ML25167A159
| ML25167A159 | |
| Person / Time | |
|---|---|
| Issue date: | 04/11/1984 |
| From: | Ebersole J Advisory Committee on Reactor Safeguards |
| To: | Palladino N NRC/Chairman |
| References | |
| Download: ML25167A159 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555 April 11, 1984 Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Dr. Palladino:
SUBJECT:
ACRS COMMENTS ON THE POSSIBILITY OF AN ORGANIZATION LIKE THE NATIONAL TRANSPORTATION SAFETY BOARD (NTSB) FOR NUCLEAR SAFETY Since the ACRS discussion with the Commission about the possibility of an NTSB-1 ike organization for nuclear safety has been postponed, we would like to pass on some recommendations we would have made during the meeting.
You will recall that the Committee and the Commission reacted negatively to the idea when it first appeared in 1978, partly because up to that time there had not been accidents recognized as worthy of the kind of de-tailed study implied by the creation of a new agency, and partly because there was confusion about the role of the study of precursors in accident avoidance.
Nonetheless, the Commission created the Office for Analysis and Evaluation of Operational Data (AEOD). It has provided independent analyses of operating events, and has contributed to the identification of precursors. We believe the time has come to take an additional step, by elevating its status to that of a Commission-level office.
Al though the original proposal for an 11NTSB 11 called for an independent organization (simply to assure its freedom to criticize the NRC), we have seen no evidence that the independence of AEOD has been infringed.
Yet, it is a part of the NRC Staff structure and conflicts are not beyond reasonable conjecture.
It seems to us prudent, now that AEOD has proven itself, to point to the future by removing this possibility.
Such conflicts are not unthinkable.
The NTSB has just issued its findings on the amazing event in which an Eastern L-1011 lost all three of its engines because 0-ri ngs were 1 eft off the master chip detector plugs in the lubricating oil systems on all engines during the same maintenance operation. The NTSB placed much of the blame on the airline and the main-tenance crew, but also placed substantial blame on the FAA inspectors for having failed to follow up earlier incidents of the same kind involving the same airline. Given the current reporting chain of AEOD, it is easy to see where problems might arise in a similar circumstance.
We believe there is much to be gained and little to be lost by having AEOD report at a higher organizational level, especially as we move to a more operationally or-iented NRC.
1887
Honorable Nunzio April 11, 1984 There is a clear administrative problem which we propose to solve by volunteering.
We would suggest that Commission overview of AEOD be sup-ported by asking ACRS to establish a standing subco11111ittee for that pur-pose.
Such a subcommittee could, inter alia:
(a) provide a critical link to the full Committee and thereby an ad-ditional link to the ColTfllission on the activities of AEOD, (b) meet frequently with AEOD for mutual reinforcement, (c) act as a technical bridge, to sharpen both groups' awareness of potential nuclear safety problems, and (d) seek full ColTfllittee action and Co11111ission support, as needed, to assure the independence and continuity of AEOD.
We believe the suggestion represents a reasonable compromise between the original idea of a wholly independent agency and the NRC organization now in place.
We would be happy to discuss these matters further with you.
Sincerely yours,
~~~
Jesse C. Ebersole Chairman 1888