ML20128E487
| ML20128E487 | |
| Person / Time | |
|---|---|
| Issue date: | 12/16/1992 |
| From: | Rogers K NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9302100476 | |
| Download: ML20128E487 (2) | |
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H0TATI0H V 0 T Ej RELEASED TO THE PDR l
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T0: SAMUEL J. CHILK, SECRETARY OF THE COtMISSION FROM: C0t44ISSIONER R0GERS
SUBJECT:
SECY-92-337 - RESPONSE TO REC 0l44ENDATIONS OF THE MATERIALS REGULATORY REVIEW TASK FORCE APPROVED e I"e urg DISAPPROVED ABSTAIN m n__
NOT PARTICIPATING _
REQUEST DISCUSSION C0ff4ENTS:
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Commissioner Rogers' Comments on SECY-92-337 }
I agree with the comments of Chairman Selin and Commissioner Remick. To implement the recommendations of the Materials ;
Regulatory Review Task Force, the staff has proposed a major ]
effort to develop and revise regulatory guidance, conduct team assessments of licensee facilities on an ongoing-basis,_and do several rulemakings. This is an ambitious proposal to regulate a relatively small number of licensees and I am concerned that it may not place an appropriate share of the burden on these licensees to assure the safety of their own facilities. In this ,
regard, I would make several recommendations.
First, I believe that the staff should encourage the licensees to establish a mechanism (perhaps modeled after INPO) for ,
cooperative and effective self-regulation. Such a mechanism would need to overcome certain obstacles that might be posed by the desire of licensees to protect proprietary information. To the extent that it could do so, it could reduce-the scope and frequency of staff team assessments that would otherwise be needed to assure safe operations.
Second, I believe that the licensees should do integrated safety analyses for their facilities at the earliest possible tire.- The
, staff intends to do a rulemaking that would require the licensees to do these analyses. I think that this is fundamentally an excellent idea that would help to assure that.licenseos assume their responsibility for safety; however, such rulemaking would not start before FY94 according to the action plan. Meanwhile, a number of other actions would be underway, I believe that integrated safety analyses, performed by the licenseos, could be unique in their ability to inform both the staff and the--
licensees of potential safety concerns that should-be the focus of other action plan efforts. In this vein, I recommend that the staff strongly encourage the licensees to develop (subject to staff approval) a consensus approach to doing integrated safety analyses and to start them as soon as practicable.- Perhaps the mechanism for self-regulation recommended above could be applied to developing this consensus approach.
Finally, I recommend that the risk-analysis component of the of the integrated safety analyses include quantitative estimates of the probabilities of potentially high-consequence accident sequences. One of the root causes of the GE-Wilmington incident-
-was that--the 1iconsee did not--consider-criticality to be-a - - - -
credible accident. I believe that the disciplined, thoughtful process that must be invoked to quantify probabilities can help to forestall such thinking.
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