ML19305D379
| ML19305D379 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1980 |
| From: | Plesset M Advisory Committee on Reactor Safeguards |
| To: | Ahearne J NRC COMMISSION (OCM) |
| References | |
| ACRS-R-0867, ACRS-R-867, NUDOCS 8004150006 | |
| Download: ML19305D379 (2) | |
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UNITED STATES f
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NUCLEAR REGULATORY COMMISSION I
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March 12, 1980
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Honorable John F. Ahearne 01 airman U. S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
ACRS CCNMD7FS 04 RECCNMENDATIONS T )RC SPECIAL INQUIRY GROUP REGARDING ACRS ACTIVITIES r
Dear Dr. Ahearne:
te Special Inquiry Group (SIG) made a ntaber of ccaments and recommenda-l tions about the role of the ACRS, and this letter contains our response.
l We SIG noted that the ACRS was the only group capable of independent and in-formed input into the licensing process, but also felt that the ACRS did not j
live up to its potential.
We specific concerns were that ACRS letters i
have been cryptic, that safety issues have been resolved by the staff before ACRS letters were written, that the Atomic Safety and Licensing Boards are i
not required to pay attention to recommendations in ACRS letters, that the ACRS does not deal with a sufficiently broad tange of probles, and that the ACRS mebers are overworked.
Nonetheless, the SIG (as had the Presidential i
commission before it) recommended the retention of the ACRS, with a strength-i ened and somewhat modified role.
We agree with this reccanendation and concur in some of the criticim of the report.
tis letter will deal with l
some of the specifics.
l l
Some of these issues are easy to address.
We have already agreed with you that the ACRS should deal with a somewhat broader range of problems than has been the case heretofore, and we have agreed to advise the Commission in the forthcoming rulmaking on waste disposal. As this trend continues, it will, of course, be necessary to reconsider the balance of talents represented on the ACRS, as well as the level of staff support that it will require.
At some point, the balance between breadth and depth will have to be addressed.
l 2e SIG recomended, as have others, that the ACRS not be required to comment on each licensing recommendation, and we concur.
tis may help to provide a little breathing space for the broader activities mentioned above. We do not agree that the ACRS should play a more formal role as a party in licens-ing proceedings because we wish to retain the format of an advisory commit-tee.
However, we feel that it would be useful to require that each Atomic Safety and Licensing Board make some disposition of each ratx-nandation made by the ACRS in its reports on license applications. We have commented
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+ March 12,1980 Honorable John F. Ahearne 15, 1980. We problem of " closing on these matters in our letter of January the loop" on ACRS recomendations is a serious one, and major improvement is mis is true not only for licensing matters, but also for the necessary.
more general safety issues occasionally raised by the ACRS, and we are pleased that some progress is being made on this problem.
in comon with other outside investigative groups, also felt the te SIG, need for an oversight group, to effectively monitor the performance of NRC (though the SIG recommendation was made in the context of a transformation of NRC to an administrator format, as was the Presidential Comission recom-mendation). The SIG had a unique suggestion, which was that a Nuclear Safety Board be established within NRC, composed of technically trained members, yet independent of all other offices within NRC, and that the five full-time members of the Board also be mmbers of ACRS.
Sus, the
%e ACRS ACRS would consist of five full-time and ten part-time members.
would then have two classes of members which would tend to disturb the It collegiality which many feel is one of the strengths of the ACRS.
is clear that many feel the need for some such function, since the SIG, the Presidential Commission, and the draft Bill introduced by Congressman Udall We do not wish to ccament here on whether all provide for some such Board.
there is need for such a Board, but believe that it would be inappropriate to attach it to the ACRS.
the Comittee recognizes that an alternative to the creation Nonetheless, of such a Nuclear Safety Board is that some of these same functions be It may be that the penalty in terms of increased performed by the ACRS.
time comitment of the members, probable increased size of the ACRS staff, broadening (and hence dilution). of ACRS expertise, etc., have the potential J
to be sufficiently damaging to ACRS performance as to suggest the establish-l We feel, however, that it is better to ask the ACRS to ment of the Board.
fill some of these admitted lacunae in the regulatory process on a limited and selective basis than to contribute at this tone to the proliferation of I
m is is especially true in view of the fact that the boards and committees.
Presidential Oversight committee will certainly be appointed soon, the Nuclear Safety Board being considered by Congress may come into being, and the NRC's own Office for Analysis and Evaluation of Operational Data already However, if the burden of the additional responsibilities becomes exists.
too onerous, one might have to consider major alterations in the ACRS format.
Sincerely, Milton S. Plesset Olairman Y*
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