ML20235P043
| ML20235P043 | |
| Person / Time | |
|---|---|
| Issue date: | 03/06/1985 |
| From: | Bernthal F NRC COMMISSION (OCM) |
| To: | Asselstine, Palladino, Roberts NRC COMMISSION (OCM) |
| Shared Package | |
| ML20235N989 | List:
|
| References | |
| FOIA-87-300 NUDOCS 8707200315 | |
| Download: ML20235P043 (3) | |
Text
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UNITED STATES e
NUCLE AR REGULATORY COMMISSION
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W ALHINGTON, O C. 20555 k, *
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OFFICE OF THE COMMISSION E R LIMITED DISTRIBUTION, MEMORANDUM FOR:
Chairman Palladino Commissioner Roberts Commissioner Asselstine Commissioner Zech FROM:
Frederick M. Bernthal PROPOSED REVIEW OF NRC RESEARCH PROGRAMS AND POLICY The recent APS report on source term issues strongly reinforces a view which I had informally submitted for Comission consideration in December, namely, that a comprehensive review of NRC research programs is l
urgently needed. One is led to this conclusion not so much by what APS said about source term i.echnical issues per se, as by what APS said and '
implied about nuclear safety research in general.
Developing Comission policy on safety goal, severe accidents, source terms, advanced reactors, and backfitting controls will further intensify the demands on agency research procrams and priorities. At the same time, budgetary pressures in the research area will continue to worsen unless we can provide to Congress and the OMB a cogent, f6resighted, and reasoned. justification for NRC's overall research effort.
I would argue the likely need for a restoration of the severe cuts in many of those l
programs, but such a restoration can only come with establishment of clear Comission policies and priorities.
l The APS report raises fundamental questions of NRC management of its broad research mandate (not that the NRC is alone in its problem).
Though individual programs and the professional cadre may very well be j
excellent, integration of those programs into a purposeful, goal-oriented effort has cpparently been substantially deficient.
Indeed, many of the problems implicitly or explicitly identified in the APS report suggest a i
generic c'ifficulty (poor communications between contractor laboratories l
and RES; lack of adequate internal peer review of key orogram elements; failure to integrate and document research progress as represented in published and unpublished reports; failure to legitimize and ' certify" research results and progress by publication in peer-reviewed open literature; inadequate treatment of uncertainties).'
Moreover, there appears to be widespread misunderstanding by the Congress, and indeed within the agency itself, of the distinction to be made between two equally important and justifiable components of NRC's safety research charter:
ONDASHB7-3OO PI)R Y
.(11 Elements'of the broad se'ety research role left over frorin the old AFC, specifically that portion which fosters certain:U.S.
government safety research programs under the aegis of NRC, just as other basic and applied research prourams-are carried out in the national interest under the aegis of NSF, DOE, and NASA.
l (2) The more limited, regulatory-product-oriented confirmatory research that should be largely determined on. order, so tc speak, by the specific needs of N'1C's user offices.
Without prejuccing what the balance between these two categories of l
research shoulc be, I believe it is imperative for the Commission and the l
l Congress to recognize and clarify these functions, each important in its own right, so that policy decisions consistent with adequate and stable funding can be made.
In this context, the dramatic increase in foreign safety research, much of it complementary to the U.S. program, must be noted. While the U.S.
may never again be alone as the world leader in safety research, fundamental policy considerations dictate the NRC's leadership role in preserving a mejor U.S. presence in the world safety research community..
For all of,tbe ebove reasons and more, it seems clear that a strategic rethinking >of MC's research program is necessary and timely. Whether or not the ACRS might be the appropriate arm of NRC to lead such an endeavor, it is vitally important, in my judgment, that the study involve experts outsik the agency in a prominent and meaningful way.
The. charter of this special task force should address the above strategic considerations, and such other issues as the Commission may define, e.g.:
Which elements of RES programs are identifiable in category o
(1) and which in category (2) above? How should the programs in these two categories be manaced and coordinated, i.e.:
Is the current overall research program and organizational structure providing the stability, direction, and sense of purpose needed needed to achieve agency and broader U.S.
safety research obiectives?
.Is the present organizational relationship between the offices that require research servicas (mainly NRR) and the principal office responsible for carrying out that research (RES) appropriate and effective?
Are the mechanisms in place for assurino clear objectives and timely responses by RES to NRR?
Does the organizational and physical separation of these two offices contribute to deficiencies and confusion of purpose? If so, what is the remedy?
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ll Are there important areas of research beinn neglected in o
current NRC research pronrams', Phat special coals or missions o,
in research should the agency' set?
g What lessons can be learned from the APS source tern study? -
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Has the Study identified at'least some of the-significant.
questions? If so, how can the agency answer them-q expeditiously?
le, If the Commission initiates such an evaluation of our research effort, it should be completed as quickly as possible, perhaps within six months of Commission action.
I would urge that the Coinmission giYe these matters early consideration.:
SECY please track responses, p(
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