() 2 3

institution our previous speaker just came from.

lot of credibility.

It added a I

4 DR. SHACK: Because he was from the University of l 5 Tennessee?

6 DR. KRESS: Yes.

7 (Laughter.]

. 8 VICE CHAIRMAN POWERS:. I almost asked if we could l 9 have Mr. Gunter replace him-when I heard that. .

10 [ Laughter.)

11 CHAIRMAN SEAL 8: I am going to give everybody 12 about ten minutes to stretch, and then we are going to take 13 up the future ACRS activities before lunch. i 14 MR. LARKINS: Can I suggest, you might want to i I() 15 just knock out those two letters before lunch.

16 CHAIRMAN SEALE: Okay. We'll look at it that way. ,

17 Fine. Ten minutts. ,

18 [ Recess.)

19 [Whereupon, at 11:20 a.m., the public meeting was- >

20 concluded.) ,

21 22 23 24 $

H25  ;

) ANN RILEY & ASSOCIATES, LTD,

'- Court Reporters ,

1250 I Street, N.W., Suite 300

- Washington, D.C. 20005 1 (202) 842-0034 P

. Ae *,O..-------+ + m , 4 --m ++v v y , t- m - .L,. ,-

,e- mave-cr. r-= y yw.--,..- r,,,r**-t.--t-,v - ~ 7 7 t 7 ~- m -- r-

O NRR STAFF PRESENTATION TO THE ,

ACRS  ;

SUBJECT:

Severe Accident Management Program DATE: November 7,1997 O

PRESENTER: Robert L. Palla TITLE /ORG: Sr. Reactor Engineer

, Containment Systems & Severe Accident Br Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation i

TELEPHONE: 415-1095 Q SUBCOMMITTEE: Severe Accidents 1

OVERVIEW O e Accident Management (A/M) is an essential element of the NRC Integration Plan for Closure of Severe Accident Issues (SECY-88-147, May 1988)

• Fundamental objective of A/M unchanged from that originally stated in SECY-89-012:

To have each NRC licensee implement en A/M plan which provides a framework for:

- Evaluating infonnation on severe accidents

- Preparing and implementing severe accident q

operating procedures and guidance

- Training operators, technicalsupport staff, and managers in the procedures

• A/M program is vehicle for assuring insights identified through IPEs and severe accident studies are incorporated in licensee emergency response capabilities

, 9

O OVERVIEW Ccont>

e Dialog with industry was considered essential to A/M program success and !nitiated early in the program o 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 agreed to implementation through an industry O i"Iti"tiva I" 'i"" f a '"9"'"t 'Y "oti "

l

• NRC remains committed to importance of A/M and the responsibility to assure high quality l implementation across the industry l

l

• Some level of inspection anticipated at each plant i to develop confidence in program implementation l

l

INDUSTRY A/M PROGRAM ,

• Industry-wide effort coordinated by Nuclear Energy ,

Institute Electric Power Research Institute (EPRI)

Owners Group for each vendor

- Institute for Nuclear Power Operations (INPO)

• Methods and guidance developed to provide a means of achieving desired A/M enhancements

- Severe Accident Management Guidelines O (SAMG) for use by Technical Support Center (TSC) staff Severe accident-related Emergency Procedure Guideline changes (BWRs)

Methodology / criteria for assigning A/M strategies to either control room or TSC (BWFU)

Severe accident training materialsilesson plans 3 O

O LICENSEE IMPLEMENTATION

• Industry has committed to implement A/M enhancements pursuant to " formal position" (November 21,1994 NEl letter)

Each licensee will:

. Assess current capabilities to respond to severe accident conditions using Section 5 of NEl 91-04, Revision 1, " Severe Accident Issue Closure Guidelines. "

I implement appropriate improvements identified in the assessment, within the constraints of existing 1

9 personnel and hardware, on a schedule to be l detennined by each licensee and communicated to the NRC, but in any event no later than December 31,1998.

l

• Schedules for completing implementation provided by all licensees 6/97 - 12/97 37 Units (Mostly W plants) 1/98 - 6/98 4 Units 7/98-12/98 69 Units (Mostly GE plants) b 4 l

EXPECTED LICENSEE STEPS IN O IMPLEMENTING A/M e 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 implemer.tation O

e Institutionalize the A/M plan to maintain capabilities and accept new information should it become available e Perform periodic A/M drills and self-assessments 5 $

l  !

O NRC PLANS FOR INSPECTING A/M IMPLEMENTATION l

1. Participate in A/M demonstrations to observe how l elements of formal position are being implemented

2. Determine appropriate scope / depth of pilot inspections, and complete draft Tl

3. Conduct pilot inspections at 4-5 plants using Tl.

Additional plants if necessary O

4. Develop draft inspection Procedure (IP) based on findings from pilot inspections

5. Hold public meeting / workshop to discuss results of pilot inspections and drait IP

6. One-time inspection at remaining plants using IP

7. Inspect A/M maintenance on a for-cause basis, as a Regionalinitiative O e

A/M DEMONSTRATIONS O.

BACKGROUND e Objective -- to gain insights into:

licensee's implementation / evaluation process

- development of plant-specific SAMG

- training of personnel

- use cf SAMG during drills

- self-assessment of training & drill performange

- how well the draft Tl would guide inspections need for modifying planned inspection process O

• Content:

(1) overview of implementation process (2) A/M table-top drill

• Status:

Demonstrations completed for 2 W plants Additional demos planned for B&W, CE, and GE 7 $

O A/M DEMONSTRATIONS OBSERVATIONS

• Key elements of formalindustry position addressed plant-specific SAMG

^

severe accident training initial training / drills administrative program to maintain capebilities

• SAMG appears to improve TSC response in drill awareness of strategy impacts and phenomena prioritization of activities l

• Some concerns identified, e.g.,

sole reliance on classroom or workbook training for developing / maintaining knowiedge and skills feedback processes for assessing / revising training programs not fully developed no plant-specific IPE insights added to generic SAMG no new strategy implementing procedures need for changes to E-Plan to reflect SAM responsibilities

• Demo objectives met for W plants 8

.i i

i REMAINING NRC ACTIONS O

• 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 l

• Conduct A/M demonstrations at B&W, CE, and GE plants. Develop inspection guidance as appropriate

• Provide training for NRC staff to assure consistent O expectations / perspectives Headquarters, including Emergency Operations Center staff Emergency Preparedness inspectors Resident inspectors

• Confirm adequacy of licensee implementation through inspections and drill observations 9

O

SUMMARY

• A/M program will enhance capabilities to prevent .

and to mitigate severe acc: dents

• Closure will be achieved on a plant-by-plant basis i

implementation completed in accordance with industry initiative 9

adequacy of implementation confirmed by inspection O e A/M capabilities will be maintained "living" periodically exercised by conducting utility A/M drills periodically updated by utility to incorporate new information

• NRC will maintain oversight of utility capabilities 10

, .................................l

i

~

Industry Positions on I

Fire Protection Rulemaking Fred Emerson Nuclear Energy Institute Advisory Committee on Reactor Safeguards g,

November 7,1997 1

0 Topics

> Introduction

?> Ddustry response to NRC rulemaking

' activities 1

-  ; > Industry positions

> Proposed industry involvement N ,E I m

i o

O' Introducti m

> 10 CFR 50.48 and Appendix R high on NRC list of regulations needing change

> Commissioners recently directed rapid evaluation of elements needed to support rulemaking

> Methods, data needs, uncertainties as outlined in SECY 97-127

> OGC opinion on backfit implications

> Industry input on need for rule

~,e .

O I

Industry Response

> NEI Fire Protection Working Group

> Formed in 1994 to provide guidance on industry fire protection positions and activities

> Utility executives / managers and senior fire protection professionals

- > NEI Fire Protection Rulemaking Issue Task Force

> Formed 9/97 to manage timely industry involvement in rulemaking activities yg , > Fire protection, PSA, licensing, engineering, legal representation O

i t >

Industry Response

> Survey sent to Chief Nuclear Officers October 1

> Intended to provide input on

> Rule considerations deemed necessary

> Potential adverse impacts

> Possible alternatives to a rule

> Responses received from all utilities with operating nuclear plants

()

Summary of Industry Positions

> A new rule is not desired, nor necessary to assure or improve safety

> lndustry will participate extensively if rulemaking proceeds

> The rulemaking schedule must allow adequate time for completion of support elements

, >The use of risk / performance techniques has promise r

O Industry Positions

> New rule is not desired, nor necessary to assure or improve safety

> Industry has effective fire protection / safe shutdown programs under current rule

> NRC and industry process generally effective in addressing tmerging issues

> Option of compliance with current rule must be preserved

> Rebaselining existing programs to a new rule will be burdensome, and the safety benefit is not clear N,E a O

Industry Positions

> Industry will participate extensively if rulemaking proceeds

> Issue task force in place for timely action

> Many years experience complying with existing rule

> Projects undenvay which can support i rulemaking

> 100% industry response to rulemaking survey 9

t >

Industry Positions

> The rulemaking schedule should allow for completion of support elements

> Functionalinspection pilots and IPEEEs should be completed to determine whether generic safety issues demand a new rule

> NFPA activities to develop a performance-based consensus standard should be factored into any new rule activity

> The implications of eliminating existing N,E I exemptions should be carefuliy considered O

Industry Positions 1 l

I

> The use of risk / performance techniques has promise

> Need to emplace a framework for the development of risk and modeling tools

> Many utilities would like to use these techniques more to address existing or emerging issues

> These tools can be used to support the existing exemption process as well as in a new rule N,E l 1

3

O Proposed Industry involvement l

> Short term l

> Meetings with NRC staff to discus progress of l I

st.:ff evaluations and industry contributions

> Long term (if rulemaking proceeds)

> Develop with NRC staff mutual understanding ,

of process, contributions, and schedule I

> Contribute to pilot studies and research

> Develop / review documents and positions

> Long term (if no rulemaking)

NEI

> Work with NRC staff on useful alternatives O

I l

l 1

O 6

~ ^

O O O FIRE PROTECTION RULEMAKING i

i November 7,1997 Edward A. Connell Plant Systems Branch ,

301-415-2833

o O

~

O

Background

+ SECY-92-263 - Staff Plans for the Elimination of Requirements Marginal to Safety

+ SECY-93-143 - Report on the Reassessment of the NRC Fire Protection Program

+ SECY-96-134 - Options for Pursuing Regulatory improvement in Fire Protection Regulations for Nuclear Power Plants l

+ SECY-97-127 - Development of a Risk Informed Performance Based Regulation for Fire Protection at Nuclear Power Plants

O O O l

l Objectives

+ Ensure Public Health & Safety j + Uniform Licensing Basis for All Plants -

+ Eliminate Need for 850 Exemptions

+ Allow for Application of Performance-Based & Risk-informed Methods as Appropriate

O O O Current Status

+ Responsibility Transfered from RES to NRR

+ Expedited Schedule w/ Detailed Milestones Submitted for Commission Approval

+ NEl Fire Protection Forum

+ National Fire Protection Association Technical Committiee on Atomic Energy i

o o o Path Forward l

+ Solicit Public and Industry input

+ Scrub Existing Requirements & Guidance

+ New Requirements Backfit IAW 50.109

+ Continue Research Activities e

i I

1 i

~

O .O O .

C ERN =

l SCIENT9STS i .-a EHil Concerns About Risk-informed Fire Protection Regulations David . Lochbaum Union of Concerned Scientists Paul Gunter Nuclear Information & Resource Service November.7,1997 L- -_--- _ -

O. O O .

UNION OF CONCERNED

=' = 'S'S Concerns

- 1 D EHI E Complex plant-specific licensing bases for fire protection makes conformance by licensees and enforcement by NR.C extremely difficult.

E Some, if not all, plant risk assessments prepared by-licensees non-conservatively estimate risk from fire.

E NRC staff has not adequately determined the technical bases for the existing fire protection regulations.

O. O O .

UNION OF CONCERNED Sa a "'S'S Complex Licensing Bases-EEEl E Recent experience with fire barrier penetration seals, on the heels of the Thermo-Lag events, demonstrates- ~

that NRC staff and its licensees do not have an easily retrievable record of the fire protection licensing bases l

l for each plant.

- While a handful of plants are required to meet App. R Subpart III.M, Browns Ferry is not.

E Recommendation: Adopt a single fire protection rule that is applicable to all licensees (e.g., "one hazard, one rule.")

k . . . _

~

O O O .

UNION OF CONCERNED Sc'"""S Non-conservative Risk Studies 1

E EEti EIn the last decade, there have been numerous reports of missing or deficient fire barrier penetration seals.

E Within the past few years, licensees have developed plant-specific risk assessments.

E Some, if not all, of these risk assessments assume 100%

fire barrier penetration sealintegrity (i.e.,0% chance that fire-rated wall or floor will be breached by fire).

E Given documented history of fire barrier penetration seal problems, it is non-conservative to assume 100%

effectiveness in preventing fire propagation.

E Recommendation: Do not base risk-informed fire protection rules on deficient risk assessments.

O O .LO .!

UNION OF CONCERNED Inadequate Determination of  !

S='5" Technical Bas ~es for Regulations

~

~

Hil

~

E In NUREG-1552, in response to Rep. Markey, and in meeting with NIRS and UCS, NRC staff stated that the technical basis for the non-combustibility requirement '

in 10 CFR 50, App. R,Section III.M was not known.

t E The technical basis is explicitly specified by the NRC Commissioners during their review of the App. R rulemaking (.see transcript of 10/16/80 Commission meeting with the draft final rule): '

- Commission specifically refased the industry's proposal to require penetration seals to meet same rating as wall.

- Commission specifically required non-combustible fire barrier penetration seal material to prevent combustible cable jackets from

- propagating fire across fire wall (i.e., wick effect). l

O O O: .;

i

(

UNION 'OF nadequate Determination of CONCERNED

" ' " = " Technical Bases for Regulations H ]I E App. R,Section III.N, Fire Barrier Cable Penetration Seal Qualification

" Some commenters suggested that this entire section be deleted and replaced with the following two sentences: ' Penetration seals shall provide the equivalent protection which is required of the fire barrier. Evaluation of the penetration seals based upon a design  ;

review and relevant test da'.. 3r qualification tests may be made.'"

- "The Commission has reconsidered this issues and revised the rule to:

(a) require the use of only non-combustible materials in the construction of such fire barrier penetration seals; (b) require such fire barrier penetration seals to be qualified by test; and @ require such tests to satisfy certain acceptance criteria."

E App. R Subpart III.M matches the Commission's express direction. The Commission specifically refuted the very policy which the NRC staffis following. .

~

0 0 . O .

UNION OF CONCERNED Inadequate Determination of 5==$

Technical Bases for Regulations

~

, r .

(lll j EIN NUREG-1552, the NRC staff advocates that fire barrier penetration seals need not be non-combustible -

but merely meet the same fire rating as the wall or floor.

E This NRC staff position is virtually identical to that l p.osition specifically discarded by the Commission in ]

1980.

E Recommendation: Do not issue proposed rulemaking for risk-informed fire protection regulations until the

technical bases for the existing regulations are fully understood.

i

i

.f l O O O .;

UNION OF i

CONCERNED 1

" """ =

Summary .

% ~. .

, C lll l E NRC should pursue rulemaking aimed at implementing fire protection regulations that apply to  ;

j allits licensees.

E Risk-informed fire protection regulations should not be l

adopted if they rely on deficient risk assessments.. j i

! E The NRC staff must fully document the technical bases for existing fire protection regulations as part of the rulemaking process.

E Until the final fire protection rule is implemented (some years hence), the existing fire protection regulations must be rigorously enforced.

~

- .- - . ._.m _ _ _ _ _ --

REPORTER'S CERTIFICATE (yx_ ; This is to-certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:

NAME OF PROCEEDING: 446TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)

DOCKET NUMBER:

PLACE OF PROCEEDING: ROCKVILLE, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear

-s Regulatory Commission taken by me and thereafter reduced to

\- # typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.

M

'l h)

TVhnX " L .

J Hundley Official Reporter Ann Riley & Associates, Ltd.

/

Q)

-, 1