ML20237A332

Audit Guidance,Severe Accident Management Implementation

ML20237A332
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Issue date:	07/30/1998
From:	NRC
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ML20237A330	List: ML20237A328 ML20237A332
References
PROC-980730, NUDOCS 9808130277
Download: ML20237A332 (22)

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-AUDIT GUIDANCE SEVERE ACCIDENT MANAGEMENT IMPLEMENTATION 01 OBJECTIVES To assess how the licensee has evaluated and implemented enhancements to the

- capability of their Emergency Response Organization (ERO) to respond to potential severe accidents, in accordance with the formal industry position on severe accident management (SAM) set forth in NEI 94-01. Revision 1. and the related licensee commitments.

02 BACKGROUND On August 8.1985, the Commission published its policy statement regarding severe reactor accidents (50 E8 32138). The Commission stated that "the commitment of utility management to the pursuit of excellence in risk management is of critical importance." The term " risk management" encompasses actions to: reduce the frequency of events that could lead to core damage, prevent and minimize the consequences of severe core damage through effective accident management, and limit the effects of the accident on public health and safety through offsite protective measures. In SECY-88-147, the NRC described its plan for the integration and closure of severe accident issues. This included the conduct of Individual Plant Examinations for internal and external events and the implementation of accident management plans by each licensee. In SECY-89-012.

the NRC described its approach for closure of the accident management portion of the integration plan for severe accident closure and described the major goals.

framework and elements of accident management.

The ' staff. had originally envisioned issuing a generic letter to licensees concerning implementation of accident management. This effort was suspended in view of industry's commitment to voluntarily implement SAM at each nuclear power plant (NPP) pursuant to a formal industry position on this issue. The industry commitment. is provided in a November 21. 1994 letter from Nuclear Energy Institute (NEI). NRC acceptance of the industry position is documented in a January 9.-1995 letter to NEI. In docketed correspondence, each licensee has committed to implement the formal industry position. The formal industry

. position-is incwded as Section 5 of the NEI " Severe Accident Issue Closure l Guidelines". NEI 91-04. Revision 1. The pertinent pages of this document are I

reproduced in Attachment A to this audit instruction. Additional clarifying guidance contained in an NEI letter dated July 22. 1997 and NRC letters dated I- January 28, 1998-and June 25. 1998 has been incorporated in this document.

Implementation of SAM in accordance with the NEI and staff guidance meets the intent of SECY-89-012.

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This guidance document has been developed for use in a limited number of auditt of licensee actions to implement SAM pursuant to NEI 94-01. Revision 1. NRC intends to visit approximately four sites with different reactor designs in the -

latter part of 1998 for the purpose of eveluating how licensees have implemented SAM, and have addressed each of the major steps and " severe accident management implementing elements" set forth in the formal industry position. The guidance will be used to assess: (1) licensee actions taken to evaluate and implement enhancements to the capability of their ERO to respond to potential severe accidents, pursuant to the formal industry position on SAM. and (2) licensee performance and the use of severe accident management guidelines (SAMG) during SAM-oriented drills.

The information and perspectives gained through the audits will provide insights into the effectiveness of the industry initiative. and those aspects of licensee's programs that are most crucial to successful implementation. This information will be used to develop recommendations regarding closure of severe accident management, any follow-up actions necessary to confirm the adequacy of implementation at the remaining plants, and actions to maintain oversight of these capabilities in the longer term.

No enforcement action will result from the SAM audits. Any concerns regarding adverse impacts of SAM implementation on regulated programs, such as Emergency Preparedness or Operator Licensing programs, will be identified and evaluated as part of subsequent inspections of the affected programs.

03 AUDIT REQUIREMENTS I 03.01 Development and Implementation of Plant-Soecific SAMG l Review the licensees development and implementation W plant-specific SAMG to confirm that:

a. Strategies for dealing with accidents which ext..ad the plant design basis have been identified, and guidance and/or procedures to direct the ERO  !

personnel in implementing these strategies have been provided. l

b. r Ptaticul aids and/or pre-calculated analyses have been provided to assist the ERO in estimating key plant parameters which affect SAM decisions.  !

c. SAM guidance and/or procedures provide an awareness and encourage use of plant instrumentation which is expected to be available and reliable during severe accidents.

03.02 Integration of SAMG with Emeraency Doeratina Procedures and Emeraency Plans Review the manner in which the SAMG has been integrated with the emergency operating procedures (EOPs) and emergency plan (E-Plan) to confirm that:

a. Responsibilities for evaluating, authorizing. and implementing SAM strategies have been delineated within the E-Plan and the ERO position descriptions.

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b. The transition from the E0Ps to the SAMG is clear and will not adversely affect emergency response actions.

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c. Changes made to the E0Ps and the E-Plan to incorporate the SAMG were

, reviewed in accordance with site procedures.

03.03 Incorporation of Severe Accident Information Into ERO Trainina Review ERO personnel training to verify that:

a. Severe accident management training has been developed implemented, and maintained, using a systems approach to training.

b. severe accident management training has been provided to all ERO personnel with responsibilities as evaluators, decision makers, or implementors for severe accident management.

03.04 Maintenance of SAM Capabilities Review the licensee's administrative arocedures for maintaining its SAM capabilities to confirm that these incluce:

a. A commitment to perform periodic SAM training, and SAM table-top and/or inter-facility mini-1 rills.

b. A mechanism for ider tifying. evaluating, and incorporating new severe accident information.

03.05 Evaluation of Licensee Performance Durina Drills Evaluate the licensee's use of SAM drills to confirm that:

a. Drill Scenario Evaluation. The drill scenario provides an opportunity to exercise multiple SAM strategies, and the supporting drill scenario package is complete.

b. Drill Performance Evaluation. Licensee staff in the ERO (cont,al room.

and Technical Support Center) demonstrate the ability to effectively implement the SAMG during the drill.

< c. Drill Critioue Evaluation. The licensee's drill critique is rigorous and objective, and a mechanism is in place to address dri11 findings.

04 AUDIT GUIDANCE General The audit will consist of two parts: (1) a review of the actions taken by licensees to evaluate. enhance, and maintain the capabilities of the ERO to l respond to potential severe accidents, and the results achieved, and (2) an )

l evaluation of the licensee's ability to effectively implement their plant-  !

specific SAMG. as demonstrated during a SAM-oriented drill.

The formal industry position to which the nuclear industry has committed recommends a SAM closure process consisting of four major steps:

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1. Development and implementation of plant-specific SAMG. l

2. Integration of the SAMG with the E0Ps and E-Plan. l

3. Incorporation of severe accident information into training programs.

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4. Maintenance of SAM capabilities.

Guidance relating to each of the four major steps of the closure process is -

provided in Sections 04.01 through 04.04 below. The overall objective of the process / documentation review is to confirm that each of these steps. as well as the associated " severe accident management impleme... ting elements" provided in Section 5.3 of NEI 91-04 have been addressed.

Guidance relating to the evaluation of licensee performance during the SAM drill is provided in Section 04 05 below. The performance evaluation includes: review of the drill scenario, observation of licensee activities in the control room and the Technical Support Center (TSC). and evaluation of the licensee's drill critique. The focus of the performance evaluation is on the ability of the team in the particular ERO facility to implement the SAMG. rather than on an individual's abilities to perform specific duties.

Soecific Guidance 04.01 Development and Implementation of Plant-Soecific SAMG. The formal industry position calls for licensees to develop and implement 31 ant-specific SAMG for important accidents based on evaluation of industry-deve'oped technical bases and Owners Group SAMG. IPE and IPEEE insights, plant-spedfic capabilities, and other generic and plant-specific information (Section 5.2 of NEI 94-01).

Specific guidance is provided in Sections 5.3.1. 5.3.3. and 5.3.4 of NEI 94-01.

Revision 1. It is expected that auditors will review the licensees development and implementation of plant-specific SAMG to determine that these commitments have been met,

a. Confirm that strategies for dealing with accidents which exceed the plant design basis have been identified, and guidance and/or procedures to direct the ERO personnel in implementing these strategies have been provided. This can be demonstrated through completion of each of the following actions:

1. The licensee has developed and implemented plant-specific SAMG based on the generic guidance developed by their respective owners group.

The BWR SAMG is comprised of the Severe Accident Guidelines (SAG) portion of the BWROG Emergency Procedure and Severe Accident Guidelines, together with the Technical Support Guidelines (TSG).

The auditor should note any major variations from the owners group guidance and review the licensee's documentation for the deviations.

For PWRs. the SAMG is expected to be implemented in the TSC for use by designated members of the engineering staff. For BWRs. the SAMG can be implemented either in the control room for use by operators or in the TSC for use by designated members of the engineering staff.

The default location is the control room, however, responsibility for all or part of the SAMG can be relocated to the TSC using the BWROG Placement Criteria described in Section 5 of the BWROG Accident Management Guidelines Overview Document (Attachment B to this audit instruction). For BWR sites that have implemented all or part of the SAMG in the TSC, a technical evaluation justifying this relocation should be performed and documented by the licensee. The auditor i should review the licensee's supporting evaluation and confirm that the deterministic, mechanistic, and risk significance criteria set forth in the Overview Document have been addressed, and that the 07/30/98

relocation is reasonable and would not adversely impact emergency l, response capabilities.

l The licensee's SAMG review and validation process should include internal review by emergency preparedness, operations, engineering, and training departments, and resolution of comments generated from SAM training and drills. External peer review is desirable, but is not required. SAMG is considered to be outside a plant's design and licensing basis, and should not be considered safety-related or subject to Appendix B requirements, unless the guidance scope is not exclusively limited to severe accident mitigation.

2. The licensee has performed a systematic examination of the insights from the plant-specific risk assessment study (including IPE and IPEEE) to determine the need to incorporate additional strategies and guidance in the plant-specific SAMG. Additional strategies or guidance identified through the evaluation have been incorporated in the plant-specific SAMG. Examples of relevant insights include: (1) insights or issues identified in the IPE submittal as areas to be addressed as part of SAM implementation. (2) plant-specific SAM strategies or recovery actions important to reducing the frequency of core damage or large releases that are not included in the generic SAMG. (3) unique system alignments or cross-connections for accomplishing a SAM strategy, and (4) plant-specific information related to accident progression (such as unique containment failure modes and locations). The auditor should consult with the SRA prior to the audit to identify plant-specific insights or licensee commitments relevant to SAM. The systematic process for evaluating SAM capabilities that is described in NUMARC 92-01 is a useful tool for confirming SAM capabilities, but its use by licensees is l optional.

3. The accident management strategies described in Generic Letter 88-20.

Sup)lement 2 and NUREG/CR-5474 have been evaluated, and incorporated witlin the SAMG where such strategies are viable. In general, the owners group for each reactor design attempted to address these strategies in the generic SAMG. but the applicability of the strategies should be addressed at a plant-specific level by each licensee.

4. The licensee has developed procedures to facilitate or expedite the implementation of those SAM strategies for which pre-existing procedures are judged necessary in order to effectively implement the strategy. Since most of the actions and hardware mani)ulations recuired to imalement SAM strategies are already covered )y normal anc abnormal plant procedures, additional procedures specific to SAM are expected to be limited. A good licensee practice in this area is to compile SAM strategies developed during previous drills and exercises for future reference. Such strategies and information (e.g. alternative system alignments) need not be proceduralized in 4 advance if sufficient time and resources are expected to be available l to evaluate the information on-the-fly prior to implementation during an event.

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5. The licensee has taken appropriate preparatory measures, such as l constructing and pre-staging cables, adapters, jumpers, and spool l pieces, to minimize implementation uncertainties. delays, and 07/30/98

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potential adverse effects of certain strategies. Critical resources and procedures to implement strategies should be identified and reasonably available, but in general, equipment need not be -

prestaged. Strategies that warrant pre-staging of equipment would generally be limited to actions for which credit has been taken in the plant-specific risk assessment study.

b. Confirm that the licensee has developed and implemented plant-specific computational aids and/or pre-calculated analyses to assist the ERO in estimating key plant parameters which affect implementation of the SAMG and SAM decisions. This can be demonstrated through completion of the following actions:

1. The licensee has provided computational aids and/or pre-calculated analyses as necessary to support the plant-specific implementation of the SAMG. The necessary computational aids are identified in the generic SAMG. and should be modified by the licensee to reflect plant-specific considerations. The tools may enable estimation of ach parameters as reactor coolant system and containment leak rates, remaining time to key events, and the flammability /detonability of hydrogen. These tools may be in the form of tables, charts, system dependency matrices, a compendium of severe accident analyses, guidance on detecting reactor pressure vessel breach, a compilation of plant-specific design information. Computer programs or fast-running severe accident analysis codes may be provided by the licensees but are not required.

2. All resources external to the tools have been identified and made available. Resources may include instrumentation inputs and technical references.

c. Confirm that SAM guidance and procedures are structured to rely on plant instrumentation which is expected to be available and reliable during severe accidents. This can be demonstrated through completion of the following actions as part of the SAMG implementation process:

1. The licensee has identified: (1) the information needed to assess plant status, and select, implement, and monitor each SAM strategy.

and (2) plant-specific instrumentation for sup31ying the needed information, taking into consideration the availa)ility and surviv-ability of the instruments and their support systems during the sequences in which they would be needed. Information needs may be met by direct measurements, indirect (inferred) measurements, parameter trending, or computational aids.

2. The plant-specific SAM guidance and procedures were developed consistent with the above assessment, and include guidance on how and where critical parameters required for SAMG implementation should be obtained (e.g., specific instrumentation or calculational aids are called out).

3. The licensee has provided guidance to the ERO on interpreting instrumentation outputs during severe accidents and using alternative means of providing the necessary information. In general only a limited number of ERO staff are qualified to interpret instrumentation outputs during an accident. These positions should be identified and receive special training in this regard.

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04.02 Intearatign_pf SAMG with Emeraency Doeratina Procedures and Emen r.rsy

, Plans The formal industry position calls for licensees to: (1) interface the SAMG with the plant's E-Plan (Section 5.2). (2) delineate responsibilities for authorizing and implementing SAM strategies within the E-Plan and the ERO personnel task descriptions (Section 5.3.5). and (3) upon creation of the plant-l specific SAMG. perform an initial evaluation to ensure the material has been

! integrated into the emergency response organizatim without adversely affecting emergency response capability (Section 5.3.6). It is expected that auditors will evaluate the process used by the licensee to integrate the SAMG with the E0Ps and l E-Plan to confirm that these commitments have been met.

2. Confirm that the licensee has appropriately interfaced the SAMG with the E-Plan. The SAMG may be implemented as a stand-alone document separate from the E-Plan and emergency plan implementing procedures (EPIPs), but could alternatively be implemented in the form of severe accident EPIPs.

Either approach is acceptable. Responsibilities for evaluating, authorizing, and implementing SAM strategies should be delineated within the E-Plan and EPIPs. In general, the responsibility for SAM i decisionmaking will transfer from the control room (e.g. . the senior licensed operator) to the TSC (e.g., the emergency director) concurrent {

with or shortly following entry into the SAMG. The exception is BWR 1 plants which implement the SAMG in the control room (the default approach for BWRs). The plant-specific approach to transfer of responsibility i should be clearly identified in the E-Plan. )

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b. Confirm that the SAMG has been integrated with the E0Ps such that any

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transition from the E0Ps to the SAMG is clear and will not adversely affect emergency response actions. The approach for transitioning from '

the E0Ps to the SAMG differs among the various owners group, and is described further in the respective SAMG technical basis document. In general. operators at Westinghouse ]lants will exit the E0Ps and enter the Severe Accident Control Room Guide'ines (SACRG). Operators at B&W plants will also exit the E0Ps. but are not provided any follow-on guidance such as SACRG. Operators at BWRs will exit the EPG portion of the guidance and enter the SAG portion. In contrast, operators at CE plants will remain in the E0Ps. For CE plants. the auditor should confirm that the licensee has identified those areas where the guidance provided in the E0Ps may conflict with the guidance provided in SAMG. and included this information in the SAM-related training provided to the ERO.

c. Confirm that the changes made to the E0Ps and the E-Plan were reviewed in accordance with site procedures and that any evaluations required by 10 CFR 50.59 and 50.54(q) were performed. For PWRs. changes to strategies and procedures that are only applicable for mitigation of damaged core conditions do not require a 50.59 evaluation. However, a screening should be performed to assure that there are no SAMG-related changes that affect hardware or procedures within the scope of 50.59. For BWRs. changes to current E0Ps due to implementation of the EP/ SAG should be made in accordance with 50.59 to the extent that 50.59 is applicable. In general.

50.59 is considered applicable to changes related to implementation of the EPG section of the EP/ SAG, as well as those portions of the SAG that could be entered in response to licensing basis accidents (e.g., large break LOCAs in certain BWR plants). 10 CFR 50.59 is considered not applicable j to the SAG section of the EP/ SAG (with the previous exception) or to the l TSG. However, a screening review of all EP/ SAG-related changes to plant hardware and procedures should be performed to ensure that they do not affect the licensing basis as reflected in the FSAR.

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If E0Ps are modified, these changes should be validated. More detailed guidance- on evaluating changes to E0Ps is provided in IP 42001-02 -

" Emergency Operating Procedures."

d. Confirm that the licensee performed an initial evaluation to verity that the SAMG has been effectively integrated into the ERO. The evaluation should include an inter-facility drill with full ERO staffing and should demonstrate that the SAMG implementation does not adversely impact the effectiveness of the E-Plan, and that ERO staffing is adequate to handle

' the additional SAM responsibilities.

04.03 Jncorocration of severe accident information into trainina oroarams. The l formal industry position -(Section 5.3.2) states that: (1) severe accident training should be provided for ERO personnel commensurate with their responsi-bilities defined in the E-Plan, and (2) suggested learning objectives and related training materials will be developed using a systematic approach to training. i It is expegted that auditors will evaluate the licensee's training programs to confirm that the licensee has implemented SAM training consistent with the l systems approach to training (SAT)1 The SAT process consists of the following key elements: (1) analysis of job performance requirements and training needs, (2) develo) ment of learning objectives based upon the preceding analysis. (3) ,

i design anc . implementation of the training program based upon the learning objectives- (4) trainee evaluation, and (5) program evaluation and revision based upon the preceding evaluations.

The auditor should verify that the licensee has:  !

a. conducted a training needs analysis for all personnel with responsibility ,

for response to severe accident management. These personnel should include: (1) personnel responsible for assessing plant symptoms in order to determine the plant damage condition (s) and potential strategies that may be used to mitigate an event (evaluators), (2) personnel responsible for assessing and selecting the strategies to be implemented (decision i makers), and (3) personnel responsible for performing those steps necessary to accomplish the objectives of the strategies (implementors).

A detailed job and task analysis is not necessary but the licensee should ,

be able to demonstrate that a systematic assessment of' severe accident  !

1 management tasks was- conducted as a basis for developing learning j objectives and for differentiating between tasks for initial and  ;

continuing training 2 The licensee may base the training needs analysis d on generic analyses or tasks lists In such cases the auditor should verify that the licensee has evaluated the applicability of the generic l product to the site and modified the generic analysis as necessary to ,

address any inconsistencies and site specific severe accident management I tasks. 3 i 1

' Letter from G. Holahan, U.S. Nuclear Regulatory Commission, to D. Modeen, Nuclear Energy Institute, January 28,1998.

2 Letter from A. Thadani, U.S. Nuclear Regulatory Commission, to R. Pinelli, Nuclear Energy Institute, August 1,1995.

Letter from S. Collins, U.S. Nuclear Regulatory Commission, to R. Beedle, Nuclear Energy Institute, June 25,1998.

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2, developed learning objectives that are based upon the preceding analysis

' and that reflect the job performance conditions and requirements which can be anticipated for a severe accident.

3. designed and implemented training for SAM using methods that are appropriate for the content and learning objectives and that have been proven successful with similar materials. For example. table-top exercises and/or inter-facility mini-drills are appropriate for the

. development of skills and abilities that will be required in dynamic interactive job conditions. The auditor should verify that all personnel requiring severe accident training have received, or are schedule for.

severe accident training, consistent with the licensee's training plan.

4. has established a schedule for regularly evaluating trainee performance, provides remediation when appropriate, and provides continuing training that contains performance requirements for difficult, important, or infrequent tasks.

5. established a formal mechanism to evaluate and revise the training program. as necessary, in response to trainee performance and critiques, and to assure that it continues to reflect a current state of knowledge regarding severe accidents.

Detailed guidance for the evaluation of the systems approach to training is provided in NUREG-1220. Revision 1. " Training Review Criteria and Procedures."

i b. The auditor should review a sample of training records to verify that personnel with responsibilities as severe accident decision makers.

, evaluators, or implementors have received training appropriate for their

responsibilities.

04.04 Maintenance of SAM capabilities. The formal industry position states that licensees should: (1) utilize period table-top and/or interfacility mini-drills for the purposes of training, and evaluating and improving in-plant response capabilities (Section 5.2). and (2) establish a means to consider and possibly adopt new severe accident information from licensee self-assessments, applicable NRC generic communications, and PRA studies (Section 5.3.6). It is expected that auditors will evaluate licensee's administrative procedures for maintaining in-plant response capabilities.

Confirm that the licensee's administrative procedures contain the following:

a. A commitment to perform refresher training and conduct SAM drills on a periodic basis, with the objective of testing and evaluating the in-plant SAM response capability. Important aspects of such drills include: use of scenarios which challenge the technical staff's abilities. use of a drill critique to identify strengths and areas for improvement, and technical assessment of promising preventive and mitigative measures ,

identified during the drills as part of a longer term follow-up. The j auditor should review training schedules and attendance records for  !

previous classroom training sessions and SAM drills to confirm that  !

licensee personnel designated as SAM evaluators, decisionmakers, and I implementors have received training and participated in drills consistent )

with their responsibilities in these roles, and on the schedules l established by the licensee.

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b. A formal mechanism for identifying. evaluating, and incorporating nsw information from ongoing industry or NRC research programs, and feedback and lessons learned from staff training and SAM drills. The auditor -

should survey licensee records of feedback received from classroom training sessions and SAM drill critiques, and confirm that corrective actions and/or program modi fications were made or scheduled as i appropriate.

04.05 Evaluation of Licensee Performance Durina Drills. The formal industry position (Section 5.3.6) states that pcriodic tdble-top and/or inter-facility mini-drills should be utilized to ensure that ERO personnel are familiar with the use of the SAMG and with the interfaces and delineation of responsibilities between ERO facilities during SAMG use. These activities should include exercising of pieventive or mitigative measures as well as appropriate critiques immediately following the drill to capture lessons learned.

It is expected that auditors will evaluate activities in the control room and TSC during a drill. The focus of these evaluations is on the ability of the licensee team in the particular facility to implement the SAMG. rather than on an individual's abilities to perform specific duties. In each of these facilities the following activities may be evaluated:

1. Facility manning and control.

2. Communications and information flow between facilities.

3. Assessment of plant conditions. and challenges to fission product barriers.

4. Decisionmaking process.

5. Availability and useability of guidance, computational aides, procedures, and equipment needed to perform duties.

Interviews of licensee staff should be used, as appropriate. to clarify initial perceptions of drill performance, identify underlying reasons for performance, and add credibility to findings presented to utility management at the exit meeting. The auditor should also survey available licensee records from previous SAM drills to reinforce observations regarding the licensee's drill scenario and drill critique.

a. Drill Scenario Evaluation. In advance of the drill, obtain a copy of the dril scenario and determine whether the drill scenario provides: (1) failures of equipment and critical functions that require entry into SAMG, (2) failure or challenge of multiple fis.sion product barriers to include or result in severe cladding failure and potential for large offsite release of fission products. (3) an anticipated time period of SAMG use sufficient in duration to present opportunities to exercise multiple strategies. The scenario package should include a detailed time-line. and should identify: scenario success paths. SAM strategies expected to be evaluated, recommended, and implemented by the ERO. and the licensee's criteria for evaluating drill performance.

b. Drill Performance Evaluation

1. Control Room Evaluation. Observe the control room staff's abilities in the following areas:

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(a) Transitioning from the E0Ps to the SAMG. Depending on the site l.

specific implementation this may involve exiting the E0Ps and taking direction directly from the TSC. Ensure that the

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licensee's . declaration regarding applicability of 10 CFR i

50.54(x) and (y) and notification of NRC pursuant to 1; CFR 50.72 (b)(1)(ii)(c) are indice ' or simulated at appropriate points in the drills. NRC's position on this issue is provided i in an NRC letter to NEI dated January 28. 1998. Note any di fficulties in the transition process. and conflicts or inconsistencies between the E0Ps and the SAMG in terms of the directions or priorities provided to operators.

(b) Useability of the SAMG. including implementing the E-Plan in 3arallel with the SAMG. Note any conflicts or inconsistencies l Jetween the E-Plan and SAMG. and the impact of the SAMG on the o)erator's workload and ability to execute the E-Plan. Confirm t1at the implementation of SAMG does not overburden the control room staff such that the required emergency planning activities

! cannot be performed.

(c) Communicating with and providing information and data to the TSC and the Operations Support Center (OSC) during the drill, and taking direction from outside the control room.

l (d) Implementing those portions of SAM strategies executed from the control room. including any that may require implementation before the TSC is functional.

2. Technical Suooort Center Evaluation. Observe the TSC staff's capabilities in the following areas:

(a) Identifying when plant conditions warrant transition from the E0Ps to the SAMG.

(b) Using the SAMG effectively to assess plant status and identify candidate SAM strategies.

l (c) Demonstrating knowledge of severe accident strategies. relevant severe accident phenomena, and downsides or negative conse-quences of strategies.

, (d) Using , computational aids effectively to assist in SAM dec1slonmaking.

(e) Developing sequence-specific procedures to implement selected SAM strategies, and obtaining review and approval of these procedures in a timely manner.

(f) Maintaining effective communication with the control room and OSC during the drill. This includes clear, accurate, and timely communication of: information essential to SAMG implenntation, decisions and direction regarding implementation of SAM strategies, and priorities for recovering failed equipment.

(g) Maintaining oversight of TSC. control room, and OSC staff activities to manage the accident.

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Observe the TSC director's capability to manage the TSC. make decisio'ns regarding strategies to mitigate the accident and provide direction to the -

staff implementing the strategies.

Observe the TSC staff's capabilities to impicment the E-Plan in parallel with the SAMG. Note any conflicts or inconsistencies between the E-Plan and SAMG. and the impact of the SAMG on the TSC staff's work. load and ability to execute the E-Plan. Confirm that the implementation of SAMG does not overburden the TSC staff such that the required emergency planning activities are adversely affected.

c. Drill Criticue Evaluatioq. At the end of a drill, each facility should hold a critique with the controllers and players while the details are fresh. This preliminary critique should be followed by a formal critique that evaluates the overall drill performance and the interaction of facility representatives and players with one another. The licensee's drill critique should be evaluated to determine whether:

1. The drill is evaluated by a team of licensee /uti_lity personnel with

. collective experience in operations, training, emergency prepared-ness severe accident analysis, and familiarity with the plant-specific risk assessment study.

2. The evaluators provide an unbiased and candid evaluation of drill performance, including:

(a) The adequacy of the drill scenario in terms of its realism and technical challenge. This should include consideration of whether the scenario: (1) contains elements of accident sequences (failures of equipment and critical functions) that are importar.t to the plant-specific risk profile. (2) is of sufficient duration and complexity to present opportunities to exercise multiple strategies.

(b) Effectiveness of the ERO personnel in identifying, selecting, and implementing SAM strategies. This should include consideration of whether recovery actions are " played-out" as far as reasonable. For restoration of equipment this might involve obtaining necessary work permits, dosimetry, tools, and procedures, accessing the equipment, and performing or simulating the repairs.

(c) Identification of areas of strength and weakness, as well as areas needing improvement.

3. Corrective actions are defined and scheduled.

OS REPORTING REQUIREMENTS Results of each audit will be documented in a trip report. The report will be provided to NRR/ADT through DSSA. DRPM. and DRCH management.

06 COMPLETION SCHEDULE 07/30/98

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NRC staff will visit approximately four sites in the latter half of 1998 for the

• purpose of evaluating how licensees have implemented SAM. and addressed each of the major steps and " severe accident management implementing elements" set forth in the formal industry position. The audit guidance contained in this document will be used for these visits.

Sites will be selected in cooperation with industry and NEI on a voluntary basis.

07 NRR CONTACT Questions regarding this audit instruction should be addressed to Bcb Palla (301-415-1095) or Jim O'Brien (301-415-2919).

08 STATISTICAL DATA REPORTING A TAC number will be established for purposes of tracking effort expended in performing the accident management audits. These charges will not be fee recoverable.

09 ORIGINATING ORGANIZATION INFORMATION 09.01 Organization Responsibility. The Containment Systems & Severe Accident Branch initiated this audit activity.

09.02 Resource Estimate. Audits of completed SAM implementation will be Jerformed by a four to five member team comprised of NRC Headquarters staff. The 4RC region offices will be informed of the audits and invited to participate at their discretion. The team should include staff with expertise in the following disciplines: emergency preparedness, operations severe accidents and PRA and human performance / training. It is anticipated that evaluation of all aspects of SAM 1 implementation will require approximately 100 staff-hours on-site.

Approximately one day of specialized training will be provided to the team prior to the visits.

10 APPENDICES Attachment A - Section 5 of NEI 91-04. Revision 1. December 1994 Attachment B -

Section 5 of the BWROG Accident Management Guidelines Overview Document, Revision 1.-June 1996 l END l

07/30/98 ATTACHMENT A ~

Excerpt from NEl 91-04 - -

Stvsre Accidant issus Closure Guidslines R: vision 1, D:cember 1994 -

5.0 SEVERE ACCIDJNT MANAGEMENT CLOSURE 5.1 Scope of Severe Accident Management Accident management consists of those actions taken during the course of an accident by the Emergency Response Organization (ERO); specifically plant operations, technical support and plant management staff, in order to:

. Prevent the accident from progressing to core damage;

. Terminate core damage progression once it begins;

. Maintain the capability of the containment as long as possible; and

. Minimize on site and off site releases and their effects.

The latter three actions constitute a subset of accident management referred to as severe accident management, or more speci6cally, severe accident mitigation. Post-TMI a:tions and IPE insights have already addressed most aspects of preventing core damage. The focus of the industry effort is to provide guidance where Emergency Operating Procedures (EOPs) are no longer effective, or revise EOPs if appropriate.

The goal of severe accident management is to enhance the capabilities of the ERO to mitigate severe accidents and prevent or minimize any off-site releases. The objective is to establish core cooling and ensure that any current or immediate threats to the fission product barriers are being managed. To accomplish this the ERO should make full use <

enstmr plant capabilities, including standard and non-standard uses of plant systems and equipment.

Significant interaction among utility, INPO, EPRI, vendor Owners Groups, NRC, and other recognized experts has produced the foundation of actions and plant response from which plant specific severe accident management guidance can be developed (see References 11, 12 and 13). These actions can be categorically divided into elements similar to those described by the NRC in SECYs 88147 and 89-012 (References 3 and 9).

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5.2 Severe Accident Man =nement Closure Process The severe accident management closure process for a given licensee is recommended to consist of the following steps (illustrated in Figure 6):

Evaluate industry developed bases and Owners Group severe accident management guidance (SAMG) along with the plant IPE, IPEEE and current capabilities, to develop severe accident management guidance for accidents ,

found to be important in your plant as screened with the criteria provided in j Section 2.0. Consider other gereric and plant-specific information (e.g., NRC f

and industry studies, PSA results, etc.) as appropriate; l

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. Interface SAMG with the plant's Emergency Plan;

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Incorporate severe accident material into appropriate training programs; and

. Establish a means to consider and possibly adopt new severe accident l

information from licensee self assessments, applicable NRC generic communications, PRA studies, etc.

Because this is an industry initiative, there are no specific regulatory criteria. Rather, industry has defined its goals and objectives by its actions relative to severe accident  !

management. These include, but are not limited to, performance and submittal ofIPE and l 'IPEEE, development of generic (Owners Group) SAMG, and numerous interactions at  !

l various levels among industry, NRC and vendor personnel. The following element descriptions provide a tool that may be used for focusing licensee efforts to enhance their L

capabilities.  !

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_ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . . . . _ _ _ . _ . - . _ . . . _ _ _ _ _ . _ . _ . . _ ._. __ _ . - _ _ _ _ _ _ _ _ . . - _ ._ _ . . _ _ _ _ _ _ . _ _ . _ _______..______i

5.3 Ssvere Accident Management Imniementing Elements 5.3.1 Severe Accident Management Guidance / Strategies for Implementation Guidance is to be provided for use by ERO personnelin assessing plant damage, planning and prioritizing response actions, and implementing strategies that delineate actions inside and outside the control room. Strategies and guidance will be interfaced with the utility EOPs and Emergency Plans.

. The guidance should include: (1) an approach for evaluating plant conditions and challenges to plant safety functions; (2) operational and phenomenological conditions that may influence the decision to implement a strategy, and which will need to be assessed in the context of the actual event; and (3) a basis for prioritizing and selecting appropriate strategies, and approaches for evaluating the effectiveness of the selected actions.

The strategies should make maximum use of existing plant equipment and capabilities, including equipment and alignments that may not be part of the typical" safety related" systems. Critical resources and procedures, if necessary, to implement strategies will be identi6ed and reasonably available, but need not be prestaged. Rather, what is important is a clear delineation of the flow ofinformation, identification of the decisions that have to

' be made, and some up front consideration of the viability ofimplementing the more significant strategies (e.g., not detailed procedures, but a small number oflists that include a description of system lineups, benefits and negative impacts, interlocks to be overridden, special equipment required, etc.).

5.3.2 Training in Severe Accidents

- Severe accident training should be provided for ERO personnel commensurate with their responsibilities defined in the Emergency Plan. In particular, training is recommended for 41

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w. .= -. __ . _ _ .

those speciSc personnel with the following severe accident assessment and mitigation responsibilities:

evaluators responsible for assessing plant symptoms in order to determine the plant damage condition (s) ofinterest and potential strategies that may be utilized to mitigate an event deci=ian ==hars in the ERO designated to assess and select the strategies to be implemented Implementors responsible for performing those steps necessary secomplish the objectives of the strategies (e.g., hands-on control of valves, breakers, controllers, and special equipment)

Existing training programs already address most of the tasks associated with strategy implementation by implementors (e.g., licensed and non-licensed ope: ators, maintenance personnel, radiation protection specialists, etc.). Thus, it is expected that severe accident considerations should be a minor addition to the scope of their training, commensurate with the frequency, importance and difficulty of the potential tasks. The areas of emphasis and level of detailin the implementors training will be different than that provided to the evaluators or decision makers.

Suggested learning objectives and related training materials will be developed using a systematic approach to training and include training techniques proven successful with similar materials. 4 I

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5.3.3 Cornputational Aids for Technical Support ERO personnel should be provided computational aids, as appropriate, in estimating key plant parameters and plant response relative to accident management decisions. The aids should be easy to use and need not be computer based.

5.3.4 Information Needed to Respond to a Spectrum of Severe Accidents "rovide an awareness, and encourage use, ofinstrumentation that is reasonably expected to be available for assessing plant status. The availability and survivability of the information source and the ability of these sources to provide indication of sufficient accuracy for the intended use should be considered. Alternative, indirect means for providing necessary information should also be considered.

5.3.5 Delineation of Decision-Making Responsibilities Ensure responsibilities for authorizing and implementing accident management strategies are delineated as part of the Emergency Plan. The ERO pers.'nnel task descriptions should be modi 6ed to specify responsibilities. Nonetheless, die decision making process needs to be Dexible enough to accommodate situations beyond the scope of currently recognized situations.

5.3.6 Utility Self-Evalt. tion Self-evaluation of the licensee's severe accident response capability is recommended to ensure its feasibility and usefulness. Upon creation of the plant-speci6c SAMG, an initial evaluation should be performed to ensure the material has been integrated into the licensee's emergency response capability without adversely affecting emergency response.

Subsequently, periodic table top and/or inter facility mini drills should be utilized to ensure that ERO personnel are familiar with the use of the SAMGs and with the interfaces 43

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and delineation of responsibilities between EROS during SAMGs use. The objective of the table-top and/or inter facility mini-drills should be training, evaluating and improving the in plant, severe accident management response capability. These activities should include excrcising of preventive or mitigative measures as well as appropriate critiques i immediately following the drill to capture lessons learned (e.g., assess performance and perform a technical assessment of any useful preventive or mitigative measures identified  !

I during drills).

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There is no need for such mini drills to be part of the graded Emergency Plan exercises; in any case, evaluations of severe accident strategy use should e separate from these formal I exercises.

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Figure E Severe Accident Management Closure Process l

l Owners Group SAMG IPE insights .

Utility Evaluation Utility implementation of SAM y of SAM Capabilities Enhancements Severe Accident Training Utility ERO (tasks, nature) (Decision Making)

Guidance 2 Structure Ear; SAM = Severe Act' dent Management SAMG = Severe Acc Jrt Management Guidance ERO = Emergency Reeponee Organization IPE = individual Plant Examination

1. "Jtilize NEl Report 9144 Revision 1 (former1y NUMARC Report 9144) section 2 screening criteria to ass;a. In determimng amount of effort warranted. NUMARC Report 92 01 offers insights as to appropriate attributes for given accidert? management elements.

2. Generic industry task analysis, learnleg objectives and activities and lesson plans will be available.

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l 6.0 REFEIGNCES

1) USNRC. " Integration Plan for Closure of Severe Accident Issues," SECY 88-147, May 25,1988.

2) "Guidehnes for 10 CFR f 50.59 Safety Evaluations," NSAC-125, Final Report, June 1989.

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3) USNRC, " Individual Plant Examination For Severe Accident Vulnerabilities - 10 CFR 50.54(f)," Generic Letter 88-20, November 23,1988.

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4) " Procedural and Submittal Guidance for the Individual Plant Examination of l External Events (IPEEE) for Severe Accident Vulnerabilities," NUREG-1407, Report prepared for Nuclear Regulatory Commission, June 1991. )

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5) Jack R. Benjamin and Associates, Risk Engineering, Inc., Yankee Atomic Electric Company, PLG, Inc., and RPK Structural Mechanics Consulting, " Industry j Approach to Seismic Severe Accident Policy Implementation," Final EPRI Report NP-7498, October 1991.

6) Jack R. Benjamin and Associates, RPK Structural Mechanics Consulting, PLG, Inc.,

I. M. Idriss, and Southern Company Services, " Nuclear Power Plant Seismic i Margin," EPRI NP-6041, Revision 1, July 1991.

7) Jr k R. Benjamin and Associates, and Risk Engineering, Inc., Supplement to j l " Industry Approach to Seismic Severe Accident Policy Resolution: Review Level Ground Motion Assessments for 58 Eastern U.S. Sites," prepared for EPRI, to be published, November 1991.

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8) J. A. Iambright, et. al., " Fire Risk Scoping Study: Investigation of Nuclear Power Plant Fire Risk, including Previously Unaddressed Issues," NUREG/CR 5088, l January,1989.

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l USNRC, " Staff Plans for Accident Management Regulatory and Reseanch 9)

Programs," SECY 8912, January 18,1989.

10) Paul Smith, " Earthquake Safety and Licensing Report,' March 15,1991, Vol. 3,

' No. 3.

11) . NUMARC 92 01, A Process for Evaluatine Accident Manneement Capabilities. April 1992.

12) EPRI Report TR-101869, Severe Accident Manneement Guidance Technical Basis Report. December 1992.

13) NSSS Owners Group-Specific Accident Management Guidance Reports, to be published.

14) USNRC, " Revised Livermore Seismic Hazard Estimates for 69 Nuclear Power Plant Sites East of the Rocky Mountains,"NUREG 1488, October 1993,

15) NEI White Paper, " Justification for Reduction in IPEEE Program Based on Revised LLNL Seismic Hazard Results," forwarded to NRC (Dr. A. Thadani) by NEI letter, April 5,1994.

16) NEI Ietter, " Industry Comments on NRC Workshop and Draft Contractor Reports on Seismic Revisit of the IPEEE," forwarded to NRC (Dr. J. Murphy), November 18, 1994.

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