ML20054D238
| ML20054D238 | |
| Person / Time | |
|---|---|
| Issue date: | 09/21/1981 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Sniezek J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML19239A281 | List: |
| References | |
| FOIA-81-405 NUDOCS 8204220468 | |
| Download: ML20054D238 (3) | |
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION
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WAp*lNGTON, D. C. 20555
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ecP 21 1981 MEMORANDUM FOR:
James H. Sniezek, Director Division of Resident & Regional Reactor Inspection s
FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
COMMUNICATION RESPONSIBILITIES FOR TMI ACTION PLAN INFORMATION This is in response to your memo of September 1,.1981.
I concur with the agreement and am' returning the signed original herewith.
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arrell G.
isen ut, Director Division of Licensing l
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Enclosure:
As Stated cc: R. Tedesco G. Lainas T. Novak J. Olshinski
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A 8204220468 811112 PDR FOIA SHOLLY81-405 PDR
TMI ACTION PLAN COMMUNICATIONS RESPONSIBILITIES The Offices of NRR and IE accept the responsibilities listed below in order to ensure the effective exchange of TMI Action Plan infomation:
1.
Starting in September,1981 and' monthly thereafter, IE/DRRRI will send to NRR/DL a printout of TMI Action Plan Tracking System status (full listing) for each operating reactor docket to which NUREG-0737 enclosure r
1 applies.
2.
NRR Project Managers will review the listing for thei assigned dockets and will notify the Resident Inspector per telecon of the following:
l a.
Acceptance by NRR of a change in due date' to which the licensee is committed for items subject to IE verification. This notification will include references to licensee and NRR written correspondence that document the change in date.
b.
Decisions by NRR that licensee commitments are inadequate based on post-implementation review, and imposition of additional requirements on licensees necessary to satisfy items subject to IE verification.
This notification will include references to licensee and NRR written correspondence that document the change in requirements and acceptance of new commitments.
4 3.
IE, Resident Inspectors will review the TMI Action Plan Tracking System listing for the affected dockets', based on information received from NRR
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Project Managers, and revise when appropriate, l
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NRR will notify IE/DRRRI when new requirements or generic changes to existing requirements are issued.
IE/DRRRI will determine which of these new requirements or changes are appropriate for IE verification, and IE will revise or issue inspection procedures accordingly.
5.
NRR will provide feedback to IE/DRRRI on the acceptabili.ty of_ safety evaluation reports prepared by IE, including specific SERs which need improvement prior to issue.
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l JamesH.Sniezek,Directjr DM. Eisenhut, Director Division of Licensing Div' sion of Resident and Regional Office of Nuclear Reactor Regulation
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J MEMORANDUM FOR:
Chairman Ahearne Commissioner Gilinsky Commissioner Hendrie -
Commissioner Bradford
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FROM:
James J. Cummings, Director Office of Inspector and Auditor
SUBJECT:
IMPROVEMENTS NEEDED IN COORDINATING THE DEVELOPMENT 0F 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
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accident at Three Mile Island (THI).
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, DIA is deferring work in this area until a future date. We do, however, have sme 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 OIA during the survey which we believe merits immediate attention.
'0BSERVATIONS
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TMI ACTION PLAN
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.In general,'the cmponents of RES's revised program are contained in the -
NRC Action Plan developedin response to the recommendations of the y,., _
numerous investigative ~ reports on the'THI accident.
The NRC Action..: :...
Plan delineates 23 separate tasks for which RES either has direct or i.
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supportive responsibilities.
It is. estimated that $68.2 million and r.,
26.6 RES. staff years will te required in fiscal year (FY)_1980 to be' gin 4 Pr-W work on the 23 tasks. Res'ources.to continue kork.on these tasks are
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estimated at $6'/.4 million and 26.4 RES staff years for FY 81.
A deta.iledWi'.QF
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breakdown of these tasks and their associated resource requirements are contained in Attachment I.
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4 According to RES officials, it was readily apparent fron the Till accident 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 after the 11 arch 1979 accident.
Some comments on two of these programs follow.
SMALL BREAK LOCA AND ANOMALOUS 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 testsatloss-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 Till were started immediately after the accident at Till.
The LOFT plan accelerated the tests for small break and anomalous transients which were scheduled for later fiscal years and deferred scheduled large break tests until the new test series can be completed.
Initial testing efforts are already undenvay. 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 Synlemental 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 the 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 l
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 funding of $8.4 million in FY 80 and $12.9 million in FY 81.
RES officials recognized shortly after the THI accident that extensive research was needed in the core degradation / fuel melt area and began assembling a program plan in the sumer 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 into 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 THI, its scheduled accomplishments will be totally dependent on available funding, which at this time is still uncertain.
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One 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 l
expressed the view that the research necessary to provide the technical l
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 rules currently under development.
IllPROVEMENTS NEEDED IN COORDINATING THE DEVELOPl!ENT OF RELATED RULES 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 (Nird 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 6ad aeasures to control 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) 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 varied. The major problem areas identified with related staff comments follow: -
The development of the siting, degraded 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 NRC.
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currently there is no one individual or organization within NRC coordinating the degrade core rule (RES official).
I a fundamental problem with the development of the rules is that
t organization responsibility is fragmented within NRC--there is l'
serious overlap in responsibility for rule development between SD and NRR--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 commit 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 should 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 form 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 formulative stages--such analysis is necessary to determine 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).
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Ineffective coordination in rule development on the part of the NRC will adversely impact public and industrial comment.
5 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 Ilhile 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.
RECOMMENDATION We recommend the EDO take immediate action to establish the means for assuring effective agency wide coordination of the four actions discussed in this report.
AGENCY COMMENTS The EDO 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 ccntained in Attachment II.
cc:
W. Dircks, AEDO l
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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 Instrumentation Work Already Underway 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 Analysi-s 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 Population Densities Support of Rulemaking on 0.4 1.0 Notice to Conduct Rule akin-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 Underwey Program (IREP)
Continuation of IREP 0.2 0.1 Approach to be Developed in October, 1980
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 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 ll,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 Containment Structure -
Nuclear Data Link 300k 0.3 Work Already Underway Radioactive Gas Management 150k Work to be Initiated in FY 82 or Later Study Radiciodine 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 Hornal HRC Operatinq Budca' 4
RESOURCES DOLLARS STAFF MAN YEARS TASK DESCRIPTION FY 80 FY 81 FY 82 FY 80 FY 81 FY 82 SCHEDULE Plan to be Developed by 0.1 Plan for Early Resolution of Safety Issues October,1980
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0.1 Support of Assessment of Operating Reactors TOTAL 68,220k 67,350k 6,160k 26.6 26.4 3.0 L
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August 14, 1980 MEMORANDUM FOR:
James J. Cumings, Director Office of Inspector and Auditor FROM:
William J. Dircks Acting Execut?ve Director for Operations
SUBJECT:
RESPONSE TO DRAFT OIA REPORT:
IMPROVEMENTS NEEDED IN COORDINATING THE DEVELOPMENT OF RELATED RULES 4
We appreciate the opportunity to review the draft memorandum.
Specific comments follow:
Small Break LOCA and Anomalous Transient Tests at LOFT.
The cut-back in the small-break LOFT program represents a considered balancing of financial expenditures vice program results in the process of budget development.
The views of all concerned have been considered.
Integrated Fuel Melt Research Plan.
The offices of HRR, RES, and SD believe that the research in this area is appropriately designed, or will be by the time the plan is approved. We note that the ACRS feels more resources may be needed (NUREG-0699) to carry out the work rapidly enough.
Improvements Needed in Coordinating the Development of Related Rules.
The problem of coordinating the related sets of rules and the supporting activities by the staff has been recognized for some time.
Meetings involving senior representatives from NRR, RES, and SD were held in Spring,1980, to establish close coordinating of efforts and have been continued to date.
A feedback process, contingent on a certain level of development of the rules, is neces-sary before effective coordination is possible. An action plan is being developed by SD for the interrelated rulemaking and will be presented to the ED0 in August 1980.
illiam J. Dircks Acting Executive Director for Operations
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