ML19318C304
| ML19318C304 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/25/1980 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Berhero R, Harold Denton Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| NUDOCS 8007010329 | |
| Download: ML19318C304 (4) | |
Text
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BALTIMORE GAS AND ELECTRIC COMPANY P. O. BOX 1475 BALTIMORE, MARYLAND 21203 i
1 June 25, 1980 AmTHun E.LuNOVAu,JR.
v.cc P.ssiose s v..o Office of Nuclear Regulatory Research U. S. Nuclear Regdatory Co:smission Washington, D. C.
20555 Attn:
Dr. Robert Bernero, Director f
Probabilistic Analysis Staff Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attn:
Dr. Harold R. Denton, Director
Subject:
Calvert Cliffs Nuclear Power Plant Unit No. 1, Docket No. 50-317 Interim Reliability Evaluation Vrocram
Reference:
NRC letter dated 5/23/80 from D. G. Eisenhut to IREP Participants, same subject.
Gentlemen:
The referenced letter informed us of the NRC's intention to conduct an Interim Saliability Evaluation Program on a cross-section of operating plants as the second phase of a three-phase effort to develop and implement probabilistic techniques for overall assessment of risk to the public health and safety from core damage accidents. The letter confirmed earlier indications from NRC that Calvert Cliffs Unit No. 1 would be asked to participate in the program.
l A meeting was held on June 12, 1980 by your Staffs with the prospective licensee participants to discuss the concept and objectives of the Program. We agree wholeheartedly with the concept of using proba-bilistic techniques for risk assessment and of applying those results to the regulatory process, both during the design review phase of plant licensing and during the operational phase with due regard to appropriate value-impset assessments. We firmly believe that all parties concerned - the public, the licensees, and the regulators - can benefit from such an approach that is well-planned and has the cooperative participation of both the licensees and the NRC. However, we have several basic concerns with the Interim Reliability Evaluation Program as it was outlined in our June 12, 1980 meeting with members of your Staffs. These concerns are enumerated below.
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Messrs. Bernero & Denton June 25, 1980 1.
Schedule. The propcsed schedule for the progrea seems to be unrealistically compressed.
It.any be possible to conduct an evaluation of a specific plant in six months assuming the method-ology is clearly understood by all parties and has been developed and tested. To attempt to develop a methodology concurrent with obtaining meaningful results and to do so with the full participation of licensee representatives, who are basically unfamiliar with the detailed program objectives and the possible types of methodology, is overly ambitious. Assuming completion of the program in this case, ve are concerned that it would be at the expense of licensee understanding and participation, and that the results may be inconclusive and ambiguous because of time restrictions imposed on program development.
2.
Methodolorf. The actual methods which vill be used to initiate the program might apparently be drawn from experience at Crystal River or they might come from other sources. While ve are not yet experts in risk assessment techniques, ve do_ recognize that there are many vsys to approach the task. It was indicated at our meeting that a " cookbook", which includes the basic methodology and assumptions upon which the entire program depends, vould be developed as the program progressed, keeping about a month ahead of the actual program. The schedule, we vere told, does not allow time for licensee input into the development of the " cook-book".
We do not believe the results of the program vill be meaningful without significant licensee participation in develop-ment of assumptions and methodology.
3 Timing. There is, as you know, a great deal of activity nov l
taking place at all operating plants in response to tha lessons learned at TMI-2.
This activity includes such things au major modifications to auxiliary feedvater systems, changes to emergency power systems, control room changes (human factors engineering),
operator training upgrades, the procurement of plant-specific simulators to improve operator response, and the like. These factors and others can and vill have a major impact on system and operator response, and their impact on the results of the IREP must be just as great, assuming all of these changes are being made to enhance overall safety. In some cases, NRC has not had the manpower necessary to review design changes being made, and it would seem appropriate to delay the start of the IREP until all of the TMI-related modifications are at least reviewed so that final designs can be factored into the IREP data i
base.
h.
Licensee Participation. We are concerned that the party coming out of the IREP at the end with the least total contribution and the least understanding vill be the licensee. The verve with which the NRC's Probabilistic Analysis Staff has described the conduct of the program has us concerned that they may charge off and leave us dragging along behind in the dust. To this end, licensees may want to have an outside consultant provide guidance and/or review services.
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Messrs. Bernero & Denton June 25, 1980 5
Reculatorv Ratcheting. The close involvement of the NRC's Licensing Staff in the IREP makes it clear to us that the 1
possibility exists of short notice changes to licensing require-ments. Even though the IREP has been described as a "research program", we all know that, as time goes on, the results of this research vill become more and more concrete as a foundation for licensing changes. The spirit of cooperative research and learning with which the program is conducted vill likely be replaced by regulation based on the resulting numbers, which in fact may have little real basis because the assumptions and methodology were arbitrarily chosen by the Staff. Further down the road, assumptions and agreements made in the early stages of this "research" may well be forgotten as NRC personnel changes j
occur, as they frequently do.
For all of these reasons, we do not believe either the Staff o:-
the licensees involved vill benefit significantly from the IREP as it is nov planned; the program cny in fact result in negative effects. We strongly recomend the folleving changes:
l 1.
Provide for licensee input into the methodology and assumptions l
to be used. This includes time for substantive peer re riev and coment of the Crystal River study, and licensee review and comment of the " cookbook", with fomal resolution of all concerns l
and co=ments prior to beginning the program. To this end, it may i
be beneficial to have a meeting once the final version of the groundrules is drafted to ensure that all of the participants have a basic knowledge of and agreement on the methods to be utilized.
2.
One of the NRC's admitted main objectives of the program is to l
meet the (arbitrary) schedule. This constraint should be greatly i
deemphasized, and the program tied instead to reasonable develop-j ment and implementation of a meaningful program. We feel strongly that a Spring 1981 completion date is unattainable with any meaningful results, and that the program should allow for a Fall 1981 completion date or later if the need for such an expansion of the schedule is indicated.
3.
Schedule periodic check points in the program which provide specific and ample time for review of the project to that point, and allow for consideration of possible changes in direction, scope or method as a result of review of the experience of other IREP plants and of other studies proceeding concurrently, such as the l
NSAC study of Oconee.
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Messrs. Bernero & Denton k-June 25, 1980 i
We are certain that you share our_ desire to make the Interim Reliability Evaluation Program as meaningful and beneficial as possible to all concerned. To this end, we request the opportunity to discuss the resolution of these concerns prior to finalizing our plans for participation in the Program.
Very truly s,
&.a- - - -
f, ec:
J. A. Biddison, Esquire G. F. Trowbridge, Esquire Messrs. E. L. Conner, Jr. - NRC Dr. M. L. Roush, U of MD D. K. Davis - TERA G. D. Baston - Northeast Utilities W. T. Craddock - AP&L i
J. A. Raulston - TVA l