ML20127N412
| ML20127N412 | |
| Person / Time | |
|---|---|
| Issue date: | 11/16/1992 |
| From: | Shewmon P Advisory Committee on Reactor Safeguards |
| To: | Selin I, The Chairman NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1503, FACA, NUDOCS 9212010244 | |
| Download: ML20127N412 (2) | |
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'4 J 4 tity%o UNITED STATES f'
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' NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS ACRSR-1503 s
- WASHIN'JTON, D C. 20665 PDR
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- November 16, 1992 The Honorable Ivan Selin .
Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear ChairmTn Selin:
1
SUBJECT:
RISK-BASED REGULATION During the 391st meeting of the Advisory Committee on teactor '
Safeguards, November 5-7, 1992, we reviewed a draft Cownission '
paper on Risk-Based Regulation. The paper responds to the Staff Requirements Memorandum (SRM) dated March 26, 1992. During this meeting, we had the benefit of discussions with representatives of the NRC staff, and of the document referenced.
We interpret the Commission's charge-to the staff-as reflecting a recognition of the increasingly sophisticated and widespread use of analytico1 risk assessment techniques in the nuclear enterprice,_a-natural evolution 'of a process that began with the 1975 publication of the Reactor Safety Study, WASH-1400.- Since it is now possible l to make informed and quantitative statements about many (but.not all) of the contributors to nuclear risk, it is correspondingly possible to optimize the deployment and use of the regulatory-resources available to the Commission. The SRM directed the: staff to both examine the feasibility of such_a risk-based approach:to regulation and to suggest means by which it could;be implemented.
The draft paper on which we ' were ' briefed is the preliminary response to that charge. :l We - would prefer not to comment in detail on the paper itself, _!
except to note that it needs a great deal of work before it can be consides.ed responsive to the Commission's charge at the-level of sophistication-demanded by-the importance of the question.- The staff is still working on the paper,_and we expect to see a later and - improved version. It is simp?.y - not ' y_et - ready for public.-
comment.
Far more important to_us is.the issue of coherence of the_various efforts now in progress in various parts of the staff to develop .
and implement activities that could be collected under the name of risk-based regulation. We have commented earlier about the 4 Maintenance Rule, Regulations Marginal to Safety, and other
@000M W 9212010244 921116 6 -PDR- ACRS-g i
R-l#03 P"
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'i The Honorable Ivan Selin 2 November 16, 1992 initiatives involving the use_of risk analysis, and ave at_this meeting heard about. Risk-Based Regulation, revision of the Regulatory Analysis Guidelines, and the Prioritization-of Generic Safety Issues. Each of these requires informed use of quantitative risk information and _ appropriate. attention to the Commission's safety goals, yet each is being analyzed by an independent-group, with an independent perspective on the NRC's needs. In addition to-this, there is the PRA Working Group, whose progress we_have been following close"y. . We are unable to find any focal point for all these efforts, except at the level of the EDO.
We continue to call for increased coherence in the treatment of all these matters, bound to each other by the common need to weave the-threads of the safety goals (the expression of the ultimate objective of regulation) and quantitative risk assessment (the tool that makes more directed risk management possible) into the NRC fabric. If it is not done at the level of the EDO it will not be done, and resources that could be devoted to assuring nuclear safety will be squandered.
In the past we have suggested strong measures to address this problem. While not pushing any particular solution, we still ;
believe that the collection of issues discussed here is important to the future performance of the agency. The coherence problems will not be solved by an incoherent effort.
Sincerely, kf%%
Paul Shewmon Chairman
Reference:
Memorandum dated October 16, 1992, from Warren Minners,' Office of Nuclear Regulatoty Research, NRC, for Raymond F. Fraley, ACRS, transmitting Draft SECY Paper (undated) from James M. Taylor, Executive Director for Operations, for The Commissioners,
Subject:
Risk-Based Regulation (Predecisional)
,