ML20054E899
| ML20054E899 | |
| Person / Time | |
|---|---|
| Issue date: | 06/03/1982 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Watkins K LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| References | |
| FOIA-82-212 NUDOCS 8206150011 | |
| Download: ML20054E899 (1) | |
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(f[,g NUCLEAR REGULATORY COMMISSION 5g t#f.. y WASWNGT ON, D. C. 20555
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June 3, 1982 g-
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Katharine A. Watkins, Esquire s
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Lowenstein, Newman, Reis & Axelrad m
1025 Connecticut Avenue, N.W.
IN RESPONSE REFER Washington, DC 20036 TO FOIA-82-212
Dear Ms. Watkins:
This is in response to your letter dated April 23, 1982 in which you requested, pursuant to the Freedom of Information Act, a copy of SECY-82-72A.
A copy of the requested record is being placed in the NRC Public Document Room (PCR),1717 H Street, N.W., Washington, DC 20555.
You may obtain access to this record by presenting a copy of this letter to the PDR or requesting folder F0IA-82-212.
There is no charge for inspecting records maintained at the PDR. The char records maintained at the PDR is five cents ($0.05)ge for copying per page, as specified in 10 CFR 9.14(a).
If you do not wish to visit the PDR to inspect or copy this record, you may obtain a copy by calling (634-3273) or writing directly to the PDR.
Upon your agreement to pay the copying charges, the PDR will arrange for the record to be copied by a private contractor servicing the PDR. You will be billed by the private contractor for copying charges, plus tax and postage.
Sin er ly, f
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. M. Felton, Director ivision of Rules and Records Office of Administration 8206150011 820603 PDR FOIA WATKINU82-212 PDR J
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March 25,1982
..,S SECY-82-72A
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POLICY ISSUE (Information)
For:
The Commissioners From:
William J. Dircks Executive Director for Operations Subject C0ORDINATED PROGRAM FOR STEAM GENERATORS Purpose':
To advise the Commission of a ' proposed management' st'ructure for a coordinated NRC/ Industry Steam Generator Program and of plans for" developing the effort as a joint government / industry effort.
Discussion:
In a previous paper on tha 9verall Steam Generator Program (SECY-82-72), I reported that
..e staff was working to develop a coordi-nated NRC/ Industry program on the necessary short term fixes and longer term ~research activities that could promote resolution of.
l the steam generator degradation problem.
Working together with NRR and the ACRS, and the lead office, RES, we have now developed a proposed management structure for an NRC/
Industry coordinated program to address Steam Generator Degradation I
(Enclosure 1).
A two-tiered management structure has been developed
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that will be headed by a Policy Group of top level people to provide overall direction and to be spokesmen for committing funds, and 1 Steeri.ig Committee of engineering managers that would be responsible for identifying the needs for resolving the problem, reviewing i
l current work. to '.dentify gaps, and the'i managing this work as well as coordinating :he already ongoing work.
Attachment A to
- disi.sses the kinds of technical issues that must be addressed by the Steering Committee.
l To initiate this effort we plan to invite a senior official of l
AIF, EPRI, the Steam Generator Owners Group and ACRS to discuss the feasibility of a coordinated NRC/ Industry effort.
At
- is an proposed agenda for that meeting.
Contact:
C. Z. Serpan, RES 44-35907
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The Commissioners.
I am taking the lead in s'etting up the initial meeting.
William J. Dircks Executive Director for Operations l
Enclosures:
1.
Proposed Management Structure for an NRC/ Industry Coordinated Program to Address Steam Generator Degradation, with Attachment A 2.
Proposed Agenda
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PROPOSED MANAGEMENT STRUCTURE FOR AN NRC/ INDUSTRY COORDINATED PROGRAM TO ADDRESS STEAM GENERATNR DEGRADATION Objective The objective of this paper is to outline a structure for developing, managing and implementing the results of a coordinated NRC/ Industry Steam Generator Program that will result in better resolution of the degradation problems in stemn generators so as to assure short-term needs and longer term solutions for safety and reliability of steam generators.
The fol. lowing plan of action addresses the problem of steam generator degradation, and is a follow-up to the earlier Canmission Paper (SECY,
- 72) which presented a sunmary overview of the problem, what is going on right now, and what are some of the short term fixes being employed.
The initiation of this effort should be via an invitation -
to the Presidents of AIF and EPRI, and the Chairman of the Steam Generator Owners Group and ACRS to meet and discuss a series of issues centering on the establishment of a coordinated NRC/ Industry Program to address the problem of degradation in steam generators.
These issues would include the objective and scope of the program, the management structure, membership and chainnen, provision for funding of the effort, control and management of the research activi ties, short tenn needs, and the need for coordination and collaboration of appropriate organizations to assure implementation.
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Implementation of this plan requires the identification and organization of a small group of people from governnent and industry to direct and manage the effort, as well as the identification and study of the technical and short-tenn regulatory issues relating to the steam generator degradation.
Management will be by a two-tiered structure consisting of (1) a small Policy Group to set goals and directions and to be spokesman to canmit funds, plus (2) a larger technically-oriented Steering Committee that would develop details of the program and effect its management, as well as recommend methods for timely implementation.
Identification of the proper personnel,
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Chainnan, working methods, authority, etc., for these canmittees are matters that must be worked out and are discussed briefly herein. The technical and' regulatory issues are summarized in this. document as well as in SECY-82-72, but the details of what ha' aeen done, is being'done, and what needs to be done, as well as how to gain rapid implementation of acceptable solutions all must be studied and worked out by the Policy Group and Steering Committee.
It is foreseen that these two groups would first draw up a comprehensive plan of what is needed to resolve the problem, including both technical and licensing issues.
The next step would be to canpile a summary of the ongoing work and detennine how much of it could be enbraced or easily modified to become part of the overall plan. Then, the remaining research and shorter tenn regulatory work could be identified as required to be undertaken for problem resolution; this new work is expected to be smaller in scope than that already underway. The groups should bend every effort to utilize information already available to aid short-term needs, set priorities and reduce unnecessary expenditure of resources with corresponding savings of time. Therefore, for this scenario to be successful, it is crucial that
3 current ongoing and planned work be made available so that it becomes an integ,r,al part of the overall program.
Management Structure It is proposed that a joint program to resolve the steam generator degradation problem be managed by a two-tiered structure consisting of a small Policy Group and a larger Steering Canmittee.
Policy Group - The role of this group would be to identify the overall needs and directions, assure complete coverage without undue overlap, assure the inclusion of and coordination with ongoing programs, approve the plan for' research and shorter-term needs recommended by the Steering Canmittee, recanmend the plan for implementation, and following' appropriate management a'pprovals, canmit funds and manpower or other resources for the work.
This Policy Group should be rather small--between four and seven persons.
The specific individuals and the identification of a chairman are questions to be addressed.at the initial meeting between NRC and industry.
As a core, the Policy Group should.contain a representative from the utility /nuc. lear industry, the ACRS, the NRC, and from EPRI or steam generator owners groups.
Policy Group members should be of a senior level, be reasonably cognizant of stema generator problems, and have the authority to commit funds and manpower or other resources of their respective organizations.
It is expected that the authority to canmit funds will be worked out between the representative and the management of the organization he represents.
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g The Chaiman of the Policy Group will be a critical choice.
He can be'from NRC or from the industry.
A chainnan from the NRC would certainly help keep the program oriented toward regulatory goals and issues.
However, the steam generator problem has a large reliability facet to it, and in the final analysis, steam generators are a utility problem encompassing both safety and economics.
Furthemore, the industry has committed significant funds to help resolve steam generator problems.
For these reasons, it is believed that a chainnan from industry would be more appropriate for the Policy Group.
If the industry coalesced around one group and one person as spokesman who is chaiman, he could be given authority and funding power up to certain l'imits' by an industry review board,' and he could then go back for more when and as he needed it.
This industry chaiman could then truly operate from a base of significant authority to lead and. direct wo rk.
The Policy Group needs to be sufficiently strong and command the appropriate respect to assure that the research program it approves and funds is directly carried out by the subordinate groups and research activities, and that the recommendations for implementation are carried out.
Each of the participating goverment and industry organizations would be expected to support the l
program financially and provide manpower for the Steering Committee, as requi red.
Following the initial series of organization meetings, we expect that the Policy Grcup would need to meet fomally'for a day about twice a year, but be prepared to review the ongoing work on a more frequent
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basis, as requested by the Steering Committee.
The Policy Group would depend heavily on the Steering Committee for detailed program recommendations and for close administration of the research work.
For this reason, serious consideration should be given to making the chaiman and vice chaiman of l
the Steering Committee ex officio members of the Policy Group.
It would be l
a key ~ responsibility of the Policy Group, however, to assure'close participation of all necessary and cognizant groups involved so that the results that flow from this effort will be readily accepted and rapidly implemented.
Steering Committee - The role of this group is to plan, recommend, monitor, coordinate and manage the research program as well as develop an implementation plan aimed at. solving both the short and long-tem steam generator degradation problems.
The Steering Committee will be responsible for carrying out a broad spectrum of programmatic activities and, hence, its membership would consist of about 10-20 individuals.
Technical expertise in one or more of the disciplines needed for resolving the issues before the Committee would be a principal ~
criterion for membership.
The members could be drawn from the ACRS, licensing dnd research offices of NRC, DOE, utilities, vendors, EPRI, Academia, testing and/or inspection organizations, for,eign countries, professional societies and consultants.
The makeup of this Committee, the breadth of its scope, and the assignment of chaiman fran NRC or industry are issues to be worked out; decisions on
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6 Gr these issues should be made at the meeting between NRC and industry representatives which will initiate this entire efrort. The level of Steering Committee members should be.that of engineering managers, such as ACRS members, who have access to large snounts of information on the steam generator problem, but also are in good positions to channel manpower to the efforts.
Members at this level are in a good position to gain the the confidence of the Policy Group thereby making for good re,lations between the two groups.
Members would probably depend upon subordinate staff efforts to develop the information and to ultimately manage the coordination and research work; thus, this option has the disadvantage of establishing, de facto, a third level of support.
However, we do not believe that this a serious problem.
Selection of a chairman and vice chairman for the Steering Canmittee should be an important issue of the initial NRC/ Industry meeting.
If we accept the premise that the Policy Group Chainnan be from industry, then a good balance would be provided by having the Steering Committee Chainnan from NRC and its vice chainaan fran industry.
The Steering Committee Chainnan needs to be strong, technically oriented, and one who w'ill have sufficient time available to devote to its activities and demands.
The Chairman must also have a clear sight to the goal of safety and reliability of steam generators. The selection criterion should be that of technical competence plus ability to manage large, multidisciplinary efforts. An additional duty of the Steering Committee Chairman would be to attend all Policy Group meetings whether or not he is made an ex-officio member of the Policy Group.
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Members could have specific responsibility within the canmittee, for the technical area of their special expertise or-interest.
They would further be responsible for organizing and running appropriate support activities on that specific subject to get the broadest practical base for input and constructive criticism of the proposed program of research.
The Steering Canmittee would meet at reasonably frequent intervals, say quarterly, and it is foreseen that the meetings would be on the order of several days in length, consisting of highly interactive workshop-level discussions rather than a seiies of presentations for subsequent canment.
The first order of business for the Steering Committee would be to determine what needs to bd done, to review all ongoing steam generator.research activities in view of the stated needs, identify the remaining work to be done, suggest short-term needs that could be rapidly addressed, and outline a plan for final implementation of results and recommendations.
Therefore, at the outset, the Steering Canmittee would be expected to be in session more frequently over the early months of the effort until a comprehensive research program and implementation plan were put into place.
Operating Philosoohy The primary function of the program is to coordinate already ongoing research activities, manage the new research that energes from a review of the needs as balanced against the current work, and develop solutions to short-term needs as well 'as long-range problems.
Funding for this new work would have to be identified, and possibly even placed in a conmon pool.
The amount of C
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funds to be made available in any such pool of money fran both NRC and Industry is not clear at this time.
The primary reason is because work already underway,in NRC research programs, owners groups, vendors, etc.,
would not be merged with the coordinated program for funding purposes, but rather would continue to be managed and funded-by the respective organizations.
These ongoing programs would, however, be coordinated through the program, and the results would certainly be merged with those coming from the program research efforts.
Thus, the amount of funds in the pool would not represent all that currently being spent, but only that needed for the newly-identified work.
Two different operating philosophies are possible for the conduct of the coordinated steam generator research program and the administration of the
" po ol " fu nds.
For the first option, all the necessary funds for the new work would be put into a canmon pool, and the work would'be funded therefrom.
This option has the advantage of focussing the work with the overall coordinated research program rather than with the individual participating agencies.
A potential disadvantage of this option is that it could appear that NRC would be financially contributing to the resolution of the reliability and econanic problems of steam generators and not just of safety aspects.
The second option is for assignment of responsibilities for research tasks among the various participants, with those participants then performing the actual contracting and funding within their respective agencies.
The fragmented approach is currently in practice, and although it may be easy i
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to implement, program control will be weakened.
It would be preferred for either option, that the research program monitors be either members of the Steering Committee or be directly responsible to the Steering Committee-member within their respective organizations.
Implementation of the results and recomnendations of this effort into new procedures, regulations, etc., must be accanplished. As already noted, both the Policy Group and Steering Committee must address themselves to this issue of assuring that the research findings are translated into new procedures or equipment that can better control or mitigate the material degradation occurring in stemn generators, and that the appropriate national standards, guides or regulations be prepared and implemented for this same goal. -It is in the best interest of both industry and NRC to mutually achieve this goal.
Technical Issues and Disciplines The technical issues involved in steam generator degradation are discussed in the " Steam Generator Status Report" Canmission Paper, SECY.82-72.
They include materials, water chemistry and control, design and mechanical con-siderations, secondaky system components, primary and secondary side inspection, repair procedures and personnel exposure, systems interactions.
QA and licensing reviews and implementation.
A summary discussion of these technical issues and disciplines is provided as Attachment A to this enclosure.
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'l ENCLOSURE 1,
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ATTACHMENT A e
SUMMARY
DISCUSSION OF TECHNICAL ISSUES AND DISCIPLINES RELATED TO STEAM GENERATOR TUBE DEGRADATION
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tbterials - As with most of the technical areas, dwo paths are necessary to pursue:
the' materials of current construction and the materials proposed for new or replacement construction.
Sane critical factors that will need to be considered include (1) corrosion and corrosion rate; (2) compatibility; (3) cracking, including stress corrosion cracking; (4) tube and support integrity; and (5) fabrication and processing.
Water Chemistry and Control - In this area', the water chemistry must be
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studied in bulk and in the crevices or sludge piles where most of the cracking and degradation takes place. The changes in the coolant makeup as a result of resir.-bed and condenser intrusions must be studied.
Proposals for primary side decontamination and secondary side chemical cleaning should be addressed in this area, and plans laid for determining the effects
. of such proced' res on long-term integrity.
Corrosion testing under the u
appropriate conditions revealed fran the water chemistry studies should form the basis for both material selection and the selection of limits.
From this technical area must flow the information upon which are based the reconmendations for improved specifications and limits on water chemistry parane ters.
Desian' and Mechanical Considerations - The potential for many of the current degradation problems is greatly enhanced simply by the design l
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Tube sheet crevices, support hole configuration, preheater baffTes, and design leadi'ng to excessive vibration and fretting are just sme examples.
Fabrication considerations deriving from design include discontinuities in tube surface at the U-bend roll junction, and
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ovalization and residual stresses in U-bends.
Factors th'at need to be considered here, which should lead to strong new recommendations, include adequacy of design review, fluid-hydraulic effects, and adequacy of proof tests for new or replacement components.
Secondary Systen Components - All of the engineered systems in the balance of the secondary systen including those that control, cN1, condense, purify, and pump the secondary coolant must be carefully reviewed, both fra the standpoint of functionality and from operational procedures.
From this area must evolve the recommendations for improvements in or upgrading of the present installed secondary system component, (e.g., materials for retubing of condensers), and for totally new designs for new systems, as well as the validation showing fitness for purpose of al1 such recommendations.
l Primary and Secondary Side Inspection - A number of new and improved NDE techniques are now eitiher under development or ready for implementation, all of which should be caref0lly reviewed and qualified for use in detecting and characterizing cracks, flawe, dents, wastage, thinning, and other fanns of degradation in tubing. Tube plugging and sleeving criteria need to be reevaluated in light of research results on tube integrity versus NDE signal s.
Methods for inspecting the secondary side of generators, plus criteria for how and what to inspect for need to be developed and qualified.
.:. S Repair Procedures and Personnel Exposure - Procedures in use for repair of generator components, especially for plugging and sleeving of tubes, must be carefully reviewed and upgraded, as necessary.
Current practice may show the need for greatly increased use of automation for these tasks to increase speed, accuracy, and quality, and to reduce operator exposure. All tasks related to inspection, maintenance and repair of generators which require activi. ties in close proximity to the generator should be carefully studied with cost-benefit analyses made to determine the most efficient means to accomplish the ends with safety.
Systens Interactions - A comprehensive review of systems response and interactions in the event of a tube rupture is-necessary to ensure that potential safety concerns have been identified and properly addressed.
This effort should go beyond current design basis criteria to consider credible multiple failures which could complicate tube rupture events.
Typical concerns might include multiple tube failures, tube failures in multiple steam generators, control systems failures, and pumps or valve failures.
Operator emergency procedures and NRC regulations should be reviewed in the context of these events to detennine their adequacy and to identify necessary improvements.
Quality Assurance - The Quality Assurance practices associated with the steam generator maintenance, repair, inspection and testing must be carefully considered and developed to assure necessary control over these activities.
The development of new and improved NDE techniques,
.-4' including the qualification of such techniques, and the review and upgrading, as necessary, of the procedures to use for the repair of generator. components has already been mentioned. The quality assurance practices must also address the other aspects associated with ensuring the integrity of the steam, generators such as the control of water chemistry, and the review and upgrading of procedures for routine inspections and tests, including the necessary qualifications of personnel, equipment and procedures.
Licensing Review and Implementation - Operating experience must be reviewed and factored into the direction of the research effort.
Experience should be taken from foreign operating plants, especially if their procedures result.in superior (or even podrer) performance relative to USA plants.
The procedures and criteria for licensing rev'iew of steam generator materials, design and operation should be reevaluated to determine if tightening them can contribute to greater safety (fewer accidents or cracking / degradation incidents) and also better reliability.
Such a detennination would lead to the question of how best to implement the desired changes.
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T*3' ENCLOSURi2 PROPOSED AGENDA MEETING ON C0ORDINATED ST'EAM GENERATOR PROGRAM I.
INTRODUCTION II.
PRESENT STATUS III.- COORDINATED NRC/ INDUSTRY PROGRAM A.
PROS AND CONS IV.
DISCUSS OBJECTIVES OF COORDINATED PROGRAM V.
MANAGEMENT STRUCTURE TO ACCOMPLISH OBJECTIVES
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A.
CONSIDER TWO TIER MANAGEMENT 1.
POLICY AND TECHNICAL GROUPS B.
MAKE UP 0F GROUPS l1.
PROPER MIX - INDUSTRY, ACRS, NRC, OTHER 2.
ORGANIZATIONAL LEVEL 0F MEMB'ERS 3.
IECHNICAL DISCIPLINES NEEDED.,
4.
AFFILIATION OF CHAIRMAN AND VICE CHAIRMAN VI.
CHARTER OF GR0'UPS VII.
HOW GROUPS WILL FUNCTION-A.
TIME COMMITMENT VIII.
FUNDINGOFPROGRdM IX.
CONCLUSIONS AND ACTIONS A.
AGREEMENTSAND ASSIGNMENTS B.
SCHEDULING e
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