ML25168A049
| ML25168A049 | |
| Person / Time | |
|---|---|
| Issue date: | 05/16/1983 |
| From: | Ebersole J Advisory Committee on Reactor Safeguards |
| To: | Palladino N NRC/Chairman |
| References | |
| Download: ML25168A049 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555 Honorable Nunzio J. Palladino Chairman May 16, l 9B3 U. S. Nuclear Regulatory Commission Washington, DC 20555 near nr. Palladino:
Subject:
ACRS REPORT ON REGIONALIZATION Ouring its 274th, 275th, 276th, and 277th meetings, February 10-12, 1983, March 10-12, 1983, April 14-16, 1983, and May 12-14, 1983, respectively, the Advisory Committee on Reactor Safeguards has continued to study the pl an for regionalization of certain NRC operations.
As a result of the discus-sion during the 276th Meeting, we sent you a letter on April 19, 1983 expressing concern about the potential negative impact of regionalization on reactor safety, but did not, at that time,. spell out the exact nature of our concerns.
For this reason, we thought it worthwhi 1 e to send you a clarification in the hope that that may help to focus the discussion.
Our major concerns are:
- 1. Dilution of technical talent:
ltJe are concerned about whether it is possible to form six adequately staffed multidisciplinary organ-izations (Headquarters and the Regional Offices) with the current NRC staffing and resource limitations.
- 2.
Fragmentation of multidisciplinary interaction:
The regulation of the nuclear industry calls for the consideration of complex systems and their integration, which requires t'1e application of many diverse disciplines.
Interactions among the needed disciplines are essential, and are facilitated when the people involved have easy access to each other.
We are concerned that regional ization will make this access more difficult.
- 3.
Division and confusion of authority between NRC Headquarters and the Regional Offices:
The potential for confusion as to where the ultimate authority of the Staff lies (with the Regional Adminis-trators or with Headquarters) will be increased by regionalization.
We believe that a structured appeal process will be needed with provisions for protection against possible retaliation by Regional authorities who might be sensitive to appeals over their heads.
2885
Honorable Nunzio May 16, 1983
- 4.
Lack of uniformity among the Regions:
As decisions are made in the Regions, it will be unavoidable that differences in interpretation and implementation of regulations will occur.
This lack of uniform-ity could have significant safety implications.
- 5.
Maintenance of lines of communication:
The benefits of shared operating experience will be lost unless effective communication channels are provided among the Regional Offices, and between the Regions and NRC Headquarters.
There are already communication problems among the separate offices at NRC Headquarters, and these will certainly not be relieved by regionalization.
- 6.
Decisions on which issues have significance beyond a specific Region:
Although it is proposed that issues with generic implications will be handled at NRC Headquarters, the decisions on which issues fall into this category will be made in the Regional Offices. We are concerned that the relatively small technical staffs at the Regional Offices will not have sufficient experience or expertise to make appropriate decisions on these issues.
In addition, we might note that the ad hoc National Academy of Sciences' review of the Federal Aviation Administration (FAA) in the aftermath of the Chicago DC-10 accident (aviation's TMI) strongly criticized the regionali-zation of FAA, for many of the reasons we have mentioned here.
While there are differences in the two cases, the many similarities make the Academy group's conclusions difficult to ignore.
Sincerely, Jesse C. Ebersole Acting Chairman 2886