ML20043H269

Discusses ACRS 362nd Meeting on 900607-09 Re Proposed Rule to Implement ERDS

ML20043H269
Person / Time
Issue date:	06/12/1990
From:	Wylie C Advisory Committee on Reactor Safeguards
To:	Carr K NRC COMMISSION (OCM)
References
FRN-55FR41095 ACRS-R-1395, AD32-1-8, NUDOCS 9006220339
Download: ML20043H269 (3)

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UNITED STATES

'8 NUCLEAR HEGULATORY COMMISSION ACRSR-1395

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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS PDR WASHINGTON, D, C. 20586 g

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1 June 12, 1990 i

i The Honorable Kenneth M. Carr Chairman U.S.. Nuclear Regulatory Commisnion

.I Washington, D.C.

20555

SUBJECT:

PROPOSED RULE TO IMPLEMENT AN EMERGENCY RESPONSE DATA SYSTEM During the 362nd meeting of the Advisory Committee on Reactor Safeguards, June 7-9, 1990, we discussed with members of the-NRC l:

staff their proposed rule to implement an Emergency Response Data System (ERDS).

We also had the - benefit of discussions with.a representative of NUMARC and of the referenced documents.

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In previous reports to the commission dated May 6 and November 12, i

1980, the Committee expressed its' concern that a proposed nuclear data link could lead to inappropriate NRC involvement in - the management of any future serious nuclear power plant accident. -We continue to believe that all operational aspects of accident 1

management must be the responsibility of the licensee / owner /op-erator.

. We are aware that the NRC. has the authorityL and - the responsibility to manage, for example, to give orders concerning the operation of a nuclear power plant, if that is determined by the Commission to be necessary to protect public health and safety.

What concerns us is the possibility of informal intervention l

without the formal assumption of authority and responsibility, and 3

in light of the examples of intervention during normal plant i-I operation to be found -in Appendix A of draft NUREG-1395 as; referenced in SECY-90-80, " Draft Regulatory Impact Survey Report,"

L our' concerns ' are not alleviated' by-staf f insistence that ' the j

existence of an ERDS will not make this more likely.

L We recognize that the NRC has a responsibility to provide informa-

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tion to various governmental entities and to the media.

.However, we also looked-for evidence, both in the documentation provided to'.

us and in our meeting with the staff, that the existence of an ERDS would decrease public risk.

Although both the documentation.and.

the staff's presentation make statements that risk will. be decreased, no evidence is provided to back up these assortions.

Thus, if the ERDS is to be treated as a backfit, the benefit side of,,the-J edgerpnta-itis crrly tatements that more information, and y

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.o The Honorable Kenneth M. Carr 2

June 12, 1990 more accurate information, available in the NRC Incident Response Center, will decrease risk.

We were also told that the information that ERDS can provide would free. the plant. operational staff from the burden of having to respond to questions from NRC headquarters.

-However, since any serious accident is likely to result from and to produce unexpected phenomena, it is plausible to suppose that the existence of ERDS might actually ' increase the number of questions asked.

We also observe that in station blackout, which many PRAs predict as a major risk contributor, ERDS would be unavailable.

We acknowledge that the system has positive aspects, but in our view they are outweighed by what we view as negatives.

We therefore do not support the proposed ERDS, and thus we do not endorse the proposed rule.

If, however, it is decided to continue with ERDS, we recommend that it not be made compulsory until several years of experience have indicated the form it should take and the way in which it should be operated.

Some of the problems that have occurred with the safety parameter display system could have been avoided if experience had been gained before these systems were mandated.

Additional comments by ACRS Members James C. Carroll,- Ivan Catton, and Carlyle Michelson are presented below.

Sincerely, s

L Charles J. Wylie l

Acting Chairman i

l Additional Comments by ACRS Members James C. Carroll. Ivan Catton, and Car 1vle Michelson Although we share the concerns about the accident management issue i

discussed in the Committee's letter, we believe that the potential benefits of the ERDS in supporting the NRC's role in accident l

situations are of suf ficient importance to outweigh these concerns.

Accordingly, we would recommend that the staff proceed with the proposed rulemaking unless it becomes clear that the present voluntary program will ensure industrywide participation.

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Referencen:

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Draft Proposed Rulemaking Package (transmitted by note dated May 31, 1990 from Tony DiPalo, RES), with enclosures:

(1)

Federal Register Notice of Proposed Rulemaking,

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The Honorable Kenneth M. Carr 3

June 12, 1990

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Regulatory Analysis of the Proposed Rule Concerning the Emergency Response Data System, and (3)

NUREG-1394,

" Emergency. Response Data System (ERDS)

Implementation" 2.

U.S. Nuclear Regulatory Commission draf t NUREG-1395, " Industry Perceptions of the Impact ~ of the U.S.

Nuclear Regulatory Commission on Nuclear Power Plant Activities," dated February 1990.

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