Re: NRC on Realism

["Mike Fox" <foxy1@owt.com>]

Ted:

I've been saying this (speaking out against the nonsense) for 25 years.  I

have a very small voice!!!

Mike

----- Original Message -----

From: "Ted Rockwell" <tedrock@starpower.net>

To: "NRC-FaroukEltawila" <FXE@nrc.gov>; "RADSAFE"

<owner-radsafe@list.vanderbilt.edu>; "Rad-Sci-L" <rad-sci-l@WPI.EDU>;

"Zebroski, Ed" <edzeb@sbcglobal.net>; "Bert Wolfe" <bertramwolfe@attbi.com>;

"Todreas, Neil" <todreas@mit.edu>; "Taylor, John" <JJTAYLOR@epri.com>;

"Stone, Henry" <HStone5190@aol.com>; "Starr,Chauncey" <CSTARR@epri.com>;

"Simpson, John W" <jws@hargray.com>; "Schriesheim, Alan"

<Schriesheim@anl.gov>; "Ted Rockwell" <tedrock@starpower.net>; "Pate, Zack"

<ztpate@attbi.com>; "Mandil, Harry" <BMandil@aol.com>; "Levenson, Milton"

<mlevenso@nas.edu>; "Davis, Kenneth" <wkdavis@aol.com>; "Cohen, Karl"

<karlpc@earthlink.net>; "Chapin, Doug" <dchapin@mpra.com>; "McNeill, Corbin"

<camcneill@wyom.net>; "Don Hintz" <DHintz@entergy.com>; "David Christian"

<david_christian@dom.com>; "Charles Pryor" <mjinlynchburg@aol.com>

Cc: "Connie ANS-Cherry" <ccherry@ans.org>; "NN-BetsyTompkins"

<btompkins@ans.org>; "Foulke, Dr. Larry" <Larry.R.Foulke@verizon.net>

Sent: Sunday, May 16, 2004 10:31 AM

Subject: NRC on Realism





> 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

>

>

>

>

>