ML20215F891
| ML20215F891 | |
| Person / Time | |
|---|---|
| Issue date: | 11/10/1986 |
| From: | Kelber C NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20215F873 | List: |
| References | |
| FOIA-87-300 NUDOCS 8706230045 | |
| Download: ML20215F891 (4) | |
Text
3 November 10, 1986 9
MEMORANDUM FOR:
E. Beckjord, Director Office of Nuclear Regulatory Research FROM:
C. N. Kelber
SUBJECT:
COMMENTS ON NAS RECOMMENDATIONS After your discussion with the Advisory Committee on Reactor Safeguards on Noveniber 6, I considered at lencth your remarks that the coming reorganization on the NRC poses difficulties with the acceptance of some of the NAS recommendations in their forthcoming report.
I list the recommendations on the following pages, together with a reconsidered reply taking into account your remarks.
Because the recommendations are connected in many ways, there are many ramifications to the reorganization. You may want to consider in depth three optiens:
1.
Respond to the NAS, more or less along the lines indicated in the attachment; 2.
Accept the report with the assurance that the recommendations will be given the " fullest consideration; or, 3.
Accept the report with thanks but note that it has been overtaken by the passage of time.
(This is a viable option because the NAS was late in getting started and did delay their finish.)
Charles N. Kelber cc: D. F. Ross Division Directors j
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REPLIES TO NAS COMMENTS
- 1. Research on Reactor Safety Should be Continued.
Ans. We all agree,on this point.
- 2. There are serious management problems affecting NRC sponsorship of research. Suggested solutions are:
- a. Maintain programs at FY 86 level.
1 We agree.
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- b. Bring in very high caliber people with active research experience to bolster top and middle management at RES.
Ans.: The recent reorganization in RES with its intermingling of standards development personnel among the research functions, to be followed by a major NRC reorganization that will cdd further regulatory functions and personnel to RES renders this recommendation impossible to follow. This is made even worse by these additional considerations: (1) The continuing downward pressure on federal personnel ceilings; and, (2) the management culture at NRC which, as shown by a recent survey, places highest value on "getting along with others," and lowest value on
" technical competence." Such a culture is antithetical to the rough and tumble of active research.
- c. Separate the functions of standards development and research.
Ans.: The actions intended in the major reorganization of the NRC will further entangle research in the regulatory activities, in a way that appears to most observers to strengthen the role of the Research Office.
Critics may argue that this violates the rubric of the Energy Reorganization Act of 1974, but, in fact, we believe this action responds to comments received from' Congressional oversight committees and the OMB. The reorganization will make tighter, more efficient and effective NRC with the Office of Research an important part of the organization. Thus, the NRC does not agree with the NAS recommendation.
- 3. Funding of research should be guided by the following considerations:
- 1. The US gov't should fund a significant amount of NPP safety research;
- 2. The utilities and vendors do more than they now do;
- 3. NRC should continue to be a direct fundor of research; 4. DOE & NRC
a -
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should encourage more cooperative work with industry; 5. Universities and others with relevant skills should be more actively involved with setting the research agenda; 6. The Division of contracts should do as other gov't agencies and facilitate contracting for research with universities and others; 7. Balance between DOE labs and others needs to be reviewed; 8. Long term and exploratory research should be maintained; and, 9. The cost of research should be internalized.
Ans: While we basically agree with the thrust of these recommendations, we find that, except for working with the. Division of Contracts.to revise rules for contracting with universities, the impending reorganization does complicate the problem of implementation.
In particular, the intermii.gling of regulatory functions heightens a conflict of interest problem, and may make legislation to internalize costs more difficult to rationalize because of the conflict of interests that can arise.
As far as agenda setting is concerned, current staff actions to censor contractor reports will negate most efforts in this direction, and this will be fortified by the addition of regulatory i
staff and functions.
4 & 5. These concern program emphasis and may be changed in the final draft.
- 6. The RES director should use best researchers; establish a coherent planning process; make routine use of review groups; establish a strong, independent advisory group; strengthen links with users; ensure diversified support.
Ans. The use of best researchers is intended, but NRC managers'
. emphasis on congeniality mediates against this; good planning is our goal; the staff appears to be strongly opposed to review groups and peer review processes generally, and the reorganization of NRC will subsume users into RES, 7 & 8 These are aimed at EDO and OCM.
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