ML19280A376
| ML19280A376 | |
| Person / Time | |
|---|---|
| Issue date: | 08/12/1980 |
| From: | Bickwit L, Hanrahan E NRC OFFICE OF POLICY EVALUATIONS (OPE), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| References | |
| FRN-45FR71023, RULE-PR-50, TASK-CA, TASK-SE 45FR71023, SECY-80-379, NUDOCS 8009100422 | |
| Download: ML19280A376 (28) | |
Text
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^" " '*' "' CO M M ISSIO N ER ACTIO N
"~* ~'"
FOR:
in ers
,4 FROM:
Edward J. Han en, Director Office of Policy Evaluation Leonard Bickwit, Jr.
+
General Counsel
SUBJECT:
PROPOSED PLAN FOR DEVELOPING A SAFETY GOAL CONTENTS:
Page PURPOSE 2
BACKGROUND 2
1.
Commission Request 2
2.
Work Status 2
3.
Legislation 3~
DISCUSSION 4
1.
The Safety-Goal Issue and Its Parts 4
2.
Program Approach 5
3.
Organization and Management 7
PROPOSED PLAN 8
1.
Objective 8
2.
Scope 8
3.
Overall Plan and Schedule 8
4.
Tasks 8
5.
Public Participation 13 6.
Organization 14 7.
Program Adjustment 14 RECOMMENDATIONS 15 ENCLOSUR D 1.
Status of NRC Work 2.
Description of RES-Sponsored Projects 3.
Draft Staff Requirements memorandum 4.
Draft Federal Register notice riiiCT:
a Sege (OPE) ch (0GC)
Oogg
. PURPOSE:
To propose for Comission consideration and approval a plan for development and articulation of NRC safety objectives, notably -- but not exclusively -- with respect to reactors; with special attention to interim objectives attainable in the near term, but including consideration of an overall program as well.
BACKGROUND:
1.
Comission Request In connection with its consideration of SECY-80-230B,
" Update of Chapter V of TMI Action Plan:
NRC Policy, Organization, and Management," the Comission directed OPE and 0GC to prepare a proposed plan for developing a safety goal, to be submitted to the Comission in August 1980.
The plan was to include provisions for utilizing on-going efforts by the Office of Research, NRR, and the ACRS, which are scheduled to be completed in October 1980.
(Memo, Secretary to ED0/GC/0PE/0PA, 7-9-80, at item 9.)
This paper responds to that Comission direction.
The Comission further directed that OPE submit, by December 29, 1980, a draft safety policy statement for Comission consideration and public comment.
(Memo, Secretary to ED0/GC/0PE/0PA, 7-9-80, at item 10.)
Provision for that draft policy statement is included in the proposed plan.
The Comission had previously stated its intentions in this regard:
. In its FY 1982-86 Policy, Planning, and Program Guidance, the Comission stated its intent to seek to define more clearly the level of protection of the public health and safety that it believes is adequate.
. In its letter to Dr. Press comenting on the Kemeny rep _ ort, the Comission stated that it is prepared to move forward iith an explicit policy statement on safetv philosophy and on the role of safety-cost tradeoffs in NRC safety decisions.
2.
Work Status Pertinent work has been or is being done or sponsored by OGC, the ACRS, RES, and NRR.
The~~ status of these efforts is presented in Enclosure 1 (supplemented with further detail concerning the RES-sponsored efforts in Enclosure 2).
s The NRC and others have underw&y a number of probablistic plant analyses which are producing estimates of the prob-ability of significant accident sequences (severe core damage or core melt sequences).
The Probablistic Analysis Staff (Office of Research) has been suggesting the use of interim criteria and priorities for taking corrective action pending forme-development of numerical criteria.* The interim criteria suggested by PAS are as follows:
Estimated Probability of Severe Core Damage, Per Year Action Greater than 10-2 Correct in days 10-2 to 10-3 Correct in month's 10-3 to 10-4 Correct in years 10-4 to 10-5 Consider correction Less than 10-5 No action Users of these interim criteria are urged to weigh possible bias in the analysis, the quality of the analysis, the potential scale of consequences, and other significant factors in applying them.
3.
Legislation The Senate Environment Comittee's NRC Authorization bill for FY 1981, S. 2358, would require NRC, after notice and appertunity for public hearing, to develop a safety goal for reactor regulation.
The goal would be required to delineate subjective criteria, supplemented to the extent possible by quantitative criteria.
The bill calls for consideration.of retroactive -- as well as prospective --
application of the goal.
It specifies a June 30, 1981, deadline for a repor.t to Congress.
(Section 5 of S. 2358, 2-28-80.)
This bill has not yet passed the Senate.
There is no corresponding provision in H.R. 6628, the House version of the NRC FY 1981 authorization, as reported by either the Comittee on Interior and Insular Aff airs or the Comittee on Interstate and Foreign Commerce.
- (1) " Interim Quantitative Action Criteria," R. Bernero (PAS) to R. Mattson (NRR),7/29/80.
(2) " Crystal River IREP Study and Interim Criteria for Action,"
R. Benero to R. Mattson, 7/22/80.
(3) R. Bernero, oral presentation at Duke Power Co./NSAC Seminar on Oconee Risk Assessment, Charlotte, N.C., 7/22/80.
(4) R. Bernero, oral presentation before ACRS Subcomittee on Reliability and Probabilistic Assessment, Los Angeles, 7/1/80.
. DISCUSSION:
1.
The Safety-Goal Issue and its Parts The basic principle of a safety goal and its application is simple:
a general degree of safety is established as a goal and rules are made and licensing actions taken with that goal in mind.
Ideally the goal would be translated into actual decision standards by Comission rules, and the rules (rather than the goal itself) would be applied in individual cases.
In practice, development of a safety goal is subject to complications which are of the essence of the issue. They stem from data-base gaps, which limit knowledge of what the risks are; different philosophical perspectives as to criteria that should be used to define when a risk is " acceptable"; and important subsidiary issues, such as those involving economic and equity con-siderations, and techniques of interpretation under uncertainty.
The questions constituting these essential parts of the issue can be articulated and grouped in many ways.
In fact, such articulation and grouping are expected to evolve as the policy development work progresses.
The following is a starter list, compiled for initial planning purposes and as a point of departure for later modifications:
a.
What estimated risks flow from available licensing-policy options?
(1) What uncertainties surround those estimates?
b.
What known risk levels are acceptable?
(1) What uncertainties are acceptable?
(2) To what extent is there increased aversion to risk of high consequences even at low probability?
c.
What constrains safety requirements that NRC should impose?
(1) What is the role of safety-cost tradeoffs?
(2) To what extent should benefits of nuclear power
-- absolute and relative to alternatives -- enter safety-requirement decisions?
(3) To what extent is it appropriate for requirements for new and previously approved plants to differ?
(4) How should stringency of safety goals compare with risks accepted from other (non-nuclear) electrical energy sources and with risks arising in various other contexts?
. (5) To what extent should equities of distribution of benefits and adverse impacts influence safety requirements?
(6) Should safety goals be applied directly to cases, in order to attain a similar degree of safety from case to case (even though that may result in specific design and oepration requirements differing according to circumstances)? Or should goals be applied generically and have requirements, rather than estimated degree-of-safety results, be uniform?
(7) To what extent should goals reflect protection of individuals regardless of numbers of persons affected, and to what extent should they reflect total, integrated population or societal effects?
d.
What policies are appropriate in the face of gaps in knowledge as to what the risks are and the need for clarity of licensing requirements?
(1) Should there be an overall top-level safety-goal policy that would control lower-order specific decision classes, with toleration of uncertainties in interpretation of overall policy in terms of specific regulations? Or should goals be defined in operationally useful form for narrower areas, thereby achieving better predictability of require-ments, though at the cost of losing some overall philosophical consistency and conceptual completeness?
(2) What is the proper balance between stability of requirements and flexibility for modification as knowledge develops and insights change?
e.
In view of inherent uncertainties, how should probability estimates and consequence predictions be verified?
f.
Under uncertainty as to goals or imprecision of goals or doubts as to their interpretation, how should judgments be made in:
(1) Establishing generic requirements?
(2) Cases?
2.
Program Approach The proposed program approach focuses in the near term on (a) general policy statements, (b) articulation of policy with respect to parts of the issue, and (c) isolation of
. more difficult questions for further consideration.
The approach rests on recognition that even if a full and definitive resolution of the safety-goal issue is not a practical near-term objective, highly useful purposes can be served by significant limited contributions to the objectives.
In addition, the policy development process itself can perform a useful function of illuminating the safety-goal issue and its place in regulation, thereby helping to rationalize regulatory decision-making.
The proposed program emphasizes development of options for near-term Comission action, while also providing for foundation-laying for subsequent further development of policy.
The method of approach includes the following elements:
. Utilization of rssults and interim results of ongoing NRC efforts (ACRS, RES, NRR).
. Consideration (and, as appropriate, solicitation) of inputs from outside groups with considered views (AIF, EPRI, other industry groups; nuclear-critic groups).
. Performance of background studies (past AEC/NRC practices, practices of other agencies, approaches in other industrial countries, theories and facts of risk acceptance).
. Workshops, for discussion among knowledgeable persons of varied viewpoints.
. Solicitation and consideration of public comments, with wide and varied opportunities for public participation (including public availability of papers for coment, public meetings, and public attendance at workshops, etc.).
. Reception and development of a broad range of alternatives before narrowing to a limited number of significant options (and ultimately perhaps a single recommended approach).
. Staff papers for Comission consideration at critical stages of policy analysis.
. Opportunities for Comission guidance as the work pro-gresses.
Preliminary Comissioner views will be sought in interviews early in the program.
The form of eventual Comission action (policy statement, rulemaking, etc.) is left open at this time.
. Should there be legislative direction concerning this work, its scope and schedule will be reviewed in light of legislative requirements. The thrust of the Senate Environ-mental Committee's bill (Section 5 of S. 2358, 2-28-80) was taken into account in planning, but we judged it to be premature to rely on the scope and schedule specifics of that bill in structuring the program.
3.
Organization and Management The capabilities of the ACRS and all pertinent NRC offices will be utilized, supplemented by consultants and contractors as necessary.
The proposed plan gives program responsibility to OPE, working with an Inter-0ffice Steering Group, chaired by the Director, OPE.
~ PROPOSED PLAN:
1.
Objective To develop an explicit articulation of policy with respect to the fundamental issues of public health and safety and the level of protection the Commission believes is adequate.
2.
Scope The policy articulation to be developed will include some general approach to risk acceptability and safety-cost tradeoffs, and, to the extent that these reasonably lend themselves to articulation, quantitative safety goals, safety improvement goals, and standards for review of past actions in light of new rules and improved practices.
The w'ork will deal primarily -- but not exclusively --
with power reactors.
3.
Overall Plan and Schedule The proposed plan is keyed to submittal of two papers for Comission consideration and public comment, as follows:
. A preliminary policy paper by December 29, 1980, as directed by the Commission.
. A policy paper within a year of submittal of this plan.
The milestones are presented in Table 1.
4.
Tasks The proposed work consists of the tasks described below.
Task I:
LIAIS0N 1.
Follow ongoing NRC and NRC-sponsored activities (in-cluding ACRS, RES, and NRR).
Obtain final and interim results for consideration in the program.
Principal early inputs include ACRS findings on quantitative safety goals (mid-October 1980); final report on " Approaches to Acceptable Risk" (RES/ORNL/ Decision Research, October 1,1980); preliminary reports on risk critaria._and _
their impact and on risks of other societal activities (RES/ Brookhaven, September 1980); and a revised, expanded draft of paper on " Concepts, Problems, and Issues in Developing Safety Goals and Objectives for Commercial Nuclear Power" (NRR Division of Safety Technology, early October 1980).
. Table 1 PROGRAM MILESTONES Event Date Establish Inter-Office Steering Group 9/8/80(a)
Preliminary reports on Brookhaven risk studies 9/15/80 Complete Comissioner interviews 9/19/80 Final report of ORNL study of approaches to 10/1/80 acceptable risk ACRS report on quantitative safety-goals 10/15/80 Amplified NRR paper on concepts and issues 10/15/80 Exploratory meeting on Approaches with 10/22/80 NRC/ Industry /Public Interest Groups Complete working paper on Criteria 10/31/80 Submit information paper on detailed plans and 10/31/80(b) schedule for Background Studies Complete working paper on Alternative Frameworks 11/24/80 Submit PRELIMINARY POLICY PAPER 12/29/80(c)
Hold Workshop on Frameworks
?/17/81 Receive public coment on Preliminary Policy Paper 3/16/81 Mc!d public meeting (s)
Spring '81 Complete Background Studies 4/30/81' Complete preliminary draft of Proposed Approach 5/20/81 Hold Workshop on Proposed Approach 6/23/81 Submit POLICY PAPER 8/7/81(c)
(a) Or two weeks af ter Comission approval of plan.
(b) Some background studies may be initiated before that date.
(c) Issue for public coment after Comission approval for release.
i 2.
Establish and maintain contact with outside groups known or believed to have interest and considered views (including industry and public interest groups).
Solicit as necessary and receive for consideration articulated views and analyses from these groups.
3.
Establish and maintain information interchange with groups having relevant responsibilities and related interests.
(This includes Congressional and NSF/NAS contacts, other governmental contacts, and may include foreign contacts.)
(OPE, Inter-Office Steering Group, and to be assigned.)
Task II:
BACKGROUND STUDIES A.
Nuclear Regulatory Statutes and Practices Update and amplify the Commission paper, " Adequate Protection of the Health and Safety of the Public" (OGC,10-18-79) as necessary to provide a current compendium iicluding legal analysis, interpretation of safety goals in AEC/NRC regulations and cases, history of changes in law and interpretaticns, and controversies concerning interpretation.
Prepare reports on legal and historic aspects.
(0GC/ Historian, early 1981.)
8.
Statutes and Practices of Other Agencies 1.
Select for study 3 to 10 other Federal agencies with important safety responsibilities.
(Candidates include EPA; FAA; Department of Transportation, notably with respect to highway safety; NASA; Food and Drug Administration; Consumer Products Safety Comission).
2.
Analyze the practices of the selected agencies with respect to safety goals, utilizing analysis of pertinent statutes in the October 1979 OGC paper.
3.
Prepare report on findings, including comments concerning relevancy to NRC.
(Responsibility and schedule to be determined.)
C.
Approaches of Other Industrialized Countries to Safety Goals Using information developed by the ACRS and RES, conduct limited additional study to round out the information concerning nuclear safety goals as viewed in other countries.
(Candidate countries include UK, FRG, France, Japan.)
Prepare report, including comments on relevancy to U.S. and NRC.
(IP/0PE, schedule to be, determined.)
. D.
Social Acceptance of Risks 1.
Review the literature on the levels and circum-stances of risk acceptance in contexts other than the nuclear industry, including the results of the RES-sponsored study of coal vs. nuclear risks and of recent CONAES studies of risks of various electrical energy sources.
(Candidate other contexts include transportation, tobacco, alcohol, home and consumer products, industry, construction, dams, war, sports, natural hazards.)
2.
Prepare sumary reports (overview).
(Responsibility and schedule to be determined.)
E.
Theories of Risk Acceptance Describe alternative theories of risk aversion and acceptance, including considerations such as relation to other risks, voluntary or involuntary exposure, nature of hazards, specificity of victim, number of persons at risk, proximity in time and place, relation to benefits, and uncertainty as to nature and magnitude of the risk, using the results of ORNL study and adding the limited work necessary.
(OPE /RES, schedule to be determined.)
Task III:
POLICY DEVELOPMENT A.
Criteria 1.
Develop a set of criteria by which the merits of a safety-goal formulation should be judged.
(Candidate criteria may include such considerations as: To what extent does the fcrmulation address significant elements of the issue? How complete is it? To what extent does it lead to coherent and raticial ~ ~
~
results? To what extent is it acceptable to affected publics? How clearly can it be interpreted in terms of regulatory actions?
Etc.)
2.
Prepare working paper for use in policy development.
(OPE, October 1980.)
8.
Frameworks 1.
Develop candidate approaches to safety-goal formulation.
(These may include frameworks that aim at a compre-hensive statement, or statements with respect to only those parts of the issue judged to be tractable; quantitative and/or qualitative formulation approaches;
. concentrating on individual or social risks, or both; stated in terms of probabilities of events, such as core melt and/or containment failure, or of public consequences, notably radiation exposure risk; etc.)
Drawn from work of ACRS, NRR, RES, AIF, EPRI, public interest groups, etc.
2.
Prepare working paper on alternative frameworks, presenting a range of alternatives, for use in early policy development.
(OPE, November 1980.)
3.
Narrow down to a few significant approach options which span the range of approaches, and develop further for use in Subtasks III.C and D.
(OPE, December 1980; update July 1981.)
C.
Preliminary Policy Paper 1.
Prepare a draft policy statement concerning safety goals, setting forth significant approach options, together with underlying rationale, for Commission consideration.
2.
Following Comission review, submit for public comment.
3.
Prepare proposed updated program plan for next phases of work and submit for Commission consid-eration.
(OPE, December 1980.)
D.
Policy Paper 1.
Evaluate Commission guidance and peer and public coment on the Preliminary Policy Paper (Subtask III.C).
2.
Prepare a draft policy statement concerning safety goals, together with underlying rationale, for Comission consideration and public comment (taking item 1 into account).
(OPE,8/7/81.)
3.
Identify and plan for further work and submit for Commission consideration.
(OPE, August 1981.)
Task IV:
WORKSHOPS Note:
This task envisages holding two workshops, to help illumintate the considerations that should guide the narrowing of options.
These will be discussion workshops, with assigned topics (and perhaps subtopics assignad to subgroups),
. involving invited knowledgeable persons representing a broad range of viewpoints, drawn from technical, social, and humane disciplines, industry, public interest groups, universities, and government. The composition of the two wcrkshops is not expected to be identical.
The proposed workshops and associated tasks are as follows:
A.
Workshop on Frameworks and Philosophies of Approach 1.
Prepare and provide to participants an input package including the Preliminary Policy Paper and topics and guidelines for discussion.
2.
Hold workshop to discuss general approaches to safety-goal formulation, including goal forms, assumptions, and decision criteria.
(Arrangements responsibility to be determined; February 1981.)
3.
Prepare report, for use in Subtasks IV.B and III.D.
B.
Workshop on Proposed Approach 1.
Prepare and provide to participants an input package including the Preliminary Policy Paper, preliminary draft of proposed approach, report on Workshop A, and topics and guidelines for discussion.
2.
Hold workshop to discuss merits and problems of a reference safety-goal statement and its chief alternatives.
(Arrangements responsibility to be determined; June 1981.)
3.
Prepare report, for use in Subtask III.D.
Task V:
MANAGEMENT 1.
Plan, organize, and integrate the project.
2.
Measure progress and adjust the program in light of Comission guidance and other developments.
(OPE, with assistance of Inter-Office Steering Group.)
5 Public Participation Wide public participation will be sought.
Upon Commission release, the availability of this paper will be noticed in the Federal Register, with invitation or public comment.
The exploratory meeting on approaches with NRC, industry, and public interest groups (see Schedule, above) will be open to the public, as will the two workshops.
. The Preliminary Policy Paper and the Policy Paper will be issued for public coment, and consideration will be given to possible invitations of comment on other papers.
One or more public meetings will be held, to provide further occasion for public input.
6.
Organization The Comission has assigned responsibility for the pre-liminary policy paper due December 29, 1980, to OPE.
We propose that the program responsibility remain with OPE through the scheduled submission of the policy paper in August 1981.
An Inter Office Steering Group should be established to gain the benefit of NRC-wide participation in guidance of the program and to serve as a focal point for securing work contributions from the various NRC offices.
The offices represented should include OPE, OGC, RES, NRR, SD, IE, and NMSS.
In addition, an ACRS member should participate.
The members should be broadly capable professionals, of inquiring mind, and not averse to challenging established ways.
Their participation will be part-time, with a priority adequate to the program's schedule.
They should be appointed by the respective Office Directors (or Committee Chairman),
with approval of the ED0 in the case of offices reporting through the EDO. The group's chairman will be the Director, OPE.
OPE and the steering group will be further assisted in program guidance by outside consultants.
The study work will be done partly by assignment of specific work packages to appropriate NRC offices, contractors, and consultants.
Consideration will be given to retaining the services of a national laboratory for " housekeeping" and other contractual support of the goal-development effort.
7.
Program Adjustment As the work progress, OPE, in consultation with the Inter-Office Steering Group, will develop any needed modifications of this plan, in consonance with the program's objectives, scope and overall schedule, and in accordance with Commission guidance.
. RECOMMENDATIONS: We recommend that the Commission:
1.
Acorove the plan.
2.
Note that, upon approval, the Secretary will sign the staff requirements memorandum at Enclosure 3 on behalf of t.1e Commission.
3.
Note that the Federal Register notice at Enclosure 4 wiTT be issued.
4.
Note that OCA will notify appropriate Committees of Congress.
5.
Note that OPA will issue a press release.
COORDINATION:
We had the benefit of consultations with RES, NRR, SD, and ACRS members and staff.
Enclosures:
1.
Status of NRC Work 2.
Description of RES-Sponsored Projects 3.
Draft Staff Requirements memorandum 4.
Draft Federal Register notice Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b.
Wednesday, August 27, 1980.
Commission Staff Office comments, if any, should be subnitted to the Ccrmissioners NLT August 20, 1980, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional tire for analytical review and content, the Comnissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations ACRS Secretariat
STATUS OF NRC WORK
. OGC:
OGC has submitted for the Comission's information a legal analysis of NRC's present requirements and practices with respect to safety adequacy.
(" Adequate Protection of the Health and Safety of the Public," memo to the Comission from L. Bickwit, GC, 10-18-79.)
. ACRS:
In May 1979 the ACRS recomended to the Comission that NRC consider the establishment of quantitative safety goals for nuclear power reactors.
(Letter to NRC Chairman Hendrie from ACRS Chairman Carbon, 5-16-79.)
After expression of interest by Comissioner Ahearne (letter to Chairman Carbon, 6-11-79), the ACRS undertook to develop the concept further and assigned the project to its Subcomittee on Reliability and Probabilistic Assessment.
In August 1979 the ACRS wrote that it would take up to a year to arrive at a recomendation that the Committee would find appro-priate.
(Letter to Comissioner Ahearne from ACRS Chairman Carbon, 8 79.) After a series of meetings which included consideration of a number of domestic and foreign risk-analysis and criteria-development programs, the Subcomittee presented a tentative framework for risk management decision-making to the Comittee at its June 1980 meeting.
The ACRS Subcommittee on Reliability and Probabilistic Assessment met on July 1, 1980 to continue its evaluation of development of quantitative safety goals for nuclear power plants.
Speakers from NRC's Probablistic Analysis Staff (RES), EPRI, AIF, IEEE, and General Atomic, as well as ACRS Fellows and consultants presented and discussed proposed approaches.
Based on the information provided to the Subcommittee through its July 1, 1980 meeting, Subcomittee Chairman Okrent informed the Comittee on July 12 that he and ACRS Fellows working with him would prepare a draft letter for Comittee review at the September or October 1980 ACRS meetir.g. The draft is expected to be accompanied by background documents describing:
-- Approaches to safety goals found in the literature.
-- A possible set of safety goals and decision rules, and their implications.
It is expected that the ACRS will report its findings to the Comission after its September or October 1980 meeting.
. Office of Nuclear Regulatory Research:
The Office of Nuclear Regulatory Research has in progress a research program on quantification of safety decision-making.
The specific activities involved and their status are as follows:
-- A Comparative Risk Assessment and Acceptable Risk Criteria project is being conducted by the Oak Ridge National Laboratory to develop methods for addressing unacceptable and acceptable risk, and to compare public and occupational risk associated with the coal and nuclear fuel cycles.
A preliminary draft of a report on Approaches to Acceptable Risk is
-t-presently being reviewed, and a draft report on the risk associated with the coal and nuclear fuel cycles is being finalized for distribution in October 1980.
-- A research task force of a variety of professional disciplines has been established to formulate several possible sets of numerical criteria, using different technical approaches. The formation of the research task force and the conduct of its meetings are being coordinated through the Institute of Electrical and Electronic Engineering (IEEE),
with cooperation from other professional engineering societies.
The task force has been established in the IEEE SC-5 Reliability Committee, and has completed several working group meetings as of June 1980.
Discussions are currently taking place among IEE, ANS, and AIF con-cerning the respective roles of these organizations, in efforts to arrive at a coordinated approach.
-- Brookhaven National Laboratory has been contracted to independently formulate criteria in order to investigate the implications of such criteria and to determine the impact of attempting to satisfy such criteria.
Information on risk exposure and risk acceptance criteria from other societal activities is being collected.
Draft reports are expected in September 1980.
Also, 5aseline calculations of WASH-1400 accident sequence probabilities ar-being revised by using hardware and human error failure rates.
-- As means of peer review during the BNL project, the National Science Foundation, the National Academy of Science, and the American Statistical Association have been contacted to set up peer review functions.
Negotiations are underway to define the specific mechanisms for these peer reviews.
~
The ACRS Subcomittee on Probabilistic Analysis are carrying out inde-pendent reviews and formulating their own recommendations.
-- Several meetings are scheduled to accomplish an integration of these activities.
A meeting of nuclear industry representatives was held in Washington, D.C., on March 18, 1980 to discuss fundamental issues involved in establishing risk criteria.
It is anticipated that one or more of these meetings will be internationally sponsored.
Task descriptions and schedules of the various RES-sponsored efforts appear in Enclosure 2.
. Office of Nuclear Reactor Regulation:
On July 10, 1980 the NRR's Division of Safety Technology (DST) circulated for comment within NRC a draft paper entitled, " Concepts, Problems, and Issues in Developing Safety Goals and Objectives for Commercial Nuclear Power."
In October 1980, DST plans to issue a revised and expanded draft, which is expected to include a fuller treatment of suggested goal forms and assumptions for the goals, together with a rationale for decision criteria for choosing among candidate sets of interrelated goals, standards, and guidelines.
In addition, DST is prepared to develop a paper on the desirability of specific safety goals.
The paper would be drafted from a licensing perspective and would be intended as a proposed "NRC staff" alternative, for consideration along with other viewpoints.
DESCRIPTION OF RES-SPONSORED PROJECTS 9
PROJECTS TO FORMULATE AND EVALUATE QUANTITATIVE RISK CRITERIA Perfonnino Oroanization:
Brookhaven National Labora'ery Task 1.
perform a comprehensive literature review on published articles addressing quantitative risk criteria.
Revised draft report due September 15, 1980.
Task 2.
Update WASH-1400's curves and tables on risks from activities other than nuclear.
Evaluate both individual and societal risks along with associated uncertainties.
Revised draft report due September 15, 1980.
Task 3.
Review present state-of-the-art of fault tree and event tree
~
modeling and quantitative risk evaluations.
Explicitly identify limitations and capabilities in utilizations to determine whether nunerical risk criteria are satisfied.
Draft report due September 15, 1980.
Task 4.
Update WASH-1400 calculations to incorporate new failure data and new quantitative models.
The updated WASH-1400 evaluations will serve as baselines to compare with risk evaluations of other plants.
Coding of WASH-1400 fault trees and event trees for automatic computer updating to be completed by October 1, 1980.
Task 5.
Based on comparative risk considerations, 63rmulate and evaluate quantitative risk criteria based on an acceptable level approach.
Consider quantitative criteria for acceptable ~1evels for:
a..
core melt probability b.
probability versus curies released c.
early fatalities e
d.
latent fatalities e.
dollar damage Evaluate different criteria and give the pros and cons for utilizing each criterion along with the risk ramifications.
Consider different methods for compliance detenninations.
Specifically address the treatment of uncertainties and data and models required.
Draft reDort due September 15, 1980.
4 e
e
....6
. Task 6.
Fomulate and evaluate quantitative criteria based on an unacceptability level. approach.
Consider the same five items as for the acceptable level approach.
Consider ramifications and methods for detemining compliance.
Specifically address the treatment of uncertainties along with data and nudels requi red.
Draft report due September 15, 1980.
(Note: ' Final reports will be issued in 1981.)
Perfomino Orcanizations:
Oak Ridce and Decision Research (Paul Slovic, Ralon Keeney, Etc.
Task 1.
Consider'the comments and reviews made on the draft report of Acoroaches* to Acceptable Risk and issue a final report.. Final report due October 1,1980.
Task 2.
Fomulate and evaluate specific quantitative criteria for acceptable levels of risk from nuclear reactors.
Consider quantitative levels for core melt probability, probability versus release, early and latent fatalities, and dollar damage.
Consider the different approaches for justifying the criteria (expert judgment, comparative arguments, decision-theoretic approaches, etc.) and discuss possible public reactions.
~
Evaluate ramifications of the criteria and specifically consider methods for implementing and detemining compliance with the criteria.
Draft report due January 1981.
Task 3.
Consider quantitative criteria based on the unacceptable level approach.
Perfom. the same analyses as in Task 1 but addressing defined, unacceptable quantitative criteria.
Also consider how the unacceptable level approach might converge to the acceptable level approach. ' Draft report due January 1981.
Performina Orcanizations:
Oak Ridoe and Science Acolications Task Complete final report on evaluating risks from coal versus nuclear power.
The report treats all phases of the-nuclear fuel cycle and coal cycle.
Final report due October 1,1980.
Perfoming Orcanization:
Arconne National Laboratory Task 1.
Begin to quantify the benefits from nuclear pwer for considerations in risk-benefit evaluations.
As phase one of this task, specifically consider the loss of economic benefits from
..., - / ;; *
. shutdown of one plant or multiple plants.
Utilize existing computer codes and consider specific plant shutdowns covering minimum to maximum losses.
Consider multiple plant shutdowns by region.
Develop an empirical model for decision-theoretic utilizations.
Draft report due December 1,1980.
Task 2.
Apply decision-theoretic approaches to regulatory decisionmaking.
Explain in understandable teminology the concepts and inputs required in utilizing fomal decision-theoretic approaches.
Use the rodels and analyses obtained from IREP as specific case studies.
Perfom detailed sensitivity studies to determine the impacts of different value assessments.
Develop a fomal treatmeht for handling uncertainties in the decisionmaking process.. Draft report due March 1981.
Note:
In addition to the above projects, the IEEE has established working groups to fomulate numerical risk criteria from an industry-oriented point of view.
The National Academy cf Science and National Science Foundation has carried out several forums on acceptable risk criteria.
The American Statistical Association has also established a committee dealing with the proper use of statistics in risk analyses.
o O
F e
MEMORANDUM FOR:
Edward J. Hanrahan, Director, OPE Leonard Bickwit, Jr., General Counsel Milton S. Plesset, Chairman, ACRS William J. Dircks, Acting ED0 FROM:
Samuel J. Chilk, Secretary
SUBJECT:
STAFF REQUIREMENTS -- PROPOSED PLAN FOR DEVELOPMENT OF A SAFETY G0AL (SECY )
1.
The Commission has approved the proposed plan.
(OPE with contributions from other offices.)
(SECY suspense:
preliminary policy paper 12/29/80.)
2.
The Commission requests that you proceed with appointment of members of the Inter-0ffice Steering Group as described in item 6 (Organization) of the Plan.
(ED0/ACRS/0GC/0PE) (SECY suspense:
within 10 days.)
cc:
Carl. ton C. Kammerer, Director, OCA Joseph J. Fouchard, Director, OPA
UNITED STATES NUCLEAR REGULATORY COMMISSION Proposed Plan For Developing A Safety Goal Notice is hereby given that a proposed plan for developing a safety goal prepared jointly by the Commission's office of the General Counsel and Office of Policy Evaluation is available for inspection by the public in the Commission's Public Document Room at 1717 H Street, N.W., Washington, D.C.
Requests for copies of the proposed plan should be addressed to dae U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, Attention: Director, Division of Technical Information and Document Control.
Interested persons may submit comments on the proposed plan for the Commission's consideration.
To be of maximum usefulness, comments should be received by (30 days from date of notice).
Comments received by the Commission will be made available for public inspection at the Commission's Public Document Room in Washington, D.C.
Comments received will be taken into consideration in possible modification of the plan.
Comments from interested persons of the public should be addressed to the Nuclear Regulatory Commission, Washington, D.C.
- 20555, Attention:
Edward J. Hanrahan, Director, Office of Policy Evaluation.
. ~,
2 Dated at Bethesda, Maryland, this day of FOR THE NUCLEAR REGULATORY COMMISSION Samuel J. Chilk Office of the Secretary O
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