ML19345C136
| ML19345C136 | |
| Person / Time | |
|---|---|
| Issue date: | 10/14/1980 |
| From: | Hanrahan E NRC OFFICE OF POLICY EVALUATIONS (OPE) |
| To: | Ahearne J, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19345C127 | List: |
| References | |
| FRN-45FR71023 45FR71023, NUDOCS 8012030930 | |
| Download: ML19345C136 (3) | |
Text
A-v Question 1..
Background:
.Various possible specific objectives, not necessarily mutually exclusive, have'been posited for the safety-goal statement. These include:
(a) Some general approach to risk acceptability.
1 (b) Quantitative safety goals.
(c) Qualitative -- even subjective -- standards.
(d) Appraoch to safety-cost tradeoffs.
(e) Goals ar future safety improvements.
(f)- Standards for determining when new requirements
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should be applied retroactively.
Question:
What are the most important objectives that, in your opinion, the eventual safety goal statement should serve?
Ouestion 2.
Background:
The Commission's eventual' safety-goal statement could ae viewed as serving:
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(a) to guide the staff in developing and interpreting rules and evaluating cases; (b) to guide the Boards in' interpreting rules and deciding cases where rules are silent; (c) to generally systematize rules and practices and improve predictabiilty of HRC's actions; e
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s (d) to focus generic and case safety deliberations on the most essential issues.
Question:
What sort of role doe you envisage for the safety-goal statement in NP.C's regulatory activities and in the activities of licensees, applicants, and intervenors?
Question 3.
(a) What problem areas do you see with the present regulatory
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~ practices that could be ameliorated by articulation of a safety goal?
(b) How would a safety goal statement achieve that amelioration?
(c) What characteristics should the statement have to achieve the amelioration?
Question 4.
Without trying to be at all precise at this point, can you give an example of a degree of nuclear plant safety that you would consider:
(a) Clearly acceptable?
(b) Clearly unacceptable?
Question 5.
In your view, to what extent is there increased aversion to risk of high consequences even at low probability?
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' Question 6.
What, in your present view, should be some of the characteristics of safety requirements:
(a) What should be the role of safety-cost tradeoffs?
(b) To what extent should benefits of nuclear power --
absolute and relative to alternatives -- enter safety-requirement decisions?
(c) To what extent is it appropriate for requirements ft,r new and previously approved plants to differ?
(d) How should stringency of safety goals compare with risks accepted from othe- (non-nuclear) electrical energy sources and with risks arising in various other contexts?
(e) To what extent should equities of distribution of benefits and adverse impacts influence requirements?
(f) Should safety goals be applied directly to cases in order to attain a similar degree of safety from case to case (even that gh that may result in specific design and operation require-ments differing according to circumstances)? Or should goals
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be applied generically and have requirements, rather than estimated degree-of-safety results, be uniform?
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(g) 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?
Question 7.
What, in your opinion, is the proper balance between stability of requirements and flexibility for modification as knowledge develops and insights change?
Question 8.
Do you have ongoing or planned work that you may wish us to receive and consider? What? When?
Question 9.
Do you have any other comments or suggestions?
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UNITED STAT ES NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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October 14, 1980 M
NOTE T0:
Chairman Ahearne Comissioner Gilinsky Commissioner Hendrie Commissioner Bradford FROM:
EdUard J. Hanraha
SUBJECT:
REQUEST FOR INTERVIEWS CONCERNING DEVELOPMENT ')F A SAFETY GOAL The program for developing a safety goal (SECY-80 779), now approved by the Commission, includes plans for interviewing each Commissioner early in the program, in order to gain the benefit of their preliminary thoughts and advice.
OPE will contact your respective offices to request appointments for such interviews.
We enclose a list of the sorts of questions on which we would particularly like to solicit your views at this time.
Enclosure:
As stated cc:
Leonard Bickwit Sam Chilk CONTACT-George Sege (OPE) 634-3295 i
Knct!oaure e
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~ COMMISSIONER INTERVIEW QUESTIONS Question L Backgrouni:
Various possible sp;; Fic objectives, not necessarily mutually exclusive, have been posited for the safety-goal statement.
-These include:
(a) Some general approach to risk acceptability.
-(b) Quantitative safety goals.
(c) Qualitative -- even subjective -- standards.
(d) Approach to safety-cost tradeoffs.
(e) Goals for future safety improvements.
(f) Standards for determining when new requirements should be applied retroactively.
Question:
What are the most important objectives that you expect the eventual safety goal statement to serve?
Question 2.
Background:
The Comission's eventual safety-goal statement could be viewed as serving:
(a) to guide the staff in developing and interpreting rules and evaluating cases; (b)'to guide the Boards in interpreting rules and deciding cases where rules are silent; (c) to genert'ly systematize rules and practices and improve predictability of NRC's actions; a
(d) to focus generic and case safety deliberations on the most essential issues'.
. Question:
What sort of role do you envisage for the safety-goal statement in the agency's regulatory _ activities?
Question 3. -
Background:
The Commission's safety-goal statement could take any of various forms, such as a policy statement or a rule; or some combination, such as an interim policy statement, to be followed, after public comment, by a rule, which would supersede it.
The Senate's NRC Authorization bill for FY 1981 (S. 2358) would require NRC, after notice and opportunity for public hearing, to develop a safety goal for reactor regulation, with a June 30, 1981 deadline for a report to Congress.
(There is no corresponding provision in the House version.)
Question:
Do you have any views at this time as to what form and approximate timing would be appropriate for a safety-goal statement by the
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Commission?
Question 4.
What sorts of input from the safety-goal development program would you view as potentially helpful to your decisions with i
respect to safety goals?
Question 5.
Do you have any other words of advice for us?