ML19256A587
| ML19256A587 | |
| Person / Time | |
|---|---|
| Issue date: | 12/27/1978 |
| From: | Bennett G NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Budnitz R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML19256A581 | List: |
| References | |
| RTR-WASH-1400 NUDOCS 7901090057 | |
| Download: ML19256A587 (1) | |
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DEC2 71978 10:
Robert J. Budnitz Deputy Director, RES FROM:
Gary L. Bennett, Chief Research Support Branch, RSR
SUBJECT:
STAFF VIEWS Otl RESULTS OF SURVEY OF USES OF WASH-1400 In response to your memorandum of December 22, 1978 on the same subject, I would like to corment on item (b) in Mr. Gossick's memorandum of December 20, 1978.
With regard to reconmendations for reconsideration of certain uses, I list the following:
1.
The safety analysis and acceptance of nuclear power plants should be done with a probabilistic event / fault tree approach.
2.
The introduction of regulatory requirements, (including regulatory guides, branch technical positions, standards and the Code of Federal Regulations) should only be done after a thorough value/ impact analysis which includes a probablistic event / fault tree systems analysis. This recommendation also applies to proposed backfitting of hardware.
3.
Formal decision analysis techniques, including event / fault trees, should be required for every allocation of resources.
While one can fault the WASH-1400 approach as an overextension of the methodology, to me the alternative is worse:
decisions made with no explicit consideration of the decision maker's values or the consequences of the decision.
I have sat in Regulatory Requirements Review Committee meetings when decisions to impose additional requirements were made on the basis that it made certain people feel better.
I emphatically disagree with this method of regulating a multibillion dollar industry.
f;RC must discipline itself to act in a responsible, thoughtful manner. We must focus our attentions on the real substantive issues and not have our efforts diluted by a myriad of "nonissues".
I believe that a disciplined application of the probabilistic risk analysis technicues can aid us to focus our limited resources on the key issues.
The ultimate advantage of the event / fault tree methodoiogy is that it forces people to look beyond their own narrow interests to the total system.
4 Gary L. Bennett, Chief f'
Research Support Branch, RSR 6
cc's (see next page) 790109 oM7
DECP 71c 9 cc:
Saul Levine Thomas E. Murley F. J. Arsenault A.-R.
Buhl R. M. Scroggins L. S. Tong C. fl. Kelber
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