ML20247A370
| ML20247A370 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1989 |
| From: | Lewis H Advisory Committee on Reactor Safeguards |
| To: | Carr, Roberts, Zech NRC COMMISSION (OCM) |
| References | |
| ACRS-M-0024, ACRS-M-24, NUDOCS 8903290107 | |
| Download: ML20247A370 (3) | |
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, , UNITED STATES adXMadMfpg NUCLEAR REGULATORY COMMISSION y ;I ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MSHINGTON, D. C. 20666 3-A'[
.m. March 10,1989 L
- MEMORANDUM FOR: Chaiman Zech Commissioner Roberts Commissioner Carr Commissioner Rogers Commissioner Curtiss 1
FROM: Harold W. Lewis, ACRS Member
SUBJECT:
SAFETY G0AL POLICY You should know that I have been unable to persuade the ACRS to forward the following proposal as a fonnal letter, so that what follows reflects only.
my personal views. Obviously, I believe it to be a constructive sug-gestion, and am therefore forwarding it on my own. It has to do with what I regard as the appropriate next step in the great safety goal saga.
The ACRS has often observed in letters to you that the principal use of the safety goals ought to be as standards against which to evaluate the effec-tiveness of the body of regulation which now serves to protect the public health and safety against the inherent risk of the nuclear enterprise.
(Comittee's point, my words.) Since the goals have now been promulgated and accepted as statements of the Comission's policies, the time would appear to me to be ripe to start a serious and substantial effort toward such an evaluation, in the context of the goals. Clearly, this cannot be done by the staff, not only because of inevitabic appearances of self-interest, but also because the staff is so deeply involved in the pressing regulatory matters that it would be unreasonable to ask them to develop the necessary perspective.
I believe that such an effort could be extremely important, and lead to genuine insights, to say nothing of representing the next logical step in the Comission's effort to rationalize regulation. The Comission, in my view, took a forward step in promulgating the goals, and the next-is.
clearly an impartial judgment about whether the goals are in fact being met. I would not presume to prejudge the outcome of such a review, but can see great value to the Comission either way.
The Comission could begin by exploring means through which such an eval-uation might be performed by an informed but impartial group, recognizing the difficulty inherent in assembling such a rarity. I do not envisage a ten-year study involving hundreds of man-years, and resulting in an inscru-table eight-volume report, but rather a modest effort less than a tenth that size. The point is to get a defensible judgment, not an encyclopedia.
While I do not wish to prejudge the composition of such a group, it is obvious that quality and credibility are the principal criteria. There are 8903290107 89031o PDR ACRS V (
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examples of success in such an enterprise. The Commission was well served by the.Rasmussen Study which, even though less than perfect (and I was among its critics), ushered in a new era of semiquantitative regulation.
Other organizations have benefited from strong Academy studies. The organization of such a study for maximum usefulness would require care, but.
I believe the outcome could well justify the effort.
cc: ACRS Members R. F. Fraley, ACRS e
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n NUCLEAR REGULATORY COMMISSION 5 $ ADVISORY COMMITTEE ON REACTOR SAFEGUARDS o, ,
WASHINGTON, D. C 20555
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March 24, 1989 MEMORANDUM FOR: Jim McKnight Document Control Systems FRON: Ethel Barnard Advisory Committee on I actor Safeguards The attached ACRS document is provided to you for listing on the accessions list. Please forward to the Public Document Room.
Attachment:
ACRSM-0024 Lewis ACRS Nember memo 3/10/89 to NRC Commissioners, Safety Goal Policy 0
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