ML19341A533
| ML19341A533 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1980 |
| From: | Jamarl Cummings NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | Ahearne J, Gilinsky V, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML19341A503 | List:
|
| References | |
| FOIA-80-516 NUDOCS 8101260282 | |
| Download: ML19341A533 (24) | |
Text
{{#Wiki_filter:. j [puscg 'o, UNITED STATES NUCLEAR REGULATORY COMMISSION 2.I II k. 3 ['. E WASHING TO N, D. C. 20555 June 11, 1980 gw MEMORANDUM FOR: Chainnan Ahearne Commissioner Gilinsky Commissioner Kennedy Commissioner Hendrie Commissioner Br ford ~ FROM: . ou n Offic of Insp or an uditor
SUBJECT:
V REVIEW 0F NRC'S PLAN FOR RESEARCH TO IMPROVE THE SAFETY OF LIGHT-WATER NUCLEAR POWER PLANTS Attached is our report resulting from a review of NRC's plan for research to improve the safety of light-water nuclear power plants. This review was conducted as a part of our ongoing audit of the research activities of the Nuclear Regulatory Commission (NRC). The purpose of the review was to detennine whether NRC was responsive to Public Law 95-209 dated December 13, 1977, which required a long-tenn plan to improve the safety of light-water nuclear power plants. In addition, it was equally important to detennine the status of the plan's implementation and whether there were any areas warranting improvement. The audit was conducted intermittently from April 1979 through November 1979 at NRC Headquarters with the primary effort being expended in the Office of Nuclear Regulatory Research (RES) and included a review of the: " Plan for Research to Improve the Safety of Light-Water Nuclear Power Plants," submitted to Congress in April 1978; References cited in the plan; Documentation used or generated in the preparation of the plan; Congressional hearings and reports for NRC authorizations and appropriations for Fiscal Year (FY) 1978 through FY 1980; and Advisory Committee on Reactor Safeguards reports. Contacts: A. Gauthier, 01A C. Kelley, OIA 49-27051 0101260 y Q
2
SUMMARY
'0F FINDINGS Our review disclosed that NRC's plan for research to improve the safety of light-water nuclear power plants was well formulated, considaring the . time constraints for the first submission to Congress. We found that: The' plan was generally well prepared and responsive to the Congressional mandate; references were correctly presented; selection criteria used in determining priority research topics were reasonable, meaningful and valid; and there appears to have been adequate a coordination in the formulation of the plan with the Department of Energy and other Government agencies; The pian did not contain a long-term assessment of research needs-- beyond a three-year period; RES's selection of topics to be researched was satisfactory; however, we believe the research projects, " Improved Methodology for Evaluating Research Topics" and " Scoping Studies," should be done in-house to the extent possible prior to contracting them out to the private sector; and The implementation of the plan h'as had only limited success. This has been caused by some internal problems and some circumstances beyond NRC's control. RECOMMENDATIONS The' report recommends that the Director, RES, take the following actions to improve this program and update the present plan: 1. Modify the plan to show greater emphasis on long-range applicability of the recommended projects; 2. Accomplish the recommended projects, " Improved Methodology for Evaluating Research Topics" and " Scoping Studies," in-house to the extent possible prior to contracting them out to the private sector; and 3. Seek advice and guidance from the Commission whenever there is an Executive or Congressional mandate. More specifically, Commission guidance should be sought if there are any major Congressional policy or direction changes for the plan.
The Comnission 3 AGENCY C0lil1ENTS in commenting on our draft report, the Directer of RES, with the concurrence of the EDO, agreed substantially with its contents, conclusions and recommendations, and advised us of his corrective action to each of the recommendations. A copy of the Director's, RES, response is shown in Appendix C to the report.
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4 o i TABLE OF CONTENTS ~ Page INTRODUCTION 1 ' SCOPE OF REVIEW 3 -FINDINGS 3 PREPARATION OF PLAN 4 ~ PLAN CONTENTS 5 l Responsiveness.to the Congressional Mandate 6 i 7 Sources of References and Suggestions Selection Criteria 8-i Selection of Research Projects 9 IMPLE!!ENTATION OF THE PLAN 11 Problems with OMB 12 Congressional Committee-Related Problems 13 Internal Difficulties 16 CONCLUSION 16 RECOM!iENDATIONS 16 AGENCY C0fiMENTS 17 APPEllDIXES A-ATTETIDEES, JANUARY 10, 1978 4 B-ATTEf1 DEES, FEBRUARY 10, 1978-C-!1E!10RANDUf1 DATED JUNE 9, 1980, FROM DIRECTOR, RES 's
INTRODUCTION The subryonic thrust for the development of a plan for research to improve reactor safety emanated from a Ford-Mitre report, " Nuclear Power, Issues and Choices," published in late 1976 or early 1977. This report was included in the hearings of the Senate Canmittee on Environment and Public Uorks on April 8, 1977. _ Included in the Ford-Mitre report was the following pr.agraph: ...We believe that in research and development more emphasis should be placed on actually improving safety as compared with . proving that reactors are " safe enough." The present government safety program, which is oriented toward the latter confirmatory approach, will ultimately narrow the range of uncertainty, but it is unlikely to reduce the probability of accidents. Steps should also be taken to ensure that the regulatory process does not inad-vertently create disincentives to impr vements in safety design... The inclusion of this report, particularly the above paragraph, generated interest in the Nuclear Regulatory Commission's (NRC) research program among the various Congressional committees. For example, in the hearings before the Subcommittee of the Committee on Appropriations, questions were asked as to how NRC could give additional emphasis to developing or verifying reactor safety systems of improved capacity. This question was asked of NRC because the Ford-Mitre study criticized the research programs as being heavily weighted in the direction of efforts to demonstrate that present designs are safe, with only minor efforts devoted to developing improved sa fe ty. The answer provided by NRC in effect stated that its emphasis in the research programs was in accordance with the definitions of the Energy Reorganization Act (ERA) of 1974--to provide confinnatory research for the regulatory process as opposed to the developmental functions. NRC further stated that as long as its research is carried out from the viewpoint of collecting applicable data and analyzing the potential improvements in the safety of various approaches, it would not consider this to be a violation of its charter. Developing detailed designs of safety features for use by the industry, however, would likely be considered beyond the proper responsibility of hRC. NRC further stated that if its charter were to be changed to permit both developmental and confirmatory research, a conflict of interest question could be raised because a regulatory agency would be involved in developmental activities. Any change in the research charter should be given careful consideration in detennining whether NRC or the Department of Energy (DOE) is the appropriate agency for conducting developmental research. i l i
2 Subsequent to these hearings, two Congressional reports were issued regarding NRC authorizations for Fiscal Year '(FY) 1978. In these reports, Congressional concerns were highlighted regarding the need for improved reactor safety and the role'NRC was to play in the development of any long-tenn plans. More specifically, the May 11, 1977, House Report considered the NRC safety research program to be deficient and authorized $4.5 million for an improved safety systems research program. It also contained a proposed change to Section 205 of the ERA to provide NRC with specific authority to sponsor research on new or improved safety systems to be incorporated into nuclear reactors. The Senate conmittee on Environment and Public Works-issued a report dated liay 16, 1977, which in effect stated that NRC had a positive responsibility to cake the initiative in the development of improved safety. The committee further stated that NRC's research has leaned toward confinning the adequacy of standards and regulations and has not been directed at developirig improved As a result, the committee stated that NRC research programs -systems. should be redirected and a more positive approach to the development of improved systems be taken by expanding its research efforts toward applied The committee believed that smch efforts would developmental research. increase NRC's capability for insuring the safe operation of existing and No infonnation, however, was contained in the emerging technologies. report regarding the cost of developing and implementing a plan for improved reactor safety research. On November 1,1977, the House / Senate Conference Report was issued finalizing the Congressional views regarding NRC authorization for appropriations. Included in this report were the conferees' views toward NRC's role in improved safety systems research. Specifically, the report called for an amendment to Section 205 of the ERA of 1974 providing NRC with the, authority to develop a long-tenn plan for projects for the development of new or improved systems for nuclear power plants. In addition, the conferees expressed the intent that the plan include a brief description of the projects, etc., and the time requirements for the initial and subsequent submissions of the plan. No specifics were contained in the Conference Report regarding the funds for this research even though the previous House Report recommended $4.5 million be authorized for this program. 13, 1977, Public Law 95-209 was passed authorizing appropriations On December to NRC. Included in the Public Law was an amendment to Section 205 of the ERA of 1974 for the development of a long-tenn plan; however, there were no funds cannarked for this purpose. In April 1978, NRC submitted to Congress its first plan, " Plan for Research to improve the Safety of Light-Water Nuclear Power Plants (NUREG-0438)." This plan included :n evaluation of concepts to improve safety and recounended a three-year, $14.9 million research program. The plan recommended that the following research tor ;s be undertaken: (a) alternate cnntainment ~ concepts; (b) alternate de ay heat removal concepts; (c) alternate emergency core cooling concepts; (d) improved in-plant accident response; (e) advanced scismic designs; (f) scoping studies of other concepts; and (g) improved methodology for evaluating research topics. I I~
3 SCOPE OF REVIEW As part of its ongoing review of NRC's research activities, the Office of Inspector and Auditor (0IA) completed its audit of NRC's plan for The research to improve the safety of light-water nuclear power plants. -purpose of the review was' to detennine whether NRC was responsive to Public Law 95-209 dated December.13,1977, which required a long-term plan to improve the safety of light-water nuclear power plants. In Laddition, it was equally important to detennine the status'of the plan's implementation and whether there were any areas warranting improvements. The audit was conducted intermittently from April 1979 through November 1979 at NRC lleadquarters with the primary effort ~being expended in RES and included: Discussions with appropriate RES officials; A review of NRC's " Plan for Research to Improve the Safety of Light-Water Nuclear Power Plants" submitted to Congress in April 1978; A review of all references cited in the plan; Examinations of documentation used or generated in the preparation of the plan; Examinations of all Congressional hearings and reports for NRC authorizations and appropriations for FY 1978 through FY 1980; and A review and analysis of related Advisory Committee on Reactor Safeguards (ACRS) reports. FINDINGS Our review disclosed that NRC's plan for research to improve the safety of light-water nuclear power plants was well formulated considering the time constraints for the first submission to Congress. We found that: The plan was generally well prepared; references were correctly presented; selection criteria used in detennining priority research topics were reasonable, meaningful and valid; and there appears to have been adequate coordination in the formulation of the plan with COE and other Government agencies; The plan did not contain a long-term assessment of research needs-- beyond a three-year period;
4 RES's selection of topics to be researched was satisfactory; however, we believe the research projects, " Improved Methodology for Evaluating - Resear ' Topics" and " Scoping Studies," should be done in-house to the extent possible prior to contracting them out to the private sector; and The implementation of the' plan has had only limited success. This has been caused by some internal problems and some circumstances beyond NRC's control. The details of our findings in each of the above areas follow: PREPARATION OF PLAN A Research Review Group (RRG) was formed to provide guidance in the preparation of the first report to Congress. The RRG, chaired by the Director of RES, was composed of nine high-level officials from RES and the Offices of Nuclear Reactor Regulation, Standards Development, and the Executive Director.for Operations. Most of the members had exteasive experience with some aspect of light-water reactor safety research. With only 120 days to submit its first report, it was extremely.important for RES to bring together a variety of-talents in an expeditious manner. In late December 1977 and early January 1978, these arrangements were consummated. Participants with differing nuclear backgrounds were drawn from NRC contractors, other Government agencies and industry to assist in the preparation of the plan. In addition, arrangements were made with Battelle Columbus Laboratories (BCL) to assist RES with a substantial portion of this task. The objective of Battelle's efforts was to evaluate the potential value and cost of improved safety concepts for light-water reactors. BCL was to prepare the initial draft report which would be the source document for review by the RRG participants and for submission to Congress. Further, an announcement was issued to the public that the RRG would be holding its first meeting on January 10, 1978. This release stated the purpose of the meeting and indicated that RES wculd be soliciting comments and suggestions from individual consultants. In our opinion, such a release was not only informative but also opened the door for a carte blanche invitation to the public sector to participate, at least indirectly, in the preparation of the plan. On January 10, 1978, 42 persons attended the meeting to discuss the merits of the proposed long-range research plan to improve reactor sa fety. Attending the meeting were representatives from NRC, DOE, ACRS and nongovernment sectors (see Appendix A). In addition to discussing the related merits of the proposed outline, the RRG solicited and received numerous suggestions for improving reactor aafety.
9 5 The second meeting was held on February 10,1978, with 43 persons in attendance.- The purpose of t'his meeting was to discuss the comments on the first draft for possible incorporation into the second draft. More specifically, the meeting was held to obtain comments on the draft plan, solicit suggestions for improving the plan, solicit suggestions for additional safety _research topics to be evaluated in the plan, and to discuss the validity of the criteria. The composition of those in attendance was basically the same as the first meeting (see Appendix B). The participants' comments were incorporated into the second draft of the plan which was submitted to the ACRS working group for review on March 3,1978. A third draft of the plan was prepared and sent to the Commissioners for approval to transmit the plan to Congress. The third draft was rewritten to reflect' comments from various reviews; however, the recommended ~ research projects were the same as presented to the participants and the ACRS in the second draft. The ACRS favorably reviewed the plan and supported the recommendations. The final version of the plan for research to improve the safety of light-water nuclear power plants was submitted to Congress on April 12, 1978. RES officials estimated that it took 2-3 man-years of effort to formulate and prepare the plan at an overall cost of $80,000 per man-year. The approximate cost of $200,000 includes the salaries and expenses of Government officials and consultants from the private sector. The above estimate, however, does not include the cost of printing nor distributing draft and final reports to the various participants. OIA believes the preparations were handled in an expeditious and efficient manner and that there was adequate cooperation and coordination between the RRG and NRC program offices. We have also concluded that the plan itself was administrative 1y well prepared. PLAN CONTENTS During our review of the plan contents, we focused our efforts on the detennination as to whether: The plan was responsive to the Congressional mandate (PL 95-209); The sources of references and suggestions were correctly presented and in the proper context; The evaluation and selection criteria were reasonable; and The selection of the individual research projects for immediate undertaking was satisfactory.
6 i l Responsiveness to the Congressional Mandate On December 13, 1977, Public Law 95-209 was passed authorizing an amendment to Section 205 of the ERA of 1974. Specifically, this bill required NRC to develop a long-tem plan for projects for the development of new or improved safety systems for nuclear power plants.- Although we found that the plan was generally responsive to the Congressional mandate, we do not believe it was completely responsive regarding the long-tem research plans for improved safety. In fairness to RES, the authorizing legislation did not define "long-tem plan for projects for the development of new or improved safety systems". On the surface it would appear the term "long-tem" is somewhat academic and could range from 1 to 20 or more years. In our opinion and from our review of Congressional hearings, we believe the Congress had something in mind longer than a three-year period. For. example, during hearings in 1978, the Director of RES was asked what the long-tem plans were for the loss of Fluid Test (LOFT) facility. The response provided was that the LOFT program was expected to continue through 1986, or a total of eight more years. Also in our discussion with other RES personnel, it became evident that the three-year time frame "in the plan" as presented was in effect a " starting period" and that a considerably greater amount of time would be required to carry out these projects. OIA believes, in any updated plan, greater emphasis should be placed on the long-range applicability of the recommended projects. The range of applicability should be expressed both in estimated funds and the time that would be required to adequately and thoroughly accomplish the tasks. In regard to other aspects of the mandate, the Conference Report, " Nuclear Regulatory Commission Authorization for Appropriations for Fiscal Year 1978," Report No. 95-788, November 1,1977, amplified NRC's new mandate as follows: The basic purpose of this research is the improvement of reactor safety and not the enhancement of the economic attractiveness of nuclear power versus alternative energy sources; The plan is to include brief descriptions of the projects which are proposed, the need for each project, a timetable for its implementation, the cost of the project, and other pertinent infomation; The Commission, in developing the plan, should coordinate with DOE or other agencies which are conducting similar efforts, and any other actions taken to implement such a plan should take into account related activities in progress at other agencies; and This plan is to be updated annually and submitted to the Congress by l February 1 of each year.
i 7 01A's review of the plan and supporting documentation disclosed that RES was responsive to the above requirements. In our opinion, the plan is for the improvement of reactor safety and not for the economic attractiveness of nuclear power. There tas adequate information in the plan describing the research projects and there was adequate coordination with 00E and other Government agencies.' Sources of References and Suggestions A systematic review was conducted by the RRG of recommendations published in several reviews and reports on nuclear reactor safety. Special attention was given to the recommendations of the ACRS and to comments provided by NRC staff members and the various outside consultants. Input into this plan emanated basically from eight major sources which provided 273 suggestions, remarks, or statements pertaining to safety and safety issues. The following exhibit shows the sources with the corresponding number of suggestions: Exhibit I Sources Number ACRS Reports / Working Group Meetings 48 NRC Staff Members 52 Individual Cor;ultants 113 American Physical Society Study 35 Group Report Ford Foundation Study 6 Emergency Core Cooling System (ECCS) 8 Acceptance Criteria Environmental Quality Laboratory Report 11 Total 273 Disposition of these 2'/3 suggestions was made by classifying them into con-firmatory research, developmental research, improvement-oriented research or licensing categories. u
8 Because of.the volume of suggestions, 0IA focused its review efforts on comments made by sources other than NRC' staff members. We, therefore, revice d. i all ACRS letters, reports, and minutes of meetings and all the written comments made by outside consultants and all referenced statements in the report. Our review disclosed that the suggestions or remarks cited by the various sources were included in the final report and were correctly presented. Selection Criteria In identifying research topics for consideration, the RRG applied the following set of judgmental criteria: Breadth of Support: Degree of consensus among the sources of suggestions for research as well as the technical expertise of the various sources; Risk Reduction: The risk-reduction potential of each concept, estimated principally on the basis of insight derived from the Reactor Safety Study; Generic Applicability: The number of existing and future plants in which the projected improvements could be implemented; this criterion included consideration of the possible times involved in implementation; and Cost: A rough estimate of the cost of implementing the improved concept or system. In evaluating a research topic, the above criteria were used by assigning values of high, medium or low, as applicable. The first criterion, breadth of support,.was weighted heavily in the selection process. Some topics were supported by only two sources, whereas others were supported by all seven sources. Judgment was exercised by the RRG in assessing the degree of consensus among sources and the technical expertise of the various sources. The second criterion, risk-reduction potential, was also weighted heavily in the selection process. In assessing this potential, the RRG considered the potential accident sequences in the Reactor Safety Study that were significant contributors to the overall risk reduction associated with the operation of nuclear power plants. The third criterion, generic applicability, was weighted less heavily than the previous two because of evaluation difficulties. Evidently this criterion covered more than one consideration. The principal one was the number of reactors in which research results could be inplemented; however, evaluation problems were encountered in reference to whether an existing plant could be backfitted because of varying designs. In some cases this criterion had a high generic applicability because the research results could be applicable to existing and future plar.cs.
e 9 The fourth criterion, estimated cost of implementation, was -not weighted heavily'in the overall selection of recommended projects because sufficient information was not available regarding precise costs for backfitting, replace-meat costs and downtime factors. DIA is-in general agreement with the four criteria; however, we believe it is - extremely important to keep the fourth criterion in the proper perspective. '~- Overemphasis of this criterion could and may be construed as being in conflict with Congressional direction. Our review of the Congressional hearings and reports disclosed virtually no data.egarding the aspects of the costs of implementation or whethee it should appropriately be a consideration when selecting research topic; to improve the safety of light-water nuclear power plants. Overall we belidve that the criteria are reasonable, meaningful and ~ valid. Selection of Research Projects Ultimately the previously mentioned 273 suggestions were categorized into sixteen major research topics for evaluation as follows: Nondestructive Examination and On-line lionitoring Improved Plant Controls -- Improved In-plant Accident Response -- Reduced Occupational Exposure -- Alternate Emercancy Core Cooling Concepts 4 -- titerffce Decay Heat Removal Concepts -- Alternate Containment Concepts -- Improved Reactor Shutdown Systems -- Reactor Vessel Rupture Control -- Core Retention Measures Equipment for Reducing Radioactive Releases l -- Advanced Seismic Designs Improved Plant Layout and Component Protection -- Protection Against Sabotage -- New Siting Concepts Improved Offsite Emergency Response Planning
V' t 10 These were then evaluated using the established criteria; however, only those projects that appeared to have the highest potential foi-improving the safety of nuclear power plants were recomme.nded for the initial research program. Five research projects were selected for immediate consideration as follows: Alternate Containment Concepts; Alternate Decay Heat Removal Concepts; Alternate Emergency Core Cooling Concepts; Improved In-plant Accident Response; and Advanced Seismic Designs. In addition to the above five projects, RES proposed that two additional projects be undertaken as follows: Improvement of the methodology for evaluating research topics and alternate plant designs and Scoping studies of the eleven additional research topics that were suggested but not selected for immediate consideration. The purpose of the research project to improve the methodology is to develop more objective and precise methods for making value/ impact assessments. More specifically the research would include: The development of methods for arriving at a reasonably quantitative way of evaluating the risk-reduction potential of proposed concepts to improve - the safety of nuclear power plants as well as the overall change in risk level that would be achieved by proposed changes if research results were to be implemented and The development of methods for combining various factors such as breadth of technical support, risk-reduction potential, generic applicability, and cost of implementation in a more quantitative formula for detennining value/ impact considerations. In the development of the final report, it became evident to the RRG and the consultants that some efforts should be devoted to improving the program evaluation methods so that the evaluation would be less judgmental, especially if the information and technology were available to improve the objectivity and precision of value/inpact assessments. The Chairman, ACRS, in a letter dated March 13, 1979, to Chairman Hendrie, strongly endorsed the need for improved methodology for evaluating projects and believed that it was es;ar.tial to the success of this new effort. He stated, however, that there will always be a large subjective or judgmental element in the selection of research projects and that selections should be made on a quantitative and as factual a basis as practical. l
11 The purpose of the scoping studies is to further identify new concepts worthy of research support, to determine which topics covered by NRC programs require additional research, and to obtain preliminary value/ impact analyses of the various alternatives proposed for improved safety. 0IA believes RES's _ selection of projects to be researched was satisfactory; _ however, r believe the research projects, " Improved Methodology for Evaluating Research.w..:s" and " Scoping Studies," should be done in-house to the extent possible prior to contracting them out to the private sector. Our belief is predicated on the besis that there is presently in RES adequate talent and resources to accom;'lish a preponderance of this work. IMPLEMENTATION OF THE PLAN Although the plan for research to improve reactor safety was well fomulated, RES has had limited success implementing it. This has been caused by some circumstances beyond RES's control and some internal problems. Dealings with the five Congressional committees and OMB are difficult at times in regard to the authorized and appropriated funds and have certainly caused some internal problems. In addition, sporadic Congressional interest, as well as the absence of guidance from the highest level of NRC managenient, has complicated the situation further.- As indicated earlier, during the formulation of the plan, suggestions for reactor safety research were consolidated into research topics which were examined against a set of judgmental criteria. After extensive evaluation of the merits of each research topic, seven research projects were recommended to be carried out. Af ter the plan was fomulated, RES officials prioritized the projects recommended by the plan. Subsequent to and in light of.the knowledge gained from THI, RES reconsidered the prioritization assigned to these projects. Nonetheless, even with the benefit of new insights derived from the TMI incident and other sources since the plan was formulated, the initial seven research projects still represented those topics most deserving of immediate attentior. Exhibit 2 shows the evolution of the priorities of the seven research topics as a result of the Plan for Reactor Safety Research (NUREG-0438) and post TMI, ACRS comments, the Lessons Learned Task Force (LLTF) and the Kemeny Commission.
mm 12 i Exhibit 2 IMPROVED REAC10R SAFETY EVOLUTION OF PRIORITIES Program Element Priority Post-ACRS, NUREG-0438 fost-TMI LLTF, Kemeny Alternate Containment 1 1 2 Alternate Decay '9at Removal 2 3 3 Improved Methodology 3 4 4 Improved In-plant Accident Response 4 2 1 Advanced Seismic Design 5 5 6 Alternate ECCS 6 7 7 Scopi'a Studies 7 6 5 In spite of the fact that top-level resources were utilized at an approximate 4 cost of $200,000 and their efforts resulted in an excellent plan, internal difficulties and problems with OMB and Congressional committees have plagued the successful implementation of the plan. The details of those problems follow. Problems with OMB The plan was submitted to Congress on April 12, 1978, too late for consideration in the 1979 budget process. However, the FY 1979 Authorization Act still authorized $1.5 million toward the implementation of the plan, but there were no funds appropriated for this purpose in that year. RES was able to begin work on ie plan in FY 1979 by reprogramming funds. RES requested $4.4 million for FY 1980 to be used toward implementing the plan; however, NRC officials were essentially unable to convince OMB officials that NRC should be carrying out the projects recommended by the plan. The Jiscussions with OMB offir.ials resulted in a reduction of the amount of ). ds being requested to 51 million. OM3's concern was that such projects would be putting NRC in the developmental research area and out of NRC's realm of responsibility. RES officials disagreed with OMB's position and questioned whether OMB officials understood the plan. The discussions with OMB resulted in OMB directing NRC not to undertake any hardware-oriented developmental research efforts under its reactor safety research program, adding that such efforts should be carried out by 00E. OMB further directed
13 4 i NRC not to do any reactor safety testing nor any ~ research that is experimental in nature. OMB also advised NRC that funds would be given to DOE for the purpose of carrying out reactor safety research projects for NRC-and instructed NRC to work with DOE to implement the plan. The Director, RES, infonned us that in accordance with OMB directives, NRC and DOE signed a programmatic agreement which chartered a,ioint coordination group for this work. NRC. developed,- documented and' nnt to DOE on February 6,1980, NRC's guidance for DOE's research on improved safety systems. However, when D02 requested $3 million in its FY 80 supplement to perfonn the research, OMB denied the request. OIA' believes these OMB-related problems caused delays for the implementation of the plan. Congressional Committee-Related Problems Although the plan was prepared in response to a Congressional mandate, our review of Congressional hearings, conferencc reports, and other related Congressional records disclosed that Congressional interest in the plan prior to, during, and after its fonnulation was sporadic. Additionally, our review of such documents for periods subsequent to the submission of the plan to Congress indicated a lack of enthusiasm for the reactor safety area, particularly prior to TMI. Congressional records for periods immediately following the TNI incident showed a surge in Congressional interest and enthusiasm about the plan and a number of questions were asked about the status of plan implemerdaticn. A review of more recent Congressional records indicated a drop in interest ir. reactor sefety. More importantly, financial support for the plan has been inconsistent, especially comparing the various authorization reports atJ the appropriation acts. Exhibit 3 indicates these in. consistencies. i Exhibit 3 AUTHORIZATIONS / APPROPRIATIONS Auth. Fiscal Year House Reports Senate Reports Conference Reports Act 1978 $4.5 1979 2.5 1.5 1.5 1980 4.4 1.0 Another problem exists when the funds authorized are different to those appropriated and definitized into an act. Where such a discrepancy exists, the office being granted the responsibility and the funds must explain to the Congressional committees why it is not carrying out tasks specified by the committee.
14 \\ ( In addition,. RES offir,ials Lelieve that reviews and assijnment of funds are at I too lcw a level, thus taking away RES's flexibility to use funds as needed within a program area. For example, even though improved reactor safety is a program area, the reviews and funding levels may reach below the program area to topics contained in the program, e.g., vented containments. Consequently, if user needs.or other priorities should change, RES would not have the ~ flexibility of reprogramming funds from vented containments to another' topic within the program area, e.g., alty nate decay heat removal systems. RES officials further stated that even in cases where a dollar value is mentioned in relation to a decision unit or a topic under a decision unit in Congressional hearings, the Controller's Office holds RES accountable to that dollar level even though neither the authorization nor the appropriation act sets such limits. RES officials do not feel they should be held to dollar limits that may have been mentioned, for example, in a conference report, but do not appear in the acts. In an effort to initiate selected research projects, RES officials sought to obtain funds from FY 1978 unobligated funds and by reprogramming FY 1979 dollars camarked for other purposes. After Commission and Congressional approval,$400,000 was given to RES in April 1979 to Legin plan implementation. This $400,000 has been obligated for a research project concerning vented containments being carried out by Sandia Laboratories. Another $400,000 froin reprogramming was obtained in August 1979 with Commission and Congressional approval after being rejected by Congress in May 1979. This $400,000 is being used to study better use of computers in reactor control rooms and to identify information the operating crew must have to understand plant status. These projects are being perfomed at Oak Ridge National Laboratory and Idaho N4tional Engineering Laboratory. Reprogramming funds requires Commission approval as well as the approval of five Congressional committees--three authorization (oversight) and two appropriation committees--and each committee has 90 days-to respond to the proposed action. Failure on the part of a committee to respond in 90 days gives approval of the reprogramming action. If the proposal is rejected and resubmitted as was done in the above instance, the calendar starts over at the time of resubmission. It took about four months to obtain approval of the reprogramming action. Exhibit 4 shows the time frames for both the unobligated funds and the reprogramming action. Another note of interest is that RES officials feel the authorization committees have deep doubts about nuclear power but are fair in providi1g funds for RES to carry out its mission. On the other hand, they feel the appropriations committees support nuclear power, but generally cut RES's budget in spite of their support. While we recognize that the majority of the aforementioned problems are not unique to RES, we can appreciate the fact that little can be done without adequate resources. Inasmuch as resources are limited, priorities must be established with due consideration of needs previously stated and programs already undemay. However, not perfonning a needed task may impede NRC's ability to carry out its regulatory responsibilities and impact upon public acceptance of the agency.
FY 1979 REPROGRAMMING ACTIONS i i CONG PRIOR YEAR > COM -+CONG >APPR ~* FIN PLMI FUNDS CURP.ENT > COM R I 5 YEAR CHANGES >CONG a 3CONG CONG Re.iected Thil >APPR g s C O Impicment V2) C3 weJ ha e) OCT NOV DEC JAN FEB MARCH APRIL MAY JUNE JULY AUG SEPT g DES U .1 e
f 16 Internal Difficulties In addition to the budget-related problems RES/NRC encountered with OMB and Congressional committees, internal difficulties, varying in nature, have also impeded implementation of,the plan. The 1978 Budget Authorization Act essentially- ~ altered Cor.nission policy which required RES to only engage in confirmatory resea 't The new charter extended NRC's role in research from being essentially confin.atory to one in which research efforts should also be directed toward projects which could improve the safety of reactors. The Congressional authorizations and appropriations were directed to the Commission for their implementation. The Commission had ample opportunity to participate in the development and implementation of the plan. In light of this, it would seem the formulation of the plan and the projects to be undertaken by NRC in the reactor safety area would have been Commission directed. We found no evidence that. guidance was either sought or provided by the Commission. In addition, it seems the plan was relegated to an RES, instead of an NRC, document in the early stages of its formulation. Further, there are indications that RES officials had to do a " selling job" to get other NRC officials to endorse the plan. We believe that if the Commission had been actively involved in the fonnulation of the plan in the early stages, many of the problems experienced in later months would ha,ve been eliminated, e.g., funding, approval of projects, etc. For example, even after the plan was submitted to Congress, NRC officials still raised some questions about whether NRC should be conducting some o^ the projects recommended by the plan. l'hatever problems NRC officials had with the plan should hava been worked out prior to the submission to Congress. In addition, internal cifficulties impeded plan implementation further when RES requested $1.7 million as a supplement to the FY 1980 budget and the request was disapproved by NRC, even though the plan estimated $14.9 million would be needed over a three-year period. CONCLUSION We have concluded from our review that NRC's plan for research to improve the safety of light-water nuclear power plants was well formulated and generally responsive to the Congressional mandate. However, the implementation of the plan has had limited success. We believe the Director, RES, should have sought Commission guidance prior to the formulation of the plan for research ~ to improve the safety of light-water nuclear power plants. RECOMMEWDATIONS We recormend that the Director, RES, take the fellowing actions as a means of improving this program and updating the present plan: 1. Modify the plan to show greater emphasis on long-range applicability of the recommended projects.
b i e o i ] \\ 17 -r i 2. Accomplish the' recommended projects, " Improved Methodology for Evaluating Research Topics" and " Scoping Studies," in-house to the extent possible prior to contracting them out to the private-sector. 3. Saek advice and guidance from the Commission whenever there is an Executive or Congressional mandate. More specifically, Commission guidance should be sought if there are any. major Congressional policy or direction changes for the-plan. ~ AGENCY COMf1ENTS In commenting on our draft report, the Director of RES, with the' concurrence of the EDO, agreed substantially with the contents, conclusions and recommendations, and advised us of his corrective actions to each of the recommendations. A copy of the Director's, RES, response is shown in Appendix C. 1 S l i l i l i
APPU; DIX A 1 I f ATTENDEES MEETING ON REPORT TO' CONGRESS January 10, 1978 Name Oroanization Gary Bennett NRC/RES Andrew J. Pressesky DOE /NPD Ronald M. Scroggins NRC/RES Charles Z. Serpan, Jr. NRC/RES W. Y. Johnston NRC/RES Andrew Bates NRC/ACRS Fred C. Finlayson Aerospace Corp. M. A. Taylor NRC/RES William R. Corcoran Combustion Eng. Ronald'Feit NRC/RES D. Dorfan UCSC Ian B. Wall NRC/RES Jerry Harbeur NRC/RES Anthony Buhl NRC/RES P. Norry NRC/RES A. W. SerkiZ NRC/RES Ronald B Foulds NRC/RES R. B. Borsum B&W D. J. McCloskey Sandia J. E. Richardson NRC/RES Raymond DiSalvo NRC/RES Jares A. Norberg NRC/0SD AIF/Sargent & Lundy John E. Ward Stan Fabic NRC/RES George Brockett Intermountain Tech. Carl J. Hocevar Energy Engineering Group Dale Bridenbaugh MHB Tech. Assoc. Donald H: Roy B&W M. Levenson EPRI S. Levy S. Levy. Inc. L. S. Rubenstein NRC/NRR ( S..H. Hanauer NRC/EDO Glenn*Sherwood GE Spencer Bush BNW Richard S. Denning BCL Jim Zane EG&G Tom Murley NRC/RES Warren Owen Duke Power Romand Salvatori Westinghouse Saul Levine NRC/RES E. S. Beckjord DOE cn rp my cg Tr a T. G. McCreless ACRS 0 -{g se e
APPENDIX g + ATTENDEES' February 10, 1978 Meeting d Name Title / Organization G. L. Bennett Chief, Research Support Branch, NRC T. E. Murley Director, RSR, NRC S. H. Hanauer Technical Advisor, EDO, NRC D. H. Roy Babcock & Wilcox Co. S. Levy S. Levy, Inc. J. O. Zane EG&G G. F. Brockett Intermountain Technologies D. Dorfan UCSC G. Sherwood General Electric C. J. Hocevar Energy Engineering Group D. Bridenbaugh MHB Tech. Assoc. N. M. Newmark Univ. of Illinois E. S. Beckjord DOE S. Levine Director, RES, NRC P. Strom NRC/ID F. Finlayson Aerospace Corporation L. S. Rubenstein Chief, Research Analysis, NRR W. Bixby DOE /ID E. H. Davidson Asst. Chief, Systems Engineering Branch, NRC C. Z. Serpan Chief, Metallurgy & Materials Branch, NRC I. Wall Deputy Director, Probabilistic Analysis Staff, NRC R. S. Denning Battelle M. A. Taylor NRC/RES/ PAS C. Jupiter NRC/RES W. A. Paulson NRC/NRR H. H. Scott NRC W. R. Corcoran Comb 0stion Engineering, Inc. T. G. McCreless ACRS Staff A. Adamautiades EPRI W. Owen Vice President, Duke Power Co. W. H. Beach NRC/RSR J. C. Landers NRC/ CON W. V. Johnston NRC/RSR R. B. Foulds NRC/RSR H. Kouts BNL D. J. McCloskey Sandia Laboratories J. A. Norberg NRC/OSD R. DiSalvo NRC/RSR l A. J. Pressesky NPD/00E J. E. Ward Sargent & Lundy/AIF S. Fabic NRC/RSR A. H. Spano NRC/RES R. Salvatori Westinghouse D "" D
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