ML19308B993
| ML19308B993 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/28/1979 |
| From: | George Minor MHB TECHNICAL ASSOCIATES |
| To: | Rogovin M NRC - NRC THREE MILE ISLAND TASK FORCE |
| Shared Package | |
| ML19308B994 | List: |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001170736 | |
| Download: ML19308B993 (4) | |
Text
OI B4 TECHNICAL ASSOCIATES C~^~Y 999 TECHNICAL CONSULTANTS ON ENERGY & THE ENVIRONMENT
~
l Dale G. Bridenbaugh 1
1723 Harnillon Avenue-Suite K Richard B. Hubbard D
San Jose. California 95125 Gregory C. Minor Phone: (408) 266-2716 Augus t 28, 1979 Mitchell Rogovin,"Esq.
Director NRC/TMI Special Inquiry Group U.S. NUCLEAR REGULATORY COMMISSION Washington, DC 20555
SUBJECT:
Comments and Suggestions Following SIG Meeting August 15-16, 1979
Dear Mr. Rogovin:
The SIG peer review meeting of Augus t 15 and 16, 1979 was quite productive.
It offered me and the others a good opportunity to review the plan and report outline and resulted in numerous questions and suggestions being raised.
Because the audience was frequently changing, I decided to document my primary sugges tions in this letter.
These suggestions involve several of the defined tasks of the SIG, so I will attempt to sort them by subject.
I CO'9ENTS RELATED TO GOAL OF SIG REPORT:
The I&E report, Lessons Learned, and EPRI reports on TMI read as very factual but somewhat sterile documents.
In the spirit of an inquiry, the SIG report should delve into the touchy areas such as the "what ifs," the question of the NRC's role, the effectiveness of the Commissioners' involvement, the precursors to TMI---heeded or ignored, the uncertainty o'f who's in charge during a nuclear plant accident, and the question of who's in charge of radiation monitoring during an accident.
In my opinion, the nation i
I doesn' t need another s terile document; it needs to have the touchy areas fully defined and exposed.
l II COMMENTS REGARDING THE ACCIDENT SEQUENCE:
1.
Bill' Johnson's people have done an excellent job here, but the area does not warrant much additional fine l
tuning.
The various accident sequence documents now in existence are in fairly good agreement with SIG's sequence and additional effort may only serve as a manpower drain.
8001170 7 3 ( f
' Mr. Rogovin Page Two August 28, 1979 2.
The peer group's suggestion of annotating the accident sequence with supportive data such as the number and qualifications of people in the control room as a function of time in the sequence, and the level of reactor coolant in the core as a function of the time in the sequence should be pursued.
3.
The "what if" questions and discussions need to answer many of the public concerns that the inquiry has not considered (or possibly considered but not disclosed) all the dangers presented by the accident.
The "what if" analyses may be treated as sensitivity analyses considering possible additional equipment failures or failures of the operators to take certain actions (e.g., not discovering the closed AFW valves throughout the accident), and the possibility of further consequences, such as melting the control rods and the core achieving recriticality.
4.
The "reactimeter" played a key role in the post-mortum of TMI-2, but it was merely fortuitous that such a device was installed and operating at the time of this acci-dent.
The cost and complexity of adding such a device is nominal and the presence of a "reactimeter" or " fight recorder" type of device on all reactors would be a useful and helpful addition to understanding transient and accident behavior of reactors and operators.
I urge you to include this as a SIG recommendation.
III COMMENTS P2GARDING_ HUMAN FACTORS:
1.
The ESSEX study is an impressive program but may be too extensive for the amount of actual operating data that is available.
l 2.
The trai<ning of operators is part of the review /
report plan but the simulator design seems to have received only nominal attention.
The B&W simulator is like Rancho Seco not TMI-2.
How does this affect the operators' training and effectiveness?
3.
The SIG group should consider the desirability of automating functions.
This requires consideration of the deficiencies of reliance on computer functions as well as possible improvements in the reliability of operations.
A major uncertainty of software-driven systems in safety appli-cations is the problem of QA and security of the sof tware.
/
o
. Mr. Rogovin Page Three August 28, 1979 4.
A recommendation should be made for a Human Factors research program to evaluate the effectiveness and/or improve-ments in the man-machine interface.
When there are quantita-tive results available, the NRC should use these to establish criteria for design of control rooms in nuclear reactors.
IV COMMENTS REGARDING NRC LICENSING PROCESSES:
TMI has shown that the NRC has placed an inordinate reliance on the (assumed) impenetrable barriers to radiation release, the sufficiency of the single-failure criterion, and the incredibility of the Class 9 accident.
The NRC should
,/
utilize a new licensing approach in the future ; one that admits the possibility of Class 9 accidents and reviews the actions to mitigate the accident.
This is a totally different approach that is presently utilized.
At the present time, the NRC is attempting to add more zero's to accident probability numbers which are already uncertain in the second or third digit.
Most of the operator training time is spent learning how to start up, run, and shut down the reactor and a nominal time is spent learning how to handle the accidents that are included in the design basis (DBA's).
There is presently n,o /
effective means of training beyond these DBA's.
The SIG V
report should address these problems.
V COMMENTS REGARDING PEER REVIEW GROUP PARTICIPATION:
1.
The peer group should be allowed to review the work of outside firms performing studies of the areas of interest (e.g., ESSEX Corp., control room mock-up).
2.
There is no need for the report to include comments by the peer group since only the comments on the Final Draft would be meaningful and there is only a short time for such a review.
There will be much to learn from the Report of the President's Commission.
Their recent public hearings indicated a good under-standing of precursors to TMI, the effectiveness of procedures, and the role of the NRC.
Their recommendations are likely to be very strong.
l 1
Mr. Rogovin Page Four Augus t 28, 1979 Since Dale 's work will require him to be unavailable for the remaining months of the SIG review, I look forward to con-tinued participation on the Peer Review Groupi Therefore, as an administrative matter, please address future correspondence to me rather than Dale.
Very truly yours, MHB TECHNICAL ASSOCIATES Gregory C. Minor GCM:ke cc:
George T. Frampton, Jr., Esq.
i
_ -.