ML20058A674

Forwards Comments Re Program Support Budget for FY84 & FY85. No Distinction Made Between Program Support Funds for Research & for Work on Stds Development

ML20058A674
Person / Time
Issue date:	07/14/1982
From:	Shewmon P Advisory Committee on Reactor Safeguards
To:	Palladino N NRC COMMISSION (OCM)
References
ACRS-R-0984, ACRS-R-984, NUDOCS 8207050100
Download: ML20058A674 (16)

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UNITED STATES at E '~

NUCLEAR REGULATORY COMMISSION o

E ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9

W ASHINGTON, D. C. 20555 o

%,*****/g July 14,1982 Honorable Nanzio J. Palladino Chainnan U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

ACRS REPORT ON THE NRC SAFETY RESEARCH PROGRAM BUDGET FOR FISCAL YEARS 1984 AND 1985 The Advisory Committee on Reactor Safeguards is pleased to transmit its comments on the Office of Nuclear Regulatory Research Budget proposed for FY 1984 and 1985.

Only that portion of the budget relating to Program Support has been considered.

No attempt has been made to distinguish between Program Support Funds for research and for work related to standards development, since the latter repre-sent a relatively small proportion of the total.

The proposed funding levels considered are those included in the recommendations of the Executive Director for Operations which were provided to the Committee for its 267th meeting, July 8-10, 1982.

l We will be pleased to discuss these comments with you and the Commissioners, if you desire.

Sincerely, P. Shewmon Chairman i

r"SIGMT7 Certified By _ k,y~? /,

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1 1.

INTRODUCTION Our comments are divided into three parts.

Section 2 relates generally to programs for which we think greater effort or emphasis is needed.

Section 3 provides specific comments on the proposed programs in each Decision Unit and, in most cases, for individual Subelements within each Decision Unit.

Specific recommendations regarding the Research Program Support Budget are given in Section 4.

2.

GENERAL COMMENT

S 2.1 Introduction The Of fice of Nuclear Regulatory Research (RES) still fails to give to certain programs the emphasis recommended by the ACRS.

Several of the more important programs in this category are discussed in the remaining portion of this Section, and recommendations for funding, as appropriate, are given in Section 4.

2.2 Light-Water-Reactor (LWR) Safety Approach in Other Countries There now exist increasingly sophisticated approaches to LWR safety, or specific aspects thereof, in many foreign countries including France, the Federal Republic of Germany (FRG), Japan, Sweden, and the United Kingdom.

The NRC Staff should make a major effort to remain current concerning such developments, including not only a knowledge of differences from U.S. prac-tice but also the detailed reasons for these differences.

For example, the Japanese have specific approaches to seismic design and qualification, the British have developed many significant additional safety requirements for their version of the Standardized Nuclear Unit Power Plant System (SNUPPS),

and the Germans and Swiss, among others, have developed special requirements for shutdown heat removal and sabotage protection.

The NRC Staff appears to have maintained a casual, even parochial, attitude with regard to understanding foreign safety approaches to LWRs.

RES should devote enough resources to this task so that, working in concert with the Office of Nuclear Reactor Regulation (NRR), they can develop the relevant information expeditiously.

2.3 Design-Related Safety Research In NUREG-0795, we called attention to an aspect of safety research that has been weak or deficient in the past NRC program, namely design-related safety research and analysis.

We noted the importance of a knowledge of design I

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possibilities, capabilities, costs, and tradeoffs, and called attention, as examples, to the need for more effort of this kind in the areas related to severe accident rulemaking and design to reduce the potential for sabotage.

The recently initiated studies of detailed plant behavior in support of the Unresolved Safety Issue on the Safety Implications of Control Systems (A-47) is an example of such research.

Another example is an examination of the relative merits of an improved direct capability for pressure reduction in the primary system of a pressurized water reactor (PWR) compared to increased diversity and/or redundancy in the auxiliary feedwater system.

Automatically controlled pressure restoration and direct control of pressure to suitably low values after a chilling transient, along with automatic restoration, i f necessary, of core submergence (or other mode of cooling) might be worth investigating as a solution to the current Pressurized Thermal Shock (PTS) problem.

We believe that a thoughtful program of design-related safety research and analysis should be instituted.

2.4 Externally-Produced Floods There is fairly general agreement that it is now difficult to quantify the contribution to risk from accidents which arise from externally-produced floods.

The uncertainties in any estimate of the recurrence frequency of the " probable maximum flood" are very large, and the degree of protection afforded by the approach currently approved by the NRC Staff may vary widely from site to site.

Although we have recommended on several occasions that priority be given to research on flood probabilities in the NRC Safety Research Program, the NRC program includes no flood related research in FY 1982 and 1983.

However, we l

are pleased to note that about $0.5 million per year is proposed currently l

for flood related research both in FY 1984 and 1985.

In addition to a continuing inability to assess the adequacy or the possible excessive stringency of the current requirements for flood protection, the low priority given to this matter by the Staff in the past leaves the NRC ill-equipped to deal with flooding in connection with the newly proposed NRC safety policy.

For example, the adequacy of design basis flood conditions is being questioned in several plants as part of the Systematic Evaluation Program.

Decisions regarding the allocation of resources in backfitting l

cases such as these may require, or could benefit from, flood probability guidance.

l We believe that the NRC should maintain the necessary priority for flood l

research in FY 1984 and 1985, and should accomplish some reprogramming of money to this task in FY 1983. We recommend that the NRC state its intention l

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to support research in this area, set aside appropriate funds, and encourage the receipt of well thought-out proposals from recognized experts having the potential for making a significant contribution to NRC needs in this area.

An area for emphasis should be that to obtain improved knowledge of increas-ingly severe precipitation conditions and the accompanying hydrological status (or at least a better definition of the uncertainties and their causes).

2.5 Seismic Effects in Control Room The NRC has research programs on Human Factors, Seismic Safety, and Severe Accident Sequence Analysis, including some evaluation of the emergency operating procedures currently under development by the industry.

In addi-tion, work is underway or contemplated on prioritization of alarms.

However, a topic not specifically identified is the matter of how severe earthquakes may unpredictably and simultaneously impact a nuclear power plant in a large number of different ways, leading not only to a transient and/or possibly concu ent small LOCAs, but also to an indeterminate set of systems, possible failure of some engineered safety failures in non-safetf features, a loss of most of the information normally available to the control room, and the existence of spurious information.

The vendors maintain that their newly developed symptom-oriented procedures should be adequate for the seismically induced transient / accident, as well.

However, this is currently a poorly studied area, and warrants a well-focused safety research effort that takes advantage of other relevant pro-grams.

2.6 Design Against Sabotage On several prior occasions, we have recommended that the NRC Staff perform necessary research to obtain enough information to enable the NRC to develop a regulatory approach regarding the matter of what additional provisions, if any, should be included in LWR design to reduce the likelihood of a serious accident arising from sabotage by insiders or outsiders.

The NRC Staff has performed some safety research in this area.

However, the Staff states that budget constraints have limited the extent to which they are developing a regulatory policy on possible design approaches to prevent sabotage.

We believe that it is time this matter received the needed priority.

We anticipate that the attempt to write a proposed rule and/or the comments from the nuclear industry will clari fy further research needs requi ring substantial funding beyond that currently contemplated by the Staff, if this matter is to be dealt with in a timely fashion.

4 3.

SPECIFIC COMMENTS AND RECOMMENDATIONS 3.1 Reactor and Facility Engineering 3.1.1 Mechanical Engineering Redirecting some of this effort toward showing the effect of allowing ductile fluid system boundary piping to work in the inelastic deformation range would be of value in clarifying the failure potential associated with mal-functior, of anchors and snubbers, unanticipated thermal movement, and mis-location of restraints.

Since such errors cannot be totally avoided by design, toere is a need to show that some structural tolerance exists for this type of error.

In addition, much of the safety significance of pressure system ruptures is dependent upon the manner in which system ruptures occur and how the rupture size is affected by fluid system forces applied to the rupture opening.

Not enough has been done to relate system pressure change, fluid mass flow, and rupture geometry in a manner that would give realistic charac-terization of the effects of fluid system ruptures on public safety matters.

Recent events at the Ginna Nuclear Power Plant, as well as prior concerns for asymmetric loads under postulated guillotine pipe ruptures, further emphasize the importance of such research.

The plan for developing improved under-standing of rupture behavior should be clarified prior to implementation of the FY 1984 safety research program in this area.

3.1.2 Seismic Safety Margins Research Program (SSMRP)

NRR has recently issued a strong user need request for short-term and long-term probabilistic seismic analysis methodology.

Although we have been critical of the SSMRP in the past, we have been urging the development of such an analytical capability and support NRR's request.

Further, we reit-erate our previous recommendation that the SSMRP include a limited proba-bilistic seismic safety study of a boiling water reactor.

3.1.3 Primary System Integrity The proposed program on Primary System Integrity is sound.

The increased funding is primarily for work on material fracture in relation to the concern about possible pressure vessel rupture resulting from PTS.

The program should provide a basis for regul atory decisions concerning:

(a) Which, if any, available nondestructive-examination techniques would allow one to determine if the irradiated region of the pressure vessel is free of cracks that can give rise to catastrophic consequences from PTS events.

5 (b) The problems associated with annealing an irradiated reactor pressure vessel,in place.

3.1.4 Electrical Equipment Integrity This program continues to include fire qualification work.

We still believe that the fire safety work should be supported by industry sponsors, but concede that if the need is as urgent as the NRC Staff believes, then NRC funding might be justified.

3.1.5 Process Control This program appears to be in need of a better definition of its goals and of improved organization.

3.2 Facility Operations 3.2.1 Human Engineering and Man-Machine The proposed budget and scope for Human Factors research have been increased significantly in FY 1984 and 1985, continuing the trend of the past few years.

We believe that this trend is appropriate and that the proposed funding levels are adequate.

The NRC Staff has responded satisfactorily to the concerns related to the Human Factors research program as expressed in our report to the Congress (NUREG-0864).

We believe that the new and modi-fied programs proposed for FY 1984 and 1985 will be of substantial benefit; however, consideration should be given to an expanded program directed toward reducing the safety impact of human failure in maintenance and testing.

We also note that there is a trend toward increasing research on human per-formance as compared to that on the machine aspects of the human-machine system.

We believe that this trend should continue into future years.

3.2.2 Plant Instrumentation and Control We continue to support research in this area.

The proposed budget for l

l FY 1984 and 1985 represents a significant increase over the FY 1982 and expected FY 1983 funding levels.

We endorse the proposed levels of funding for FY 1984 anJ 1985.

Nevertheless, based on our review of the ongoing and the proposed research in this area, we believe that the major activities being conducted are comparatively new and are trying to find a mission.

We believe that they have not yet succeeded.

What is needed is a more careful definition of the problems to be solved and the questions to be answered.

1 We believe that the ongoing and the proposed work should be reexamined to establish relevance to NRR licensing needs and to determine its effective-ness on a cost-benefit basis.

The review should address the timeliness of l

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6 the expected results, and whether the specific projects planned are more properly an industry or NRC responsibility.

We believe that NRR should be an active participant in this review.

The work as currently planned appears to put too much emphasis on the behavior of specific tystems and components and not enough on the development of a statement of safety needs and performance criteria. We believe that this is a weakness that must be remedied.

We believe especially that the work that is directed toward evaluating and developing methods for defining the safety implications of control systems should be given a high priority and should be directed toward the prompt resolution of the Unresolved Safety Issue on the Safety Implications of Control Systems (A-47).

It is unlikely that this will be achieved under the current work plan.

We urge that additional planning effort be given to the tasks of this Subelement and that better coordination be established with users of the expected results.

3.2.3 Occupational Protection As mentioned in our May 12, 1982 letter to the Executive Director for Opera-tions, we believe that greater effort needs to be directed to occupational protection.

A concerted effort should be made to gain a better understanding of the control of radionuclides and their removal from nuclear power plant cooling systems.

A clearer definition of overall goals and objectives, and a specification as to how each research project assists in the attainment of these objectives would be beneficial.

Among the specific projects reviewed, the one on Optimization Studies may deserve increased funding support for both FY 1984 and 1985.

3.2.4 Safeguards This Subelement includes a number of routine--though necessary--chores which will require continuing attention.

These include support for new rules and guidance, equipment acceptance criteria, optimization of the use of inspec-tion manpower, and study of the vulnerability of Independent Spent Fuel Storage Installations.

The budget for this Subelement has been drastically reduced ($3.6 M in FY 1982, $2.2 M in FY 1983, and $1.0 M in FY 1984-1985).

This appears to be appropriate, at least so far as items of the sort referred to above are concerned.

However, there are several safeguards projects which deserve greater emphasis in FY 1984 and 1985.

These include studies of both design and human factors to minimize the likelihood of sabotage by insiders, l

and studies to acquire knowledge of foreign technology for safeguards against sabotage.

The budget should be set and/or apportioned to enable studies of these matters.

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7 3.3 Thermal Hydraulic Transients 3.3.1 Semiscale and MOD-5 There are many integral facilities that simulate the Westinghouse type PWR.

Among these are Semiscale, LOBI, PKL, CCTF, and SCTF.

We endorse the possibility that the NRC will play a role in the integral Japanese facility

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ROSA-IV.

It should be noted that all of these facilities use electrically-heated rods and have received some criticism for this reason.

Some of the differences in performance between nuclear and electrically-heated rods have been overcome in recent designs and the remaining differences are understood and can be compensated for by proper analysis of tests.

There is a need for an integral facility that would simulate the Babcock &

Wilcox type PWR.

We strongly urge that the proposed Semiscale MOD-5 be made available as soon as possible for this simulation.

Without such a facility, it is difficult for NRR to perform its required regulatory func-tions for this family of reactors.

We reiterate our previous recommendation that the NRC seek significant financial contribution fran industry for this effort.

Further, we believe that the Semiscale M00-5 facility should be located at the Idaho National Engineering Laboratory so that the program can profit from the significant experimental and theoretical experience already gained with other versions of Semiscale.

3.3.2 Transient Models and Codes We note with approval the continuing development of the advanced codes, RELAP and TRAC.

Much of the basic development has already taken place although further improvements are expected.

Continued code assessment is required, but the assessment program should be reviewed carefully since funding for it has been seriously reduced. As a general point, we continue to favor strongly the continued development and use of RELAP.

There are some particulars in the advanced code programs which should be mentioned.

The transferability of the codes needs considerable improve-ment.

By transferability, we mean use of the code by others rather than the original developing group.

Apparently, the RELAP instruction manual is more useful than the manual for TRAC, but improvements in both are needed.

It would seem desirable to reduce significantly the number of special codes developed and used by the NRC.

Some of these codes are of marginal value.

3.4 SITING AND HEALTH 3.4.1 Earth Sciences We recommend that the proposed experimental program on Atmospheric Dispersion be deferred in order to provide funding for other higher priority research.

8 3.4.2 Site and Environment There may be a need for increased support of the project on the Socio-economic Ef fects of Accidents.

Aspects of this work pertaining to psychological impacts appear to be particularly important.

3.4.3 Health Effects The work in this Subelement is well coordinated with related research by other Federal agencies.

Particular projects for which we recommend support are:

(a) Gastrointestinal Absorption of Actinides, and (b) Relative Biolog-ical Ef fectiveness of Fission Neutrons at Occupational Exposure Levels.

With respect to this latter project, some benefit might be gained through a detailed examination of the records of the Department of Energy (DOE) relative to neutron exposures of workers in plutonium facilities.

3.5 Risk Analysis 3.5.1 General Although in the letter from Robert B.

Minogue, RES, to Raymond F.

Fraley, ACRS, dated May 27, 1982, the NRC Staff agreed in detail or in principle with almost all of the ACRS recommendations made in NUREG-0864 concerning the Risk Analysis (previously Systems and Reliability Analysis) Decision Unit, for many, if not most, of these recommendations the proposed level / scope of effort is not sufficiently responsive either to the ACRS recommendations or to the needs of the NRC.

3.5.2 Risk Methodology and Regulatory Analysis The proposed effort on methodology for incorporating ri sk contributors such as seismic events, design errors, operator errors of commission, sabotage, and systems interactions into probabilistic risk assessments (PRAs) is inade-quate for the need.

The possible introduction of quantitative safety guidance into the regulatory process adds emphasis to the need for such methodology.

A focused, priority effort should be placed on each of these matters either to provide a method suitable for incorporation into PRAs on a trial basis or to identify and evaluate the sources of uncertainty which make this impractical and to suggest regulatory approaches in the light of these uncertainties.

The proposed programs on LWR Safety Approach in Other Countries, Design Against Sabotage, and Externally-Produced Floods are discussed in Section 2.

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3.5.3 Reactor Risk Analysis The ongoing program on core damage and core melt prevention and mitigation features is inadequate for the needs of the NRC.

It does not include, or includes on too modest a basis, the effects of external events.

It does not adequately treat or evaluate the role of uncertainties.

It lacks suffi-cient conceptual design backup.

This program should be augmented markedly, preferably in FY 1983 rather than waiting until FY 1984.

3.6 Accident Evaluation and Mitigation 3.6.1 General We have recommended repeatedly in our reports to the Commission and to the Congress that the research in the Accident Evaluation and Mitigation Decision Unit be structured to answer questions arising in connection with reactor regulation and licensing.

In our recent reports, specific attention was called to the need for organizing the research under this Decision Unit to answer questions likely to arise in connection with the Commission's stated intention to modify the licensing process to take specific account of accidents more serious than those generally identified as Design Basis Accidents.

However, there is still a lack of definition of even one approach to deal with the severe accident issue.

Considering the difficulty of the problem, effort should probably be made to define several alternatives.

Until these e.' forts have produced some initial results, guidance for research of the type described will not be available.

Although efforts are said to have been made to describe a correlation between the regulatory process and the research program, we find little identification of specific questions associated with rul emaking, or with other means for dealing with severe accidents, that can be answered by the proposed research.

As a result, this Decision Unit, which represents a significant fraction of the proposed research budget, has the appearance of a heavily loaded cannon which may be aimed at the wrong target.

3.6.2 Severe Accident Analysis In this area, there is major emphasis on code development, and on the detailed t

analysis of some of the more obvious accident sequences brought to light by the TMI-2 accident, and by the possibility of PTS. These deserve attention, but there should also be investigations, on a less detailed ba. sis, of other less obvious sequences.

Additional effort should go toward attempts to identi fy initiators and sequences not yet encountered by operating nuclear power plants.

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10 We support the concept of some research effort that tries to consider the impact of various, possible actions by the licensee during the course of an accident involving severe core damage or core melt.

However, we are skep-tical that this effort is likely to evolve into detailed regulatory require-ments in the forseeable future. We cannot support major expenditures in this area based on currently available inforn.ctico and would not use this program to justify an expensive experimental program.

3.6.3 Damaged Fuel Phase I experiments being performed in the Power Burst Facility (PBF) will provide useful information.

Current efforts are aimed at " understanding,"

but the processes being studied are so complicated and the researc.h so expensive, that better definition of the questions to be answered should precede the research.

We have previously questioned the amount of detail that it is possible or desirable to define in an actual accident.

Signifi-cant additional attention should be given to this question in order that the research will be useful.

With this in mind, we do not recommend the work planned in the Atomic Energy of Canada Ltd., Test Reactor (NRU), Annular Core Research Reactor (ACRR), or Phase II experiments in PBF at this time.

3.6.4 Containment Loading In NUREG-0864, we stated that the experiments underway and contemplated are elaborate and expensive, but we have not seen evidence indicating that they reflect adequately the processes that will be critical in defining the rate of damage evolution.

A more coherent analysis should be made to define the most probable evolution of the accident and to identify the critical informa-tion required to assess accident progression.

The code development work associated with these studies is extensive.

However, not enough attention has been given to the question of how much detail is desirable or feasible.

We have no additional information that changes this view.

3.6.5 Fission Product Source Term Work under this Subelement appears to be well managed, and funding for FY 1984 and 1985 seems adequate.

We urge that continuing attention be given to the information needed for licensing and regulatory decisions.

A signifi-cant part of the funds requested are for development of a variety of codes, and experimental work is justified partly as being needed for validation of the codes.

Careful, early planning must ensure that the codes are likely to contribute the information needed for decision-making and do not simply become ends in themselves.

We believe that the peer review process being used will help to prevent this.

The related research on better definition of the source terms for accidents in LWR fuel cycle facilities and in facilities using radioactive materials should be subjected to similar planning and review, and should be better coordinated with the work pertaining to nuclear power plants.

11 3.6.6 Improved Safety Systems We urge that work in this area take advantage of the increasingly sophisti-cated approaches to LWR safety in many foreign countries (see Section 2.2).

3.7 Loss of Coolant Accidents 3.7.1 20/3D Program This program was designed to contribute to the understanding of large-break LOCAs in PWRs.

The large-break LOCA has been a safety question of decreas-ing concern relative to other possible transients.

At present, the major project in this program is the proposed construction of the Upper Plenum

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Test Facility (UPTF) by the FRG.

If the FRG proceeds with the construction of this facility, it will require long-term expenditures by the U.S. NRC to support analyses and instrumentation.

The estimated cost of UPTF has risen to such an extent-that there is even greater concern with the benefit, which is quite small, for a very large expenditure.

As an additional comment on UPTF, it should be noted that no; only is it directed toward the Westing-house type PWR but it also has.as a major objective the study of hot-leg injection which is a feature special to the FRG type PWR.

We reiterate our previous recommendation that the NRC expenditures for this program be reduced to the absolute minimum consistent with the international agreement governing this effort.

3.8 LOFT There are discussions under way at this time regarding the formation of a consortium that would obtain considerably increased financial support from abroad for continuing a test program in LOFT.

We wish to point out again l

that test programs in a nuclear facility are more costly and require much longer test times than in an electrically-heated facility.

There are already test facilities available with electrically-heated rods that have other significant advantages over LOFT.

Our analytic capabilities are now suffi-ciently mature to correct for differences between electrically-heated rods l

and nuclear rods.

It is therefore, in our view, undesirable to give favor-able consideration to an extended program in LOFT.

3.9 Advanced Reactors I

3.9.1 Clinch River Breeder Reactor (CRBR)

The entire Liquid Metal Fast Breeder Reactor (LMFBR) research effort is being directed to support CRBR licensing.

The proposed budget for FY 1984 and 1985 appears adequate for that purpose.

However, we believe that funding should l

be provided also for generic safety research aimed toward plants signifi-cantly larger than CRBR, if Congress continues to support LMFBR development.

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We repeat our recommendation in NUREG-0864 that $1.0 million be earmarked specifically for research to aid the development of a regulatory position for post-CRBR LNF3Rs.

3.9.2 ProbabisisticRiskAssessmentofCRBNs We recommend that the NRC safety researdh prcgram include a PRA of the CRBR.

The background and experience gained by such a study is needed for a proper evaluation of the PRA being performed by the CRBR project as well as to provide long-term guidance for future LMFBR'research.

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3.10 Waste Management 3.10.1 General We believe that the proposed funding for Waste Management Resear'ch for FY 1984 and 1985 should be supplemented by $1.0 million per year to recover part of the funds taken from this effort to support Semiscale M00-5.

Partic-ularly, we would like to see the restoration of the cuts made in the Low'-

Level Waste (LLW) Program relating.to -Engineered Disposal 'and Shallow-Land Burial Alternatives, Characterization of Chemically Toxic Cosponents of' LLW, Nondestructive Tests (NDT) for Waste Packages, and the Source Terms of Radionuclides, as well as those aspects of the 'High-level Waste Program relating to the Fracturing and Geomechanics of Jointed Rock.. ~ With the recommended supplement, we believe the funding would be sceptable for planning purposes; however, a number of actions currently bein'g contemplated by the Congress and DOE may cause even this level to be^inadqquate.

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actions include the accelerated schedules proposed by both DUE and the Congress for the construction and operation of a high-level waste repository.

Should these proposals be confirmed, a. sizable increase may become mandatory.

3.10.2 Comments on Programs in the way of comments on other aspe' cts of the current Waste Management Program, we offer the following:

(a) The Program has definitely matured over the past few years, and the methodology for selecting specific areas for study and assigning priori-ties for actions has improved significantly.

(b) We are encouraged by the steps being taken to Yubject the Program to peer review.

Our only caution 'is thaC those involved in such reviews be given an opportunity to become suf ficiently informed about the 1

Program to enable them to make effective 1 recommendations.

(c) We continue to be concerned about an apparent lack of awareness on the part of the NRC Staff and its contractors _of existing data that may be relevant to some of the basic technical questions being asked in the s

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F 13 areas of rock mechanics, mining engineering, and geochemistry.

A more aggressive effort to seek relevant data, particularly from other govern-ment a'gencies such as the Bureau of Mines, Bureau of Reclamation, and Corps of Engineers, is recommenced. '

(d) Although cooperation with DOE officials at the upper levels appears good, we note a lack of a full interchange of ideas and data at the technical working level.

In some cases, for example, it appears that data provided by DOE to NRC may be incomplete or " sanitized."

Efforts should be made to correct this situation.

4.

BUDGET RECOMMENDATI0dS Our recommendations for changes in the proposed levels of funding are given in Table 1 and explained and discussed below as they relate to the recommen-dations in Sections 2 and 3.

4.1 Fiscal Year 1984 (a) We recommend no change in the total budget.

(b) We recommend an increase of $1.5 million for Decision Unit 2, Facility Operations, to be allocated as follows:

$0.5 million for a program on Seismic Effects in Control Room, as discussed in Section 2.5.

$1.0 million for research we expect to be needed in FY 1984 on Design Against Sabotage, as discussed in Section 2.6.

(c) We recommend elimination of the experimental program on Atmospheric 2

Dispersion in Decision Unit 4, Siting and Health, with a reduction in funding of $0.9 million.

(d) We recommend an increase of $3.0 million for Decision Unit 6, Risk Analysis, for the following purposes:

$1.0 million for increased effort on Risk Methodology and Regula-tory Analysis, as discussed in Section 3.5.2.

$1.0 million for increased effort on Reactor Risk Analysis, as discussed in Section 3.5.3.

$1.0 million for work relating to LWR Safety Approach in Other Countries, as discussed in Section 2.2.

s' 14 In connection with the last item above, we recognize that the effort and funding may not appropriately belong solely within this Decision Unit. - It should cut across existing lines and may be in part a Stand-ard's effort.

(e) We recommend a reduction of $5.6 million in the program on Damaged Fuel in Decision Unit 6.

This reduction is recommended partly to emphasize and be consistent with our dissatisfaction with this program, as expressed in Sections 3.6.1 and 3.6.3, and partly to provide funds for the increases recommended for important research in other areas. We note that this reduction would not be needed if the $10 million allo-cated to the LOFT Consortium could be used instead for other areas.

Your attention is directed to our comments on the LOFT program in Section 3.8.

(f) We recommend an increase of $1.0 million for Decision Unit 9, Advanced Reactors, for research to aid the development of a regulatory position for post-CRBR LMFBRs, as discussed in Section 3.9.1.

(g) We recommend an increase of $1.0 million for Decision Unit 10, Waste Management, chiefly to restore several of the programs that were can-celled or reduced in scope to provide funds for Semiscale MOD-5, as discussed in Section 3.10.1.

4.2 Fiscal Year 1985 For FY 1985, we have proposed increases in funding for some Decision Units, corresponding generally but not in all cases to those recommended for FY 1984. However, we have proposed no offsetting decreases, with the result I

that the total budget is somewhat greater than that proposed. We are not at all comfortable with the proposed rather significant decrease in funding for FY 1985 as compared to FY 1984.

Although some of the existing programs will be completed or greatly reduced in size as research objectives are reached, it seems highly likely that new questions will arise between now and the beginning of FY 1985. Unless these are as dramatic as the TMI-2 accident, it would seem more desirable to budget for contingencies or for "new programs" rather than having to seek a supplemental appropriation.

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4 15 TABLE 1 0FFICE OF NUCLEAR REGULATORY RESEARCH PROGRAM SUPPORT BUDGET FOR FY 1984 AND FY 1985 (DOLLARS IN MILLIONS) 3 FY 1984 FY 1985 ACRS ACRS PROPOSED RECOMMENDATIONS PROPOSED RECOMMENDATIONS 1.

REACTOR AND FACILITY 40.5 40.5 42.8 42.8 ENGINEERING 2.

FACILITY 16.8 18.3 17.1 18.6 OPERATIONS 3.

THERMAL HYDRAULIC 27.5 27.5 22.6 22.6 TRANSIENTS 4.

SITING AND HEALTH 11.0 10.1 11.7 11.7 5.

RISK ANALYSIS 19.3 22.3 22.2 25.2 l

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ACCIDENT EVALUATION 45.4 39.8 38.6 38.6 AND MITIGATION l

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LOSS OF COOLANT 10.5 10.5

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ACCIDENTS 8.

LOFT 17.5 17.5 10.0 10.0 l

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ADVANCED REACTORS

9. 5 10.5 8.5 9.5

10. WASTE MANAGEMENT 11.9 12.9 12.3 13.3 TOTAL 209.9 209.9 195.0 201.5 i

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