ML20198G284

Comments on NRC Proposal for Investigating Significant Incidents at Operating Nuclear Power Plants,Per ACRS 307th Meeting on 851107-09.SECY-85-208, Incident Investigation Program, Primary Document Discussed Re 850609 Event

ML20198G284
Person / Time
Site:	Davis Besse
Issue date:	11/14/1985
From:	Ward D Advisory Committee on Reactor Safeguards
To:	Palladino N NRC COMMISSION (OCM)
Shared Package
ML20137P218	List: ML20198G284 ML20210B220
References
NUDOCS 8511250472
Download: ML20198G284 (2)

Text

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. 8" o NUCLEAR REGULATORY COMMISSION

$ ,E ADVISORY COMMITTEE ON REACTOR SAFEGUARDS S wassmoron. o. c. zosse f , ,

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November 14, 1985 Honorable Nunzio J. Palladino Chaiman U. S. Nuclear Regulatory Comission Washington, D. C. 20555

SUBJECT:

ACRS COMMENTS ON THE NRC INCIDENT INVESTIGATION PROGRAM During its 307th meeting, November 7-9, 1985, the Advisory Comittee on Reactor Safeguards discussed the NRC Staff proposal for investigating significant incidents at operating nuclear power plants. The primary document reviewed was SECY-85-208, " Incident Investigation Program,"

dated June 10, 1985. This matter was also discussed during a meeting of the ACRS Subcommittee on Aegulatory Policies and Practices on November 1, 1985. We also note that SECY-85-208 was approved.by the Comission as stated in a memorandum from S. J. Chilk, Secretary, to W. J. Dircks, EDO, dated October 16, 1985.

Related to the above, we note that the June 9,1985 total loss of feed-water event at the Davis-Besse Nuclear Plant was investigated using the process described in SECY-85-208. During our review, we discussed this process, including the report of the Incident Investigation Team (IIT)

(NUREG-1154, " Loss of Main and Auxiliary Feedwater Event at the Davis-Besse Plant on June 9, 1985," dated July 1985). We also had the benefit of reviewing the August 5, 1985 EDO letter which approves NUREG-Il54 and outlines forty-one corrective actions related to the Davis-Besse event which were tasked to various NRC offices.

TheC. omittee, in its July 17, 1985 letter to you, stated that it awaited with interest the result of the experimental approach being tried in the investigation of the June 9,1985 Davis-Besse event, pending a decision on the recomendations in the Brookhaven Report (NUREG/CR-4152), recom-mendations the Committee endorsed in its letter of March 13, 1985. In the interim the Comission approved SECY-85-208, thereby rejecting the Brookhaven recomendation for the fomation of an independent office.

The questions have now turned to the means of implementing on a more per-manent basis the procedures which were ad hoc in the case of Davis-Besse.

The Office for Analysis and Evaluation of Operational Data has been tasked with draf ting such a set of procedures, and their present status was discussed in our Subcomittee meeting on November 1,1985. We trans-mit herewith some coments, though there may be others as the work prog-resses.

Our principal concern is that the degree of coherence that was achieved through the establishment of the Davis-Besse IIT (which the ACRS com-mended in its letter of July 17,1985) seems to have been dissipated in wit 24f47%

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w November 14, 1985 Honorable Nun 7to J. Palladino the follow-up actions. Forty-one action items have been identified in the [[letter::IA-85-445, Responds to FOIA Request for Vol III of Evaluation of Transient Behavior & Small RCS Breaks in 177 Fuel Assembly Plant, Re Facility.Document Available in PDR for Insp|August 5,1985 letter]] from the EDO to the Office Directors and the Region III Administrator, and assigned to the various offices, with no evidence of an intent to do anything later on an integrated basis. We believe that, as a minimum, there ought to be a later statement by the EDO or the Commission, after the additional information collection set into motion by the investigation has borne fruit. This statement should officially validate or revise the necessarily preliminary assessment of

" root cause" provided by the IIT. It could be in the fom of a supple-mentary report or whatever -- the fom is not the issue. The issue is whether the NRC reverts to its balkanized fomat the moment the IIT is disbanded. We believe that coherence should persist somewhat longer.

On November 1, 1985, you approved an additional review of the. Davis-Besse  !

evaluations and actions. It is not clear to us whether this additional review is meant to be a permanent feature of such investigations, or is limited to the Davis-Besse case. We therefore defer comment.

As a separate item, we take exception to the statement in SECV-85-208 that the procedures thereby adopted " incorporate the intent of the coments and recomendations made by . . . ACRS . . . ." This statement is incorrect; we reconnended a different course, which you rejected when you approved SECY-85-208.

There is one important point we wish to highlight here. While the inev-itable conflict between the requirements of independo.ce and expertise for members of an IIT has been recognized in SFrv.or.208, we feel that the guidance therein is incomplete. As procedures are developed by the NRC Staff, the Connission should provide more specific guidance as to the relative weights to be assigned these two adnitted but competing virtues.

This is, in a sense, the central problem the Comission must now face, having opted for incident investigation by its own Staff. This is the right time to face it. ,

Since we hope to be kept infomed, we will defer less pressing coments ,

to a later time. l Sincerely, ,

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%20.aQ David A. Ward l

Chaiman i i

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