ML20033C640
| ML20033C640 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/1980 |
| From: | Jamarl Cummings NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | Ahearne J, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML20033C638 | List: |
| References | |
| FOIA-81-338 NUDOCS 8112030538 | |
| Download: ML20033C640 (8) | |
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UNITED sT ATES
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f MEMORANDUM FOR:
Chaiman Ahearne Commissioner Gilinsky -
I41n31alahn Commissioner Hendrie Commissioner Bradford
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.FROMi James J. Cummings, Director Office of Inspector and Auditor.
J I!!PROVEMENTS NEEDED IN C0ORDINATING THE DEVELOPMENT
SUBJECT:
OF RELATED RULES The Office of Inspector and Auditor (0IA) has completed a preliminary survey of the Office of Nuclear Regulatory Research's (RES) plan to reorient its research program to address the lessons learned from the accident at Three Mile Island (TMI).
It/was not feasible to do any detailed audit work at this time because budgetary uncertainties and the subsequent reprogramming of funds could significantly impact RES's schedule for accomplishing its research plan. Consequently, OIA is deferring work in this area until a future date. We do, however, have some observations on two of the major programs RES has reoriented to address the lessons learned from TMI.
In addition, this memorandum points out a problem brought to the attention of.01A during the survey which we believe merits immediate attention.
OBSERVATIONS TMI. ACTION PLAN In general, le components of RES's revised program are contained in the NRC Action T.an developed in response to the recommendations of the numerous investigative. reports on the TMI accident. The NRC Action Plan delineates 23 separate tasks for which RES eicher has direct or supportive responsibilities.
It is estimated that $68.2 million and 26.6 RES staff years will be required in fiscal year (FY) 1980 to begin work on 'the 23 tasks. Resources to continue work on these tasks are A detailed.
estimated at 167.4 million and 26.4 RES staff years for FY 81.
breakdown of these tasks and their associated resource requirements are contained in Attachment I.
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2 According to RES officials, it was readily apparent from the Till accident
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that research programs were needed in the areas of enhanced operator capability, small break loss of coolant accidents (LOCA) and phenomena associated with severely damaged fuel.
Consequently, steps were taken to address these needs shortly aff er the March 1979 accident.
Some comments on two of these programs follow.
SMALL BREAK LOCA AND AN0MALOUS TRANSIENT TESTS AT LOFT As shown in Attachment I the principal RES effort from a resource standpoint will be to conduct a series of small break LOCA and anomalous transient tests at loss-of-fluid-test (LOFT).
Resources in support of this program are estimated to be $39.3 million in FY 80 and $29.5 million for FY 81.
Plans to revise the LOFT program to respond to the lessons learned at The LOFT plan THI were started immediately after the accident at Tiil.
accelerated the tests for small break and anomalous transients uhich were seneduled for later fiscal years and deferred scheduled large break tests until the new test series can be completed.
Initial testing efforts are already underway. While the LOFT plan addressing the research needs in the small break area appears to be sound and well thought-out, budgetary cutbacks could adversely impact the program.
According to the Branch Chief for LOFT Research, proposed cuts in the FY 80 Supplemental 4
budget and the FY 81 budget could force the deferral of purchasing a backup core for LOFT.
This would result in an overall slowdown in the test program because tests could not be run which would challenge the system or damage tne fuel until such time a backup core is available.
Consequently, the LOFT Branch Chief did not believe the small break test program wo"1d be as responsive as it should be to address the lessons learned at TMI.
INTEGRATED FUEL MELT RESEARCH PROGRAM PLAN A second major task in the TMI Action Plan calls for research of phenomena associated with core degradation and fuel melting.
This task requires fur. ding of $8.4 million in FY 80 and $12.9 million in FY 81.
RES officials recognized shortly after the TMI accident that extensive research was needed in the core degradation / fuel melt area and began assembling a program plan in the summer of 1979. Resources from ongoing programs in this area, sponsored by different RES divisions, were pulled together to provide a funding base for one integrated program.
The RES program plan is essentially divided ir.to three parts; (1) severely damaged fuel research, (2) core melt research and (3) hydrogen studies.
While the RES plan appears to be well conceived, organized and responsive to the lessons learned at TMI, its scheduled accomplishments will be totally dependent on available funding, which at this time is still uncertain.
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!0ne concern raised about the fuel melt research program by NRC officials was that the planned research was too " pure" and not oriented enough toward providing a technical base for future design criteria requirements.
The RES task. leader for this program advised -that he would attempt to address this concern before the plan was finalized.
.One other concern related to the fuel melt research program was raised by NRC officials during the course of our survey.
Several RES officials expressed the view that the research necessary to provide the technical basis for NRC's proposed degraded core rulemaking will not be completed before the rule is scheduled to be published.
In pursuing this concern with other NRC officials, a more significant problem was widely expressed concerning the coordination of.the degraded core rule with other interrelated t
rules currently under development.
-IMPROVEMENTS NEEDED IN COORDINATING THE DEVEL0PHENT OF RELATED RULES i
In the wake of the TMI accident, NRC began work on four separate but highly related actions designed to improve the overall safety of nuclear power plants.
Three of these actions are proposed rules.
The first rule, which is the furthest along in development, proposes amendments to the regulations to strengthen emergency preparedness requirements.
The second rule will propose amendments to existing siting regulations to reflect the' experience gained since the original policy was established in-1962. The third and most complex rule proposes to amend the regulations to identify the need for reactor designs to be' evaluated over a range of loss of core cooling events with resulting core damage and identify improvements to cope with such events.. Design improvements under consideration include core retention devices, vented filtered containments and aeasures to ;ontrol hydrogen generation. The fourth action, an interim policy statement, would require the assessment of the environment. impact of class 9 accidents in Environmental Impact Statements.
During discussions with NRC officials on the scheduling of research for the degraded core rule, continual concerns were expressed that the above described four actions were not being effectively coordinated. We discussed this situation with all levels of management and staff from RES, Office of Standard Development (SD) and Office of Nuclear Reactor Regulation (NRR) i who were. involved with the development of the four actions.
There was unanimous agreement that-improved coordination of the four actions was necessary, particularly with respect to the degraded core and siting rules. Depending on the perceptions of the individuals we, talked to, the extent of the problem and suggested solutions to rectify the situation o
varied. The major problem areas identified with related staff comments follow:
1 The development of the siting, degi aded core and emergency preparedness rules and the related interim policy statement on the environmental impact of class 9 accidents are not being effectively coordinated within-4 l
NRC.
r currently there is no one individual or organization within NRC L
l coordinating the degrade core' rule (RES official).
.a1 fundamental problem with the development of the rules is that V
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organization responsibility is fragmented within NRC--there is serious overlap in responsibility for rule development between SD and HRR--SD's approach is too theoretical, NRR needs a more practical base to. support licensing actions--SD is only paying " lip service" to the need for better coordination--SD is setting their own schedules and NRR is given little time to commM on positions, turnaround time requested by SD has been 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> which is infeasible (NRR Official).
the rules are being developed by different organizations in SD, the rules shculd be under the cognizance of one SD branch chief--SD should take a stronger role-in the development of the rules (NRR Official).
early indications are the NRC staff is going in different directions in developing the four actions--as more staff become involved in the rulemaking the need for better coordination grows--SD has not been attending meetings related to rulemakings, including meetings held on RES's fuel melt program (NRR Official).
better coordination of the rulemakings is becoming a more pressing issue as work progresses on the degraded core and siting rules--an agency wide " master plan" is needed to ensure that the development and implementation of the rules is properly coordinated--some sort of PERT system is needed within the plan in order to ensure tasks are accomplished within a given time frame (Senior SD Officials).
Problems exist relating to the research programs needed to provide the technical support for the' rules.
RES is currently forced to develop its programs in a " vacuum" because the detailed structure for the rules is not yet available, RES is " planning in the dark" (Senior RES Official).
the schedule for the development of the rules is too compressed to allow for the completion of the necessary research to fann the technical base for the rules (three Senior RES Officials).
there is a need to pull the rulemaking together based on sound quantitative analysis which is not yet available (Senior NRR Official).
risk analysis is still in the fomulative stages--such analysis is necessary to detennine where to put the emphasis with respect to the degraded core and siting rules (Senior SD Official).
RES's planned research program in support of the degraded core rule is too theoretical and not practical enough--RES is into pure' research while NRR leans toward technical support for design criteria (SD Official and Advisory Committee on Reactor Safeguards).
Ineffective coordination in rule development on the part of the NRC will adversely impact public and industrial comment.
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NRC is " heading for nothing but trouble" if the rules are not better coordinated--this is especially necessary)to gain the confidence of the public and nuclear industry (NRR Official.
the development of the rules is different than anything NRC has attempted before, the rules are highly complex and need sound input from the public and nuclear industry--this may not happen because the rules will be published independently and the public and industry may not be able to fully appreciate their interrelatedness and
" throw up their hands in confusion" (SD Official).
CONCLUSION While recognizing that the development of the degraded core and siting rules is still in its initial stages, we share the above concerns expressed by the NRC staff. We believe the complex interrelated technical considerations being addressed in the four actions and the far reaching impact these actions _ could have on the nuclear industry require a need for more effective agency wide coordination of their development.
RECOMitENDATION We reconmend the ED0 take immediate action to establish the means for assuring effective agency wide coordination of the four actions discussed in this report.
AGENCY COMMENTS The ED0 responded that an action plan is being developed by SD for the interrelated rulemaking and will be presented to the EDO in August 1980.
The text of the ED0's response is contained in Attachment II.
cc:
W. Dircks, AEDO 1
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TABLE OF TASKS LISTED IN THE TMI ACTION PLAN REQUIRING RES SUPPORT RESOURCES DOLLARS STAFF MAN YEARS TASK DESCRIPTION FY 80 FY 81 FY 82 FY 80 FY 81 FY 82 SCHEDULE Upgrade Training Simulators 195k 600k 900k 0.2 0.5 Initial Work to Begin in May, 1980 Improved Control' Room 1,800k 2,450k 1.1 1.3 Work Already Underway Instrumentation Technology. Transfer Conference 30k 0.1 January 15-17, 1980 In-House Operational Data Analysis 2.0 2.0 Staffing to be completed by June, 1980 Special Operational Safety 1,145k 1,200k Work Already Underway Data Analysis Human Error Rate Analysis 500k 500k 0.5 0.5 Work Already Underway Phenomena Associated With Core 8,400k 12,915k 4.5 7.3 Work to Begin in FY 80 Degradation and Fuel Melting Support of Study to Reduce Risks 1.5 Work Already Underway At Operating Reactors Near High 4
Population Densities Support of Rulemaking on 0.4 1.0 Notice to Conduct Rulemaking Considerations of Core Melts will be Published in in Safety Reviews July, 1980 Interim Reliability Evaluation 1,775k 1,000k 5.5 2.5 Work Already Underway Program (IREP)
Continuation of IREP 0.2 0.1 Approach to be Developed in October, 1980 La -
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RESOURCES DOLLARS STAFF MAN YEARS TASK DESCRIPTION FY 80 FY 81 FY 82 FY 80 FY 81 FY 82 SCHEDULE Support of Systems Interaction Work Already Underway 0.3 Study
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Relief and Safety Valve Test 150k 1,700k 0.4 1.2 Work Already Underway Requirements-
' Support Auxiliary Feedwater 0.6 Work Already. Underway System Evaluation Small Break Locas and Anomalous Transients 8.2 8.0 Loft 39,300k 29,500k Tests Started in FY 80 Separate Effects 9,500k 11,700k Tests Started in FY 80 Thermal Shock 300k 1,000k Analysis Development 3,900k 3,600k Obtain Technical Data on the 525k 1,185 5,000k 0.5 1.9 3.0 Work Already Underway Conditions Inside the TMI-2 Cont-innent Structure Nuclear Data Link 300k 0.3 Work Already Underway Radioactive Gas Management 150k Work to be Initiated in FY 82 or Later Study Radioiodine Absorber 110k Work to be Initiated in Performance FY 82 or later Improved Envirnomental Monitors 400k 0.1 0.1 To Be Initiated in FY 80 Quantification of Safety Resources Assigned from Decision-Making Normal NRC Operating Budget Aer -
RESOURCES DOLLARS STAFF MAN YEARS TAtK DESCRIPTION FY 80 FY 81 FY 82 FY 80 FY 81 FY 82 SCHEDULE Plan for Early Resolution of.
0.1 Plan to be. Developed by Safety Issues ~
October,1980 Support of Assessment of 0.1 Operating Reactors TOTAL 68,220k 67,350k 6,160k 26.6 26.4 3.0 4
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