ML20038C329
| ML20038C329 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/1981 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Weiss E HARMON & WEISS |
| Shared Package | |
| ML20038C330 | List: |
| References | |
| FOIA-81-320, RTR-NUREG-CR-2285 NUDOCS 8112100437 | |
| Download: ML20038C329 (1) | |
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UNITED s1 ATES
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NUCLEAR REGULATORY COMMISSION b
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4 September 18, 1981 6) g
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Q@' O' Ellyn.R. Weiss, Esquire Harmon & Weiss 1725 I Street, N.W.
Suite 506
'IN RESPONSE REFER Washington, DC 20006 TO F01A-81-320
Dear Ms. Weiss:
This is in further response to your letter dated August 5,1981 in which you requested, pursuant to the Freedom of Information Act, five categories -
of records pertaining to the MARCll code.
In our letter dated September 14, 1981, we notified you of records placed in the NRC Public Document Room (PDR) and informed you that additional records were undergoing review. Review of the remaining-records subject to your request has been completed.
At this time, we are placing the following records in the PDR in folder F01A-81-320.under your name:
1.
6/81 Draft " Interim Technical Assessment of the MARCli Code", by Rivard, et. al., Sandia National Laboratory.
2.
7/29/81 Letter to Rivard from Cunningham, NRC, commenting on the above draft report.
3.
8/7/81 Letter to Rivard from Cybulskis and Denning, Battelle, commenting on the above draft report.
The record listed as item 1 above is a draft report which contains preliminary findings on the quality of the !!ARCil code.. We wish to.
direct your attention to the fact that the report has numerous problems and errors, as noted in the letters listed as items 2 and 3, and is expected to undergo substantial modification before final publication.
This completes NRC's action on your request.
Sincer,ely, f
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N J.j.M. Felton, Director
[8 Division of Rules and Records Office of Administration
'8112100437 810918
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II ARMON 8: WEISS 1725 1 STREET,N.W.
SUITE 506 WASHINGTON,D.C.20006 gg,f,"33 GAIL M. H AR MON yo E LLY P. R. W EIS S WILLI AM S. JORD AN, til LE E L. DISHOP L. THOM AS c ALLOWAY August 5, 1981 FREELMM4 OF IN703mgyzoy
/iCI GEQUEST Mr. Joseph Felton, Director
[ 8 [ / [ 7/ -* 7 M Division of Rules and Records Of fice of Administration
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U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Re:
FREEDOM OF INFORMATION ACT REQUEST
Dear Mr. Felton:
Pursuant to The Federal Freedom of Information Act, I hereby request that copies of the following be made available:
1.
Any memoranda, reports, documents, studies etc., authored by members of the NRC staff, ACRS staff and/or consultants to either dealings with the uses and/or limitations of the March computer code.
2.
Any documents, memoranda, reports, studies, etc. by the NRC staf f, ACRS staf f and/or consultants, which involve use of the March code to assess the potential for hydrogen generation.
3.
Any documents, memoranda, repo r t s,. studies, etc, by the NRC staff, ACRS staf f and/or consultants, involving use of the March code to assess the potential for hydrogen l
generation for the Sequoyan and McGuire plants.
4.
An NRC staff rep. ort to the ACRS dealing wholly or partially with the use of and limitations of the March code.
(This report is mentioned in the July 13, 1981 issue of Nucleonics Week.
A copy of the article is attached.)
5.
Any documents, memoranda, reports, studies, etc.
by the NRC, ACRS, nuclear industry, utility and/or consul tants to any of the foregoing, involving use of the March code to analyze the progress of degraded core and core melt accidents.
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Mr. Joseph Felton Page Two The request may be limited to material produced in 1979, 1980 and 1981.
As noted above, I am enclosing a copy of an article appearing in the July 13, 1981 issue of Nucleonics Week which should be of help in indicating the nature of the material which I am seeking.
Please call if I can be of assistance.
Very truly yours,
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Ellyn R. Weiss ERW:smq Enclosure
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cn inordinate risk.
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- ne quantitatin safety goals for nuclear power piants sho"ld be censistent with those applied to other technologies. The goals should try to ensu:e that incr: mental societil risks are commensurate with the societal benefits deri<cd from the tuhm! gy.
- And the goals shot!\\ remote the ::tional a!!ocatien of societal resources for the purposes of r public rid in order to achiese he optimum benefit attainable for the cost.
Departing from the broad tility support for the AIF epproach was the Tennessee Valicy Authority, which gave instead qualified endo. ement cf the approach advanced by NRC's Advisory Committee en Reactor Safeguards in "An Approach to Qa,titatise hfety Coals for Nudear Power ihnts"(Sure;0739). Char 4cter.
izing the ACRS prepesal as "a good arting peint," TVA praised it as containing "most of the 1.ey principles that we censider essentid to a reason le and cempreher-he safety goal."TVA tag d,however, that NRC re-i dace "some of the maplexity" of the CRS p oposalin the fina' safety goalin vider to make easier its " pub.
!!c perception and understanding."
[
- ]- d' own hard in June 26 comments on the SRg's safety goal efforts. "Th Rcnedenhe siew ofintervenors. I hn Weiss,aturney for the l'nion ef Concerned Scientists.came used to demonstrat: that it has 1.een met wilf not be used in a pure effort t' advance sdentific and" standing,"
o dedared Weiss. "On the contrary, th:y wall be ised to make decieions w!bh hase great econcmic and po!itical consequences for the organizations that will spcgsor the work. One need fook nc, further than the ennple of the misuse of Wash-1400 as the centerpiece of a gtional propaganda dmpaign acthely encouraged by the AEC/NRC to ccnfirm this. Unless the public can be assured that the baens exist to senfy comp'iance with a safety goal,it will be justifiably conduded that thib eprecents an e[fc.rt to mask the rists cf nuclear po.ver rather than to identify and understand them," Weiss cid.
"A fund.unenta! question w h!ch ruust be ad finqJ hn si-nply not been faced: Can quantitative safety goa!s be used in the regulatory process if quantitathe ris' a.sedment is incapable of yielding technica!!y sup-pertab!e results within zn acceptahle limit of certainty?
"UCS belieses that the answer to this qmtica is *no? Ush estimates whish ne inherently unreliabfe cannot legitimately be used as regulatory tools. They ghe,the i!!usion of precis 7n, Fut c.m be maidpulated -
to support whatever the predeteratined chjedhe may hej" sh said.
Weiss denounced the AIF proposal as "o!.jectica3 e" on gesc el counts. She questioned AIF's aner-bl tion, for example, that goals "should b: scner A!y app;l cable to di te-hno!agies or riirciated activities."
Saying that the rurpose of a safety geal"is presumb.y to establih 2cceptabic loc:s of sisk ficm nadear pawer," she wamed that efforts to treat all ricks as bmparable "inhita5!y merlonk" the unique and import-ant nudear risks.
The AIF sugestion that the sifety goal shdd "renect sxietal rigs," Weiss said,"imites the standud-sctter to enter a p,olitical quagmire that is not 'rbreptible to resolation in an objecthe er nonsoatroversial ny." For a safety goal to be "a meful tool f regu'a'ing nudcar power," Weiss said,it must meet the fo!!ow-ing c onditions:
- Comp!iance uith the goal must be technic 2!y.eiif'ab!c wi*ia rere;t, bly sm2!! uncertainty !imits.
S.ating the uncertainty, howeser c!cnly[is not a <uktitute for redrir.;it to'a:ceptable Incts whe,n regu?a-tory decisns ere :o be based upon quantitathe aucss nent."
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- Fstat!ishment and imp!rment$ tion of the gcd must fai:!y account for the unipe rists of catastrophic nudear accidents, includin; ecc nofc costs.
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- Tstab!ishment an iim;tementation ef the goal must not require NRC to resohc questicas whi:h are poiiticalin nature.
- Re s:icntific and tedpical community cutside the nuciar inLstry and NRC mmt 1 e invohed in estabbhing the goal and resie, wing risic anessments.
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public as bcing unbiased ap) and the quantitathe risk asses ments must be
- Both the safety goa d tedmica'!yjustified.
-- And a quantitajNe safety goal cannot be a s astitute for censenathe dete:r dnistic criteria for the t
licensing of nudest plag.s. - Artriti.ti/Merg
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THE Lt'.*!TATIONS OF THE f.'ARCil CCMPUT ER CODE, AND ITS FtJTIJRE, ARE INCREASINGLY DEBATED by NRC staff and the Advisory Comn.ittee on Reacter Safegunds. Cae NRC staffer says fbtly,"We are not gdng to get rid of the March code." Says ar.other,"I don't know. It's not clear. Here :re ahantares of sticking with itjust became of timing;it's there. With the time sd.cdule and needs we ha.e. there's an argument to fix it up, rather thn starting from scratch." But / CRS Cha:rman 1.Cmon Mark asks,"Why in heaven's name is anyore in this day and age ming the.Wrch code, inserted befoe Wash-i t00, to aness tLe hydrogen prob!cm and apply it to Sequoyah and McGuire as ifit made any sense?.. Why in this day and age are pq'e a.tirg in that 4
IMIDE N.R.C. - hty 13,1931
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a _._
ity fashion?"ne Mmh (for meltdown accident response characteristics) co$e is used to analpe ;$r3gress of d
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F core and core-melt accidents.The major criticism of the code is that, while it may be used "in a gencial way to indicate trends,"it is not securate enough "for determining specific licensing criteria," according to an NRC staffer;yet ACRS members beliese that is how the statfis usingit.
William Kerr,chairmaa of the ACRS subcommittee on class-nine accidents, tells inside NRC that he feels the code is being used "by peop!c who in some cases don't understand its limitations... and don't base any-thing else and use it in desperaticn to draw conclusions not warranted on the basis of the code."The ACRS view, he says,is that more emphasis should be put on physical research on degraded < ore problems. It's on such problems that " application of the March code is apt to give ermneous iesults," he says.
An NRC staffer says the code's major problem is "that it's being used in areas in which it's not intended to be used. It was intended to be used in risk assessment... It's rather simplistic (and) people are attempting to ascribc more accuracy to it in other forms and when it's brought into licensing,it makes a more difficult situa.
tion." Another staf fer, however, says the code is neser used by itself to make licensing decisions. "We willie.
quire an independent assessment of key par: meters for licensing decisions," he says.
Kerr's dew is that, although the NRC staff has told the ACRS several times that licensing dechions are not made on the basis of the computer code alone,"we read reports by the NRC staff where it would appear that March h3s had a significant influ:nce." Keir says codes produce only what they're told to produce. A danger,he says,is that people ne under pressure to do something, ar.d so n.ay use an inadequate code.
Keir also says that peopic who are good at putting together codes are not neceuarily good at auessing phy.
sical data."(Emico) Fermi was one of the few equa!!y at home in both. Usually people who produce big codes hwe only a nodding acquaintance with physical phenomena." And Keir worries that once time and money have been spent to preduce a code,"you use it for eseiything."
The codc has problems no matter how it is used. NRC staffers in a report to arLACHisuhrtmmittee count.
ed among the main psoblems a lack of sephistication in seseral areas. He reactor coolant system, for instance, should be treated in "a multivolume fashion," rather than as a single solume. Another difficult area for the code is in core meltdcwn nnd slumping, and still another concemt core <encrete interaction.
Core debris and w ater interaction are another problem, as is the hydrogen source term where modelling of.
the code is not adequate. Other areas of contem include the mass and energy balance, and the code's " fathom.
.T ability." Says a staffer,"It's not easy to get into March and understand what it's doing in urious aspects."
A Brookhaven National Laboratory research:1 told the ACRS recently that it takes atout 18 months to learn to use the code. "You have to use a code with intelligence," he said. "You just don't take a deck, run it, and get an output and show it to people.You must look very carefully at the input and be scry aware of what is in it and be sure you have got a good solution,"he said. And a staffer from Sandia National Laboratories warned that the code "does reduce phenomena to a false rimplicity by ignoring cornplicating factors." -- Joame D.mn THREE MILE ISbwD ALERT 'ISPUTES ARGUMENTS BY NRC and Metmpolitan Edison Co. that the com ninion ut der it is challe ing in court is inteiltcutpry and to not subject to the court'sjutisjiction, tellir.g the U.S. Court of Appeals for the District ofpolumbia Circuit that courts in the p.ist had held simil1r ord:rs to be final. The order T.kt A is fighting is tjl e March 23 dropping by the cur.unission of the issue of M t Ed's financial qu.difications f dings. Met Ed,as an latenends in the appeals court case, and NRC hwc aded th(om the TMI. restart piecee gcourt to ismiss TMI A's petition for resiew (Incide NRC,29 June,7). -
Argeing agairst dismisul,TMig calls ie com nission order "a blatant cumple of aditrary and capd-iaw states explicitly that an 1, gen;y em be ch dienged for actingin cious decisica making," alding that '
a opposition to its authorizing statute."
11 A contends its members "Inve a sit.d inte rest in ensuring tlnt Three Mile Island be operated by a liyen e that is not strapped by financial consiraints, and thereby pres <ured into cost <utting measures which might a et advenely the plant's safety." Says th: group: "Indeed, this is precisely why the Atomic Energy Act and RC segulations requiie that a licensee's financi2l qualifications be exa:nined."
As an attemative, the gr sup says, the count ceuhl hold in abeyance its petition for resiew, pending issu-ance of the order on iettary ay NRC. Met Ed,ika July 2 brief supportingits motion to dismiss the case,re.
iterates its pmition thit co6tt intenention at this time is inappropriate. "If and when the NRCissues m order before considering finas[ial qualifications," the utitih says.TM1 A may at that allowing TMI-! to restar
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NRC STAFF WOTT AGnLE TO RECOMMEND RESTART F Tf.".11 UNTilIT ll AS CVIDENCE of"scaonable progress" on dcsc (jping water levelinstrarnentation, the ghisozy Committee on Rextnr Safeguards was told at a sdcommit' e meeting. "Unless they're wo king scry much behind the s:enes, there's no way they'll have it installed by anuary 1,190," a staff membcr said."At tlk very rninimum,we requite to sce some strong
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IMIDE N.R.C. - htv 13.191 5