ML19308B940
| ML19308B940 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/07/1977 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Abrams H AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML19308B919 | List: |
| References | |
| RULE-RM-50-12, TASK-TF, TASK-TMR SECY-77-126, NUDOCS 8001170648 | |
| Download: ML19308B940 (5) | |
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Mr. Earc1d P. Abrans, President g.:.. ;-
1:1 antic County Citizens Council E r' on I:71ron=ent 9100 2-' arst Avenue
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Dear Sir:
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Ca T. une 19, 1974, the Atlantic County Citizens Council on Environment du filed a petition for rule naking requesting that the U.S. Atomic Energy sau Co==issi.on amend. its regulation 10 CFR Part 50 to require full scale
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t =n cperatic=al system tes:ing of pilot model or prototype versions of nuclear power ;1.an:s, in the configuration they are expected to be employed in si:u, prier to licensing for production manufacture wherein it is evident that s:ch plan:s are to be assembly line nanufactured, mass produced, or cthew.s e turned out in substantial quanti:y for distribution on a wide i
scale.
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the rea. sons set forth in :he enclosed notice, the Nuclear Regulatory Co-4 ssi.:n has denied the petition for rule =aking.
Sincerely,
- .C' 7 Samuel J. Chilk
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Secreta y of the Commission Fn:los::e:
So: ice of Denial of Petiti:n i.
for Inle Makizq;
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OFFICE OF POLICY EVALUATION COMTS OF JANUARY 18, 1977
-M WITH OFFICE OF STANDARDS DEVELOPMENT RESPONSE
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1.
Avoid the implication that present practice contrasts sharply with the Es=
prototype concept by pointing out that, in fact, successive nuclear E E",="
power plants have usually been preceded by near-prototypes with I-h!5=E demonstration required for new safety-related features.
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Present practice on commercial plants does not utilize the prototype 33 concept as commonly defined.
As discussed on pages 2 and 3 of Enclo-
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s ure "C", the present commercial nuclear power program has matured g..
past the stage where experimental prototypes are needed. As pointed out on page 13 of Enclosure "C", the land-based plants serve the same function for the floating plants as a prototype.
2-2.
Discuss the safety nerits of this current evolutionary approach.
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- The safety nerits of the current NRC approach are discussed on pages 2, N
3,13 and 14 of Enclosure "C".
3.
Admit the exact prototype testing may result in added assurance of 1.
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s safety, but concentrate on the cost-benefit argument, i.e.,
that the t='
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possible increase in safety for an exact protctype is over-balanced by u=gy:: ----
the incremental costs' in time, resources, and flexibility for improveme:t.
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ggg The staff believes that a requirement for prototype testing in addition to the normal NRC procedure will not provide any significant s
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? PE protected. The detailed discussion concerning the cost-benefits of mu
,if? n-the prototype approach are discussed in Alternative 2 of the staff E
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paper and on pages 13 and 14 of Enclosure "C".
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In response to the OPE cocnent, the following sentence was added to page 14 of Enclosure "C" and to page 4 of the staff paper to clarify 3+
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" Adding an extra requirement for prototype testing is not likely i
to provide any significant increase in this assurance."
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4 Emphasize that petitioners are addressing only licenses issued under Appendix.M of 10 CFR Part 50.
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. response to this com=ent an additional paragraph was added to page 2 of the staff paper to mention this point (paragraph 2).
Furthermore, the fcotnote on page 1 of Enclosure "C" was expanded to indicate that the OPS application was filed under Appendix M of ik=
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Finally, a sentence was added at the end of the
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second paragraph of Enclosure "C" to indicate that the notice is
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dealing with plants licensed under Appendix M of 10 CFR Part 50.
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point out that manufacturing licenses will be conditioned, i.e., NRC is involved in regulating the manufacturing process itself.
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---NM This is discussed on pages 8, 9 and 13 of Enclosure "C".
In addition, the following sentence was added to the second paragraph on page 3 of Enclosure "C" to rurther bring out this point:
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i "This includes inspection during the manufacturing process to verify that the conditions of the license are being satisfied."
6.
Avoid a purely defensive posture.
"e agree with this comment and believe that the notice of Enclosure "C",
in particular, pages 13 and 14, has not indicated a defensive posture.
1 7.
The Notice of Denial should delete all substantive comments on OPS.
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Since the petition refers specifically to the OPS type application, the staff believes that in order to be responsive to the intent of the petition the Notice of Denial should speak to these concerns as y::
well.
Specific comments related to the OPS application have been made a-.
to allay public concerns regarding the adequacy of the NRC program in 1_ '.. !"
fh this area.
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Two additional sentences have been added to Enclosure "C" just prior I!.I.:.;:
to the detailed discussion of the floating nuclear plants to provide a clearer motivation for the discussion.
The added sentences are "l."_..
located on page 9 of Enclosure "C" and are as follows:
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"The preceding sections have discussed the general aspects of M5
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In view of the concerns of 7:+
the petitioner regarding the offshore floating nuclear plants, considerations relative to these plants will now be discussed."
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The Notice of Denial should linit discussion to manuf acturing licenses.
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L'e have limited the discussion to nanuf acturing licenses; however, we have added additior si text as indicated in the response to question 4.
In order to describe the NRC program related to manuf acturing licenses, it was necessary to describe the overall NRC progran since the overall NRC procedure will be applied as well to the plants licensed under 3E AppendiI
.V. of 10 CFR Part 50.
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~he Notice of Denial should note that NRC will conduct surveillance of each manuf acturing licensee's operations.
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=m-Ms is discussed on page 9 of Enclosure "C".
In addition, a sentence 7:[.3.
was added, as indicated in the response to question 5, to. trther ih clarify this idea.
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I suggest that, at your earliest convenience, we meet with appropriate staff to discuss the above peints in greater detail.
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Meetings me held between 0?E and S'; personnel on February 3 and 4,
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1977,to discuss the above OPI cow-ents as well as other concerns that l
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OPE held.
The meetings resulted in a mutually acceptable revision to hf
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as well as on additional niner points raised during the meetings.
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