ML18047A284
| ML18047A284 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/15/1982 |
| From: | Budnitz R FUTURE RESOURCES ASSOCIATES, INC. |
| To: | Russell W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18047A285 | List: |
| References | |
| RTR-NUREG-0820, RTR-NUREG-820 NUDOCS 8204200279 | |
| Download: ML18047A284 (6) | |
Text
. ~
- .~
,~;..
. ".\\.
2000 Center Street Room 418 Berkeley, California 94704.
415/526-5111 15 April 1982 Mr. William T. Russell Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washirigto~ DC 20555.
Dear M~l {fJt RECEIVED APR 19 1982&> 1o IS WCllil ir..lllftf -=-
iCCVIUIJ a:amm.
lliC This letter comprises my report to you under Purchase Order# DR-82-0961,
- in which my assignment has been to review Draft Report NUREG-0820, 11 Inte-
_grated Plant Safety Assessment: Systematic Evaluation Program, Palisades Plant".
As you know, I received a copy of this report personally on April 2nd, when I was visiting Bethesda on other business.
I arrived back here in Berkeley on April 7th, and after Verbal authorization from Ms~ Arlene McNulty of NRC Division of Contracts on April 9th, I began the review process in earnest.
Unfortunately, I am departin~ on April 16th (tomorrow) for a two-week business trip, so my review has had to be squeezed into the few days between April 9th and 15th~ plus the time I put into it after I got the draft report on April 2nd.
Regarding the mission of the SEP, I have used as primary references a pair of Commission papers (SECY-76-545 and SECY-77-551) that you furnished.
I understand that these together comprise the 'charter* for the SEP effort. Of cou~se, during my two years at NRC (1978-80) I learned a lot about the SEP and therefore have considerable additional background as to its goals, methodo-logy, and constraints.
While I have nothing in writing telling me my own scope of work, I have read the scopes of work for two other reviewers (Ors. Bush and Hendrie), and I have*
assumed that my own scope is identical.
I understand that the objective is "to provide an evaluafion of the adequacy o"f the rationale used by the staff in identifying and making recommendations for backfit requir~ments.
11 I have interpreted this charter slightly more broadly, and my comments will reflect my broader interpretation.
To be specific, I will provide discussion touching on each of the following qu~stions:
~
- 1) Is the Palisades SEP report asking and
- 2) What implicit policy-type decisions do their rationale appropriate ?
- 3) Is the review methodology appropriate ?
8204200279 820415 CF ADOCK 05000~~-5 answering the right questions ?
I detect in the report ? Is
.___,...........------;-~-*--. *~ *-*** ~--*~.-*~-- ---.--.--~--*--- -:------- ---:-*~-----*,-~-..,,.-~------~:,-;-~---**.~--~ -*.*- **~:.___*.. -. * -----.---.. ----*-****--* *--:--:--- *---*:;":.---:-~*---~-~---*TI-~... -*--*~--'!'~--~--~-.
W.T. "Russell 15 April 1982 page 2
- 4) Are important issues left out of the review ?
- 5) What has been included in the review that might have been omitted without significant compromise ?
- 6) How adequate is the rationale used to identify and recommend backfit requirements ?
(This question is the specific objective of the review.)
Because I have been short on time, I have not provided herein an~ comments on specific *safety topic*s.
I do have several specific-comments, with varyfn*g degrees of importance, which I will assemble into a coherent package during my trip over the next two weeks.
If it seems useful later, I can provide additional material to you upon my return, after May 2nd.
A.
Is the Palisades SEP braft Report asking and answering the right questions ?
In a narrow sense, I believe that the answer to this question is affirmative:
that is, the original charter seems to emphasize reviewing the older _plants against modern review criteria (the modern Standard Review Plan, modern regu-latory guides and standards, etc.); with the subsidiary goal that for plants with Provisional Operating Licenses the SEP review would form part of the basis for conversion to Full Term Operating Licenses.
To the extent that these objectives have guided the SEP effort, they have been quite successfully ful-filled, in my view.
I find that there has been a systematic analysis of the areas where the Palisades plant review, were it being conducted by the NRC staff today, would have been different:
in some areas the review procedure would have been different; and in others the plant or its operating. procedures
. would have been different.
When I used the word 'narrow' in the first sentence of the paragraph above, I meant it in its purest for~: that is, I realize that it is extremely important that every item on the 'list' be discussed properly, and its resolution docu-mented.
I find that the draft report has accomplished this effectively.
As one who has generally been uncomfortable with the (apparently ubiquitous) need to get papers into the file covering every gnat's eyebrow, I find the detail contained in some of the explanations and resolutions to be a little extreme.... but I do recognize the l~gitimate reason for this, namely that bringing Palisades into line and up-to-date with the large number of newer operating units is important in its own right.
My discomfort arises from the following perception:
I personally believe, and have believed for some time, that plants such as Palisades have b~en built and operated in a manner that.assures adequate protection of the public health and safety", in the sense that the NRC Corrrnissioners and staff have used that phrase or its generalized counterparts like 'no undue risk'.
However, this belief does not rest upon specific, well~founded grounds except for the strongly affirmative safety record of the industry to date; therefore, analyses that tend to confirm it are always important.
In this regard, one philosophical rationale for undertaking the Systematic Evaluation Program has been to look at 1
- *******-------*-** **-**'---****~-*-*-* ---*-* -**---**** **----****-***r***---- -
,----*-**-;.-------~-----~-----::- -* *---*-*~*-:-**7..,--*-*-**-,-
--~--,c~---* -*. *- ------=--===*** *--**-**-*---*----*-* ~----=----=---,-,,-----=*=---==*-.7 0---=-=----*-**-...*-*~-"_..,..._,__ ______ :-,
___ -:-__ :-_--_--::_=.,..*=-*-*=--:---
.....,--,--..,-,._.~---.-.-:
J.
W.T. Russell 15 April 1982
. :e page -3 older plants like Palisades, attempting to uncover any ~afety concerns that might cast doubt on the "adequate protection 11 determination.
In this regard I have reached two conclusions after reading the draft SEP report.
The first is that none of the safety issues treated seem in my view to have turned out to be.highly important to *safety, after analysis.*.. and this conclusion comforts me a good deal:
I can almost hear myself breathing more easily. Second, and in some ways more significant, is my conclusion that a few quite_ important_safety issues are absent from_the analysis in.this tjraft
-report ! _ I e 1 ab orate as fo 11 ows:
if somebody asked-me for my persona 1 -
opinion about what safety issues might compromise the judgment that Palisades poses no undue risk, I would list several items that are broadly encompassed by the USI (Unresolved Safety Issues) and TMI (Three Mile Island Action Plan) categories.
Thus, I continue to be worried about thin~s like systems inter-actions (LISI A~17), station blackout (USI A-44), control systems issues (LISI A-47), the.full range of human factors concerns, and the dependency of safety systems on crucial support functions like instrument air, service water, and
. electrical distribution buses of uncertain reliability.
The fact that NRC is systematically addressing these U~I and TMI issues gives me comfort.
In my view it is very likely that all of them will be resolved sooner or later, that all of our plants will somehow be safer because of it, and that the safety imporvements will be highly cost-effective. Nevertheless, I believe that the draft report I have in front of me is somehow inadequate or insufficient to the extent that it does not highlight this key point.
I
- would feel be.tter if the. report had something like the following, up* front somewhere, to guide the reader:
11The regulatory staff recognizes that several of the most important
~afety issues have not been addressed or resolved in the course of this SEP effort, in each case. because they are being coped with through other regulatory efforts:
in particular, the Unresolved Safety Issues list and the Three Mile Island Action Plan list contain some issues whose safety significance is probably far greater than a majority of the issues dealt with and resolved herein.
11 In summary, my answer to the question posed above (Is the report asking and ans~ering the right questions ?
11
) is that while it asks most bf the right questions; it finds itself unable to answer a reasonable fraction of them..
Phrasing my concern another way, I find a lot of what ~ in this draft report to-be operating in the strahge ~ake-believe land of the traditional NRC approach to regulation, an approach where regulation per se survives as important separate from safety.
One concrete example of this is the (luckily
-**-'-----~*** ~-*.....:::;; __
- -*--~--
- .. :-.--::..~.-~............... _______
- -*****~*---*-
= =_,
__ -=-*---~~~'
W.T..Russell 15 April 1982 page 4 few) places where, instead of assuring by other*means*that the licensee carries out a certain procedure, the staff wants a change to the Technical Specifications.
I had the impression that the staff was moving toward a philosophy of having less specificity in tech specs *... and if it isn't so moving, I believe it ought to !
Yet here is the SEP effort sticking more little stuff into tech specs. *Isn't there some other, better way ?
_ B.
What *imp 1 i cit po 1 icy-type deci s i ans do I detect-in the report ? Is their rationale appropriate ?
I detect several policy-type decisions that I agree with.
Perhaps the most important is the general feeling that I get in reading-the report that Palis.ades is, indeed, 'adequately safe'. This feeling pervades the text of the report as I read it, and it apparently has played a part is some of the decisions on whether urgency is required for various backfits.
Another important policy decision is the strong presence of the concepts of PRA (probabilistic risk assessment) as a valuabl~ tool in safety dectsion-making.
I endorse this with delig~t: I feel that the ~ay PRA has been used is just about right. It has been used for its insights into relative safety importance, but for not much in th~ way of quantitative information.* (Of course, this is partly because there has been no PRA done on Palisades itself; the Sandia-written appendix only references a comparison between systems at Palisades and at a mysteriously-unnamed different plant of CE design.)
The Sandia write-up on the PRA analysis is lucid, and explicitly recognizes the major uncertainties in any-quantitative conclusions.
- Another key policy-level decision seems to have been that hardware fixes should be required only if no other type of backfit or procedural arrangement is available.
I applaud this decision. Conscious efforts to avoid unnecessary backfits are, in my view, an important element in NRC's regaining credibility with the licensees.
C.
Is the review methodology appropriate ?
I am pleased to report my finding that the methodology used in the report is appropriate and adequate for the purpose.
As mentioned above, I ~m especially pleased to note that PRA methods have been used to rank the safety significance of several of the issues, and that PRA insights have assisted the staff in deciding on the importance or urgency of required changes.
(I could quote the Lewis Report here, but I will restrain myself.)
. The methodology gives different depth of treatment to issues of differing safety significance; and this is fully appropriate.
I especially applaud the concept of an integrated assessment in which a large number of issues are viewed in sum rather than one-by-one.
This integration affords the analyst broad insights into urgency and cost~effectiveness; and affords the reviewer or critic the chance to grasp the whole SEP analysis more fully.
I think that whoever has brought about this conceptualization of the SEP effort should be congratulated for clarity of thought.
- ------**--~-:......*... ---.-* -- ***--* ---------
W.T. Russell 15 April 1982
.*e page* 5
.. _.. _....:.,.. *~----~ ---**--..
- 9 I also find the approach used by the Oak Ridge group in analyzing operating experience at Palisades to be a good one. Their logic in identifying those events with real.safety significance seems to be fully $atisfactory, and there are some excellent discussions of specific topics (especially about control rod drive mechanism problems and partial/full loss of offsite and ans ite povJer.)
The one part of the methodology that leaves me a little uncomfortable is the
_linkage of the analysis, at least in a structural.sense, to the outmoded issues list compiled in about 1977.
The list itself (the definitions in Appendix A of the report, for example) contains some examples of thinking about safety/regulation/retrofits/NRC-licensee interactions that are today
.outdated, or at least overtaken by the events following Three Mile Island.
However, the implementation of the methodology overcomes much of the
.difficulty imposed by the use of the outmoded list and definitions: there are several examples of more up-to-date thinking about issues.
D.
Are important issues left.out of the review ?
I have already discussed my discomfort that several important issues are not analyzed in this draft report because they are being coped with through a different regulatory mechanism (USI, TMI, etc.).
I understand the rationale for this, and accept it prima facie.
I also have discomfort about the omission of a collection of issues involving management.
Specifically, I know that various utility managements are viewed in different ways within the NRC staff:
some are thought to be more competent than others, without necessarily implying that any one or more of them are insufficiently competent.
What struck me as I read this draft report is that I cannot, for the life of me, figure out from-it how Consumers Power's managem~nt is viewed !
(The discussion on page 1-6, penultimate paragraph, is the only clue I found as to what NRC thinks about Palisades management.)
For all.I know, they are thought to be 1the best utility around', or 'the worst', or whatever.
Sinte everybody now appreciates how crucial good management is to safety, -some specific treat'ment of this issue 0ould se~m t~ be called for.
The same comment applies to. utility in-house enqineering competence.
Some utilities have very fine engineering staffs, while others are weaker, relying instead on outside assistance. Again, I cannot figure out where Consumers Power fits into this spectrum, yet engineering competence, like management competence,* looms large as a key element in safety.
- --~-----***--:-~.' '------- --
-- --'-----*.!...-**--***~*--*-*- --***- -~*---'--~-.:..:_:..-*~~* ' *- _.:_,.:..:.:'...
J
- 9 W. L Russell page 6 J 5 Apr i 1 1982 Finally, the entire SEP seems to give insufficient tr,eatment to the human factors and control systems side of safety.
Even considering that many human-factors and control systems issues are bound up in the TMI Action Plan list, I would have felt better had there been more discussion of them, especially in the integrated. assessment part of fhe* report.
E.
What has been included i~ the review that might have been omitted without significant compromise ?
In one phrase, "not much".... except for the apparently ubiquitous need to cross all the t's and dot all the i's.
F.
How adequate is the rationale used to identify and recommend backfit requirements ?
This is the question that was asked directly of me as a reviewer.
I already mentioned, and will repeat here, my finding that the rationale for decision-making is fully satisfactory.
I find the staff's thoroughness, issue by issue, to be commendable.* I find-that the use of PRA as an aid to engineering insight is at just about the right level.
I am pleased with the apparent decision not to seek hardware changes except in those. few areas of high safety significance where no other remedy could be identified.
Summary I will summarize by stating that I believe this first SEP report has been quite successful: the metaphor of the laundry list that has been cleaned up is appropriate.
Maybe Palisades can get a regular operating license now, for one thing; and maybe the utility staff and the regulatory staff can go on from this mop-up activity to think hard about the real issues of safe operation of Palisades, issues hardly dealt with in-the analyses within this draft report.
Finally, I do think it is important to state my view that *it is only in retrospect, after the analysis, that one is at liberty to characterize the SEP list for Palisades as a 'laundry list': beforehand, we didn't really know what would crop up.
So in that regard the activity has been successful indeed.