ML20217C292

Summary of 980304 Meeting W/Nuclear Energy Inst in Rockville,Md Re Severe Accident Mgt Guidance.List of Attendees & Agenda Encl

ML20217C292
Person / Time
Issue date:	03/20/1998
From:	Wen P NRC (Affiliation Not Assigned)
To:	Essig T NRC (Affiliation Not Assigned)
References
NUDOCS 9803260411
Download: ML20217C292 (35)

Text

,

March 20 1d98;

^

. MEMORANDUM TO: Thomas H. Essig, Acting Chief Generic lasues and Environmental Proiects Branch Division of Reactor Program Managemer,t Office of Nuclear Reactor Regulation '

- FROM: ' Peter C. Wen, Project Manager Original Signed By:

Generic issues'and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

{

1

SUMMARY

OF MARCH 4,1998, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING SEVERE ACCIDENT

' MANAGEMENT GUIDANCE On March 4,1998, a public meeting was held at the U.S. Nuclear Regulatory Commission's (NRC's) offices in Rockville, Maryland, between representatives of the NRC, NEl and other interested parties. Attachment 1 proyides a list of attendees at the meeting. Attachment 2 is the agenda that was used for the meeting. Attachment 3 is the presentation material provided by NEl for the meeting and a compilation of background information that was referenced in NEl's presentation.

1 During the meeting, the NRC staff and NEl and utility representatives discussed industry's

views on the staff's January 28,1998 letter regarding severe accident management implementation issues. The general industry concern is that NRC appears to be reversing ,

some previously understood positions, escalating its expectations as to adequacy of industry I implementation, and focussing on details rather than overall performance. The staff positions on licensed operator training / evaluation, use of a systematic approach to training, and application of 10CFR50.59 seem to be of greatest concem to industry. The NEl representative claimed that the NRC positions in the January 28 letter would cause significant impacts on work done to date and in progress. He further stated that the industry intends to complete implementation in accordance with the previous guidance provided in NEl 91-04 and in the July 1 22,1997 NEl letter, and that this represents more than adequate fulfillment of the industry's  !

commitment regarding accident management. The staff indicated that it would further evaluate the information provided by NEl, elevate and discuss the key issues with NRC management, f

and provide a response to NEl.

//

Attachments: As stated / I cc w/att: See next page r@3 DISTRIBUTION: See attached page OFFICE- PM:PGEB 'SCSB - SC:PGEB9,gw NAME PWen:swpcd RPallaM FAkstulewiliU DATE 3/jf /98 3/ fl/98 OFFICAL OFFICE COPYs 3/W/98 gh gg '

, ,wycd fM3 i NRC IW CRTE COPY 9803260411 980320 PDR REVGP ERONUMRC PDR .

L 1

a pm44 9

.. g t UNITED STATES g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30886 4001

.,g March 20, 1998 MEMORANDUM TO: Thomas H. Essig, Acting Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM: Peter C. Wen, Project Manager &0 hb-./

Generic issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF MARCH 4,1996, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING SEVERE ACCIDENT MANAGEMENT GUIDANCE On March 4,1998, a public meeting was held at the U.S. Nuclear Regulatory Commission's (NRC's) offices in Rockville, Maryland, between representatives of the NRC, NEl and other interested parties. Attachment 1 provides a list of attendees at the meeting. Attachment 2 is the agenda that was used for the meeting. Attachment 3 is the presentation material provided by NEl for the mee*ing and a compilation of background information that was referenced in NEl's presentation.

During the meeting, the NRC staff and NEl and utility representatives discussed industry's views on the staffs January 28,1998 letter regarding severe accident management implementation issues.. The general industry concem is that NRC appears to be reversing some previously understood positions, escalating its expectations as to adequacy of industry

. implementation, and focussing on details rather than overall performana. The staff positions

' on licensed operator training / evaluation, use of a systematic approach to training, and

- application of 10CFR50.59 seem to be of greatest concem to industry. The NEl representative

~

claimed that the NRC positions in the January 28 letter would cause significant impacts on work

. done to date and in progress. > He further stated that the industry intends to complete implementation in accordance with the previous guidance provided in NEl 91-04 and in the July i 22i 1997 NEl letter, and that this represents more than adequate fulfillment of the industry's l

commitment regarding accident management. The staff indicated that it would further evaluate j the information provided by NEl,' elevate and discuss the key issues with NRC management,  !

, and provide a response to NEl.

l

. Attachments: As stated l

cc w/att: See next page '

)

- 1 NRC/NEl MEETING ON SEVERE ACCIDENT MANAGEMENT IMPLEMENTATION LIST OF ATTENDEES March 4,1998 l

l NAME ORGANIZATION Fred Emerson NEl Larry Walsh _ NAESCo Howard Crawford GPUN/B&WOG

' Bill Berg PSE&G/BWROG Bob Lutz Westinghouse /WOG Lawrence Wild ABB/CEOG l Wayne Russell Entergy/BWROG Mike Ruby RG&E P.M. Abraham Duke Power  ;

Jim Foiford NUS Information Services l Althela Wyche SERCH/Bechtel Scott Newberry NRC/NRR/DSSA l Bob Palla NRC/NRR/DSSA  !

George Thomas NRC/NRR/DSSA Jim O'Brien NRC/NRR/DRPM Eileen McKenna NRC/NRR/DRPM Peter Wen NRC/NRR/DRPM ,

Robert Latta NRC/NRR/DRCH Juan Peralta NRC/NRR/DRCH Robert Gramm NRC/NRR/DRCH David Desaulniers NRC/NRR/DRCH John Munro NRC/NRR/DRCH  ;

Sud Basu NRC/RES/ DST i Attachment 1

i .

2 PROPOSED AGENDA NRC / Industry Meeting on Severe Accident Management implementation March 4,1998 8:30 Introductions; purpose and goals for meeting i

8:40 industry perspective on purpose of SAM implementation 8:50 Systematic approach to training Operator training and evaluation I

9:30 Application of 10 CFR 50.59 to SAM implementation I Applicability of " safety related" and Appendix B Decisionmaking and application of 10 CFR 50.54(x) and (y) 10:00 Inspections versus monitoring of self-assessments Use of NUMARC 92-01 and IPE insights implementation closure 10:20 Summary of areas of agreement and resolution pathways l

1 10:30 Adjoum 1

f t

Attachment 2

v r .

'(.

I Severe Accident Management implementation issues NRC / Industry Meeting March 4,1998

't

l Topics a Background' perspective e Industry view ofissues in January letter

'/

e Industry plans for closure QEI I

Background

e Agreement with h1C that SAM is supposed to be a relatively low-cost enhancement to existing emergency response capabilities

. Addnional tools for ERO e Use of exisung plant capabilnies e Agreement with NRC in 1994 that SAM should be implemented through an industry initiative QEI

('

1 Attachment 3

?O

)

Background

e Almost 10 years of extensive industry effort

. EPRI technical basis report

. NE19144

. Owners' Group SAMG products

. INPO training products

. Owncts' group maining products

. Three NEI and numerous Owners Group workshops

. Couplms with IPE/IPEEE efTorts -

. All plants implementmg. more than a dozen have completed g l

Background

e Extensive interactions with NRC staff and integration of NRC views into industry products

.),

gri 1

Clarifications Provided

. After NEl workshop in March 1997, hTl (at utility request) provided additional implementing guidance to utilities in July

. Effort was made to reflect known NRC positions e These clarifications provided to NRC for information in July 1997 i

e NRC resp %4 provided January 28,1998 QEI 2

a ,

C l

GeneralIndustry Concerns e At this very late stage in the implementation process, NRE is apparently:

. Reversing some previously understood NRC positions, including those related to cost

. Escalating fu expectations as to adequacy of implementation by andustry

. Focusing on details rather than overall(mdustry and utility) performance m this unregulated area

. Not recognizing the relative priorny of SAM among activipes supporung safe plant operanons QEI I

Issues Raised by NRC e 10 CFR 50.59 application e Decisionmaking! application of 50.54(x)& (y)

, e Operator training and evaluation

( e Inspections vs. monitoring of self assessments e Application of systematic approach to training e Applicability of" safety related"& Appendix B e Use of NUMARC 92-01 & IPE insights e SAMissueclosure QEI I

10 CFR 50.59 (PWR) e Existing plant procedures for 50.59 cvaluations will apply to SAMG implementation

. Agree with considering 50.59 applicability to:

. Changes to hardware or existmg procedurn

. Evoluuona involving a second operating urut e For ruidance beyond core damage,50.59 or screening cannot be done QEI

(

l 3

a 3 .

I 1

I i

10 CFR 50.59 (BWR) i e Existing plcnt procedures for 50.59 evaluations will apply to EPG/ SAG implementation i

e Guidance in July letter will be applied t I

j grs .  ;

4 i

I i Decision-making i e SAMG does nelinvolve a change from current practice

. E-Plan governs in both cases

. $ame decision-making responsituhty in SA space as DB space '}

.j

. Only change - enhanced tools available to decision-maker i

e Command and control already clearly identified l 4

and process tested '

YEI l l

i 10 CFR 50.54 (x) and (y) i e Industry comfortable with position in July letter

. $0.54(x) declaration not necessary if SAMO implemerned under 50.59 e Emergency Directors should have the option to declare 50.54 (x) at their discretion l e Reporting requirements will be met  !

QEI J

i 4

l i

\  !

I j

4 m

( l Operator Training / Evaluation e Industry cone.ctn about operator burden shared with staff on many occasions a NRC position in fanuary 28 letter in direct conflict with earlier position:

. Detailed questions on specific mitigation strategies and guidelmes are not anticipated."

e Exact plant response to strategies not known e Never intended that operators be responsible for detailed SAMG knowledge gg I

Inspections a Understand that NRC expects to conduct inspections e Monitoring of self-assessments is just as efrective

. Agrees with 1994 NRC statement that "Our intent is to rely on utthty self-evaluation ..rather than toutine staff audits'mspecuens ."

. Better use of NRC and bcensee resources gri l

Systematic Approach to Training e SAMG training is ERO training '

e ERO training not under Systems Approach to Training (SAT) e Systematic approach (sat) used by industry similar to ,

SAT s No need to formally evaluate adequacy / completeness of training other than through performance e " sat" more applicable because it provides good direction but not the definitive answers required in SAT TEI

[

e a

l l

Simulator Use e Use of simulator to initiate utility SAMG drill should be at plant option

. Not all utilities have luxury of sufUcient simulator time -

for SAMG drilbraining inruation

. No value added by static use of simulators

. No upgrade of simulators to reflect severe accident conditions e Use for SAMG may result in negative gg tratnmg i

Safety Related / Appendix B e 10 CFR 100 for design of plant, not for limits during emergency conditions e Appendix B should not apply to SAMG changes that do not impact ability of safety-related SSC ~)

to mitigate design basis accidents

. Agree with NRC that plam procedures that only afrect SSC operata durmg SA mitigation are not safety related grI I

Use of NEl 92-01 e Utilities have systematically incorporated IPE / >

IPEEE insights without the use of NEl 92-01 l

e NEl 92-01 may be useful but is not necessary for utilities using Owners Group SAMGs QEI

_)

6 1

(

l SAM issue Closure e Closure of utility commitment should be handled in concert with existing licensing practice QEI i

industry Direction e Complete implementation by carrying out NE191-04 and supplemental guidance r . This represents more than adequate fulfillment of 1994 SAh! rmplemenution goals QEI I

Summary .

e Industry is very close to achieving its 1994 i goals for SAM implementation e Apparent NRC positions in January 28 letter would cause significant impacts on work done to date and in progress e Need to focus on licensee performance, not detailed methods ,

o Plan to complete implementation IAW stated industry positions and close issue on schedule

)

QEI

(

l 7

l

. , Mr. David Modeen Nucle:r Energy Institut3 January 28, 1998

"~ 1776 l Street NW Suite 400 Washington, DC 20006-3708 f

Project Number: 689

{

Dear Mr. Modeen:

Your letter of July 22,1997, transmitted clarifications of a number of issues raised by utility staff as they implement severe accident management. Although NRC comments were not requested, we consider a response appropriate, given the issues involved and their impact on j utility implementation i Overall, the clarification offered in the letter is generally consistent with NRC staff views and ,

should aid in the utility implementation process There are several areas where we either do not agree with the clarification provided, or feel that additional clarification is warranted. Our comments and views in these areas are provided in the enclosure to this letter.

In your letter you indicated an intent to incerporete the clarifying guidance into a future revision of NEl 91-04, " Severe Accident issue Closure Guidelines." Because of the numerous changes suggested by our comments, we recommend that the guidance be reconci!sd with the v.omments prior to revising the NEl report. If you consider it worthwhile, we can arrange a meeting with the appropriate NRC staff to discuss these issues further.

If you have any questions, please contact Robert Palla at (301) 415-1095.

Sincerely, Original signed by:

Gary M. Holahan, Director Division of Systems Fafety and Analysis Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page 9

i j

?

Enclosure NRC Staff Views on Clarifications Contained in NEl's July 22,1997 Letter on Severe Accident Management Application of 10 CFR 50.69 to SAM imit ..e.;i-ik .

PWR A --L-d--i of 10 CFR 50 59 NEl states that no screening review or Unreviewed Safety Question (USQ) analysis is necessary for PWR plants to implement Severe Accdont Management Guidelmes (SAMG) since PWR SAMG covers a regime outside the plant's Technical Spadh;;ees and FSAR and therefore cannot involve a USQ.

Although we do not expect that PWR SAMG implementaten would generally involve a USQ or require a

$50.59 evaluation, there may be SAMG-related hardware or procedure changes hvolving or affectmg hardware or procedures within the scope of $50.59. Such changes will req > ire the $50.59 evaluation Examples of such changes are provided in the NEl discussion on Applicability of" Safety Related" and Appendix B to SAM Implementation, and illustrate the need to evaluate hardware and procedure changes for theirimpact Also, severe accident guidelines that involve cross-ties to a second, non-affected unit would warrant an evaluaton for impacts on the second unit. Given the potential for SAMG-related changes to affect hardward or procedures within the scope of $50.59, we believe that a screening review must be performed as part of SAMG implementation for PWRs.

BWR ALsL2.en of 10 CFR 50.59 The staff agrees with the NEl discussion on BWR applicebon of 10 CFR 50.59, but believes that additional guidance is needed to address those situations where the Severe Accident Guidelines may be entered ,

during design basis events. Staff views are provided below. I The BWROG Emergency Procedure and Severe Accident Guidelines (EP/ SAG) contain an Emergency Procedure Guideline (EPG) secbon and a separate Mre Accident Guideline (SAG) section. The former is essentially EPG Rev. 4, with cha .gv to address. M resolution of DBA-related issues, some of which were reviewed by NRC (e.g., chanps os to therms, hydraulic stability concems) and others which were not, (2) actions within the EPG scopt identAc. cdj development of severe accdent guidance, and (3) relocation of certain actions to the LM secton. The latter includes some material that was previously in EPG Rev. 4, and supplementary guidanw ior sev,re accidents. The transition between the two sets of guidelines is generally "w onset of a severe acddent, t;ut as s. sted in the BWROG Accdent Management Guidelines Overview Document, it is believed that the licensing basis DBA LOCA can produce conditions that require entry into the SAG, even though the event will not result in core damage i i

4 Changes to the current Emergency Operating Procedures (EOPs) 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 j those portions of the SAG that could be entered in response to licensing basis accidents (e.g.,large break LOCAs in certain BWR plants) or previously analyzed FSAR accidents. Previously analyzed FSAR accidents include analyses related to degraded core hydrogen control measures, hardened wetwell vents, and containment flooding capabilities in the design, where such provisions are described in the FSAR.

We expect that in performing the $50.59 evaluation, licensees $ vill be able to utilize or build upon previous SERs and $50.59 evaluations where the basic actions or functions addressed in the i

,- j 2

orgnal evaluation are not fundamentally different in the EP/ SAG. Section 50.59 is considered DQt applicable to the SAG secten of the EP/ SAG (with the above exceptions) or to the Technical Support Guidelines. 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, thereby requiring a $50.59 USQ determination.

Decisionmaking and Application of 10 CFR 50.54(x) & (y)

' The staff agrees with the general characterization of decision-making by ERO personnel and considers the guidance in Reference 3 (NRC letter re: Big Rock Point) to still be relevant. We also agree that a declaration of $50.54(x) and (y) can be performed at the licnesee's option upon " entry" into SAMG, but take excephon to the view that the determination es to whether the operator is in $50.54(x) and (y) space depends on whether the plant has implemented SAMG through the use of $50.59, as discussed below in greater detail.

10 CFR 50 54(x) & (v)

We agree that " entry" into SAMG (that is, a determinaten to discontinue following plant operating procedures and/or emergency operating procedures, and to begin following SAMG), by itself, does not constitute a departure from a license condition or Technical Specifcst;vn and, therefore, does not require ,

operators to invoke 50.54(x) and (y) in order to property transition to the SAMG. Thus, we agree with NEl's characterization that declaration of $50.54(x) and (y) upon entry into SAMG is at the plant's opbon However, we caution that actions taken almost immediately upon entry into SAMG could depart from the licensing basis and Technical Speedicatens, and therefore require licensees almost immediately to invoke

$50.54(x) and (y). For example, the first step in the Severe Accxient Control Room Guidelines (SACRG-1) for Westinghouse plants cats for operators to place the control switches for certain equipment in pull-to-lock position, thereby violating the licensing basis, and requiring this acton to be taken pursuant to $50.54(x) and (y). Licensees should continue to carefully consider the implications of all actons taken j under SAMG, and to obtain appropriate technical review and approvals.

We disagree with the position that the determination as to whether the operator is in $50.54(x) and (y) space depends on whether the plant has implemented the SAMG through the use of $50.59. Specifically, i we do not believe that the existence of a prior safety analysis conducted for purposes of determining I whether an unreviewed safety question exists is sufficient to determine whether $50.54 (x) and (y) must be invoked.

Finally, regardless of the licensee's philosophy regarding applicability of $50.54(x) and (y) to SAMG entry, NRC should be informed of any transition into the SAMG pursuant to $50.72(b)(1)(ii)(C). This regulation requires licensees to report any event or condition that results in the plant being in a " condition not covered by the plant's operating end emergency procedures". We consider the transition into the SAMG or SAG, and the plant conditions under which this transition would occur, consistent with the criteria for notificaton This notdication should be made regardless of whether the SAMG or SAG has received a review under $50.59.

Transfer of Decision-Makina Resoonsibility The transfer of decision-making responsibility that cccurs following entry into SAMG represents a fundamental change in the relationship between the TSC and the control room that warrants additional consideration by licensees. Prior to implementation of the SAMG, the TSC provides support to the control room staff in: (1) control of repair team personnel, (2) setting priorities for repair of equipment, and (3) proposing alternate methods for mitigating the event (i.e., methods not described in the EOPs). The

_ a

? -

3 TSC may also have responsibility for other emergency response activities, such as classifying events, recommending public protective actions, and notifying offsite authorities. During this time period, Geensed operators remain responsible for controlling the plant in accordance with the plant procedures. After entry into SAMG (in accordance with Westinghouse Owners Group guidance, for example), the guidance on plant response will shift from the EOPs to the SAMG, and responsibility for accident response will transfer from the control room (senior licensed operator) to the TSC (Emergency Director). This is a fundamental change from current practice in that the TSC would be responsible for directing rather than advising the control room operators. This transfer of responsibility and authority may be appropnate under the conditions associated with entry into SAMG, i.e., the EOPs have been ineffective and the core has been severely damaged However, it is important that such a transfer be clearly identified in the emergency plan, and that the process is thoroughly tested to ensure it is effective.

Operator Training and Evaluation on SAM The staff disagrees with NEl's charactenzation that licensed operator training concoming broad knowledge of SAM duties and responsibilities is not testable in license examinations. NEl has indicated for PWRs that the licensed operator training programs and examinations should be limited to knowledge of the transition from the EOPs to the SAMG. Training for the period where SAMG is in effect should be limited to familiarization training consistent with a " systematic approach to training" rather than the

" systems approach to training" as defined in 10 CFR 55.4 and should not be testable in licensed operator initial or requalification examinations. For BWRs, NEl cites the NRC position regarding licensed operator training and examination on severe accidents, set forth in the NRC's August 1,1995, letter to the Boiling Water Reactor Owners Group as apparently supportive of the position summarized above. This citation mischaracterizes the NRC position and furthermore implies that the position is applicable only to BWRs.

For both PWRs and BWRs, the staff expects that the NRC initial operator licensing and requalification 1 examinations will address, as appropriate, operator knowledge of SAMGs consistent with their l responsibilities regarding the manipulation of facility controls for implementing the specific guidelines or procedures. SAMG procedures and guidance assign licensed operators duties and responsibilities in the implementation of the action steps. The training programs' evaluation component (operator testing) should focus on the knowledge and abilities required for the operators to safely execute SAMG acbons, e.g., the ability to understand how their actions comply with the intent of the procedure or guideline and their effect on plant and system conditions. The depth of knowledge tested will be commensurate with the relative importance of severe accident knowledge as compared to other knowledge requirements for licensed operators. (The evaluation of the use of a " systematic approach to training" process is discussed later.) She 'd operator testing be identified as a deficient area, the NRC may reconsider the adequacy of the voluntary industry initiative, and the need for further guidance or regulatory action in this regard.

Inspections Versus Monitoring of Self-Assessments it should be noted that the staff has not, at this time, changed its plans for inspection of accident management implementation. These plans are to: (1) participate in the industry-sponsored A/M demonstrations or site visits, (2) complete a temporary instruction (TI) using insights obtained through the demonstrations or site visits, (3) perform pilot inspections at about five plants using the TI, (4) develop an inspection procedure (IP) for use at remaining plants based on findings from the pilot inspections and feedback from industry, (5) evaluate implementation at remaining plants using the IP, and (6) in the longer term, evaluate A/M maintenance on a for-cause basis as a regionalinitiative. Although the demonstrations to date have been very informative, they have been limited to Westinghouse designs. We  ;

i

4 believe it would be appropriate to visit additional sites (i.e., CE, B&W, and BWR sites) in order to gain an understanding of the implementation process for these NSSS designs prior to finalizing the Tl. Such visits would preferably be organized as additional A/M demonstrations, but attematively could be arranged as site visits separate from the demonstration process.

Application of a Systematic Approach to Training NEl has stated that plants should utilize a " systematic approach to training" rather than a formal" systems approach to training" as defined in 10 CFR 55.4. NEl further states that a systematic approach to training involves the same elements - analysis, design, development, implementation and evaluation - as the systems approach The contrast between a " systems approach" and a " systematic approach" consequently appears to be based on the former being defined by regulation and considered " formal" whereas the latter describes a process that is not defined by regulation and, by implication, less formal.

The staff has no objection to the term " systematic approach" solely to convey the fact that the approach is not required by regulation. However, the staff expects that the process activities of a " systematic approach" to training for severe accident management wi:1 involve the same elements and will be )

conducted with equivalent rigor and effectiveness that is associated with a " systems approach" to training, as defined in 10 CFR 55.4. Consequently, the staff intends that it will use the same criteria that it currently uses for reviewing implementation of a " systems approach" to training (i.e., NUREG-1220, Training Review Criteria and Procedures) when reviewing the implementation of the " systematic approach" to conducting severe accident management training.

NEl has stated that one or more of the elements of a systematic approach to training has been addressed on a generic basis by e combination of INPO and Owners Groups. NEl, while advising plants to review generic analysis and design activities for applicability to their plants, also states that plants should

" develop supplemental material only for those elements which were not addressed by INPO and the cognizant Owners Group." Although licensees may substantially benefit from the use of these generic training-related materials, the NRC has not formally reviewed the adequacy of these products. It is the staft's position that licensees are responsible for ensuring that each element of a systematic training approach has been adequately addressed. Licensees that choose to use generic products should, in addition to evaluating the applicability of generic analyses and design activities to their plant, evaluate the adequacy and completeness of such products for meeting their site-specific needs. The generic materials should be modified or supplemented as needed in this document, NEl refc s to a task list applicable to eva untorr., decision-makers, and implementers.

The staff is only familiar with a draft "i ccident management task training matrix." The training matrix does not address the tasks of implementers. The staff also believes that the task list and/or training matrix have not been widely disseminated to the industry. Consequently, licensees may be lacking material that would provide a basis for evaluating the generic analysis activities that NEl suggests can constitute largely, if not wholly, the analysis phase of a systematic approach to severe accident management training.

NEl states that "the simulator should not be modified to conduct this type of [ severe accident l management] training." The staff recognizes the limitations of current simulators for simulating plant response to severe accident phenomena. However, experience has shown that simulators are highly i effective training and assessment tools. Consequently, the staff believes that simulators should be used, within their existing modelling and instructional capabilities, to support the training and evaluation of I emergency response organization (ERO) personnelin severe accident management. The use of simulators for these purposes should be consistent with a systems approach to training and commensurate with the importance to safety of the severe accident knowledge and skills to be trained or i evaluated.  !

l

P

• s m

5 Within the above guidelines, licensees should consider using dynamic simulation for severe accident management training and evaluation to the extent that these activities can be supported by simulators which meet the specifications of ANSl/ANS 3.5. Thereafter, licensees should consider using simulators in either a static or unpowered mode to support the training and evaluation of the ERO's implementation of the severe accident management process, including (1) the ability of the control room crew to transition from the EOPs to the severe accident management guidelines, (2) ability to transfer or change decision making responsibility, (3) the ability of ERO personnel to reliably and accurately communicate plant state data and severe accident mitigation strategies between the TSC and the control room, and (4) the ability of the control room crew to implement the severe accident management guidelines.

NEl states that a panel of experts selected tasks for which training would be necessary and considered classroom lesson plans, computer-based training, and simulator use. It would appear the expert panel did not consider part-task simulation, table-top exercises, or other low fidelity simulation techniques which could prove useful for severe accident management training. In addition, NEl was not explicit conceming the conclusions reached by the expert panel regarding the appropriate application of the methods that were considered. Each of these methods can have relative strengths and weaknesses forimparting the knowledge and abilities necessary for severe accident management. NEl 91-04, states that severe accident management training will " include training techniques proven successful with similar materials."

It is the staffs position that successful training in severe accident management will ensure that decision-makers, evaluators, and implementors have the ability to reliably implement the severe accident management guidelines in real time under the performance conditions expected to be present during a severe accident. Consistent with a systematic approach to training it is incumbent upon licensees to select methods for training implementation and trainee evaluation which will ensure task proficiency on severe accident management tasks.

Applicability of" Safety-Related" and Appendix B to SAM implementation The staff generally agrees that severe accident management guidance (PWR severe accident management guidelines and BWR severe accident guidelines)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. For example, portions of the current BWROG Emergency Procedure and Severe Accident Guidelines which could be entered into during design basis LOCAs in certain BWR designs should continue to be treated as safety-related.

It should be noted that the accidents considered in the definition of safety-related SSCs in 10 CFR 100, Appendix A, Section Ill(c) are not limited to "only design basis (FSAR Chapter 15) accidents" as indicated in the NEl letter, but also include events such as fire, floods, storms, or earthquakes. These events are not explicitly considered in the review of anticipated operational occurrences and postulated accidents in Chapter 15 of the FSAR, but could result in potential offsite exposures comparable to the applicable guideline exposures set forth in $50.34(a)(1) or $100.11. In a similar vein, NEl should refrain from

)

introducing definitions of terms (e.g., " safety function") which are not related to providing guidance to the industry on SAM implementation. -

Finally, it should be stressed that severe accident management implementation does not obviate regulatory requirements applicable to safety-related SSCs or activities. Therefore, the staff disagrees with l NEl's position that " Changes affecting the design or operation of safety related SSCs should not be treated as safety-related unless it is determined that the safety function of the SSC is impacted prior to the time the safety function is required." Accordingly, with the exception of plant procedures that gn!y affect

l*,

\

6 SSC operation during the severe accident mitigation phase, i.e., beyond the design and licensing basis, any severe accident-related change (hardware, software, or procedural) affecting the design or operation of safety-related SSCs should be treated as ' safety-related" and, thus, govemed by Appendix B to 10 CFR Part 50 requirements.

Use of NUMARC 92 01 and IPE Insights The staff believes that there is greater value to licensees using a systematic process for assessing their accident management response capab:lities than alluded to in the NEl letter. The value of performing a systematic assessment, using a process such as provided in NUMARC 92-01, is not so much in identifying additional accident management strategies, as in identifying improvements in other areas important to accident response, such as: (1) plant-specific approaches or unique system alignments for implementing the generic strategies contained in the SAMG, (2) additional plant procedures, equipment pre-staging, or ERO training that could improve response capabilities, and (3) risk-significant ci.inpcE4,6t failures, recovery acbons, and containment challenges that should be factored into A/M training and drill scenarios. Accordingly, we would encourage rather than discourage licensees to perform a systematic assessment of their capabilities to respond to accidents found to be important from their IPE and IPEEE studies.

SAM implementation Closure The staff does not believe that it can rely upon the voluntary industry initiative as a substitute for NRC regulatory action if it is optional for utilities to notify NRC when they have completed severe accident management implementation. In order for NRC to rely on an industry activity as a substitute for a regulatory action, it is necessa y that: (1) the regulatory objectives and action be well understood and ,

defined, (2) the attemative industry action be well understood and defined, and (3) the industry acbon be completed at each plant and documented. The regulatory objectives and approach related to accident management were established in SECY-89-012, and attemative industry acbons to meet these objectivea are set forth in Section 5 of NEl 91-04, Revision 1. Each licensee has committed to implement these l actions as part of the voluntary industry initiative on severe accident management. The NRC has accepted the industry commitments in lieu of a regulatory action, but in order to reach regulatory closure on this issue requires confirmation from each licensee that the related commitments have been met.

Accordingly, we consider it essential, rather than optional, for licensees to notify NRC when they have completed implementation.

l 1

1 j

EI NUCLEAR INERGY IN Silt U T E David J. Modeon N c) T mstoN July 22,1997 Mr. Gary Holahan I Director, Division of Systems Safety and Analysis (Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555 0001 Project Number: 689

Dear Mr. Holahan:

This letter provides a document containing clari5 cations on a number ofissues related to utility implementation of severe accident management. These issues were discussed extensively by both NRC staff members and industry participants at the NEI Severe Accident Management (SAM) Implementation Forum in March 1997. It was clear from questions raised by industry participants that these issues require further clarification. This industry perspective on these issues is intended to provide additional guidance to the plant staffimplementing SAM, and information for the NRC staff formulating NRC policy on how SAM implementation is to be evaluated. The document draws on industry and NRC positions previously documented as well as information from the implementation workshop.

The SAM implementation areas addressed in this document are:

Consis ency am ng plants Application of 10 CFR 50.59 Decision making and application of 10 CFR 50.54(x) and (y)

Operator training and evaluation on SAM Inspections vs. monitoring of self assessments Application of a systematic approach to training Applicability of" safety related" and Appendix B to SAM implementation Use of NUMARC 92 01 and IPE insights SAM implementation closure ne . ,c- w - e.m = . ., ,m -

~w ~ . . -.c

.g.

Mr. Gary Holahan July 22,1997 Page 2 -

We intend to incorporate the guidance in this document into a revised NEI 9104, Revision 1, " Severe Accident Issue Closure Guidelines," for distribution in August.

NEI believes that NRC positions have been taken into account, and it is in the best ,

interest of the plants to be able to utilize this guidance in the near future to support commitments they have made for SAM implementation. Therefore, comments from )

NRC are not requested prior to this revision but will be considered. ]

Please note that NEI appreciates very much the extensive participation of several 3 NRC staff (Robert Palla, James O'Brien, and David Desaulniers) throughout the l March workshop and the subsequent demonstration of SAM implementation at l Comanche Peak. They provided their perspectives (including questions and I answers) on at least two occasions during the workshop, and responded to many I individual questions from participants. Industry feedback indicates that both the utility and NRC staff participants benefited greatly from the free exchange of perspectives, and these gentlemen are to be commended for their contributions and the professional nature of their communications.

If you or your staff have any questions, please contact Fred Emerson at (202) 739-8086 or fae@nei.org.

Sincerely, Q --

David J. Modeen FAE/tcp/tmc Enclosure c: Mr Carl H. Berlinger, NRC NRL Public Document Desk (Project Number 689)  :

i l

1 I

)

Enclosure 1 CLARIFICATIONS TO SEVERE ACCIDENT MANAGEMENT INDUSTRY GUIDELINES INTRODUCTION This document clarifies the industry perspective on a number ofissues related to utility implementation of Severe Accident Management (SAM). These issues were discussed extensively by both NRC staff members and industry participants at the recent NEI Severe Accident Management Implementation Forum, but it is clear from questions received by industry participants that these issues require further clarification. These clarifications are intended to provide additional guidance to the plant staff who are implementing SAM, and information for the NRC staff formulating NRC policy on evaluating SAM implementation at utilities. As such, it is intended to supplement NEI 91-04, Revision 1 " Severe Accident Issue Closure Guidelines."

This document provides additional clarification about industry's intent and guidance for the following implementation areas:

. Consistency among plants

. Application of 10 CFR 50.59 Decision making and application of 10 CFR 50.54(x) and (y)

. Operator training and evaluation on SAM

. Inspections vs. monitoring of self assessments Application of a systematic approach to training Applicability of" safety related" and Appendix B to SAM implementation

. Use of NUMARC 92 01 and IPE insights

. SAM implementation closure This document dra- s on industry and NRC pritins previously documented as well as insights f.om the implementation workshop.

CONSISTENCY AMONG PLANTS Utilizing consistent approaches to SAM implementation can be beneficial to a plant, but only where it supports the plant's individual implementation goals and constraints. Most plants can benefit from the good practices observed in other plants to the extent that they are applicable. Sharing experience with peers at other plants during implementation can be very useful. In addition, efforts within several Owners Groups to develop common or similar products can be beneficial to the participants because of shared development costs. Consistent approaches among plants can help reduce the extent of self assessments or NRC

J 4

inspections and the time required to address perceived differences among plants.

However, NEI and Owners Group guidelines were written in such a manner as to allow plants flexibility in implementing them, recognizing that plant-specific

. operating philosophies and designs could make it difficult to achieve a high degree of consistency. NRC has recognized and generally accepted this. As long as plants have implemented SAM systematically and in accordance with the appropriate guidelines, it is not necessary for general implementation or any ofits elements to closely resemble that of another plant.

Recognizing a diversity of approaches can result in the external perception that certain plants have developed mora thorough or extensive programs to address certain areas - such as training - that have others. This leads to the concern that plants perceived as less thorough will be "ratcheted" into " improving" their program accordingly. As NRC has stated that it is not their intent to do this, plants should develop the elements of SAM implementation using the overall performance based criterion of whether it works for them, as determined during the self assessment process (see below).

APPLICATION OF 10 CFR 50.59 TO SAM IMPLEMENTATION This clarification is applied to the existing version of $50.59. The NRC is currently reviewing and perhaps revising existing guidance for applying $50.59 and performing Unreviewed Safety Question (USQ) determinations. If the rule is revised, this clarification will be revised accordingly.

The industry position on the application of $50.59 was described in Reference 1.

Since that time, the PWR Owners Groups (Westinghouse, CE, and B&W) have generally taken the position that $50.59 is not applicable to SAM implementation at their plants, while the BWR plants expect to use $50.59. Clarifications will be provided in three areas:

. Generic application of $50.59

. Application of $50.59 to <WR plants

. Application of $50.59 to BWR plants i Generic Aoplication of 65Q&R Each plant has its own procedures for the use of $50.59 in determining whether a plant change involves an Unreviewed Safety Question (USQ). Generally these procedures cover the applicability, scope, and depth of the review, whether it is a l screening review or a detailed safety analysis. These procedures should be used to guide the applicability of $50.59 to SAM implementation.

2

)

A If a plant intends to make changes to the physical configuration of a plant for SAM implementation, then a $50.59 review should be performed because of the potential to impact normal or design basis plant operations. Changes to an existing procedure resulting from Severe Accident Management Guideline (SAMG) implementation should receive the same level of $50.59 review as any other change to the procedure.

The application of 950.59 to new procedures or guidance used to implement SAMG may differ signi6cantly between PWR and BWR plants, and is described below.

PWR Aeolication of 650.59 PWR SAMGs cover a regime outside the plant's Technical Specifications and FSAR; hence, implementing SAMGs could not involve a USQ. When the SAMG are put into use, the plant conditions are well beyond the design and licensing bases for the plant. Since severe accidents are beyond design basis events, pre planned or spontaneous procedures and guidance written to mitigate the consequences, and any plant change made during the severe accident to help mitigate the consequences, are not governed by $50.59.

No screening review or USQ analysis is therefore deemed necessary for PWR plants to implement SAMG procedures or guidance, unless speci6cally required by current plant procedures governing safety reviews.

BWR Aeolication of 650.59 BWR plants expect to implement SAMG through the use of $50.59, and this has been accepted in principle by NRC staff (Reference 2). Current plant procedures governing safety reviews should be utilized to perform the screening review and, if necessary, USQ analysis for new SAMG procedures or guidance.

The BWROG Emergency Procedure Guideline / Severe Accident Guideline (EPG/ SAG) strategies involve some changes to actions previously performed by operators and subject to the NRC SER for Revision 4 of the EPGs. The EPG/ SAGS should be implemented using $50.59 guidance as long as that guidance applies. If the particular steps in the EPG/ SAGS affect previously analyzed FSAR accidents, then the $50.59 guidance applies. However, the EPG/ SAGS will eventually enter the realm of severe accidents, where multiple failures have occurred. If this is outside the design and licensing basis of BWR plants, then l50.59 guidance does not apply.

3

- 1 l

DECISIONMAKING AND APPLICATION OF 10 CFR 50.54(X) AND (Y)

Decision making by Emergency Response Organization (ERO) personnel in severe accident situations should be very similar to decision making as it is currently implemented and practiced in plant Emergency Plans. There may be considerable variability from plant to plant.

However, several characteristics should be stressed.

Authority: The appropriate emergency planning documents should clearly indicate the ultimate responsibilities for decision making at various stages of the accident. The timing and " rules" for the transfer of authority, if such a transfer takes place, should be clearly indicated as well. Training and practice drills should address this area. The applicability of $50.54 (x) and (y) is discussed further below.

. Teamwork: Regardless of who the authority is, decisions should rarely be made by that individual in isolation from other members of the ERO team. The full capabilities of the team should be utilized where possible, including the Control Room staff. Training and practice drills should emphasize the importance of team decisions.

. Communication: Maintaining up to-date plant status information and open communication among decision making elements are both important factors in successfully responding to severe accidents. It is important that the latter be accomplished without interference from the former. Ways of providing plant status information to the Technical Support Center (TSC) should be utilized which (1) do not unduly impact essential Control Room staff, and (2) do not tie up telephone lines essential for communication among the ERO organizations.

f 50.54 (x) nd (y) were intended to permit licensees to take extraordinary actions to protect the public health and safety where existing icense conditions and technical 1

specifications are not effective. These actions are to be approved (as a minimum) o a licensed senior operator prior to taking the action. The applicability of $50.54 (x) and (y) to SAM implementation was discussed previously in Reference 1. This document concluded that f 50.54 (x) and (y) generally support the application of plant-specific SAMG during an event. j l

In general, a declaration of $50.54 (x) and (y) can be performed at the plant's option {

upon entry into SAMG. However, different considerations apply for BWRs and PWRs, as described below: 1 4

)

\

.*. \

BWRs: If a plant has implemented SAMG t51 rough the use of $50.59 it should not be necessary to declare entry into 550.54 (x) and (y). The prior performance of a safety analysis, in combination with comprehensive generic strategy development, provides an appropriate degree ofconfidence that actions outside the FSAR and Technical Specification domain have been carefully considered.

This should handle the need for entering $50.54 (x) and (y), or should at least

}

considerably reduce the number ofoccasions where that regulation should be applied. It is unnecessary to declare it routinely when entering SAMG.

PWRs: Since SAMG procedures and guidance are not subject to {50.59 review, the declaration of $50.54 (x) and (y) upon entry into SAMG helps assure that the regulatory intent for situations outside the FSAR and Technical Specifications are met. Such a declaration is still at the option of the plant, but should be explicitly considered.

In practice, the application of $50.54 (x) and (y) can lead (and has led) to situations where existing decision making processes and plant procedures are disregarded, potentially an uncontrolled situation. When entry into $50.54 (x) and (y) is declared for entry into SAMG, the SAMG should be followed in order to maximize the likelihood of successful accident mitigation. Any decision to apply alternate ad hoc strategies should receive appropriate technical review with consideration given to plant design, industry severe accident guidance / insights, and plant specific guidance / insights.

With respect to approval of actions by, "as a minimum, a licensed senior operator prior to taking the action," the NRC interpreted this approval authority as follows (Reference 3): '

" Ultimate responsibility for plant response in an emergency resides in the highest authority in the chain of command of the acility r licensee available to make a 1 decision about the response Any senior operato. licensed for a unit and acting for  !

the facility licensee can maxe tha decision for that unit, unless more senior licensee personnel are available and are authorized to make the decision; however, no one  ;

below a licensed senior operator can make the decision."

With reference to accountability, the NRC further stated:

"All personnel working for the facility licensec should use their best judgment in an l emergency, and a licensed senior operator should give that judgment to his superiors. If a licensed senior operator is overruled and the decision of his superiors turns out in retrospect to be wrong, it is highly unlikely that the NRC will take any l

enforcement action against him."

5 4

e In summary: The licensee should clea'rly designate the ERO position with ultimate responsibility for making decisions. That position should be at least a senior reactor operator, but may be a more senior utility position whose incumbent is not required to have a license. If that position for some reason is unavailable to make the decision, the decision-maker must be at least a senior reactor operator. A senior reactor operator should generally provide input to making decisions, either in the development of plant-specific SAMG strategies used in an emergency, or in actually implementing the strategies during the emergency.

OPERATOR TRAINING AND EVALUATION ON SAM Training and evaluation of the licensed operators in the control room can be divided into two parts: (1) that applicable to formal training and examination for initial and re-qualification license examinations, and (2) that applicable to a broad knowledge of duties and responsibilities that is not testable in license examinations.

Licensed Operator Initial and Re-analification Trainine Programs and

. Examinations Operator training and evaluation on severe accident management should be limited to the responsibilities specifically assigned to them during severe accident response cs detailed in the plant Emergency Operating Procedures. For BWRs, the NRC stated in Reference 4 that "SAMG should be addressed by the licensed operator re-qualification program consistent with a systems approach to training. With regard to initial operator licensing, the NRC [or plant staff, in accordance with GL 95-06, I

" Changes in the Operator Licensing Program") will likely test the license candidate's knowledge on select broad topics such as transition points, and responsibilities once in the SAMG. Detailed questions on specific mitigation strategies and guidelines are not anticipated."

For PWRs, only the transition from the Emergency Operating Procedures to the SAMG should be included in licensed operator initial and re qualification training programs and examinations since all of the SAMG is outside of the plant design and licensing basis. Training for the licensed operators for the period where the SAMG is in effect should not be in the licensed operator training program or examinations, but rather as familiarization training as discussed below. In effect, the PWR licensed operator training programs and examinations should be limited to the Emergency Operating Procedures before, during, and after the transition into SAMG.

6 i

l I

i

i .

Licensed Ooerator Familiarization and Evaluation Familiarization training on operator and Technical Support Center responsibilities during severe accident response should generally address responsibilities after the transition to SAMG. Operator responsibilities after the transition are generally very limited, and should not require signi6 cant training. All operator familiarization training on SAMG should be prioritized appropriately with existing training requirements; there should not be an incremental increase in the overall operator training requirements to address SAMG. Operator training to prevent severe accidents should have a higher priority than training to mitigate severe accidents. Therefore, existing operator training on normal evolutions and emergency procedures intended to prevent inadequate core cooling should be emphasized over severe accident mitigation training.

Evaluation of operator knowledge of severe accident response should directly parallel the emphasis placed during training. Since it is generally accepted that obtaining and maintaining a senior reactor operatoror reactor operator license is not dependent on his knowledge of severe accident response, it is important for each licensee to construct its training program such that undue emphasis is not placed on Severe Accident Management response over more important responsibilities.

The application of a " systems approach to training" should be considered more as a

" systematic approach to training," and is discussed later in this document.

INSPECTIONS VS. MONITORING OF SELF-ASSESSMENTS The implementation of SAMG at each plant is driven by a formal industry initiative rather than regulatory guidance. NRC staff accepted this approach. It is appropriate that the success ofimplementation be judged by the existing mechanism oflicensee self assessments rather than NRC inspections. However, NRC re'ains the option ofissuing regulatory guidance if not satisfied with industry implementation.

Because of NRC plans to provide some degree ofinspection, NRC and industry representatives have discussed the degree to which inspections are appropriate.

NRC staff have stated that monitoring licensee self assessment may be appropriate once a few initial inspections have established a baseline ofinformation with which to compare the results of monitoring self assessments. The extent of future inspections will likely be based on the NRC staff perception of the plants inspected earlier.

Each plant should establish criteria and frequency for SAM self assessments. An initial assessment should be performed which allows time to implement any self-7

3 corrections. Self assessm'ent plans, criteria, and frequency for the period beyond the committed date should be developed based on each plant's evaluation of need in order to maintain severe accident response capabilities, and within the context of existing plant self assessment or evaluation programs. The frequency may eventually diminish as self assessments indicate successfulimplementation on an ongoing basis, or increase if difficulties remain and self-correction is unsuccessful.

Criteria for SAM self-assessments may utilize the current revision of NEI 9104 and appropriate Owners Group guidance, and should cover the following areas:

. EP interface and impact

. Training

. EOP interface

. Communication

. Decision-making

. Drills The goal of SAMG implementation is to enhance existing severe accident response capabilities. Self assessment criteria addressing these areas should therefore be ,

performance based, aimed at gauging whether enhancements have taken place and whether the guidelines are effective in practice. Though minimum requirements for implementation activities (such as specification of training methods or frequency) may be necessary, these requirements are less useful as success criteria than are performance based criteria.

If NRC staffintend to inspect a plant's implementation, the plant may request substitution of a thorough self assessment in lieu of an inspection, in accordance with current NRC practice.

APPLICATION OF A SYSTEMATIC APPROACH TO TRAINING As indicatea above, plants should utilize a " systematic approach to training" rather than a formal" systems approach w training" as defined in 10 CFR 55.4. This is consistent with the implemen stion of SAM through an industry initiative rather than regulatory guidance. A systematic approach to training involves the same elements - analysis, design, development, implementation, and evaluation as the systems approach. One or more of these elements have been addressed on a generic basis by a combination ofINPO and the Owners Groups:

. Analysis: Subject matter experts in engineering, training, and management determined the task list applicable to evaluators, decision makers, and implementers 8

.i -

e Design: Based on the task list developed, these experts selected those tasks for which training would be necessary that could be addressed in a generic fashion.

They considered classroom lesson plans, computer-based training, and simulator use, but determined that the simulator should not be modified to conduct this type of training Development: In some cases, generic lesson plans and computer based training material were developed.

Unless a plant intends to utilize an alternate approach to training, it should build on the Owners Group work and develop supplemental material only for those elements which were not addressed by INPO and the cognizant Owners Group. As an example, ifINPO and an Owners Group have analyzed training requirements for implementers, decision makers, and evaluators, and designed learning objectives, it is not necessary for plant personnel to duplicate that effort unless they intend to take an alternate approach. They can complete the necessary steps for a systematic approach to training by (1) assuring that the generic analysis and design activities apply to their plant, (2) developing and implementing a training program based on the generic learning objectives, and (3) developing an appropriate evaluation and feedback program. They should document this process, but only reference the generic guidance used rather than duplicating it.

In general, the four Owners Groups have generically addressed the five elements as follows:

. Westinghouse analysis, design, development

. CE - analysis, design

. B&W - analysis, design, development

. BWR - analysis, design.

Plant development of the SAM training elements ,hich have not been provided generically (cuch as developinent, implementatic- , and e /aluation) shs ild be consisteri with existing plant practices for training program development. SAM trainir.g program development should not have as high a priority as INPO-accredi ed training programs and safety related training.

APPLICABILITY OF " SAFETY RELATED" AND APPENDIX B TO SAM IMPLEMENTATION NOTE: The use of the term " safety related"in this section is consistent with its use  ;

in Reference 5. Safety-related therefore applies to systems, structures, and components (SSCs) necessary to assure the integrity of the reactor coolant pressure j 9

1

y, boundary, assure the capability to shut down the reactor and maintain it in a safe condition, and prevent or mitigate the consequences of accidents which could result in offsite exposures comparable to those in 10 CFR 100. However, this reference to tecidents resulting in offsite exposures comparable to Part 100 limits includes only design basis (FSAR Chapter 15) accidents.

During the development of generic SAM guidance it has been the position of industry that SAM implamentation should not be considered safety related, and chould not be subject to Appendix B requirements. In the abstract, SAM is considered to be outside a plant's design basis because it is intended to help respond to accidents beyond the design basis. However, it is clear that SAM implementation may impact safety-related elements of plant design and operation to some degree.

The application of Appendix B and " safety-related" to SAM implementation should

' be limited to those elements of plant design and operation which will be speci6caDy impacted by SAM implementation.

In general, changes (hardware modi 6 cations (if any), procedure revisions, new procedures, or new guidelines) resulting from SAM implementation should be-treated in the following manner. The term " safety function" refers to an action or function described in the licensing basis which provents or mitigates a design basis cccident.

. Changes affecting the design or operation x uafety related SSCs should not be treated as safety-related unless it is determined that the safety function of the SSC is impacted prior to the time the safety function is required. This will necessitate a review for each safety related SSC impacted by SAMG implementation. Ifit is too difficult to differentiate between safety and non-safety functions of safety related SSCs, then the changes should be treated as  ;

safety related. The decision as to whether a change is safety related should be documented in accordance with existing plant procedures.

. Changes affecting nonsafety related SSCs should not be treated as safety related unless interfacing safet., functions are affected.

A few examples are provided for clarity.

1. A modification to a safety-related pump to improvo Gow under severe accident conditions would be considered safety related only if the safety function were affected prior to or during the time it is required. For a modi 5 cation to a nonsafety.related pump to add water to the vessel using existing flow paths, only that portion of the modification which impacted the safety function of the interfacing safety related flow paths prior to the need for their use for design-basis accidents would be considered safety-related.

10 I I

).*

2. A change to the operating procedure for the aforementioned safety-related pump would not be considered safety related unless the safety function is affected. A new operating procedure for the nonsafety related pump would not be safety-related unless it affected the safety function of the flow paths it tied into.

3. A new guideline affecting the operation of the aforementioned safety related pump would not be considered safety related unless the safety function is affected. A new guideline for the nonsafety related pump would not be safety-related unless it affected the safety function of the flow paths it tied into.

This guidance is intended to be consistent with the guidance for applicability of

$50.59.

USE OF NUMARC 92-01 AND IPE INSIGHTS A number of plant specific accident management insights have been identified from Level 1 IPE analyses, such as operator actions and the use of alternate systems to prevent core damage. These insights have generally already been addressed by changes to plant procedures (e.g., Emergency Operating Procedures (EOPs), System Operating Instructions (SOIs), etc.). Level 2 analyses less frequently consider operator actions or alternate uses of equipment to mitigate the consequences of a core damage accident (due to the lack of formalized guidance at the time the IPE /

PRA study was performed). Key generic insights into the accident progression and potential release pathways have already been captured in the generic SAMG from each of the Owners Groups based on the IPE / PRA studies and the results of accident management research programs. Thus, there are generally few additional plant specific accident management insights to be incorporated into SAMG from a plant's Level 2 IPE.

The IPE / PRA insights applicable to the SAMG are expected to come from two places:

Many of the SAMG strategies are similar to the those in the EOPs (e.g., add water to the RCS, depressurize the RCS, etc.). The operator actions and alternate equipment considered in the EOPs and SOIs (with the IPE / PRA insights already considered) can form the basis for the specification of possible equipment and actions to implement SAMG strategies.

NEI's Severe Accident Issue Closure Guidelines (NEI 91-04) contains a set of suggested licensee responses (in Section 2) for investigating potential additional preventive and/or mitigative measures for certain classes of dominant core damage accident sequences. One of these responses is to ensure that SAMG are 11 i i

l

a

.a

~ in place with emphasis on prevention / mitigation of core damage or vessel failure, and containment failure. Consideration of SAMG for these classes of dominant core damage sequences may yield additionalIPE / PRA insights applicable to SAMG.

Thus, the IPE/ PRA insights applicable to SAMG are expected to be limited to the identification of the key equipment and systems that can be used to implement a SAMG strategy.' It is not expected that more detailed assessments (as suggested by NUMARC 92 01 or NUREG/CR-5543) will yield any improvement in the plant-specific SAMG.

NUMARC 92-01, "A Process for Evaluating Accident Management Capabilities,"

was originally intended as the principal guideline document for implementing severe accident management. It includes detailed and comprehensive guidance for guiding plant implementation. Later each of the four NSSS Owners Groups developed generic SAM guideline products, based in large part on the EPRI Technical Basis Report, for the use of their members. These generic Owners Group products are intended to assist plants in meeting the guidelines of NEI 91-04, Revision 1, which is the overall guideline for plant SAM implementation.

Therefore, it is not necessary for plants considering plant specific IPE insights in implementing their generic Owners Group SAM products to utilize the NUMARC 92 01 guidance. NUMARC 92-01 remains a useful reference for plants who choose not to implement portions of the generic guidance or who desire to check whether implementation plans address the right elements.

SAM IMPLEMENTATION CLOSURE

. Closure of severe accident management as an issue for a plant should be considered es occurring when all of the following are accomplished:

e All phases of SAM implementation have been completed, including procedures and guideline development and initial training for emergency response personnel e Mechanisms for including updated information (from plant changes or new external knowledge) affecting SAM implementation, and for periodic self-assessments, are in place

.- An initial self assessment or other appropriate review is performed and suggested changes have been accomplished 12

f.* ,

I.

o.- l

' The committed date for completion is reached.

/

Though SAM implementation may be closed as a regulatory issue, a responsibility for ongoing maintenance of severe accident response capabilities continues for the life of the plant.

It is not necessary for plants to notify NRC when they have achieved closure. NRC may inspect a licensee's implementation to satisfy themselves that regulatory goals have been met, but this is not an element of closure. If plants wish to inform the NRC of closure a sample letter is provided as Attachment A; however, plants may choose e different process or wording for informing NRC.

REFERENCES l I

1.

NEI Letter to NRC regarding the application of 10 CFR 50.59 and 10 CFR 50.54 (x) and (y) to implementing Severe Accident Management Guidance (SAMG),

dated October 29,1993.

l

2. NRC letter to the BWROG addressing BWR implementation of severe accident management, dated May 27,1994.

3. - NRC letter to Consumers Power Company addressing use of 10 CFR 50.54 (x) and (y), dated November 5,1986.

4.

NRC letter to the BWROG addressing severe accident management training and the BWROG Technical Support Guidelines, dated August 1,1995.-

5. 10 CFR 100 Appendix A, Section IIIc.

4 13

e ',*

Attachment A SAMPLE NOTIFICATION OF SAM CLOSURE Address to Plant NRC Project Manager

Dear  :

In November 1994 the US nuclear industry committed to implement severe accident management at their plants by December 31,1998, using the guidance contained in the current revision of NEI 91-04. On (date) we noti 6ed the NRC that we would complete implementation of severe accident management by (date). The Plant has fulfilled this comminnent as of(date ), including the following elements:

o All phases of SAM implementation have been completed, including ,

procedure / guideline development and initial training for emergency response personnel; o Mechanisms for including updated information (from plant changes or new external knowledge) affecting SAM implementation, and for periodic self-assessments, are in place; and o An initial self assessment has been performed and indicated changes have been i accomplished.

Please contact if you require additionalinformation.

Sincerely yours, XXX/yyy cc: Mr. Robert Palla (NRR)

Mr. Frederick Emerson (NEI)

e 4

O 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 17761 Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Programs Nuclear Energy 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 1776 l Street, NW 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 Suite 400 1776 i Street, NW Washington, DC 20006-3708

Distribution: Mtg. Summary w/ NEl Re' Severe Accident Management Dated March 20, 1998 Hard. Copy Dochet File PUBLIC . 1 PGEB R/F j OGC ACRS PWan RPalla EMail I l

SCollins/FMiraglia l BSheron l RZimmerman JRoe DMatthews SNewberry l

CBerlinger i TEssig FAkstulewicz >

O'Brien RLatta JPeralta RGramm i GThomas DDesaulniers SBasu JMunro EMcKenna GTracey, EDO

)

i I

,, u '.. S b d i

l