ML19339D009
| ML19339D009 | |
| Person / Time | |
|---|---|
| Issue date: | 10/30/1980 |
| From: | Fraley R Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML19339D006 | List: |
| References | |
| ACRS-1793, NUDOCS 8102130091 | |
| Download: ML19339D009 (8) | |
Text
/*# "%'g NUCLEAR REGULATORY COMMISSION UNITED STATES
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,g ADVlsORY COMMITTEE ON REACTOR SAFE 2UARDS
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't4 October 30, 1980 EMORANDUM F,0R:
ACRS Members k
R. F. Frale>,
ecutive Dig ctor, ACRS FROM:
ACRS ROLE IN THE REGULATORY PROCESS
SUBJECT:
During the 247th ACRS meeting the Committee will meet with the Chairman of the Nuclear Safety Oversight Committee (Governor Bruce Babbitt) to discuss the ACRS role in the regulatory process and methods by which its function might be strengthened consistent with the re Attachment A).
This subject was discussed during the 246th meeting and the members v on several specific suggestions taken from the Rogovin report, the ACRS regarding the Rogovin report (Attachment B),
letter of January 15, 1980 i ht the appearance by ACRS representatives before the President's Overs g Committee (July 28,1980),etc.
items 'and Attachment D for a summary of the vote regarding specific items l
Based on the Committee's action during the 246th In addition, Mike Bender has identified Babbitt (see Attachment E).
several additional items as the basis for additional discussion among it the Committee members regarding specific ways to l
These items will be the basis for discussion during the Procedures Sub-80 committee meeting (4:30 P.M.
6:30 P.M.) on Wednesday, November 5,19and di b
6, 1980) before the meeting with Governor Babbitt.
If you have suggestions regarding any additional items that warran cussion please let me know ASAP so I can develop related backgrou fonnation, etc.
In this connection it should be noted that Commission action is alrea better definition of the in progress to strengthen the ACRS role by:
ACRS role in rulemaking; consideration of ACR l
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APPENDIX A 810 213 0o9b O
"* ** Nema.
I have attached the related Staff papers which propose appropriate rule These are con-changes, policy statements, etc. (Attachments G and H).
sistent with the intent of the Committee vote taken during the 246th meeting although some fine tuning of specific wording ney be appropriate.
Attachments:
Report of President's Commission on A.
The Accident at Three Mile Island ACRS letter dated 1/15/80 on Recom-B.
mendations of President's Commission on ACRS Role 8/20/80 Recanmendations to Strengthen C.
the ACRS Role in the Regulatory Process Working Paper Draft 2. Excerpt from D.
Summary nf 246th ACRS Meeting, October 9-11,1960 Draft 2. M. Bender, Proposed Chairman's E.
Position to Strengthen the Role of the ACRS in the Regulatory Process Draft M. Bender to Milt Plesset, letter F.
re suggested discussion to improve role of ACRS in regulatory process Letter from Gaske to Rehm dated 10/15/80 G.
re ACRS Participation in Rulemaking Activities Undated memo to Sege, OPE, from Fraley Consideration of ACRS Letters in Adjudicatory H.
Proceedings i
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NOTE: Anoendix A with Attachment E, ?, C, H with attach memos, etc and Anpendix D v attach D and Appendix e and B are deleted as
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the setting of safety po'licy in this cg2ncy ano teo......Crmmiss board."
The major officas within the NRC operate inde;.end'ently T
with little evidence of exchange of information or experience.. or 5;
example, the fact that operators could be confused due to reliance h
on pressurizer level had been raised at various levels within t e Yet, the matter " fell between the cracks" and d
never worked its way out of the system prior to the TMI-2 acci ent.
NRC organization.
- 6. 1.icensing of a nuclear plant is a two-step process. Firs The CP stage does not the coepany must later must obtain an operating license (OL). require co does not occur until the OL stage.
dollars have been spent or committed in the construction process.
Therefore, the ultimate safety review may be influe i
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at the OL s ta ge.
The Advisory Committee on Reactor Safeguards (ACRS) :}:
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reviews all applications for licenses and poses whatever guestio 7.
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r it deems appropriate.
However, it has [
NRC staff which regularly reviews safety questions. establ l
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ACES members are prt-time senthly acetings of limited duration.and have a very small staff, th h NRC
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ACRS members tend to staff for follow-up of their concerns. concentrate on their own particu i
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b 'resulting in a fragmented licensing review.
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i m w-ns -=ec. mum s'Mw There are serious inadequacies in the NRC licensing l
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l process.
Applicants for licenses are only required.to analyze
" single-failure" accidents; they are not required a.
The accident at TMI-2 was a multiple-failure accident.
i other.
NRC's design safety review places primary emphasis on This designation is crucial b.
those items labeled " safety-related."
d in the since items not labeled " safety-related" need not b diaarily l
need not be testable, do not require redundancy, and are orThere are no I
not subject to NRC inspection.
d " the which compor wts and systems are to be labeled " safety-relate ;
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utility maki.. the initial determination subject to NRC approva.
Tor example, at TMI-2, the PORV was not a " safety-related" itesOn th j
because it had a block valve behind it. block valve was not " s l
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of it.
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An n uld ba to sxtcina, en n in addressing
' > the parformance of the agency and of a:: cucleer isdustry cstablished.
Its purpose i h the and resolving important public safety issuas assoc loring the I
overall risks of nuclear, power.
The members of the committee, not to exceed 15 in numbe i
persons should be appointed by the President and should include:
a.
cy conversant with public health, environmental protection, emergen tion, and planning, energy technology and policy, nuclear pow
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en fal public.'-
The committee, assisted by its own staff, should report p p Wresident and to Congress at least ann b.
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independent f.
j retained, in a strengthened role, to continue providing anThe members of t 3
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technical check on safety matters.
continue to be part-time appointees; the Commi i d 17
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I-r making them full-time federal amployees.
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following changes:
The staff of ACRS should be strengthened te provideS p:
increased capacity for independent sna! sis.should be gi s.
ld of public I
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.O bealth.
When ACRS chooses to review a license ap b.
ty.
In should have the statutory right to intervene in hearings as a par application.
issue in l3 particular, ACRS should be authorized to raise an d
'y i i it makes.
- i to require formal response by the agency to any subm ss on
>p Any member of ACRS should be authorized to appear and tes hich j d hearings, but should be exempt from subpoe i
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i submis'sion.
ACRS should have similar rights in rulemaking In particular, it should have the power to initiate a c.
i safety rulemaking proceeding before the agency to resolve any gener c proceedings.
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issue it identifies.
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. w p-u. nm The Agency's Substantive Mandate The new agency's primary statutory mission and first operat f nuclear priority must be the assurance of safety in the generation o hf diversion, power, including safeguards of nuclear ' materials f or loss.
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ADVISORY COMMITTEE ON REACTOM SAFEGUARDS i
mAsMineGToss.0. C. 20555 r
ka January 15, 1980 e
Bonorable John F. Ahearne Chairman U. S. Nuclear Regulatory Commission m shington, DC 20555 RErCMTN3710NS T PRESIDOC'S CO98.ISSION CN ACRS RC
Subject:
i
Dear Dr. Ahearne:
te following comrents are offered in response to Mr. Chilk's letter of its j
November 9,1979 requesting that the ACRS provide d
Accident at tions of the report of the President's Comission (PC) on theIndividu t ree Mile Island.
below with ACPS coments following.
dd be retained,
'ne Advisory Committee on Reactor Safeguards (ACRS) 1 1.
Re ACRS agrees.
safety matters.*
f the Comittee should continue to be part-time appointees...."
2.
- We menbers o t e ACRS agrees.
- ne staff of ACRS should be strengthened to provide increase f
3.
for independent analysis."
inadequate to provide suitable independent-analysis capability; to ke ific abreast of EC Staff, industry, and foreign group activities on spec l
the members so the latter can make the best use of the I
i and to l
S e ("m mittee provide proper support to the numerous ACRS subcomittees.
ii be author-therefore requests that ten additional, senior-staff pos t ons dations and to provide an adequate technical supp d
St in addi-These positions are intended *':mver, if budgetary operation of the Ccanittee.
tion to those authorized in the Fellowship Program.
limitations prevent this level of support, the Commtee would accept s i
conversion of Fellowship positions into parmanent, senior posit ons.
f In connection with strengthening the staff, it is no h
bly l i It is of-information and data or in carryirs out some sp t
q#*
term studies as needed.
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UNITED STATES fp u ng',,,
NUCLEAR REGULATORY COMMISSION 3'
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AovisORY COMMITTEE ON REACTOT4 SAFEGUARDS i
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,e January 15, 1980 0A Honorable John F. Ahearne Chair: nan U. S. Nuclear Regulatory Comission Washington, DC 20555 REC 09EXATICNS T PRESIDDrr'S COMISSIGi mi ACRS R32
Subject:
Dear Dr. Ahearne:
The following cements are offered in response to Mr. Chilk's letter of November 9,1979 requesting that the ACRS provide the l
tions of the report of the President's Casnission (PC) on the Accident at J
Individual reccanendations from the report are listed n ree Mile Island.
below with ACRS comments following.
i be retained, i
- ne Advisory Committee on Reactor Safeguards (ACRS) shouldd ro 1.
in a strengthene
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safety matters." h e ACRS agrees.
"Se members of the Corsnittee should continue to be part-time appointee 2.
te ACRS agrees.
'The staff of ACRS should be strengthened to provide increased ca 3.
for independent analysis.'
inadequate to provide suitable independent-analysis capability; to keep abreast of NRC Staff, industry, and foreign group activities on specific safety matters; to provide technical and backgromo information to the menbers so the latter can make the best use of their limited time; and to Se Comittee provide proper support to the numerous ACRS subecanitte h
ized for the ACRS staff in order to meet the sense of the PC's rec dations and to provide an adequate technical support base for improved Rese positions are intended to be in addi-operation of the Comittee.
Ikwever, if budgetary tion to those authorized in thy Fellowship Program.
limitations prevent this level of support, the Consnittee would accept acme conversion of Fellcmehip positions into permanent, senior positions.
In connection with strengthening the staff, it is note f
It is of information and data or in carrying out some spe i
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term studies as needed.
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