ML20005G153
| ML20005G153 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1989 |
| From: | Michelson C Advisory Committee on Reactor Safeguards |
| To: | Carr K NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1383, NUDOCS 9001180206 | |
| Download: ML20005G153 (2) | |
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UNITED STATES
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I AOvisoRY cOh4WTTEE ON REACTOR SAFLoUARDs l
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l December 22,198g m
The Honorable Kenneth M. Carr Chairman U.S. Nuclear Regulatory Comission Washington, D.C.
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Dear Chairman Carr:
SUBJECT:
C0HERENCE IN THE~ REGULATORY PROCESS listed a number of problems, but deferred any recome aE had had a chance to speak to the EDO.
This occurred so late in our L
. December meeting that it was impossible to prepare a report on this i
important subject with the: care that it deserves.
We therefore beg your indulgence while we defer still another month.
Nonetheless, we haie been briefed at this meeting on one of the increas-Y
_ingly important elements of the process-the SALP ratings and their use
--and believe it appropriate to single out the. subject for individual treatment.
We know you are aware of some. of the' problems of external
-cf - the ratings themselves, from the ; viewpointmisuse of the of coherence of the
- regulatory process.
- The SALP ratings are extremely important to the licensee, for both economic and other reasons; it is therefore essential that the process through which they are deterzined be as objective and credible as it is.
Possible to make it.
We recognize that there is not available a set of fully ~ objective performance indicators and that any rating system must therefore have an element of subjectivity.
It is then doubly important that the procedures incorporate a set of credible checks and balances to
- 1 minimize the effect of the personal predilections of the board members, 1
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-Instead we learned from this briefing that-the process is almost en-1 who not only appoints most of the Leard from among i
s-N but'is even free to reject an SALP rating he doesn't like, and reconsti-tute the board - as he wishes.
The rating therefore provides still effectively free of restraint.another weapon for the Administrator to enfo There is no appeal procedure. Even with the best of Regional Administrators this strikes us as unwise.-with the worst it could make a mockery of coherent regulation.
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l The Honorable Kenneth M. Carr December 21, 1989
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y l-rating is.to advise the Regional Administrator (though l
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then to help him advise the licensee We were also told that a licensee m.
At the end it wasn't clear which, L
keep his SALP rating constant, then that he needn't', and fin 611y th did.: If true, that-is not~ consistent regulation, i
what end?. You say wish to read the transcript of our meeting. Improvement t1 We could' continue, but the messa process which is out of control. ge.is that our staff has created a.
have reasonable: answers If indeed a 1 the questions we asked elements, even during a, prepared briefing devoted to the subject.
On this isolated example of 1' coherence, we think you should make a n
clear statement of.. the purpose of ~5 ALP ratings. insist that your staff implernent that purpose ~ and no other, insist that the staff not use the ratings as weapons to enforce obedience to idiosyncratic policies that 1
are not'yours, greatly dilute the Regional autarchy in the process, and.
i institute a workable set of checks and balances.
and they bring no credit to the regulatory process. Abuses of SALP abound, We also believe' that this is a sufficiently important problem to justify consideration of suspension of the program and issuance of no new SALP ratings until enough reform measures are instituted to lend credibility
-te_the process.
Sincerely,
.)
dw Ca lyle Michelson Acting Chairman t40 Docs PPR
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