ML20056C530
| ML20056C530 | |
| Person / Time | |
|---|---|
| Issue date: | 02/12/1993 |
| From: | Ward D NRC |
| To: | Carroll J NRC |
| References | |
| ACRS-CT-2060, NUDOCS 9306240424 | |
| Download: ML20056C530 (2) | |
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2/12/93 To: Jay Carroli From: Dave Ward p
Comments on draft letter:
As we discussed, I believe the two subjects would best be covered in two separate letters.
With regard to the OF subject, I offer the following comments:
line 160 I suggest this should not say simply to auantify. The end of any scientific effort is often [always?] to quantify something.
- But, there are steps leading up to this; identifying and characterizing important elements and their relationships.
It is probably too ambitious to expect that quantification of OF will come soon.
line 192 There should be more to OF research than what the staff is doing in the present program. Personally. I believe the emphasis on quantification and PRA is overwrought. I know Murley wants a tool.
But, the use of that tool will only be to help understand how bad something is. The PRA community is cooperating because they like the idea of making PRA more complete and more accurate. Also the attempts to quantify bring some discipline to the research, which is good.
Although there are these benefits in quantifying, I believe the emphasis should be on how to make things right. What is needed from a research effort in this area are not just " measurement tools" but information on how to desian organizations and organizational processes so that NPPs are operated safely.
The driving need behind TH research has never been to furnish information so that TH-related risk might be quantified.
Although that has been a benefit of such research. What TH research is used for is, rather, to provide information which will permit vendors to make adequately good their designs of ECCS and other systems, to permit operators to operate those systems in an adequately good way, and to permit regulators to have confidence that those systems really are being designed and operated in a good enough way.
p Providing input for PRA is a secondary or tertiary part of all of that.
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- ""N 9306240424 930212
-206 PDR Certified By.
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line 204 I agree emphatically with what you say in this paragraph. The approach being taken by RES and NRC management seems almost designed to drive a stake through the heart of, what they seem to regard as, this beast. Thereby making sure it does not rise again in this generation.
line 211 It would be a good idea to make the recommendations more specific:
Continue the program to reduce the number of dimensions, to validate, to the extent possible [There should be no pretense that this can be an exact mathematical validation, but it is still useful and absolutely necessary.], and field test and optimize the measuring instruments [you point out the need for the latter in your paragraph beginning on line 197].
Also, there should not be an expectation that completion of this little program in, say, two years should be the end for all times of R&D effort in this area. We have been doing TH and materials research for 40 years. It is some combination of naivets and arrogance to expect that two years at a few hundred $K per year is going to put these issues to rest. There are certain aspects of TH science and certain aspects of materials science which we have found to have unique importance to the safety of NPPs. NRC and the NP industry have dutifully undertaken the necessary R&D to understand these sufficiently well. NRC and industry have the same duty with regard to management science. They are not very far along. If industry is slow in moving on this, NRC has the responsibility to lead.
They've accepted such responsibilities before.
line 245 You should name the problem more clearly. What is it?
I see this as a " rock-turning-over" or an " emperor has no clothes" effort which has no advocate high enough in the staff to keep it going. The effort calls for a set of skills and interests with which the managers are unfamiliar and uncomfortable. Therefore, it is j
seen as suspect. The favored strategy is to make it go away.
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