ML20037D297
| ML20037D297 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/1981 |
| From: | Michelson C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 8107090329 | |
| Download: ML20037D297 (6) | |
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MEMORANDUM FOR: William J. Dircks Executive Director for Operations
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FROM:
Carlyle Michelson, Director Office for Analysis and Evaluation of Jperational Data SUBJECT.
GE LETTER C)NCERNING AEOD REPORT, " SAFETY CONCERNS ASSOCIATED WITH PIPE BREAKS IN THE BWR SCRAM SYSTEM".
We have reviewed the subject letter of April 16, 1981 and have two reactions.
First, the letter contains a number of statements which could convey misleading impressions and secondly, the letter seems to reflect an inadequate understanding of AEOD's charter and method of operation. Enclosure 1 provides some specific comments on the letter and Enclosure 2 addresses some of the issues raised from the standpoint of AEOD's policies and procedures.
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While, in general, I share the GE concern that the extensive media coverage on this report resulted in a sense of priority and significance that was not warranted, at the same time it is unfortunate the conclusions are being made regarding the technical merits of the issue before definitive plant-related-infomation has been developed and evaluated.
Please let me know should you wish any clarification or additional infomation on this matter.
Carlyle Michelson, Director Office for Analysis and Evaluatior of Operational Data
Enclosures:
As stated cc w/ enclosures:
K. Cornell T. Rehm J. Heltemes S. Rubin T
. 8107090329 810427
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x SPECIFIC COMMENTS ON THE GE LETTER OF APRIL 16 1.
The correct title of the AEOD report is " Safety Concerns Associated with Pipe Breaks in the BWR Scram System."
2.
The report was not issued by "an NRC employee,"'but rather by an NRC office which was chartered and directed to perfom evaluations of events, problems, or situations which could be significant in tems of the potential impact on public health and safety.
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3.
The report did not claim that "a serious safety problem" existed in BWR plants.
If this was really the AEOD position, a recommendation regarding the advisability of continuing plant operation would have been made. The AE0D report identified a serious concern and requested action related to detemining the validity of the concern. This process of validation involves NRR's review and action on the report, and receipt and evaluation of licensee responses for the affected plants.
4.
The report was not " prematurely" released.
It was released in a routine way consistent with the charter of AEOD and similar AEOD reports previously released.
5.
The Journal article appeared on April 7, a copy of the AEOD report was ghen to GE on April 3, and the subject material was fully disclosed in a public ACRS subcommittee meeting on March 10 (concerning the Browns Ferry partial failure to scram event) and published in a transcript.
6.
Regarding whether a proper technical review was completed, it should be noted that the report was carefully developed over several months using the technical resources available within AEOD, the concerns were presented to the ACRS, and the report was issued for fomal review in a planned manner consistant with the AE0D charter.
(For additional background, please see the April 21 memorandum from C. Michelson to W. Dircks regarding this report and the discussion of the review process in Enclosure 2.)
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7.
GE indicated that the Journal article has eroded public confidence in I
nuclear power and in NE's capacity to regulate. The mission of AEOD is to attempt to identify potential safety situations and to effect l
resolution before such situations result in an impact to public health and safety.
Such activities should enhance public confidence and NRC's capacity to regulate.
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GE indicates there may be a rrluctance to bring to the NRC's attention j
safety issues having a legitimate safety importance.
It should be l
noted that vendors already have a moral and legal obligation to identify all j
issues which may be of " legitimate safety importance."
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GE indicates it is " fundamentally unfair" to release a report which adversely reflects'upon a supplier's product without first affording the supplier an opportQnity to address the matter.
It should be noted that most NRC reports, bulletins, circulars, notices, and letters adversely t eflect on specific vendors to varying d2grees. It has never been an NRC policy to permit vendors to address such NRC documents prior to issue.
10.
GE believes that the release of the report will result in a significant misapplication of resources. While the extensive media attention has
'resulted in an unplanned and unintentional sense of urgency and significance, it is likely that the final extent of resources needed to resolve the issue will be about the same as if the media had not picked up on the report.
11.
GE indicates that the safety issue is not a cause for concern. While it is hoped that this turns out to be the case, it should be noted that the utilities have indicsted that:
(a) this issue is very plant. specific, and (b) much of tre equipment in question may not have been supplied )y GE. Thus, the technical validity of the concerns must await the receipt and evaluation of the affected licensee responses.
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12.
GE asks the Commission to avoid such occurrences.in the future. Here it is assumed that the occurrences that GE refers to are publication of report resul.ts in the Jocrnal. Although the media attention was not warranted and was certainiy une~xpected, 'it must be realized that neither AE00 or the Commission can control which publicly available information is or is not printed in any publication outside the Agency.
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AEOD 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. AEOD 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 event or situation when AEOD detemines such analysis and evaluation is warranted."
It is asked to. " Provide a report to appropriate NRC offices identifying specific safety probic w (actual or potential) and recommendations for action resulting from AE0D analysis of a particular event o* 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 NRC office responsible for action on AE0D recommendations and highlight areas of disagreement to the responsible office and the EDO.
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AE0D Casa Studies AE0D " case studies" crc 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 AEOD engineers over several months, and generally involve receiving information from a variety of inside NRC and outside sources. Nomally, a site visit -
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is made. in order to assure firsthand knowledge of plant hardware and arrangement. The case study report is reviewed within AEOD for technical accuracy and completeness of coverage. After appropriate reviews which may 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 the Office Director. The report is then reproduced and distributed.
As prescribed in the Charter, all AE00 case study reports are sent for appropriate action to the licensing office (nomally NRR) and/or to IE. The report is also forwarded at this time through the EDO to the Comissioners, industry, and the public (i.e., PDR).
It is an established policy that the 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
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2-s negotiations 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 information and which was in the NRC and public interest.
Reviews of AEOD Case Study Reports 3
Revie'ws of AEOD case study reports normally occur on two levels:
(a) peer review of operational event reports; and (b) determinat;'9s of appropriate i
action by the cognizant NRC program office.
AE0D initiated a procedure in December 1980 to have case stud.v reports on reactor operational events reviewed in draft form by the licensee, NRR and u
IE. The approach was adopted to assure that the rep'rt was factually accurate and complete with regard 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 5
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, AEOD has not used the " peer review" process. The subject ( April 3) AE0D 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 to the ACRS or some other forum; but an AE0D generic case study is normally not reviewed by the NRC staff until after it has been carefully considered and documented as a valid generic concern by the office.
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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 AEOD.
After receipt by the cognizant NRC program office (normally NRR), a full technical review is made in order to determine agreement or disagreement with the findings and whether the recommendations in the report should be modified, accepted, or rejected.
Narmally, the program office will then decide the appropriate course 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 oc more NRC offices in determining the final staff position, the cover page of each AEOD case study conta:ns a note that disclaims any official NRC endorsement by stating, "The findings and r-
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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 AEOD studies started as a result of the Browns Ferry partial insertion of-control rods in June 1980.
The first AEOD 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 considered by AEOD to warrant such urgent attention.
The second AE0D case study was issued on September 30, 1980 and concerned the interim equipment and procedures at Browns Ferry to detect water in the scram discharge t(lume.
The third ( April 3) AEOD case study was an outgrowth of the August 1 report, and really extended and highlighted concerns expressed in that report.
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Essentially the same policies and procedures were used to develop, issue, 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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