ML16288A471

ACRS Comments on the Safety Goal Policy and Its Relationship to the Concept of Adequate Protection

ML16288A471
Person / Time
Issue date:	10/11/1989
From:	Remick F Advisory Committee on Reactor Safeguards
To:	Carr K Advisory Committee on Reactor Safeguards
References
D891011
Download: ML16288A471 (11)

Text

D891011 The Honorable Kenneth M. Carr Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

ACRS COMMENTS ON THE SAFETY GOAL POLICY AND ITS RELATIONSHIP TO THE CONCEPT OF ADEQUATE PROTECTION During the 354th meeting of the Advisory Committee on Reactor Safeguards, October 5-6, 1989, we discussed implementation of the Commission's Safety Goal Policy and the relationship of the concept of adequate protection to this policy. This was in response to a staff requirements memorandum (SRM) from Mr. Chilk to Mr. Fraley dated August 21, 1989. We had the benefit of discussions with members of the NRC staff during this meeting. We have previously provided our views on implementation of the Safety Goal Policy in several reports to former Chairman Zech, the most recent of which was dated February 16, 1989. We also met with the Commission on this subject on May 3, 1989.

Although our discussions with the staff provided a valuable exchange of views, we have not yet come to agreement with the staff on how the concept of adequate protection should be seen as it relates to the Safety Goal Policy, nor have we yet come to agreement with how the Commission's backfit rule, 10 CFR 50.109, comports with the Safety Goal Policy. We expect to be able to clarify areas of agreement and disagreement on these matters within another month or two, after the staff has had an opportunity to consider discussions held during this meeting.

In general, our position remains as stated in previous reports. That is, on the one hand, compliance with the regulations is generally regarded as presumptive evidence that the public is adequately protected from risk associated with operation of a nuclear power plant. On the other hand, as we have proposed, adequacy of the body of regulations should be judged by whether the population of nuclear power plants built and operated under these regulations is causing risk no greater than the objectives given in the Safety Goal Policy.

We believe that the backfit rule, as just one part of the general body of regulations, should be regarded as subordinate to the Safety Goal Policy.

We have not developed a position at the present time on whether the backfit rule is entirely consistent with the policy. As we have recommended before, we believe a systematic review of the whole body of regulations and regulatory practice, to assess consistency with the safety goal, should be undertaken. We are not suggesting a massive, resource-intensive effort, but believe plans for a program with carefully developed goals and pri-orities should be started soon.

We note that, in addition to the issue of adequate protection, there were several other points in our report of February 16, 1989 that described significant disagreements with positions of the staff as expressed in their draft Implementation Plan for the Safety Goal Policy (SECY-89-102), dated

March 30, 1989. These disagreements are yet to be resolved.

Sincerely, Forrest J. Remick Chairman

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