ML20150E914

Discusses Budget Aspect of Lewis Comm Rept.Res Estimates an Increase of 3 Persons & $1800K in FY79 & $2300K in FY80

ML20150E914
Person / Time
Issue date:	12/12/1978
From:	Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
RTR-WASH-1400 SECY-78-638, NUDOCS 7812220119
Download: ML20150E914 (19)

Text

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December 12, IM8 NUCLEAR REGU TORY cOMMtsslON

.lNFORMATION REPORT I

i Edqtra. PDR I

FOR:

The Commissioners 4

FROM:

Lee V. Gossick Executive-Director for Operations

SUBJECT:

BUDGET IMPACT OF LEWIS COMMITTEE REPORT DISCUSSION:

In an October 19 memo to the EDO, S. Chilk requested an analysis of the budget impact of program changes resulting from the Levis Committee Report. The staff was requested on October 27 (see Attachment 1) to identify:

1.

Those decision units, planned accomplishments, and' associated resources where WASH-1400 findings were used for such purposes as setting program priorities for performing-reviews or determining levels of effort.

2.

Any program or resource cha'nges in the above areas as a result of the Lewis Committee Report.

3.

Changes in any other decision units because of the Lewis Committee Report findings.

NRR, IE, SD, and NMSS indicated that no decision units were based on WASH-1400 f.indings and that there would be no budget impact as a result of the Lewis Committee Report.

IE indicated that WASH-1400 methodology, but not its findings, is being used in the inspection program. NRR indicated that WASH-1400 insights were being used to review priorities for various generic issues (see Attachments 3 through7).

RES indicates a need for resources over and above its current total FY 1979 office availability to accomodate the Lewis Committee Report recommenda-tions in the Risk Assessment decision unit. RES CONTACT:

Tony Abell, MPA SECY NOTE: This paper is curren' scheduled for a 492-7507 Commission briefing 'o Thursday.

December 14. 1978

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-The Commission;

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q estimates"an increase' of 3 persons and $1800K in FY 1979 and $2300K in FY 1980.- If additional-i FY 1979 resources.are 'not'available,.FY 1980 require-3 ments would increase by 3 persons and $2500K. See.

Attachment ~2 for details.

I have asked the' Director, RES to reexamine.his FY 1979 program priorities to determine whether these additional needs can be absorbed within.his current resource availability. -The RES review 4 11-be incorporated in an.overa11 agency assessment-of~

FY.1979 resource reallocation ' including. reprogram-ming requests. This will be submitted to Congress in compliance with reprograming. requirements of the :

Authorization and Appropriation Committees.' This.

overall review should.be complete by-.mid-January..

1979.

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g lee V. Gossick Executive-Director for'0perations-l

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. Attachments-AsStated-(7)

i DISTRIBUTION Commissioners Comission Staff Offices.

Exec Dir for Operations ACRS Regional Offices Secretariat i

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,f October 27, 1978 MEMORANDUM FOR:

Harold Denton, Director, NRR Saul Levine, Director, RES Robert Minogue, Director, SD Clifford Smith, Jr., Director, NMSS John G. Davis, Acting Director, IE FROM:

Norman M. Haller, Director Office of Management and Program' Analysis

SUBJECT:

FY 1979 AND FY 1980 IMPACT OF LEWIS COMMITTEE REPORT The Comission has requested (Chilk memorandum of October 19, 1978, attached) that an analysis be made of the impact of any changes that might be necessary, as a result of the Lewis Committee Report, on the Corriission's FY 79 and 80 programs.

So the EDO staff (CON and MPA) can consolidate infomation on the impacts for each office, please use the attached table to identify:

1.

Those decision units, planned accomplishments, and associated resources where WASH-1400 findings were used for such purposes as setting program priorities for perfoming reviews or deter-mining levels of effort; 2.

Any program or resource changes in the above areas you now feel are necessary as a result of the Lewis Committee Report; 3.

Changes in any other decision units you feel are necessary because of the Lewis Committee report findings.

n crder to have a significant influence on our plans for FY 1979 and

n the OM3 review of our FY 1980 budget, this review must be completed Ex;editiously. The Comission suspense on $s action is November 15;

-herefore, your reply by November 6 would 'e

- 1reci ated. Please pro-tide your response to MPA (iony Acell) wit

.opy to CON (Bruce Cooper).

Have your 9taff call Tony (x27507) if there re any questions.

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g forman M. Haller, Director tr

'fice of Management and Program Analysis

,ra Attachmeks:

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Chilk-to Gossick me d dtd 10/19/78 2.

Resource and Impac Tacles

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• J. Dircks DEDO H. Shapar,, ELD D. Donoghue, ADM S. Hanauer, EDO L. Barry, CON B. Cooper, CON T. Abell, MPA l

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October 19, 1978 y

Minogue Smith CFFICE OF THE Shapar STCRETARY J.

Shea MEMORANDUM FOR:

Lee V. Gossick, IDO Tucker Kenneth Pedersen, Director, OPE HaWen James L.

Kelley, Acting G ral Counsel Hanauer Carlton Kamnerer, Direct OCA P

FROM:

Samuel J.

Chilk, Secreta

,D STAFF REQUIREMENTS - DIE UpION OF RISK SU3 JECT:

ASSESSMENT REVIEW GROUP

1. ORT, 10: 4 0 A.M., FRIDAY, OCTOBER 13, 1978, COMMISSIONERS ' CONFERENCE ROOM, D.

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OFFICE (OPEN TO PUBLIC ATTENDANCE)

The Commission requested that:

a draf t NRC public statement be prepared which a.

would acdress the Cc= mission's current policy regarding the applicability and significance of -

WASE-1400 risk estinates, would indicate Cc= mission acceptance of the Lewis Report, would indicate that the Cc= mission is currently reviewing the use of risk assessment techniques within NRC to identify any necessary corrections, would address controversial issues associated with pric: Commission statements regarding WASH-1400 and its Executive St.. mary, and would describe initiatives to be the Cc= mission and the NRC staff; MP4 takep(IL, OPE /OGC) v (SECY Suspense: Oct. 31, 1978) b.

a propcsed response to Congressman Udall and other Ccngressional offices, as appropriate, be prepared regarding the Commission's position regarding the Lewi.s Repert, including a descriptien of initiatives to be taken by NRC as a result of the report's concluc % s:

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- (EOO OGC/ OPE) (SECY Suspense: Cet. 31, 1978) a review be conducted of responses to Congressional c.

correspondence to identify a.y NRC comments that may require revision in light of the Lewis Report; (C?E/OCA) (SECY Suspense: Oct. 31, 1978) g-. = = =.

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Nov. 15, 1978)

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e, the staff should review the extent to which licensing j

and other regulatory actions or staff positions have relied on the risk assessment models and results

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o f WASE-14 0 0. - The staff should review those actions and positions and state their views as to whether there should be continued reliance and the effect of discontinuing that reliance; TwQAe

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an analysis be made of the i= pact of any program

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changes that might be.necessary as a result of the Lewis Report on the Commission's FY 79 and 80 bmissions; and

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an appropriate letter transmitting the Lewis 1

Report to all prior recipients of WASH-1400 be prepared for the Secretary 's si~gnature.

The proposed letter will be circulated for Commission concur-ance' prior to issuance.

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(ED SECY) (SECY Suspense: Oct. 31, 1978) l cc:

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Chairman Eendrie Cczmissioner.Gilinsky Cc=missioner Kennedy Cc =issioner 3radford Cc=missioner Ahearne Cirector, OPA e.

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MEMORANDUM FOR: ' Norman M.:Haller, Director

- Office of Management and Program Analysis FROM:'

Sau1~Levine, Director Office of. Nuclear Regulatory Research

SUBJECT:

IMPLEMENTATION COSTS OF THE LEWIS COMMITTEE:

FINDINGS AND RECOMMENDATIONS:

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The Probabiliktic Analysis Staff (PAS) appeared before meetings of the

. Risk Assessment' Review Group during the past year and identified many of the deficiencies in the Reactor' Safety Study which. along with others,:

were noted in the Review Group report. Work has already been initiated

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to effect improvements in these deficiencies; Thus, PAS is alreaoy implementing many of the recomendations made'in the: report and has planni,ng in progress to respond to other concerns raised by the Review-Group' even though resources for many of these efforts were not included in the FY 79~ and FY 80 budgets.

PAS'ha.s reviewed in detail lthe findings and recomendations of the Lewis Comittee to determine further program efforts required, and~ the resource '

1 impact' of implementing their repopted suggestions. PAS estimates that -

$1.8M is required' in' FY 79 and $2.3M in FY 80 to accomplish the work-t suggested in the Lewis Committee report.- If no funding 11s made available in FY 79, then it is estimated that $2.5M will be necessary to accomplish the efforts-in FY 80 and $2.0 in FY 81. In addition, a. staff increase ~of three will be required to assume thi's additional, workload.

The efforts to be. undertaken are.as follows:

1.

Improve the' data base--this will provide for an acceleration of.

the' development and analysis of the data bases in common cause areas such as fires, floods, and human errors.. In addition, it provides for the LER, NPRDS, and plant log reviews to permit the timely development of a more complete data base of nuclear power plant components.. Included in this effort will be model development and statistical calculations required to determine the failure distributions and data uncertainties.

2.

Human errors - this will provide for the analysis of human errors which could act as accident initiators.

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3. -. Consequence'modeling - to provide for an improved consequence model which has incorporated more realistic dispersion characteristics and

- biological effects models. Efforts in this area will include refinements to the "CRAC" code for improved use on site specific applications.

' 4.

Risk assessment use - will accelerate the training activities _necessary to provide a capability in other NRC offices for performing. analysis '

using the risk assessment techniques. This activity also includes

the formulation of additional traini,ng courses required.to adequately ~

implement the Lewis Committee reconnendations.

5.

Inspection' evaluation - will provide for analysis of the' inspection efforts. A determination will be made as to the extent which.

further application of the RSS findi.ngs will enhance the. inspection effort-for assuring public safety.

6.

Value impact studies - will extend the application.of the risk assessment methodology and the RSS findings-to include the con-firmatory research program. These efforts will provide a framework within which the need.for and effectiveness of confirmatory research programs can be evaluated in. terms of their potential for assuring operating safety.

7.

Generic systems informa' tion - will provide an organized collection of LWR systems information on' operating safety systems. This will permit the use of. fault-tree / event-tree analyses to resolve generic 1 issues, determine their' applicability to existing and planned plants, and to support the licensing staff with systematic evaluations of-operating and planned reactors.

n n/ gh aul Levine, Director Office of Nuclear Regulatory Research h

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' UNITED STATES NUCLEAR REGULATORY COMMIS$10N '

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MEMORANDUM FOR: M M. Haller, Director, Office of :

Management and Program Analysis.

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FROM:

John G.. Davis, Acting Director, Office of Inspection and Enforcement

SUBJECT:

FY 1979 AND FY 1980 IMPACT OF LEWIS l'

COMMITTEE REPORT I

The Office of Inspection and Enforcement has analyzed the potential impact of the Lewis Committee Report on the FY 79 and 80 IE pro-grams and has. determined that it will have no impact.

l Whereas IE has not used the risk assessment models and numerical j

results of WASH-1400, it should be noted that IE has used and continues to' use the insights gained from the WASH 1400 Report in -

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its ongoing efforts to improve the inspection' program. Enclosed i

is a brief description of the areas where we are using the insights

'l gained from WASH-1400.

l o n G. Davis i

Acting Director l

Office of Inspection

.I and Enforcement

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Enclosure:

-IE use of WASH-1400 cc:

H. D. Thornburg, IE L. B. Higginbotham IE E. M. Howard, IE G. C. Gower, IE L. I. Cobb, IE A. F. Abell, MPA B. A. Cooper, CON CONTACT:

J. H. Snie:ek,-IE 49-28019 ATTACHMENT 4

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Study of Independent Verification Option I

i-Decision Unit Title Reactor Operations Inspection 300,000 O

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WASH 1400 methodology and does not i

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l Planned Issue Report.

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Conduct ~ study of inspection resource allocation to risk rated activities - (based on WASH 1400 methodology and general system groupings as related to risk) - No impu,,t since study results will not depend on absolute accuracy of WASH 1400 numbers.

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Identify Risk Related Facility Procedures with emphasis on Human Factors-(based on broad groupings'of risk.

related systems and activities as determined by applying WASH 1400 methodology) - No impact since the findings do not depend on absolute accuracy of WASH 1400 numbers.

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wasniwarow, n.c.nossa NOV 7 :.1978 MEMORANDUM FOR:

Norman M. Haller, Director Office of Management and Program Analysis -

- FROM:

Robert B.~ Minogue, Director.

Office of Standards Development

SUBJECT:

FY 1979 AND FY-1980 IMPACT OF LEWIS COMMITTEE REPORT-In' order that you could make an analysis of any program changes that' might be necessary as a result of the Lewis e,mnittee Report, your October 27, 1978 memorandum.to me requested ' that we identify:

1.

Those decision units, planned accomplishments, and. associated' resources where WASH-1400 findings were used for such purposes t

as setting program priorities for performing reviews or deter-i mining levels of. effort; 2.

Any program or resource changes in the above areas you now feel are necessary as a result'~of the Lewis Consnittee Report; 3.

Changes in any other decision units you ' feel are necessary because of the Lewis Conmittee report findings.

The Office of Standards Development will have ncL change in program levels for FY.1979 or FY 1980 as a. result of the Lewis Consnittee Report and no change in the budget for any decision units is necessary.

f cf Robert B. Minogue, Director cc: Tony Abell, MPA Bruce Cooper, CON 53 !! "*/

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MEMOPANDUM FOR:

Nonnan M. Haller, Director Office of Management and Program Analysis FROM:

Clifford V. Smith, Jr., Director Office of Nuclear Material Safety and Safeguards 1

SUBJECT:

FY 1979 JL 1980 PROGRAMS - IMPACT OF LEWIS COMMITTEE REPORT Confirming telephone advice to Tony Abell of your staff, the Divisions of Fuel Cycle and Material Safety and Waste Management have reviewed their.

FY 19H and 1980 budget planned accomplishments and required resources wi-h regard to WASH-1400 and the Lewis Commtttee Report findings. ' No planned accomplishments for any decision unit have been identified as based upon WASH-1400 or would be affected by the findings of the Lewis Committee Report.

Original Signed by CLITI;P.D V. Si!ITH. JR.

Clifford V. Smith, Jr., Director Office of Nuclear Material

. Safety and Safeguards cc:

A. F. Abell, MPA B. A. Cooper, CON 1

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NOV 141978 l

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MFt10RANDUM FOR:

A. F. Abell, Chief Internal Information Systems Branch Division of information Analysis and Plannin,g Office of Management and Program Analysis FROM:

D. F. Bunch, Director Program Support Staff Office of Nuclear Reactor Regulation

SUBJECT:

FY'1979.AND FY 1980 IMPACT OF LEWIS COMMITTEE REPORT The memo from Denton to Gossick of October 6,1978 provides our initial reaction to the Lewis Committee Report.

It i s not possible, at this point, to go much beyond the conrnents in that memo. Thus, we are not l

able to be definitive in responding to the memo from Norman Haller of October 27,'1978.

l We did not develop the FY 1979 and FY 1980 budgets based on WASH-1400,

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and there are no specific program assumptions in any of NRR's decision I

units which are related to WASH-1400.

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We are in the process of reviewing the priorities for various generic l

Issues using among other things, the insights-/ rom the Reactor Safety 3

Study. However, this effort is intended to help assure optimal allo-cation of resources rather than create a new initiative.

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D. F. Bunch, Di rector Program Support Staff E

Office of Nuclear Reactor Re@ation

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4 MEMORANDUM FOR:

Lee V. Gossick Executive Director for Operations FROM:

Harold R. Denton, Director Office of Nuclear Reactor Regulation

SUBJECT:

LEVIS COMMITTEE REPORT.ON REACTOR SAFETY STUDY Your memorandum of September 19,.1978 requested our initial reaction to the Lewis Comittee Report. We have reviewed that report, and our responses to the five questinns posed in your memorandum are enclosed.

As you know, NRR staff have commented on the RSS on several pre-vlous occasions.

In many instances the Lewis Committee Report contains comments similar to those raised by NRR. Generally, the Lewis Committee Report seems to express the same views set

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forth in your memorandum to Comissioner Kennedy of March 2,1977, a view which we endorse.

While we are,in agreement with much of what is contained in the report, there are a number of recommendations and conclusions which need to be carefully considered before any decision is made to accept or reject them.

Some of these involve several offices '(l&E, RES,NRR). Accordingly, I recommend that you establish a small task force with representatives from each Office to develop a coordinated position on the principal recommendations of the Committee.

/

Harold R. Denton, Di rector Office of Nuclear Reactor Regulation

Enclosure:

As stated cc:

S. Levine, RES H. Shapar, ELD A. Buhl, RES J. Davis, ICE R. Minogue, SD.

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1. ' Areas of Potential Disaoreement' Between Staff Views and the Lewis l

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.i (a) It.is; recommended that the consequence modeT used in WASH-1400 should be substantially improved and its sensitivities explored,'

before it..is used in the regulatory process.

NRR staff a'grees-i

. that the model has'significant limitations.

However, as dis-cussed in SECY-78-137, we believe that it can be used.to pro-vide useful insights in the reviews of. unusual sites.

RES has.

programs underway to improve the model'and we support that ef.

fort.

(b) The Committee noted that the RSS estimate of core melt proba-bility was substantially greater than the often-cited one-in-a-million goal for an accident whose consequences would exceed -

Part 100 guidelines. The Committee then suggested a need to consider revising 10 CFR Part 100. We agree that a review of our siting policy and practice is in order (and efforts-in this area are underway).

However, the connection the report draws between a ' generalized aiming point of one-in-a-million and.

1 Part 100 is incorrect. We do not agree that the RSS results indicate a failure of Part 100 to accomplish its intended goals.

i 2.

Potential Effect on Procrams in Your Office if the Lewis Reoort Recom-mencations are Acceptec (a) A key view expressed in the Lewis Report is that the RSS results

. are not adequately reflected in the priorities of either the

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stated " quantitative safety:... analysis can also serve to improve safety itself by enabling the NRC and the industry to more properly match resources to the we'ak points uncovered."

i NRR agrees with th'is view and is moving in this direction.

l Ongoing efforts in cooperation with the RES and PAS staff.

include, for example, reevaluating the priorities for generic issues. An intensification of these e.fforts may be' warranted, in light of the Committee recommendation.

(b) On page 16 a number of recommendations are made regarding acquisition and review of data. However, the statements that improved data "must be entered into the (regulatory) process in a formal and continuing manner" and that " reanalysis based on the improved data (of technical issues) should' be done as the occasion arises" go beyond a. suggestion for merely acquiring data.

Implenientation of these recommendations will require fur-ther consideration and will need to be coordinated with our NPRDS efforts.

(c) Page 25 states:

"This raises a very serious question of the extent to which we can be confident that the actual construc-tion and materials conform to design specifications." Although the Browns Ferry incident has already caused significant changes' in licensing practices, this statement seems to be an implied reconTnendation for additional action of some sort.

3.

Major poliev Issues Foreseen Needino Resolution as a Consecuence of tne Lewis Recort (a)

Since the Lewis Committee has endorsed the general RSS methodology,

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RSS, as recommended by the Committee.

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It is recommended that fault-tree / event-tree analyses should be among:the prine'ipal means used to deal'with generic safety

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issa?.s to formulate new regulatory' requirements, etc. While.

l the staff does utilize fault-tree and event-tree analyses to aid in reviews of various issues, a decision. to use such methods in most or all applications would be a significant j

departure from current practice and should be explored further.

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4 Areas Where Past' or pendino Commission or Staff Actions and Positions Relied on the RSS Wnien May Have to ce Reconsicereo t

l (a) On page x it is stated that the RSS has been misused as a vehicle to judge the acceptability of. risks. _There have been a' number of staff documents. (including the recent ATWS and LPGS reports) which have spoken to, and to some extent relied on, the RSS re-

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Elsewhere in the report, the Committee appears to.'

endorse the staff's reliance on RSS methods for ATWS.

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(b)- The Comission has deferr'ed action on SECY-78-137 pending' com-

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' plation of the Lewis Comittee review.

In light of.the Lewis-lL Comittee conclusions about the RSS consequence model, it may be

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L necessary to update that paper.

a 5.

Portions of the Lebs Report that you Intend to Concentrate our Technical Review i

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(a)~ We ' agree with the conclusion that the proper application of the l

I methodology can assist in licensing decisions and improve re-sourceutklization. We are devoting a considerable _ effort in l

this area and will consider if additional measures would be useful at this time.

(b) On page ix it is stated that the Committee is unconvinced of the correctness of the RSS conclusion that-important classes 1.-

of initiating events including fires, earthquakes-and human initiat. ion contribute negligibly to the overall' risk. We heve given increased attention to comon cause failures, and the need for further efforts will be studied.

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