ML19347F592
| ML19347F592 | |
| Person / Time | |
|---|---|
| Issue date: | 05/18/1981 |
| From: | Hendrie J NRC COMMISSION (OCM) |
| To: | Bray A GENERAL ELECTRIC CO. |
| Shared Package | |
| ML19347F593 | List: |
| References | |
| NUDOCS 8105220015 | |
| Download: ML19347F592 (9) | |
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/1 dl UNITED STATES E
NUCLEAR REGULATORY COMMISSION L'
- E WASHIN GTON, Dr. 20555
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OFFICE OF THE May 18,1981 CHAtRMAN Ylv%
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3 Mr. A. Philip Bray Vice President & General Manager g
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'S General Electric Company Ao
r 175 Curtner Avenue San Jose, California 94125 V er e
k Dear Mr.
ay I am in receipt of your letter of April 16, 1981, in which you address the NRC report on " Safety Concerns Associated with Pipe Breaks in'BWR SCRAM Systsms".
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As you are aware, the report was developed by the Office for Analysis and Evaluation of Operational Data (AE00), under their charter to perform independent evaluations of operational experience which could be signifi-cant in terms of the potential impact on 'public health and safety.
A summary of associated e!ents is enclosed.
Under the circumstances described in the staff enclosures I see no improprieties in the p'rocedures surrounding the release of the report.
Preparation, publication, and release of the report was handled in a manner similar to the release of previous reports by the Office of Analysis and Evaluation of Operational Data.
Release was not prenature., neither.
was it inappropriate to identify a potential safety problem subject to further resolution in concert with interested parties.
The NRC has, in the past, taken a position of independence, openness, and candor in carrying out its regulatory mandate and expects to continue this policy in tho future.
Further, any allegation of " leaking" to the press does not hold up in view of the dates and actions cited in the enclosures.
Insofar as the technical merit of the report is concerned, the likelihood of the event and the sufficiency of corrective action are matter.s which must be properly pursued with GE and licensees.
In that regard,.the Office of Nuclear Reactor Regulation has asked, under 10 CFR 50.54(f), for further information on both a generic and a licensee specific basis.
Meanwhile, NRR's initial evaluation, which is in consonance with AE0D's original recommendation, is that no immediate corrective action is required to alleviate safety concerns.
810522o0/f
Mr. A. Philip Bray.
In conclusion,'I believe that AE0D acted entirely correctly in this matter.
- S ncerely, ose M. Hendrie Chai n
Enclosures:
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Background Events Related to AE00 Report 2.
AE00 Policies & Procedures
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. Relating to Case ^ Study Reports e
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BACKGROUND EVELTS P, ELATING TO AE0D REPORT ON SAFETY CONCERNS ASSOCIATED WITH PIPE BREAKS IN THE BWR SCRAM SYSTEM
Background
The recent AE00 report addressing the potential consequences of a pipe break in the BWR scram system is an outgrowth of previous AE00 reports.
In fact, the general concern regarding the ability to isolate a leak in this system was addressed in the AE0D report issued July 31, 1980. The context or concern at that time was the possibility of fa.ilure of the vent or drain valves.
Should either of these non-redundant valves fail in conjunction with a leaking or open scram discharge valve, there would be a leak outside primary containment.
The present report extends this concern to include the possibility of pipe breaks, and examines in additional detail the potential consequences which we believe -have not been thoroughly addressed before.
March 10 ACR3 Meeting The first public disclosure of the specific concerns highlighted in the subject ( April 3,1981) report was on March.10,1981 during the ACRS Subcommittee Meeting on Reactor Operations. This meeting dealt with Congressman Udall's ATWS concerns prompted by the Browns Ferry 3 partial failure to scram event of June 28, 1980. The entire day was dedicated to the BWR scram function and focused almost entirely on the Browns Ferry event.
This meeting was prenoticed and open to the public. Although the meeting clearly concerned GE, the draft minutes of the meeting did not show any GE representative as attending.
lne agenda for the meeting was to review all phases of the Browns Ferry l
event. A considerable portion of the meeting dealt with the findings, recommendations and actions of AE00, NRR, and IE. These were presented by representatives of the various offices. Since the subject report reflected the most recent findings and was of a different nature, it was presented last. The transactions of the entire meeting appear in a published transcript.
l The AE00 presentation on the postulated pressure boundary failure in the scram discharge system starts on page 431 of the transcript. The speaker was Stuart Rubin who prepared the report. The presentation was based on a draft copy of the subject report as it stood at that time, but edited for oral presentation.
Part way through the presentation, an ACRS member indicated that time was short and a summary was desired. A summary was given in lieu of completing the full presentation, but all essential concerns were carefully disclosed by Mr. Rubin.
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. The only extensive comment received from the ACRS was a request to consider the probability of the situation and to prepare a quantitative estimate.
This.was subsequently done and added to.the subject report as Appendix A.
NRC Distribution and Contacts Af ter the ACRS meeting, additions and refinen)ents in the re; ~ ct were completed and the report was finalized.
In order to infom NRC manageme'.t of the impending release of the report, a brief description and summary was prepared and forwarded as the AEOD portion of the " Weekly Infomation Report" for the week ending March 27, 1981.
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In order to provide other NRC offices with an advanced copy of the report, a personal note to Harold Denton was sent on Monday (March 30) enclosing a copy of the report and indicating that the report would be signed and released on Friday ( April 3). Two additional copies of the report were also distributed to NRR staff via copies of the note to Mr. Denton. One additional copy was sent at the same time (March 30) to the cognizant staff member in IE.
The distribution made on March 30 were the first copies of the report to leave AE0D.
The only feedback received as a result of tssuing the advanced copies was a call from NRR on April 2 expressing a concern about having a potential problem without a readily apparent recommendation for solution. Al though this concern was considered valid, since the report was completed, an obligation was felt to release it in fulfillment of AE0D's responsibility to report in a timely fashion on matters which may have a potential impact cn public health and safety.
Consequently, the subject report was signed out on Friday, April 3.
A xerox copy was given at that time to the local GE representative at his request. No other distribution was made. The document was then sent to reproduction.
On Monday morning, April 6, the copies were assembled for distribution including the public document room.
Contacts with the Press At 9:30 am on Monday (April 6), Carl Michelson received a call from JoAnne Dann of Inside NRC concerning what work AE0D might be doing on the Aircraft Safety Reporting System ( ASRS) and the PWR pressurizer block valve problem. After briefly discussing these subjects, she asked if AE0D had any new reports.
Mr. Michelson mentioned the subject report which was signed on Friday and noted that copies would be available soon in the PDR. She bemoaned the problem of finding information in the PD1 so as a gesture of goodwill, Mr. Michelson offered to give her a copy, aqd she indicated someone would pick it up. A messenger picked it up about nooa time.
. At 10:00 am on Monday Mr. Michelson received a call fram John Emshwiller of the Wall Street Journal.
(Mr. Michelson's only previot s contact with Mr. Emshwiller was in August or September 1980, when he called concerning an investigation by the Limestone County Alabama District Attorney into some purported acts of sabotage at Browns Ferry which were reported as LERs during February 1980.)
Mr. Emstwiller opened the conversation by relating that he had heard from his " sour'." that AE00 was issuing a report concerning Browns Ferry and was wondering if Mr. Michels.or could tell him something about it.
Since the report was already issued and was in the process of distribution, Mr. Michelson discussed it with him. This conversation was consistent with past AE0D policies to respond to inquiries from the press and provide reasonable help to ensure a proper understanding and, thereby, factual reporting to the public. However, as a matter of policy AE0D has not and does not initiate such calls to the press.
Mr. Michelson discussed the subject report for about ten minutes in general terms since Mr. Emshwiller did not appear to grasp the details. He asked some-logical -questions which indicated that he had a reasonable understanding of what the concern could be. However, none of his questions or comments indicated that he had any previous knowledge gained from viewing or reading the subject report. To the contrary, some of his qudstions would have been self-evident if he had seen the figures'in the report.
After the conversation, Mr. Michelson gave him permission to be qu'oted in his article, but only with the understanding that he check back if any important points remained unclear. Mr. Michelson also volunteered to send him a copy of the report and this was done on Tuesday ( April 7). No other calls were received from the press on Monday.
On Friday, April 10, Jack Heltemes and M. Michelson placed a call to Mr. Emshwiller to verify his involvement.
Mr. Emshwiller confirmed that his previous contact with Mr. Michelson was last Fall and that there were -
no other contacts prior to Monday, April 6.
He indicated that his reason for calling Mr. Michelson on Monday was because his " source" or " sources" indicated that AE0D may be issuing a report on a Browns Ferry problem.
f He did not wish to identify his " sources" without first checking to verify l
that it was acceptable to do so.
He did verify that Mr. Michelson was not his source.
Responding to a direct question, he indicated that he had never l
seen or read a copy of the report and that he had not yet received the copy which was sent to him on Tucsday.
l Other Outside Contacts Most of the engineering evaluations and case studies performed by AE0D have required various sources of information, including the licensees and NSSS vendors such as GE.
In the case of the Browns Ferry event and related studies,
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GE was contacted on several occasions by the AE0D staff concerning various l
aspects of the event, but no overall or organized presentation was made to GE regarding the concerns.
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. From time to time, Mr. Michelson has had conversations with various Congressional committee staff members concerning the kinds of work and studies AEOD is doing and how the office is progressing -- in view of their special interest in and support for the office. However, at no time have AE0D reports been released to or read by such individuals until after they are signed and publicly available.
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Mr. Michelson has also contacted INP0 and hSA'C from time to time, but did not raention or discuss the subject repo,rt with them.
If the proposed Memorandum of Agreement had been signed, however, discussion in advance of public distribution could have been anticipated since the proposed agreement calls for sharing of " ongoing work" of interest to both parties. As part of the normal distribution, copies of the subject report were sent to INP0 and NSAC on April 7.
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AE00 POLICIES AND PROCEDURES RELATING TO CASE STUDY REPORTS AEOD Charter At the request of the Commission, a charter for AEOD was prepared, extensively coordinated and reviewed by the staff, and submitted to the Chairman on August 14, 1980 with a' copy to the Public Document Room (PDR). The assigned specific tasks and activities include the systematic and independent analysis and evaluation of operational experience.
AE0D is instructed to develop and maintain an in-house capability for expert independent analysis and evaluation work.
It is also instructed to, " Perform an independent, in-depth analysis and evaluation of any e ent or situation when AE00 determines sucn analysis and evaluation is warranted."
It is asked to, " Provide a report to appropriate.
NRC offices identifying specific safety problems (actual or potential) and recommendations for action resulting from AE0D analysis of a particular event or situation... and assure that such reports are available to the licensee, industry, and the public." Finally, it is to review the implementing actions taken by each HRC office responsible for action on AE0D recommendations and highlight areas of disagreement to the responsible office and the EDO.
AE0D Case Studies AE0D " case studies" are in-depth analyses of operational events, trends, patterns, or situations which are considered to have the potential of impacting public health and safety.
These studies are conducted by AE0D engineers over several months, and generally involve receiving information from a variety of inside NRC and outside sources. Nonnally, a site visit is made in order to assure firsthand kncwledge of plant. hardware and arrangement.
The case study report is reviewed within AE0D for technical accuracy and completeness of coverage. After appropriate reviews which may I
involve receiving comments from others on drafts of the report (see discussion below on peer reviews), the report is finalized and a forwarding letter highlighting the major conclusions and recommendations is signed by che l
Office Director. The report is then reproduced and distributed.
As prescribed in the Charter, all AE0D case study reports are sent for
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appropriate action to the licensing office (normally NRR) and/or to IE. The report is also forwarded at this' time through the EDO to the Commissioners, industry, and the public (i.e., PDR).
It is an established policy that the l
report is always placed in the PDR at the time it is transmitted for action to other NRC offices or is distributed to any organization outside the NRC for comment.
This policy is needed in order to assure equal access of hil parties to AEOD documents, to protect against possible perceptions of compromising l
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.iegotiations with outside parties, and to provide for full and timely public disclosure of AEOD studies.
This policy could be modified, of course, if a Memorandum of Agreement were signed with an outside party which provided a proper basis for exchange and protection of certain infomation and which was in the NRC anti public interest.
Reviews of AE00 Case Study Reports Reviews of AEOD case study reports nomally occur on two levels:
(a) peer review of operational event reports; and (b) deteminations of appropriate action by the cognizant NRC program office.
AEOD initiated a procedure in December 1980 to have case study reports on reactor operational events reviewed in draft fom by the licensee, NRR and IE. The approach was. adopted to assure that the report was factually accurate and complete wi.th regar.d to the event description and associated plant and personnel responses. When such a " peer review" is initiated, a draft copy of the report is placed in the PDR at the time it is sent to the licensee, thereby releasing it for public use and comment. After comments are received, the report is finalized and distributed in a-routine way.
If case studies are on generic subjects and, therefore, not directly related to a particular event or a specific plant, AE00 has not used the " peer review" process. The subject (April 3) AEOD report was a generic report, and dealt with concerns of broad applicability.
In such cases, care is taken to ensure the acquisition of accurate and complete information without the incumberance of a conscious or subconscious bias from the sources. Generally, an attempt is made to assure an awareness among the NRC staff members, such as by personal communication or organized presentations tc the ACRS or some other forum; but an AE00 generic case study is nomally not reviewed by the NRC staff until after
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it has been carefully considered and documented as a valid generic concern by the office.
It is then finalized and distributed in a routine way.
The real technical review of the report by the NRC staff comes after release by AE00.
After receipt by the cognizant NRC program office (normally NRR), a i
full technical review is made in order to determine agreement or disagreement l
with the findings and whether the recommendations in the report should be modified, accepted, or rejected.
Normally, the orogram office will 'then decide the appropriate ccurse of action 'regarding licensee action, and will assure that AE0D is informed concerning what action is intended and the associated bases.
Because of the involvement of one or more NRC offices in detentining l
the final staff position, the cover page of each AE0D case study contains a note l
that disclaims any official NRC endorsement by stating, "The findings and
3-recommendations contained in this report are provided in support of other ongoing NRC activities and do not represent the position or requirements of the responsible program offices of the Nuclear Regulatory Commission."
Previous Browns Ferry Reports The subject ( April 3) report was the latest in a series of AE00 studies started at a result of the Brodns Ferry partial insertion of control rods in June 1980.
The first AE0D report was issued as an operational event case study on August 1,1980.
The next AEOD document was a memorandum to NRR on August 18, 1980 concerning the potential for unacceptable interaction between the control rod drive system and the nonessential control air system at Browns Ferry Nuclear Plant.
The memorandum was issued in accordance with the AEOD Charter provision that the EDO and Directors of NRR and IE are to be notified of any significant matter requiring immediate attention. This was the only occasion when this provision was-invoked, and it was the only matter conside.. red by AE00 to warrant.such urgent 4ttention.
The second AE00 case study was issued on September 30, 1980 and concerned the interim equipment and procedures at Browns Ferry to dstect water in the scram discharge volume.
The third ( April 3) AEOD case study was an outgrowth of' the August i report, and really extended and. highlighted concerns expressed in that report.
Essentially the same policies and procedures were used to develop, isuse, and distribute all three case study reports. No comments or concerns were expressed by GE on any report associated with the Browns Ferry studies except this latest one, even though the AE0D handling was essentially identical.
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