ML20137M670

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Supports Substantial Agreement W/Commission Preliminary Option 1 & Option 2 Be Changed Somewhat to Reduce Emphasis on Option 1 & Increase Emphasis on Option 2
ML20137M670
Person / Time
Issue date: 01/23/1997
From: Rogers K
NRC COMMISSION (OCM)
To: Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, The Chairman
NRC COMMISSION (OCM)
Shared Package
ML20137M619 List:
References
COMSECY-96-060, COMSECY-96-60, DSI-11, SECY-96-060-C, SECY-96-60-C, NUDOCS 9704080150
Download: ML20137M670 (2)


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NUCLEAR RE U RY COMMISSIOA RELEASED TO THE PDR

) WASHINGTON, D.C. 20555 .

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  • date initials OFFmE OF THE COMMISSIONE R January 23, 1997 I

MEMORANDUM TO: Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan FROM: Commissioner Rogers .

SUBJECT:

COMSECY-96-060: OPERATING REACTOR PROGRAM OVERSIGHT, DSI-11 1

After a review of the Phase II Stakeholder Interaction Report and after listening to the Steering Committee briefing on January 13, I am in substantial agreement with the Commission's preliminary views. I would prefer, however, that the balance between l Option 1 and Option 2 be changed somewhat to reduce emphasis on Option 1, and increase emphasis on Option 2. While it is important to understand and apply lessons learned, Option 1 may put too much emphasis on recent events. Recent events are important, but they should not dominate our future plans. We should take the widest possible view of lessons learned, i considering the more distant past as well as the full breadth of ,

our experience.

Option 2, seeking new approaches, can be used to improve the regulatory process as the. industry's operating environment is changed by the process of economic deregulation. A changing i environment provides opportunities that otherwise may be unavailable.

I believe that some urgency should be assigned to establishing an objective standard (s) for the application of risk-informed, performance based regulation, perhaps in the form of individual plant safety goals. I would also encourage the staff to ensure that any relevant knowledge developed in the implementation of the maintenance rule be fully utilized in the development of risk-informed regulation.

I believe even limited implementation of Option 3 should be approached with some caution. Trying to redesign all, or a large part of, the reactor oversight process at one time probably carries a high probability of failure. I would encourage the

staff to identify opportunities for redesigning specific processes within the reactor oversight system, and then expand the scope as experience is gained.

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2 This Direction Setting Issue is obviously closely related to DSI-12, Risk-Informed, Performance Based Regulation, and DSI-13, Role of Industry. The staff should ensure that implementation plans developed for these issues are mutually compatible and do not create duplicate activities.

cc: EDO OGC

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