ML20153B240
| ML20153B240 | |
| Person / Time | |
|---|---|
| Issue date: | 03/15/1988 |
| From: | Kerr W Advisory Committee on Reactor Safeguards |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| REF-GTECI-A-45, REF-GTECI-DC, TASK-A-45, TASK-OR ACRS-R-1288, NUDOCS 8803210552 | |
| Download: ML20153B240 (2) | |
Text
G M E-/A88
,oj,,,,%
UNITED STATES I '
'p-NUCLEAR REGULATORY COMMISSION o
e ADVISORY COMMITTEE ON REACTOR SAFE /,UARDS 0,
WASHINGTON, C. C. 20555 e'g
..+
March 15, 1993 The Honorable Lando W. Zech, Jr.
Chairinan U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Chairman Zech:
SUBJECT:
ACRS COMMENTS ON THE NEED FOR GREATER C0HERENCE AMONG NEW REGULATORY POLICIES buring the 335th meeting of the Advisory Comittee on Peactor Safeguards (ACRS), March 10-12, 1088, we discussed the problem whicn we see as an increasing lack of coherence and integration among several separate areas of policy raking within the NRC. We understand that the NRC Staff is atterpting to develop an integrated approach to implementing the Comission's Severe Accident Policy.
In the usual course of events, we would expect to review the Staff's proposals at a later date.
- However, we believe it might be helpful to forward a few comments to you at this time.
The Severe Accident Policy is only one of a number of new Comission policies and programs concerning nuclear power plants that have been advanced over the past two or three years.
Others relate to the safety goal, standardized plant designs, ISAP, and advanced reactors.
In addition, the resolution of USIs and GIs has led, or might lead, to important new requirerents and guidance for licensees in several areas.
Although the NRC Staff, the ACRS, and the Comission have provided some overall guidance toward integration of these policies and new require-ments, we bclieve this has been insufficient.
As a result, licensees can be confused or burdened with contradictory new requirements fron different parts of the NRC Staff.
For example, a part of the resolution of USI A-45, "Shutdown Decay Heat Removal Requirements," proposed some months ago, incorporated the use of safety objectives similar to, but not the same as, objectives being developed in implementation of the Safety Goal Policy.
8803210552 880315 PDR ACRS PDP 1288
O The Honorable Lando W Zech, Jr. March 15, 1988 We offer two suggestions for your consideration:
(1) The attempt to integrate ?volving policies and issues should not be limited to those embodied in the Severe Accident Policy, but should incorporate the entire range recently addressed in policy state-i ments or ccrrently before the Comission.
(2) The Safety Goal Policy should not be viewed as just one of the several policies and issues on today's table.
Instead, it should be seen as an umbrella policy which should be the principal tool for integrating and providing coherence to the entire set.
We expect to review the integration program being developed by the NRC Staff when it is available.
Sincerely, William Kerr Chairman 4
e 1
9 i
_-_.