ML20135B121
| ML20135B121 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/1996 |
| From: | Larkins J Advisory Committee on Reactor Safeguards |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| ACRS-GENERAL, DSI-13-00013, DSI-13-13, NUDOCS 9612040172 | |
| Download: ML20135B121 (3) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION c
,I ADVISORY COMMITTEE ON REACTOR SAFEGUARDS wAssiNaToN, D. C. 20655 a
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November 27, 1996 9'"*
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NOV 2 71996 MEMORANDUM TO:
John C. Hoyle, Secretar; Office of the Secre 0500 01 th
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FROM:
John T.
Exe tive Director
\\ N r,, i Advisory Committee on Reactor Safeguards
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SUBJECT:
COMMENTS BY INDIVIDUAL ACRS MEMBERS REGARDING DIRECTION SETTING ISSUES Attached for your consideration are comments by Drs. Dana Powers and Donald Miller, and Mr. John Barton, ACRS Members, regarding Direction Setting Issues # 2 (Oversight of the Department of Energy), # 13 (Role of Industry), and # 11 (Operating Reactor Program Oversight), respectively.
These comments represent the views of the individuals mentioned above and do not necessarily represent those of the ACRS full Committee.
Attachment:
As stated cc:
ACRS Members J. M. Taylor, EDO J. Milhoan, EDO J. Craig, RES 9612040172 961127 PDR NRCSA I PDR 13 Ds/3
s l-COMMENTS BY
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ACRS MEMBER DON MILLER l
ON STRATEGIC ASSESSMENT ISSUE PAPER DSI-13 ROLE OF INDUSTRY i
Option 4: NRC regulatory guidance, primarily promulgated through Regulatory Guides, l
extensively uses consensus industrial standards as a basis. Typically this is accomplished through endorsement of these standards, with appropriate exceptions. In many cases, these standards have been developed with a primary objective of serving as a basis for Regulatory 1
l Guides and have also benefited from participation by NRC staff.
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In the past several years, guidelines have been developed by industrial groups with leadership provided by industrial organizations (or its predecessors) such as the Electric Power Research l
Institute (EPRI) and the Nuclear Energy Institute (NEI). This approach has been used to j
address specific regulatory issues, the industry believed more definitive guidance was required. These guidelines often have been developed with input from NRC staff. They, unlike consensus standards, have not used the consensus process.
Guidelines.dso have not been developed with the objective of endorsement by the NRC as a l
Regulatory Guide, although on several occasions guidelines have been endorsed through a
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safety evaluation report (SER). The development of guidelines has been a valuable i.
contribution to improving the regulatory process.
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The NRC should continue to increase its encouragement of industrial participation in I
standards, codes and guidelines. With the " downsizing" of plant staff's and NRC, the NRC i
should establish a high priority on Option 4. This option has an established record of 1
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providing significant contribution to the regulatory process. Option 6 should be selected at a minimum to maintain the current level of contribution.
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Although it is recommended that priority be placed on Option 4, there are many opportunities for expansion of the industry role in regulatory oversight. For example, industry has taken an expanded role in operator license examination. For example, publication of plant-specific perfonnance indicator device would be an appropriate area for involvement by industry.
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