ML20217D237
| ML20217D237 | |
| Person / Time | |
|---|---|
| Issue date: | 01/12/1998 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20217D082 | List: |
| References | |
| SECY-97-287-C, NUDOCS 9803270358 | |
| Download: ML20217D237 (2) | |
Text
Tressure island BSC' ID:7028947414 JAh 11'98 22:16 No.023 P.05 NOTATION VOTE RESPONSE SHEET TO: John C. Hoyle, Secretary FROM: CHAIRMAN JACKSON
SUBJECT:
SECY-97-287 - FINAL REGULATORY GUIDANCE
. ON RISK-INFORMED REGULATION: POLICY ISSUES Approved XX Disapproved Abstain w/ Comments Not Participating Request Discussion COMMENTS: a 1
i See attached comments.
SIGNATURE Release Vote / XXI January 12, 1998 DATE i
Withhold Vote / /
Entered on "AS" Yes No 990327o358 900319 /
RESP DE hPDR
Chairman Jackson's Comments on SECY-97-287, Final Regulatory Guidance on Risk-Informed Regulation Policy issues I approve the staff recommendations on policy issues related to the final version of risk-informed regulatory guidance.
Since the staff is recommending that the basic approach for treating uncertainties contained in DG-1061 be retained in the final version of the regulatory guide, as the pilot programs are completed, the salient features of the decision-making process should be documented to ensure a consistent, scrutable and common understanding as to how risk-informed decisions should be promulgated. Particular focus should be given to the staffs treatment of uncertainty and the role of increased NRC management attention in the decision-making. I remain
. particularly concemed about the role of uncertainty in the decision-making process. While, I continue to believe that it is possible to be mislead by relying on on mean values with little or no regard to CDF- or LERF-associated uncertainties, I realize that elaborate methods for quantifying and applying uncertainty may unnecessarily limit risk-informed initiative, and that consideration must be given to the unquantifiable benefits of proposed changes.
In addition, a risk informed approach should not focus exclusively on allowing risk increases. A balance is necessary if risk insights reveal significant vulnerabilities, risk reduction may be called for. In addition, in a risk-informed framework, it may be possible to control or reduce regulatory burden, by balancing resource requirements with the risk importance of corresponding regulatory activities, without any corresponding increase in core damage frequency (CDF) or large early release frequency (LERF). This type of balancing may provide a quantitative measure of regulatory effectiveness. Where practical, the staff should consider these types of evaluations prior to considering CLB changes that cause risk (CDF and LERF) to increase.
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