ML20002C466
| ML20002C466 | |
| Person / Time | |
|---|---|
| Issue date: | 11/28/1980 |
| From: | Libarkin M Advisory Committee on Reactor Safeguards |
| To: | Sege G NRC OFFICE OF POLICY EVALUATIONS (OPE) |
| References | |
| FRN-45FR71023, RULE-PR-50 NUDOCS 8101100341 | |
| Download: ML20002C466 (2) | |
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NUCLEAR REGULATORY COMMISSION
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3, November 28, 1980 VRC PL"dLIC DecGMEE.%.'t 0
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MENORANDUM FOR:
G. Sege Office of Policy Evaluation P,
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FROM:
M. W. Libarkin fg us #
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SUBJECT:
CRITERIA FOR JUDGING A SAFETY G0AL FORMULATION During the November 20 meeting of the Steering Group on Development of Cof sf Safety Goal it was decided to concentrate the Group's attention on three \\g extant approaches to formulating criteria:
The criterion sets suggested (1) in the August 1980 paper by Mattson, Ernst, Minners and Spangler, and (2) by Slovic, et al in a recent draft research report; and the suggested categories of criteria in your working paper of November 14.
I believe that the decision was a mistake in view of the fundamental difference in the nature of the suggested approaches. The two former are, in fact, suggested sets of criteria for judging the adequacy of a risk management framework; the latter is a suggested set of categories from which sets of such criteria might be drawn as options.
In order to make appreciable headway, the Steering Group should focus on one approach or the other.
My own choice would be to work on options for the actual criteria, without attempting to set up more general categories from which suggested criteria sets might subsequently be drawn.
The latter approach, while it does satisfy a certain sense of order, will lead unavoid-ably (! am afraid) to such wrangles as: does a particular criterion (e.g.,
" measurability") belong in the category of " criteria of result" or should it properly be included with the " criteria of practicality." That would forward no useful purpose!!
Beyond that, I would like to comment on several statements in the discussion, in your working paper, of " Criteria of Reach," since they seem to embody core assumptions about some of the central issues in establishing a risk management framework.
I do not know whether other Steering Group members share your views, but I believe that tne conclusions should be arrived at after scme 7
discussion, rather than being assumed a priori, if they are to be used in the l
formulation of goals or criteria recommended to the Commission.
(Refer to page 5 in the November 14 working paper.)
o "There is a widely shared view that the core issue in safety-goal formulation relates to power-reactor accident considerations -- more particularly, major accidents."
Comment:
It may well be that an actual analysis of risk contributors shows that the aggregation of risk due to lower consequence, higher probability events results in a more serious impact on individuals or the public; the possibility, at least, should not be ruled out without discussion.
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1-G. Sege November 28,1980 o
... At issue here is to what further extent (beyond major accidents) power-reactor safety is covered by a candidate policy approach.... A case can be made here for giving particular weight to sabotage, because... normal operation... has had a safety record that suggests absence of major policy causes...."
Comment:
In view of the continuing public and political concern over low-level radiation effects, normal operation (and expected releases) should not be simply shunted aside in any risk management frame-work suggested to the Commission.
o "A further broad concept is whether the goal covers... nonreactor facilities and processes....
The most notable issue here is that of radioactive wastes."
Comment: From am imposed risk standpoint, mining, milling, and transport may be more significant than waste disposal.
cc:
E. Hanrahan, OPE R. Bernero, RES K. Goller, OSD M. Ernst, NRR G. Page, NMSS
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