NRC on Realism

["Ted Rockwell" <tedrock@starpower.net>]

Friends:



NRC Chairman Nils Diaz is "walking the walk" when it comes to applying

realism.  He recently defined what he meant, in a talk before the Japanese

Atomic Industrial Forum, April 21 in Tokyo:



"The regulation of nuclear power plants in the U.S.is in a transitional

phase.We need, and we are constructing, a regulatory program that better

meets our present needs.I have said many times: .Regulation must result in a

benefit or it will result in a loss...It is frequently too easy to do a

little more .regulation,. to appear a bit more .protective,. and to add

another ounce of .conservatism..  More regulation can appear enticing.The

NRC is not in the business of zero risk.Zero is not an option, it is a

disruption.We are learning how to define adequate protection in more precise

terms.that make sense to the American people.We have the opportunity to

change the future, and I submit to you that we have the obligation to do so.



"I am convinced nuclear regulation now needs to be anchored in realistic

conservatism.if we are to avoid the twin pitfalls of under-regulation and

over-regulation.I use .conservatism. in the sense of preserving adequate

safety margins, and I use .realistic. in the sense of being anchored in the

real world of physics, technology and experience.When engineering margins

are applied to input parameters, they can distort our understanding of what

is truly important.  Safety margins are better discerned when they are

applied at the decision-making stage, rather than at the analysis stage."



He then went on to apply this to a real and significant physical issue:



"Two major steps.are close at hand, and they are important, practically and

philosophically.  I am talking about 10CFR50.69 and 50.46.  The technical

information and analytical methods are available and the will to change is

strong.We have a sufficient understanding of the probabilities and

consequences to be able to progress to the next rational level of

regulation.Effectively, the current Large-Break LOCA would not be a design

basis accident.The commitment to go forward with 50.46 is fully formed and

the NRC Staff will develop proposed rule changes.The re-definition of the

Design Base LOCA is just one step, but a very important step, in the effort

to revise the regulatory requirements to be more risk-informed and more

broadly coherent."



Going a step further, he recently issued the following news release:



"--NRC HAS ADDED A "FOR THE RECORD" SECTION TO ITS WEB SITE. A May 13 notice

on NRC's home page said the section "provides NRC responses to inaccurate,

misleading or false information in print, on television and radio, and in

large write-in campaigns in order to provide the public with accurate and

truthful information." Items initially posted include NRC responses to

letters received regarding nuclear plant security and a proposed independent

spent fuel storage installation at Indian Point. The commissioners said in

an April 28 staff requirements memorandum that "when research reports are

misused and quoted out of context, the staff should respond promptly." The

NRC web site is at http://www.nrc.gov.";



This is something I have never convinced our own people, in nuclear

utilities and labs to do.  If the Chief Nuclear Watchdog can do this, can't

we Nuclear Advocates follow suit?  There is no reason to shy away from being

realistic.



Ted Rockwell