ML20134D999
| ML20134D999 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, Maine Yankee File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/29/1996 |
| From: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| DSI-11-00005, DSI-11-5, NUDOCS 9610310157 | |
| Download: ML20134D999 (1) | |
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Date:
10/29/96 7:24pm '
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Subject:
Strategic Assessment (Forms submission) g
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Your name: Jmaes Lieberman E-mail address: jxi@nrc. gov 2
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Affiliation: nrc Full Mailing Address: James Lieberman Director Office of Enforcement USNRC Washington, D.C.
Number of the issue Paper: 12 Topic: 3 (responsiveness)
Jmaes Lieberman sent the following comment via the WWW server:
I am very concerned about an emphasis on risk based regulation for operating reactors.
Tne lessons of Millstone and Haddam Neck as well as Maine Yankee tells me that compliance will be more important as the reactor industry deregulates and is more subject to competition. The idea for performance based regulation works best in my view in industries whgich are well financed. Maybe perfromace based regulation would of been ok for plants of yesterday, but today with cost containment and economic pressure, NRC should be focusing on the fundamentals and programmatic issues. We cannot subscribe to the no harm no fowl theory which to me is performance based. We must insist that reqactors operate by design and not achieve success fortuitously because of margin considerstions. I am concerned that the recent IG report on the perfromace based mainteneance rule is misguided and will lead to the wrong result. It objects to the staff's implementation because the staff has taken a comp! liance approach.
In Millstone there were not a lot of performance problems but we were lucky. I am concemed that a focus on performance rather than root causes of potential problems will lead only to more Millstones. We need to focus not only on the results but also the process, procedures, training, the degree of questioning attitude, self assessments, etc so we can spot programmatic issues before negative results with impact on the public occurs.
In the nuclear business, it is too late when the meltdown occurs. We need to predict problems in advance. Compliance is a tool to do it. The agency needs to recognize this and staffitself accordingly.
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