ML20198S040
| ML20198S040 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1986 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Pollard R, Weiss E UNION OF CONCERNED SCIENTISTS |
| Shared Package | |
| ML20198S043 | List: |
| References | |
| IEB-79-27, NUDOCS 8606100304 | |
| Download: ML20198S040 (3) | |
Text
D)k 8[ pun d
)o UNITED STATES NUCLEAR REGULATORY COMMISSION o
h WASHINGTON, D. C. 20555 May 15, 1986 CHAIRMAN Robert D.
Pollard Ellyn R. Weiss Union of Concerned Scientists 1616 P Street, N.W., S.310 Washington, D.
C.
20036
Dear Mr. Pollard and Ms. Weiss:
In your letter of February 28, 1986 you provided a report detailing your views on the safety of Babcock and Wilcox (B&W) reactors.
In a letter dated March 25, 1986, from Victor Stello, Jr., Executive Director for Operations, he indicated that the staff intended to consider the issues raised in your letter as part of the reexamination of the basic design requirements for B&W reactors.
Furthermore, as stated in Mr. Stello's response, your report did not provide any information that would cause NRC to alter its conclusion that continued operation of the B&W plants, during the time it takes to complete our reexamination, does not pose an undue risk to the public health and safety.
Your letter of April 2,
1986 questions the staff's conclusions that the continued operation of B&W plants does not pose an undue risk to the public health and safety.
Based on the staff's review of the Incident Investigation Team reports of the Davis-Besse and Rancho Seco events, NUREG-1154 and NUREG-1195, respectively, and discussions with the B&W Owner's Group, it was concluded that while there are generic implications from these events many of the problems which occurred were plant specific.
However, the staff is concerned about the complexity of the post-trip response exhibited by these events.
As a result, a reassessment of the B&W plants has been initiated in order to identify whether potential plant modifications are warranted to improve plant response to anticipated operational transients.
While the recent events at B&W plants have reinforced staff concerns regarding the sensitivity of B&W plants to operational transients, continued operation of the B&W plants, while this reexamination is performed, does not pose an undue risk to the public health and safety.
As noted above, the issues you raised will be considered as part of the reexamination of B&W reactors.
8606100304 e60415 PDR COMMS NRCC CORRESPONDENCE PDR
. p With respect to your comments on IE Bulletin 19-27, the staff has been directed to assess the need to reevaluate the actions taken by the staff and by the licensees in response to the findings, conclusions and-recommendations of a number of documents and reports including IE Bulletin 79-27.
Commissioner Asselstine has the following comment:
The NRC has been well aware of the vulnerabilities of B&W plants to failures in the Integrated Control System (ICS) and Non-Nuclear Instrumentation (NNI) for seven years or more.
In my view, the NRC has not taken effective action to correct these problems.
I believe that view is shared by the Incident Investigative Team (IIT) that conducted a review of the December 26, 1985 accident at Rancho Seco.
The IIT report was highly critical of the NRC staff's failure to heed the lessons of numerous 09erating events that demonstrated the safety vulnerabilities in this aspect of the B&W plant design.
Based upon the team's report and my own concern regarding the staff's past regulation of the B&W plants, I urged the Commission to form a special review s
group, including experts from outside the NRC, to conduct a thorough review of the safety vulnerabilities in the B&W design and the adequacy of past NRC efforts to ensure that the B&W plants meet acceptable safety standards.
This was the approach taken by the Commission in the case of the June 3, 1985 accident at the Davis-Besse plant on the basis of less compelling evidence of failures in the staff's past performance.
I believe that such a review is particularly appropriate given the NRC staff's expressed view following the Davis-Besse accident that there was no need for a generic review of the safety of the B&W design.
Unfortunately, the Commission rejected my proposal.
As a result, any review of the adequacy of,the staff's performance will be left to the staff itself.
Chairman Palladino has the following comment:
The IIT fact finding effort provided plant specific Rancho Seco information as well as generic B&W design information.
Based on the generic information and discussion with the B&W Owners' Group, the decision was made to further investigate the B&W design.
I believe the additional review of adequacy of the B&W design is appropriate and is aimed at possible further improvements in a design already substantially modified since the TMI accident.
The IIT fact finding effort was an independent review of both Rancho Seco and the staff efforts regarding Rancho Seco.
I believe that another review of Rancho Seco by experts from outside the agency would be redundant to the IIT review already accomplished.
As such, it is unnecessary and would be a misuse of resources.
In fact, Commissioner Asselstine commented at the Commission IIT February 25, 1986
O,
meeting that he "had reservations about the IIT program, quite frankly, to start with, and the kind of candor and forthrightness in this report gives me confidence that the program is-really working the way we all wanted it to work, and I am very pleased with that aspect of it."
Commissioner Asselstine also indicated that, "I found this report to be hard-hitting, forthright, candid and direct."
I was also pleased with the IIT report.
Regarding the Davis-Besse Ad Hoc Group Report itself, this independent body considered it essential to compare the practices and procedures for the Davis-Besse IIT incident investigation with those of the subsequent San Onofre and Rancho Seco IIT investigations.
This report recommended several improvements to the IIT investigatory effort, and concluded, among other things, that:
(1) the mandate for IIT's is adeouate for conducting NRC incident investigations, and (2) the IIT members possessed adequate technical expertise to comply with the requirements necessary to perform their investigative task.
I agree with these conclusions, and based on this and the IIT report itself, believe that further independent investigations are unwarranted.
Sincerely, fA Y,
(k/5kA Nunzio V.
PaF a ino i
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