ML16344A299

ACRS Comments on the NRC Safety Research Program and Budget for Fiscal Year 1987

ML16344A299
Person / Time
Issue date:	06/11/1985
From:	Banks M Advisory Committee on Reactor Safeguards
To:	Palladino N NRC/Chairman
References
Download: ML16344A299 (6)

Text

D850611 June 11, 1985 Honorable Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

ACRS COMMENTS ON THE NRC SAFETY RESEARCH PROGRAM AND BUDGET FOR FISCAL YEAR 1987 During its 302nd meeting, June 6-8, 1985, the Advisory Committee on Reactor Safeguards completed its review of the proposed program and associated budget for the Office of Nuclear Regulatory Research (RES) for Fiscal Year 1987. This matter was considered also by the ACRS Subcommittee on the Safety Research Program at meetings on May 8 and June 5, 1985 and at several meetings of other ACRS Subcommittees having interest in specific portions of the research program. During our review, we had the benefit of discussions with representatives of RES, the Office of Nuclear Reactor Regulation (NRR), and the Office of Nuclear Material Safety and Safeguards (NMSS). We also had the benefit of the documents referenced.

Our comments and recommendations are directed to the budget presented to us by RES on June 5, 1985. On that date, the proposed budget for program support was $128.6 million, distributed among the five Decision Units as shown in the attached table. We note that this figure is $7.6 million (about 6 percent) greater than the $121 million requested of Congress for FY 1986. Although we have some concern about proposing a research program at a level of funding that may be difficult to obtain, we have not tried to agree on recommendations that would reduce the program to a level consistent with the requested budget for FY 1986.

Our comments are provided below and our budget recommendations are summarized in the attached table.

REACTOR ENGINEERING We endorse the programs and the proposed funding level of $44.6 million for this Decision Unit. If absolutely necessary, some reductions could be made by stretching out programs in some areas.

However, we do not believe that this should be done for the research programs related to "plant aging"; any reductions in these programs would delay the timely completion of this important work or reduce its scope.

THERMAL-HYDRAULIC TRANSIENTS

We support the proposed total budget of $23.4 million for this Decision Unit.

We believe that a major capability for thermal-hydraulic research should be maintained. It is especially important to ensure the continued availability of experienced specialists. We support the concept for a new or modified integral test facility to be co-located with a technical staff capable of analysis and code development. The budget proposal of $4.5 million for this effort is appropriate if firm planning for such a facility is begun immediately and if it leads to a decision to proceed.

A vigorous experimental program in Separate Effects should be sponsored and maintained by the NRC at universities and other smaller facilities throughout the country and a funding level of about $4 million would be appropriate rather than the $3.2 million proposed by RES. This program should include investigation of phenomena, such as water hammer, which could impact nuclear safety but have not yet been extensively studied in that context. We recommend that a program of flow visualization studies, proposed earlier by RES, be reinstated.

The advanced thermal-hydraulic codes, such as TRAC and RELAP, have contributed greatly to an understanding of reactor operation and risk. To ensure their continued availability and utility, they must be effectively maintained. We endorse the NRC program to maintain these codes and to continue their assessment and improvement by a program of cooperation with foreign research institutions. We caution, however, that a strong domestic capability for maintaining and using these codes must continue.

The nuclear plant databank (NPDB) and nuclear plant analyzer (NPA) programs are intended to extend the utility of the major thermal-hydraulic codes. The NPDB program, while important to users in both NRR and RES, is not research. We recommend that it be funded from the NRR budget. The NPA program has the potential for providing an extremely flexible and useful tool for nuclear systems analysts.

We believe this development program is important and should be continued.

However, one part of the NPA program involves development of parallel-processing using smaller, special-purpose computers as a substitute for mainframe computers used for the major thermal-hydraulic codes. While this work is interesting and may be of general use, it is not directly related to the NRC's thermal-hydraulic research program. We recommend that it be funded elsewhere.

Considering our recommendations above, we believe that funding for the Transient Models and Codes program can be reduced from the proposed $5.8 million to about $5 million.

ACCIDENT EVALUATION With publication of NUREG-0956, the source term reassessment report, the NRC Staff will have completed the first phase of the development of a suite of codes meant to describe the course of a severe accident with sufficient detail and accuracy to permit the results of the calculational methods developed to be used in regulatory decision making. In recent meetings with the RES Staff, we have been assured

that, in their view, the results of the calculational methods described in NUREG-0956 can, indeed, be used for that purpose.

Nevertheless, RES proposes further research aimed at refining the methods and removing uncertainties in the approach described in the source term reassessment report. This is said to be partly in response to comments contained in the recently released review by the American Physical Society of the source term research results.

However, the deficiencies said to exist, and the uncertainties that will be removed by the proposed research for FY 1987 have been described only qualitatively. Before more research can be justified, deficiencies in existing codes should be identified, a more detailed and quantitative description of what is to be done to remove these deficiencies should be developed, and the improvements expected and the effect they will have on the regulatory process should be described.

Although we believe that the course of action recommended will improve the likelihood of obtaining useful results, we note that we have repeatedly expressed skepticism concerning placing almost total dependence on the results from large mechanistic codes as a tool for decision making. We continue to recommend that any decisions made take due account of the large uncertainties in the results of so-called mechanistic codes.

In NUREG-1105, we recommended initiation of a program to obtain information needed to develop containment performance criteria.

That has not occurred. Nor does support for such a program appear in the proposed FY 1987 budget. We urge that a program be initiated with funds coming from the Fission Product Source Term work.

We have, within the past few days, received the comments of NRR on the proposed severe accident research program. We share NRR's doubts concerning the wisdom of continuing work on MELPROG. We are, however, pleased to observe that there appears, finally, to be an effort to evaluate the use to be made of results from the research program related to severe accidents, and to design future research to provide whatever additional information may be needed by NRR.

Although we are not as sanguine as NRR appears to be about the adequacy of the information that will be available by the end of FY 1986, we believe that the process of negotiation which seems to have begun between NRR and RES should define a more useful research program than we have seen described to date. We recommend that $2.5 million of the proposed funding be reallocated from those portions of the research dealing with in-pile tests to support research on human factors and man-machine interaction. We cannot comment further on the proposed budget for this Decision Unit until we have the results of the negotiations between NRR and RES.

REACTOR OPERATIONS AND RISK In NUREG-1105, we took strong exception to the NRC decision to terminate research in the human factors area in FY 1986. We deeply regret that RES persists in omitting such research in its proposed FY 1987 budget. We strongly recommend that this decision be reconsidered and that a carefully formulated long-range research program

in human factors and man-machine interaction be launched. We recommend that about $2.5 million be taken from the in-pile experimental program on Damaged Fuel and Source Term and reallocated to research on human factors and man-machine interaction. This should include matters such as design, maintenance, quality of personnel, and basic management philosophy, as well as coping with unexpected complex transients.

We agree with the proposed total level of support of $15.6 million for risk-related programs in this Decision Unit, but do not agree with the allocation to various tasks or with all of the tasks themselves.

In NUREG-1105, we recommended that a thoughtful research effort be devoted to a search for possible weaknesses in current probabilistic analyses, e.g., accident paths either not currently evaluated or dismissed as insignificant, which may, on closer scrutiny, prove to be very important to risk. We reiterate that recommendation here. An example of a subject for such examination might be whether pressure components whose gross failure probability is assumed to be negligible are designed, fabricated, operated, and inspected with validated techniques to an extent commensurate with the low assumed failure probability. We believe that such research is properly the role of the NRC and not to undertake it reflects an ostrich-like position.

We also recommend the initiation of, or increased emphasis on, research on methodology for treating design errors, systems interactions, plant aging, equipment qualification, and external floods in PRAs.

Furthermore, we believe that in FY 1987 the research on evaluation of severe accident risk and risk management is being curtailed or even terminated prematurely. Issuance of the proposed policy statement on severe accidents will not tell us how to specify a containment performance criterion. It will not tell us the importance of plant-specific features to risk. Nor will it tell us the role of external events, design errors, human cognitive errors, etc., in evaluating risk. We recommend continued strong support for studies having the appropriate focus.

We believe that the proposed program on regulatory and inspection applications as well as the plant-specific calculations with MELCOR should be reduced or stretched out as necessary to permit adequate support of the risk-related programs recommended above.

WASTE MANAGEMENT, EARTH SCIENCES, AND HEALTH We believe that the proposed funding for the programs on High-Level Waste Management and Low-Level Waste Management is adequate. A similar conclusion has been reached regarding the funding for research on Health Effects, exclusive of the needs for support on occupational radiation protection.

As before, we recommend that a research program aimed at improving our knowledge of the likelihood of severe floods should be undertaken. Support for such research (about $0.25 million) should be obtained by reallocation of funds within this Decision Unit.

RES has proposed that all support for work on occupational radiation protection be eliminated from the FY 1987 budget. We do not agree.

Examples of problems that need to be addressed include the development of:

a. A radiation protection program data base;

b. A standard methodology for optimization analyses;

c. A system of performance indicators for assessing the quality of nuclear power plant radiation protection programs; and

d. Improved clothing for protection against internal exposures, including studies of the net risks of using respirators.

It is estimated that items "a" and "d", which have been endorsed by NRR, would require $0.5 million for FY 1987. Support of items "b" and "c" is estimated to require $0.2 million. We urge that funds for the support of these activities be provided either within the NRC research budget or through Technical Assistance Programs within NRR.

Sincerely, David A. Ward Chairman

Attachment:

Table 1 - Office of Nuclear Regulatory Research Program Support Budget for FY 1987.

References:

1. Table entitled, "Nuclear Regulatory Research FY 1987 Budget,"

dated June 4, 1985, submitted at the June 5, 1985 ACRS Safety Research Program Subcommittee meeting

2. Memorandum from Robert B. Minogue, Director, Office of Nuclear Regulatory Research, to Jack W. Roe, Chairman, Budget Review Group,

Subject:

NRR's Comments on the RES Budget, dated May 31, 1985

3. Memorandum from Harold R. Denton, Director, Office of Nuclear Reactor Regulation, to Robert B. Minogue, Director, Office of Nuclear Regulatory Research,

Subject:

NRR Review of RES FY 1987 Internal Budget Presentation to ACRS and BRG, dated May 29, 1985

4. Memorandum from E. F. Conti, Acting Director, Policy, Planning and Control Staff, Office of Nuclear Regulatory Research, to L.

W. Barry, Director, Office of Resource Management,

Subject:

Analysis of "Hard Call" Programs in the RES FY 1987 Budget Allocation, dated May 21, 1985

5. Memorandum from E. F. Conti, Acting Director, Policy, Planning and Control Staff, Office of Nuclear Regulatory Research, to RES Division Directors,

Subject:

Considerations Related to the FY 1987 Allocation to the $130 Million EDO Mark, dated May 17, 1985

6. Memorandum from E. F. Conti, Acting Director, Policy, Planning and Control Staff, Office of Nuclear Regulatory Research, to L.

W. Barry, Director, Office of Resource Management,

Subject:

FY 1987 Internal Review, dated May 17, 1985

7. Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, "Reassessment of the Technical Bases for Estimating Source Terms," Draft NUREG-0956, dated April 1985