Does the record of operations at fuel cycle facilities show a need for regulatory change?
NRC staff initial position: NRC staff analysis of serious incidents at fuel cycle facilities (Reference 1) indicated that a significant fraction of those events resulted from systemic deficiencies in licensee safety programs. In addition, analysis of events reported under Bulletin 91-01 indicated that such deficiencies are not isolated, but widespread. The staff believed that the frequency and nature of events and incidents at fuel cycle facilities demonstrate deficiencies in licensees’ existing safety programs that can be addressed by changes to Part 70. Such changes would help meet NRC’s goal of improving safety. Industry position: In general, industry representatives expressed the view that the events/incidents noted by NRC are not sufficiently serious to justify a revision of Part 70. Industry representatives noted that the events reported are the result of operator errors and not the absence of or deficiency in safety programs. Industry representatives indicated that the occurrenc
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