ML20245A572
| ML20245A572 | |
| Person / Time | |
|---|---|
| Issue date: | 03/21/1986 |
| From: | Bernthal F NRC COMMISSION (OCM) |
| To: | Blush S NATIONAL RESEARCH COUNCIL |
| Shared Package | |
| ML20235N989 | List:
|
| References | |
| FOIA-87-300 NUDOCS 8704150231 | |
| Download: ML20245A572 (7) | |
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);1 P pnat:q* UNITED STATES p, ..p
.-f" ,, ' NUCLE AR REGULATORY COMMISSION WASHINCTON O C. 20555
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., s March 21, 1086
' OFFICE OF THE COMMt$510NER
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Mr. Steven M. cllush p' ,
' ' . Staff Officer Committee en Nuclear Safety Research )
? National Research Council R 2101 Constitution Avenue I Washington, D.C. 20418
Dear Mr. Blush:
l Pursuant to vour reouest of February 19 for writter responses te certain -;_
cuestions which you have posed for Members of the Nuclear Regulatory Commission as part of the review of our research proarams by the Committee or Nuclear Safety Research, I have compileo the following comments for Coninittee consideration. While it may be sorrewhat repetitive, I.also append a memorandum wnich I wrote a year aan or the broad sub.iect of NRC
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tafety research.
I hoDe the enclosed comments are helpful, and I look forward to meeting with the Committee.
l Sincerelv, wt- l YQ, i Frederick M. Bernthal l
I Enclosure L' i 1
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' 1. In your view, which of the followinc constitu*e " nuclear safety research":
(a) research supporting the operation and maintenance nf nuclear power plants (b) research in support of licensing (c) research to reevaluate existing regulations against new criteria 1 l
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(d) research on new designs or to extend the life of existino plants (e) basic research
'(f) other (please specify).
ANSWER 1:
"All of the 'above," that is (a) through le), with the word
" safety" added in each case.
For example, basic research initiatives to On the other explore "r.ew designs (d) is not the province of the NRC.
hand, until very recently NRC interpreted itt. mardate 50 strictly as to fail, in my judgment, in its responsibility to provide timely and thorough commentary and opinion on safety characteristics _of new reactor designs, in the spirit that the FAA, for example, does for proposed new airframe designs. I am pleased to report that this narrow interpretation of our mandate is ending, and to illustrate, I hope the Committee will have the benefit of the Commission's Advanced Reactor Policy Statement now nearing
( completion.
For (a) and (b), with over 100 operating pisnts and about 20 plants coming on line in the U.S., research supporting this effort is crucial. Many of i
these 120 plants were licensed for construction (and in some cases for operation) in an era when a number' of important safety issues were unresolved. Continuing safety research is important te assure that these l p' ants achieve full operational potential, and that the.public Technical areas such can as be pipefully l
confident in ti,e operations of the plants. ;
cracking, man / machine interface, microprocessor.centrcls.. water chemistry, !
systems interactions, probabilistic risk sssessment, and maintenance 1 optimization all are important and need sustained attention.
As to point (c), a common misperception is that' research reevaluating _ j existing regulations generally results in reduced conservatism, and !
therefore reduced ' safety. But such research, prcoerly executed, should i
result in better understanding of engineering reality -- a result which l must ultimately lead to less uncertainty and greater safety in the sciene.e- i of nuclear powerplant engineering. Thus, It is entirely appropriate, for l
example, for NRC to sponsor research directed at modifying Appendix K (ECCS
' requirements), GDC-4 (dynamic effects of pipe break), or Part 100 siting criteria. -
Research area (d) -- a personal favorite of mine - is an area 1 fear is -
getting less and less attention, certainly within NRC, as Gramm Rudman budget cutt take hold and forward-looking safety research on future designs
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is considered a luxury. .As "new design" evaluation ard safety research diminishes, " basic safety" research fitem f ell may !'so be headina for
' oblivion within NRC. I hope this isn't so. . I be'*e.e that a significant component of NRC research should be dedicated to' exploring new safety ~
concepts separate from the more immediate needs desc-ibed above. If the U.S. is to be a leader in safe nuclear power in the 21st century..it is in the national interest that sach research go forward today, and it is in.the interest of the utilities that the NRC corrent early and in as much detail as possible on the safety characteristics of proposed new plant designs,. or on new safety ccncepts which might be considered as such designs are L
developed.
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- 2. What safety research should'be done; who should do it; who should use it; who should fund it' ANSWER 2. What should be done? See 6bove.
Kho should do it? Aside from statutory constraints, it is immaterial to me as a matter of policy whether NRC. 00E, the industry, or anyone'else does it. What matters is that the policy decision be on the basis of national interest and that, if necessary, the U.S. Government make necessary investments in the future, especially high-risk investments, if the private sector is unwilling or unable to do so.
It is importart to note that NRC research has a dual role. Indeed, there
( appears to be widespread misunderstanding by the Congress, and within NRC itself, of the distinction to be made betwaen two equally important and justifiable components of NRC's safety research charter:
(1) Elements of the broad safety research role left over from the old AEC, specifically that portion which fosters certain U.S.
Government basic safety research programs under the aegis of NRC, just as other basic and applied research orograms are carried out in the national interest under the aegis of NSF, DOE, and NASA.
(2) The more limited, regulatnry-product-oriented confirmatory research that should be largely determined on order, so to speak, by the specific needs of NRC's user of' ices.
Although I believe that item (1) above is an important NRC function I l would rather see that function transferred to DOE than for it to. languish l
and possibly die in an NRC that can't justify safety _research to Congress, in any event,' NRC must maintain-a strong confirmaterv regulatory research program if it is' to continue its independent audit of research results presented to us by DOE and industry.
Who should use it? Anybody who wants to.
Who should fund it? Current vogue would require entities that directly benefit from a program to fund it, even if they do not actually do the work themselves. NRC charges a fee to utilities to process an.
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operatino license. At present, however, it is difficult for the NDCnich to extrapolate that policy to assess the induttry Whilefor the,a'et, rc..aarch concept of userw has a more indirect benefit to industry. i taxation (this would be a " tax" or the ratepayers) has broad philosophical 1 apoeal to me as a matter of policy, the legal and procedura' impediments,
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and the prob 1en of a level playing field are su'ficiant to lead me to cuestion whether it is worth the effort.
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- 3. What safety research now being done should be brought to closure?
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A curious question. In f act, the " goal-orientation" philosophy ANSWER 3.
implicit in the question seems characteristic of the engineer's view (as coposed to the pure scientist's view) of the nature and ob,iective of j scientific inquiry. Not to beg the question, however, ITosuppose all be sure, for a research should, in principle, be brought to closure.
regulatory agency, research is most useful when it presents answers that oermit agency action. <
Good.examoles include the source-term and related prnbabilistic risk This work should be broucht to " closure" as rapidly as assessment work. the possible so that appropriate agency actions can be taken to implement.
severe accident and safety goal policius of the Commission, to mcdify ;
emergency preparedness and containment requirement regulations, and to '
apply reliable backfit cost-benefit criteria to determine need for olant
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j Setting priorit es for clcsure is difficult (pRA can be an effective tool). '
A rule of thumb mioht be to seek first to resolve issues that present the greatest uncertainty -- e.g. uncertainty in estimated probability of system interactions, in estimated core-melt probability, and in consequences to the public. The NRC regulates, af ter all, to uncertainties, and programs l designed to resolve " big ticket" uncertainties can have significant Dayoff l for improved safety, for regulation, and ultimately for the economics of l nuclear power. !
4 Do you believe research responsibilities are preocr*y allocateo wii.M6 l
the NRC? within DOE? within industry? If r.ot, how should they be reallocated?
See above. Unless the mood of Congress changes, more and more ANSWER 4 of the safety-related research burden in the (1.5. will have to be borne by indu3try. But the government should remain the " safety net" to insure that essential research not go undone. As to responsibility within NRC, I believe the NRC research effort would be more responsive to meeting NP.R, IE, and NMSS needs if these several offices had more influence on program directior.. It has been suggested that the whole program of severe accident research, for example, be put under the direct control of those who have to live with and act on the research results, namely NRR. An intelligent form of matrix management suggests itself.
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- 5. What are your views on the state of cooperative goverrrrent-industry -
research in the United Sta*.as?
Ny views are mixed. The final verdict on the IOCOR/FDC effnet l ANSWER 5.
in severe accidents is not in, but my information is workinqFes it that quite this well. A united covernment/ industry effort, for exampla, ousition from IDCOR and NRC on the major cuestions regarding severe accidents can greatly assist in resolving issues and moving ahead with The IDCOR/NRC procran, of course, is rot rneaningful safety improvements. The MIST and FIST j the only example of NPC/ industry Cooperative ef forts.
programs in thermal hydraulics have also met with some limited success.
That said, i* must be noted that close cooperation between NRC and industry in such matters must be carefully handled to avoid even the appearance of NRC being co-opted by industry's interests.
- 6. How effectively in your opinion does this country integrate safety research--done abroad? .research done by industry? research done by government?
ANSWER 6. Poorly, in every case.
l The APS report on source term research raisqs fundamental questions of NRC !
management of its broad research mandate (not that the NRC is alone in its i
problem). Though individual programs and the professional cadre may very well be excellent, integration of those programs _ into a purposeful, Indeed,goal- many
( oriented effort has apparently been substantially deficient.
of the problems implicitly or explicitly identified in the APS report suggest a generic difficulty (poor communications between contractor ;
laboratories and RES; lack of adeouate internal peer review of. key program.
elements; failure to integrate and document research progress as represented in published and unpublished reports; failure to legitimize and
" certify" research results and progress by publication in peer-reviewed open literature; inadequate treatment of uncertainties).
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The nature of i.he government and prRate institutions involved.. the ,
political forces that sometimes affect research (derisions, and the !
- ,srvasive bureeveracies all encourage and contribute to differentiation instead of integration. Examples to illustrate the point
o Integration by industry One of the interesting things about the TDCOR ef fort is that it does not represent industry as a whole.
It represents the utility inte.'est which can be at times at odds with reactor vendor interests, o Integration by NRC One look at the host of disconnected programs in our Pesearch Division serves to illustrate. NRC does severe '
accident research at BNL, ORNt., LANL, Sandia, Livertnere, and-Battelle Columbus, and at myriad universities. Sometimes there is duplication of effort. But more important is the difficult job of assuring an etfective interface between computer codes (theory), experiments, and analysis to yield an integrated 4
result. Improvements are planned. For esample, the intearated This facility should themal hydraulics center planned 'or INE_,
unify the parts of thermal hydraulic exceHments, analvs1s and computer code capability.
r urthermore, in this engineering field et least, a strong tradition o' publication in respected, refereed, archival jourrels appears to be absent, and has been inadequately promoted by NRC and other responsible institutions. "The literature" Various consists largely o' laboratory, agency, and private and governmental entities responsible contractor reports.
for the research have differing ob,iectives and responsibilities. In my judpent, only the requirement that individuals achieve professional standing and reputation by the reliability of their research (common in most scientific disciplines) will guarantee the availability of an
" integrated" body of accepted knowledge in this or any other field of inquiry.
Finally, a pragmatic reason for an integrated research program is that it is more likely to be understood by the Congress. Here again, NRC is weak.
How do ycu convey a sense of urgency when programs are labeled " Thermal Hydeaulic Decision Unit," " Integral Facilities," ar.d "Semiscale Test Matrix"? Unless these programs are associated with meaningful goals (e.g.
unresolved safety issues) in the broadest policy sense, they are unlikely 5 to convince the skeptical Congressman in the era of Gramm-Rudman.
(* 7. What is your judgment of the cuality of the safety research being done?
ANSWER ?. I am impressed with the quality of many individual research projects and the expertise of the investigators. On the other hand, as described above, the discipline of publication in archival literature is badly needed. The NRC should promote and demand that discipline wherever possible, and ultimately should measure the quality of the research product by the Quantity and quality of archival publications, and by the independent reviews of disinterested expertt in the field, 8 In your opinion, is the United States fully replenishing the pool of scientific talent avaliaoie fu ccr. ducting research in nuclear safety?
ANSWER 8 No, but this unfortunate state of affairs is largely driven by the infallible ability of young people to discern where the future lies.
- 9. To what extent does the Federal Government Fave a responsibility for sustaining the technical community engcged in nuclear safety research?
ANSWER 9. In the interest of national security, the Federal Government must be mindful that a bread base of expertise is maintained in all fields of science and technology -- a
- stable of thoroughbreds" capable of meeting any technical challenge when called upon to do so. The judgment of what
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constitutes a sufficient " stable" in any field is one that must be m3de at the highest levels of government.
In my judgment, expertise in nuclear safety research and technology will be essential for the foreseeable future; it would be folly to pe M t complete disintegration of the cadre of experts in this field, just. as it would be l foolish to abandon all underlying, fundamental research in synthetic fuels proouctior,unless and until alternative energy sources are assured.
- 10. What constraints impinge on the conduct of safety research?
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ANSWER 10. I fear that bureaucratic intrusion is one of the more ~!
significant constraints. I have long argued that the community of scholars should themselves recomend directions and resource allocation for safety research. As High Energy Physics (HEPAP), Nuclear Physics (NUS/C), and other research communities have.their respective advisory panels who set i
priorities and make explicit recommendations on the most effective ve,e of available funds, so NRC should encourage the nuclear safety research comunity to establish such an independent panel to review, on an annual basis, funding and make recommendations on the best disposition thereof.
(Anticipating a cuestion: ACRS does not today, in my judgment,. provide the guidance that such a panel would, and that the NRC, at least, needs.)
By and large, governmental administrative' bureaucracies lack the expertise and insight to make such judgments; theirs should be That is the the not roleway of the NoC has i
referee, aovisory -and ultimate administrator.
l dealt with its supporting research community.
- 11. What recommendations do.you have for improving nuclear safety research?
ANSWER 11 While I recognize that the American Physical Society (APS) charter was ouite difforent from that of the present National Academy Comittee, the recent Report of the APS Study (Group on Radionuclides R from Severe Accidents [Rev. Mod. Phys, 9:51 1985)]. in its critique of j certain specific problems in nuclear saTety research, points toward generic !
problems in the management and administration of nuclear safety research.
While APS did not specifically address how the federal agency. principally responsible for funding much of that research might assist in resolving these problems, the inferences are not difficult to draw. I With that as.a startino point, and in summary of several points discussed in more detail earlier in this paper, I offer the following recommendations: .
o NRC shou?d substantially change its anoroach to the management and administration of reser.rch under its purview. The following l I
' specific measures might be explored:-
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