ML19261B820
| ML19261B820 | |
| Person / Time | |
|---|---|
| Issue date: | 02/09/1979 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Ahearne J, Bradford P, Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| References | |
| SECY-78-637, NUDOCS 7903070292 | |
| Download: ML19261B820 (5) | |
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MEMORANDUM FOR:
Chairman Hendrie Commissioner Gilinsky Commissioner Kennedy Commissioner Bradford Commissioner Ahearne FROM:
Lee V. Gossick Executive Director for Operations SbBJECT:
FINAL RESPONSE FROM SURVEY'0F. STAFF VIEWS ON 'RESULTS OF SURVEY OF USES OF WASH-1400 (DATED 11-22-78 AND INCLUDED IN SECY-78-637)'
As noted in my. January 5 and January 15,1979. memoranda to you on.this subject, I requested staff coments on Enclosure 2 of SECY-78-637.
Enclosed is the. final response to that request.
NRR has just completed the results of a further review of the extent to which licensing or other regulatory actions relied upon WASH-1400. This latest NRR review goes beyond the initial survey of SECY-78-637 forwarded to you in December. The NRR Commission paper will reach you early next week.
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(Signed) Lee V. Ec d Lee V. Gossick Executive Director for Operations
Enclosure:
As stated
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cc:
S. Chilk, SECY PE GC' CONTACT:
J. L. Crooks, MPA 492-7735 79030706t#/ 1
ENCLOSURE 1
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JAN 2 3 579 MEMORANDUM FOR:L "Trman M. Haller, Director Office of Management and Program Analysis FROM:
Norman C. Moseley, Director Division of Reactor Operations Inspection Office of Inspection and Enforcement
SUBJECT:
STAFF VIEWS ON RESULTS OF SURVEY OF USES OF WASH-1400 The requested survey of the staff of the Office of Inspection and Enforcement has been completed.
The remaining 24 staff members have been surveyed with negative results.
A comment statement by a staff member identified in the January ll, 1979 memo, has been rewritten for clarity and is enclosed.
l CC (mck forman C. Moseley Director Division of Reactoc Operations Inspection Office of Inspection and Enforcement
Enclosures:
1.
Memo K. Plumlee to 11. Crocker dated 1/3/79 2.
Memo N. Moseley to B. Grier dated 1/11/79 3.
Memo K. Plumice to 11. Crocker dated 1/16/79 IO 9
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s January 16, 1979 MEMORANDUM FOR:
H. W. Crocker, Acting Chief, Radiation Support Section, FF&MS Branch FROM:
K. E. Plumlee, Radiation Specialist, Radiation Support Section
SUBJECT:
EXPLANATI0ff 0F STATEMENT DATED JANUARY 3,1979 ON NRC USE OF WASH-1400
Reference:
Memorandum, N. C. Moseley to B. H. Grier, dated January 11, 1979 In regard to the reference memorandum, I wish to explain that no criticism of either the NRC or the authors of WASH-1400 was intended.
I intended to indicate a difference of opinion resulting from the apparent references in the past to the conclusions of the WASH-1400 study without any reference to the limitations of the method of analysis used in the study.
I believe there are reasonable differences of opinion as to the potential risks and modes of failure that can occur in nuclear power plants.
In addition, there are many differences in the equipment, design and operation of various facilities.
'Since the omission of any risk or mode of failure inherent in a facility will result in an overoptimistic risk assessment, it would be prudent to review actual occurrences in order to identify any actual risks or modes of failure that were not included in WASH-1400.
So far as I am aware, NRC's effort is being limited to the reassessment of the risks that were included in WASH-1400, as was done with the Lewis Report.
I believe it would be m' ore objective to focus attention on actual events as they occur than to reconsider past decisions. The perfonnance of such an evaluation might well result in NRC making changes in the light of new information.
I am not advocating any reconsideration of past decisions or changes in policy at this time other than as stated above, and I am not aware of any instances of improper use of WASH-1400 in regulatory decisions.
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~L Karl E. Plumlee Radiation Specialist, RI V
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Sa a're FAXED TO REGION 1/11/79 UNIT Io STATES NUCLEAR REGULATORY COMMISSION
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Janua ry 11, 1979 MEMORAflDUM FOR:
Boyce H. Grier, Director, Region I FROM:
Nornan C. Moseley, Director, Division of Reactor Operations ' Inspection, IE
SUBJECT:
WASH-1400 USE STATEMENT By a memorandum dated December 29, 1978, I asked that regional technical personnel be individually contacted concerning uses of WASH-1400.
As a result, the enclosed memorandum was prepared by Karl Plumlee of the Region I staff.
In reviewing Mr. Plumlee's statement, it is not clear to me exactly what is being criticized.
The information which was intended to be obtained by my memorandum can be paraphrased as follows:
1.
Based on your knowledge, please identify instances in which WASH-1400 was used in regulatory decisions.
2.
In light of the Lewis Report criticisms, should these decisions be reconsidered?
I discussed the enclosed statement with Mr. plumlee this morning, and he said his criticism was based on verbal statements, press releases, etc.
Please ask Mr. 'Plumlee for a written response to items 1 and 2 above and a statement to further context the enclosed.
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Norman C. Moseley Director Division of Reactor Operations Inspection, IE
Enclosure:
Moro, K. E. Plumlee to H. W. Crocker dtd 1/3/79,
" Personal Views on NRC Use of WASH-1400 (Rasmussen Report)"
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J.*,8 3 UB MEMORANDUM FOR:
H. W. Crocker, Acting Chief. Radiation Support Section FF&MS Branch FROM:
K. E. Plumlee. Radiation Specialist Radiation Support Section, FF&MS Branch
SUBJECT:
. PERSONAL VIEWS Ok NRC USE OF WASH-1400 (RASMUSSEN
. REPORT)
I'beli' eve that NRC use of the subject report has been predicated on over optimism, and negative information has been ignored.
Tha following
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examples illustrate this point.
1.
This report was issued with the standard disclaimer.
2.
The introductory section of the report contains an additional disclaimer, acknowledging that previous studies using(The claim Was the same method of analysis underestimated the actual risks.
made that revious errors were eliminated in the study reported in WASH-1400.
3.
I believe that it has been recognized officially that the risk due to fire was underestimated in WA5H-1400.
4.
There is no, clear indication that " unexpected modes of failure"
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will be recognized and incorporated into the risk assessment should such failures occur.
This is to be distinguished from NRC's policy of reassessing risks as experience accrues with expected modes of failure for which the analysis may have used higher or inwer frequencies of failure than will prove out as time progresses.
W Karl E. Plumlee Radiation specialist
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