Re: GAO Report: NRC Staff Have Not Fully Accepted Planned Changes

[jack bell <bellstar@erols.com>]

Hello,

I retired from the NRC 3 years ago with 44 years of experience with the
AEC/NRC and 4 years with the USAF in special weapons work.

You sound like my kind of person and I would really appreciate some help
with the terms "performance based" and "risk based" inspection and
regulation.

I was at TMI when the NRC headquarters staff had an epiphany and threw
the concept of "performance based" inspection at us poor mortals in the
field.  In spite of asking what "performance based" inspection meant at
every counterpart meeting and at every opportunity when confronted by
"management", I never received an answer that made a bit of sense to
me.  As far as I was concerned, I could not imagine any other kind of
inspection.  If we weren't inspecting to determine a licensee's level of
performance,  what were we doing?

Then, another epiphany at headquarters:  "Risk based" inspection!
Again, I inquired of every one that I thought should know what this term
is supposed to mean all to no avail.  Again, I always thought that my
job as an inspector was to establish to what extent a licensee was
minimizing risk to its workers and the public consistent with the
regulations, T.S.s, etc.

This whole business of reinventing what doesn't need reinventing is a
mystery to me.  It always seemed to me that the inspectors (and
headquarters grunts) did as good a job for the workers and the public as
could be expected, given the limited resources available, in spite of
management's attempts to generate new buzz words that gave some people
the impression that we were improving the protection of workers and the
public when, in fact, absolutely nothing was changing.

I would really appreciate it if you would provide an explanation of the
terms "performance based" and "risk based" and how these "new
approaches" (oops, sorry, "new initiatives") benefit the worker and the
public or point me in the direction of someone or something that can.
And pls, don't refer me to inspection procedures, Commission papers,
NUREGS, etc., I'm sure that I have read them all.

Thanking you in advance,

Jack Bell, bellstar@erols.com

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