ML20215F910
| ML20215F910 | |
| Person / Time | |
|---|---|
| Issue date: | 12/11/1986 |
| From: | Kelber C NRC |
| To: | Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20215F873 | List: |
| References | |
| FOIA-87-300 NUDOCS 8706230051 | |
| Download: ML20215F910 (9) | |
Text
t December 31, 1986 Memorandum for :Eric S. Beckjord, Director Office of Nuclear Regulatory Research 1
i From : Charles Kelber, Senior Research Scientist Subject : Review of "Revitalining Nuclear Safety L search" by the National Research Council
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i Enclosed for your use is my own in-depth review of the NAS report.
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1 Charles Kelber )
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9 Review of " Revitalizing Nuclear Safety Research" by Charles N. Kelber, Senior Research Scientist After a brief comment on the general direction of this report, my review focuses on specific recommendations and findings in the report.
i Genarbl Dir.cchioD i This report is intended as a constructive document to correct the defects apparent starting in 1963 and culminating in the very large budget cut of FY 1986, The report is rightly criticiced as being deficient in not recognizing the major accomplishments of research. The point is that the NRC research organization hss accomplished a great deal to be proud of, and that the aim of constructive criticisms is to restore this capability.
The Committee might reply that they are resporiding to the existing problem, not taking a historical view. Failure to j recognize that in the period 1973-1983 the research program had )
many major accomplishments is a major mistake in the political arena, an arena familiar to many of t.he Committee's' members.
Finally, there may be some merit to the cynical remark that this report is like "trying to breath life into Jack Kennedy." That is, is the effort worth saving. I believe that it is, because there is no substitute that comes close.
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.' fipecific_!.;Dmmen%D
. Findings While the US government should continue to fund research on reactor safety, the industry should take on an increased part of the burden.
Comment There has, for reasons concisely stated in the Committee's report, been no rush by industry to fill the gap created by the Commission's actions in cutting our budget. I have no doubt whatsoever of the personal commitment by industry personnel to maintaining reactor safety, but translating this commitment into research activities is difficult unless the NBC_renuires_it_ The only part of the NRC with authority of this sort is NRR. To take such action, NRR has to know:
- 1. What the problem is, and what the questions are.
This is hard to d, without substantial research support, and a good basis for communication between RES and NRR, as well as a broad range of technical capabilities in NRR.
- 2. That additional requirements will not be rejected because of an indefinite cost / benefit analysis, The industry naturally maintains that the world is OK as it is, and that no additional burdens should be borne. The backfit rule gives them a formidable weapon in this regard. Of course, this is not so uniform a reaction as to defeat every proposed action, but it is, as it was meant to be, a high hurdle.
Again, substantial research must be done to overcome this obstacle. Thus, we have a chicken-egg problem. Nevertheless, when
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NRR wants a substantial follow-on program, such as MIST l follow-on, to be carried out, they should be willing to put
. pressure on industry to carry its share of the burden.
Finally, I believe,that the Commission could do well to meet with the PUC's (via NARUC) to express their concerns that regulatory measures that inhibit industrial cooperation on safety mattert be relaxed.
Ettemmendation l
1 Universities and others with relevant knowledge should be more actively involved in setting the research agenda and in competing I for and performing research.
Comment The staff is assembling recommendations to make competition for contracts for research to be made more expeditious. There is no doubt in my mind that we will succeed in finding a satisfactory procedure. This is not the 'w hole problem, however.
One of the major errors of the recent past was placing the burden on the laboratories to discover issues for themselves so as to justify their continued existence as NRC contractors. This led to a very bad state of affairs and is a dereliction of our duty. Our job as researchers is to understand the regulatory issue, even if i it is not yet looming large on the near-term horison, and develop from that understanding a set of technical problems whose resolutions will support effective regulation. It is this key aspect of the job that, to my mind, more than any other, requires that a substantial part of the senior staff be made up of members drawn from the active research community.
The research staff needs to know what recearch can and cannot do; it needs to know how to define technical problems so as to permit resolution in terms useful as a basis for regulation. It needs to ,
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- know how researchiis donc so as to guide the contractors and make {
corrections to perceptions of the problem as knowledge is acquired. At the same time, it needs to understand how the knowledge is to be deployed in support of-regulation. This is a /
tall order. In my experience the staff in the Office of Research during the 1973-198U period had these capabilities.
BccDmmtDuhtiDD The U. S. government should maintain programs of long-term and exploratory research and maintain effective nuclear engineering !
programs of the quality and quantity needed by t,he country at the university level.
CommenL I
This recommendation evades the question of which agency in the US j government should undertake this task. The NSF is not doing such ;
work at present, though it could be the most readily effective agency. DOE is doing significant work in nuclear engineering, some of it clearly related to techniques in safety analysis. For the sake of the health of the NRC research program, the NRC should undertake a small effort through a grants program, and that effort should be coordinated with DOE to avoid gaps in ;
coverage of key disciplines.
RecommendaLLon The committee made certain programmatic recommendations.
Comment 1
At least one committee member told me that he felt these recommendations had not been well thought out; my view is that they do have some merit and should be given consideration in the following way: when we attempt to prioritise programs we should not just include the current efforts but consider suspended I
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, restart another; so be it; why perpetuate errors? )
1 EccommeDdation ,
l The IJRU should bring in some high-caliber people with active
- research experience to bolster top and middle management'in the i Office of Research; and, should consider separating the functions of standards. development and research.
Comment My own experience has made me very bitter about this recommendation; it takes me back to 1973 when RSR was formed. But I shall point out the key argument put forward by the Committee:
'Unfortunately, the result has been more for regulatory formalism to displace technical competence and experience in the management of the research and thereby to diminish the effectiveness of the.
program '
No steps are in the offing to counter this trend, and I do not believe bringing in professors on sabbatical will do the job, A though it will have some beneficial effect in some cases. It should be noted that the title " Professor" does not -in itself lend enough authority to overwhelm a determined bureaucracy, it in leadership at each management level that sets the style.
It would be well to recall that the AEC, with the advice and consent of Congress, established the reactor safety research program as an independent entity in 1973, with the director reporting directly to the Commission. This was done to enable the Commission to have a source of technical knowledge that was independent of the contending pressures of development and regulation. (The technical assistance program for regulation
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, started;in 1971.) Over the years, Congress's purpose has been distorted.
Aiding this distortion of purpose has been incorrect interpretation of the phrase " confirmatory research.' This phrase was inserted to prevent RSR from developing a breeder reactor on its own; I was in charge of breeder reactor safety and never felt the urge to circumvent the law. Indeed, when we were able to submerge the tension between regulator and regulated, we in RSR were able to work productively with UR13R project staff to resolve ..
key issues.
Nevertheless, the phrase " confirmatory research" has been used by those ignorant of our history to justify a highly restrictive view of the scope and depth of our work.
When RSR was first formed we were in many ways a community of scholars. When we visited our contractors we received their technical respect and they responded to our leadership. We truly worked cooperatively. The challenge is to restore that condition.
Recommendation The NRC should develop a cogent safety philosophy.
Comment I think we should take this remark seriously and work with Commission staff to come up with a pithy statement of objectives and criteria for safety research. 1 would be pleased to work on such a document.
Recommendation NRC should establish a research planning process.
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Commen1 This is long over-due. We used to develop over-all logic charts showing the projected program course, schedule, and objectives.
These were presented in the " buff books' together with supporting details that covered the short term. That capability should be restored.
Becomminda.tlon The NRC should establish independent topical peer review groups and encourage the publication of sponsored research in peer-reviewed professional pub.lications.
Commuut Of course we should. We used to do this. An NRC research publication was correctly regarded the world over as a high quality piece of work. But amacingly enough, when a plan to restore this process was circulated recently there was vociferous objection from managers and many key staff. Some of the latter had the curious objection that they were already doing this (peer review, etc.) and therefore the policy shouldn't be put in place! ;
I Other objections reflect the triumph of formalism over the research approach. Only consistent management leader ~ ship at all levels of management will enable us to restore this policy in an effective way. In the interim, quality will continue to be in question.
Recommendation The NRC should request that Congress expand NRC's grant authority and then NRC should award more money to universities as grants, rather than as contracts.
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. I.would be more enthusiastic a supporter of this recommendation if I were not aware that the major question we face each year is what programs do we cancel next. If the budget can be stabilined for, say. a three to five year period, then I would agree.
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