ML20054K434
| ML20054K434 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Indian Point |
| Issue date: | 03/03/1982 |
| From: | Conran J Office of Nuclear Reactor Regulation |
| To: | Greismeyer M Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20049A217 | List: |
| References | |
| FOIA-82-176 NUDOCS 8207020076 | |
| Download: ML20054K434 (3) | |
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s/da NOTE TO: Mike Greismeyer, ACRS Staff FROM:
Jim Conran, Systems Interaction Staff, RRAB
SUBJECT:
STAFF /PASNY PARTICIPATION IN SUBCOMMITTEE REPORT SESSION ON SYSTEMS INTERACTION.... AND RELATED MATTERS In response to Dr. Okrent's request (relt.yed by you in our telephone conversation this morning), the staff will attend the Subcommittee Report Session scheduled late Thursday evening prepared to discuss the results and conclusions of the SRP review we have undertaken.
The questions we are examining specifically in our review is what types and to what extent safety system / safety system interactions are included under existing regulations (specifically, under the " licensing basis" for IP-3).
The primary purpose, of course, is to try to better understand just how the systematic and comprehensive treatment of that aspect of systems interaction (particularly in the" spatially-coupled" systems context) would add to the scope, cost, schedule, etc.
of the IP-3 program if included therein.
That's a very tall order, of course; and I do not expect to complete such a review by Thursday evening. But I will be there to share with the Committee whatever I know of these matters by then.
I have also en-couraged PASNY to continue to work on this question, and asked if they would be pre-pared to provide whatever insight they can gain in this regard by the appointed hour.
They have agreed to do so (with the same caveats I have expressed).
I am more than happy to respond in this fashion (and any other reasonable way) to try to resolve this issue that was raised at the Subcommittee meeting, because I genuinely fear that it jeopardizes the proposed IP-3 program.
From conversations with PASNY yesterday and this morning, I believe that there is no doubt left that they are seriously recon-sidering their options (regarding either going ahead or withdrawing their proposal) as a result of the reaction they received from the Subcommittee on Friday.
For our part, Mike, we feel strongly that the PASNY program is an integral and important element of the overall SI program, and is an important vehicle for testing very
" promising" methodology that we feel can be applied effectively and efficiently in the broad scope treatment of systems interactions in reactor plants.
The Subcommittee's questions and comments rega, ding this (comparative methodology) aspect of our program are understandable; but ultimately such questions are not resolvable by speculation or discussion.
They must be given a real trial....and that is what PASNY is offering in their proposed program.
As a further important consideration, because in plant opera-tions it is clear that the " unexpected" will continue to happen because of the'"un-analyzed", we believe that the PASNY program (with all its perceived imperfections) could contribute significantly to improving safety in our operating plants generally, and in IP-3 speci fically.
I surely hope that this current difficulty can be resolved and the PASNY program can go forward as planned.
I believe that a formula can be found to work out differences on these important questions; and, in fact, I believe that one such formula is implicit in 8207020076 820528 U
2-176 PDR
s Greismeyer the transpired at the Suboutline bblow (which refl by the principals inv l ects committee our meeting and regarding thunderstanding a o ved):
1 The Subcommittee has e comentsretation of what SI Analysis Program Dnot reviewe and positions fully reviewed escription);d extensively the PASNY sub stated broad scope the proposal and found i but the Systems Intera t and safety beneficial) 2 c ion Staff hasmittal (P The Subcommittcc t acceptable (i.e of safety systemgarding acceptability ofappeared to
., sufficiently care-the proposed programagree generally with coupled systems"/;afety system interacti but notedthe staff's judgment prehensively in determi i context) did not appear to bon (pa,rticularly that the re-3 The Systems Interactio n ng the scope e
of the proposed programconsidered the safety system /saf t n Staff acknowledged of the com-in the context of theoverall SI analysis issue e y system interaction the Subcommittee's will be treaarea study beyond exA requirement to includ generic " pilot prog concern in x
e treatment of safety /saf SI studies. and compr c
cannot, however,isting regulations /guid chartered specifically t be imposed legally on PA ance (e.g.,ety interactions in the IP 3 without due process SRP methods o prevent the SNY....and the Stello Cand cr 4
becauseThe Subcommittee enco staff from trying to do s i
ommittee is added benefit of full-of the potential safety bthe performance o " informally" uraged
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considered " promising" scale trial ofenefits to be derivedo was understood a " candidate" for additional safetythey have propo, sed at IPhow SI ana(lysisThere is also the ram that, even if PASNY cand efficient, by the SI
-3, i f the methodology quirements staff's generic programs idompletes the b would be imposed (assystem/ safety system SI a plants.
(In sta ff It PASNY indicated theother words, no gradfathe iappropriate
\\5 entify theprogram r
need t
posed program asa condition for going forneed for some ex se re-other docum regard).
operating them,enting the points ward at all.of ACRS acceptance of course) would seem an outlined above (as the Co So of their pro-appropriate vehiclemmittee per,ceivesa Committee letter and format for doing thisand interpre
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't Greismeyer.
I hope that the tine allotted during this full Committee meeting will enable full consideration of all the respective parties' positions as indicated above, and that some sort of letter (or indication of ACRS' intent to provide a letter) indicating positive ACRS response to PASNY's proposal and encouragement to get on with the program can result from the Committee's consideration of these matters at this time.
If we can be of further help in bringing this about, please let me know.
(, h 2~
' Jim Conran Reliability and Risk Assessment Branch Division of Safety Technology i
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