ML16204A259

Position on Direction Setting Issue 22 - Future Role of NRC Research

ML16204A259
Person / Time
Issue date:	11/19/1996
From:	Kress T Advisory Committee on Reactor Safeguards
To:	Shirley Ann Jackson NRC/Chairman
References
Download: ML16204A259 (5)

Text

November 19, 1996 The Honorable Shirley Ann Jackson Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

POSITION ON DIRECTION SETTING ISSUE 22 -- FUTURE ROLE OF NRC RESEARCH During the 435th and 436th meetings of the Advisory Committee on Reactor Safeguards, October 9-12 and November 7-9, 1996, respectively, we reviewed Direction Setting Issue (DSI) 22. At the 435th meeting, we discussed this issue with the NRC staff. We also had the benefit of the documents referenced.

Direction Setting Issue 22 raises the question of what role the Office of Nuclear Regulatory Research (RES) will have in the future. A range of possible roles is defined in the discussion.

These vary from elimination of a research capability at NRC to continuation of the research at its current, diminished level on a broad range of topics. The preliminary thinking is to select the continuing "business as usual" role for RES.

We contend that, first, changes are occurring within both the nuclear industry and the regulatory community that make it essential for NRC to have a research function. Second, we contend that a "business as usual" approach to NRC research is too timid.

There is an urgency for the NRC to have research information to meet its obligations to protect the public health and safety in a changing environment. Finally, we contend that the planning for future research should be directed toward areas of focused need.

In particular, research is needed to support NRC's transition to risk-informed and performance-based regulation.

The research arm of NRC has occupied a central role in the development of the body of regulations needed to ensure public health and safety in the commercial use of nuclear power. Since the division of the Atomic Energy Commission into the NRC and what eventually became the Department of Energy, RES has overseen the work needed to develop the design-basis analysis of nuclear power plants. This has included ensuring through a combination of experimental and analytical research that the analyses done for Appendix K to 10 CFR Part 50 are on a sound technical foundation.

RES has also undertaken a vast effort to understand the residual risk posed by the use of nuclear power through the studies of

severe accidents and the associated radionuclide source terms. RES has, in fact, been responsible for the evolution in the analysis of reactor safety from the bounding and the qualitative to the use of quantitative risk analysis.

From the pinnacle following the accident at Three Mile Island, RES has suffered a continuing scale-back of the activities it can afford to undertake. As with many institutions facing budgetary pressures, the longer term benefits of research activities have been sacrificed to ensure that there is the necessary financial backing for day-to-day activities that are the responsibility of NRC. NRC's research budget has, then, suffered disproportionately when funding cutbacks have been inflicted on NRC as a whole.

Today, the available funding for research is, indeed, small enough that it is a legitimate question whether a viable research program can be maintained.

At the time these cutbacks in research funding have been taking place, changes have also been taking place in the way society deals with safety regulation. Most directly obvious has been the effort supported by both the Executive Branch and by Congress to base regulation on actual risk rather than bounding conservatism. The Vice President heads a Government-wide effort to base regulation, including regulation of nuclear power, on risk. Relative to most other regulatory agencies, NRC is well on the way to developing a risk-informed and performance-based regulatory system. NRC may well set an example for other regulatory agencies in this regard.

It is, then, important that this be a good example.

A second societal development that will have safety implications is the economic deregulation of electrical power generation. This development has yet to be fully realized, but already efforts are being undertaken by the nuclear utilities to achieve greater economic competitiveness. Increases in reactor operating power and the extension of fuel life are just two immediate steps the industry is taking that have obvious safety implications. It is widely forecast that draconian measures will be necessary in the future to maintain nuclear power as a viable option for the generation of electrical energy. There are, of course, other changes taking place in the industry that fall in the domain of NRC such as plant aging; plant decommissioning; development of new, passive plant designs; and disposal of nuclear waste.

NRC is making great efforts to respond to the challenges posed by societal and industrial changes that are now taking place. The information available to the agency to meet these challenges is, however, proving to be limiting. By way of examples, consider the following:

. NRC is attempting to develop a risk-informed and performance-based regulatory system to improve the safety of nuclear plants and to relieve the industry of unnecessary burden.

But, NRC is trying to do this without any detailed knowledge of shutdown risk because RES is unable to fund studies comparable to the NUREG-1150 studies performed to understand risk during power operations.

. NRC development of probabilistic methods has not kept pace with its needs. Methods to treat human errors of commission or the impacts of organizational factors and management practices on risk are not available. Experience shows that human errors, organization, and management are responsible for or contributing to many accidents and "near misses."

. NRC wants to regulate in light of risk, but there is now only the technical capability for routine, noncontroversial evaluation of core-damage frequency. The capacity to extend estimates of core-damage frequency to evaluate risk has not been made widely available. There is not even consensus on how accurately analyses of risk, given that core damage has occurred, must be done nor how comprehensive such analyses must be.

. The introduction of digital instrumentation and control (I&C) systems in nuclear power plant safety related systems requires NRC to have the capability to regulate high-reliability software-based systems. NRC's understanding is limited to current software engineering methods which employ highly disciplined development process to design and produce high-reliability software. A consequence of this approach is lack of well-developed methods for evaluating the product of the process. NRC is limited to regulating the process of design and development of digital I&C systems because no accepted tools are available for evaluating the product.

. Financial constraints forced NRC to allow its codes for predicting fuel behavior to atrophy so they are no longer up to the state of the art. These codes cannot adequately predict fuel and clad behavior at burnups now being used by licensees. Recovery actions by RES have been constrained by resource limitations to narrow topical areas.

. NRC has not yet been able to formulate a risk-informed and performance-based fire protection rule to replace Appendix R to 10 CFR Part 50 which has been the source of so many exemptions and other controversies.

. NRC's opportunities to leverage its research budget by participating in international research consortia are becoming limited as NRC has less to contribute to the consortia efforts.

. NRC finds it must evaluate new, passive plant designs using tools developed for older plant designs because it cannot afford to develop analytical tools better suited for the simulation of the physics of these new designs. NRC must "make do" with computational tools that are now over a decade old and don't even begin to take advantage of all the more recent advances in computer technology.

. NRC is unable to predict or detect newly discovered modes of degradation of the primary pressure boundaries of pressurized water reactors. It has been forced to use rules designed to deal with wastage and corrosion of steam generator tubes to

protect against a variety of forms of stress corrosion cracking.

There is clearly a need for a more aggressive NRC research program to confront the many challenges that the agency continues to face.

We can be confident that the agency will meet its obligation to protect the public health and safety. But, without up-to-date tools produced by a forward thinking research organization, the agency will have to resort to methods that do not contribute to either regulatory efficiency or economic efficiency of the nuclear industry.

The financial resources now available to the agency for performing research are indeed limited. It has been necessary to make hard choices on what is to be done and what must be abandoned. A significant factor in the thinking on what is to be supported and what is to be abandoned has been a desire to preserve technical capability. This effort to preserve technical capability appears to have:

. led to an emphasis on the things that the agency knows best such as the thermal hydraulics of existing reactors, and

. diluted the efforts in many areas to preserve the current organizational units of RES.

The preliminary decision for DSI 22, which is to continue conducting research as it has been done in recent years, appears to enforce this emphasis on what is known well and to preserve the existing organizational structure of RES.

It is our position that more aggressive options need to be developed in response to DSI 22. One of these options is to focus the research in areas to meet the agency needs as it embarks on its experiment with risk-informed and performance-based regulation.

The goal of research, then, ought to be, first, to provide risk information that is far more comprehensive than that now available, and then, to identify the performance indicators that do indeed reflect the risk. Furthermore, efforts are needed to use plant data and event reports to assess the adequacy of current probabilistic risk assessment methods.

RES also needs to anticipate safety implications that licensees will make in response to economic pressures. RES should be in a position to provide tools suitable for the safety evaluation of these changes. To do this, the split of work by RES between user requests and self-directed work may have to be reevaluated.

Sincerely,

/s/

T. S. Kress Chairman

References:

1. United States Nuclear Regulatory Commission, "Strategic Assessment and Rebaselining Initiative, Stakeholder Involvement Process Paper," dated September 16, 1996

2. United States Nuclear Regulatory Commission, "Strategic Planning Framework," dated September 16, 1996

3. United States Nuclear Regulatory Commission, "Strategic Assessment Issue Paper," dated September 16, 1996