ML19320D358
| ML19320D358 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/27/1978 |
| From: | Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| To: | Hendrie J NRC COMMISSION (OCM) |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8007210279 | |
| Download: ML19320D358 (4) | |
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E The Honorable Joseph Hendrie, Chairman Nuclear Regulatory Commist.on Washington, D.C.
20555
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Dear Chairman Hendrie:
M.
r I have recently reviewed a suggee~ ion for improved nuclear
- d. accident analysis and prevention which I considered worthy of further examination.
The suggestion was made to me
- in the attached letter by Dr. Hal Lewis, of the University of California.
As Dr. Lewis explains therein, he believes
.that the nuclear regulatory process could benefit by creation of a statutorily independent, quasi-judicial board for accident analysis similar to that now operating
- in conjunction with the Federal Aviation Administration.
That board, the National Transportation Safety Board (NTSB),
undertakes objective analyses of aviation accidents to determine what regulatory assign probable cause and' m
improvements could be madi to preclude the occurrence of such accidents in the future.
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Dr. Lewis' comparison of safety problems in the nuclear and l~
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aviation industries seems to indicate that such an independent body for accident assessment might be appropriately used to improve reactor safety.
I would appreciate the views of the Commission on this subject, particularly with respect i
to the following:
1)
What are the differences and similarities in nuclear and aviation industries and regulatory structures which could bear on the effectiveness of a board like the NTSB?
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2)
How would creation of such a board fit into the
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administrative format of the NRC?. What, if any, significant
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administrative changes might be required at the NRC to w
adjust to a statutorily independent, quasi-jiudicial body
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like the NTSB for review and recomendacion regarding 7Q nuclear accidents?
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==sb 3)- How do the duties and authorities of the NTSB sq differ from those of the Advisory Comittee on Reactor Safeguards, and how would creation of an NTSB-like group
==e affect'ACRS workload and productivity?
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4)
In what ways might creation of such a body help or hinder nuclear. regulation?'
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- 5) % at are the pros and cons of assigning responsibility for the analysis'of defects, malfunctions and accidents to a-statutorily independent, quasi-judicial body separate from the staff whose function is to. develop, implement and enforce regulations designed to prevent such problems?
g 6)
What ldgislative action would be required for creation of a board like the NTSB for work in conjunction with'the NRC?
- 7) - What are the Commission's recommendations with respect to any such future legislation?
The ACRS will also be approached for its views on Dr. Lewis' suggestion.
It.would be helpful to me if the views of 7.i.=
the Commission were available by July 30, 1978.
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Sincerely,
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4 MORRIS K. UDALL Chairman 2
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- UNIVERSITY OF CALIFORNIA, SANTA BARBARA
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- SANTA CRt*E LEnXFLEY
- DAY 15
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- SAN DIECO * $\\N ntANCISCO 3,r.; ;
=x; DEPAItT.\\!ENT OF PflYSICS SANTA BAMDAftA, CAI.!FOMNIA 93106 November 23, 1977 m
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The Honorable Morris K. Udall' House of Representatives
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Washington, D.C..
20515
Dear Congressman Udall:
Although you know that I chaired the APS study on Reactor Safety, and am currently chairing the NRC look at Risk Assess-I wish to emphasize that I am wearing none ment and WASH-1400, of these hats in the following.
?;Lp:n For some years I have been concerned about safety assurance and have been bochered by the fact that so for nuclear reactors, much of the public attention has been focused upon risk assess-ment, to the detriment of the former.
In some respects it is I-easier to make contributions to the former than to the latter, and it is in that context that I wish to bring to your attention and which I a suggestion which I have been making for years, It would probably require some obviously believe has some merit.
3 1cgislative action.
There are many analogies between the problem of reactor Each deals with a highly safety and that of aviation safety.
complex _ mechanism, with potential for mechanical, electrical, and human failure, and with the safety of each predicated upon.,
a " defense in depth"..
In the aviation case, the analysis of real accidents normally reveals a chain of events cou' pled with a?.though the operator error, ultimately leading to an accident, record sometimes includes unique events such as the baggage The analogy I see is that these two door failure on the DC-lO.
the analysis technologies each involve extremely complex systems, strains our of ~ whose _ behavior, especially under upset conditions, capaoility to'or perhaps past the limit.
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and continue to improve, aviation
.How then do we assure, that We recoghize that designs are not perfect, safety?
that ' pilots are not perfect, and that inspection'is not perfcct, accidents themselves can form a statistical base for safety In particular (and this is a feature shared with assurance.
reactors), we' cxploit the fact that any serious accident must and that the precursors them-
-have.some less serious precursors, solves provide. statistical keys to the weaknesses in the system.
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e The Honorable Morris K. Udall November 23, 1977 Page 2
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The problem is to learn enough from small accidents to make the corrections necessary for the prevention of large ones.
Histor-
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ically, this has been a successful approach, and public acceptance of aviation attests to that fact.
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The bureaucratic mechanism used (and I don't mean the term in a pejorative sense) is a quasi-judicial board known as the National car Transportation Safety Board, independent of the relevant regulatory agency (in this case the FAA),*' Wakes a responsible analysis, including hearings, of aircraft accidents.
The hearings are not intervenor-like proceedings, but are responsible efforts to assign
" probable, cause" to the accident and the Board's determinations are of ten followed by recommendations to the FAA for either alterations in procedures or systems or aircraft.
The FAA has ultimate responsibility for regulation, and may then issue mandatory retro-fits on the relevant aircraft, may adjust its own controllers' procedures, or may do nothing.
But it is not responsible for
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evaluating its own performance.
This procedure, over a period of time, has served to make flying acceptably safe, and indeed many of the mandatory retrofits o
are initiated by the FAA without NTSB action.
The philosophy is simple, and it works.
It seems to me that an analogous prccedure with respect to the nuclear industry could be effective ( md I say this withouw Not
+4 any implication about the ability of NRC
- o do its job).
only would it help, over a period of time, to close the loopholes
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on reactor safety, but it would even help in the public domain.
For example, a dispassionate external analysis of the Brown's Ferry incident would be valuable even now.
I could spell out this proposal in greater detail, but am not sure that it would be useful.
I would be happy to come in to talk to either you or to Henry Myers about ' this, and even to bring along some sample NTSB reports to give the flavor of that operation.
If you are interested, and feel that would be useful, please let me know.
Sincerely, s
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Lewis J
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