ML20249C461
| ML20249C461 | |
| Person / Time | |
|---|---|
| Issue date: | 06/25/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Ralph Beedle NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| PROJECT-689 NUDOCS 9806300054 | |
| Download: ML20249C461 (8) | |
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4' f"%4 .. UNITED STATES.
4- E~ NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20565.-0001 June 25,1998 Mr. Ralph E. Beedle L Senior Vice President and Chief Nuclear Officer, Nuclear Generation Nuclear Energy Institute 1776 i Street, NW, Suite 400 l Washington, D.C. 20006-3708
Dear Mr. Beedle:
I am responding to your letter of April 3,' 1998, in which you discussed perceived changes in the expectations of the U.S. Nuclear Regulatory Commission (NRC) for severe accident
- management (SAM) and offered recommendations for facilitating program completion.
Based on a review of your letter and the further clarification we offer in the enclosure to this letter, I do not believe there are major differences in NEl's and NRC's expectations for SAM implementation and closure.' Our observations of the SAM demonstrations gives us confidence
- that the industry is making progress in implementing SAM consistent with the original goals of
_ the program, and should continue to proceed with implementa*!on.
- As' stated in previous correspondence, the NRC remainc committed to the importance of SAM -)
and to this end plans to perform some level of evaluation and oversight to assure that licensees .
implernent and maintain enhancements to severe accident response capabilities in accordance with the formalindustry' position on SAM. The staff had previously characterized these evaluations as inspections against licensee commitments,' but upon further consideration of the voluntary nature of this program, has concluded that such evaluations would more appropriately
- be conducted as audits. The logic for reaching closure that you outlined in your letter is consistent with current staff thinking in this regard.
We plan to finalize guidance for the SAM audits shortly.' NEl can support this next phase by identifying potential pilot pluts. Similar to the SAM demonstrations, the audits would include observation of a SAM drill and review of the licensee's implementation process, but tha audits 4
.would provide additional flexibehty to address implementation issues and drill observations. We
- anticipate that an audit would involve the participation of four NRC staff members on site for three daysc Upon completion of the audits, NRC will hold a public meeting to discuss key findings, as well as the approach for confirming the adequacy of SAM implementation and capabilities in the long term. We plan to continue' our interactions with industry throughout this process and to consider industry views in developing the performance criteria and review
. guidance that will be used for judging SAM implementation.
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Mr. Ralph E. Beedle 2 We appreciate the support for accident management that NEl and the industry have shown to date and look forward to full implementation of this important safety enhancement.
Sincerely, b
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Mkhor Office of Nuclear Reactor Regulation Enc!osure: As stated cc: See next page
! 2 operator license training and evaluation programs. The level of detail and depth of knowledge to be trained on and evaluated would be determined by licensees using the SAT process. For example, through the SAT process tasks are objectively selected for training and evaluation based on such criteria as percent of time incumbents perform a task (to maintain task proficiency) and the consequences of inadequate task performance. Topic areas that may be selected for training and evaluation based on the application of the SAT process to severe accident management could include: transition points from the emergency operating procedures (EOPs) to SAMG; areas in which operator actions based on SAMG may differ from previous training for non-degraded core conditions; transfer of decisionmaking authority and understanding of the chain of command before and after entry into SAMG; knowledge of SAMG objectives, structure, and terminology; understanding of the application of 10 CFR 50.54 (x) and (y) relative to SAMG use; implementation of any SAMG that could be raquired befors activation of the Technical Support Center.
Conduct of 10 CFR 50.59 Evaluations The comments in our previous letter concerning pressurized-water reactor (PWR) SAMG implementation under 10 CFR 50.59 are consistent with the view of the NEl that changes to physical configuration and to existing procedures would require review pursuant to 10 CFR 50.59, on the basis of licensee procedures governing such change processes (as discussed under " Generic Application of 10 CFR 50.59" in the NEl letter of July 22,1997). The evaluation l performed pertains to the physical configuration and procedures associated with " design-basis" operations and not to mitigation of a core damage event. We also agree that changes to strategies and procedures that are only applicable for mitigation of damaged core conditions do not require a 10 CFR 50.59 evaluation in referring to the need for "screersing" in our previous letter, the staff was noting that licensees need to be alert to the possibility that changes to the physical facility or to procedures described in the safety analysis report might Erise in the course of SAM program implementation and, thus, that SAMG strategies are not categorically excluded from possible 10 CFR 60.59 review (as implied by the first sentence under "PWR '
Application of 10 CFR 50.59" in the July 22 NEl letter).
Plant-Scacific Reviews of Generic SAM Trainina Products L
The discussion in Enclosure 1 of the NEl letter indicates agreement that utilities should evaluate
- the applicability of the generic SAM training products to their plants, but contends that additional utility review for adequacy and completeness of these products, as suggested by NRC, is e
unnecessary. The staffs intent in this regard was to caution the industry that the generic training products may not address all site-specific training necessary to support effective SAM implementation. Our concem stems, in part, from a recognition of the divergent approaches taken by the owners groups to develop training materials, and the apparent differences in the scope and content of the resulting products. Although the staff does not consider licensee i review of the adequacy and completeness of the generic training products as a prerequisite to the initial implementation of SAM tdning, we continue to believe that such reviews would provide timely identification of site specific SAM training needs. If a licensee chooses not to
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perform such reviews as part of the development of SAM training, the staff expects that
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subsequent program evaluations, conducted as part of a systems approach to training, would ensure that the site-specific training activities are adequate and complete as developed, or revised as necessary.
Use of NUMARC 92-01 To Evaluate the Acolicability of IPE and IPEEE Insiahts We recognize that the owners groups considered available IPE insights in developing the generic SAMG, and that, pursuant to the formal industry position on accident management, utilities will consider the need to incorporate additional insights in developing the plant-specific SAMG. Our previous comment regarding use of NUMARC 92-01 was not intended to imply that utilities need to use this methodology. Rather, we intended to portray the benefits of using such a methodology in a more favorable light than presented in the earlier NEl letter. The NUMARC 92-01 methodology remains a potentially useful but optional tool for confirming accident management capabilities.
Given the above clarification, we believe that the views expressed in the letter of January 28, 1998, do not represent an escalation of NRC's expectations regarding SAM, or a fundamental diffarence from the NEl guidance. Accordingly, we do not see any reason why utilities should not proceed with implementation pursuant to the NEl guidance and the additional NRC clarification.
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e Mr. Ralph E. Beedle 2 We appreciate the support for accident management that NEl and the industry have shown to date and look forward to full implementation of this important safety enhancement.
Sincerely, 0@d@$
SamuelJ.Comns Samuel J. Collins, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated i cc: See next page
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DISTRIBUTION:
SCollins/FMiragha BBoger BSheron JRoe BTravers i RZimmerman Central Files SCSB r/f (2)
SCSB Action File !
NRR Mailroom
' PMagnanelli(YT0980082)
- See previous concurrences
' DOCUMENT NAME: YT980082.R4 Tm recahre e copy of this document, indicate in the box: 'C' = Copy without attachment / enclosure 'E' = Copy with attschment/ enclosure "N" = No copy OCFICE SCSB:DSSA:NRR l BC:SCSB:DSSA l TECH ED l D:DSSA:NRR l D:DRCH l NAME RPalla:bw CBerlinger BC% GHolahan LSpessard DATE 05/22/98* 05/22/98* T20/98* 06/11/98* 05/28/98*
OFFICE D:DRPM:NRR ADPNR% i /
NAME JRoe- SShpi6ff '" (SCollins ,
DATE 05/05/98*
~
/03/?!f98 06/l5/98 ) / /98 / /98 l OFFIC ECORD COPY
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l Mr. Ralph E. Beedle 2 We appreciate the support for accident management that NEl and the industry have shown to date and look forward to fullimplementation of this important safety enhancement.
Sincerely, l Originalsignedily SamuelJ.ColDns Samuel J. Collins, Director 1 Office of Nuclear Reactor Regulation
Enclosure:
As stated t
l i
cc: See next page i
DISTRIBUTION:
SCollins/FMiraglia BBoger BSheron JRoe BTravers RZimmerman Central Files SCSB r/f (2)
SCSB Action File NRR Mailroom PMagnanelli(YT0980082)
- See previous concurrences DOCUMENT NAME: YT980082.R4 1 . T. ,.e.iv. . copy oe tw. docum.nt. inment. in ih. bo.: c - copy wit %ui set chmentienciosur. E - copy with e:t.cher.ntionciosur. N - No copy l- OFFICE D.DRCH SCSB:DSSA:NRR l BC:SCSB:DSSA l TECH ED l l D:DSSA:NRR l l NAME RPalla:bw CBerlinger BCh GHolahan LSpessard DATE 05/22/98* - 05/22/98* 04/20/98* 06/11/98* 05/28/98*
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OFFICE D:DRPM:NRR ADPNRih _ t D-NAME JRoe ipshp6ff' (Sf2 Tins DATE 05/05/98* [0gf498 06/13/98 / /98 / /98 OFFIC ECORD COPY l
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- Nuclear Energy Institute Project No. 689 cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President _
Plant Support and Chief Nuclear Officer Nuclear Energy Institute
' Nuclear Energy Institute Suite 400 Suite 400 . 1776 l Street, NW 1776 i Str,eet, NW Washington, DC 20006-3708 Washington, DC 20006-3708
. Mr. Alex Marion, Director.
- Prograrns Nuclear Ener0y institute Suite 400 1776 l Street, NW -
- Washington, DC 20006-3708 Mr. David Modeen, Director
- Engineering Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director
- Licensing Nuclear Energy Institute Suite 400 17761 Street, NW i
- Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager-Nuclear Safety _and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation -
- P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations:
Nuclear Energy institute Suita 400 1776 i Street, NW -.
. Washington, DC 20006-3708 ~
- l. -
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- Enclosure I
- Clarification of implementation issues Raised in April 3,1998, NEl Letter 4
The Nuclear Energy Institute (NEI) expressed concern that guidance provided in our letter of
- January 28,1998, appears to represent an escalation in the expectations of the Nuclear
' Regulatory Commission (NRC). Five specific areas were identified:
. i Operator training and evaluation on severe accident management guidance (SAMG)
- Conduct of 10 CFR 50.59 evaluations -l j
- . Plant-specific reviews of generic severe accident management (SAM) training products
. Use of NUMARC 92-01 to evaluate the applicability of individual plant examination (IPE) and individual plant examination of extemal events (IPEEE) insights
. . Reporting completion of SAM implementation On the basis of our review of the NEl letter, we offer the following additional clarification on l these topics. The last item is an area in which we have agreed that all plants should report to. ,
NRC by letter when they have completed SAM implementation and we need no further - .l j
elaboration.'
Ooerator Trainina and Evaluation on SAMG t We acknowledge that our reference, by example, to the level of detail that this evaluation' l l
should focus on - the ability to understand how the actions of the operators comply with the
' intent of the procedure and the effect of these actions on plant and system conditions - may have been misunderstood.' There was no intent to escalate the evaluation component in a ;
manner such that operators would be responsible for, or testeJ on, detailed severe accident phenomena and mitigation strategies that are the responsibility of the SAMG decisionmakers and evaluators.: However, as discussed in our letter of August 1,1995, to the Boiling Water
- Reactor Owners Group, we believe that SAMG is applicable to the licensing of operators and should be addressed by the licensed operator requalifL ation program to the ei snt discus =ed below.' Furthermore, we continue to believe that the evaluation component of the resultant operator training program should address, as appropriate, operator knowledge of SAMG consistent with the operators' responsibilities.
Licensed operator training programs that are using a systems approach to training (SAT), as defined in 10 CFR 55.4, are required to conduct a systematic analysis of the jobs to be performed and to evaluate trainee mastery of the teaming objectives derived from that analysis.-
. Consistent with these requirements, the roles of licensed operators in severe accident management should be systematically analyzed' and addressed in operator and senior
'As discussed in our letter of August 1,1995, to the Boiling Water Reactor Owners Group,
- although the staff does not believe that detailed jot' and task analyses are necessary, the staff expects that a systematic analysis will be conducted to ensure that an ad3quate assessment of training needs has 7 ; been ecAAn piished.