ML20042E077

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Comments on Proposed NRC Safety Research Program & Budget for FY91 Presented During 360th ACRS Meeting on 900405-07 & Suggests That Agency Focus on Safety Research Philosophy & long-range Strategy Rather than Ongoing Research Programs
ML20042E077
Person / Time
Issue date: 04/11/1990
From: Michelson C
Advisory Committee on Reactor Safeguards
To: Carr K
NRC COMMISSION (OCM)
References
ACRS-R-1391, NUDOCS 9004200038
Download: ML20042E077 (6)


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NUCLEAR REGULATORY COMMISSION o

3-ADVISORY COMulTTEE ON REACTOR SAFEGUARDS l

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WASHINGTON, D. C. 20695 i

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April 11, 1990 t

' The Honorable Kenneth M.

Carr L

Chairman

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. U.S. Nuclear' Regulatory Commission' Washington, D.C.l 20555 I

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Dear Chairman Carr:

SUBJECT:

NRC SAFETY'RESEARCH PROGRAM BUDGET-During : thel 360th meeting of' the - Advisory Committee. on Reactors Safeguards,: April 5-7, 1990, we discussed the proposed NRC.1cfety 4

Research Program and budget for FY 1991.

Our Subcommittee on the-Safety Research Program met with' the Executive Director 'for Operations, representatives from-the Office;of Nuclear Regt.iatory Research (RES), and~the Office of Nuclear Reactor Regulation (NRR)-

. on February 7,

1990, and discussed the proposed' FY 1991' budget along'with the rationale for the.' continually dwindlingLNRC. Safety; a

- Research Program budget and the ' associated impacts'.

LAfter considering the =information ~ gathered at these meetings,1we find ourselves concerned, not so much about.the proposed FY 1991 budgeti-but about the trend of. continually diminishing-funding for;the NRC_'

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. research prcgram.

. Unless this trend is; arrested, the overall

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effectiveness of the agency will.be seriously compromised.

We have been critical of~certain parts of the NRC-research program

'i in the past and remain so (Refs. 1-6).

It is notuour intent to 4

iz address program deficiencies _in this report, but to communicate our belief that a viable re' search program is'an. essential part of the NRC - regulatory process._-

In. the following paragraphs, we describe the reasons for our. concerns about the research budget

'_ trend, and offer suggestions for change.

TREND IN THE RESEARCH PROGRAM BUDGET Pertinent figures from the NRC budgets for' fiscal. years 1975, 1981, 1983, ano 1991_ follow:

9004200038 900411 PDR ACRS I

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c The Honorable Kenneth M. carr-2 April 11, 1990 Total Agency.

Research Program-Funding Total Support Funding

  • Fiscal (in constant Agency (in constant No. of FTEs*

Year 1975 dollars)

FTEs 1975' dollars) for Research 1975

$148.1M 2006

$ 61.2M 94 1981 294.6M 3139 129.5M 155 1983 277.4M 3403 110.0M 140 1991 218.0M 3240 36.1M 120 When the total NRC budget-increased 1 markedly in the late 1970s and.

carly

1980s, the.research -budget increased proportionally.
However, since 1981 funding for research has. been much more dramatically diminished than that for the agency.

From 1983 to 1990, the research program support' budget, in-1975 dollars, was reduced by a factor of three.

POSSIBI.E EXPLANATIONS FOR THE RESEARCH BUDGET TREND :

.j Among the reasons that might be offered for the trendin research funding are:

e The Commission has explicitly decided.that research has become-less important than other agency activities.

It may s have concluded that nuclear power has reached relative maturity and that most of :the - technical questions. relating; to : reactor safety and regulation have been answered.. In competition with other demands on resources (e.g.,-

the belief that 'more inspections of operating' plants are needed),1 research has.

taken a "back seat."

e Research funding has been teduccd as;part of a policy' directed by the Administration or the Congress, perhaps for the:reanons mentioned above.

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e Given the government budgeting process, it is easier.to reduce funding for NRC research, which is. largely allocated to persons and 4 institutions not. on the NRC payroll, than - to curtail or terminate. regulatory activities - that J directly -

involve NRC employees.

  • Associated with actual research support.which includes. planning, 4

coordination, and managing research projects.

Does:not include technical assistance support' for developing rules and regulations, resolving generic and unresolved safety issues, or review of 1

IPE/PRA submittals.

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he Honorable Kenneth M. Carr 3

April 11, 1990' T

All of these' reasons may have influenced the research funding:

trend, but we believe that the third ~ reason has.had a-dispropor-tionate influence.

As evidence for this, staff presentations to us described the largest portion of the-agency's budget, which includes. funding ~for. salaries,- rent, travel, office accessories, 3

l' etc., as "nondiscretionary."

When pressed, the staff agreed that these funds were not'really "nondiscretionary" in the sense that.

there is explicit guidance to that effect from-the Commission.

r HISTORICAL BENEFITS OF NRC RESEARCH a

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Since its inception, the NRC has expended over $2' billion (actual

. i dollars) on research.

Rcsearch has led to. numerous-. important i

technical contributions to the NRC's regulatory program and nuclear-safety.

Several examples follow:

e In the thermal-hydraulics

area, extensive research. has confirmed that emergency core'. cooling systems would adequately -

respond to the worst credible. loss-of-coolant accidents, resulting in revision to Appendix..K, with a potential avoided capital cost of about $8. billion'(Ref. 7).

Later,-improved methods of analysis provided guidance. for responding to questions arising from the. TMI-2 accident about. plant operation, and have permitted optimizations in reactor. systems and operations.

Several elements of the plant cging research program have led-the way in assessing the effects of aging on-nuclearfpower-plant components and structures.. They have also led to the

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development of examination ' and ' testing techniques = and the identification of the essential elements for i managing the-effects of aging.

The results of these research, elements constitute the principal technical basis for: addressing the aging-related issues associated with nuclear ! plant life extension and license renewal.

In the geophysics and seismic areas, NRC-sponsored research a

programs have provided better understanding!of the' Eastern U.S.

seismicity, which has permitted more' realistic assess -

ment of risk from earthquakes.

In the area of materials =scienc'e, NRC-sponsored =research has i

e provided means to improve. and ensure the reliability of inspection methods and has provided~' key information in managing problems of stress corrosion cracking-in. BWRs.

Additionally, research has provided the means for dealing with the pressurized thermal shock ~ issue..other research has made it possible to improve reactor cafety by ; justifying the elimination of unnecessary pipe supports.

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The Honorable Kenneth M. Carr

-4 April 11-1990l j

e NRC-sponsored research has led the way in development of methods for risk analysis..In-addition, recearch has made it-possible for the NRC to come to grips with severe accident' questions.

Beyond these technical accomplishments is another benefit which is -

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-i not always explicitly recognize 3, yet is as important as the others.

We believe it to be generally ' accepted that the NRC's-research program has been an important contributor to :the, high technical quality of the-staff. 'The research program has'not-only developed important safety information,-but hasEnttracted-capable people to work for the NRC and-ts. contractors, and has provided a resource of technical expertise to all activities of _ the-agency.

REASONS FOR' CONTINUING A COMPREHENSIVE RESEARCH PROGRAM Important questions about nuclear safety andf regulationi remain unanswered.

Applications of nuclear energy-involve -demardingL technologies, and society expects nuclear activities to be-carried out to-extremely high standards of public and environmental safety.

While analysis indicates that the.NRC has been largely successful in its-task of ensuring safe practices, significant uncertainties in risk predictions and lack of-understanding of certain important t

phenomena remain. - These involve technical' areas such as components -

and materials performance, seismic risk,- accident management,.

j severe -accident phenomena, and human behavior. < ~ Continuing research 1

- can gradually provide information'and: understanding'that-will be i

valuable in dealing with these questions and uncertainties.

In addition, it is necessary to maintain the' technical' quality _and credibility of the NRC staff.

We were. told that the-~ average; age; of the research staff is now about' 50.

. Vital and: consistently :

J funded programs will ' retain the contributions:. of ~ experienced -

researchers and attract capable new people to-the agency, in:both research and nonresearch positions.

Many of the manifestations of several years of decreasing research-

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funding are already. visible:

Important research programs are being curtailed or terminated.

1 e

e The national laboratories are systematically moving. - their '

l better people to more-attractive programs.

e RES is having difficulty in attracting competent technical'.

personnel with research experience, which has -led to: ani overall reduction in' quality.

e-The,results of several expensive experimental programs have been lost.

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n Th'e Honorable Kenneth M. Carr 5

April 11, 1990 University programs have essentially ceased to exist in most r

e areas.

The role of RES as a world leader in research has diminished.

e e The use of large-scale and separate-effects facilities has ended.

e RES participation in major cooperative foreign experimental programs is diminishing.

CONCLUDING REMARKS g

It is difficult to establish the proper magnitude of support for R

research.

Two aspects should be considered.

First is the absolute magnitude.

In 1975, NRC research was funded at $61 million.

In 1981, research funding had increased to $197

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million, which was about $130 million in 1975 dollars.

In 1991, the buriget calls for about $78 million for NRC research which is about $36 million in 1975 dollars.

Appropriate funding for a research program must be sufficient to retain vitality in programs, personnel, and facilities. What is appropriate depends on a number nr of factors, many of them imponderables.

The nature of important research questions, the existence or nonexistence of appropriate facilities, results of early research, and experience in plant operation are among them.

In the face of these uncertainties, the Commission must make judgments about funding research.

Our judgment is that the present research funding level is below the minimum.

If there are further reductions, RES will not be able to support and maintain an effective research program.

The fraction of the total NRC budget allocated to research is also an important consideration.

It is a measure of the extent to which research programs can be expected to help maintain the technical expertise of the agency.

We mentioned above that the research budget has been reduced from over 40 percent in the earlier years of the agency to about 16 percent in 1991, and that may be further reduced by the Congress.

Fe believe there is evidence that this is too low and suggest that a guideline of at least one-quarter of the agency budget is more appropriate for a viable research program.

Finally, we suggest that you not take just our word for it.

The agency has in place an excellent panel of experts to advise the RES Director, namely the Nuclear Safety Research Review Committee.

We suggest that they focus more on their primary mission, which is to advise on general safety research philosophy and long-range strategy, rather than on the details of specific ongoing research programs.

They should consider questions of what might constitute

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~ Th'e Honorable Kenneth M. Carr 6

April 11, 1990-s a viable research program, in terms of the technical areas and.

I funding requirements, both absolute and relative.

l Sincerely, Carlyle.Michelson Chairman

References:

1.-

ACRS Report dated March 15, 1989, from Forrest J. Remicki ACRS

Chairman, to Lando W.
Zech, Jr.,

NRC' Chairman,

Subject:

Proposed Severe Accident Research Program Plan.

4; 2.

ACRS Report dated July. 7',

1988, from David A.

Ward, Acting-ACRS Chairman, to Lando W. Zech, Jr.,-NRC Chairman,

Subject:

NRC Research Related to Heat Transfer'and Fluid' Transport in.

Nuclear Power Plants.

-j 3.

ACRS Letter dated December 8, 1987, from. William Kerr, ACRS-Chairman, to Victor Stello, Jr., EDO,'

Subject:

ACRS Comments on Memorandum from Victor Stello, Jr., EDO,--dated > October 7, 1987, Regarding the Embrittlement of Structural Steel.

4.

ACRS Report dated September 11, 1987, from William Kerr, ACRS Chairman, to Lando W. Zech, Jr., NRC_ Chairman,-

Subject:

"ACRS=

Comments on Code

Scaling, Applicability and-Uncertainty Methodology for Determination of Uncertainty Associated with' i

the Use of Realistic ECCS Evaluation Models.

1 I

5.

ACRS Letter dated July 15, 1987, from William L Kerr, ACRS:

Chairman, to Victor Stello,-Jr., EDO,

Subject:

i ACRS: Comments.

{

on the Embrittlement of Structural Steel.

6.

ACRS Report dated - July 15,

1987, from William Kerr, _ ACRS Chairman, to Lando W. Zech, Jr., NRC Chairman,

Subject:

-.ACRS j

Comments on Draft NUREG-1150,

" Reactor Risk Reference Document."

7.

Letter dated February 8, 1985, from E. P. Rahe,.Jr., Nuclear Safety Manager, Westinghouse Electric Corporation, to D.

F.-

Ross, Office of Nuclear Regulatory-Research,.NRC,

Subject:

LOCA-Margin Benefits, i

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