ML20154J870
| ML20154J870 | |
| Person / Time | |
|---|---|
| Issue date: | 08/22/1985 |
| From: | Basdekas D NRC |
| To: | Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML20151L097 | List: |
| References | |
| REF-GTECI-A-49, REF-GTECI-RV, TASK-A-49, TASK-OR NUDOCS 8603110092 | |
| Download: ML20154J870 (2) | |
Text
r Ref: E00-724 Osetc6 UNITED ST ATES g WUCLE AR REGULATORY COMMISSION ,
i WASHINGTON. D. c. 20555 I g , - P 0.
1 # Mink,be g ,/ August 22, 1985 Denton GC ngham
,,y, ad OCA The Honorable Morris K. Udall Chairman, Subcomittee on Energy and the Environment Committee on Interior and insular Affairs United States House of Representatives Washington, D. C. 20515
Dear Mr. Chairman:
On July 18, 1985, The Nuclear Regulatory Commission responded to your letter of June 13, 1985, in which you recommended the establishment of an ad hoc panel of experts to assess the FTS hasard and the adequacy of the Comission's efforts to reduce it to an acceptable level. The Commission's position is that " '
because of the l' wide-ranging and in-depth" reviews already performed it is not necessary to establish such a panel. I respectfully disagree with the Comis-sion's position because its bases and reasoning are fiswed in substantial ways.
The NRC staff and others within the agency, including the ACRS, have been highly preferential in considering views of technical experts. The views of people from the nuclear industry received prompt attention and virtual approval quite consistently, while expert views less favorable to the nuclear industry's position were generally received in a cursory fashion and then dismissed. Hence, the mere fact that the Commission and its staff were presented with technical views differing from their .own and those of the nuclear industry and contractors is not a sufficient condition to imply, as the Comission's letter does, that these differing views have been properly considered. They have not been. -
on March 19, 1985, I submitted to you information detailing my reasons for considering the Commission's treatment of this issue to be flawed and inade- .
quate. Updated highlights of these reasons are given below:
- 1. Relevant operational experience was neglected by the NRC staff, and some i of what was considered was unjustifiably altered in non-conservative ways.
- 2. Opinions of technical experts in materials engineering, fracture mechanics, and industrial engineering outside the nuclear community were brushed aside.
j 3. Undue reliance was placed by the NRC on analyses performed by the nuclear industry. NRC sponsored studies on the safety implications of control systems were severely limited and their results given the short shrift or ignored. Those expressing technical concerns with a potential challenge
} to existing positions faced intimidation and reprisals.
. 4. " Improved" results submitted to the NRC by licensees on the phemical compos-ition of vessel weldsent materials are not supported by their own data.
l
~ B603110092 B50906 7 ;
i MEETING 001 t
l The Honorable Morris K. Udall August 22, 1985
- 5. The resolution of generic issues has been delegated to the of fice respon-sible for licensing and regulation. This de facto conflict of interest and the direct industry access to the internal NRC review of generic requirements, in conjuction with the improper use of probabilistic and cost-benefit analyses, have been dangerously detrimental to saf ety.
I agree with the Commission that the PTS hazard requires intensive, multidis-ciplinary studies. I believe, however, that these studies should be thorough and competent, open and unbiased. Clearly, the NRC studies do not meet these i basic criteria. Furthermore, experts in one discipline must cross over into
other disciplines interacting with theirs to ensure that there are no gaps, errors, or inconsistencies. I have attempted to do this, but with limited success and a lot of difficulty. Such initiatives are discouraged at the NRC.
I thoroughly agree with your position that in view of the catastrophic conse-quences of a reactor pressure vessel failure, every practical step should be
' taken to avoid it. Therefore, the establishment of an ad hoc panel of experts to independently assess PTS is most prudent. The ad hoc panel approach has served us reasonably well in the past, i.e. in the WASH-1400 and source term reviews. It will help the Commission do what is needed for PTS and plant dynamics and control without waiting for the next meltdown and its expensive lessons. ,
The recent event at the Davis-Besse plant should bring a sobering measure of f I
pragmatism to all who are concerned with nuclear safety. In a June 27, 1985, memorandtsn to the Executive Director for Operations Mr. Denton, Director, Of fice of Nuclear Reactor Regulation, states:
"I believe that the recent Davis-Besse event illustrates that, in the
! real world, system and component reliabilities can degrade below those we and the industry routinely assume in estimating core melt frequencies.
Our regulatory process should require margins against such degradation i and also reflect the uncertainties in our PRA estimates." ,
I agree with Mr. Denton's general assessment of the realities of nuclear
' safety and its regulation, and I applaud his frankness. However, if history and the institutional character of the nuclear regulatory program may serve as guides, I am concerned that this sensitivity to reality, which also amarged af ter the THI accident, may dissipate again as soon as the " cloud" of Davis-Besse " blows over". There are indications that this may stready be in progress.
t Commissioner Asselstine's comments contained in the Cossaission's response
)
reflect a pragmatic appreciation of important probisms on hand, a r.d I trust that your continued interest in this matter will convince all members of the Consnissica to accept your recounsendation.
This letter is written under the provisions of 10 CFR Part 0.735-55, Annex A and the Civil Service Reform Act of 1978.
i Sincerely, wM. MM Demetrios L. Basdekas l Sr. Electrical Engineer s
t cct Chairman Palladino W. J. Dircks, EDO / ~
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