ML19260E026
| ML19260E026 | |
| Person / Time | |
|---|---|
| Issue date: | 06/13/1979 |
| From: | Michelson C Advisory Committee on Reactor Safeguards |
| To: | Carbon M Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML19260E024 | List: |
| References | |
| REF-QA-99900400 NUDOCS 8002130145 | |
| Download: ML19260E026 (2) | |
Text
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ENCLOSURE 1 pr. nc 3
'o UNITED STATES iV, NUCLEAR REGULATORY COMMISSION v
e 5-ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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o WASHINGTON, D. C. 20555
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June 13,1979 TMs rytriny eccln prgrictary or other L6 tat.'en WMsk"M B8 prc sted frnr.: pub 2discb:ure., it shouhinot be tekssed untila r:12W gggggg@:Etkg hesaClQl teg.
i TO:
Dr. Max Carbon
/
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FROM:
C. Michelson, ACRS Consultant [.,k
SUBJECT:
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OIE Investigation of Very Small Break LOCA Report Dated January,1978 On May 21,1979, I was interviewed by Bill Ward of OIE concerning the history of my January,1978 report on very small break LOCA performance for B'W plants. At that time T ex'ressed some thoughts concerning how to handle certain types of safety i: ues which did not seem to fit the reporting requirements of 10 CFR Par t 21 or 50.55(e).
In particular, hcw should new ideas or views be ivorted that could have an adverse affect on safety if subsequently verified, but which are not presently verified and may even be contrary to well establisheo views. On June 11, I received a call from Lawrence Stickler of OIA seeking some additional clarifications concerning the earlier interview and any farther thoughts on the reporting issue. The purpose of this letter is to document these views, which are my own, concerning reporting requirements.
The reporting of defects and noncompliance under Part 21 or 50.55(e) is a relatively straightforward process when dealing withiexisting hardware and analyses. However, the situation becomes very fuzzy when dealing with the reporting of new or unusual concepts or ideas even though they could conceivably lead to a determination that safety significant defects or noncompliances exist in the present hardware or analyses. New or unusual concepts or ideas must be developed and nurtured before they can be brought forth as a challenge to the exist-ing scheme of things.
In my opinion, a means must be provided to encourage an early disclosure of such concepts or ideas so that timely development is assured. This should lead to an early deter-mination of validity that can then establish whether or not a safety significant defect or noncompliance exists.
Reporting under Part 21 or 50.55(e) does not seem to fit this situation very well since these regulations are written from the viewpoint that something may already be wrong rather than from the viewpoint that there may be a new or unusual way of thinking which could eventually conclude that something is wrong.
There ought to be a forum for freely expr!ssing such concerns infomally, although it is not clear that it would be enforceable by regulation. A route into the regulatory process
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2 is needed which encourages an early but informal hearing and consideration of such concerns and assures that worthy items are identified for formal consideration by the regulatory process.
Perhaps the ACRS could encourage the provision of such a route within the NRC.
It should also be recognized that new ideas or unusual concepts will originate from within the regulatory process, but, for various reast.ns, may not be effectively aired in the originating organization. The pro-posal route could provide as apprcpriate form for such internal views.
cc: Bill Ward (0IE)
Lawrence Strickler (OIA)
Raymond Fraley 4