ML19291A503
| ML19291A503 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1976 |
| From: | Hanauer S NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Levine S NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| FOIA-79-109 NUDOCS 7905160360 | |
| Download: ML19291A503 (6) | |
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...a Saul Levine, RES REVIEW OF LMFBR SAFETY RESEARCH PROGRAM PLAN DRAFT DATED DECEMBER 15, 1976 At your request, I have reviewed the captioned draft plan, together with the draft "LMFBR Safety Technology Review-1976" recently received.
These documents go a long way toward delineating a research program directed toward LMFBR safety concerns, and they contain much useful information. However, I believe that the Program Plan can be and must be improved in the following respects:
1.
The Program Plan in its present form is much too vague as to just what the program contains. The " Ball-and-Arrow" Levels B and C Diagrams are tantalizing in their specificity, but when the reader looks for details in the writings, he finds mostly vague generalities. The few-word descriptions on the diagrams do not suffice by themselves, and the writeup is less than no help, in delineating the NRC procram out of what could be done - and likely should be, by smebody.
I believe the writeups should be made specific for each analytical or experimental task, giving in particular what comes out and where it goes; the diagram only shows an unspecified "use in licensing procass."
2.
Dependence of NRC proposed programs on ERDA programs or facilities should be made explicit, task by task.
3.
The introductory :naterial does not make it clear how NRC objectives and the NRC program differ from national or worldwide objectives and programs. Better delineation of the NRC program in the writeups (Item 1 above) would help but not cure this problem.
Inclusion of ERDA and foreign programs in the diagrams makes the task of separation harder yet.
The introductory material should clarify that this Program Plan is the NRC program, and give some idea how it fits the larger worl d.
4.
The lack of adequate discussion of users' needs (the material on pp 3-4 is totally inadequate) is a fatal defect in an NRC research program plan.
I recognize that this lack of discussion is evidence of the lack of user-defined needs, which mostly cme from outside RES.
79051603(oo l1- \\ R
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j Saul Levine, RES 2
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5.
The program needs guidance in the shape of event trees, I
etc., etc.; that is, systematic investigation of l
failure sequences. At this stage of development, it is at least debatable whether a Reactor Safety Study would be feasibly useful, or wise. But I don't think anyone l
disagrees with the desirability of setting up, in a disciplined way, the trees or sequences that allow assessment of the importance to safety of the various phenomena to be studied in research. This point was made strongly in Section 2.3.1.1 of "An Assessment of I
the ERDA LMFBR Safety Research Program," USNRC Staff, l
May 26, 1976.
(This document is incorrectly referenced l
in the Program Plan.
It was transmitted in a letter from Gossick to Fri on June 11, 1976. The SECY paper l
referenced was a draft, I believe.)
l The NRC Program Plan should be revised to include an NRC effort sufficient for NRC licensing and research needs.
i 6.
The heavy emphasis on CDA, in the introductory material I
particularly, reflectsan attitude I believe is already l
becoming obsolete. A great issue two years ago, a lesser one now - I predict that the difficult LMFBR licensing i
decisions will be in other areas, althcugh I do not predict that the CDA problem will go away. Compare reactivity transients in LWRs.
i 7.
The program is too optimistic. All the analysis is shown I
to be done by CY 84, for example, yet fuel and STF experiments are not much more than started and the first comercial breeder l
1s not yet licensed for construction.
In sumary, the Plan needs more work in important areas to improve its usefulness as a definitive statement of NRC programatic intentions.
Detailed c:nments are attached.
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Orisin:1 ci:--e 37 i
Stephen.~.. c.,n
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Stephen H. Hanauer Technical Advisor to Executive Director for Operations
Enclosure:
Detailed Comments cc: See next page
Saul Levine, RES 3
Os cc:
L. V. Gossick B. Rusche R. Minogue E. Volgenau C. Kelber T. Murley bec:
H. Ornstein L. Tong 1
DISTRIBUTION Central Files EDO RF SHHanauer RF TA ED0 SHHanauer:mc 12/ /76
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l DETAILED CCTEt1TS Page 1, paragraph 1 - This sets forth a national plan and not an.NRC plan.
i Page 1, paragraph 4 - These are infomation requirements frcm all sources. The principal information source is the protagonist of a licensing action, who must defend with technical data the technical acceptability of his proposal.
Page 2, 1 Both the PSAR and the FSAR are licensing applications and l'
both the CP and -the OL are licensing decisions.
Page 4, paragraph 1 - This seems much too vague to me.
There should be i
some discussion as to who was consulted, what questions were asked, and l
thus what questions are answered in this document.
Page 4, paragraphs 3 and 4 - The premise of this discussion is correct, but the conclusion does not agree with the correct premise.
If it took 10-15 years to work out generic safety issues, why are these generic safety issues going to be finished in 7 years? This is particularly noticeable with the analysis portion.
This discussion is therefore unrealistic since it does not include the analysis needed to go with the farther experimentation or the problems which are not foreseen today.
Page 6 - This table is not correct.
ERDA or the industrial protagonist of a licensing action must present sufficient data ta demonstrate its safety acceptability. in all respects. NRC does confirmatory research in various areas as required for the various purposes enumerated in recent studies. The functions actually tabulated could be ERDA or flRC functions depending on which side of this fundamental dividing line i
they fall on. The table should be redone entirely.
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i Page 8 - Figure 1 - The verification activity seems to be left off.
l Also, the " Evaluation and Acceptance" function may be at least in part a licensing and not a research function. The role of user needs and outsider judgment needs to be included.
I Page 11, bottom paragraph and its carryover on page 13 - This document l
was not really a user need or rather to be more precise was not entirely a user need.
It is incorrectly referenced, and it is not clear to me that the latest version actually transmitted is being used as a reference.
i I cannot emphasize enough the necessity of a real set of user needs.
The NRC assessment of the ERDA program is certainly not the same thing, although ERDA must supply the data required to substantiate ERDA applications.
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? age 16,1st paragraph - The evaluation model computer codes are the prerogative of Licensing and not Research. The code structure and method are developed by Research, but the specification of the evaluation model is not. Some notion of verification is necessary here also. The whole analysis task and program description neds to have this function put into it in a specified way.
I Page 17 - The top paragraph is a very poor description. One cannot tell l
what is to be done in this area by reading this material.
Page 17 - paracraph 2 - This treats only CDAs and core damage. A large fraction of 1 % *ing safety review is directed toward systems which prevent or forestall..ase events. An accident initiating phase study must be i
directed towards these events also. This is an example of overemphasis on the CDA in this whole program.
Page 18, top - The inclusion of experimental tests in this analytical program is peculiar and disruptive to the reader.
It may be done in this branch for administrative convenience, but the description, I believe, does not belong here.
Page 18 - middle paragraph - Is the "first"'or the "second" type of analysis being described in this program element? The reader can't tell. Again, the validation experiments don't belong in this analytical task, but the i
verification probably does.
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Page 18, bottom - In line 2, change LMFBR to LMFBR plant, and change
" failure" to " initiating event." The phrase " heat transport system" I
at the end of this line is too narrow.
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Page 18, bottom and continuation on page 19, treats very advanced goals 3
which are not needed forall or even most systems evaluation. A large j
fraction of the systems work can be done with less detailed single j
dimensional methods.
I do not have a high hope of developing any time soon (seven years) the class of code capability which is described in this paragraph in any extensive way.
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" Analysis" diagram following page 19. My comments on this diagram are typical of those on others. The " output to regulatory process" milestones are verj important. They should show semehow either on the diagram or another place just what is it that the regulatory process gets at this point in time from this program. Similarly, the infonnation needed frcm other programs needs to be shown even in the fairly cryptic form. The I
more detailed level C schedules at the end of the report are somewhat helpful in this respect, but do not show these interactions as well as they could be.shown.
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3 Page 20 - Objectives - These are the objectives of the national program and are in fact an extremely broad and comprehensive set of worldwide objectives. Some distinction must be drawn between them and what the NRC program objectives must be.
Page 20, bottom - Some notation of information racds and user needs should be included.
Page 21, top
" Identification of key safety issues" is an extremely important function which I do not see any significant program effort directed toward in t" ' whole paper.
"Cafety Test Facility" diagram following page 22 - This is too simplified a
to be much use.
Page 25, top - Material like this, somewhat more specific, is what I look for in vain in most program elements.
It is still not exactly clear just what the tasks are in the NRC program.
Pages 31 and 32 - This description is so general and cryptic that it tells i
one practically nothing.
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