ML20132C898

Comments on NUREG/CR-4152 Re Need for Independent Safety Organization.New Organization Would Improve Public Perception of Nrc,But Would Not Necessarily Improve Performance

ML20132C898
Person / Time
Issue date:	03/22/1985
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Heltemes C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
Shared Package
ML20132C621	List: ML20132C617 ML20132C624 ML20132C802 ML20132C808 ML20132C840 ML20132C846 ML20132C849 ML20132C854 ML20132C870 ML20132C874 ML20132C878 ML20132C883 ML20132C886 ML20132C893 ML20132C898 ML20132C903 ML20134D717 ML20134D837 ML20134D920 ML20134D941 ML20134D948
References
FOIA-85-427, RTR-NUREG-CR-4152 NUDOCS 8504080409
Download: ML20132C898 (2)

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ARLINGTON. TEXA8 70011 MAR 2 2 985 1

EMORANDUM FOR: C. J. Heltemes, Jr. , Director Office for Analysis and Evaluation of Operational Data FROM: Robert D. Martin, Regional Administrator

SUBJECT:

STUDY OF THE NEED FOR AN INDEPENDENT AGENCY TO INVESTIGATE INCIDENTS AT NUCLEAR POWER PLANTS This is in response to your February 15, 1985, memorandum requesting comments.

on the BNL report (NUREG/CR-4152) on this subject.

We are not persuaded by the BNL study that fundamental changes in the present NRC organization, organizational responsibilities, and organizational relationships are appropriate. While we are in agreement that many of the

• shortcomings can and should b'e remedied, and that organizational inefficiencies should be eliminated, these improvements should be handled by directed changes in practices rather than reorganizations. It is recognized that the improve _ments recommended and accepted are more than simply fine-tuning the present practices, but it is unwarranted to spring from a finding that the current practices are generally conducted in a prof.icient and technically competent manner into a recommendation that wholesale chan,ges be implemented.

Some of the anticipated improvements appear to be unrealistic tr without foundation. Anticipation that there will be an ability to " freeze" plant conditions appears unrealistic for most rational scenarios; anticipation of more accurate and timely identification of significant events also seems unjustified. We also are compelled to comment that the suggestion of a conflict of interest between NRC elements in seeking the truth is a " red ,

herring"; if there are adversarial relationships between the NRC and utility personnel in seeking the truth, it is unlikely that another NRC element will do better.

We are convinced that some improvements in practices are warranted, and it may well be that the cxecution of such improvements should be primarily by AE00.

. This should be by directive, not reorganization.  ;

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. C. J. Heltemes, AE00 In the decision in how to improve the NRC performance in this area, we suggest that a parallel between the NRC emergency response arrangements and this matter be considered. On both of these topics, a spectrum of events is to be considered, ranging from significant (but not urgent) events, up to very serious events requiring a mobilized response on the part of the NRC. We fully expect most events considered by the organization to be significant, but not of a magnitude which prompts ',RC mobilization. This would indicate that improved organizational practices would be the cornerstone of improved NRC performance, as opposed to reorganization. It would also indicate that proper NRC response to urgent events of extremely significant magnitude would require resources beyond those availabic to the BNL proposed organization. It is worth noting that the proposed reorganization would not relieve NRR, IE, or the regional offices of their responsibilities regarding significant events.

We recognize that there is a matter of perception regarding the establishment of a Commission-level organization called the Office of Nuclear Safety with the functions and responsibilities outlined in the BNL report, and that this may be seen in a positive manner by the public and by others. We are nevertheless persuaded that the driving force should be better achievement of results than the perception of results. ,

Ei Robert D. Martin .

Regional Administrator cc:

H. R. Denton, NRR J. H. Taylor, IE J. G. Davis, NMSS R. B. Minogue, RES G. H. Cunningham, ELD -

T. E. Murley, RI J. N. Grace, RII J. G. Keppler, RIII J. B. Martin, RV F. Hebdon, AE00 4

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