ML20024E421
| ML20024E421 | |
| Person / Time | |
|---|---|
| Issue date: | 07/27/1983 |
| From: | Lakner A NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Baranowsky P NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20024C857 | List: |
| References | |
| NUDOCS 8308100576 | |
| Download: ML20024E421 (4) | |
Text
% [J "' "' %r UNITED STATES fJUCLE AR nEGULATOnY cOMMISslON k
0 Vi ASHINGTON, D C. 20555 h+ tl)
July 27, 1983 MEMORANDUM FOR:
Patrick W. Baranowsky, Leader Reactor Reliability Section Reactor Risk Branch i
Division of Risk Analysis, RES FROM:
Armand A. Lakner Reactor Reliability Section Reactor Risk Branch Division of Risk Analysis, RES
SUBJECT:
EXPRESSION OF DIFFERING PROFESSIONAL OPINION
Reference:
Lakner to Baranowsky memorandum dated July 8,1983 The purpose of this memorandum is to express my differing professional opinion per NRC Chapter Manual 4125, September 1980; the areas of my concern are (a) the agency's total lack of reliability assurance program plan and requirements, (b) my management's negative attitude towards reliability research, (c) the potentially catastrophic health damage and possible loss of lives as a result of the nuclear power industry infliction upon the innocent general public due to (a) and (b) above and finally, (d) my management's damaging practice of placing the staff in a complete professional isolation vis-a-vis the other high technology reliability experts.
This situation is, unfortunately, reflected in research, regulations, enforcement application and finally compliance.
I therefore, strongly suggest research activity as outlined in the enclosed NRC Reliability Systems Engineering Program Plan, Safety Assurance and Failure Elimination (SAFE-) modeled afte' proven aerospace, FAA and DOE r
reliability programs.
1.
My perception of Agency's current position Reliability experts and amateurs alike agne that reliability requirements are prerequisites to a safe and reliable nuclear power plant operation; in the absence of this, it is obvious that the nuclear power generation industry is in a direct collision course with an accident caused apocalyptic event.
The NRC research management is not responsive to the Commission's needs in the reliability assurance ana and thus it is inflicting a reat disservice to the a
agency and the general public; there are n_o goal oriented research plans or programs that will support the establishment of an NRC reliability assurance program. The following constitutes a partial listing of documented views, requests and opinions in support of the above statement:
a.
President's Commission Report on THI-2 Accident, October 30, 1979 b.
NRC Action Plan Developed As A Result of,TMI-2 Accident, Task IIC-4, j
NUREG-0660, April 1980 yA XA Copy Hos Been Sent to PDR s
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Patrick W. Baranowsky c.
Denton-Minogue memorandum Request for Reliability Assurance Program Research, February 14,1983 (RR-NRR-8301) d.
NRC/IEEE sponsored Electrotechnology Conference, Washington, DC, January 1980 e.
Lakner-Baranowsky memorandum, Coordination of RAP and RAP Related Activities, June 30, 1983 f.
Lakner-Baranowsky memorandum, Preparation of Expression of Differing Professional Opinion, July 8,1983 g.
Morris-Thadani memorandum, Notes on the IPRDS. Steering Committee i
Veeting on June 23, 1983 I
h.
Morric-Coffman memorandum, Pha:e II of NASA /KSC Reliability Guidelines Contract (FIN B8230) June 22, 1983 1.
Application of Aerospace Failure Reporting Systems to Power Plants, l
NSAC-4/EPRI, June 1980 j.
Space and Missile Reliability and Safety Program. NSAC-31/EPRI, February 1981
)
I k.
Morris, RAP /QAP Assessment, June 22, 1983 1.
NRC Reliability Program Plan (Recommended) Rome Air Development Center (USAF), Reliability Analysis Center December 1982 m.
Phase I Report of NASA /KSC Reliability Guidelines (FIN 88230) 2.
MLopinion differences I strongly feel that the absence of an agency reliability assurance program is l
totally opposing nty views of what is needed to protect the health and safety of the American public; my management's attitude and views are in conflict with my opinion of what constitutes good technical management of reliability and safety disciplines. Therefore, I am hereby suggesting a reliability assurance program research to be implemented without delay as reflected in the enclosed Reliability System Engineering Program Plan, Safety Assurance and Failure Elimination (SAFE); this plan was submitted to my management and subsequently ignored on:
June 15,1982 S. Burdick), Version #1 June 9, 1983 G. Burdick), Revision #1 June 27,1983 P. Baranowsky), Revision #1 3.
My assessment of resulting consequences As stated in 1 above, if no reliability assurance program requirements are immediately initiated and implemented I predict catastrophic nuclear power plant accidents; the risk increases as plants age.
s Patrick W. Baranowsky,
4.
Related efforts The following research programs are related efforts and will be strongly affected by the reliability assurance program research (SAFE) suggested herein:
I 1.
In-Plant Reliability Data System, ORNL, J. Johnson, Project Manager 2.
Pressurized Thermal Shock Analysis, ORNL (FIN B0468), C. Johnson,
=
ProjectIhnager Additionally ATWS event, instrumentation and control. failures will be drastically decreased or eliminated.
As a result of my management being non-responsive to my needs as far as admints-trative and technical support is concerned on my expression of differing pro-fessional opinion, (see Lakner-Baranowsky memorandum, Preparation of Expression of Differing Professional Opinion, July 8,1983) this submission is to be considered only partial; programmatic plans of differing professional opinion
- will be further developed and appropriately forwarded through the management chain of command.
I hereby request that in addition to the review process outlined in the NRC Manual Chapter 4125, the enclosed proposed reliability program plan (SAFE) be reviewed and cr!tiqued by an impartial peer review group composed of reliability experienced individuals recognized for their contribution in the reliability field; the membership of this group should not be limited to NRC Staff but it must consider the available expertise residing in NASA, D00, DOE, National Safety Society, Universities, and the National Academy of Sciences.
I feel that I would not conscientiously discharge my responsibility here at NRC without expressing my deepest concern and interest in the protection of the health and safety of the American people.
% u u s. c f E '
h i( W Armand A. Laknpr Reactor Reliabilicy Section Reactor Risk Branch Division of Risk Analysis Office of Nuclear Regulatory research
Enclosure:
As stated
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cc:
A. Rosenthal, ASLAP R. Bernero, ASP 0 M._Ernst, RES G. Burdick, RES R. liinogue, RES RRB Staff 1
C..Horris, NRR Z. Rosztoczy, NRR e
T. Murley, Region I P. Clieck, Region IV R. Mattson, NRR F. Forscher, IE PDR 4
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