ML19276F272
| ML19276F272 | |
| Person / Time | |
|---|---|
| Issue date: | 03/05/1979 |
| From: | Hendrie J NRC COMMISSION (OCM) |
| To: | Minnick L YANKEE ATOMIC ELECTRIC CO. |
| Shared Package | |
| ML19276F274 | List: |
| References | |
| NUDOCS 7903280178 | |
| Download: ML19276F272 (6) | |
Text
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,,eg NUCLEAR REGULATORY COMMISSION come fi,P Q
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\\,,',( 8 March 5, 1979 CH AIRMAN Mr. L. E. Minnick President Yankee Atomic Electric Company 20 Turnpike Road Westborough, Massachusetts 01581 Dear Mr.
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This responds to your letter of January 25 concerning release of the Commission's policy statement on the Reactor Safety Study (WASH-1400) and the review of that study by Dr. Harold Lewis' Risk Assessment Review Group.
First, let me say that I can understand your dilema in not being able to find out in a timely way precisely what the Commission said in its policy statement.
It was released to the press here in Washington about 1:00 p.m. on January 19, and was made available at the same time to both industry organizations and public interest groups.
Copies were handed out at the Public Document Room on January 19 even though the Public Document Room was closed on that particular day to regular users with extensive reference requirements.
Copies of the statement also were available both on Saturday and Sunday at our Washington office on the lith floor.
In retrospect, I believe we may not have given sufficient notice that this statement was irminent. We probably should have given some noti-fication to allow both the news media and interested organizations to have time to study it carefully.
I am enclosing an excerpt from my February 5 testimony before the Senate
'Conmittee on Environment and Public Works which discusses the Safety Study, the Risk Assessment Review Group Report and the Conmission's pol. icy statement, and their relationship to the health and safety regulatory system for nuclear power. plants.
I hope you will find this helpful.
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Josep M. Hendrie
Enclosure:
As stated,
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xcerpt Trom Chainnan Hendrie s 2/5/79 testimony Tne Pisk Assessment Review Group Report As ycu knew, the NRC established the Risk Assessment Review Group in I
July 1977, under the leadership of Dr. Harold Lewis, Chairman of the A?.erican Physical Society's Study Group on Light Water Reactors, with four elements to its charter:
-- clarify the achievements and limitations of WASH-1400;
-- assess the peer correnents thereon, and responses to these comments;
-- study the present state of risk assessment methodology;
-- reco=nend to the Commission how (and whether) such methodology can be used in the regulatory and licensing process.
'Ihe Review Group published its report last September, and it was provided to the Congress at that time.
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After consideration of the Review Group's findings, the Camatission issued a policy statement on January 18th simrarizing its response to the Report.
In the Statement, the Commission accepted the Report's findings and noted its actions as follows, and I quote:
" Executive Su= nary:
The Commission withdraws any explicit or implicit past endorsement of the Executive Summary.
'Tne Peer Review Process:
The Core:tission agrees that the peer review process followed in publishing WASH-1400 was ina1 equate and that proper peer review is fundamental to making sound technical decisions.
H e Comatission will take whatever corrective action is necessary to assure that effective peer review is an. integral feature of the NRC's risk assessment program.
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" Accident Probabilities:
The Commission accepts the Review Group Report's conclusion that absolute values of the risks presented should not be used uncritically either in the regulatory process or for public policy purposes and has taken and will continue to take steps to assure that any such use in the past will be corrected as appcopriate.
In particular, in light of the Review Group conclusions on accident probabilities, the Commission does not regard 'as reliable the Reactor Safety Study's numerical estimate of the overall risk of reactor accident.
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" Communication with the Congress and the Public:
Canmissioner correspondence and statements involving WASH-1400 are being reviewed and corrective
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action as necessary will be taken."
'i "With respect to the component parts of the Reactor Safety Study
, the-Commission expects the staff to make use of them as appropriate, that is, where the data base is adequate and analytical techniques perndt Taking due account of the reservations expressed in the Review Group i
- Report, and in its presentation to the Commission, the Commission supports the extended use of probabilistic risk assessment in regulatory decisionmak ng."
f The Commission has provided additional detailed instructions to the NRC staff concerning continued use of risk assessment techniques and results in response to the specific comments of the Risk Assessment Review G and has asked the staff to submit by June 30, 1979, detailed procedures
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_to ensure the proper and effective use of risk assessment theory, methods data development, and statistical analyses.
_ :g:get - Sa INSERT TO PREPARED TESTIMONY OF JOSEPH M. HENDRIE; 'ID BE INSERTED AFTER P. 8 I would note that a primary goal of the Reactor Safety Study, as established in 1972, was to obtain a~" quantitative evaluation of the risk frca the operation of a nuclear plant." The Safety Study was, I
in effect, a " measurement," made by analyzing two typical plant designs, 1
of the effectiveness of an existing system of nuclear regulation.
t Tnat regulatory system depends on having nuclear plantr sited, t
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t designed, constructed, and operated on the basis of conservative applica-ij.
- tion of sound and accepted engineering principles, on req'uirements for i
cultiple and redundant safety systems, and on a se.t of regulatory
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requirements that are updated to reflect operating experience. The ddsigners, builders, and operators of these plants are required to have effective quality assurance programs and their work is _ subjected to a continuing licensing and inspection process by the NRC.
The results k
of the licensing and inspection process are, in turn, subject to independent review by the Advisory Comatittee on Reactor Safeguards and I
often to examination in.public hearinas.
5 Tais. health and safety regulatory system, much of which evolved
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1cng before the Reactor Safety Study was carried out, is unchanged in j
I its basic princ nes today.
It does not depend on the ability to make precise quantitative estimates of overall risk -- although that ability would be highly useful and should be developed..
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Budget - 8b We believe this regulatory system has served us well.
It is an exceptionally rigorous system, and appropriately so in' view of the
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technology we regulate.
It is our job as regulators to make sure that' i
there is no undue risk from licensed facilities and, while one must i
acknowledge strongly held views to the contrary, over 400 reactor-years j
t of experie'nce to date give us reason to believe that we are on the right track.
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1 hhat the Lewis group has told us is that the " measurement" of our
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regulatory system, as reflected in the overall risk estimates of the Reactor Safety Study, is much less precise than had been asserted.
The Lewis group did not conclude that the overall risk estimates were higher r
or lower than reported in WASH-1400, although they speculated on possible j
l factors in both directions, but only that they thought the error bands j
on those estimates were_ substantially larger than had been reported.
On I
that account, they recomended to us that the overall risk estimates of t
WASH-1400 should be used with great caution -
"should not be used
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uncritically" were their words -- in the regulatory process or for-public policy purposes.
We have accepted and are implementing with, vigor that recommendation, ss well as the other findings and recommenda-tions of the Lewis group.
We are also carefully reviewing past regulatory decisions to ascertain whether actions contrary to those, recomr.endations have been taken.
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. Eudget - Sc To sta up, it is important to keep in mind what the Commission did er.3 did not do in response to the Lewis Report.
It did reevaluate its E-reliance on, and relationship to, the Reactor Safety Study.
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However, it
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did not thereby take a new view of reactor safety.
E Nor did the Commission
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take a new view of past licensing decisions that each licensed plant I*
will be so operated as to provide adequate protection to the health and.
safety of the public.
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