Pilot programs for risk-informed, performance-based regulation

In a paper presented at PSA 96 in Park City, Utah in September 1996, entitled "Call to Action; Pilot Programs for Performance Based Regulation," I recommended the start of at least two pilot programs to change the decision process for determining "adequate protection of public health and safety" from the existing detailed prescriptive process to a more "performance based" process. This performance based process was to use the qualitative goals and the quantitative health effects objectives contained in the Nuclear Regulatory Commission Policy Statement on Safety Coals for the Operations of Nuclear Power Plants published in August 1986 as the definition of "adequate protection of public health and safety." The pilot programs were to use a Level III Probabilistic Risk Assessment to determine where each pilot nuclear unit stood with respect to the quantitative hearth effects objectives and determine how the existing regulations could be changed to achieve a more effective and efficient regulatory process for operating nuclear units. A preliminary program to define this more effective and efficient regulatory process has been defined. Three potential nuclear units have been identified for possible pilot programs.; These nuclear units are Arkansas Nuclear One - Unit 2, San Onofire - Unit 2, and South Texas Project - Unit 1. A draft program plan has been submitted to the Nuclear Regulatory Commission and a series of meetings have been held to discuss the draft program plan. The basic premise underlying the proposed pilot programs will be that regulations and the implementation of regulations should be consistent with the public health risk factors at which the regulations are directed. At areas where there appears to be a mismatch between the risk importance of a regulation and the resources devoted to the implementation of that regulation, potential changes to the regulation will be proposed and hopefully implemented in the pilot programs.