ML20134E001

Staff Comments on DSI-12 Re Risk Based Regulation for Operating Reactors.Nrc Need to Recognize That It Is Too Late When Meltdown Occurs

ML20134E001
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-12-00006, DSI-12-6, NUDOCS 9610310158
Download: ML20134E001 (1)

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2)s I- /4 From: webadmin <webadmin@nrc. gov > g 7 To: WND1.WNP2(secy),NCD1 A.ncp2(webadmin) 8 4 4 Date:

Subject:

10/29/96 7:24pm Strategic Assessment (Forms submission) gDO #

OCT ? 9 ggy z Your name: Jmaes Lieberman s p}[D of the E-mail address: jxl@nrc. gov .

Affiliation: nrc +

Full Mailing Address: James Lieberman # g Director Office of Enforcement USNRC Washington, D.C.

Number of the issue Paper: 12 i Topic: 3 (responsiveness) 2 Jmaes Lieberman sent the following comment via the WWW server:

i

! I am very concerned about an emphasis on risk based regulation for operating reactors.

Tne lessons of Milistone 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 l because of margin considerations. I am concerned that the recent IG report on the perfromace based mainteneance rule is misguided and willlead to the wrong result. It objects to the staffs implementation because the staff has taken a comp! liance approach.

J In Millstone there were not a lot of performance problems but we were lucky. I am concerned 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 resuits 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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