ML17298B869
| ML17298B869 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/29/1985 |
| From: | Knighton G Office of Nuclear Reactor Regulation |
| To: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 8502070092 | |
| Download: ML17298B869 (11) | |
Text
JAN 2 9 ]985 Docket Nos.:
50-528, 50-529 50-530 Mr. E.
E.
Van Brunt, Jr.
Vice President - Nuclear Projects Arizona Public Service Company Post Office Box 21666 Phoenix, Arizona 85036
Dear Mr. Van Brunt:
EJordan ACRS (16)
DISTRIBUTION
'55-
/52,/5 NRC PDR L PDR NSIC PRC System LB¹3 Rdg.
JLee EALicitra
- Attorney, OELD NGrace The Commission's Policy and Planning Guidance for 1984 (NUREG-0885, Issue 3) states:
"Existing regulatory requirements that have a marginal importance to safety should be eliminated" (section IV.A, Planning Guidance No. 3).
To implement this item, the NRC staff has initiated a program entitled "Effectiveness of LWR Regulatory Requirements in Limiting Risk".
This program was announced in the Federal
~Re ister on October 3, 1984.
A copy of that notice is enclosed.
As part of that program, we plan to visit a sample of utilities to obtain their views on any regulatory requirements that are believed to have marginal importance to safety but which have high burdens on the utilities or the NRC.
Two contractor personnel from Pacific Northwest Laboratories, plus Dr. Anthony Tse from NRC's Office of Research, an NRC project manager from the Division of Licensing and possibly one additional NRR representative would participate in a one-day visit in your corporate offices.
More details concerning this proposed visit are also enclosed.
We anticipate that the visits would take place in February or March of 1985.
No response to this letter is necessary.
We will be contacting you by telephone to see if you are interested in participating in this phase of the
- program, which is entirely voluntary.
Sincerely,
Enclosures:
1.
FR Notice 2.
Visit Details original signe8 by qe.orgo W. Y~ighton George W. Knighton, Chief Licensing Branch No.
3 Division of Licensing cc w/enclosures:
See next page DL:LB¹3 g
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1ghton 1//g/85 lj/)/85 8502070092 850129 PDR ADOCK 05000528 P
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Pal o Ver de Mr. E.
E.
Van Brunt, Jr.
Vice President - Nuclear Proiects Arizona Public Service Company P. 0.
Box 21666 Phoeni x, Arizona 85036 Arthur C. Gehr, Esq.
Snell 5 Wilmer 3100 Valley Center Phoenix, Arizona 85073 Mr. James M. Flenner, Chief Counsel Arizona Corporation Commission 1200 West Washington Phoenix, Arizona 85007 Charles R. Kocher, Esq. Assistant Counsel James A. Boeletto, Esq.
Southern California Edison Company P. 0.
Box 800
- Rosemead, Ca 1 iforni a 91770 Ms. Margaret Walker Deputy Director of Energy Programs Economic Planning and Development Office 1700 West Washington Phoenix, Arizona 85007 Mr. Rand L. Greenfield Assistant Attorney General Bataan Memorial Building Santa Fe, New Mexico 87503 Resident Inspector Palo Verde/NPS U.S. Nuclear Regulatory Commission P. 0.
Box 21324 Phoenix, Arizona 85001 Ms. Patricia Lee Hourihan 6413 S. 26th Street
, Phoenix, Arizona 85040 Regional Administrator - Region V
U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Kenneth Berlin, Esq.
Winston 5 Strawn Suite 500 2550 M Street, NW Washington, DC 20037 Ms. Lynne Bernabei Government Accountability Project of the Institute for Policy Studies 1901 gue Street, NW Washington, DC 20009 Ms. 'Jill Morrison 522 E. Colgate Tempi, Arizona 85238
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39066 EnClOSII're 1
Proposed Rules Federal Ret))alar VO). 4Q. No. 1Q3 Wednceday.
October 3, 19S4
'he secbon ot Itic FEDERAL fIEGISTER conQlns nohcea to the pUb4c ot the proposed wuance ot rules and reyuhtenL The purpose ot these notices
.)S 1O QIVe huerested persons an opporlUEllty ar parecpate hi the tufe maisng pnor to Ne adoption Of eie anat fldee NUCLEAR REGULATORY COMM)SSION 10 CFR Part 50
~MMCNO5ca of Avallabf)ttyof Proorafrt Piarl to Review Effactfvanaaa of LWR Raotta)tory Rac)tf)rafneftia in Ufnf5ng Ilatt AORNcv: Nuclear Regulatory Commission AcT1oec Notice ofavailability.
stisnsAftv: The NRC staff intends to initiate a review of the, risk importance of current regulatory sequirements for Light Water Reacttea (LWR).This program ie being initiated to itientify carrrent regulatory requirements which.
ifdeleted m appropriately modifietL seoul d intfawa the aKckency m effectiveness ofNRCs reguhtory program fornudeer power plants w)thout adversely affecting safety.
InitiaDy. this progtem weal systematically assess the risk hnportance of selected current regulations in 10 CFR Part 50 and related regul story requirements. The NRC staff is seeking pubDc OM151ent on the Program Plan preparesl by the,staff to describe the review progran1.
Aoosttaa h copy of the Program Plan Is avaDable forpublic inspection and copying in the NRC Public Document Room. 1FV H Street NW Washington, DC. Copies may also be obtained by writingto Dr. Anthony Tse at the
-. address listed below.
~Oa AlltTMI)tfl&OttNAT)offCONTACT:
- Dr. Anthony N. Tse, Regulatory Analysis and Materials Risk Branch. Division of ask Analysis and Operations, Office of Nudear Regulatory Research, US.
Nudear Regulatory Commission.
Washington. DC 20555; telephone: (301)
)fc)~ 443-7902; SUppLNsINTAftvtNFoltMAT)ofcht the direction of the Executive Director for Operations, the NRC staff has initiated a program to identify cur'rent regulator'y requirements which.'f deleted or appropriately modiBed. would improve the efficency and effectiveness of the NRC regulatory program for nuclear power p)ants without adversely affecting safety. Anumber ofexisting prognims 'ssess the adequacy of present regulations. However. these progranis are not specifically designed to weed out fodsttng regulations or regulatory requirements which do not reduce risk aignificantiy. Initially.this program ia designed to f1) systematicaDy screen all current regulatory requinments associated with 10 CFR Part 56 and to assess the importance of selected requirements based Brat on their contribution to assuring that nudear power plants are safely designed. canstructetL and operated and sectmd on their impact on licensee. applicant. and NRC resources.
and (2) identify and propose appropriate modificat)ons to eliminate duplication.
inconsistency or mmecessary requirements and thus focus avaDable NRC and industry resources more directly and Ifrecutely on the significant safety areas and issneL Prie ctnrtBdates formotmcation will be old regulatory nts which in light ofpresent knosv edge may no longer be considered risk t or whose risk fnqxntance may ve been reduced sufltantia5y by the implementation ofnewer requiiements and g) areas in which there are large ufety margins or conservathms which can be reduced without measurably increasing the level ofrisk In suoh cases modiGcation could produce a signiGcant ufety benefit. since the attention and resources of Bcerisees. applicants, and the NRC that are now directed to these areas could ba redirected to other areas ofgreater safety significance, The initialwork. to be completed in FY 1NS, willindude a survey of
~ regulatory requirements assoc)ated with 10 CFR Part 50 to categorise them according to their relative safety
'significance. In a parallel effort. several requirements that appear to be good candidates formodiBcation or elimination wQl be evaluated in detail to
'aaaeles Indada (s) 6>> Generic issue ugl t)nreeoived Safety )eeoc prsSranN: IS) prspenN and cache thai <<se)d be Seided by the Severe Accident
~slicy Sieiemesi lvhes leaned; ts) the lniegraied Safety Aeeeeenlest pleerain tnt OpefadnS teeclote:
(e) the operatinS eapenesce review by the Of)Ice for Anelyeie and Evalaeiton ofOpefaulxNI Deie: end IS) ihe OLeny efedieL enelyeea teel and enpertinenie eepported by ibe OfFice ofResearch.
assess their safety benefits and the NRC and industry costs of implementation. At the end of 1Q85. the NRC willascertain the wefulness of this program and determine whether any of the identificd candidates shou d be pursued further in a rulemaking.
As part of the program. the NRC wiD solidt suggestions from the regulated industry as to candidate requirements that might be eUtninated or modified to improve tha eSactiveaess and the efficienny ef the regulatory program. The NRC willal&consider any other public comments received. Allsuggestions will be evaluated by the staff. but none will be etna)dered as petitions for rulemaking or aa formal comments that require response. Any petitions for ruiemaking must be submitted as directed in 5 2.882 of 10CFR Part 2 of the Commission regulations hny saggestions would be welcomed and should be sent to Dr. AA.Tse.
Dated et Weahiolten. DC. t)iie lyib day ci Sap taaber lQSL Far tbepfadeer Reffa)story Commission.
W)D)ata J. D)rcks, ZzscQtfre Dl'recforjotOperotl'N7J.
tya nea~ rural tD44c see aa)
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Enclosure 2
REVIEW OF REGULATORY REQUIREMENTS FOR LIGHT WATER REACTORS The NRC's for 1984 (NUREG-0885'ssue
- 3) states that "exfstfng regulatory requfrements that have a mar gfnal fmportance to safety should be elfmfnated."
Other statements fn the same document.
as well as several fnftfatfves undertaken fn recent years'ndfcate the NRC~s caenft-ment to the goal of fmprovfng regulatfon of the nuclear fndustry> fn order to ensure that
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requfrements fmposed on the regulated fndustry contr fbute sfgnfffcantly to the health and safety of the publfc
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unnecessary regulatory burdens are avofded
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NRC and lfcensee resources are utflfzed fn a manner whfch effectfvely and efffcfently achfeves protectfon of the publfc health and safety.
The NRC recently fnftfated a program to fmplement the po11cy and plannfng gufdance quoted above.
Pacfffc Northwest Laboratory (PNL) fs provfdfng tech-nfcal assfstance to the NRC staff fn conductfng thfs program.
PNL's work fn the ffrst phase of the program consfsts of two tasks.
In the ffrst task>
exfstfng 1fght water reactor regulatory requfrements wfll be screened to fden-tffy potentfal candfdates for elfmfnatfon> or> ff approprfate>
modfffcatfon.
The bases for screenfng the requfrements wfll Include thefr fmportance to rfsk> the burdens they fmpose on fndustry> the resources requfred for the NRC to 11cense and fnspect agafnst them>
and other relevant factors.
In the second task>
PNL wfll conduct comprehensfve evaluatfons of selected regulatory requfrements that may warrant elfmfnatfon or modfffcatfon.
Cost-benefft assessments of the consequences of changfng or elfmfnatfng the requfrements wfll form an fmportant part of these evaluat1ons; publfc rfsk> 1ndustry burdens (fncludfng costs and occupatfonal exposure)>
and NRC resource requfrements wfll be among the factors consfdered fn the cost-benefft assessments.
As part of the ffrst task> f.e.> screenfng the ex1stfng requfrements to fden-tffy candfdates for elfmfnatfon or,modfffcatfoni PNL wfll conduct a ser1es of fntervfews to obtafn the vfews.of var1ous partfes> for example>
ut111tfes.
reactor vendors>
archftect-engfneers>
contr actors.
and NRC staff.
The follow-fng paragraphs gfve a brfef sketch of the expected scope of the fntervfews and the top1cs that wfll be dfscussed.
In the ffrst phase of the programs the scope of the revfew and screen1ng fs lfmfted to regulatory requfrernents and gufdance assocfated wfth 10 CFR Part 50.
However> wfthfn thfs boundaryr the scope fs broad and may fnclude any exfstfng r equfrement or gufdancei for examples regulatfonsi regulatory gufdes.
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0 technical specifications.
standard review plan sections>
branch technical positions.
and codes and standards.
The idea of reexamining existing regulatory requirements is not new. of course>
nor is it unique to the nuclear industry.
In facti a wide variety of sugges-tions have been made along these lines ovet the years.
Among the many examples that could be cited> three are discussed briefly for illustrative purposes.
The possibility of streamlining and optimizing tech specs is of considerable current interest and is the subject'f several ongoing studies by the industry and the NRC.
Possible modifications under study include surveillance intervalsi action statements that may require shut-downs unnecessarily>
allowable times for equipment to be inoperable>
and definitions of operability.
There has been much recent interest in the role of extreme loads in design.
The highly conservative nature of sane of the assumptions associated with the use of these loads in the design process has been noted>
along with the resulting cost impact.
This topic has been under study for some time and revisions of the design bases are under consideration.
at reassessing the source terms for reactor accident consequence analyses.
This work is nearing completion and its implications for the existing regu-latory structure are being discussed.
Some observers have suggested>
for example> that changes in current emergency planning requirements should be considered.
During the interviews>
PNL staff will be interested in identifying other regulatory requirements.
guidance>
or areas of regulation that may be suitable candidates for reexamination and possible elimination or modification.
In some instances>
the suggested candidates for reexamination may already be the sub)set of ongoing studies>
as is the case for the examples mentioned above.
In other instances>
the suggested candidates may not currently be under consideration in any formal program. It is hoped that candidates of both kinds will be identified. It is also hoped that the suggestions will cover a broad spectrum of regulatory requirements>
including those related to designs construction.
and operations.
Some observers maintain that most of the good ideas for regulatory improvement have already been suggested and are already being pursued.
Based on our previous work with industry, PNL staff believe that this is unlikely and that many possibilities are not currently being pursued.
The basic goal of the interviews is to obtain a broad spectrum of constructive suggestions for improving regulation of the nuclear industry by eliminating or appropriately modifying certain regulatory requirements.'o assist in identifying suitable candidates for reexaminations it may be useful to consider briefly sane tentative criteria.
These criteria may be helpful in focusing the search for suitable candidates.
Regulatory requirements that have negligible impact on r isk may be potential candidates for reexamination.
In facto sane observers have raised
h v
p c
the poss1b111ty that certa1n requ1rements may actually be counter-product1ve
~from the standpo1nt of r1sk. It should be stressed that the concept of r1sk has mult1ple d1mens1ons.
1nclud1ngi for example> offs1te rad1at1on exposure@
core melt> core damage>
challenges to safety systems>
defense-1n-depth.
and so on ~
Certa1n requ1rements may be part1cularly burdensome from the v1ewpo1nt of occupat1onal exposure to rad1at1on.
If they also con-tr1bute negl1g1bly to the protect1on of the publ1c health and safety> then they may be su1table cand1dates for reexam1nat1on.
1" "I"
"" p" 1mpacts.
If they also make only a negl1g1ble contr1but1on to the protect1on of the publ1c health and safety.
they may be su1table cand1dates for reexam1-nat1on.
5B~MM.
Some requ1rements result 1n espec1ally h1gh demands on NRC resources for 11cens1ng and/or 1nspect1on.
If they also make a negl1g1ble
'contr1but1on to the protect1on of the publ1c health and safety> they may be su1table cand1dates for reexam1nat1on.
The pred1ctab111ty and stab111ty of the regulatory process are 1mportant cons1derat1ons.
Certa1n requ1rements may have part1cu-lar ly negat1ve 1mpacts from th1s standpo1ntr wh1le contr1but1ng only negl1gHRy to the protect1on of the publ1c health and safetyi and thus may be su1table cand1dates for reexam1nat1on.
As a result of operat1onal exper1ence.
techn1cal progress>
research f1nd1ngsi or other developmentsu certa1n requ1rements may now be r1pe for reassessment.
PNL staff bel1eve that th1s 1s a part1cularly useful cr1ter1on for 1dent1fy1ng pran1s1ng cand1dates for reexam1nat1on.
il 1
1 I
1 p
p other requ1renents.
Such tequ1rements may be su1table cand1dates for reexam-1nat1on to el1m1nate dupl1cat1on.
These cr1ter1a are 1ntended only to ass1st 1n 1deht1fy1ng potent1al cand1dates for reexam1nat1on and poss1ble el1m1nat1on ot mod1f1cat1on.
Recoaeendat1ons on whether to el1m1nate or mod1fy certa1n regulatory requ1rements w1ll be formulated by the NRC staff at a later t1me and would be based on canprehens1ve evaluat1ons of the consequences of such regulatory changes.
Develop1ng a
l1st of potent1al cand1dates 1s the f1rst step 1n the process.
After all the 1nterv1ews are completed>
PNL w111 comp1le the suggest1ons and prepare a seanary of them.
Th1s seanary of the suggest1ons along w1th a br1ef quest1onna1re w111 then be sent to the organ1zat1ons part1c1pat1ng 1n the 1nterv1ews.
The purpose of th1s step 1s to
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prov1de feedback to the par t1c1pat1ng organizat1onsi
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conf1rm the f1nd1ngs of the 1nterv1ewsi
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obtain (through the questionnaire) an approximate>
Judgmental evaluation of the costs and benefits of elkmknatfng or mod$ fy$ng the requirements,
~
seek addktfonal suggestions of requirements that may be cand)dates for reexam1nat$ on but were not covered
$ n the
$ nterv$ ews.
PNL plans to maintain contact with the part$ c$ pat$ ng organizations>
keeping them informed as the work proceeds.
a,c