ML20209B399

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Informs Commission of NRC Views of & Actions in Response to Recommendations in Nas Rept, Revitalizing Nuclear Safety Research
ML20209B399
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Issue date: 02/24/1987
From: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
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ML20209A941 List:
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TASK-PII, TASK-SE SECY-87-053, SECY-87-53, NUDOCS 8704280427
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POLICY ISSUE February 24, 1987 (InfOrmatiOn) SECY-87-53 For: The Comissioners Fran: Victor Stello, Jr.

  • Executive Director for Operations

Subject:

STAFF REVIEW 0F NAS REPORT " REVITALIZING NUCLEAR SAFETY RESE.RCH"

Purpose:

To inform the Comission of the staff's views of and actions in response to the recomendations made in the NAS report,

" Revitalizing Nuclear Safety Research."

Sumary: In most cases, the staff is in ' basic agreement with the -

recomendations made by the NAS Comittee and is in the process of implementing or has implemented the changes that were recomended.

The staff views the report as a welcome endorsement of a vital, '

stably funded research program. Some of the recomendations pertain to matters beyond the staff's purview and hence are discussed for the record only. Disagreeinents in whole or in part are with the recomendation to separate standards and research and, to a lesser extent, with the recomendation for independent topical review groups, since a number of such groups have existed for several years.

Background:

On February 25,19f>5, Dr. D. F. Ross, Jr., Deputy Director of the Office of Nuclear Regulatory Research, wrote to Dr. R. G. Kaspar, Executive Director of the Comission on Physical Sciences, Mathematics, and Resources of the National Research Council, asking that a study of the research program be made. The original charge i to the Comittee was to develop fundamental principles of nuclear l safety research based upon an examination of the following )

questions: 1 l

1. What can be said at present about the information needs that will be confronted by those who regulate nuclear power in the 1980's and 1990's that can be met, in part, through new research?

Contacti C. Kelber, RES 443-7991 1

8704280427 870422 PDR SECY 87-053 PDR ,

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2. What are the alternative mechanisms for producing these research results and the relevant strengths and limitations of each?
3. What, if any, advantages accrue from federal support of undirected research in nuclear safety, including replenishing the pool of scientific talent available to address specific problems as they arise?
4. What are the implications of the findings for questions 1 through 3 above for the scope, structure, and coverage of the ,

federal program, given current statutory requirements?

At its first meeting, in the summer of 1985, the Comittee heard former Chairman Palladino amplify this charge as follows:

. Did the Comittee agree or disagree that more research is -

needed?

. If it agreed that more research is needed, what program of research did the Comittee feel would anticipate future regulatory problems? If it disagreed, how fast did it feel that current efforts should be phased out?

. Is it better for licensees to do the research, cnly the NRC, or some mix? If a mix, what should that mix be?

. Should federally funded research be aimed at specific problems as they arise, or at broader issues in anticipation of specific problems?

. To what extent should research work be focused solely on explicit, near-term objectives? If any other type of research work should be done, how should it be guided?

. What is the potential value of retaining a general pool of scientific and engineering talent that could be directed to work on specific problems as they arise?

The Comittee met a number of times and solicited views by mail as well. The Comittee report was forwarded for printing in final form on December 8, 1986.

The report contains an introduction and executive sumary followed by three chapters that address Principles of Nuclear Safety Research (Chapter 2), Elements of a Future Agenda for Nuclear Safety Research

4 The Commissioners 3 (Chapter 3), and Eliminating Barriers to an Effective Program ofNuclearSafetyResearch(Chapter 4). The staff's review is organized according to the three chapters --2, 3, and 4--that contain the detailed recomendations.

Discussion: The report contains a number of recommendations that endorse staff actions currently under way such as seeking increased cooperation with industry, DOE, and foreign groups or that the staff has anticipated and is starting to implement such as a plan to revitalize the grants program. The review is given in the enclosure. ,_,

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d f Tb V ctor Stello, Jr.

L Executive Director for Operations .

Enclosure:

NRC Staff Review of the NAS Report, .

CRevitalizing Nuclear Safety Research."

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DISTRIBUTION:

Commissioners OGC (H Street)

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COMMENTS ON CHAPTER 2 Principles of Nuclear Safety Research ,

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In this chapter the NAS Comittee studied three questions: '

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1. Who should fund nuclear safety research ,,

j 2. Who should set the research agenda?

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3. Who should conduct the research?

The results of the Committee's deliberations are expressed in eight recommendations: ,

i 1. The U.S. government should continue to fund research on the safety of comercial power reactors.

i 2. Nevertheless, an increased proportion of research should be funded and conducted by the industry than is now the case.

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! 3. Direct NRC funding of safety research should continue.

, 4. The Department of Energy and the NRC should encourage more research

! funded cooperatively with industry or international partners. .

! 5. Universities and others with relevant knowledge and skill should be j more actively involved in setting the research agenda.

i 6. Research funded by the NRC should be a product of a competition i among the DOE labs, private contractors, and university researchers.

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7. The U.S. government should maintain programs of long-term and i

exploratory research and maintain effective nuclear engineering I

programs of the quality and quantity needed by the country at the

university level. -

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8. The cost of research should be internalized. l i

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Recomendations 1, 2, 3, and 4: Government should continue to support safety research and DOE and NRC should encourage more cooperatively funded work at home and abroad. More should be done by industry.

These recomendations give strong and constructive support to current efforts
in both NRC and DOE to expand cooperative research programs while maintaining
strong base programs in each agency. The NRC has developed cooperative i

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! research programs with foreign parties in the areas of severe accident research, piping integrity, and validation of thermal-hydraulic codes. Several i smaller efforts are in place on specific programs such as the CONTAIN code,

! seismic effects, and the Advanced Fluid Dynamics Model. While such cooperative

! programs place a strain on our foreign travel budget, these efforts take i advantage of the fact that reactor safety research programs abroad now approach  ;

! and, in some cases, exceed our own level. Getting access to such large efforts l l brings us very substantial benefits relative to the NRC contributions.  ;

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The NRCwith research staffindustry has hadand significant the ElectricsuccessPower in Research negotiations for coop (erativeEPRI). DOE .I Institute 1 also has a number of such agreements. The NRC staff welcomes the Comittee's

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} encouragement of a more forthcoming attitude on the part of industry. A good l

! example where such cooperation would be mutually beneficial arises in the  !

I current efforts on safety issues A-47 (Safet  :

1 A-49 (Pressurized Thermal Shock), andSystemsInteractions). A-17 (y ImplicationsSignificant of Control Systems) j participation by Babcock and Wilcox, developers of the integrated control system, would not only provide funds, but would also provide highly specific

! knowledge that would speed the work. The staff will continue efforts to secure .

1 greater industrial participation; a number of avenues open to regulatory

agencies will be explored.

l l In its discussion of the partition of effort, the NAS Connittee clearly perceived that the major focus of NRC research on current reactors is work that is aimed at improving regulatory decisions. This fairly represents the NRC!s

position and the Committee endorses it. The Committee also foresees need for i

!' cooperative work on current reactors where the effort has safety implications.

The main emphasis here is on cooperative efforts with industry. Current examples of such cooperation are the joint programs on seismic margins and on

plant aging that the NRC is carrying out with EPRI. Again, this fairly reflects
the NRC position. On advanced reactors, the Committee recomends that the NRC

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carry out research to establish the applicable safety standards. The advanced a reactor program is being restarted at a modest level and aims at keeping pace

! with DOE and industry efforts. .

i i Recomendation Si Universities and others with relevant skills should be more l actively involved in setting the research agenda.

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} As research has shifted away from dependence on large test facilities located l f

at national laboratories, the wisdom nf making increased use of talents in the i

! academic world has become apparent. Supported by the NAS recommendation, a -

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! plan for increasing significantly the amount of work at universities has been drafted. This plan calls for increased amounts of contract research as well as making full use of grant authority. When such use is demonstrated to be

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j -productive, consideration will be given to seeking an increase in authority to make grants. To make more use of contract research, effective procedures that allow contracting for research on a timely basis are needed. A team from the  !

Division of Contracts and RES is developing such procedures.  !

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Reconmendations 6 and 7: Research funded by NRC should be a product of l l competition and should include long-tem and exploratory research.  ;

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j The process of maintaining long-tem work involves a discussion of time 4

horizons and the role of stable budgets. Most reactor safety research requires

!' at least three years to be re*ady for application to regulation and, more .!

nomally, seven to ten years. When budgets are not relatively stable over '

j these periods of time, the investment in the early development of the program 1 i in an area may be lost or potential accomplishments put off indefinitely in

! meeting budget ifmits. Long-tem work may last at least ten years; programs .l

! such as primary system integrity may be so basic as to go on for much longer 1 3

times. On the other hand, a long-tem program may suddenly become focused on a i' current problem, as was the case with pressurized thermal shock, which used knowledge from three long-tem programs: primary system integrity, thermal .

i hydraulics, and risk analysis. Exploratory research is necessarily without any i definite time horizon; the aim is to see if there are potential problems or

} answers not found in more straightforward fashion.

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Competition among potential contractors has the benefits of giving rise to new ideas and concepts for more efficient ways to carry out the work. Cooperation ,

! also has benefits: it helps ensure that an issue has been fully examined and i i may be considered closed; it enhances the transfer of technological advances in i the conduct of research; and it encourages the development of technical ,

spinoff. Thus there are good reasons to use both open competition among the  !

i various possible research contractors and cooperation. There is one legal

{ impediment to full com the DOE labs are not able to respond to a 1 Request For Proposal (petition:RFP), the normal way of starting a competitive pro

! There is one other matter to be considered: too frequent competition impedes the development of breadth and depth of expertise needed for rapid response to ,

unforeseen problems and for help in setting the ,research agenda. While no hard and fast rule can be given for choosing between competition and cooperation, RES intends to foster both modes of working, with competition largely aimed at new work. In general, the most productive competition is the competition of ideas, and this will be evident in the agenda planning process.

Recommendation 8: The cost of research should be internalized. -

i Finally, internalizing the cost of research is a topic to be considered by the Commission and Congress in their discussions of cost recovery through fees. A policy is needed to establish a consensus among federal and state regulators, the regulated industry, and the general and directly affected public as to how l i costs reflect benefits. But in any event, the safety research needs to be l

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i done. This need will remain even if interested parties complain that the work doesn't directly benefit them. The staff believes that, if such fees were to be remitted to the U.S. Treasury for the general fund, there would be less conflict of interest with setting the research agenda, but major problems would remain.

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5 COMMENTS ON CHAPTER 3 Elements of a Future Agenda for Nuclear Safety Research In this chapter, the Comittee focused on research topics that should constitute elements in the nation's future agenda for nuclear safety research. The principles of nuclear reactor safety research developed in Chapter 2 are utilized to examine each topical area. The topical areas included those identified by the j NRC in "NRC Safety Research Program" as well as others that the Comittee 1 determined to be important. The Comittee limited its review to current reactor  :

safety research and thus did not address other aspects of the nuclear fuel cycle  ;

that are licensed by the NRC. In general, the Comittee concluded that, irrespective of new reactor license applications, significant research remains to be performed to adequately regulate existing reactors.

The staff's coments on the Comittee's findings follow.

Behavior of Materials in Nuclear Power Plant Environments .

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We agree with the Comittee's position that basic, exploratory, long-term research on materials used in the structures, systems, and components of nuclear power plants is essential to establishing a technical base for confirming the adequacy of many aspects of slant design, construction, and operation. Pecause of funding limitations and t1e Comission's express priority for research applied to imediate needs. NRC does not fund as much basic materials science and engineering work as the staff would like. Rather, research is generally directed to specific needs. The Heavy Section Steel Technology (HSST) program is the primary vehicle for performing the limited basic researc'i that is accomplished in ,

this area. Basic research results from the HSST ,

identification of the pressurized thermal shock (prograr led which, PTS) isrue, to the through further focused research, was resolved. The budget reductions of the last few years have severely restricted NRC's ability to perform exploratory research of I the kind that disclosed the PTS issue.

The Structural Engineering program recently furnished an example of the progression from basic exploratory work on new methods of flaw detection to their application to nondestructive inspection of piping by improved ultrasonic methods. This work, which took about 11 years to come to fruition, is a major advance in the assurance of safety in the operation of nuclear power plants.

Decomissioning The staff agrees with the NAS Committee that decomissioning will be important in the future and that NRC must be prepared to deal with the associated issues.

l Currently, NPC is establishing regulations that address licensee financial and '

operational responsibilities of licensees. The staff agrees with the Comittee

6 on the need for a continuing research program to support the larger need for decomissioning that will arise in the future. It is the staff's opinion, however, that the amount of research NRC is presently sponsoring on decomissioning is sufficient to support the present regulatory activity.

Present research includes acquiring and analyzing data on techniques, wastes, radiation exposures, and costs from the decomissioning of the Shippingport and Humboldt Bay plants and from the cleanup of THI-2. This research will nelp define areas of concern that need further research to ensure t..at NRC will have a technical base to support future regulatory actions.

Extended Fuel Cycle Two types of extended fuel cycle cores are currently under consideration:

1. Use improved fuel in the same lattice,
2. Use a fundamentally different lattice.

For cores of type 1, the consensus is that the tests performed by industry and .

DOE satisfy current regulatory requirements and that no active participation by NRC Research is required. Since these fuels contain significantly more transuranics at end of life than does current fuel, this position may have to be reexamined if such isotopes are found to be important in assessing risk from nuclear power plants.

For cores of type 2, the situation is different. In Europe the plans are to use very dry lattices on a hexagonal mesh, together with very high burnup and plutonium recycle. Any move to use such designs in the U.S. would have arofound policy as well as research implications. U.S. vendors do not appear to te followin) this trend, at least as far as plutonium recycle is concerned, but the situation requires careful observation.

Human Factors, Instrumentation and Control, and Operations

, This element has several components integral to it or strongly interfacing with it. The staff agrees that human factors research needs in these areas should be reassessed and that a comprehensive program should be developed. It is with this realizatinn and cbjective that NRC is sponsoring an ongoing effort with the National Research Council. At the end of June 1987, the National Research Council will complete a study of human factors / human reliability research needs in nuclear power operations. The resulting report will be an important element in setting the agenda for human factors research. In the meantime, the staff is in the process of drafting a research plan for human safety performance research that will encompass the elements recomended by the Committee as well as seek the participation of industry and 00E.

Pescarch needs for diagnostic instrumentation, on-line calibration, and advahed

7 technology applications in nuclear power plants, will be reassessed in cooperation with DOE and industry.

Furthermore, the larger question of plant dynamics and control, including its relationship to Unresolved Safety Issues A-47, A-49, and A-17, on the safety implications of control and safety system interactions will be reassessed and properly integrated with the research efforts on human factors and thermal hydraulics, taking into account rapidly changing technologies such as process control.

Plant Aging (License Extension)

The staff agrees with the Comittee's conclusion that NRC needs research to enable it to determine whether safe conditions for life extension can be found.

In fact NRC has taken the lead, worldwide, in the area of plant aging research.

The Nuclear Plant Aging Research Program (NPAR) has been fonnally in place since 1982 and, consistent with the Comittee's recomendation, involves research into the aging phenomena of all types of materials, components, and systems found in licensed comercial nuclear power plants. Specifically, this research involves ,

such areas as structural integrity of plant systems, on-line diagnostics, integrity of radiation-embrittled materials, annealing, nondestructive testing, and the functional capability of systems and components.

The above research is currently being conducted at a number of national and private laboratories and is principally directed toward resolving aging-related safety issues in a timely manner. The Comittee is correct in observing that the results are not yet being used to resolve license extension issues. However, as the research 3rogram progresses over the next several years, the results will serve as the basis for the Comission's regulations dealing with plant life extension. Furthermore, the NRC's funding for this program has been steadily increasing despite the decline in the overall NRC research budget.

The staff agrees with the Comittee's coment on cooperative research programs.

The integration of the NPAR program within NRC and between NRC and other domestic and international organizations is the primary objective of the NRC's Technical Integration Review Group on Aging and Plant Life Extension, which was formed in 1986, and will continue in a management oversight capacity. RES has, for example, recently met with DOE to exchange information on resident aging programs with an eye to expanding the exchange of information and to plan mutually cooperative efforts.

Policy Research i

The staff agrees that a research effort to develop regulatory policy and decisionmaking under uncertainty should be initiated to augment some of the work done in previous years but terminated prematurely. NRC will seek to induce industry to undertake a similar effort. Moro recently, DOE has performed a brief review of the risk significance of major regulations.

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8 Quality Assurance / Quality Control ,

All work in this area was transferred to the Office of Inspection and Enforcement; as the reorganization takes effect, the status and future direction of this work must be evaluated with due consideration given to the Comittee's views.

l Mondestructive Testing and Examination The NAS report states that further research is needed to develop advanced NDT capabilities and to refine techniques presently in use. In addition, the report .

recomends that NRC dedicate a portion of its funding to basic and exploratory '

research directed to the monitoring of component and system degradation. The staff agrees with the Comittee's position on the need for the development of advanced NOT and NDE techniques, including the need for basic researci directed to developing techniques for monitoring structural degradation. It must be noted, however, that the existing scope of NRC research does not include development activities. In general, present research is focused on confirming I

the applicability and reliability of 1DT and NDE techniques used by licensees ,

and on improving these techniques.

Reevaluating Existing Regulations This topic should be considered in the context of " Policy Research."

Reliability of Plant Components and Plant Systems The staff agrees that further research is needed to confirm that component and plant systems are sufficiently reliable to meet overall safety objectives.

A program in operational safety reliability is under way to develop reliability engineering methods for NRC use and, in cooperation with industry, to evaluate reliability engineering methods and provide guidance for licensee activities. A related program on performance indicators is also under way to ,

develop risk-based perfonnance indicators for NRC to monitor safety performance.

S,1fety Analysis Methodology and Application The staff is in basic agreement with the Comittee's position on this element. 1 It should be pointed out, however, that additional work in PRA methodologies is being undertaken for use in generic issue resolution, operational reliability, and performance indicators as well as for applications in -

inspection and enforcement and other regulatory activities such as assessment of technical specifications. Efforts will be made to augment the integration of PRA and thermal-hydraulic analysis in order to achieve a more consistent set of analyses of risk and attendant overall uncertainties. ,

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9 Seismology, Soil Mechanics, and Structural Response to Seismic Events The Comittee apparently misunderstood the relationship between the USGS and NRC programs in seismology. The two programs have, in fact, been highly coordinated.

Basically, the USGS focuses on the seismology of the continental U.S. west of the Rockies and the NRC on the rest of the continental U.S. The data-gathering program in the U.S. east of the Rockies is gradually being turned over to the

. USGS. RES is expanding its interaction and cooperative support of projects with the Earth Sciences Division of the National Science Foundation.

In addition, the NRC is sponsoring a major research program to develop methods, procedures, and data to estimate the capability of nuclear power plants to withstand earthquakes larger than their original design basis. This research is closely coordinated with similar efforts being carried out by the Electric Power ResearchInstitute(EPRI)toavoidunnecessaryduplicationandtoensurethat mutually beneficial products are produced.

Severe Accidents i The NRC staff generally agrees with the statements concerning the NRC research program on severe accidents in LWR's. In fact, the ex3ert peer review of this l

research program as generally recomended earlier in t1e NAS report has already begun (January 1987). A report on this peer review will be presented to the Comission in April 1987.

The NAS Comittee recomended that the research be refocused in the future toward " prevention" rather than " mitigation," since the current program is aimed more at the latter. The word " prevention" is used in the in the sense of reducing the frequency of a radiological release to the public and the word mitigation in the sense of reducing the radiological source to the public. In this context the staff agrees with the NAS recomendation to focus and use the result of the research more to prevent a major release than to mitigate it.

Both efforts, however, are needed to guard against incomplete understanding of how accidents arise and in the case of obscure nodes of failure, to contain the radiological release.

Once a validated methodology with well-characterized uncertainties has been developed, analysis of effective preventive measures can be made by asking "what if" questions throughout any given sequence. The results of the analysis can then be used to determine the cost / benefit and risk / benefit ratio for the pro)osed preventive system. It should be clear however, that the accuracy of suc1 analyses requires a basic, fundamental, quantitative understanding of the systembehavior(physicalandchemical)atallstagesofanyproposedaccident sequence. Such an understanding is the goal of the past, present, and future severe accident research program of the NRC.

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10 Thermal Hydraulics The staff agrees with the Comittee's view that more analysis is necessary on thermal-hydraulic transients and that there is a need for faster and more realistic simulations of transients. The speed of thermal hydraulic computer codes is being enhanced by the use of the fastest hardware available, improved numerical techniques, and parallel processing. In addition, the development of the nuclear plant analyzer and nuclear plant data bank will make the codes much easier to use and reduce analysis time significantly.

The Comittee's coments on NRC's thermal-hydraulic transient codes fail to make the distinction between codes used by NRR to audit calculations submittted by

, licensees and the best-estimate codes developed by RES. The former do indeed contain conservative and non-physical assumption and models because licensees are recuired to use such assumptions and models by Appendix K to 10 CFR Part 50.

The mocels and correlations used in RES-developed codes are best estimate and provide the most realistic predictive capability available at the time they were developed. As the Comittee stated, additional research is necessary to utilize the results of more recent thermal-hydraulic experiments to improve .

on this predictive capability.

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, The NRC staff is in full agreement with the Comittee's assessment that the NRC 1

should have substantial participation in international thermal-hydraulic programs. The NRC is and has been participating in the 2D/3D Program, which involves a trilateral agreement between the Federal Republic of Germany, Ja pan, and the U.S. to study reflood and refill phenomena in large-scale thermal hydraulic facilities. The U.S. is also collaborating with Japan on the ROSA-IV project, which is soon to begin testing. In addition, the NRC has entered into thirteen bilateral international agreements (with three additional agreements pending) for participation in the International Code Assessment Program. The objective of this program is to assess NRC thennal-hydraulic computer codes by exercising them against tests in a broad range uf experimental facilities throughout the world.

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! COMMENTS ON CHAPTER 4 i Eliminating Barriers to an Effective Program of i Nuclear Safety Research I

Chapter 4 of the NAS report entitled " Eliminating Barriers to an Effective Program of Nuclear Safety Research" discusses structural and procedural barriers to an effective program of nuclear safety research that exist within the NRC and in its relations with OMB and Congress. It provides 23 recomendations that the comittee feels must be implemented to eliminate i the barriers.

1 In the report, many of these steps are characterized as administrative reforms.

Some are actions largely addressed to RES; others involve actions proposed for the E00; the remainder are in the province of the Comission and Congress or i else are directed at other government agencies. For clarity of discussion in 1

this paper, the recommendations are analyzed in the three parts just described.

Recomendations Addressed to RES 1 These recomendations are listed in Table I. The recomendation number in the NAS report is shown in parentheses in this and similar lists.

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Comments on Recomendations Addressed to RES The first two recomendations recognize that the original intent of the merger l of the Offices of Standards Development and Nuclear Regulatory Research was to

provide a better transition from research result to effective regulation. The 1

NAS Comittee contends that the result has been for regulatory formalism to displace technical competence and experience in the management of research, thereby dininishing the effectiveness of the program.

j Recomendation 1: The NRC should bring in high-caliber researchers to bolster

management.

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The Office of Research staff has ex'alored the possibility of bringing i laboratory research managers into RIS for term assignments. The laboratory program directors have unanimously reacted negatively to this idea for two reasonst one, on the basis of their experience, such assignments tend to break the career oaths of people assigned, and make it difficult for them to gain reentry to tl1e laboratory organization; and, two, the problems of

, cost of-living and agency pay scales in comsarison with the laboratories make -

! it difficult to persuade people to undertaco such assignments. Nevertheless,

, the Office of Research is undertaking a search for faculty members who might be willing to undertake an assignment during their sabbatical year.

Recomendation 2t_ The NRC should consider separating the functions of I

standards development and research. '

i The staff takes exception to the blanket indictment in the discussion e

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regarding the displacement of technical competence and experience by regulatory formalism. Good and bad managers and staff were in each organization. Program effectiveness, given a competent staff, is proportional to the quality of leadership and the level and kind of support.

The staff believes that a case can be made for the involvement of research people with standards and rulemaking, because research knowledge can contribute to writing of the rules and incorporation of the best science and technology. That is, more effective technology transfer from research to practice can be made in this way. ,

The staff of the Office of Nuclear Regulatory Research boasts a wide range of academic experience; the profile is given in Enclosure 1. In addition, most of the staff have had some to considerable research experience, some with over twenty years in a productive research environment. Such a staff will respond positively to leadership that emphasizes excellence in the planning and management of a productive research program. To this end, following the current reorganization of the program offices, the Director of the Office of Nuclear Regulatory Research will have reporting to him a Deputy ,

Director for Research responsible for directing the research activities.

The reorganization will also result in the absorption by Research of a part of the regulatory staff devoted to the technical support of day-to-day regulatory efforts plus the resolution of generic issues. Under the leadership of a Deputy Director for Generic Safety Issues, this group will greatly strengthen Research in attacking short-term problems and in reducing research results to regulatory practice.

Involverrent of research with the generic issues should improve researchers' knowledge of reactor plant problems, and hence sharpen the focus of research.

Again, it is expected to help increase the technology transfer from research to practice.

For the reasons cited above, the staff believes the new organization ard leadership should be given a chance to demonstrate its capabilities before any further extensive management or organizational changes are made.

Recommendation 3: The NRC should develop a cogent research philosophy.

Although the discussion by the NAS Committee states that the development of a

" cogent research philosophy" rests with the Commission, the staff believes that it would best serve the Commission by developing suitable schema that -

reflect the principles that should guide the allocation of funds among research programst the strategic basis for effective long-range planning; the roles of preventing and mitigating accidentst and the development of plans for

13 accomodating the unexpected. RES has started the )rocess by circulating among the Program Offices a concise work plan for tie current fiscal year.

Additionally, RES is starting the development of a strategic plan to be completed by the end of this fiscal year. These planning processes will reflect the guiding principles discussed above and thus illustrate how a proposed schema or " cogent research philosophy" is applied in practice. A proposed statement is given in Enclosure 2.

Recommendation 4: The research planning process should involve all relevant offices.

The Director of Research and the principal managers meet often with opposite numbers in EPRI, industry, foreign counterparts, and research comunities to develop a mutual understanding of key issues, progress toward their resolution, and work that is needed. The same holds true for meetings with the other Program Offices in the NRC. These meetings are often informal; thus they may not have the visibility that the NAS comittee would prefer. The staff believes that it is a management objective of the Program Office Directors to make this arocess work, leading to a well-coordinated and agreed-upon program .

of researc1 in support of the NRC mission. If the process does not work, it is doubtful that a more fonnal procedure would succeed. The most obvious need now is to factnr the result: of these meetings more explicitly and earlier into the research planning process. The staff believes that the forthcoming strategic plan provides an opportunity to achieve that goal.

In sumary, the staff believes the recomendations addressed to research are being accomodated in intent if not via the mechanisms proposed.

Recommendation 5: The NRC should impanel an independent advisory group reporting to the Director of Research.

The recomendation of the Comittee to impanel an. independent advisory comittee is being implemeried. Three options are under consideration:

1. Ask the Comission to allow a special subecmmittee of the ACRS to carry out this function;
2. Fom a new, independent advisory committee under the procedures set forth in the Federal Advisory Comittee Act; ,
3. Contract with the National Academy of Science to form a new standing.

board similar to those used for review purposes by NASA and the National Bureau of Standards.

1 It is anticisated that an option will be selected and fully implemented before the end of t1e current fiscal year, FY 1987.

Recemmendations 6 and 7: The NRC should create a fair and competitive process l

14 for contracting for research and should analyze the relative costs and benefits of consolidating work at national laboratories.

There is a difficult problem with setting up a formal competitive process with the national laboratories: the laboratories can not enter into competitive bidding procedures. Nevertheless, the Office of Research intends to allocate its resources to a larger comunity than at present. Sur:h a process will need ,

several years to become effective so as to preserve the belefits from work ,

performed in the past and build up ,the requisite expertis elsewhere. l Recomendation 8: The NRC should institute an annual review of the program with the principal performers of research. ,

See the remarks under item 4, above.

Recomendations 9-12: The NRC should do more work at universities.

As discussed earlier, a plan for 1rcreased use of universities is under reviews this plan adheres to the recomendations of the NAS. The staff intends to ,

demonstrate first that it can use its current grant authority productively before requesting an increase in such authority. The current grants program does not exhaust current NRC authority.

Recomendation 13: The NRC should establish independent topical peer review groups and encourage publication of sponsored research in paer-reviewed professional publications.

Although the NAS coment that RES does not use the " peer review" system is formally correct, it incorrectly implies that we do not have a reasonable or effective review system on the technical approach and experimental method for the research. One very important principle of operation of safety research, initiated under the AEC and emphasized on the change to NRC, was expert ,

review of the program technical content, approach, and programatic goals.

It was called the Review Group S outside (industry and academia) andystem the inside and who included were members very highlyfrom both the respected for competence in their disciplines. At the very outset of RES activities, all prograns were required to develop an Analysis Before Test document that would carefully analyze the scientific methods, approach, and experimental matrix to be employed to gain the progrannatic result. The ABT was sent to Review Group members in advance of the formal meeting in which it was reviewed and critiqued. Subsequent Review Group meetings continued to review the scientific and experimental methods being emsloyed, but of course put increased focus on the results and interpretations. T1e basic principle of this process is still used by several, but not all branches. New programs must develop a program description that shows the methods and concepts to be used to obtain the programatic goals, and that approach is critically reviewed by the best people we can obtain. While we do not deny that our review approach is oriented more toward programatic goals, we do not hesitate to say that we

15 l

l demand the very best science and use of the best scientific principles for the i work. We believe widespread use of this approach in RES will meet the goals l of the recomendation.

1 Some appropriate examples of the use of the review group method are:

> o Containment Integrity Program -- A peer review panel consisting of eight independent experts from academia, architect-engineers, and consulting firms was established in 1979. This panel meets about twice a year to review and comment on plans, activities, and results.

o Seismic Methods Validation Program -- A peer review panel consisting of five independent experts from academia, consulting firms EPRI, and AIF was established in 1985. This panel meets about twice a year to review and comment on plans, activities, and results, o Category I Structures Program -- A technical review group consisting of six independent experts from academia, utilities, architect engineers, and consulting firms was established in 1980. ,

This review group meets twice a year to review and coment on plans, activities, and results. In addition, the program is periodically reviewed by the NRR Seismic Oversight Steering Comittee.

o Seismic Margins Programs -- A peer review panel consisting of five indepandent experts from architect-engineer firms, consulting firms, utilities, and national laboratories was established in 1986. c This panel is reviewing the seismic margins review of the Maine Yankee Nuclear Power Plant to evaluate the applicstion of the guidelines and procedures developed in this program. In addition, the program is extensively reviewed by the NRC Seismic Design Margins Working Group which is made up from NRR and RES staff.

o Seismic Hazard Characterization Program -- A peer review panel was established in 1985 to review and comment on the methodology developed and implerented in this program. The panel consisted of four independent experts from academia.

Recommendations Addressed to E00 Three recomendations are explicitly directed at the EDO: .

1. The executive director of operations should ensure that more face-to-face discussion occurs among the NRC program of fices at the branch level concerning the philosophy and content of the research program (NAS5).
  • 2. The NRC should adopt the practice of producing interoffice documents l l

7 16 that sumarize what is known and what research is still needed (NAS 6).

3. The NRC should charge its contract office to develop procedures to make research contracting with organizations other than the national i

laboratoriesaneasilyavailableoption(NAS16).

Comments on Recomendations to EDO The E00 believes that the new organization of the Program Offices plus the consolidation at White Flint North will solve a major part of the problem of securing greater intaraction among tFa Program Offices. Interoffice papers suggested by the NAS comittee appear to be an amplification of the Research InformationLetters(RILs)writtentodescribeacompletedresearchproduct.

The current information system requires feedback from program offices when a i . RIL is issued, and it will be a small additional task for RES to coordinate such responses to form a document such as that described by the NAS.

The Division of Contracts and RES have formed a small group to develop improved j procedures for contracting for research. .

I Recomendations to the Comission. Congress, and other Agencies The NAS report contains seven recomendations addressed to the Comission, Congress, or other agencies. These are listed in Table II.

{ Coments on Recomendations to the Comission and others

! Recomendation_1: Congress should relieve ACRS of the formal requirement to I

review the safety research program.

The staff's experience with the ACRS is that in depth reviews of specific research topics are much more valuable than the broad brush review made in the report to Congress. There is good reason to believe the ACRS shares this feeling, and the staff feels that the recomendation to relieve the ACRS of its obligation for a formal review of the research program is wise.

l Recomendations 2 and 3: The options for restructuring the NRC to restore leadership to the research program should be reexamined, and the Chairman should assign a staff member full-time to monitoring research.

The staff believes that the current NRC restructuring is a positive step and

, that judgement on further restructuring should be suspended until the new 4 organization has had a chance to prove its worth. To focus on the issue of the role of standards and rulemaking within a research organization, it should be noted that a case can be made that such activities are a natural application of research best made by those familiar with the underlying work. The reason i is that standards are engineering design guidelines that express the consensus of what has been learned from research. Similarly, many rules translato

O 9 17 research results into technical requirements for nuclear powar plants.

Typically these have a significant research input, as in the case of GDC.4, PTS, and the Appendix K revision. Such inputs are most carefully expressed by staff knowledgeable of the technical substance.

With respect to Comission restructuring, including designation of a staff i member to spend full tire monitoring research, and to moving toward a single

! administrator form of management, the staff notes that, when the Reactor l

Safety Research Division was initially formed in the Atomic Energy Comission.

l the Division Director reported directly to the Comission, and there was a I single Comissioner charged with oversight of safety and regulation. Thus, a number of viable management options are available and the staff does not believe that one or the other should be selected solely on the basis of the i role of the research program. Never matter by the NAS Comittee Chairman}heless, underlies thethe strong point emphasis that any such given this Comission restructuring should include specific attention to the role of research.

Recomendation 4: The Chairman should require periodic reviews of the status ,

of major researcT projects.

The staff has prepared periodic briefings for the Comission on major areas of research, and it believes that the sessions have been productive. Should the Comission feel the need for more frequent briefings or, perhaps, the preparation of panel reviews for Comission information, these will readily be preparod.

Recomendation 5: The Chairman should defend the research program before OMB and Congress.

The Chairman did, in fact, defend the FY 1988 budget proposal, including the research component before OMB, and is now doing so before Congress.

Recommendition 6: DOE and NRC should collaborate and sharo information, including that from classified programs.

Recomendations for periodic sharing of research results with classified 00E programs require interagency discussions best carried out at regular meetings between agency heads. With respect to unclassified work, there is good sharing of work results now.

Recomendation 7: 00E should ensure that a portion of its budget for university. based R&D supports safety research relevant to current reactors.

As the RES grants p ogram is more formally established, coordination with DOE and NSF programs will also be established.

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The NAS Comitee Chaiman had direct personal experience with the management of NASA, a Federal agency with a very large research component.

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! RECOMMENDATIONS ADDRESSED TO RES

1. The NRC should bring in some high-caliber people with active research experience to bolster top and middle management of the Office of -

Research(NAS1).

2. The NRC should consider separating the functions standards development andresearch(NAS2),
3. The NRC should develop a cogent research philosophy that can be used to direct and assess the effectiveness of the safety research program (NAS3). ,

, 4. The NRC should establish a research planning process involving all of j the relevant offices within NRC, as well as representatives from industryandtheuniversityresearchcommunity(NAS4). ,,

5. The NRC should impanel an independent advisory group, reporting to the director of research, with expertise in the range of disciplines relevanttonuclearsafetyresearch(NAS13).
6. The NRC should create a fair and competitive advisory group for  ;

allocating research among national laboratories, industry, and '

contract researchers, including universities (NAS 15).

7. The NRC should conduct a careful analysis to weigh the relative costs and benefits of various options for consolidating work at thenationallaboratcries(NAS17),

c

0. The NRC should institute at least an annual review of the program with the principal performers of research, including but not limited to resresentatives of the national laboratories. EpRI, and managers ofotlermajorpiecesoftheresearchprogram(NAS18),
g. The NRC should request that Congress expand NRC's grant authority and then NRC should award more money to universities as grants, rather thanascontracts(NAS19).  !
10. The NRQ should encourago and assist university faculty to do nuclear safetyresearchatthenationallaboratoriesCNAS20).

I 1g .

11. rant gram I The reviewNRC should panels establish grant for selecting a competitive recip $ents fNAS 21f.using peer
12. The NRC should assign a staff member the task of overseeing universityresearchfunding(NAS22).
13. The NRC should establish independent topical peer review groups and encourage publication of sponsored research in peer-reviewed  ;

professional publications. All research products should be so reviewed (NAS14).

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TABLE II

] RECOMMENDATIONS ADDRESSED TO THE COWtISSION AND OTHERS i 1. The Congress should relieve the ACRS of any formal requirement to review j the safety research program (NAS 7).

j 2. Options for restructuring the NRC to restore leadership to nuclear

! , safety research at the NRC should be reexamined (NAS 8).

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j 3. The NRC Chaiman should assign a member of his or her staff to devote j full time to monitoring research (NAS 9). -

l 4. The Chairman should require. periodic review of the status of major research projects (NAS 10).

5. The Chairman should develop an understanding of the research program
and then personally defend the program before OMB and the Congress .

l (NAS11).

i j 6. Both DOE and NRC should collaborate to establish mechanisms for periodically sharing appropriate results of their respective programs j of nuclear safety research, including any applicable results from the  ;

I naval reactor and defense production reactor programs (NAS 12).  ;

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) 7. The Department of Energy should ensure that a portion of its budget for university-based R&D goes to support safety research of relevance to l currentreactors(NAS23).

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Enclosure 1 RES STAFF PROFILE DEGREES Assoc Bachelors Masters Doctors i ** liajor Field Accounting -

    • Subtotal ** ,

2 0 0 0

    • Major Field Business Admin '
    • Subtotal **

0 0 1 0

    • Major Field Chemical Engr
    • Subtotal **
O 5 1 4 ,
    • Major Field Chemistry
    • Subtotal **

O 2 0 l'

    • Major Field Civil Engr
    • Subtotal **

0 1 2 2

    • Major Field Economics
    • Subtotal **

0 1 0 1

    • Major Field Education
    • Subtotal **

0 0 1 0

    • Major Field Elec Engr
    • Subtotal **

0 1 3 0

    • Major Field Geography
    • Subtotal ** --

0 0 1 0

    • Major Field Geology
    • Subtotal **

0 0 0 2 i

, 22 l

l Enclosure 1

    • Major Field Health Physics
    • Subtotal **

0 0 3 1

    • Major Field Hydrogeology
    • Subtotal **

0 0 1 0

    • Major Field Industrial Tech
    • Subtotal ** '

0 1 0 0

    • Major Field Materials Engr
    • Subtotal **

0 0 2 0

** Major Field Math Statistics .
    • Subtotal **

0 0 2 1

    • Major Field Mathematics
    • Subtotal ** .

0 1 0 2

    • Major Field Mech Engr
    • Subtotal **

O 4 5 8

    • Major Field Metallurgical Engr
    • Subtotal ** .

0 0 1 2

    • Major Field Meteorology
    • Subtotal ** ,
    • Major Field Nuc1 Engr ,
    • Subtotal ** I O 2 9 -10 -

l

    • Major Field Operations Research  ;
    • Subtotal ** ,

0 0 1 0 )

    • Major Field Physics
    • Subtotal ** I O 2 4 7
    • Major Field Prob Risk Assess
    • Subtotal **

0 0 1 1 l

23 Enclosure 1 ~

    • Major Field Psychology
    • Subtotal **

0 0 0 2

    • Major Field Public Health
    • Subtotal **

0 0 1 0

    • Major Field Radiobiology .
    • Subtotal ** '

0 0 0 1

    • Major Field Seismology
    • Subtotal ** '

0 0 1 1

    • Major Field Structural Mech .
    • Subtotal **

0 0 1 1

      • Total ***

2 20 42 47 9

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w Enclosure 2: Page 1 DRAFT "A Cogent Philosophy of Research" INTRODUCTION The National Academy of Science Report, " Revitalizing Nuclear Safety Research,"

recommended that the NRC develop a cogent research philosophy "that supports the mission of the agency..."

Further, this philosophy is to serYe as the basic guidance for the conduct of the research program. This draft is an attempt to develop such guidance.

What is a research philosophy?

A research philosophy, in the eyes of the NAS Committee, is to serve as guidance to the Office of Nuclear Regulatory Research in its overall conduct of work. 1 Some guidance on the work of the coming year is given in Policy and Planning Guidance and, occaisionally, through staff requirements memos. The safety research philosophy sets forth guidance on the manner in which the objectives set out in the more detailed guidance are to be achieved.

To that end, such a philosophy has to include criteria for the scope of work, the.

basis for basic programmatic planning decisions, and measures by which the program's success will be judged.

Why is a philosophy needed?

This philosophy is needed to give direction to research planning, to provide a framework on which the program can be built, to establish principles for setting priorities, and to furnish criteria with which to assess whether a given area of research.is continuing to serve a useful purpose.

These matters are discussed in the following pages.

SCOPE i

The scope of the research program is defined by the following criteria:

1. The work supports the development of licensing criteria needed in connection with' activities to resolve generic issues and with licensing reviews, and the development of regulatory rules, guides and standards.
2. The work provides an audit capability needed for the review of -

material submitted by a current or potential applicant in the licensing review process.

3. The work provides an independent base of physical data, engineering information, and computer codes needed to substantiate the technical basis for licensing and inspection.
4. Work needed for implementation of the safety goal.

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Enclosure 2: Page 2 DRAF' "A Cogent Philosophy of Research" I

, 5. Work needed for establishing the licensing bases for advanced and for

, standardized plants.  ;

1 FUNDING LEVEL l Relatively stable funding levels (barring major disturbances) will be sought for the following reasons:

1. The strategic planning horizon of research is several, typically ten years or more; decisions taken now affect the capability of the NRC to discharge its mission a decade hence. .
2. The planning and conduct of rer.earch requires the patient accumulation of relevant knowledge and skills; premature termination of work wastes the investment in developing such knowledge; moreover, when defered work is resumed, the process of skill development has to start all over again.

The planning process is complex because of the natural tension between the .

short-range and long-range program needs. Normally, Commission decisions are foreseeable over an interval of 1 to 2 years. Technical support for such decisions requires the application of existing knowledge to problem resolution.

Unless large gaps in knowledge are discovered or the problems turn out to have unanticipated facets that present a challenge, the research is short term, drawing on a vast reservoir of past technical experience.

On the other hand, it is necessary to anticipate such decisions well in advance l of their arriving on the scene for decision so that the needed reservoir of knowledgecaybefilledup. The planning horizon for such work is of the order of ten years just because there is a large body of past experience that
indicates it takes about ten years to bring a new technical issue to a stage where it can be satisfactorily resolved for regulatory ends.

Some problems wil.1 arise that were not foreseen; such problems can be successfully attacked only if there is a good base of fundamental research to build on.

ALLOCATION OF FUNDS The Commission's primary goal is to ensure that all NRC-licensed plants and fuel cycle facilities are constructed, operated, and maintained in accordance with the highest standards for public safety. In support of this goal, research funds must be allocated so as to give highest priority to those research projects, standards, guides, and rules that support the NRC's capability to ensure that I The HSST program has been going on for many more than ten years. The ECCS l program started in 1973 and was nearly complete, from a technical point of view, in 1983. The advanced reactor program started in 1973 and completed its mission in 1983. Adavanced ultra-sonic inspection techniques started at U. Michigan in 1974 and are now being transferred to the commercial sector.

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Enclosure 2: Page 3 DRAFT "A Cogent Philosophy of Research" plants in operation meet or exceed the s'afety goal and are as safe as reasonably achievable.

Funds must also be allocated to supply the capability to carry out similar regulatory actions with regard to future plants or licensing applications (such as plant life extension) where there is a sound basis for anti"ipating the eventuality.

In making these allocations, the primary guidance for setting relative priorities is furnished the safety goal; the division of effort between projects aimed at accident prevention and those aimed primarily at accident mitigation must be based on their expected contribution to reducing health effects over the lifetime of the affected plants. The Office of Research is instituting a priority scheme that recognizess this guidance.

The division into " mitigation" and " prevention" is not always clear, but the practical effect can be outlined in this fashion:

Recent development of mature regulatory policy is based on reliability and risk ,

models, which, in turn, are based on probability and statistical tests and models. These models are used to treat problems in terms of a systems analysis that (1) identifies faults that cause accidents, (R specificsubsystems,includingbothhumanopdra).relatesthesetoeventsinvolving tors ano pieces of equipment, and (3) assesses the likelihood that the chain of events will end as a severe accident. The analysis of the experience to data with similar subsystems is what yields the likelihoods of failur; or success at each step.

Such analyses tell us with what frequency a severe accident may occur but not when or where. This is to be contrasted with a calculational approach that establishes the temperatures, stresses, flow conditions, etc., that mathemetical modesl predict will lead to a severe accident but does not establish the frequency with which such conditions occur. The detenninistic approach does, however, reveal the magnitude of the health effects. The magnitude of the he:lth effects expected over the lifetime of the reactor is derived from the product of the frequency'of severe accidents and their consequences.

Clearly, reducing the frequency factor will reduce risk. It does not make the accident impossible, but it reduces the chances that the accident will occur in any specific year.

. i The benefit of mitigation is the other side of the coin. Mitigation reduces risk by reducing the consequences whenever the accident may occur. Since there is always some finite chance of an accident occurring, mitigation is as important, j generically, as prevention. The real question is addressed to any specific 1 proposal for work: which has the better prospect for efficiently reducing our l estimate of the risk (health effects) from operation of a nuclear power plant?.  !

None of the methods used claim to be omniscient: errors of omission will happe'n, though efforts are made to reduce the number of such errors. To allow for the unexpected and to enable the Commission to have ready access to a wide range of 1

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Enclosure 2: Page 4 DRAFT "A Cogent Philosophy of Research" axperts, the Office of Nuclear Regulatory Research will carry out a long-term program of basic and exploratory work. This program will utilize the nation's universities in such a way as to play a major role in developing and maintaining an adequate supply of highly skilled scientists and engineers knowledgeable about safety problems in nuclear power.

The research program will support the Comission's goal of improving the regulation of the nuclear industry by allocating funds as needed to:

1. Incorporate new knowledge into current rules and regulations;
2. In cooperation with other Offices, develop new rules and regulations to implement Comission policies as they are defined, e.g., Severe Accidents, Standardized Plants, and Advanced Reactors.

Funds will be allocated to support research needed to resolve generic safety issues and similar open safety issues promptly, as well as expose new issues.

MEASURES OF SUCCESS We are still considering how to phrase a concise, cogent statement on the measure of success.

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