ML20055D005
| ML20055D005 | |
| Person / Time | |
|---|---|
| Issue date: | 05/02/1990 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9007030068 | |
| Download: ML20055D005 (3) | |
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N0TATIO gj 0000,oo000000000000 ntLEASED TO THE PDR l
RESPONSE SHEET
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SAMUEL J. CHILx, SECRETARY OF THE COMMISSION FROM:
COMMISSIONEBCURTISS
SUBJECT:
SECY-89-102 - IMPLEMENTATION OF SAFETY G0AL POLICY APPROVED * *" "*'*
DISAPPROVED ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION COMMENTS:
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See attached comments.
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M1 SIGNATURE 5/2/90 9007030068 900502
[8RseEEc^i@ieU5E'Poc DATE YES
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70 NO ENTERED ON "AS"
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am anuewscaw uwe i
' t, Commissioner Curtiss' comments on SECY-89-102:
I approve implementation of the Safety Goal Policy Statement in the manner proposed by the Chairman, subject to the following comments:
1)
I agree with the statement of the Chairman that the staff should routinely consider the safety goals in developing and reviewing regulations and regulatory practices.
To achieve this objective, I would recommend that we direct the staff to establish a formal mechanism for ensuring that future regulatory initiatives are evaluated for conformity with the
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safety goal.
Recognizing that the state of knowledge is i
such that the degree to which regulatory issues can be l
related to the safety goals will vary considerably, the staff's consideration of the safety goals could range anywhere from quantitative risk comparisons involving the safety goals themselves to a deterministic judgment that, in light of the safety goals and available knowledge (or lack j
thereof), a given issue does or does not warrant a change to the regulations or regulatory practices.
In any case, what i
I in impor* ant is that the safety goals be considered in formulat ng regulatory policy.
I believe that the
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est;b' ient of a formal mechanism to accomplish this,
)
i incin a requirement for documentation of the staff's analyn.4, is necessary to translate what may otherwise be construed as merely a platitude (i.e., that the staff should routinely consider the safety goals) into a tangible reality.
2)
I agree with Commissioner Remick's proposal that we modify the Safety Goal Policy Statement to incorporate a large l
release guideline and, furthermore, that we define large release in the Policy Statement.
On the definition of large release, I generally agree with the site-independent approach suggested by Commissioner Remick, but would propose the following alternative formulation:
"A large release is any release from a reactor event involving core damage and the failure or bypass of all, engineered barriers designed to prevent the release of radioactive materials to the environment."
3)
I agree with the Chairman and Commissioner Remick that containment performance objectives might be useful for establishing containment design requirements, but that such objectives should not be imposed as requirements themselves (i.e., they should not be used solely in a deterministic sense in individual licensing actions or in the staff's review of advanced reactor designs).
4)
Consistent with the views expressed in 3), above, I do not object to the use of a containment performance objective,
d expressed as a conditional containment failure probability (CCFP), subject to the followings a)
The CCFP objective should not be so conservative as to constitute a da facto new "large release guideline".
b)
Establishment of a CCFP should be approached in such a manner that additional emphasis on prevention is not discouraged.
In this regard, staff should develop appropriate guidance for establishing CCFPs to address this concern and provide a uniform methodology for implementing such an approach.
c)
Recognizing that it is entirely possible that a deterministically-established containment performance objective could achieve the same overall objective as a CCFP, starf should be prepared to review the merits of sech an approach (if proposed) and, if workable, accapt such an approach as an alternative to a CCFP.
5)
I have no objection to the use of a 10 per reactor-year CCFP for evolutionary designs, applied in the manner described in 3) and 4), above.
CCFP performance objectives for classes of plants beyond the evolutionary plants should be submitted to the Commission for approval, togethct with a justification l
for the recommended approach, t
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