ML19332D250
| ML19332D250 | |
| Person / Time | |
|---|---|
| Issue date: | 11/20/1989 |
| From: | Remick F Advisory Committee on Reactor Safeguards |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| ACRS-R-1375, NUDOCS 8911300220 | |
| Download: ML19332D250 (3) | |
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NUCLEAR REGULATORY COMMISSION T
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' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS p
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t November 20 1989
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.Mr.' James M. Taylor j
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' Acting Executive Director for Operations J
U.S. Nuclear Regulatory Comunission bj
' Washington, D.C. -20555 1
a Dear Mr. Taylor I
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SUBJECT:
THE RELATIONSHIP OF THE QUANTITATIVE SAFETY GOAL TO THE
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C6NCEPT:0F ADEQUATE PROTECTION-a:
i' During the 355th meeting of 'the ' Advisory Committee on Reactor Safe-guards, November 16-18, 1989, we discussed the.. concept of " adequate
. protection" and its role -in thes plans. for implementation > of - the NRC Safety Goal Policy.
We, discussed this subject during-several previous meetings of, the Cossnittee : and : our Subcommittee-on Safety Philosophy, Technology, and; Criteria.. During this. review,i we - had the benefit : of.
3 discussions with, members ; of the. NRC staff ? and ' ofi the documents ref-erenced.
3 7e In a~ series: of reports toithe Commission-culminating inithe report of
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February 16.-1989, the ACRS has. commented 'on; the staff's proposals. for LimplementingL the Comunission's. Safety Goal Policy. 'We also discussed L
.this _ subject in a meeting between the ACRS and the Comunission on May 3, D
'1989.
Following-this neetingvand a. neeting with the staff on July 26 1989,'the Commission asked for a clarification of the seemingly differ-
- entL positions held by the staff and by the ACRS concerning the role'of g"
ethe concept of adequate-' protection.in the; staff's plan for implementing the Safety Goal Policy (Staff Requirements Memorandum' dated August 21 1989). We provided an interim 1responsecin our: report to Chairman Carr on October 11, 1989.
As an instrument for providing-the requested clarification to the
. Comunission, the staff prepared a draft' paper entitled.. " Adequate Pro-tection As It Relates to Safety Goals:
ACRS and Staff Positions," that
.was forwarded to us-for review as an attachment to a memorandum from E.
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. S. Beckjord, Office of Nuclear Regulatory Research, to R. F. Fraley, H*
ACRS, dated November 2, 1989.
l Iw We take exception to the description of the ACRS positions, as described i
in the draft paper, as -follows:
l (1) On page 2 of the draft paper, the staff provides a quotation from H
the Conunittee's February 16, 1989 report (under Definition of
" Adequate Protection"), as follows:
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c Mr. James M. Taylor
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November 20, 1989 i
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We believe that the safety goal should play an. impor-i tant, but indirect, role.n defining adequate protec-i tion.
- Ideally, compliance with the Commission's
. regulations -is a
suitable surrogate for-defining adequate protection of the public. However, we believe that.the adequacy of the regulations should be judpd f
C from the viewpoint of whether nuclear power plants, as a class, licensed under those regulations, meet the safety goals.
It is our understanding, following discussions with the staff, that the staff proposes the safety goal to be a sort of aspirational objective which would be sought but not necessarily reached.
t Tc provide a better understanding of the ACRS position, the staff should also include the paragraph that precedes the above quota-tion, namely:
l
.The tem " adequate protection" has importance in the 1
legal areas of safety regulation.
Although it is needed and used with apparent precision in legal instruments, its technical definition is not precise.
In general, it is accepted as equivalent to the term j
'with no undue risk to public health and safety" often used in other contexts. Another ters, "in full compli-ance with the regulations" is used as a surrogate, on occasion, for either of these.
.(2) Following this quotation, the staff's draft paper describes the.
ACRS position as, in effect, equating the concepts of " safe enough" and." adequate protection." This.is not correct. The ACRS believes-1
'that the safety goal sets a standard of what is " safe enough," for i
the population of plants or a class of plants. As we have consis-j tently stated in our previcus remrts on this subject, the quanti-l tative safety goal should be usec only to judge the adequacy of the e
L NRC's body of regulations and should not be used to judge the
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adequacy of-the design and perfomance of-a particular individual plant.
We do not attempt to equate the safety goals to " adequate protection" in the sense in which the courts have recently con-sidered it.
Sincerely orrest J. Remick Chairman l
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t Mr. James M. Taylor November 20, 1989 References
_ 1. -
Memorandum dated Novesber 2,1989 from Eric S. Beckjord, Office of l
Nuclear Regulatory Research, NRC, to Raymond F.
Fraley, ACRS, l
transmittirg Draft Commission Paper for the Cosmissioners, subject:
Adequate Protection As It Relates To Safety Goals: ACR$ and Staff Positions (Predecisional) 2.
Memorandum dated August 21, 1989 from S. J. Chilk, Secretary, to J.
M. Taylor, Acting EDO, and R. F. Fraleyf Policy Statemento For ACRS,'
Subject:
Staff Requirements. - Briefing on Integration o Severe Accidents, Advanced Reactors, Safety Goals, and Standardira-tion - July 26, 1989 t
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