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' i.tNIRAL I-1LE AEB.R/F
- LGHulman
,e ., -_ . @ 0 2 1984 - AD/RP RF MEHORANDUM FOR: Robert M. Bernero Director Division of Syst.us Integration THRU:
T -Daniel R. Mulbr, Assistant Director for Radiation Protection $
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Division of Systems Integration -
FROM: ' L. G. Hulman, Chief Accident Evaluation Branch Division of Systems Integration
SUBJECT:
, ,'TERH USE IN REGULATIONPROPOSED PLAN FOR C Proposed herein is a plan for development of a Comission Policy Paper to accompany NUREG-0956. The purpose of the paper is to explain how the Comission intends to use the infomation developed through the Accident Source
'and Term Program Office (ASTPO) in rel.ated areas of regulatory poli practice.
The plan consists of assembling a cadre of senior staff members from within NRR, RES and I&E to identify the impacts of the ASTP0 sponsored research, including the American Physical Society review, and to draft a
,. c Comission Paper which identifies associated changes in policy and practice.
- L The group would be advised by RES representatives and RES e contractors to assure the group is fully familiar with the research, APS review, and the ASTP0 findings. The group would accomplish the following tasks in parallel with completion of NUREG-0956;.
- s. become sufficiently familiar with the ASTP0 sponsored methodology APS review, and related risk considerations, to , judge policy and practice implications;
- b. i'dentify areas of existing policy and practice influenced -
by source term research (note that NUREG-0771 (FOR COMMENT) i provides such a profile through 1981, but requires u' pdating
[ in such areas as severe accident rulemaking and emergency planning);
- c. identify future policy and prcetice areas potentially influenced by the evolving source tem research; e.g.,
proposed safety gosis, siting and severe accident policy. _.
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'j Robert H. Bernero
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related regulatory policy issues including;
- 1.Do'e'sthepresentpractice(eq.,QA, maintenance, operatortraining,techspecs.,etc.)
associated with design bases for the existing '
generation of reactors provide an adequate level of safety for their lifetimes?
- 2. Are there risk reduction o.ntions that should be considered now or in the near future for the I current generation of reactors?
- 3. Are operators provided with guidelines and j
emergency procedures for recognizing and i coping t
with realistic accident sequences?
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- 4. What role should risk analysis play in developing and administrating regulations, as opposed to the present deterministic mode?
- e. identify areas of regu1'ation that are influenced by the research that are potential candidates for deratcheting or ratche AccidentPolicy),
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- f. provide a plan for evaluating applicant / licensee requests'for
.c. deviations from present practice; and
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g g. provide a plan for implementing changes to present practice through policy statements and regulation, regulatory guide'and standard review plan revisions.
Because of the breadth of source term influences, I suggest that the group include not only senior reviewers, but first and second level supervisors from the following NRR, RES and I&E organizational elements:
AEB EQB PSRB . RRAB SSPB ASTP0 CSB SAB EPB SPEB RAB
, RSS
! RRB Individuals assigned to the effort would be given specific tasks for completion, tnd would participate iri deliberations over the content and direction of reco:raendations. I envision the group starting at a level of effort of about 1/4 time, gradually increasing individual partici--
pation -
for sen,to note than 1/2 time in December. The paper should be available ' i ior senagement review by mid-January. t
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- An advis6ry group..of A/D's and'Dep. Div. Dir, would be useful to assure -
that the group fullf. considers related issues, and meets schedules. .
Also, I suggest-that the group be organized into subgroups with specific t assignments, each with a Branch Chief or Section Leader as team leader.
t I propose.the following schedule: ,
Date .
Activity 10/10 10/18 Briefing on source term research activities .
Briefing on BMI-2104 10/22 Draft charters of sub-groups to advisors for coment 10/25 10/26 Briefing on containment working groups i Coments on sub-group charters due 10/29 i- Briefing on risk perspective 10/31 10/31 Resolution of coments on sub-group charters Briefing on ur. certainties 11/1 Briefing on NUREG-0956 bottom line 11/5-8 Draft sub-group input 11/15 Draft.Comission Paper 11/15 - 1/15 Circulate for review, and update 1/15 - 1/30 Concurrence Original signed}y:
L. G. Huhan l
2 L. G. Hulman. Chief 4 Accident Evaluation Branch Division of Systems Integration
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