ML19329C803
| ML19329C803 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/08/1975 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19329C786 | List: |
| References | |
| NUDOCS 8002190914 | |
| Download: ML19329C803 (5) | |
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.e Response to Congressman Mottl's statement that "The short history of our operation of nuclear power stations has been replete with malfunctions of the safety-related systems. Luckily, the public has not yet been subjected to a catastrophic accident."
There has been a continuing evolution of the nuclear industry during the fifteen years that nuclear power plants have been in com=creial operation.
(The Dresden 1 plant began co==ercial operation in 1960.)
Many advances in technology, engineering, and science have affected the regulatory process as well as the power plants licensed to operate.
Today, 47 nuclear power plants are in cotsmercial operation (another 7 are licensed to comcence operation). Through the years, the additional planta increased in size and conplexity to meet changini; requirc=ents and standards. However, during the entire history of the co=ncreial use, the protection of the public health and safety has been the fore-m at priority and goal of the Federal government and the industry.
The Nuclear Regulatory Comission uses a philosophy of ' defense in depth" to assure the protection of the public health and safety. Thia philosophy combines the principles of redundancy (multiplo syntama to perform the same function) and diversity (different methods of accom-plishing the name function) with systematic requirer.cata and control of the design, sinuf acturs, cenatruction, testing, operation, and corrective (or following) actions of nuclear power plants,
% 1:1p10 failures or malfunctions of safety systens or ccaponenta can be tolaratad because of a number of redundant s/stema or components designed to and capable of performing the aaro function or because of different typea or methods of accomplishing the same function. Be l
great majority of salfunctions reported to the laC concern single cal-function of conponents or parts of systeza, with redundant coepenenta or syntaes opersble and capable of performing desired functions. In cases where entire systcas were inoperable, redundant or diverse systems were usually available.
One of these systecatic procedures for regulating the industry has been to have the licensees report malfunctions of safety-related equipnent to the NRC.
The N3C evaluates each event to determine the safety implications involved. Because of the broad scope and low threshold of the reporting system, there appears to be a large number of reportable events per nuclear power plant. However, it is noted that the galorig of reports received from licensees Enclosure 4
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are ninor ir asture (with respect to having an impact on pu, ic health or safety),
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-ring the routine. periodic testing of the plant systems and components, and c.
are correctable iscadiately upon discovery.
~!hus, the reporting of a relatively large nimber of licensee events does not nacassarily reflect increased probability of adversa ispact on the health and safety of the public.
G en an avent is determined to have the potential for an impact en public health or safety, prompt action is required by the licensee to prevent actual impact from occurring.
Thus, it is not luck but conscious, determined, and regulated planning e.c manaaement attention throughout the nuclear industry and multiple levala of protection that prevent events at nuclear pcwcr plants from having an actual adverse impact on public health and safety. The probability of a catastrophic accident re=ains very low because of this procesa.
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Response to Congressman Motti's statement that "It cust be stressed that a large nuclear reactor accumulates an enormous amount of dangerous and highly toxic =aterials during nor=al operation, roughly 1-1/2 tons of such material, nearly one-fifth of which is gaseous or volatile. The detonation of the nuclear weapon over Hiroshima produced only about two pounds of these materials."
There is little basis for making a comparison between the radioactivity that is genersted during normal operation within a nuclear reactor and the radioactivity generated by the detonation of a nuclear weapon.
In the case of a nuclear weapon, the radioactive =aterials are rapidly dispersed into the atmosphere.
In the case of a nuclear reactor, the radioactive materials, the amount of which depends upon the length of time >.nd the power level at which the nuclear reactor is operated, are contained within sealed fuel elements. Multiple barriers are providea to prevent the escape of radioactive materials into the atmosphere, from whatever causes. The nuclear power plant is designed to withstand severe natural forces, such as earthquakes and tornadoes, as well as severe hypothetical accidents that are postulated to occur, without compromising the barriers in a manner that would endanger public health and safety.
Even in the case of a severe accident in which all the safeguards fail to work, such as a loss-of-coolant accident for which the emergency core cooling system fails to operate and the core celes down, it has been estimated (see WASH-1400, "An Assessment of Accident Risks in
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Commercial Nuclear Power Planta," issued in draft form, August 1974) that there would be on the average, less than one fatality and about
$100,000 of property damage. The probability of such a core melt-down accident has been estimated to be on the average of one every 17,000 years per plant.
Therefore, we see that even if the most severe nuclear pouer plant accident would occur, resulting in a core teltdown, the impact on public health and safety would be many orders of magnitude less severe than that resulting from the detonation of a nuclear weapon.
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- The nuclear inspection activities are pyramidal with cach layer of activity inspected or audited by the one above. The NRC's controlling position la i
at the apex while the great bulk of the inspection activity is perfor=ed by industry beneath this apex.
The NRC's inspections are directed prL:arily at detennining that the licensee's quality assurance program is implemented and effective. This is done by a series of periodic, preplanned, onsite inspections conducted by teama usually of one to three inspectors. On a sampling basis they observe work perfornance, interview employees, and review records. As described in Enclosure 1, NRC's Office of Inspection and Enforcement found that the problems at Davis-Eesse Jnit I resulted frem. the failure in the implementation of the Conpany's quality assurance program in thia area by relying too heavily on its contractors and subcontractors for quality assurance inspection without providing an adequate audit. Steps have Seen taken to correct this failure.
In general, following each inspection, the licensee is notified of sny apparent failuras to meet commitments contained in the application or in correspondence to the 4RC and of deviations frem appropriata cedes, standards, and regulatory guides. Resolution is necessary, prior to licensing for operation of the reactor, of all deviations identified.
.is described in Enclosura 1, VRC's Cffice of Inspection and Enforccuent has intensified its inspection effort at Davis-Besse Unit 1 because of the quality assurance proble=s identified thers. More frequent JRC innpections have been scheduled to review the Company's control of safaty-related conatruction work. One such inspection was made in lata July to check safety-rtisted piping. The inspectien tean did not find any significant deficiencies in the piping work.
The situation at Davia-Besse der.custrates that the existing inspectica program of 'CC does identify and bring about correction of quality assurance problers. The NRC currently has underway a study of its inspection program. The study vill examine the adequacy of the inspection program consistent with statutory requirements and resource 4
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dB,s n bl[ gub u Mnm Response to Congressman Mott1's statement that "I wish... to urge
- nore stringone inspections of this plant, the projected Ferry nuclear complex and all nuclear power plants aider construction."
The Office of Inspection and Enforcement believes existing :GC require-ments are sufficient to assure that the nuclear power plants under construction will be able to operate without undue risk to the health and safety of plant personnel and the general public.
The nuclear facility licensing and inspection program rests on the premisn that the licensee is basically responsible for the proper construction and safe operation of the nuclear power plant.
he total syste= for the inspection of nuclear facilities - involving both industry and gov 2rnnent -
provides for multiple levels of inspection and audit, pequirecents for licensees inspections and audita as contained in the NpC's regulatiens includes the following:
"A progra:a for inspection of setivition affecting quality shall be established and executed by or for the organization perforaina the activity to verify conforrance with the documented instructions, proceduros, and drawingr, for acconplishin?, tha activity. Such inspection shall be pcdor.cd by individuals other than those
~~ aminatiens, measure-who performod the activity Saing inspected.
x ments, or tests of materini or products proceased shall be perfor ed for each work operation where necessary to assura quality.
If inspection of processed esterial or products is 1.:possible or disadvantageous, indirect control by monitoring processing methods, equipront, and personnel chall be provided. Joth inspection and process monitoring shall be provided when control is inadequate without both.
If nandatory inspection held points, which require witnessing or inspecting by the applicant's designated represent-ative and beyond which verk shall not proceed withcut the ecusent of its desi,nated repressntative arc required, the specific hold points shall be indicated in appropriate doctments."
A comprehensive systers of plannad and periodic audito shall be carried out to verify compliance with all aspects of the quality sasurance program and to determine the effectiveness of tha prog ram. The audits shall be performed in accordance with the written procedures or check lists by appropriately trained personnel not having direct responsibilities in the areas being nudited.
Audit results shall be doeur.ented and reviewed by management having responsibility in the area audited. Followup action, including resudit of deficient areas, shall be taken where indicated.'
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