ML20151H487
| ML20151H487 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Palo Verde, Perry, Indian Point, Fermi, Saint Lucie, Byron, Seabrook, Diablo Canyon, Callaway, Waterford, San Onofre, Comanche Peak, Rancho Seco, Midland, 05000000, Zimmer, Shoreham, Atlantic Nuclear Power Plant, Crane |
| Issue date: | 05/04/1983 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM) |
| Shared Package | |
| ML20151H308 | List: |
| References | |
| REF-GTECI-A-17, REF-GTECI-SY, TASK-A-17, TASK-AS, TASK-BN83-057, TASK-BN83-57, TASK-OR BN-83-057, BN-83-57, NUDOCS 8305040323 | |
| Download: ML20151H487 (22) | |
Text
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t EY 4 1983 Docket Nos. 50-528, 529, 530, 361, DO C
362, 437, 275, 323, 483, 50 28, 529, 61 389 and 370 50-362, 437, 275, 323, 50-483, 389, 370, 50-445/446, 50-454/455, 50-341, 50-247/236, 50-329/330, 50-440/441, MEMORANDUM F.0R: Chaiman Palladino 50-312, 50-443/444, 50-322 Commissioner Gilinsky 50-289, 50-382, 50-358 Commissioner Ahearne Commissioner Roberts Commissioner Asselstine FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
DIFFERING PROFESSIONAL OPINION REGARDING SYSTEMS INTERACTION AND SAFETY CLASSIFICATION (BN 83-57)
In accordance with present NRC procedures regarding Board Notifications, the enclosed is provided for your infomation. This infarmation is applicable to all nuclear power plants.
This information relates to Board Notification 83-17 and 83-44, which were issued on February 18, 1983 and April 4, 1983, respectively. These dealt with the staff position regarding unresolved safety issue A-17.
The enclosed differing professional opinion deals with certain aspects of existing policy and practice in the areas of systems interaction and safety cla.ssification.
The staff will keep you informed regarding the resolution of this differing professional opinion.
pggw'_ tr S /
d pen 2, Elb Darrell G. Eisenhut, Director Division of Licensing-Office of Nuclear Reactor Regulation
Enclosure:
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cc: The Atomic Safety and Licensing Boards for:
Byron (Miller,Callihan, Cole)
Callaway (Gleason, Bright, Kline)-
Comanche Peak 1 & 2 (Bloch, Jordan, McCollom)
Midland 1 & 2 (Bechhoefer, Cowan, Harbour)
Palo Verde 2 & 3 (Lazo, Callihan, Cole)
Perry 1 & 2 (Bloch, Bright, Kline)
San Onofre 2 & 3 (Kelley, 9and, Johnson)
Seabrook 1 & 2 (Hoyt, Haruour, Luebke) i Shoreham (Brenner, Carpenter, Morris)
Waterford 3 (Wolf Foreman, Jordan)
Zimer (Frye, Hooper, Livingston) indianPoint(Gleason, Paris,Shon)
The Atomic Safety and Licensing Appeal Boards for:
Callaway 1 & 2 (Rosenthal, Edles, Gotchy)
Diablo Canyon 1 & 2 (Moore, Johnson, Buck)
~ Fermi 2 (E11perin, Gotchy, Moore)
San Onofre 2 & 3 (Eilperin, Gotchy, Johnson)
Waterford 3 (Eilperin, Johnson, Kohl)
Zimer (Rosenthal, Eilperin Wilber)
TMI-1 (Edles, Buck, Gotchy, Kohl)
Rancho Seco (Rosenthal, Buck, Kohl) i 1
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anc ronu ais oomusicu oua OFFICIAL RECORD COPY usce mi-su,*
DISTRIBUTION LIST FOR BOARD NOTIFICATION Byron Units 1&2, Docket Nos. 50-454/455 Mr. Jay Dunkleberger Callaway Unit 1, Docket No. STN 50-483 Gary J. Edles, Esq.
Comanche Peak Units 1&2, Docket Nos. 50-445/446 Stephen F. Eilperin, Esq.
Diablo Canyon Units 1&2, Docket Nos. 50-275/323 Eric A. Eisen, Esq.
Fermi Unit 2, Docket No. 50-341 Mr. Frederick Eissler Indian Point Units 2&3, Docket Nos. 50-247/286 Mrs. Juanita Ellis Midland Units 1&2, Docket Nos. 50-329/330 Christopher Ellison, Esq.
Palo Verde Units 2&3, Docket Nos. 50-529/530 Donald T. Ezzone, Esq.
Perry Units 1&2, Docket Nos. 50,440/441 Mr. Jonathan D. Feinberg Rancho Seco, Docket No. 50-312 Mr. Steve Ferris San Onofre Units 2&3, Docket Nos. 50-361/362 Lawrence R. Fisse, Esq.
Seabrook Units 1&2, Docket Nos. 50-443/444 David S. Fleischaker, Esq.
Shoreham Unit 1, Docket No. 50-322 Mr. Zipporah S. Fleisher TMI Unit 1, Docket No. 50-289 Mrs. Raye Fleming Waterford Unit 3, Docket No. 50-382 Luke B. Fontana, Esq.
Zimmer Unit 1, Docket No. 50-358 Dr. Harry Foreman Mr. John H. Frye, III Steve J. Galder, P.E.
Ms. Marjorie Aamodt Dr. John H. Buck Phyllis M. Gallagher, Esq.
Mr. Robert W. Adler Dr. Dixon Callihan Joseph Gallo, Esq.
Mr. Vernon Adler Mr. Calvin A. Canney Mr. R. J. Gary Phillip Ahrens, Esq.
John G. Cardinal, Esq.
Ms. Sandra Gavutis ANGRY /TMI PIRC Dr. James L. Carpenter Arthur C. Gehr, Esq.
Ms. Elizabeth Apfelberg A. S. Carstens Mr. Thomas M. Gerusky Mr. Robert A. Backus Mr. Allen R. Carter David H. Gilmartin, Esq.
Edward M. Barrett, Esq.
Doug Cassel, Esq.
Mr. Stewart M. Glass Thomas A. Baxter, Exq.
Mr. Brian Cassidy James P. Gleason, Esq.
Charles Bechhoefer, Esq.
A. Scott Cauger, Esq.
Melvin Goldberg, Esq.
Mayer George G. Begany Kenneth M. Chackes, Esq.
Mr. Marc W. Goldsmith Kenneth Berlin, Esq.
Gerald Charnoff, Esq.
Dr. Reginald L. Gotchy Lynne Bernabei, Esq.
Ms. Diane Chevez Mr. Mark Gottlieb Ms. Frieda Berryhill
'Myron M. Cherry, P.C.
Greater NY Council on Energy Ezra I. Bialik, Esq.
Hon. Peter Cohalan c/o Mr. Dean R. Corren Mr. Samuel J. Birk Hon. Mark Cohen Mr. Rand L. Greenfield Lee L. Bishop, Esq.
Paul F. Colarulli, Esq.
Mr. Gary L. Groesch E. Blake, Esq.
David E. Cole, Esq.
William J. Guste, Jr., Esq.
Mr. Richard E. Blankenburg Dr. Richard F. Cole Dr. Cadet H. Hand, Jr.
Howard L. Blau, csq.
Mr. John T. Collins Dr. Jerry Harbour Peter B. Bloch, Esq.
Troy B. Conner, Esq.
Mr. Thomas H. Harris Jeffrey M. Blum, Esq.
Mr. Nicholas J. Costello Mr. Rcbert J. Harrison Mr. Dan I. Bolef Mr. Gary D. Cotton Richard M. Hartzman, Esq.
Mr. Donald Bollinger Dr. Frederick P. Cowan Mr. Wayne Hearn Ms. Louise Bradford Philip A. Crane, Jr., Esq.
W. Peter Heile, Esq.
Brent L. Brandenburg, Esq.
T. J. Creswell Donald L. Herzberger, MD.
Mr. Paul E. Braunlich Edward L. Cross, Jr., Esq.
Letty Hett Ms. Nora Bredes Jordan D. Cunningham, Esq.
Ms. Susan Hiatt Lawrence Brenner, Esq.
Mr. Donald Davidoff Mrs. Lyn Harris Hicks Mr. Glenn 0. Bright Mr. Alfred B. Del Bello Mr. Timothy S. Hogan, Jr.
Hon. Richard L. Brodsky Andrew B. Dennison, Esq.
Ms. Beverly Hollingworth Daniel F. Brown, Esq.
Thomas G. Dignan, Jr., Esq.
Ms. Joan Holt Mr. Earl Brown James B. Dougherty, Esq.
Dr. Frank F. Hooper Herbert H. Brown, Esq.
Ms. Jane Doughty Ms. Lee Hourihan James E. Brunner, Esq.
Mr. David B. Duboff Helen Hoyt, Esq.
Mr. Richard B. Hubbard 1
i.
Byron Units 1&2, Docket Nos. 50-454/455-James S. Reed, Esq.
Callaway Unit 1, Docket No. STN 50-483 Mr. John G. Reed Comanche' Peak Units I&2, Docket Nos. 50-445/446 Region III, USNRC Diablo Canyon Units 1&2, Docket Nos. 50-275/323 Ms. Marjorie Reilly Fermi Unit 2, Docket No. 50-341-Indian Point Units 2&3, Docket Nos..
W. Taylor Reveley III, Esq.
50-247/286 Joel R. Reynolds,' Esq.
Midland Units 1&2, Docket Nos. 50-329/330 Nicholas S. Reynolds, Esq.
Palo Verde Units 2&3, Docket Nos. 50-529/530 Ken Robinson, Esq.
Perry Units 1&2, Docket Nos. 50-440/441 Ms. Phyllis Rodriguez Rancho Seco, Docket No. 50-312 Andrew S. Roffe, Esq.
San Onofre Units 2&3, Docket Nos. 50-361/362 Alan S. Rosenthal, Esq.
Seabrook Units 1&2, Docket Nos. 50-443/444 Mr. Charles A.' Scheiner Shoreham Unit 1, Docket No. 50-322 Dr. David Schink TMI Unit 1 Docket No. 50-289 Mr. James 0. Schuyler Waterford Unit 3, Docket No. 50-382 Renee Schwartz, Esq.
Zimmer Unit 1, Docket No. 50-358 Cherif Sedky, Esq.
Ralph Shapiro, Esq.
Mr. Steven C. Sholly Mr. Henry D. Hukill Mr. Wendell H. Marshall Mr. Frederick J. Shon 11rs. Elizabeth B. Johnson David Martin, Esq.
Jo Ann Shotwell, Esq.
-Mrs. Phillip B. Johnson Michael W. Maupin, Esq.
Ms. Barbara Shull Dr. W. Reed Johnson' Michael McBridge, Esq.
Jay Silberg, Esq.
Dr. Walter H. Jordan Mr. Brian McCaffrey Mr. Gordon Silver William S. Jordan, III, Esq. Charles E. McClung, Jr.,Esq. Ms. Mary Sinclair Craig Kaplan, Esq.
Dr. Kenneth A. McCollom Lanny Alan Sinkin David S. Kaplan, Esq.
Mr. Patrick J. McKeon Ivan W. Smith, Esq.
t Mr. James R. Kates-Mr. Edward F. Meany Mr. Jeff Smith Frank J. Kelley, Esq.
Hon. Ruth Messinger Mr. C. W. Smyth James L. Kelley, Esq.
Ms. Joan Miles Ms. Barbara Stamiris Matthew J. Kelley, Esq.
Gary L. Milhollin, Esq.
Mayor Howard Steffen Mr. Chauncey Kepford Michael I. Miller, Esq.
Malcolm Stevenson, Esq.
Janice E. Kerr, Esq.
Ruthane G. Miller, Esq.
Michael J. Strumwasser, Esq.
Ms. Judith Kessler Professor William.H. Miller Mr. John B. Tanzer Stanley B. Klimberg, Esq.
John Minock, Esq.
Mr. Robert G. Taylor Dr. ' Jerry R. Kline Lucinda Minton, Esq.
David C. Thomas, Esq.
Charles R. Kocher, Esq.
Thomas S. Moore, Esq.
George F. Trowbridge, Esq.
Christine N. Kohl, Esq.
William J. Moran, Esq.
Dr. Mauray Tye Stephen B. Latham, Esq.
Dr. Peter A. Morris Paul C. Valentine, Esq.
Alan Latman, Esq.
Ms. Pat Morrison Ms. Anne Verge Robert M. Lazo, Esq.
Paul M. Murphy, Esq.
Harry Voigt, Esq.
Ms. Jane Lee Bruce Norton, Esq.
Mr. Robert F. Warnick i-John Levin, Esq.
Mr. Andrew P. O'Rourke Alan R. Watts, Esq.
David R. Lewis, Esq.-
Dr. Oscar H. Paris Deborah Webb, Esq.
Mr. Marvin I. Lewis Marc L. Parris, Esq.
Ellyn R. Weiss, Esq.
Ian Douglas Lindsey, Esq.
Mr. Spence Perry Richard J. Wharton, Esq.
-Dr. Linda W. Little Ms. Roberta C. Pevear Howard A. Wilber, Esq.
Dr. M. Stanley Livingston David R. Pigott, Esq.
Frederick C. Williams, Esq.
1 Terry Lodge, Esq.
David H. Pikus, Esq.
Harry M. Willis, Esq.
Mr. Harold Lottman fu. Samuel H. Porter Daniel D. Wilt, Esq.
Dr. Emmeth A. Luebke Ivnanda Potterfield, Esq.
John F. Wolf, Esq.
Mr. Fred Luekey Charles M. Pratt, Esq.
Sheldon J. Wolfe, Esq.
MHB Technical Associates David J. Preister, Esq.
John D. Woliver, Esq.
Charles J. Maikish, Esq.
Sen. Robert L. Preston Mr. Robert G. Wright Peter A. Marquardt, Esq.
Dr. Lawrence R. Quarles Dr. Bruce von Zellen Mr. John Marrs fir. Paul Rau 2
Byron Units 1&2, Docket Nos. 50-454/455 Callaway Unit 1, Docket No. STN 50-483 Comanche Peak Units 1&2, Docket Nos. 50-445/446 Diablo Canyon Units 1&2, Docket Nos. 50-275/323 Fermi Unit 2, Docket No. 50-341 Indian Point Units 2&3, Docket Nos. 50-247/286 Midland Units 1&2, Docket Nos. 50-329/330 Palo Verde Units 2&3, Docket Nos. 50-529/530 Perry Units 182, Docket Nos. 50-440/441 Rancho Seco, Docket No. 50-312 San Onofre Units 2&3, Docket Nos. 50-361/362 Seabrook Units 1&2, Docket Nos. 50-443/444 Shoreham Unit 1, Docket No. 50-322 TMI Unit 1, Docket No. 50-289 Waterford Unit 3, Docket No. 50-382 Zimmer Unit 1, Docket No. 50-358 Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Panel Docketing and Service Section Document Management Branch ACRS Members Dr. Robert C. Axtmann Mr. Myer Bender Dr. Max W. Carbon Mr. Jesse C. Ebersole Mr. Harold Etherington Dr. William Kerr Dr. Harold W. Lewis Dr. J. Carson Mark Mr. William M. Mathis Dr. Dade W. Moeller Dr. David Okrent Dr. Milton S. Plesset Mr. Jeremiah J. Ray Dr. Paul C. Shewmon Dr. Chester P. Siess Mr. David A. Ward
(
3
BYRON
',, Mr. Dennis L. Farrar Director of Nuclear Licensing Cem=:nwealth Edison Company Post Office Box 767 Chicago, Illinois 60690 cc:
Mr. William Kortier Ms. Diane Chavez Atomic Power Distribution 326 N. Avon Street Westinghouse Electric Corporation Rockford, Illinois 61103 Post Office Box 355 Pittsburgh, Pennsylvania 15230 Mr. James G. Keppler U. S. Nuclear Regulatory Commission Paul M. Murphy, Esq.
Region III Isham, Lincoln & Beale 799 Roosevelt Road One First National Plaza Glen Ellyn, Illinois 60137 42nd Floor Chicago, Illinois 60603 Joseph Gallo, Esq.
Isham, Lincoln & Beale Mrs. Phillip B. Johnson Suite 840 1907 Stratford Lane 1120 Connecticut Avenue, N. W.
Rockford, Illinois 61107 Washington, D. C.
20036 Ms. Bridget Little Rorem Appleseed Coordinator 117 North Linden Street Essex,. Illinois 60935
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Dr. Bruce von Zellen Department of Biological Sciences Northern Illinois University DeKalb, Illinois 61107 Mr. Edward R. Crass Nuclear Safeguards & Licensing Division Sargent & Lundy Engineers i
55 East Monroe Street l
Chicago, Illinois 60603 Myron Cherry, Esq.
l Cherry & Flynn l
Suite 3700 Three First National Plaza Chicago, Illinois 60602 Mr. William Forney U. S. Nuclear Regulatory Commission Byron / Resident Inspectors Office j
4448 German Church Road Byron, Illinois 61010 l
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CALLAWAY 50/483 "r. D. F. Schnell Vice President - Nuclear Unibn Electric Company Post Office Box 149 St. Louis, Missouri 1 63166 cc:
Mr. Nicholas A. Petrick Mayor Howard Steffen Executive Director - SNUPPS Chamois, Missouri 65024 5 Choke Cherry Road Rockville, Maryland 20850 Mr. Fred Luekey Presiding Judge, Montgomery County Gerald Charnoff, Esq.
Rural Route Thomas A. Baxter, Esq.
Rhineland, Missouri 65069 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.
Professor William H. Miller Washington, D. C.
20036 Missou-ri Kansas Section, American Nuclear Society Mr. J. E. Birk Department of Nuclear Engineering Assistant to the General Counsel 1026 Engineering Building Union Electric Company.
University of Missouri Post Office Box 149 Columbia, Missouri 65211 St. Louis, Missouri 63166 Mr. Robert G. Wright Mr. John Neisler Assoc. Judge, Eastern District U. S. Nuclear Regulatory Commission County Court, Callaway County, Resident Inspectors Office Missouri RRf1 Route il Steedman, Missouri 65077 Fulton, Missouri 65251 Mr. Donald W. Capone, Manager Kenneth M. Chackes Nuclear Engineering Chackes and Hoare -
Union Electric Company Attorney for Joint Intervenor's Post Office Box 149 314 N. Broadway
Mr. Earl Brown Assistant General Counsel for the School Dist.rict Superintendent l
' Missouri Public Service Comm.
Post Office Box 9 Post Office Box 360 Kingdom City, Missouri 65262 Jefferson City, Missouri 65101 l
Mr. Samuel J. Birk l
Ms.-Barbara Shull R. R. #1, Box 243 Ms. Lenore Loeb Morrison, Missouri 65061 League of Women Voters of Missouri l
2138 Woodson Road Mr. Harold Lottman St. Louis, Missouri 63114 Presiding Judge, Dasconade County
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Route 1 l
Ms. Marjorie Reilly Owensville, Missouri 65066 Energy Chairman of the League of Women Voters of University City, MO Eric A. Eisen, Esq.
7065 Pershing Avenue Birch, Horton, Bittner and Moore University City, Missouri 63130 Suite 1100 1140 Connecticut Avenue, N. W.
Washington, D. C.
20036 n
CALLAWAY 50-483 Mr. D. F. Schnell.
cc (cont'd):
Mr. John G. Reed Route'#1 Kingdom City, Missouri 65262 Mr. Dan I. Bolef, President Kay Drey, Representative Board of Directors Coalition for the. Environment St. Louis Region 6267 Delmar Boulevard University City, Missouri 63130 Mr. Donald Bollinger, Member Missourians for Safe E6ergy 6267 Delmar Boulevard University City, Missouri 63130 Mr. James G. Keppler U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 o
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C07.ANCHE PEAK 50-445/446 Mr. R. J. Gary Executive Vice President and General Manager Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201-cc:
Nicholas S. Reynolds, Esq.
Mr. Robert G. Taylor Debevoise & Liberman Resident Inspector / Comanche Peak 1200 Seventeenth Street, N. W.
Nuclear Power Station
. Washington, D. C.
20036 c/o U. S. Nuclear Regulatory Commission Spencer C. Relyea, Esq.
P. O. Box 38 Worsham, Forsythe & Sampels
~
Glen Rose, Texas 76043 2001 Bryan Tower Dallas', Texas 75201-Mr. John T. Collins U. S. NRC, Region IV Mr. Homer C. Schmidt 611 Ryan Plaza Drive Manager - Nuclear Services Suite 1000 Texas Utilities Services, Inc.
Arlington, Texas 76011 2001 Bryan Tower Dallas, Texas 75201 MF. Larry Alan Sinkin o
838 East Magnolia Avenue
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Mr. H. R. Rock San Antonio, Texas 78212 Gibbs and Hill, Inc. -
393 Seventh Avenue New York, New York 10001 Mr. A. T. Parker Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230 David J. Preister Assistant Attorney General Environmental Protection Division l
P. O'. ' Box' 12548, Capitol Station Austin, Texas 78711
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Mrs. Juanita Ellis, President Citizens Association for Sound Energy 1426 South Polk Dallas, Texas 75224 y
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MIDLAND (ForBNs)
Mr. J. W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 cc:
Stewart H. Freeman James G. Keppler, Regional Administrator Assistant Attorney General U.S. Nuclear Regulatory Commission, State of Michigan Enviornmental Region III Protection Division 799 Roosevelt Road 720 Law Building Glen Ellyn, Illinois 60137 Lansing, Michigan 48913 Mr. Ron Callen Mr. Roger W. Huston Michigan Public Serviced Commission Suite 220 6545 Mercantile Way 7910 Woodmont Avenue P.O. Box 30221 Bethesda, Maryland 20814 Lansing, Michigan 48909 Mr. R. B. Borsum Mr. Paul Rau Nuclear Power Generation Division Midland Daily News Babcock & Wilcox 124 Mcdonald Street 7910 Woodmont Avenue, Suite 220 Midland, Michigan 48640 Bethesda, Maryland 20814 Billie Pirner Garde Mr. Don van Farrowe, Chief Director, Citizens Clinic Division of Radiological Health for Accountable Government Department of Public Health Government Accountability Project P.O. Box 33035 Institute for Policy Studies Lansing, Michigan 48909 1901 Que Street, N.W.
Washington, D. C.
20009 U.S. Nuclear Regulatory Commission Resident Inspectors Office Commander, Naval Surface Weapons Center Route 7 ATTN: P. C. Huang Midland, Michigan 48640 White Oak Silver Spring, Maryland 20910 Mr. Paul A. Perry, Secretary Consumers Power Company Mr. L. J. Auge, Manager 212 W. Michigan Avenue Facility Design Engineering Jackson, Michigan 49201 Energy Technology Engineering Center
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P.O. Box 1449 Mr.. Walt Apl ey Canoga Park, California 91304 c/o Mr. Max Clausen Battelle Pacific North West Labs (PNWL)
Mr. Neil. Gehring Battelle Blvd.
U.S. Corps of Engineers e
SIGMA IV Building NCEED - T Richland, Washington 99352 7th Floor 477 Michigan Avenue Mr. I.- Charak, Manager Detroit, Michigan 48226 NRC Assistance Project Argonne National Laboratory Geotechnical Engineers, Inc.
9700 South Cass Avenue ATTN: Dr. Steve J. Poulos Argonne, Illinois 60439 1017 Main Street Winchester, Massachusetts 01890
Palo Verde Mr. E. E. Van Brunt, Jr.
Vice President - Nuclear Projects Arizona P'blic Service Company u
P. O. Box 21666 Phoenix, Arizona 85036 1
cc: Arthur C. Gehr, Esq.
Regional Adminstrator-Region V i
Snell & Wilmer U. S. Nuclear Regulatory Commission 3100 Valley Center 1450 Maria Lane Phoenix, Arizona 85073 Suite 210 Walnut Creek, California 94596 Charles S. Pierson Assistant Attorney General 200 State Capitol 1700 West Washington Phoenix, Arizona 85007 Charles R. Kocher, Esq., Assistant Counsel James A. Boeletto, Esq.
Southern California Edison Company P. O. Box.800 Rosemead, California 91770 lis. Maraaret Walker Deputy Director of Energy Programs Economic Planning and Development Office 1700 West Washington Phoenix, Arizona 85007 Mr. Rand L. Greenfield Assistant Attorney General Bataan Memorial Building Santa Fe, New Mexico 87503 Resident Inspector Palo Verde /NPS U. S. Nuclear Regulatory Commission P. O. Box 21324 Phoenix, Arizona 85001 Ms. Patricia Lee Hourihan 6413 S. 26th Street i
Phoenix: Arizona 85040 Lynne A. Bernabei, Esq.
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Harmon & Weiss 1725 I Street, N. W.
l Suite 506 Washington, D. C.
20006
PEMMY 50.-440/441 Mr. Murray R. Edelman Vice President, !{uclear Group The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 cc:
Jay Silberg, Esq.
Shaw, Pittnan, Potts & Trowbridge 1800 M Street, N. W.
Washington, D. C.
20006 Donald H. Hauser, Esq.
The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 Resident Inspector's Office U. S. Nuclear Regulatory Commission Parmly at Center Road Perry, Ohio 44081
- 0. S. Nuclear Regulatory Commission Mr'. James G. Keppler, Regional Administrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Donald T. Ezzone, Esq.
Assistant Prosecuting Attorney 105 Main Street Lake County Administration Center Painesville, Ohio 44077 Daniel D. Wilt, Esq.
P. O. Box 08159 Cleveland, Ohio 44108 Ms. Sue Hiatt OCRE Interim Representative 8275 Munson Mentor, Ohio 44060 Terry lodge, Esq.
915 Spitzer Building Toledo, Ohio 43604 John G. Cardinal, Esq.
Prosecuting Attorney Ashtabula County Courthouse Jefferson, Ohio 44047
O San Onofre Mr. Robert Dietch Vice President Southern California Edison Company 2244 Walnut Giove Avenue P. O. Box 800 Rosemead, California 91770 Mr. Gary D. Cotton Mr. Louis Bernath San Diego Gas & Electric Company 101 Ash Street San Diego, California 92112 cc: Charles R. Kocher, Esq.
Mr. Mark Medford James A. Beoletto, Esq.
Southern California Edison Company Southern California Edison Company 2244 Walnut Grove Avenue 2244 Walnut Grove Avenue P. O. Box 800 P. O. Box 800 Rosemead, California 91770 Rosemead, California 91770 Mr.HeneryPetkrs Orrick, Herrington & Sutcliffe San Diego Gas Electric Company ATTN: David R. Pigott, Esq.
P. O. Box 1831 600 Montgomery Street San Diego, California 92112 San Francisco, California 94111 Ms. Lyn Harris Hicks Mr. George Caravalho Advocate for GUARD City Manager 3908 Calle'Ariana City of San Clemente San Clemente, California 92672 100 Avenido Presidio San Clemente, California 92672 Richard J. Wharton, Esq.
University of San Diego School of. Law Alan R. Watts, Esq.
Environmental Law Clinic Rourke & Woodruff San Diego, California 92110 Suite 1020 1055 North Main Street Phyllis M. Gallagher, Esq.
Santa Ana, California 92701 Suite 222 1695 West Crescent Avenue Lawrence Q. Garcia, Esq.
Anaheim, California 92701 California Public Utilities Commission 5066 State Building Mr. A. S. Carstens San Francisco, California 94102 2071 Caminito Circulo Norte Mt. La Jolla, California 92037 Mr. V. C. Hall Combustion Engineering, Inc.
Charles E. McClung, Jr., Esq.
1000 Prospect Hill Road Attorney at Law Windsor, Connecticut 06095 24012 Calle de la Plata/ Suite 330 Laguna Hills, California 92653 Mr. S. McClusky Bechtel Power Corporation Resident Inspector, San Onofre/NPS P. O. Box 60860, Terminal Annex c/o U.S. Nuclear Regulatory Commission Los Angeles, California 90060 P. O. Box 4329 San Clemente, California 92672 Mr. Dennis F. Kirsch U.S. Nuclear Regulatory Comm. - Reg. V Regional Administrator-Region V/NRC 1450 Maria Lane, Suite 210 1450 Maria Lane / Suite 210 Walnut Creek, California 94596 Wclnut Creek, California 94596
Shil D:iDFRE.
Mr. C. B. Brinkman Combustion Engineering, Inc.
7910 Woodmont Avenue Bethesda, Maryland 20814
William C. Tallman Chairman and Chief Executive Officer Public Service Company of New Hampshire Post Office Box 330 Manchester, New Hampshire 03105 i
cc: Thomas Dignan, Esq.-
E. Tupper Kinder, Esq.
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John A. Ritscher, Esq.
G. Dana Bisbee, Esq.
Ropes and Gray Assistant Attorney General 225 Franklin Street Office of Attorney General Boston, Massachusetts '02110 208 State House Annex Concord, New Hampshire 03301 Mr. Bruce B. Beckley, Project Manager Public Service Company of New Hampshire Resident Inspector Post Office Box 330 Seabrook Nuclear Power Station Manchester, New Hampshire 03105 c/o US Nucleat Regulatory Comission Post Office Box 700 Edward J. McDermott, Esq.
Seabrook, New Hampshire 03874 Sanders and McDermott 408 Lafayette Road Mr. John DeVincentis, Project Manager Hampton, New Hampshire 03842 Yankee Atomic Electric Company 1671 Worcester Road Robert A. Backus, Esq.
Framingham, Massachusetts 01701 0'Niell, Backus and Spielman 116 Lowell Street Mr. A. M. Ebner, Project Manager Manchester, New Hampshire 03105 United Engineers & Constructors 30 South 17th Street i
Hs. Beverly A. Hollingworth Post Office Box 8223 7 A Street Philadelphia, Pennsylvania 19101 Hampton Beach, New Hampshire 03842 Mr. Philip Ahrens, Esq.
1 Diane Curran Esq.
Assistant Attorney General i
Harmon and Weiss State House, Station #6 1725 I Street, N. W.
Augusta,;taine 04333 i
Washington, D. C.
20006 Mr. Stephen D. Floyd Jo Ann Shotwell, Esq.
Public Service Company of New Office of the Assistant Attorney General Hampshire Environmental Protection Division Post Office Box 330 One Ashburton Place Manchester, New Hampshire 03105 Boston, Massachusetts 02108 Seacoast Anti-Pollution League D. Pierre G. Cameron, Jr., Esq.
Ms. Jane Doughty General Counsel 5 Market Street Public Service Company of New Hampshire Portsmouth, New Hampshire 03801 Post Office Box 330 l
Manchester, New Hampshire 03105 Mr. John B. Tanzer Town of Hampton, New Hampshire Regional Administrator - Region I S Morningside Drive U. S. Nuclear Regulatory Commission Hampton, NH 03842 631 Park Avenue King of Prussia, Pennsylvania 19406 Ms. Letty Hett Town of Brentwood RFD Dalton Road Brentwood, New Hampshire 03833
Seabrook Mr. Edward F. Meany Town of Rye, New Hampshire 155 Washington Road Rye, New Hampshire 03870 Ms. Roberta C. Pevear 4
Town of Hampton Falls, New Hampshire Drinkwater Road Hampton Falls, New Hampshire 03844 Ms. Sandra Gavutis Town of Kensington, New Hampshire RFD 1 East Kingston, New Hampshire 03827 l
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o 50-322 Swt a-
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"r. ". S. P o11 c ck Yice Presidert "uclear Lee.c Island Lichting Company 175 East Old Country Road Hicksville, Sew York 11801
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cci Howard L. Blau, Esquire MHB Technical Associates Blau and Cohn, PC.
1723 Hamilton Avenue,. Suit'e K San Jose, California 95125 217 Newbridge Road Hicksville, New York 11801 Stephen Latham, Esquire Mr. Jay Dunkleberger Twomey, Latham &.Shea..
New York State Energy Office Post Office Box 398.~ -
2' Agency Building 2 33 West Second Street. -
Empire State Plaza Riverhead, New York '11901
' Albany, New York 12223 Matthew J' Kelly, Esq"uii e s
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Energy Research Group, Inc.
Staff Counsel New York State Public Service Commissiol 400-1 Totten Pond Road
~Three Rockefeller Plaza.
~Waltham, Massachusetts 02154 Albany, New-York 12223 Mr. Jeff Smith Shoreham Nuclear Power Station Ezra 1. Bialik, Esquire Post Office Box 618 Assistant Attorney General Wading River, New York 11792 Environmental Protection Bureau New York State Department of Law W. Taylor 'Reveley, III,. Esquire 2 World 'rade Center Hunton & Williams New York, New York 10047 Post Office B'ox 1535 Richmond, Virginia 23212 Resident Inspector Shoreham NPS, U.S. NRC Ralph Shapiro, Esquire Post Office Box B Cammer & Shapiro Rocky Point,-New York 11778 9 East 40th Stre'et New York, New York 10016 Herbert H. Brown, Esquire Kirkpatrick, Lockhart, Hill, Christopher & Phillips Mr. Brian McCaffrey Lcng Island Lighting Company 1900 M Street, N.W.
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Suffolk County Attorney
~ ~ -Christopher & Phillips County Executive / Legislative Bldg.
1900 M Street, N.W.
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20036 Hauppauge, New York 11788
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- t Es 3. ~:.;;.tr.y, Esc.
3?'E Forter Street JEsnington, D. C.
20003 Lawrence Brenner, Esq.
Administrative Judge Atomic Safety & Licensing Board U. S. Nuclear Regulatory.Comission Washington, D. C.
20555
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20555 Dr. Peter A. Morris Administrative Judge Atomic Safety & Licensing Board U. S. N,uclear Regulatory Comission Washington, D. C.. 20555 4
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WATERFORD Mr. L. V. Maurin Vice President - Nuclear Operations Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174 cc:
W. Malcolm Stevenson, Esq.
Regional Adminstrator-Region IV Monroe & Lemann U. S. Nuclear Regulatory Commission i
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ZIMER 2-50-358 Ednarc R. Schweibinz U. S. fiRC, Region, III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Steven G. Smith The Dayton Power and Light Company P. O. Box 1247 Dayton, Ohio 45401 Mr. James P. Fenstermaker Columbus and Southern Ohio Electric Company
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IndianPoint2/3 Mr. J. P. Bayne Power Authority of the State of New York cc:
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White Plains, New York 10601 l
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INDIAN POINT 2/3 Mr. John D. O'Toole Conso.lidated Edison Company of New York, Inc.
cc:
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Washington, D. C.
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20036 Mr. Richard Hubbard MHB Technical Associates Mr. Dick Blankenburg Suite K Editor & Co-Publisher l
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..... w Mr. Ibicoln. H. Furbush Bruce Norton, Esq.
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Suite 1180 Washington, D. C.
20036 Regional Administrator - Region V U.S. Nuclear Regulatory Commission l
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FERMI 50-341 Mr. Harry Tauber Vice President Engineering & Construction The Detriot Edison Company 2000 Second Avenue Detriot, Michigan 48226 cc:
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20036 Peter A. Marquardt, Esq.
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GPU Nuclear Corporation 50-289, TMI-l Mr. R. J. Toole Jordan D. Cunningham, Esq.
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20006 W
- Judge Reginald L. Gotchy Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Mr. S'teven C. Sholly Washington, DC 20555 Union of Concerned Scientists 1346 Connecticut Avenue, N. W.
J. B. Lieberman, Esq.
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20036 26 Broadway New York, New York 10004 fir. Ronald C. Haynes, Regional Administrator U. S. N. R. C., Region I G31 Park Avenue King ~of Prussia, Pennsylvania 19406 l
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- Dr. John H. Buck Atomic Safety & Licensing Appeal Board John Levin, Esq.
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Dauphin County Office Emergency Shaw, Pittman, Potts & Trowbridg,e Preparedness 1800 M Street, N.W.
Court House, Room 7 -
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20036 Front & Market Streets Harrisburg, Pennsylvania 17101 Mr. E. G. Wallace Licensing Manager
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GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 William S. Jordan, III, Esq.
tis. Lennie Prough Harmon & Weiss U. S. H. R. C. - Ti!I Site 1725 I Street, NY, Suite 505 P. O. Box 311 Washington, DC 20006 Middletown, Pennsylvania 17057 Ms. Virginia Southard, Chairman -
Citizens for a Safe Environment 264 Walton Street
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Lemoyne, Pennsylvania 17043 -
Mr. Robert B. Borsum
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U.S.N.R.C.
ATTN: Coordinator, Pennsylvania P. O. Box 311 State Clearinghouse Middle' town, Pennsylvania 17057 P. O. Box 1323 Harrisburg, Pennsylvania 17120
Sacramento Municipal Utility Rancho Seco. Docket No. 50-312 District ccw/ enclosure (s):
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Sacramento Hanicipal Utility California Energy Comission District 1111 Howe Avenue 6201 S Street Sacramento, California P. O. Box 15830 95825 Sacramento, California 95813 Ms. Eleanor Schwartz California State'0ffice Sacramento County 600 Pennsylvania Avenue, S.E., Rs. 201 Board of Supervisors Washington, D. C.
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20555 Regional Radiation f.epresentative EPA Reaion IX Alah S. Rosenthal, Chairman 215 Fremont Street Atomic Safety and Licer. sing San Francisco, California 94111 Appeal Board U. S. flu: lear Regulatory Connission Mr. Robert B. Borsum Washington,'D. C.
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Washington, D. C.
20555 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Christine H. Kohl Washington, D. C.
20036 Atomic Safety and Licensing Appeal Board Herbert H. Brown, Esq.
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Washington, D. C.
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California Department of Health Washington, D. C.
20036 ATTN: Chief Environmental
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Radiation Control Unit Helen Hubbard Radiological Herlth Section P. O. Box 63 714 P Street, Room 498 Sunol, California 94586 Sacramento, California 95814
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UNITED STATES 4
Al NUCLEAR REGULATORY COMMISSION
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WASHING ton. D. C. 20555 I
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NAR 311933 MEMORANDUM FO9:
Franklin D. Coffman, Jr., Leader Systems Interaction Section Reliability and Risk Assessment Branch FROM:
James H. Conran, Senior Systems Engineer Systems Interaction Section, RRAB,
SUBJECT:
DIFFERING PROFESSIONAL OPINION 1
The purpose of this memorandum is'to submit formally, in accordance with NRR Manual Chapter 4125, a statement of differing professional opinion regarding certain aspects of existing policy and practice in the areas of systems interaction and safety classification.
Many, but not all, aspects of the matters at issue herein were addressed by me earlier in an affidavit dated February 9,1983, to the Shoreham Hearing Board. to this memorandum sets forth the detailed statement of my differing professional opinion in the areas identified above in the format suggested in Section C of NRC Appendix 4125.
In order to avoid needless repetition therein of the detailed treatment given already in the earlier affidavit to matters also of concern in the immediate context, Enclosure 1 draws to the maximum exten't possible on the presentation of issues provided in the affidavit.
Accordingly, the earlier affidavit is incorporated into this differing professional opinion as Appendix A; and Appendix A and are appropriately cr-referenced in order to facilitate their used together.
Points addressed to the attention of NRC. manage-
~
ment in the immediate context that were not treated explicitly in the affidavit to the Shoreham Board are denoted by asterisks in Enclosure 1.
Minor changes and editorial-type corrections made to the earlier affidavit since it was' executed on 2/9/83 are indicated by a bar in the right margin.
}
ames H. Conran Senior Systems Engineer Systems Interaction Section, RRAB Attachementt; See next page y
7
- Attachments:. Detailed Statement of Differing Professional Opinion.. Excerpt from Statement of Staff Views to Shoreham Board, dated 2/22/83.. Memo,' dated 3/9/79, Rubinstein to Bradford, " Probabilities That the Next Major Accident Occurs Within Prescribed Intervals".. Technical Paper, by D. Rubinstein, dated 2/4/81, "A Statisticians View of NRC Statistics".. Technical Paper (Draft), by D. Rubinstein, dated 10/26/81, " Random Thoughts on Uncertainties, Risk Analysis, and Nuclear Regulation".. Note, dated 3/18/82, Conran to Coffman, " Comments on Draft Letter (Hanauer to Cooper -NUPPSCO)....and Related Matters".. Excerpt from Rebuttal Testimony on Contention 78, dated 7/1/82, by J. H. Conran.
Appendix A - Affidavit of James H. Conran, dated 2/9/83, to the Shoreham ASLB.
cc:
R. J. Rawson, ELD w/ Attachments p
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Ot-1
Enclosure I STATEMENT OF DIFFERING PROFESSIONAL OPINION I. Systems Interaction Topic Issue A.
Significant Extension of Schedule for Pesolution of USI A-17 Without Appropriate Review or Justification 1.
Management View or Position The staff's program for resolution of USI A-17 has failed to achieve resolution of the systems interaction issue by now, in accordance with the schedule established as reasonable
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and acceptable wh'en the program wis initiated. Notwithstanding, management considers the program to be progressing i
i satisfactorily and emphasizes at this point the " confirmatory" nature of the program.( ) ( ) Accordingly:
l l
a.
management proposes at this point to continue pursuit of resolution of USI A-17 by following basically the same l
l
( ) See Statement of Staff Views to the Shoreham Hearing Board, dated 2/22/83?' (Excerpt attached as Enclosure 2.)'
l (2) Also see NRC Staff Supplemental Testimony on Contention 78 (Shoreham OL Proceeding), dated 3/10/83, at p. 5 & p. 14.
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approach and program plan employed to date, despite failure of that approach to achieve resolution of the
,important safety issue involved in the time allotted, and b.
management proposes to simply slip again, significantly, the schedule for resolution of USI A-17, without proper review and consideration of the possible need to accelerate the resolution of this issue and the possible consequences of failing to do so.
SEE APPENDIX A, AT P. 4 AND P. 10-11 2.
Differing Professional Opinion a.
Systems interaction in nuclear power plants is designated as both a Priority Category "A" generic safety concern and an Unresolved Safety Issue (i.e., USI A-17).
As such, by NRC policy and the agency's own definitions, the issue involved:
o is a matter that poses important questions regarding adequacy of existing requirements, for which S
e n
e
3-resolution is judged necessary to provide a potentially significant decrease in the risk to public health and safety, and whose resolution is likely to result in NRC action,0) and involves a generic concern judged by the staff to o
warrant priority attention in terms of manpower and funds, that should be pursued promptly to obtain early resolution that could provide possible significant increase in assurance of public health and safety.( ) ( )
b.
In view of the importance ascribed to the systems interaction issue and the indicated need for 1
prompt treatment and early resolution (as seen from A.2.a above), failure to achieve resolution of USI A-17 within the period established (by consensus) as acceptable should be treated as an important safety issue in itself.
Accordingly, the decision regarding schedule and approach to be followed from this point for resolution of USI A-17 should be made only after e.d (3) See NURIrG-0510 at p. 10 f
k (4) See NUREG-0510 at p. 11 and p. 49 (Table 1 - Priority Category "A" p ) Definition).
See NUREG-0885 at p. 5 (Commission 1983 Policy and Planning Guidance).
u a
O full review and appropriate consideration of the possible safety implications involved in further delay.
SEE APPENDIX A, AT P. 3-9, AND P. 11-12.
To assure that there is not further significant delay in c.
resolving the systems interaction issue, an augmented and accelerated approach should be adopted at this point for resolution of USI A-17.
Efforts should continue as planned under the current program, for development and demonstration by the staff of improved, efficient methods for comprehensive broad-scope systems interaction evaluations.(for later application in all facilities, if found necessary).
Additionally, however, all licensee and NT0L applicants should be required to perform limited systems interaction evaluations of their facilities (scope to be established by agreement with staff) using currently-available techniques.
This would better ensure early availability of actual in plant systems interaction data required by the staff to determine the need for full-scope systems interaction studies generically.
- se T:
s
, This approach would make the program less vulnerable to significant delays resulting from plant-specific operating problems and licensing-related difficulties (as has occurred repeatedly under the current approach), because availability of the required data would no longer be dependent upon completion of studies in just a few
" participating" facilities.
At the same time, etilities would not be unduly burdened by an immediate requirement for full-scope, comprehensive systems interaction studies that might not be justified at this time.
C
- d.
In the. absence of compelling current indication that the definitions and policy indicated in A.2.a above (regarding the nature of items designated Unresolved Safety Issue and/or Priority Category "A") no longer l
l apply to the systems interaction concern, management l
should not now characterize USI A-17 as merely or principally " confirmatory" in nature.
i s
'A i
1 l
. 3.
Possible Consequences if Differing Prefessional Opinion is Not Adopted If the underlying causes of unexpected events in reactor operating experience, such as common cause/ common mode failure, are not addressed effectively (e.g., by timely resolution of USI A-17), the likelihood of a serious accident occurring could become unaccpetably high.
SEE APPENDIX A, AT P. 6-7.
(See also A.4.b below for a more quantitative approach to treatment of the stated concern) 4.
Related Efforts and Other Information Pertinent to Resolution of Differing Professional Opinion a.
The ACRS has considered the systems interaction issue in the broad licensing context since 1974, and has made specific recommendations on several occasions regarding the kinds of less-than-full-scope systems interaction evaluations that could be usefully undertaken in both operating plants and NTOL facilities.
(See, for example ACRS letters dated 1/8/82 and 3/9/82, regarding systems h
interaction matters.) The ACRS should be consulted in deciding finally the course of action to be taken from this point in pursuing the systems interaction issue.
- b.
Mr. David Rubinstein, a statistician and member of the RRAB staff', has described previously (in a separate context) the " prediction interval method" for putting an upper bound on the probability that (given "X" number of reactor years of operation without a major accident) the next major accident will occur within a specified number of years.( ) That statistical method provides an alternate way of addressing the concern expressed qualtitatively in,A.3 above regarding urgency of timely resolution of USI A-17; and it could provide another useful perspective and additional insights in the difficult process of developing a consensus judgment i
i
(
l (6) See memo, dated 3/9/79, Rubinstein to Bradford, " Probabilities That the Next Major Accident Occurs Within Prescribed Intervals" (See attached, l ).
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O 8-now regarding the general question of acceptable schedule and proper course to be followed from this point in resolving usI A-17, and, more specifically, regarding whether or not an accelerated approach should be taken now in that regard.
Issue B.
Disproportionate Emphasis and Priority Given PRA to The Detriment of Systems Interaction Program 1.
Management Policy or Practice There have been clear indications over the last ~2 years of significant decrease in emphasis by NRC management on systems interaction as a licensing-related safety issue requiring early resolution and warranting priority attention in its own right.
Concurrently, increased emphasis and high priority has been given to PRA-related programs / activities that are only of a development nature.
Examples or manifestations of management attitude and practice in this regard include:
a.
abolishment of the Systems Interaction Branch in early 1981, and an accompanying sharp reduction in the number h.
h I
i
_g.
of NRC technical staff assigned to systems interaction efforts within NRR (PRA programs and activities within
,NRR were not similarly affected),
SEE APPENDIX A, AT P. 16-17.
- b.
assignment currently of significantly greater numbers of NRC technical staff (either full time or part time) in support of PRA-related development type programs and development activit'es than are assigaed to the licensing-related USI A-17 effort.
- c.
completion, or near-completion, to date of ~15 or more broad-scope PRA studies at reactor facilities under NRC cognizance (including both operating reactors ai:d NTOL plants), whereas not one broad-scope systems interaction study planned in connection with USI A-17 has yet been completed at any facility.
d.
withholding / delay (from October 1981 to present) of NRR approval for implementation of the important methodology demonstration phase of the systems interaction program because of (i) cost-benefit concerns, and (ii) lack of any showing that significant " risk-benefit" was to be f
gained from the systemt interaction studies planned in pursuit'of resolution of USI A-17.
l l
IEE APPENDIX A, AT P. 19-21, and P. 24.
6
. e.
pretracted effort (from ~0ctober 1981 to present) to merge the systems interaction program with the NREP program for cost-benefit advantage, without regard to adverse effect on the more important licensing-related objective ( i.e., resolution of USI A-17).
SEE APPENDIX A, AT P. 16-21.
f.
progressive blurring of the distinction between systems interaction (a licensing-related USI) and PRA (a developmental-type activity), and a growing tendency to treat systems interaction as just a subordinate part of PRA.
SEE APPENDIX A, AT P. 22-24.
2.
Differing Professional Opinion a.
Under the current system of NRC rules and procedures for reactor licensing, the systems interaction issue (i.e.,
USI A-17) is a matter that must be addressed in determining compliance with existing rules to assure adequate safety.
The same cannot be said regarding NRC's PRA-related programs and acitivities.
That is an important distinction that should be taken into account I
and weighted more heavily in determining the relative y
s s
importance and priorities of systems interaction and PRA-related programs.
NRC should continue to pursue
,PRA-related development programs intended to impruve understanding of the risks associated with operation of reactors. Disproportionate emphasis and priority has been given to PRA, however, in the last ~2 years by NRC management; and this has operated to the serious detriment of the systems interaction program, and resulted in inordinate delay in the resolution of USI A-17.
SEE APPENDIX A, AT P. 16-18.
- b.
Greater emphasis should b,e given (e.g., in the Safety Goal Implementation Plan) to,the fact that incomplete treatment of systems interaction is a major potential source of uncertainty in PRA, and that further study of the possible need for significant improvement in that regard (e.g., as planned in the USI A-17 program) must be completed before final consideration will be given to approval for use of PRA in licen' sing applications currently proscribed.
- c.
Proper balance should be restored with respect to importance ascribed and priorities given to systems b
?+
interaction and PRA-related programs by NRC management,
12 -
reflecting consideration of the important distinction between those two major areas of activity, as indicated
.in B.2.a above. Specifically, NRC management should:
assign higher priority than is currently given to o
programs for resolution of the systems interaction issue, and provide increased management support and attention to assure expedited treatment and early resolution of the important licensing related safety issue involved, o
assign greater numbers of NRC technical staff to systems interaction work (e.g., comparable to staffing levels dedicated to sys,tems interaction work prior to April 1981),
o review the effectiveness of the current organizational setup within NR.R for conduct of systems interaction programs (e.g., consider seriously a return to the organizational structure and alignments in effect at the outset of the II.C.3 program).
SEE APPENDIX A, AT P. 8.
e
'e e
A *d.
Schedules for performance of programs for resolut. ion of USI A-17 should be established and implemented so as not to
,be dependent upon, or subordinate to, PRA-related program schedules in any way that would delay achievement of necessary USI A-17 program objectives.
SEE APPENDIX A, AT P. 8 AND P. 21.
- e.
Requirements for cost-benefit analyses should not be imposed (or applied) in a way that delays excessively, or interferes with prohibitively, the conduct and timely completion of programs for resolution of Unresolved Safety Issues (in this instance, USI A-17).
SEE APPENDIX A, AT P. 21-22.
f.
Estimates of risk-benefit to be gained from doing comprehensive systems. interaction analyses, based solely on extrapolations of current PRA results/ data, cannot be regarded as accurate or dependable.
Since that is the only basis currently for such estimates, risk-benefit should not be used at this time as a decision crite-ion by management in determining whether or not to approve systems interaction studies proposed in connection with the USI A-17 program.
I SEE APPENDIX A, AT P. 24-26.
?
I k
. *g.
Lack of effective communication of systems intetaction information and perspectives, to all levels of management and to all cognizant staff (both intra-and-inter office) may have been an a factor in the development of the conditions described in preceding Sections A.1 and B.1.
Measures should be taken to assure proper flow of communications in that regard, and also to assure dissemination of alternative views regarding the state of development and usefulness of both PRA and systems interaction analysis methods and techniques.
Neither are so highly-developed or refined that both cannot continue to profit from the free exchange of the full range of views on.the important matters involved.
4 3.
Fossible Consequences if Differing Professional Opinion is Not i
I Adopted
- a.
If proper balance is not restored with respect to importance ascribed and priorities assigned to systems interaction and PRA-related programs, and if other specific corrective l
measures are not implemented as indicated in Section A.2 and l
l B.2 above, further inordinate delay in the resolution of l
USI A-17 will likely result (with possible increased i
r 4
t.-
likelihood of serious accident).
SEE APPENDIX A, AT P. 6-7.
l
[
- b.
If, in cdvance of resolution of USI A-17, NRC management continues to encourage initiation and performance of current-state-of-the-art PRAs (i.e., without comprehensive systems interaction analyses as an integral part), unnecessary and excessive costs may result for the licensees or applicants involved when/if the performance of separate comprehensive systems interaction analyses (and integration of PRA and systems interaction results) later become necessary (as has happened to PASNY in the case of Indian Point-3).
(See sections 4.c and 4.d below for further development of the point addressed here.)
4.
Related Efforts'or Other Information Pertinent to Resolution of Differing Professional Opinions
- a.
Comments offered by the ACRS and individual ACRS members j
(in the context of review of Safety Goals Policy Statement, l
Safety Goal Implementation Plan, and Severe Accidents Policy Statement), ( ) regarding treatment in PRA of uncertainties due to systems interactions and premature acceptance /use of current PRA methods and results in licensing, should be given further consideration in the light of all the preceding.
The Committee should be consulted in resolving this differing w
professional opinion.
7
(#)
See ACRS letters dated June 9, 1982; September 15, 1982; Septemberk 1982; and January 10, 1982.
~ *b.
Alternative views expressed earlier and separately by Mr. David Rubinstein, RRAB regarding quality or adequacy ofcurrenttreatmentofuncertaintigs)inPRA,anduncritical acceptance of current PRA results are pertinent and should be considered in the resolution of this differing professional opinion.
- c.
Preliminary indications from work being done currently at the Indian Point-3 facility are that great effort and expense will be required to fully factor the results of a broad-scope systems interaction study for a given facility into a full-scope PRA for the same facility, where those two efforts have been conducted as separate activities (as at Indian Point-3).
- d.
Information submitted recently to the staff on the Indian l
Point-3 docket indicates that the findings from comprehensive systems interaction analyses may affect i
significantly the results obtained from current-state-of-the-art PRAs.
Results obtained from the systems interaction evaluation of the Indian Point-3 AFW system,
()PaperdAed2/4/81,"AStatisticiansViewofNRCStatistics".
O (See attached, Enclosure 4.)
(*) Paper, dated 10/26/81, " Random Thoughts on Uncertainties, Risk Analysis and Nuclear Regulation," (Seesattached, Enclosure 5.)
17 -
when factored into the Indian Point-3 PRA, nearly doubled the system failure rate for AFW (even after modifications were made to the plant to improve / remove interactions identified),(
)
Corresponding seismic core melt frequency was not found to change appreciably for the case recomputed; but it should be l
noted that systems interaction search results for other IP-3 systems (in particular, systems that provide alternate cooling in the event of AFW system failure) are only now being separately evaluated in the final phase of the systems interaction analysis effort, and were not factored into the recomputation of IP-3 PRA results that was done at this time.
9 6
Also, core melt frequency was not recomputed at this time for the case in which the IP-3 PRA model was modified to include I
the AFW systems interactions, but fixes were not made to the plant to remove / improve interactions found.
(That case would clearly provide the better comparison and more accurate measure of the full impact i.e., " risk-benefit, of systems interaction analyses on PRA results.)
l 1
l
(
)SeePAShYsubmittaldated2/7/83,atp.4-14ofAttachmentII.
U l
s s
l
. II. Safety Classification Topic Issue C.
Insufficient Priority Given to Resolution of Known Safety Classification Problems 1.
Management Position or Practice
- a.
The use of the safety classification terms
" safety related", " safety grade", and "important to safety" inconsistently or interchangeably by individual staff members was recognized as a problem by NRR management ~2-3 years ago.
The immediate problem was dealt with effectively by issuance of guidance to the NRR staff in the form of " standard definitions" for the terms involved (derived directly from the language of the regulations themselves).( ')
NRR management has not acted expeditiously, however, in following up that action with additional remedial measures that were also prudently indicated, and which were recommended specifically,(
) i.e.:
(
)SeeMehos, dated 11/20/81, Denton to All NRR Personnel and Denton to f
Mattson, Eisenhut, Vollmer, et al, " Standard Definitions for Commonly-Used Safety Classification Terms.
(28) See Note, dated 3/18/82, Conran tp Coffman, " Comments on Draft Letter Hanauer to Cooper -NUPPSCO)....and Related Matters"; and attached routing slip.
(See attached - Enclosure 6).
P modification of the regulations to more clearly o
delineate for all interested and affected parties the general safety classification definitions that are already included (diffusely or reconditely) in the language of the regulations development of more formal and detailed guidance o
(e.g., Reg. Guides or SRP sections) for use by licensees / applicants and all NRC staff (not just NRR), in applying these terms correctly in specific design and licensing review applications.
- b.
Reasons given for not pursuing'more vigorously the followup measures indicated and recommended were:
o resource availability problems, given the magnitude of the (projected) effort to develop / issue formal guidance documents, o
NRR guidance, although not distributed officially outside NRC (and not binding in present form even if distributed) has been circulated widely (albeit I
informally) outside the agency so the staff's l
view / position with regard to definition for the terms involved is widely-known anyway, g
o no safety problems or serious potential safety problems are known to have resulted from lack of the more formal and detailed guidance recommended, s
, o the " problem" involved was thought to be simply or chiefly a " language" problem (i.e., resulting simply from inconsistent'or mistaken usage of words applied in treating or discussing safety classification concepts embodied in the regulations that are for the most part mutually understood and agreed upon.
2.
Differing Professional Opinion a.
Testimony developed recently in the discussion of safety' classification issues in the Shoreham hearing indicates clearly now that lack of unambiguous, detailed guidance regarding the definition and proper application of the classification term "important to safety" can lead to confusion and misunderstanding with respect to the intent of the regulations, and to the development of circumstances that appear to have significant potential adverse safety implications.
Specifically, in the Shoreham case cited the applicant has interpreted the term "important to safety" to be equivalent to the term
" safety-related" (as both the staff and the applicant understand the term " safety-related"), and has applied that interpretation throughout the design and construction of their facility.
s s
_ _ _ _ _ - - _ _ _ - - - Under this interpretation the applicant, in effect, does not acknowledge any requirements under the regulations
.for plant features designated by the staff "important to safety, but not safety-related." Said another way, the minimum set of safety requirements recognized by the applicant under this interpretation is considerably smaller than the minimum set of safety requirements recognized by the staff.
Such a fundamental difference of understanding regarding what is required minimally by the regulations for adequate safety clearly has significant potential for adverse safety impact.
The full implications of the situation indicated in the preceding (particularly in the context of operating facilit-ies) has not yet been completely sorted out;(24) but NRC should give high priority now to an effort to do that.
At a minimum the measures recommended below should be implemented in remedy of the situation indicated.
SEE APPENDIX A, AT P. 30-33.
(14) See Rebuttal Testimony dated 7/1/82 by J. H. Conran to the Shoreham ASLB, at p. 6-7.
F-c f **
- 7 v.
s
. *b.
NRC should take action promptly to determine the following regarding all licensees / applicants:
if all licensees / applicants are aware of the o
~
safety classification definitions in the regulations for the terms safety-related and important to safety, as indicated in Ref. 12, if there is common understanding of the safety o
classification concepts involved in the terms safety-related and important to safety, irrespective of " language-type" differences that may exist / persist in the usage of thest terms by individuals, o
if there is mutual understanding between the staff and licensees / applicants regarding what is actually required minimally under the regulations to provide reasonable assurance of public health and
- safety, o.
if there is indication of any incorrect classification and/or treatment of plant structures, systems, and components as a result of misunderstanding or confusion regarding proper usage of the safety classification terms involved.
i
, *c.
NRC should give higher priority now to implementing additional (followup) measures recommended previously, but not yet acted upon, as indicated in C.1.b above.
- d.
NRC should complete expeditiously now efforts already initiated for development of a listing of structures, systems, and components "important to safety, but not safety-related" (analogous to the listing of safety related things in Reg. Guide 1.29), to facilitate proper understanding and application of the intent of the regulations by those who have not previously understood and applied the term "important to safety" in the same way as the staff.
- e.
NRC should give high priority now to completion of the joint effort initiated ~in September 1982 by the staff and industry to develop a safety classification standard for endorsement finally by the staff in a Reg. Guide.
This has never been done, and has contributed to the i
persistence of this problem for many years.
l l
-a-
$1mm M
- de, se
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFO'E THE ATOMIC SAFETY AND LICENSING BOARD R
In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322(OL)
AFFIDAVIT OF JAMES H. CONRAN I, James H. Conran, being duly sworn, depose and s, tate that:
QUALIFICATION OF WITNESS 1..
I'am an employee of the U. S. Nuclear Regulatory. Commission (NRC).
My present position is Senior Systems Engineer, Reliability and Risk Assessment Branch, Division of Safety Technology within the Office of Nuclear Reactor Regulation.
A copy of my professional qualifications is bound into the transcript of the Shoreham Hearing at p. 6538.
l l
APPENDIX A hybtDOMON
& p.
fog a.f
PUitPOSE OF AFFIDAVIT 1.
The purpose of this af fidavit is to identify for the Board (1) areas in which I believe that testimony which I provided earlier in the 1
litigation of Contention 78 requires (or may require) amending and/or supplementing, and (2) changes that have occurred in facts or circumstances material to the matters at issue in Contention 78 which give rise to the need for amending and/or supplementing the testimony involved.
The affected testimony falls into two general topic areas, systems interaction and safety classification.
SYSTEMS INTERACTION TOPIC 2.
Change to Testimony and General Circumstance Dictating Change Consistent with the Appeal Board's decision in North Anna, staff's l
testimony on systems interaction in the Shoreham hearing included a discussion of Unresolved Safety Issue A-17, with the specific objective of demonstrating " justification for operation" of Shoreham despite pendency of that USI.
I was the principal author of the portion of staff's written testimony covering systems interaction, and was a principal witness in presenting the staff's position on that issue before the Board.' My testimony in that regard was based necessarily on my unde,rstanding, at the times that that testimony was written 1
See ALAB-491,8 NRC 245 (1978)
~
, and presented, of the state of the staff's program for resolving USI A-17, and more specificall'y on my understanding of such parameters as scope, schedule, priority, and resources allocated to that program.
These parameters determine the rate of progress and actual results tnat can be achieved, or be reasonably expected, at any given time; they are, therefore, important indicators or measures of the adequacy of any USI program, and of the prospects for timely resolution of the issue involved.
Despite unfavorable developments that had occurred with respect to these important parameters in the systems interaction program in the months preceding the presentation of staf.f's; testimony on Contention 78 in the Shoreham hearing, I had remained hopeful at that point regarding the, ultimate outcome of events in the systems interaction area and regarding the prospects for resolution of USI A-17 on some' reasonable and still acceptable schedule.
But there has been further decline in the months since; and the cumulative effect is.now such that I can no longer t
continue, in good conscience, to support the position that the staff's systems interaction program provides currently an adequate basis for the
" justification for operation" concl'usion reeuired under North Anna, as indicated in my earlier testimony.
O b
e l
s s -
. 3.
Background and Basyline At Outset of the Program for Resolution of USI A-17 As aj1uded to in the preceding, it is necessary to go back in time further m
than my participation in the Shoreham hearing last summer to set the background and to establish the baseline against which are drawn my current judgments regarding the adequacy of staff's systems interaction program. To recount briefly the relevant background, the judgment by staff management and the Commission that the systems interaction issue is a legitimate safety concern, serious enough to warrant designation as an Unresolved Safety.
Concern 'i.e, USI A-17), was documented as early as 1977;2 and a program for resolution of this-issue 1.was initiated in May 1978.3 That initial judgment and action by NRC managemer,t in this regard was reconfirmed and reinforced EintheaftermathoftheTMI-2acciden}byastrongrecommendationofthe (of which I was a member), and by further action Lessons Learned Task Force 4 by staff management and the Commission,8 to strengthen the existing, t
on going USI A-17 program.
In early 1980, the Commission approved for inclusion in the TMI-2 Action Plan a provision for an augmented and expedited l
systems interaction program; and a separate, dedicated organizational unit (the Systems Interaction Branch) was set up within the Division of Systems Interaction, NRR to plan and coordinate the conduct of the new, augmented
~
program.
By mid-1980, the new Systems Interaction Branen had developed the SeeNUREG-3410 7
2 3
l See NUREG-0510 at p. A-12 See NUREG-0585, Section 3.2 and Recommendation 9 4
5 See NUREG-0660, Item II.C.3
- program plan for the augmented (II.C.3) systems interaction program."
The expanded program included (i) studies in which staff-developed methodologies were to be applied on a trial basis in selected plants late in the construction and OL licensing process, and (ii) other studies, (already committed to by the owners of the Diablo Canyon 1 & 2, and Indian Point-3 facilities, to be initiated in mid-1980 and early-1981, respectively) employing methodologies developed by the utilities involved.
The results of all these efforts, taken together, were intended (i) to provide the basis for resolution of USI A-17, and for the development by the staff of additional requirements and regulatory guidance for systems interaction studies (if required) for application to all reactors, within about 2 years, and (ii) to provide useful information and insights to be factored into decisions regarding implementation of the National Reliability Evaluation Program (NREP).7 With the preceding background (by way of further establishing the
" baseline" alluded to earlier for current judgments of program adequacy) the decisions and actions taken by staff management and the Commission to this point in the systems interaction chronology can be characterized as follows:
" See Memo, dated 11/21/80, Stolz to Rubenstein, " SIB /DSI FY 81 Resource l
Projection" 7 See NUREG-0660, Item II.C.2 l
I
i
. a.
Baseline Consideration #1 The decisions and actions taken established the systems interaction program, in a very real sense, as a necessary regulatory activity i.e., as a USI program 8 which under existing rules must be addressed in reactor licensing safety evaluations.... (as contrasted to other highly desirable programs and activities, such as probabilistic risk assessment, safety goal development, etc.,
also provided for in the TMI-2 Action Plan, but which need not be so addressed) b.
Baseline Consideration #2 The decisions and actions taken indicated clearly that staff
^
management and the Commission intended timely resolution of this important issue..The period of time in which it was thought initially that this could be accomplished was 1-1 years. However, it was found that the fault tree methodology which had been developed in the pre-TMI phase of the USI A-17 program was not suitable for l
general, broader application in systems interaction analysis, (as had been counted on)'; so about a year was added to the time period that had initially been contemplated for program performance, to allow for search-and-development of possible alternative methodologies by the staff.
It should be said, however, that allocation of even ~2 years for resolution of such a complex uriresolved safety issue necessarily implied and, indeed, required 7
See NUREG 0510, at p.10, p.11, and p. 49 (Table 1-Category A definition)
See Memo, dated 5/20/80, Angelo to Kniel, " Summary of Meeting with Sandia...to discuss... Task A-17" l
l
O assignment of high priority, and strong commitment to the USI A-17 program by staff management and the Commission.
c.
Baseline Consideraton #3 With regard to the question implicit in the specification (as in Baseline Consideration #2, above) of the period of time to be allowed (at the outset) for the program to achieve timely resolution of USI A-17 (i.e., How to determine what is reasonable in that regard in view of the urgency of the matter?), the general concern under-lying can be stated as follows:
" Things unanalyzed" in the design of reactor plant systems (e.g., common mode / common cause mechanisms, and the effects of non-safety component failure) can lead to " things unexpected" in the operation of reactor facilities (e.g.,
occurrence of unanticipated' events, including some serious enough to be termed accident precursors).
And no matter how well trained or capable reactor operating personnel are (i.e.,
given some finite unreliability rate in operator actions), if the " unexpected" happens often enough (and it does, based on I
operating experience reports) for long enough, the likelihood of a serious accident (like TMI-2) can become unacceptably high.
I
~
The judgment, then, regarding what is a " reasonable" period of time to allow for resolution of the systems interaction issue involves
_ - somehow qualitatively (i) consideration of the rate of occurrence o'f unexpected events (in particular, serious precursor events) and (ii) a sense that the time allowed for resolving underlying causes of such events ought not to exceed some prudent fraction of the
" average interval" for occurrence of such events, based on experience and observation.
To say the obvious, that is a very difficult judgment for any individual to make, and should not, therefore, be left to ad hoc individual judgment.
Such a difficult judgment on such a complex, important safety issue should properly be evolved (as was done in the series of events leading up to initiation of the II.C.3 systems interaction program; see Baseline Consideration #5) through a broad-based consensus forming process.
As a strong corollary, once established in the proper manner (as described above, and in Baseline Consideration #5), schedules specified for the resolution of important safety issues (e.g., USI A-17) ought to be regarded seriously, and ought not to be overturned or extended significantly except on the basis of an equivalent process.
More specifically, significant extensions l
l should not be permitted or condoned simply by virtue of default on performance of the schedule established by consensus.
. d.
Baseline Consideration #4 Consistent with the high priority assignment and timely resolution objective for the augmented, post-TMI systems interaction program (see Baseline Consideration #2 above), although the II.C.3 program was to be closely coordinated with other programs (such as IREP10 and NREP22), the schedules for the completion of studies intended to lead to the resolution of USI A-17 were established initially so as not to be linked to, or dependent upon, IREP/NREP program schedules in anyway that would delay achievement of the necessary USI-related objectives.
Further indication of such intent is seen in the fact that the management of the systems interaction program (II.C.3) was established initially separate from the management of the IREP.(II.C.1) and NREP (II.C.2) programs (i.e., with the progr'am management involved in each case reporting to the Office Director and Executive Director levels through different chains of command).
e.
Baseline Consideration #5 The decisions and actions taken in establishing both the initial USI A-17 program in 1978, and the augmented, post-TMI systems interaction program (II.C.3) in 1980, were taken within the context of an _ existing, established regulatory structure and process in which well established (approved) deterministic criteria and requirements l
d dine what is adequate safety unless/until changed by due process t
l l
10 Interim Reliability Evaluation. Program (IREP).
See NUREG-0660, Item l
II.C.1 22 See NUREG-0660, Item II.C.?
_g.
(i.e., the process outlined here).
Thcese decisions and actions were based broadly on widely-shared qualitative judgments regarding the importance of the issue involved and the necessity for prompt action and timely resolution (see Baseline Consideration #3).
The decisions involved were evolved through a highly visible and open consensus forming process, which included full opportunity for review internally by cognizant NRC staff and ACRS.
4.
Changes in Material Facts or Circumstances Affecting Testimony Having established in the preceding the bac,kground and baseline which form the basis for my' understanding of the staff's system interaction program, and against which I form judgments regarding its " status" and adequacy of any given point, I identify, in the following, significant changes that have occurred with respect to these baseline facts and circumstances l
which affect my earlier testimony.
Some of the changes identified t
occurred before my Shoreham testimony, and some after; but all bear materially on the question of current validity of my earlier testimony.
And I believe that all must be considered together to understand fully my current position in this matter.
~
l
__ a.
E'xcessive Delay in Resolution of USI A-17 The most significant deficiency of the current system interaction program impacting the validity of my earlier testimony is that, although we are now nearly at the end of the period of time allocated for the resolution of USI A-17, we are nowhere near to achieving resolution of this important safety issue, along the current track and at the current pace. My optimistic estimate, in that regard, is that that goal is still 2-3 years off without significant reordering of priorities and re-constitution of the II.C.3 program i
along the lines suggested herein.
I conclude, therefore, that the program cannot be regarded or characterized as adequate (specifically in the sense required to be addressed under North Anna; see Baseline l
Considerations #2 and # 3).
To be somewhat more specific,.although notable progress has been achieved in the development of promising " candidate" systems interaction methodologies by the staff (as planned), demonstration or trial of those methodologies has not yet been done (or even i
begun).
And while there have been hopeful developments recently with regard to getting those efforts underway finally (on the basis
, of initiatives taken/ supported by the Director, NRR himself), it is clear that the completion of the demonstration phase of the II.C.3 e
program will take significantly longer to complete than initially planned (e.g., perhaps an additional 1-2 years).
Also, although extensive, broad-scope systems interaction search efforts have now been completed at the Diablo Canyon and Indian Point-3 facilities using utility-developed methods, it now appears certain (i) that the planned submittal of unevaluated Indian Point-3 search results to the staff in late 1982 or early 1983, will now be delayed until late 1983 (due to hearing related considerations and complications),
and (ii) that the final submittal of evaluated Diablo Canyon search results, which had been expected in late 1982 is now delayed indefinitely (due to well-known licensing related difficulties that have arisen in that case).
In full view of these circumstances, the prevailing staff view seems to be to " stay the course"; i.e., continue along the current track at whatever pace can be achieved to eventual resolution of USI A-17, whenever that may occur.
Under this view the program could be considered adequate currently simply because there is some systems interaction work currently underway (albeit well behind schedule), and because there is "no evidence" that drastic measures must be taken to hasten resolution of the system interaction problem.
My view, instead, is that there is "no evidence" that the consensus judgments, regarding the seriousness of the safety k
e
. concern involved and the need for timely resolution (i.e., in the time period allocated and agreed upon at the outset; see Baseline Considerations #2 and #3), were that wrong in the first instance.
The decision to delay or extend the schedule for resolution of USI A-17 is, by its very nature, a major safety decision and should not be made by default, or by a few individuals on the ad hoc "no evidence" basis indicated.
(See Baseline Consideration #3)
I believe, therefore, that the proper course of action at this point is (i) to recognize the inadequacy of the current state of the program, and (ii) to " call the question" for reconsideration, and submit it to the same decision making process that established initially the time to.be allowed for resolution of USI A-17 (See Baseline Consideration #5).
In that respect, I would favor strongly this time around a currently-appropriate variation on the original recommendation made by the Lessons Learned Task Force in 1980 in this regard,12 and the similar recommendation made by ACRS in January 198218, to wit: Require all licensees and OL applicants to begin limited systems interaction reviews of their facilities immediately, using methods now known and documented for use or See NUREG-0585, Section 3.2 and Recommendation 9
//8/82.
18 See ACRS_ letter dated #48/82, " Systems Interactions"; also see ACRS letter dated 3/9/82, " Report on SI Study for Indian Point -3."
l l
. trial (even though not completely evaluated at this time).
The reasons for favoring now the more direct and immediate approach are (i) fail'r'e to resolve the systems interaction issue u
in the three years that have passed since inception of II.C.3 (or in the five years since USI A-17 was initiated) by employing a less direct and immediate approach, and (ii) clear indication now that licensees do not need to wait on the staff any longer to develop and demonstrate workable systems interaction methodologies that can produce safety-beneficial findings and results.
In this regard it is noted that, while the staff (for whatever the reasons) has not developed and app 1'ied workable systems interaction methodologies in the time, allotted initially under the II.C.3 program, three utilities have done so (i.e., at Diablo Canyon, Indian Point-3, and most recently the Perry facility).
Although the results of these efforts have not yet been fully-evaluated by the utilities involved and reviewed by the staff, in several instances on the basis of licensees' own prudent judgment, modifications to facility designs have already resulted from these system interaction reviews.
l I
l
. So a broad scale effort involving limited-scope systems interaction r'eviews in all operating facilities and NTOL plants could both (i) produce safety beneficial plant specific findings (as has already been done) and (ii) at the same time provide much more expeditiously and extensively actual systems interaction data and information needed by the staff for making final decisions regarding the possible need for more comprehensive systems interaction reviews generically.
Suitable arrangements could be made between the staff and each utility regarding the scope of review to be done at each facility, and regarding the choice of methodology to be applied, (including choice of one of the staff's candidate methodologies, if mutually agreed).
As a final point regarding this particular aspect of changes in circumstances that have affected my earlier testimony, it might seem that the conclusions drawn at this time in this affidavit,-
regarding inadequacy of the program because of failure to resolve USI A-17 on the schedule initially established (i.e., about now),
could have been drawn as easily 6-8 months ago as now (i.e., during the preparation a.'d presentation of my earlier Shoreham testimony).14 l
Such is not trie case.
Although (as alluded to in Section 2 above) 2*See, for example, Transcript of TMI-1 Appeal Board proceeding at p.300, for for reaction of Appeal Board just to the changes of circumstance outlined for them in the affidavit cited in footnote 19.
there had been unfavorable developments in some aspects of the systems interaction program in the months preceding my p'articipation in the hearing (described in further detail in Section 4.b following), the program in other important aspects was showing significant progress and results.
For example (i) the Indian Point-3 systems interaction program plan was approved in early March 1982, and was underway and proceeding very well by early April, (ii) the matrix-based dependency analysis methodology development effort was launched in late Spring 1982, and (iii) prospects were very bright for the staff receiving extensive actual systems interaction review results from both Diablo Canyon and Indian Point-3 by late 1982.
Additionally, there seemed to be real hope of getting the badly-lagging methodology demonstration phase of the program back on track and moving as a result of a development that occurred in early May 1982.
At that time, there came down from the Chairman's office a request for a briefing on the status of the system interaction program.
I interpreted this 1
as a hopeful sign because it indicated a show of interest, initiating at the Commission level, in the state of the program; and it seemed a very real possibility that this timely show of interest from that level could result in a turning point, especially for the methodology demonstration program which was l
lagging at that point.
- d, e
i
. So it can be seen, I believe, that at the time of my involvement and participation in the Shoreham hearing there were still a number of reasons to support the (hopeful) view that the staff's system interaction program, although experiencing some serious difficulty, was still adequate at that point.
b.
De-emphasis on Systems Interaction Program Objective In March 1981, the Systems Interaction Branch (SIB) of the Division of Safety Integration (051) was abolished, and all but two of the nine SIB professionals working on systems interaction were assigned to other licensing-related activities within NRR.
I was one of the two remaining former SIB members who were transferred to the Reliability and Risk Assessment Branch (RRAB) of the Division fo Safety Technology (DST) to try to continue the II.C.3 systems interaction program.
RRAB is the organizational unit within NRR with lead responsibility for PRA-related activities, such as NREP.
The most obvious thing that can be said regarding this development is that, insofar as organizational " stature" and allocation of resources reflect the real importance ascribed and priority assigned to a given project / activity in the minds of!NRC management, this development indicated a significant~
~
decrease in the perceived importance of systems interaction
. issue on their part, and correspondingly in the " effective" p'riority assigned to the program for resolving that issue.
Concerns along these lines were expressed by me and other systems interaction staff to both SIB /DSI and RRAB/ DST management at the time.
And it was apparently also in this same vein that the THI-1 Hearing Board raised questions regarding the motivation for, and possible effects of, this action.15 All were reassured that any concerns in this regard l
were misplaced.
Despite such reassurances and the assumed good intentions underlying them, the effects of that a,ction ultimately proved detrimental, as feared.
Beginning at that point (gradually at first, but more noticeably as months passed) there began to develop in the management of the. systems interaction program at all levels within NRR a noticable lack of emphasis on the completion of the II.C.3 systems interaction program (and resolution of A-17) on the basis and schedule established at the outset of that program.
15TMI-1 hee ~ingTranscriptat 15,615-15.629 l
r
More and more with time, the new organization seemed to lose sight of the fact that both the need and schedule for timely r'esolution of USI A-17 had been established at the outset by a broad consensus, based on the widely-shared judgment that the seriousness of the safety concern involved warranted an expeditious effort to resolve it.
By contrast, at the same time that this apparent decline of emphasis and sense of urgency was occurring with respect to the systems interaction concern, increased visible emphasis was placed by staff management, and even the Commission, on PRA-related programs and activities.
(e.g., quantitative safey goal development).
It is in this respect that it simply must be said, at this point, that what has resulted is an inappropriate imbalance with regard to the importanc~e being placed by RRAB/ DST and NRR management currently on what is essentially " nice" (i.e., PRA-related activities) as compared to what must still b'e regarded, under existing rules and established procedures for reactor licensing, as "necessary" (i.e., programs for resolution of USI A-17).
These changes in attitudes on the part of management towards the importance, urgency, and priority of the system l
interaction concern are a major factor in my judgment l
of the adequacy of the systems interaction program currently, 1
I pa'rticularly with respect to prospects for resolution of USI A-17 I
1 at any reasonable time in the future, without a significant reordering of priorities and program redirection.
(-See Basel.ine Considerations #1, #2, #3, and #5).
The following specific examples are illustrative of the preceding general observations, I believe:
(1) Withholding / Delay of Final Approval for Implementation of Systems Interaction Methodology Demonstration In October 1981, approval was given by DST to a proposal for initiation of the methodology demonstration phase of the i
i II.C.3 program.
In this proposal, approval by NRR was requested regarding final selection of the NT0L pilot plants in which candidate systems interaction methodologies were to be tested.is No action was taken t
l (either approval or denial)-by NRR at that time; and the effort stalled at that point, apparently over concerns that developed in connection with cost-benefit estimates required for the expected review by the Committee for the 2SSee Memo, 10/28/81, Murley to Denton, " Implementation of Systems l
Intepection Interim Guidance".
7
~
l
. Review of Generic Requirements (CRGR) of any NRR approval action on this proposal.
In February 1982, however, in a letter from Mr. Dircks to ACRS (which required concurrence by NRR) 7 it was noted that "...the staff l
proposes to begin soon with reviews of four NT0L plants using two methodologies..." That seemed surely to indicate some movement toward final approval of the proposal to initiate the studies described to the ACRS.
However, more weeks passed with no final action on the request.
Meanwhile, (as also noted in the letter to ACRS), RRAB and DST management began consider,ing various options for combining the systems interaction program with an already envisioned NREP/SEP combined review program.
At this point still, the emphasis was said to be on expediting the resolution of USI A-17, as well as achieving cost-benefit advantages (to help in gaining acceptance / approval from (CRGR), by combining unnecessarily duplicative aspects of the three programs 23See Lette[ dated 2,fiz/ez 2
21/9-2, Dircks to Shewmon, " Systems Interactions".
. done separately).
Apparently the promise seen by NRR in this approach was great enough that NRR approval of the October 1981 DST proposal on initiaiton of the NT0L pilot plant methodology effort was delayed again, while the combined program idea was developed and explorad further.
That process has continued since;is but to date no final approval has been given by NRR for implementation of a_ny methodology demonstration studies under any option. In the process, however, the initially proposed NTOL pilot plant alternative, approved by DST in October 1981 was discarded altogether.
(I first learned that this was official in August 1982; a statement in this regard was inserted into an affidavit that I was preparing to the TMI-1 Appeal Board 19 in response to their request for a report on the status of the II.C.3 System interaction programs).
As a final comment, it is noted pointedly that the notion of expediting the resolution of USI A-17 and achieving cost-benefit advantages by combining the l
program for resolution of USI A-17 with planned PRA-related programs did not work out well in any respect.
I believe the basic error involved was in RRAB, DST and NRR management (i) not taking a more
~
18See, for example, Memo dated 9/16/82, Ernst to Miraglia, " Revised CRGR
~
Letter SEP Phase III/NREP", and Enclosures 1 & 2.
1SSee Affidavit dated 8/6/82, James H. Conran to TMI-1 Appeal Board.
l
, aggressive posture with CRGR in presenting the II.C.3 related program proposal on its own merits, i.e., as a necessary program for timely resolution of a USI, and 1
(ii) not resisting the post-facto imposition of a cost-benefit criterion in a way that delayed excessively the progress of that necessary program.
(See Baseline Considerations #1, #2, #3, #4, and #5).
(2) Systems Interaction Analysis "Just a Part of PRA" Even before being transferred to RRAB, I had begun to explore, in the context of my review of the Program Plan for the Indian Point-3 Systems Interaction Study the so-called systems interaction /PRA " interface", to try to understand better the relationship between the PRA which was already being performed-(during 1980 - 1981) at the l
Indian Point facility and the proposed systems 1
interaction study proposed at Indian Point-3.20 As a I
result of my study of the interface question, I concluded, that the inter-system dependency information developed in a systems interaction analysis is important
.e l
20See Shoreham Hearing Transcript, at p. 7534.
l 1
. in assuring the accuracy of PRA results; to such degree, in fact, that systems interaction analysis must be regarded logically as a prerequisite to PRA.21 (ACRS also made a l
similar observation in January 1982).22 In documenting my l
conclusions in this regard, and in discussing this matter with RRAB and DST management, however, I took great pains to point out even more importantly that systems interaction analysis has inherent value completely aside and apart from PRA; because its results can be used readily and effectively to improve safety (in the context of the current " deterministic" licensing approach), even if PRA is never done.
I objected explicitly to the tend,ency that I saw within the organization to think of system interaction analysis as "just a part of PRA," because that tends to subordinate systems interaction analysis (a "necessary" l
program under existing rules and established procedures
, for reactor licensing, for resolution of USI A-17) to PRA-related programs and objectives (which do not have l
l 21See " Meeting Summary and Status Report" for July 24, 1981..." by l
l J. H.,Conran, at p. 3-4.
22ACRS Letter, dated 1/8/82, " Systems Interaction" l
9 m
1 that "necessary" aspect to them in the established system).
The culmination of this tendency manifested its'eff, I believe, in the abortive efforts (described in 4.b (i) above) to combir.e the II.C.3 systems interaction program methodology demonstration studies with NREP, without regard to the impact on the schedule for timely l
resolution of USI A-17. (See Baseline Considerations #1,
- 2, and #4)
(3) Use of Unreviewed Risk-Based Decision Criterion Another manifestation of the "way of thinking" addressed in 4.b(2) above, is the informal, ad hoc use of an unreviewed risk-based decision cr,iterion in deciding important aspects of the USI A-17 program performance.
It appears that this practice figured, at least partly, in the decision to withhold final approval on implementation of the methodology demonstration phase of the II.C.3 program.
A partial basis cited recently for withholding final approval in that instance was that the systems interaction staff had not shown that the " risk benefit" to be gained by doing systems interaction analyses would be significant enough to justify the effort and expense of trying. Such reasoning amounts to overturning, without due process, a major safety decision I
i l
. made previously, on the basis of widely-share qualitative judgments, by post-facto application of an unestablished, quantitative risk-based criterion, (See Baseline Consideration #5).
It is questionable also on the basis of the following considerations:
o Inadequate treatment of common-cause failure is an acknowledged major source of uncertainty in quantitative estimates of risk based on current probabilistic risk analysis methods.
Systems interaction study is to a very great extent o
the pursuit of efficient methods to treat comprehensively and effectively common-cause or dependent failure.
o The use, therefore, of quantitative risk estimates based (necessarily) on current risk analysis methods (flawed as they are by uncertainties arising from inadequate treatment of common-cause or dependent i
failure), as a basis for deciding to delay or halt system interaction studies that could eliminate or reduce significantly such uncertainties, seems at, best self-defeating, and at worst questionable logically.
l l
l Said another way, USI A-17 must be resolved before either (i) the current deterministic licensing basis and process, or (ii) PRA and quantitative safety goals, can be applied with the improved confidence sought in reactor licensing today (because they are both " flawed" by the same source of uncertainty, i.e. common-cause or dependent failure.
So we should get on with it. What we need now as before is an adequate program to address this
" joint" problem expeditiously and effectively.
I c.
Shoreham Specific Considerations It should be said that any concern regarding the adequacy of the staff's generic systems interaction program has added significance in the Shoreham case.
It must be recalled that LILC0 has taken the position that the PRA that has been performed at the Shoreham facility has, in effect, resolved USI A-17.
It seems fair to conclude, therefore, that if the staff does not effectively pursue timely resolution of USI A-17 through its II.C.3 systems interaction program, the concern l
involved is not likely to be pursued further by positive dedicated programs by LILCO.
There is, further, another possible synergistic-type consideration arising from LILCO's position on the safety o
m.
. classification and safety classification terminology matter at issue between staff and LILCO (addressed in following sections of this affidavit).
It is now clear that LILCO truly does not understand what is required minimally for safety, in the same way the staff (and the regulations) construe that phase.
LILC0's position in that matter makes it less clear, then, whether systems interactions concerns have been treated adequately at Shoreham.
For example, it may be that the difference between the positions of LILC0 and the staff, regarding the claim that the Shoreham PRA resolves satisfactorily (for Shoreham) the systems interaction concern, derives from this fundamental difference i.n understanding of what is reouired minimally for safety (i.e.', "How little, actually, is enough?") rather than from theoretical, matters-of-degree type arguments regarding the l
question "How far beyond-what-is-required is enough?"
(as seemed to be suggested in the discussions at the hearing regarding dependency analysis and walkdowns in the Shoreham PRA)23 This question wculd seem to bear heavily on the determination of whether LILCO has satisfied what is required 1
under North Anna, regarding USI A-17, sspecially in this situation where the staff's " contribution" in that regard is called into question.
23See Shoreham hearing transcript.at p,6653, p.7500, p.7634 and p.7847 l
. SAFETY CLASSIFICATION TOPIC 6.
General Statement of Amendment to Testimony At the time of my participation in the Shoreham hearing, it was not clear to me, as it is now,( with more time to consider thoroughly all of the testimony of Applicant's witnesses, and its full implications) that LILC0 truly does not understand what is required minimally for safety by NRC under the regulations (i.e., what is considered necessary and sufficient to provide reasonable assurance of no undue risk to the health and safety of the public in the operation of a facility).
Coming to the discussions of these matters in the hearing with the background described extensively lin my testimony, I was predisposed to think of the defect in Applicant's stated position regarding the safety classification term "Important to Safety" as simply a " language problem".
That is to say, at bottom, I believed that, although we subscribed to a different set of words to describe them, both the staff and Applicant understood in basically the same way the fundamental i
safety concepts underlying the terms "Important to Safety" and
" Safety-Related" (as the staff apply those terms). Considerable effort was made by counsels for the staff and Applicant, while Contention 78 was being argued, to work out what were perceived as resolvable language differinces (as contrasted to fundmental lack of mutual understanding I
. regarding what is required minimally for safety).
I participated in those efforts, and upon several occasions responded to cross-examination by counsel for Applicant in that context and spirit, suggesting that we may have achieved near-meeting of the minds by the end of argument of Contention 78.
I recognize now, that we are, in fact, not near a meeting of the minds on the very important fundamental safety concept at root in this matter.
As a general statement of amendment, therefore regarding my testimony in that respect, it should be said that, to the extent that the Board or Parties might rely on such statements regarding " meeting of the minds" in my hearing testimony to determine outcome on Contention 78, they should not do so.
7.
Basis for Amendment of Testimony The further understanding that I have developed in this regard is based on the following:
a.
opportunity to consider longer and review more thoroughly the testimony of Applicant's witnesses, b.
involvement in the review of recent proposals by LILC0 to the staff for resolving differences left outstanding at the end of argument of the safety classification and safety classification terminology issue in the hearing, particularly regarding non-safety Q. A.
c.
synergistic consideration of a) and b).
In thaCcontext I was struck by how little movement could be seen in LILCO's six month old differences with the staff on these matters.
- With a license at stake, and that long to think a' bout and work on it, it seemed remarkable to me that there would not have been more substantive effort on LILCO's part to develop or promote improved mutual understanding on what I had thought were only language differences. The staff, for example, has continued'the effort to develop a listing of "Important to Safety" structures, systems and components; and, recently, a draft report containing preliminary results of that effort has beccme available.
In pondering these questions further, I carefully reviewed the 9
testimony of Applicant's witnesses again (in particular, testimony at p. 5425-5449 of the Shoreham hearing transcript), in which staff counsel sought to establish by cross examination equivalency between staff's and Applicant's understanding of the fundamental safety-concepts involved, even though the language applied was different.
In that. review, I finally recognized that,in responding to counsel's questions, Applicant's witnesses invariably couched their responses in a way that acknowledged some safety relevance to the specific examples provided by counsel of things "Important to Safety, but not Safety-Related", but carefully avoided acknowledgement or recognition that such items had enough safety relevance or importance to number them among that category of things required l
j minimally for safety by the regulations.
1 l
l
. 8.
Implications of Amendment to Testimony Having come to this realization and fuller understanding of these matters, I beli. eve the full implications of this can be summarized as
- follows
The concerns that occupied me chiefly at the time of the hearing a.
focused most heavily on the implications of language differences, (i) with respect to impact on staff's ability to rely on Applicant's affidavits in the audit review context, thus complicating significantly (if not prohibitively) staff's ability to come to a finding of " reasonable assurance..." through the usual, established audit review process, and, (ii) with respect to possible impact on staff's ability to obtain information required for its regulatory function during operation of Shoreham, as contemplated under Part 21 (because the Applicant might not realize that he had to report information regarding failure of some component which he did not " call" Important to Safety, but staff did).
b.
My concern at this point is more serious, however.
I no longer believe that our differences involve only a language problem l
to be sorted out mechanically.
There now appears to be a substantive defect in Applicant"s true understanding of what is really required minimally to protect public health and safety.
A language problem could be remedied simply by imposition of a definition; (or possibly even by a much more l
l l
l complicated alternative scheme proposed by LILCO). But understanding of the fundamental safety concepts underlying the usage 'of the term "Important to Safety" in the regulations cannot be imposed, (as for example by a condition g license).
Understanding must be developed, and demonstrated, I
believe.
Therefore, I believe that a condition for (i.e., prerequisite to) a license in this case should be developr:ent by LILC0 of a listing of "Important to Safety" structures, systems and corrponents for Shoreham, as a vehicle and means for developing and demonstrating the requisite understanding of what is required minimally for safety in the operation of Shoreham.
In the construction and design phase, the very detailed SRP and Regulatory Guide information can perhaps provide a " safety net" or " backstop", to mitigate serious misunderstandings regarding staff's (and the regulations') safety classification terms.
However, in the operation of a facility there is little that would act effectively in a similar way (i.e., as a backstop), either in the regulations, or in staff's procedures and activities.
There must be understanding of what is necessary minimally for safety as a prerequisite for safe operation.
And because Applicant's understanding in that re' gard is so clearly called into question, by their own
testimony, I believe there should be demonstration of reir.edy before licensing.
The staff's preliminary (draft) listing of e
structures, system and components "Impo~rtant to Safety" (referred to above) could be used as th~e starting point of an effort to do that, and could enable completion of such effort on a basis that would not have to interfere with licensing schedule.
9 e
e e-#
O O
m
E:.':ERPT FR0f1 STATEMEfiT OF MAf AGEMEf;T VIEWS TO SHOREHfW BOARD, 2/22/83
~ C.
Need for Additional Testimony Mr. Conran's February 9,1983 affidavit, if received in evidence, will significantly modify evidence proffered by the Staff in support of its position in tihe proceeding.
Fairness requires that the Staff be permitted the opportunity to supplement the record directly affected by Mr. Conran's modification of his position. The Staff is prepared to offer additional testimony od each of the two subjects addressed by Mr. Conran's affidavit. The receipt in evidence of this additional testimony is in the interest of a full and fair hearing record upon which a decision can be made. The Staff proposes to offer this testimony by affidavit.
1.
Systems interaction (A-17)
The Staff is preparing additional testimony. on the sub.iects of the status and progress of the Staff's program in support of unresolved safety issue A-17 and the basis for the Staff's position that Shoreham can be operated safely despite the pendency of unresolved safety issue A-17.
That testimony will be sponsored by Ashok C. Thadani, Branch Chief of the Reliability and Risk Assessment Branch, and Franklin D.
Coffman, Section Leader of the Systems. Interaction Section within the Reliability and Risk Assessment 83 ranch.
The principal points of that testimony are expected to be as follows:
1.
the Staff's~ current licensing requirements provide reasonable assurance of no undue risk to public health and safety from
' potential adverse systems interactions; 2.
unresolved safety issue A-17 is confirmatory in nature; 3.
the Staff's program on A-17 is progressing satisfactorily toward resolution; 4
no plant-specific systems i*nte'raction analyses are or should tie required until completion of the Staff's program determines whether they are necessary and justified.
E!1 CLOSURE 2
[ d., g -
't.pptet,R REGULt, TORY Co!.it.i!sSION
((
c g
gig;-
g
.['g_j, g wt-semen. c. c. :ms QQf.i' f U..'.R 0 E 1979 r
'O y
MEMbRANDUMFOR:
Conrnissioner Bradford em-s THRU:
Roger H. Moore, Chief, Applied Statistics Branch, MPA Norman M. Haller, Director, MPA
=
Lee V. Gossick, Executive Director for Operations
.FROM:
David Rubinstein', Applied Statistics Branch, MPA SUSJECT:
.PROSABILITIES THAT THE NEXT MAJOR ACCIDENT OCCURS k'ITHIN PRESCRIBED INTERVALS
~
Apparently yo'ur request of January 31, 1979, to Saul Levine and John Austin for."the correct way to state the statistical significance of 400. reactor years of operation without inajor accident" has
==
received fairly widespread attention in the. Commission.
I believe r-most of the concerned persons addressed this problem in terms of upper confidence limits for the ra.te of a major accident or from the'
==
point of view of hypothesis testing. An alternative way of addressing this pr:blem is through a prediction interval. As used here the ~
prediction interval focuses on the' next major acci. dent.
It puts an upper b:und on the probability that the next major accident will occur -
GG withir. 'a specified number of reactor years.
Alternatively, it will
-==
i cive a icwer bound of the probability that the next major accident will occur after a specified number of reactor years.
On the basis
.Z
' of some assumptions discussed below we may say for example:
{.
'a)
The probability is less than.5 that the next (i.e., the first)
E55-i r.ajor accident occurs within the next 400 reactor years.
((
=..E b)
The probability is less than. 05 that the next major accident y.
is occurs in the next 21 reactor years.
5
'hM c). The probabil'ity is larger than.5 that the next major accident will occur after the next 400 reactor years.
This-is equivalent
=
to :tatement (a).
5'
~
E=
The col.umn hdrded by. I in Table 1 and the graph with the triangles in y
Figure 1 give moie detailed results of the prediction interval method.
g
.The results are-given for both reactor years and time expressed in g
calendar years;'a calendar year is taken equivalent to 70 reactor years.
-~
g At present there are approximately 70 cc:maercial operating reactors.
j.3
!5.
IE:
p'E
.~-
=
f ENCLOSURE 3 h'
~
e, j y
h
~ Cc m issioner Eracferd 1.'.M 0 S 1979 Ilg a
E..
The results suggest perhaps unwarranted pessimism because of M
EE a) co.nservative features in the analysis
.M b) large statistical variability of times to first (or next) major h
Et accident
~
s c) lack of engineering considerations.
h N
The prediction intervals are derived under the assumptions that major E
accidents occur as a Poisson process; i.e., at a constant rate and K
independently.
These assumptions provide perhaps a reasonable sii approximation; however, this is not readily demonstrated. The pre-R-
ciction interval as used here does have one conservative feature in '
il that it " equates" the time to the first major accident with the time 5
cumulated to date without major failure. My gut feeling is that E
this conservatism is likely to outweigh possible non-conservatisms K
in the assumptions.
[I also see the possibility of obtaining mora j'
assurance based on somewhat plausible speculation about such matters r_
.E as early high failure rates (often called infant mortalities) or E
relative occurrence rates of subclasses of accidents. Careful and l'
E detailed examination of existing failure data might provide support E
~
for such speculation.]
ifZ On the basis of the simplistic assumption of a Poisson process one if can readily compute the probability distribution of the time to the P
nex.t major accident for any specified value of the occurrence rate of h
major accidents.
[In contrast the method.of prediction intervals E
does no't require knowledge or postulation of the value of occurrence k
rates to make' probability or confidence statements about the waiting F
time to the first occurrence.] Table 1 and figure 1 also provide E
probabilities relating to the waiting times to the next major F
accident for the major accident rates listed below:
j.;
A)
One per 170 reactor years;'this corresponds to the 90% upper.
confidence limit based on 400 reactor years with no major, b
accident.
p B)
One per 580 reactor years; this corresponds to the 50% upper confidence limit based on 400 reactor years with no major i
accident.
y s
E C)
One per 4,000 reactor years; this is an approximate amalgam of E
UASH-1400 and other " upper bounds", and the 50% upper confidence
[
limit based on about 2,.800 reactor years without major accident.
Some persons make claims of from 2,500 to 3,000 relevant (in some I
sense) reactor years free from major accidents.
e i>
l
q.
x.
r=
!E 091979
((p
- r-is'si:r.er Bradford -
is
=.
En
=.
E D)
One per 1,000,000 reactor years; this has been included here M
as some sort of holy grail.
51 15=
In line with your request, I took a very pragmatic' approach and R
deliberately played down the theoretical aspects.
I shall be happy
!EE to try to clarify them if you so desire; in particular, the precise M
interpretation of prediction intervals.
I am appending a brief E'
mathematical derivation in case mathematically inclined persons '
M will read this memo.
R EE One can duplicate similar computations for the time to the second E
major failure, third major failure, etc.
To some persons the EE pictur.e for later major accidents m.ight appear somewhat.less alarm-5 ing.
Again if you have interest in such computations, the Applied EE Statistics Branch can provide these.
M iEE EE CSdN?NMbN i
, ~
David Rubinstein~
E Applied Statistics Branch
/*
EE Division of Technical Support M
Program Analysis M
Office of Management and
- g.
cc: -Chairr.an Hendrie it Cc=issioner Gilinsky Mb Cc=issioner Kennedy s;
Co=issioner Ahearne if Lee R. Abramson
=
Dan Lurie j.s Susan B. Young
- )
Saul Levine E
John Austin E
Ei
=.
E E
p gi s
g;
- =
[aI h
j;.,
i+ w.
!!.N
=.
.te LEGEND TO TABLE 1 ce
'hes Probabilities that the Next Major Accident Occurs Within Prescribed K
Intervals
=g.
. t is time expressed in either reactor years or calendar years.
H h:as-P(Y < t) is the probability that the next major. accident occurs at or before time t.
g:
_4. :.
Column I gives upper bounds for P(Y 1 t) a's obtained by the prediction interval method on the basis of 400 reactor years free from major EEE accidents.
=
=f f
1 ) for given occurrence Columns A, B, C, and D give exact values for P(Y t
rates of major accidents as explained on pages 2 and 3.
g
=-
e is the reciprocal of the failure rates used in columns A, B, C, and D.
15
.g It is also the mean time between major accidents.
c M
=.
.=
LEGEND TO FIGURE 1 E=
=.b
==
Pr:babilities that the Next Major Accident Occurs Within Prescribed
[E-intervais g
The tim'e scale in reactor years is given on the bottom and in calendar If..
years on top.
These scales are locarithmic and scientific riotation is Ei used for the larce numbers; thus 5(4) is 5 x 10 = 50,000.
E i=r The craphs are plots of P(Y 1 t) against the P scale on the right.
E
. The Q scale gives the complementary probability 1 - P = P(Y > t).
E Both scales express probabilities in percent;'neither scale is linear.
((
The graph passino throuch the triangles. (A) refers to the prediction i
inte rval.
The other graphs are:
+ for case A(e = 170); X for case
. E(5 = 5S0); O for case C(s = 4,000); and O for case D(e = 1,000,000).
f s#
t i
s.
b
=
e t
5
..._,9
TX5^G9.
~.
PROEABILITIES THAT THE l' EXT P.UOR ACCIDEliT OCCURS WITHIli PRESCRIBED If?TERVALS t
t P(Y < t)
~
EIACTOE CALZ5D12 I
A 3-C D
!EAE5
.YIAES e
170 560 4000 1000000
_______________________c 1
01
'O.002 0.006_
0.002
--0.000 0.000 2.
. 03 0.005 0.012 0.003 0.000 0.000
~
5.
-. 07
- 0. 012 0.029 0.009 0.001 0.000 10.
.14 0.024 0.057
'd.017 0.002 0.000 20.
.29 0.048 0.111 0.034 0.005 0.000 50.
. 71
- 0. 111 0.255 0.083 0.012 0.000
' 100.
1.4 0.200 0.445 0.159 0.025 0.000 200.
- 2. 9 -
0.333 0.692 0.293 0.049 0.000
~500.
7.1
- 0. 556 0.947 0.5.80 0.118 0.000 1000.
14.
0.714 0.997 0.823 0.221 0.001 2000.
29.
0.833 1.000. 0.969 0.393 C. 0.002
.5000 71 0.926 1.000
'1.000 0.713,, 0.005 10000.
140.
0.962 1.00'O 1.000 0.918
. 0.010 20000 280 0 930 1.000 1.000 0.993 0.020
'5 0000.
710.
0.992 1.000 1.000 1.000 0.04-j 100000.
1400.
0.956 1.000 1.000 1.000
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tuthema-ical Derivation a
i.;.
The prediction interval based on accident free observation time f.
E resembles Laplace's Law of Succession.
However, the following--
g derivation is ir. dependent of the Law of Succession.
I E
E Assum;: tion:
Major accidents occur as Poisson sequence with parameter l1.
h E
=_.
is an ar'bitrary exposure time to risk of major 5
Definitions:
1) to m
accidents.
p E
2)
X()) is the time to the first major accident.
Note R
- E.
that X()) may be smaller or larger than t.
E o
g, :
=
I
[
3)
X* = min [t, X(3)].
o 3
4)
Y = X(t ) is the waiting time to the next major o
accident starting from t.
o N.
For k > 0, P[Y s kX*] 1 1 k
i*
l Theorem:
..E i'
Proof:
From the assumption of a~ Poisson process it follows ji
=s.
that Y is independent of X*.
For positive k, the
!?
U.
U:'.
probability D
P[YskX*]=f"P[X*>y/k]'lexp(-Ay)dy 1f"P[U_>y/k]Aexp(-Ay)dy,
~.
where U is a random variable exponentially. distributed with parameter A.
NotethatX*<X()).
Al so,
~
f P[U > y/k] Aexp(- Ay)dy = P[.U>Y/k]=P[Y/U 1].
k
l
~..:
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1.<
s ::
B-1:r
,~
2.
17.E
- a
=:
Since Y/U his an F distribution with 2 ind 2 degrees M
m*
of freedom and the density of F is f(t) = (1 + t)-2
-.5 2.2 er.
it follows that
=
=,
=E e
$*.~w P[Y < kX*] < 1 K + 1 (1)
P
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