ML19308C361
| ML19308C361 | |
| 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 | |
| ML19308C359 | List: |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001220835 | |
| Download: ML19308C361 (4) | |
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Q ;TECHN! CAL ASSOCIATESQ TECHNICAL CONSULTANTS ON ENERGYQ THE ENVIRONMENT
' lDate G;Bridenbaugh
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l1723 Hamilton Avenue-Suite K
^ Ricnard B[Hubbard San Jose, Caldornia 95125
._ Gregory C. Minot Phone:(408) 266 2716
- Augus t 28,11979.
.Mitchell Rogovin,sEsq.
p Director:
NRC/TMI -Special Inquiry. Group
. U; S. ~ NUCLEAR REGULATORY. COMMISSION Washington,-DC 20555 C
SUBJECT:
' Comments and -Suggestions Following SIG Meeting
' Augus t 15-16, 1979
Dear Mr. Rogovin:
The SIG peer review meeting of August 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.'rhanging, I decided to document my primary suggestions in this letter.
These suggestions involve several of the defined tasks of the SIG, so I.will attempt. to sort them by subject.
I COMMENTS RELATED TO GOAL OF SIG REPORT:
The I&E report, Lessons Learned, and EPRI reports on TMI read as very factual but sot,ewhat sterile documents.
In the spirit of an inquiry, the SIG report should delve
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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 doesn't need another sterile document; it needs to-have
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the touchy areas fully defined and exposed.
II-COMMENTS REGARD::NG THE ACCIDENT SE ]UENCE:
1.
Bill' Johnson's people have done an excellent job here, but the' area does not warrant much additional fine tuning.
The various accident sequence documents now in i
existenc'e are. in fairly good ~ agreement with SIG's sequence land additional effort may only serve as a manpower drain.
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.? 2.1 - Thelpeer:fgroup ' ~s sugges tion 1 of : annotating' the iaccident ? sequence l with supportive;-data such as :the. number
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(andyqualifications ~ of people"in ther control room as. a function'of stime!in chef sequence,: and the level? of reactor -
J scoolant in'the:Teore1 asea function ofethe~ time'in the-
. s equence(should : be pursue d. -
c 3 :.:.Thec"what_if"i questions :;and. discussions need to
- answerEmany..of
- the ' public Econcerns that the _ inquiry has :
not - con'sidered (or possibly. considered but not. disclosed) all the r dangers presented by - the f accident.
The "what'if"
~ analyses may be treated as 1 sensitivity analyses considering-e
- possible : additional. equipment failures or failures - of the Loperators to take certain actions (e.g., not. discovering -
- the closed' AFW valves throughout the - accident),- and the possibility of1further consequences, such as melting the control rods.and the core Jachieving recriticality.
4.
' The reactimeter" played.a-key role in - the posti-mortum of TMI-2, ' b'ut it was merely. fortuitous that such a
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device.was installed and operating at ' the time of this acci-
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dent.
The cost and complexity of adding - such a device is nominal and the presence 'of a "reactimeter" or " fight.
recorder" type: ofidevice on all reactors would-be a useful and helpfuliaddition to_ understanding transient' and accident t'
behavior ~6f reactors and operators.
I urge:you to include
- this as a SIG recommendation.
'III LCOMMENTS REGARDING 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.
- 2. _ The-training of operators is part of the review /
eport plan but _ the simulator design seems to 'have received
.only nominal attention.
The B&W simulator-is like Rancho
'Seco not,TMI-2'. - HowLdoes this affeet the operators'~ training Land - effe ctiveness ?
l3.
The' SIG group should consider the desirability of automating, functions.
This-. requires consideration of the
. deficiencies -of; reliance on computer. functions - as well as Lp'oss_ible; improvements;in the reliability of opervtions.
A major uncertainty of software-driven systems in.= fety. appli-
~ cations iisf the' problem of QA and security of the t oftware.
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. August 28,~1979
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'A9 recommendation'shouldLbe made for a Human Fact' ors, research program.to evaluate che1 effectiveness : and/or improve-ments. in. the - man-machine ' interface.
When there are quantira-ltive results-- available, the NRC should use these : to es tablish.
criteria for designiof. control rooms..in nuclear reactors.
IV COMMENTS"REGARDING NRC LICENSING' PROCESSES:
TMI has : shown that: the NRC has pla_ced an inordinate reliance ~on the R(assumed)~ impenetrable _ barriers.to radiation release',-- the -sufficiency. of : the single-failure; criterion, and:
1the : incredibility. _of the Class 9l accident.
The1NRC'should utilize.-a new licensing ' approach in1the 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 present-ly utilized.
At the present time, the NRC is-attempting to add more zero's to accident probability-numbers which are already. uncertain -in the secon'd 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 ti'me is spent-learning how to handle. the accidents that ~ are
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included ~in the design basis (DBA's).. There is presently no effective means of training beyond these DBA's.
The SIG report should address these problems.
V COMMENTS REGARDING PEER REVIEW GROUP PARTICIPATION:
l.
The peer group should be allowed to review the work of outside firms performing studies of the areas of interest (e.g., ESSEX Corp., con trol 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
'ould be meaningful and there is only a short time for such a review.
-There will be much - to lean from the Report of the President's
' Con ission.
Their recent ptQlic hearings indicated a good under-s tanding. of precursors to TMI, the ' effectiveness of procedures, and the role-'of the NRC.
Their recommendations'are likely to'be very strong.
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Sin ~ce : Dale l s c work 'will.: require him :to. be -;undvailable for ithe remaining months of the SIG(review,- -I?look forward: to con--
c tinuad participation onf theiPeer; Review) Group F Therefore, as -
. : an ; administrative matter, please ' address future '. correspondence -
- - to (me' ~ rather. than Dale.
Very[truly yours,
- /MEB - TECHNICAL ~ ASSOCIATES -
- Gregory C.. Minor lGCMike:
.cc:. George T. Frampton,1Jr., Esq.
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