ML25168A077
| ML25168A077 | |
| Person / Time | |
|---|---|
| Issue date: | 07/15/1983 |
| From: | Libarkin M Advisory Committee on Reactor Safeguards |
| To: | Dircks W NRC/EDO |
| References | |
| Download: ML25168A077 (1) | |
Text
MEMORANDUM FOR:
FROM:
SUBJECT:
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555 July 15, 1983 W. J. Dircks Executive Di r Operations (Y\. lJ' M. W. Libarkin, Acting Executive Director Advisory Committee on Reactor Safeguards ADDITIONAL ACRS COMMENTS ON THE PRIORITIZATION OF GENERIC ISSUES During its 278th meeting, June 9-11, 1983, the ACRS reviewed the adequacy of the NRC Staff's assignment of priority rankings to a group of generic issues, and transmitted its comments to you through a memorandum from R. F. Fraley, dated June 20, 1983.
During its 279th meeting, July 7-9, 1983, the ACRS reviewed the proposed priority rankings of an additional group of remaining generic issues, and its comments are contained in the following attachments:
- Attachment 1 lists those items for which the ACRS agrees with the priority rankings proposed by the NRC Staff.
- Attachment 2 includes a list of items for which the ACRS agrees with the priority rankings proposed by the NRC Staff, but has comments.
- Attachment 3 contains a list of items for which the ACRS disagrees with the NRC Staff's proposed priority rankings along with th':! reasons therefor.
It is requested that the NRC Staff provide written responses to the ACRS comments identified in Attachments 2 and 3.
Cognizant ACRS Subcommittees or the ACRS may review the NRC Staff's responses.
Pl ease note that in the June 20, 1983 memorandum from R. F. Fraley to
- w. J. Dircks,
Subject:
ACRS Comments on the Prioritization of Generic Issues, the following issues had inadvertently been included in Attachment 1, the list of items for which the ACRS indicated agreement with the NRC Staff's assignment of priority:
II.J.3.1 Organization and Staffing to Oversee Design and Construction III.A.3.4 Nuclear Data Link 2447
W. July 15, 1983 The ACRS actually disagrees with the priority rankings proposed by the NRC Staff for these issues, and the Committee I s recommendations and the reasons therefor are contained in Attachment 3 to this memorandum.
The ACRS will continue its review of the proposed priority rankings for the remaining generic issues and will provide additional comments as they become available.
Attachments:
As Stated 2448
New Generic Issues 8
9 10 13 18 24 27 Task Action Items A-16 A-27 A-30 B-10 B-11 B-13 B-15 B-1_7 B-18 B-19 B-20 Pl an ATTACHMENT 1 LIST OF ITEMS FOR WHICH THE ACRS AGREES WITH THE PRIORITY RANKINGS PROPOSED BY THE NRC STAFF Title Inadvertent Actuation of Safety Injection in PWRs Reevaluation of Reactor Coolant Pump Trip Criteria Surveillance and Maintenance of TIP Isolation Valves and Squib Charges Small-Break LOCA from Extended Overheating of Pressurizer Heaters Steam-Line Break With Consequential Small LOCA Automatic Emergency Core Cooling System Switch to Recirculation Manual Vs Automated Actions Steam Effects on BWR core Spray Distribution Reload Applications Adequacy of Safety-Related DC Power Supplies Behavior of BWR Mark III Containments Subcompartment Standard Problems Marviken Test Data Evaluation CONTEMPT Computer Code Maintenance Criteria for Safety-Related Operator Actions Vortex Suppression Requirements for Containment Sumps Thermal-Hydraulic Stability Standard Problem Analysis 2449
Task Action Plan Items (Cont'd)
B-52 B-54 B-59 B-61 B-69 C-3 C-4 C-5 C-6 TMI Action Pl an Items I. A.1. 4 I.A.2.2 I.A.2.4 I.A.2.6(1)
I.A.2.6{2)
I.A.2.6(3)
I. A. 2. 6{ 4)
I.A.2.6(6)
I.A.2.7 I. A. 3. 3 I.A.3.4 I.A.3.5 ATTACHMENT 1 (Cont'd)
Fuel Assembly Seismic and LOCA Responses Ice Condenser Containments N-1 Loop Operation in BWRs and PWRs Allowable ECCS Equipment Outage Periods ECCS Leakage Ex-Containment Insulation Usage Within Containment Statistical Methods for ECCS Analysis Decay Heat Update LOCA Heat Sources Long-Term Upgrading Training and Qualifications of Operations Personnel NRR Participation in Inspector Training Revise Regulatory Guide 1.8 Staff Review of NRR 80-117 Revise 10 CFR 55 Operator Workshops Nuclear Power Fundamentals Accreditation of Training Institutions Requirements for Operator Fitness Licensing of Additional Operations Personnel Establish Statement of Understanding with INPO and DOE 2450
TMI Action Plan Items (Cont'd)
I.A.4.1(1}
I.A.4.1 (2)
I.A.4.2(1)
I.A.4.2(2)
I.A.4.2(4)
I.A.4.3 I. A. 4. 4 I.C.1(4)
I.D.5(2)
I.D.5(3}
I.D.6 I.G.2 11.E.2.l II.E.2.2 IV. A. l IV.A.2 IV.D. l IV.F. l IV.F.2 IV. G. 1 IV.G.2 IV.G.3 IV.G.4 ATTACHMENT 1 (Cont'd}
Short-Term Study of Training Simulators Interim Changes in Training Simulators Research on Training Simulators Upgrade Training Simulator Standards Review Simulators for Conformance to Criteria Feasibility Study of Procurement of NRC Training Simulator Feasibility Study of NRC Engineering Computer Confirmatory Analyses of Selected Transients Plant Status and Post-Accident Monitoring On-Line Reactor Surveillance System Technology Transfer Conference Scope of Test Program Reliance on ECCS Research on Small-Break LOCAs and Anomalous Transients Seek Legislative Authority Revise Enforcement Policy NRC Staff Training Increase IE Scrutiny of the Power-Ascension Test Program Evaluate the Impacts of Financial Disincentives to the Safety of Nuclear Power Plants Develop a Public Agenda for Rule Making Periodic and Systematic Reevaluation of Existing Rules Improve Rule Making Procedures Study Alternatives for Improved Rule Making Process 2451
ATTACHMENT 2 LIST OF ITEMS FOR WHICH THE ACRS AGREES WITH THE PRIORITY RANKINGS PROPOSED BY THE NRC STAFF, BUT WITH COMMENTS Issue No:
22
Title:
Inadvertent Boron Dilution Events Proposed NRC Staff Priority:
DROP ACRS Comments:
Considering the "worst" of the designs, it should be ascertained that the probability of a radiation injury or fatality to plant personnel working in the vicinity of the core is acceptably low.
Issue No:
B-8
Title:
Locking Out of ECCS Power Operated Valves Proposed NRC Staff Priority:
DROP ACRS Comments:
The NRC Staff suggests dropping this item since no significant accident initiators have been identified to date. However, the Staff has not examined any plant PRAs in this regard.
Although the ACRS agrees with the proposed priority ranking for now, it plans to explore the significance of this item vis-a-vis available PRAs.
In the event of significant findings, the ACRS m_ay request a reopening of this item.
2452
Issue No:
Title:
Proposed NRC Staff Priority:
ACRS Comments:
Issue No:
Title:
Proposed NRC Staff Priority:
ACRS Comments: ATTACHMENT 2 (Cont'd}
8-53 Load-Break Switch REGULATORY IMPACT ISSUE (Possible Resolution Identified for Evaluation}
The question as to whether the grid or the plant main generator should be used as the preferred source of AC power should be examined in the near future either under this activity or under a new activity.
I.A.3.2 Operator Licensing Program Changes RESOLVED The ACRS agrees that the specific actions called for under this item have been adequately addressed. However, signi-ficant operator licensing program changes are still under way and necessary.
The appropriate content and form of licensing examinations arein question.
The qualifications required for license examiners need to be specified.
2453
ATTACHMENT 3 LIST OF ITEMS FOR WHICH THE ACRS DISAGREES WITH THE PRIORITY RANKINGS PROPOSED BY THE NRC STAFF Issue No:
A-29
Title:
Nuclear Power Plant Design for the Reduction of Vulner-ability to Industrial Sabotage Proposed NRC Staff Priority:
MEDIUM ACRS Recommendation:
HIGH Reasons:
The ACRS believes that the topic of interest is the reduction of nuclear power plant vulnerability to industrial sabotage.
Industrial sabotage at nuclear power plants is a sensitive issue which receives significant r,'Ublic attention. A-29 should not be restricted in scope so as to address only design changes to nuclear power plants.
The Staff needs to consider sabotage in the broadest possible terms and to ensure that the opportunities and likelihood for sabotage are as 1 ow as reaso*nably achievable.
The ACRS recognizes the difficulties inherent in using probabilistic techniques to determine public risk due to acts of sabotage.
"Re sol u-tion" of this issue most probably will consist of applying serious, broad, and continuing attention to the matter.
The ACRS believes that the scope of A-29 should be expanded and a priority ranking of HIGH should be assigned.
Issue No:
A-41
Title:
Long-Term Seismic Program Pro~osed NRC Sta f Priority:
MEDIUM ACRS Recommendation:
HIGH Reasons:
This program should be augmented or a new activity established as per the ACRS letter of January 11, 1983, to Chairman Palladino, related to the Quantification of Seismic Safety Margins.
2454
Issue No:
Title:
Proposed NRC Staff Priority:
ACRS ATTACHMENT 3 {Cont'd) 8-30 Design-Basis Floods and Probability LICENSING ISSUE Recommendation:
HIGH Reasons:
The NRC currently lacks a quantitative basis for evaluating this event.
Issue No:
B-50
Title:
Post-Operating Basis Earthquake Inspection Proposed NRC Staff Priority:
REGULATORY IMPACT ISSUE ACRS Recommendation:
MEDIUM Reasons:
Some advanced planning as to what would be required before plant startup should be done to avert unnecessarily long and expensive shutdowns and to assure that the proper actions would be taken.
Issue No:
D-1
Title:
Advisability of a Seismic Scram Proposed NRC Staff Priority:
DROP ACRS Recommendation:
MEDIUM Reasons:
The NRC Staff has not adequately evaluated this issue nor obtained an understanding as to the basis for this require-ment by the Japanese.
Similarly, the British are currently reviewing the advisability of a seismic scram.
2455 ATTACHMENT 3 {Cont'd)
Issue No:
D-2
Title:
Emergency Core Cooling System Capability for Future Plants Proposed NRC Staff Priority:
Covered in USI A-45 ACRS Recommendation:
MEDIUM Reasons:
The focus of USI A-45 is on current-generation plants, not future plants as Item D-2 implies.
In addition, based on its review and discussion with the cognizant NRC Staff, the ACRS believes that this item is not covered in USI A-45.
As the ACRS has noted in a recent report to the Commission on the NRC Safety Research Program Budget for FY 1985 and 1986, the current Appendix K requirements have influenced, and will continue to influence the design and operation of ECC systems in a manner that could be deleterious to the overall concerns of ECC.
The ACRS believes that the NRC Staff should carry this as a separate generic issue, with a MEDIUM priority, and explore it in the context of the ongoing RES effort to revise Appendix K of 10 CFR Part 50.
Issue No:
I.A.2.5
Title:
Plant Drills Proposed NRC Staff Priority:
MEDIUM or HIGH Reasons:
The ACRS questions the technical basis for the assumptions made to compute the risk reduction potential associated with this issue. Because of uncertainties in the assump-tions made, coupled with the fact that the Value/Impact Score indicated that the ranking of this issue would be LOW to MEDIUM, the conservative approach would be to assign a MEDIUM priority to this issue (at least until better information is obtained). Also, matters related to simulator fidelity and validity of training programs are being pursued with high priority under several human factors generic issues. This suggests that a higher priority might be warranted.
2456
Issue No:
Title:
Proposed NRC Staff Priority:
ACRS ATTACHMENT 3 (Cont'd)
I.A.2.6(5)
Develop Inspection Procedures For Training Program RESOLVED Recommendation:
MEDIUM Reasons:
Why is this considered RESOLVED when RES has a research program under way that should provide some criteria for assisting in training effectiveness evaluation? In addi-tion, Staff efforts are under way to respond to Public Law 97-425.
The Staff's proposed package in response to the Act includes a new training and qualification rule, a new training regulatory guide, and revised NRC inspection modules.
Since the training regulatory guide and inspection modules (not yet developed) will provide detailed guidance to the industry and inspectors, and since the Staff intends to recommend 2-5 years for Industry to comply with the new training rule/guidance, a MEDIUM priority seems appropriate.
Finally, one of the 23 tasks contained in the Human Factors Program Plan also deals with this specific topic. Since extensive Staff resources are being expended in this area, how can this issue be considered RESOLVED?
Issue No:
I.A.4.2(3)
Title:
Regulatory Guide on Training Simulators Proposed NRC Staff Priority:
RESOLVED ACRS Recommendation:
MEDIUM or HIGH Reasons:
While Regulatory Guide l.149, "Nuclear Power Pl ant Simula tors For Use in Operator Training" was published to endorse the revised ANSI/ANS 3.5-1981, additional training simulator changes still need to be made.
Regulatory Guide 1.8 should be evaluated and revised as necessary in light of the ongoing simulator research.
The Staff plans to make another revision to Regulatory Guide 1.149. This revision will continue to endorse ANSI/ANS 3.5-1981 (with some exceptions) but will require nuclear power plants to have a plant referenced simulator or other facility proposed device acceptable to the NRC.
Continued expenditure of Staff resources in this area appears appropriate.
2457
Issue No:
Title:
Proposed NRC ATTACHMENT 3 (Cont'd)
I.B.l.l Organization and Management of Long-Term Improvements, including:
I.8.1.l(l) Prepare Draft Criteria I.B.l.1(2) Prepare Commission Paper I.B.l.1(3) Issue Requirements for the Upgrading of Management and Technical Resources I.B.l.1(4) Review Responses to Detennine Acceptability I.B.l.1(6) Prepare Revisions to Regulatory Guides 1.33 and 1.8 I.B.l.1(7) Issue Regulatory Guides l.33 and 1.8 Staff Priority:
MEDIUM ACRS Recommendation:
HIGH Reasons:
The ACRS believes that improvements to a utility's management and organization will reap benefits other than human-error rate reduction. These other benefits (e.g., improved produc-tivity, improved plant quality, reduced absenteeism and turnover rate, etc.) should be taken into account when determining the priority for these items.
The ACRS believes that such an analysis would indicate that these items should receive a HIGH priority. The ACRS would also like to caution the Staff that human-error rates vary greatly with managerial systems (probably much more than 0-2oi).
Human factors experts should be actively involved in evaluating the assumptions made to arrive at the total risk reduction.
2458
Issue No:
Title:
Proposed NRC Staff Priority:
ACRS ATTACHMENT 3 (Cont'd)
I.B.1.1(5)
Review Implementation of the Upgrading Activities RESOLVED Recommendation:
HIGH Reasons:
The Staff states that, since the Office of Inspection and Enforcement (IE) routinely develops and issues inspection procedures which address new or revised regulations and requirements, this item is considered as RESOLVED.
Since utilities will be required to submit a new proposed organi-zation and management plan which will be reviewed by the NRC (including ij site review), and since the IE Staff will perform annual assessments to assure each utility is satisfactorily meeting NRC management and organization requirements (as identified in the initial NRR plant review), it seems that this issue should remain open until after the first IE audit subsequent to NRC approval of each utility's organization and management plan.
The priority assigned to this item should be commensurate with other items in I. B. 1. 1.
2459 ATTACHMENT 3 (Cont'd}
Issue No:
I.C.9
Title:
Long-Term Program Plan for Upgrading of Procedures Proposed NRC Staff Priority:
MEDIUM ACRS Recommendation:
HIGH Reasons:
The Staff's analysis concludes that resolution of this i~em might result in a total reduction in public risk of SxlO man-rem.
This is the safety importance at which an item would change from a MEDIUM to a HIGH priority. This risk reduction is based on a uniform 30% improvement in human error, including maintenance, through the dominant accident sequences. This 30% improvement includes improvements due to upgraded Emergency Operating Procedures {EOPs} which are no longer being considered as part of I.C.9.
The Staff assumes that 70% of the 30% improvement will result from upgrading EOPs and the remaining 30% will result from upgrading other procedures (e.g., normal, abnormal, main-tenance~ etc.}.
In view of the high safety importance associated with this item and the ACRS' belief that more than 30% of the total benefits derived from upgrading procedures {including EOPs} will be accrued by upgrading normal, abnormal, and maintenance procedures (excluding EOPs), the ACRS believes that this item should be assigned a HIGH priority. It is also important for the NRC to recognize that improving job design {e.g. procedures, hardware, etc.} is as important as modifying people {e.g.,
training} in reducing human errors at nuclear_ power plants.
2460
Issue No:
Title:
Proposed NRC ATTACHMENT 3 {Cont'd)
I.D Control Room Design, including:
I.D.3 I.D.4 I.D.5(5)
Safety System Status Monitoring Control Room Design Standard Disturbance Analysis Systems Staff Priority:
MEDIUM ACRS Recommendation:
HIGH Reasons:
There is overwhelming evidence that poorly designed control rooms contribute to operator error. Emphasis on the machine side of the man-machine interface {to reduce human error) is as important as the selection and training of plant personnel.
In addition, the weak link in reactor operations appears to involve diagnosis of the root cause of a plant's upset condition. Diagnosis involves cognitive skills such as judgment, problem solving, and decision making.
Control room operators need all the help they can get in a time of upset ~ant conditions.
2461
ATTACHMENT 3 (Cont'd)
Issue No:
I.D.5(1)
Title:
Operator-Process Communication Proposed NRC Staff Priority:
RESOLVED ACRS Recommendation:
HIGH Reasons:
While RES has issued a Research Information Letter (RIL-124) that provides recommendations for future action related to the operator-machine interface in reactor control rooms, this item should not be considered as RESOLVED until either those actions are carried out or they are deemed unnecessary.
The ACRS believes that this item should be assigned a HIGi priority similar to other items unaer general topic I.D, Control Room Design.
Issue No:
I.D.5(4)
Title:
Process Monitoring Instrumentation Proposed NRC Staff Priority:
RESOLVED ACRS Rec01T1mendation:
HIGH Reasons:
NRC has been evaluating number of systems (e.g., liquid level monitoring) at the LOCA experimental facilities at ORNL and INEL.
While this work is almost completed, this item should remain open until research results are docu-mented and regulatory guidance has been provided to the nuclear power industry.
The ACRS believes that completion of this ongoing work should be given a HIGH priority.
2462
Issue No:
Title:
Proposed NRC Staff Priority:
ACRS ATTACHMENT 3 (Cont'd)
II.E.2.3 Uncertainties in Perfonnance Predictions LOW Recommendation:
MEDIUM Reasons:
Higher priority should be given to the evaluation of uncertainties for small breaks.
Issue No:
II.E.6.1
Title:
Test Adequacy Study Proposed NRC Staff Priority:
MEDIUM ACRS Recommendation:
HIGI Reasons:
Disagree with the reliability initially assigned to new valves operating under adverse or design conditions.
Also, the Staff's analysis assumes that an improved testing program would reduce valve failures by 5 percent.
Can this number be justified?
Improved inservice testing of valves should make use of base-line data obtained from the valve in its new condition, e.g.,
a strip chart recording taken as the valve was cycled would show the approach to inoperability better than the leak rate tests or periodic cycling that are now used.
In addition, effort should be made to develop dynamic tests for both new and inservice valves to assure their operability under design loads.
2463 ATTACHMENT 3 (Cont'd)
Issue No:
II.J.3.1
Title:
Organization and Staffing to Oversee Design and Construction Proposed NRC Staff Priority:
MEDIUM ACRS Recommendation:
HIGH Reasons:
See comments related to I.B.1.1 (Page 5, Attachment 3)
Issue No:
III.A.3.4
Title:
Nuclear Data Link Proposed NRC Staff Priority:
MEDIUM ACRS Recommendation:
DROP Reasons:
The ACRS believes that the proposed Nuclear Data Link should not be implemented.
2464