ML19291A467
| ML19291A467 | |
| Person / Time | |
|---|---|
| Issue date: | 11/08/1976 |
| From: | Hanauer S NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Norry P NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FOIA-79-109 NUDOCS 7905160245 | |
| Download: ML19291A467 (4) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION 1
WASHINGTON, D. C. 2055L
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November 3, 1976 v
Note to Pat Norry REVIEW OF TONG PAPER FOR NUCLEAR SAFETY REF YOUR NOTE DATED NOV. 2, 1976 This paper has many important and useful things in it, but I cannot recomend publication in its present fom. The reasons for this are the following:
1.
The paper implies that only as a result of the safety research program in the future will NRC have an objectively verified basis for the evaluation of the applications. This is certainly not true.
Infomation comes to the NRC from a variety of sources, one of which is the safety research program.
Others include in particular the infomation furnished by licensees, which is required by law to be sufficient as a technical basis to justify the licensing action proposed.
2.
The paper contains extraneous material about reactor licensing which should be deleted.
3.
The paper and particularly the introduction reads as though we know nothing about reactor safety today, and that this program and its recent and future results are all we are going to know. This is not true, and its implication is a very serious charge.
If the author really believes this, he should document it in a separate paper dealing with reactor licensing rather than the safety research program.
I don't think the author intended tMs tone, and it should be removed. The industry or EPRI programs in safety research for water cooled reactors are not adequately treated, particularly in the introductory material.
4.
The discussion of code development is inadequate.
I therefore conclude that regardless of the schedule, the paper must be rewritten in the respects I have indicated above. Detailed comments are attached.
In addition, the paper is poorly organized and skips around frem subject to subject. Moreover, it is not possible to tell within a subject what are recent research results, what are the author's ideas, and what are the plans for future research.
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J.//. - 4 n 1. wN;%, g Stephen H. Hanauer Technical Advisor to Executive Director for Operations
Enclosure:
Detailed comments on paper "NRC Water Reactor Safety R'. search Program" M 5160pMS
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DETAILED COMMENTS ON PAPER "NRC WATER REACTOR SAFETY RESEARCH PROGRAM" BY L. S. TONG Abstract line 12, delete " hypothetical."
Page 1, footnote, change "ERDA" to "NRC."
Page 2, the first paragraph is objectionable since it implies that only as a result of tne safety research program in the future will NRC have an objectively verified basis for the evaluation of.the applications.
This is certainly not true.
Information comes to the NRC from a variety of sources, one of which is the safety research program. Others include in particular the information furnished by licensees, which is required by law to be sufficient as a technical basis to justify the licensing action proposed. This paragraph must be rewritten to put the safety research in its correct perspective. Furthermore, it is incompatible with the last paragraph on this page which is a more modest and more nearly correct state-ment of the water research program.
Page 3, this material should be deleted entirely.
Its material is well known to the readers of nuclear safety. The author has no business expounding why we license reactors except in a context of how the safety research program is related to licensing. This subject is not, in fact, included.
Page 4.
The word " hypothetical" is used many wrong places. These accidents are not just hypothetical; they are part of a des'gn basis of the protection system and the engineered safety features.
Page 4, bottom. Here begin for the second time brief introductory material.
That is to say one first has an overall enumeration on the top of page 4.
One then has these brief introductions, and finally the detailed discussions of each subtopic start on page 10. This reader found this organization highly confusing. The principal topics of the article should be the principal headings of its chapters. Thase chapters should be numcered as well as titled so that one can tell what goes under what. The intro-ductory statements which start at the bottom of page 4 really could be the topic paragraphs of the individual chapters.
Putting them where they are now really chops the thing up.
The top of page 4 is the place where the author could relate the various principal research areas to some notion about reactor safety.
The idea of code development and experimentation going along hand in hand in a successive approximation is not well explained in this paper.
In fact,
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2 the code development is very effectively buried and hardly ever shows with the notable exception of the Fuel Behavior section. The inadequate discussion of code verification on page 33 does not make this point at all and is given only in the context of integral thermal hydraulic tests.
The whole discussion of codes and code development and code verification is in fact inadequate.
Fig. 4 should be explained and related to the discussion.
Page 5.
The end of the first paragraph describes incorrectly how NRC evaluate, license applications. The word " mechanistically" is especially objectionable.
I see no reason why the author should in a paper on safety research describe anything about how NRC evaluates license applications.
The bottom of page 5 sounds as though we know nothing about these important topics.
Table 1 should be deleted or related to the text in a more appropriate way.
I prefer deletion.
Page 9, the next to the last paragraph.
Figure 6 does not do as advertised.
It diagrams the research program, not eh possible behavior of the fuel rod.
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Nowhere is there any notion that the fuel rod might be undamaged.
Page 10. The first paragraph is a most unsatisfactory and inadequate dis-cussion of code verification, as suggested in a previous comment.
Page 10. The middle paragraph states incorrectly that this operational safety research is necessary to maintain the low risk.
I hope this isn't true, since very little of it is going on and that on a very extended schedule.
Page 11. Why the extensive discussion of a 1966 experiment?
Page 13. Where is analytical method development in this field discussed?
The bottom paragraph implies that there has been some, but no information is given.
Page 14 bottom. Radiation embrittlement and IGSCC make strange bedfellows.
The former would seem to go with the previous subjects (fracture mechanics and vessel failure), but the latter has no discernible relationship. Yet this paragraph mixes them up inextricably and a bit incoherently. For example, the last sentence in the paragraph (top of p.15) could go with
s 4
3 either subject from the context, but makes technical sense only for vessel failure, yet follows a sentence on IGSCC.
Page 16.
This is an almost incomprehensible mixture of subjects.
Page 19. This is pretty old stuff. Why repeat it?
Page 20. Are these new results? Textbook equations? The references range frcm 1947 to 1975.
Page 21. Are these recent new results? "This calculation is similar to an experiment" is absurd to me.
Page 23. The experiments (lines 1-2) are not just an afterthought, as implied here.
" is the Bloch paper spelled out instead of referenced (line 6-7)?
Page 31, line 12. Shouldn't " cooling of droplets" be " cooling of the surface by droplets?"
In line 15, I couldn't understand the last phrase in the context of this sentence.
Page 34.
I don't think L1-3A was a hot-leg break.
Page 34 bottom. The author wants to says here that NRC-RES is not in the business of proposing new ECCS designs. He should not say who is, since it may be industry (not just the vendors) or scme other governmental body.