ML20045D098
| ML20045D098 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/1992 |
| From: | Kress T Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| RTR-NUREG-BR-0058, RTR-NUREG-BR-58 ACRS-2856, NUDOCS 9306250323 | |
| Download: ML20045D098 (24) | |
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SUMMARY
/ MINUTES OF THE ACRS SUBCOMMITTEE MEETING ON SAFETY PHILOSOPHY, TECHNOLOGY AND CRITERIA OCTOBER 28, 1992 BETHESDA, MARYLAND PURPOSE The ACRS Subcommittee on Safety Philosophy, Technology and Criteria held a meeting on October 28, 1992. The purpose of this meeting was to discuss: (1)
Revision 2 to NUREG/BR-0058, Megulatory Analysis Guidelines", and (2) the proposed guidelines for prioritization of Generic Safety Issues (GSIs). Copies of the meeting agenda and selected slides from the presentations are attached.
The meeting began at 8:30 am and adjourned at 12:00 (noon) and was held entirely in open session. No written comments'or requests for time to make oral statements were received from members of the public. The principal attendeas were as follows:
ATTENDEES ACRS NRC STAFF T. Kress, Chairman J. Heltemes, RES H. Lewis, Member B. Richter, RES C. Michelson, Member S. Feld, RES D. Ward, Member G. Sege, RES C. Wylie, Member T. King, RES D. Houston, Cognizant Staff B. Morris, RES Engineer W. Minners, RES G. Marcus, NRR H. Pastis, NRR NUCLEAR INDUSTRY C. Snyder, NUS M. Kirk, NUMARC P. Harris, Bechtel DOCUMENTS The principal documents for discussion at this meeting were as follows:
(1) Draft Revision 2, NUREG/BR-0058, " Regulatory Analysis Guidelines,"and (2) Draft Portion of Revision 4, NUREG-0933, " A Prioritization of Generic Safety Issues."
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SPT&C Mtg Hinutes October 28, 1992 DISCUSSION Chairman's Openina Remarks In his opening remarks, Dr. Kress indicated that the regulatory guidelines document is a policy making document and as such, is one of the more important issues that the ACRS has had to consider for some time. He noted that the staff, in this document, addresses implementation of the safety goals, discount rates, averted onsite costs, and the cost value per person-rem. All of these play an important part in the way that the agency carries out its function.
REGULATORY ANALYSIS GUIDELINES Staff Presentation Mr. Heltemes (RES) discussed the updated version of the regulatory analysis guidelines. He indicated that the revisions were based on some 9 years of experience using the existing guidance (Revision 1), changes to NRC policies and practices, input from outside reviews, and OMB guidance. He stated that the revisions were necessary to ensure that the decision making process by the staff is systematic and disciplined and that the proposed regulatory burdens are needed and justified. In his discussion of the elements of the regulatory analysis, he noted the assessment of risk against the safety goals as a screening criteria and indicated that the guidance given in this paper was the same as that given in SECY-91-270, a paper that had been previously reviewed by the Subcomittee. He sumarized the major differences between this draft and the current guidance and discussed in some depth the staff position, advantages and disadvantages of four principal issues: (1) voluntary actions, (2) discount rate, (3) averted onsite costs, and (4) discounting of health effects. Another issue left in the outstanding category was that of a monetary value per person-rem.
Subcommittee Comments and Ouestions During this portion of the meeting, various coments and concerns were expressed by Subcomittee Members as follows (random order):
in regard to the principle of transparency for the process, Dr. Lewis o
questioned how this is satisfied if the staff depends on corpmt: m ory as part of their oversight criteria. Mr. Heltemes's response indicated that this would happen through all the many internal reviews including those by ACRS and the Comission.
Dr. Kress and.Mr. Ward asked that if a class of plants met the safety goals, o
why go any further with the consideration of safety enhancements. Mr. Heltemes indicated that the staff would probably stop at this point. However, one might have to go back and make sure that the issues now under consideration were properly assessed in the original risk study. If not, then the staff could initiate a new regulatory analysis.
SPT&C Mtg Minutes October 28, 1992 In regard to voluntary actions, Mr. Ward asked if anyone had performed a PRA o
using just those systems dictated by the regulations. Mr. Heltemes indicated that there might have been some but that he was unaware of the results.
In regard to the 10% discount rate recommended by OMB, Dr. Lewis asked the o
staff for their basis of using a rate of 5%. The staff indicated that the lower rate was consistent with long-term historical economic conditions (4 to 7%) and that they were aware that other government agencies were also using the lower value. Dr. Lewis indicated that the staff should confer with OMB and find out the basis for their value before using an alternative value.
The Subcommittee Members expressed a number of concerns related to the manner o
by which the staff developed numbers for core damage frequencies and conditional containment failure probabilities. These concerns included among others, the summation of accident sequences to provide a final bottom line numbers, the frequency weighting of probabilities, the uncertainties and conservatisms in these calculations, and the mathematical processes used in developing best estimates. The staff indicated that the PRA Working Group would focus on many of these concerns.
PRIORITIZATION OF GENERIC SAFETY ISSUES Staff Presentation Mr. Minners (RES) discussed the proposed guidelines for prioritization of Generic Safety Issues (GSIs). The new guidelines were being proposed to allow the staff to better use its resources on matters of importance. He reviewed the past history and experience in regard to the categorization of previous GSIs. Of the 810 issues identified by the staff since the inception of the program in 1981, 35 were characterized as HIGH-Priority and 27 as MEDIUM-Priority. Of these 62 issues, only 16 resulted in some regulatory action, just 3 of the 27 MEDIUMS.
Therefore, the staff proposes to change the prioritization formula by: (1) raising the risk thresholds by an order of magnitude (10X) and (2) by simplifying the way that costs are considered.
Mr. Minners presented figures with plots of value/ impact versus change in risk i
for the current and proposed priority ranking charts. On these plots, he i
displayed the rankings for six of the resolved GSIs and showed how their ranking 1
would change under the new criteria (two HIGHS became MEDIUMS and one MEDIUM dropped to LOW). As such, the new scheme appeared to allow the staff to focus on those issues of importance that might require regulatory action.
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SPT&C Mtg Minutes October 28, 1992 i
Subcommittee Comments and Ouestions During this portion of the meeting, various comments and concerns were expressed by Subcommittee Members as follows (random order):
a Mr. Michelson asked how the prioritization scheme for GSIs would affect-o the consideration of:these issues for advanced plant designs. Mr.'Minners indicated that the Part 52 plants would have to address the MEDIUM _and HIGH priority issues and would have to review the LOW priority ones to see if they were applicable in any way. Mr. Michelson noted that the cost' analysis for implementing an issue on a new design would be considerably less than.trying to backfit it on an existing design. Mr. Minners. indicated that any such action taken on new plant designs would be by the NRR staff and that-he and the'RES staff would not be involved in their decision, In response to a question by Dr. Lewis in regard to the consideration of-o a
uncertainties, Mr. Minners indicated that they do not consider uncertainties in_any way during this process-He further stated that~the_ purpose oflthisj process is just to focus the staff resources and that as such, the process can't do much harm.
o During_the discussions in regard to_the values of changes to risk-(core melt frequencies, conditional containment failure probability, offsite doses) versus H
dollars per person / rem, it was apparent that the values chosen by the staff were strictly arbitrary and that the boundary changes for prioritization fell into this same category.
FUTURE ACRS ACTION The Subcommittee agreed on the content of'the staff' presentations on these two issues for the Full Committee during the November, 5-7, 1992 meeting. Dr. Kress asked the Subcommittee Members to provide him with any comments that they might r
want to put into a Committee report on these issues.
ACTIONS. AGREEMENTS AND COMMITMENTS No formal actions, agreements and commitments resulted from this meeting other than.the agreement for the Full Committee presentations.
REVIEW DOCUMENTS The following documents were the official review documents for this meeting:
(1) Letter dated September 11, 1992, from C. J. Heltemes, Jr., Office of -
Nucletr Regulatory Research, to Raymond F. Fraley, Advisory Committee-on' Reactor ~ Safeguard, transmitting:
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SPT&C Mtg Minutes October 28, 1992 (a) Draft SECY paper (undated) for the Commissioners from James M.
Taylor, Executive Director for Operations, NRC,
Subject:
Regulatory Analysis Guidelines of the U. S. Nuclear Regulatory
-1 Commission (Predecisional)
(b) Draft NUREG/BR-0058, Revision 2 (undated),." Regulatory Analysis Guidelines of the U - S. Nuclear. Regulatory Commission" (Predecisional)
(c) Separate Enclosures (undated) on Averted Onsite Costs and Discounting of Health and Safety (Predecisional)
(2) Memorandum dated August 5, 1992 (corrections dated August 19, 1992), from.
C. J. Heltemes, Jr., Office of Nuclear Regulatory Research, for Raymond F. Fraley, Advisory Committee on Reactor Safeguards,
Subject:
Request for ACRS Review of Revised Guidelines for Prioritization of Generic Safety Issues, transmitting:
(a) Draft SECY paper for the Commission from James M. Taylor, Executive Director for Operations,
Subject:
Revised Guidelines for Prioritization of Generic' Safety Issues (Predecisional)
(b)-Draft Markup.of Introduction Section, NUREG-0933, Revision 4, " A Prioritization of Generic Safety Issues," August 5,1992 (Predecisional)'
NOTE: ' Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document' Room, 2120 L Street, NW, Washington, DC 20006,L(202) 634-3273 or can be purchased from Ann Riley and Associates, LTD., 1612 K Street, NW, Suite 300, Washington, DC 20006, (202) 292-3950.
p ADVISORY COMMITTEE ON REACTOR-SAFEGUARDS SAFETY PHILOSOPHY,, TECHNOLOGY AND CRITERIA SUBCOMMITTEE MEETING OCTOBER 28, 1992 BETHESDA, MARYLAND ROOM-P-110
- TENTATIVE AGENDA-Wednesday October 28. 1992 TIME A. Subcommittee Chairman's Opening 8:30 am Remarks - T.
Kress
-f i
-B.
Introduction and Discussion of 8:45 am Draft Regulatory Analysis Guidelines-J. Heltemes (RES)
- BREAK *****
- 10:00~am C. Continuation of Discussion on RAGS 10:15 am D. Discussion of Revised Guidelines for.
10:45 am Prioritization of Generic Safety Issues-W. Minners (RES)
)
E. Concluding Remarks and Planning For 11:55 am Full Committee Meeting on 11/5-6/92 i
- ADJOURN ****
12:00 (Noon)
I
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t RES STAFF PRESENTATION TO THE ACRS 4
SUBJECT:
REGULATORY ANALYSIS GUIDELINES DATE:
OCTOBER 28, 1992 i
PRESENTER:
C.J. HELTEMES, JR.
i PRESENTER'S TITLE:
DEPUTY DIRECTOR,-FOR GENERIC l
ISSUES AND RULEMAKING OFFICE OF NUCLEAR REGULATORY RESEARCH PRESENTER'S NRC TEL. NO.:
492-3720 i
SUBC0144ITTEE:
SAFETY, PHILOSOPHY, TECHNOLOGY-AND CRITERIA i
i REASONS FOR REVISION 2 0F GUIDELINES i
t o -
INCORPORATs NRC EXPERIENCE AND~ KNOWLEDGE-USING EXISTING GUIDANCE o
REFLECT CHANGES'IN'NRC-POLICY AND PRACTICES SAFETY GOAL POLICY STATEMENT BACKFIT RULE (50.109)
CRGR PROCESS ~AND-CHARTER REVISION i
o CONSIDER ANALYSIS AND INPUT FROM-OUTSIDE NRC MITRE i
INDUSTRY : COMENTS O
CONSIDER. UPDATED-M GUIDANCE 4
L 1
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. PRINCIPLES 1
REVISION IS-TO ENSURE THAT:
NRC'S DECISION MAKING iS: SYSTEMATIC AND DISCIPLINED
' PROCESS IS OPEN AND-SUFFICIENTLY' TRANSPARENT.
e NEW REGULATORY BURDENS ARE NEEDED.AND. JUSTIFIED l
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a 4
REGULATORY ANALYSIS
- o PURPOSE:-
TO DEVELOP AND-DOCUMENT INFORMATION>ON THE NEED FOR AND
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CONSEQUENCES OF A~ PROPOSED REGULATORY ACTION AND ITS ALTERNATIVES.
o ELEMENTS OF REGULATORY ANALYSIS:
STATE THE PROBLEM AND DEFINE OBJECTIVES JUSTIFY THE'NEED FOR REGULATORY' ACTION DEFINE ALTERNATIVES ASSESS RISK AGAINST' SAFETY GOALS
-SELECT' ATTRIBUTES.(VALUES, IMPACTS);TO BE INCLUDED IN VALUE'
.IMPACTEANALYSIS EVALUATE : CONSEQUENCES: (VALUE IMPACT - ANALYSIS)
'DEVELOPiDECISION RATIONALE DESCRIBE-IMPLEMENTATION i
I t-f OBJECTIVES OF THE REGULATORY ANALYSIS GUIDELINES 1
i
- o TO ESTABLISH NRC POLICY-IN THE. PERFORMANCE OF-REGULATORY ANALYSES.
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TO DEFINE THE SCOPE AND. STRUCTURE OF REGULATORY ANALYSES.
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TO DEFINE' REGULATORY.' ACTIONS-' REQUIRING' REGULATORY ANA!.YSIS.
- o TO~ DEFINE.CERTAIN PROCEDURAL. REQUIREMENTS THAT RELATE TO THE
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REGULATORY ANALYSIS-PROCESS.
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MAJOR DIFFERENCES IN REVISION 2 o
INCLUDES INTERIM ~ GUIDANCE.FOR ADDRESSING SAFETY GOAL CONSIDERATIONS o
PLACES' EMPHASIS ON NEED TO QUANTIFY BENEFITS o
SPECIFIES ANALYSES AND'INFORMATION TO SATISFY BACKFIT AND CRGR REQUIREMENTS-t o
REQUIRES CONSIDERATION OF UNCERTAINTY / SENSITIVITY OF RESULTS o
ESTABLISHES FORMAL' POLICY-POSITIONS q
9 1
7.:
1 SUM 4ARY 0F PRINCIPAL ISSUES e
VOLUNTARY ACTIONS e'
DISCOUNT RATE e
AVERTED ONSITE COSTS e
DISCOUNTING OF HEALTH EFFECTS 4
10
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PRINCIPAL ISSUES
~
, ISSUE - TREATMENT OF VOLUNTARY ACTIONS IN NRC REGULATORY ANALYSES POSITION TAKEN -
HO CREDIT SHOULD BE GIVEN-FOR VOLUNTARY ACTIONS TAKEN OY. LICENSEES UNLESS ENFORCEABLE BY THE NRC
- ADVANTAGES.
o RECOGNIZES THAT VOLUNTARY ACTIONS'ARE' DISCRETIONARY IN NATURE, AND l
CAN BE CHANGED BY LICENSEE ACTION ALONE, PERHAPS WITHOUT NRC'S KNOWLEDGE o-RECOGNIZES ~IMPORTANCE OF HAVING DEFINED AND KNOWN LEVELS OF SAFETY FOR ALL LICENSEES DISADVANTAGES
- o THE BASE CASE MAY NOTLBE' REALISTIC OR REPRESENTATIVE AS TO EXISTING INDUSTRY' PRACTICES o-DOES NOT'GIVE-REGULATORY CREDIT TO-VOLUNTARY _ ACTIONS BY_ LICENSEES-AND-~THIS MAY BE A,DISINCENTIVE.FOR SUCH ACTIONS
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ISSUE -
BASE CASE DISCOUNT RATE POSITION TAKEN - USE A 5% REAL DISCOUNT RATE AND PERFORM A SENSITIVITY ANALYSIS USING A 10% RATE
- ADVANTAGES o
CONSISTENT WITH STAFF PRACTICE FOR REGULATORY ANALYSES o
CONSISTENT WITH NRC'S PRACTICE FOR NEPA ANALYSES O
MORE REPRESENTATIVE OF LONG-TERM HISTORICAL ECONOMIC CONDITIONS DISADVANTAGES-O CONTRARY TO OMB GUIDANCE
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l ISSUE - AVERTED ON-SITE COSTS (AOSC)
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POSITION TAKEN - AOSC IS TO BE INCLUDED IN THE VALUE IMPACT ANALYSIS AS c
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A COST OFFSET.AND THE RESULTS BE DISPLAYED ON A NET BENEFIT BASIS
^
(PREFERRED) (Ht M5 A VALUE-IMPACT RATIO (OPTION)
ADVANTAGES CL CONSISTENT WITH NRC'S RESPONSIBILITIES TO COMPREHENSIVELY EXAMINE THE VALUES AND IMPACTS OF REGULATORY ACTIONS FROM A SOCIETAL PERSPECTIVE-o RECOGNIZES THAT AOSC CAN BElA DOMINANT CONSEQUENCE o
RECOGNIZES'THATLTHE: LOSS OF THE PLANT IS NOT ONLY A FINANCIAL COST FOR THE UTILITY BUT ALSO AFFECTS COSTS TO THE PUBLIC:
0
-CONSISTENT WITH STAFF'S TREATMENT OF OTHER COST SAVINGS
. DISADVANTAGES o
INDUSTRY BELIEVES AOSC DOES NOT DIRECTLY RELATE TO PUBLIC. HEALTH AND-SAFETY AND THUS IS'OUTSIDE NRC'S REGULATORY MISSION 13
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ISSUE'- DISCOUNTING OF HEALTH EFFECTS POSITION.TAKEN - HsALTH EFFECTS ARE NOT DISCOUNTED l
l ADVANTAGES' O.
CONSISTENT WITH LONG STANDING NRC PRACTICE o
RECOGNIZES THAT LIFE AND DEATH ISSUES INVOLVE MORAL AND ETHICAL IMPLICATIONS AND.ARE NOT DRIVEN SOLELY BY FINANCIAL AND ECONOMIC CONSIDERATIONS o
EFFECT OF DISCOUNTING IS WELL WITHIN.THE LEVEL OF UNCERTAINTY AND IMPRECISION INHERENT IN ESTIMATES OF HEALTH EFFECTS o-A DISCOUNT RATE APPROPRIATE FOR HEALTH EFFECTS IS NOT CLEAR o
ADDS AN ELEMENT OF: SAFETY CONSERVATISM TO THE ANALYSIS DISADVANTAGES O
CONTRARY TO. BASIC ECONOMIC' PRINCIPLES
.o CAN DISTORT THE COST BENEFIT RESULT o-CONFLICTS WITH OMB GENERAL GUIDANCE
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l' RES STAFF PRESENTATION _
TO THE ACRS
SUBJECT:
GENERIC ISSUE PRIORITIZATION DATE:
OCTOBER 28,1992 PRESENTER:
W. MINNERS TITLE:
DIRECTOR, DSIR/RES TELEPHONE:
(301? 492-3900 SUBCOMMITTEE:
- SAFETY, PHILOSOPHY TECHNOLOGY AND CRITERIA
I'
~
BACKGROUND
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1 SECY-92-135: STATUS OVERVIEW 4/15/92 OF GSI PROGRAM
- COMMISSION BRIEFED 4/29/92 i
SRM:
STAFF TO EXAMINE COMPLETED 5/13/92 GSis TO. DETERMINE OPPORTUNITIES FOR'SAVING EFFORT WITHOUT SIGNIFICANT DIFFERENCE IN
' OUTCOME j
REVISED GUIDELINES FOR'PRIORITIZATION 8/5/92 OF GSisTO ACRS FOR REVIEW t
- TO COMMISSION AFTER ACRS REVIEW l
- LEAD OFFICE FOR. REVISION:. RES
- GUIDELINES ARE IN INTRODUCTION TO NUREG-0933 (DONE IN 1983) 1 1
1 7
NINE YEARS OF EXPERIENCE
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PROPORTIO.N OF RESOLVED lSSUES RESULTING IN REGULATORY ACTION:
MEDIUM:
3 OF 27 HIGH:
13 OF 35 USI:
27 OF 27 SOME BENEFIT IN MANY lNSTANCES EVEN WHEN NO REGULATORY ACTION RESULTED VOLUNTARY LICENSEE ACTION RESPONSE TO:lNTERIM GUIDANCE MEDIUM-PRIORITY ISSUES USUALLY~RESULTED IN NO MORE THAN MARGINAL IMPROVEMENTS RISK, RATHER THAN COST / BENEFIT, WAS PRIMARY
-1 DETERMINANT OF PRIORITY 3
PRIORITY RANKING CHART (CURRENT)
'VALUE IMPACT SCORE -(Person-Rem /$M) 100000 3
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$/ PERSON-REM PRIORITY H = HIGH M = MEDIUM 3,000 D
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L = LOW D = DROP 3,000 3,000 D
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10-7 10-6 10-5 10-4 A CORE-MELT FREQUENCY, PER RY
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A CORE-MELT FRECRENCY, ' PER YEAR (TOTAL, ALL AFFECTED REACTORS) 10'
- 10*
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. APERSON-REM / REACTOR -(OFFSITE) 3x10' 3x10' 3x10' 3x10' A PERSON-REM (TOTAL OFFSITE. ALL REACTORS).
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RATIONALE OF CHANGES o
KEY RISK THRESHOLDS RAISED 10X
.LARGi! ENOUGH TO SUBSTANTIALLY REDUCE INCIDENCE OF NO-ACTION CONCLUSIONS: MODELS RESOLUTION PROCESS WITHOUT EXCESSIVE MARGIN
. SCREENING FOR POTENTIAL " ADEQUATE PROTECTION" ISSUES (USIs) CAN STILL BE LIMITED TO (NOW DIMINISHED)
HLGli PRIORITY GROUP STRENGTHENED ATTENTION TO UNCERTAINTIES AND SPECIAL CONSIDERATIONS IN EACH CASE RELIED ON IN LIEU OF GENERAL EXTRA MARGIN 4
o VALUE/lMPACT-ROLE SIMPLIFIED, DIMINISHED tiLGli PRIORITY BASED ON RISK REDUCTION ALONE AT 0.1 TO 1X tilGli THRESHOLD,' ALWAYS MEDIUM, REGARDLESS OF VALUE/lMPACT
$3,000 PER PERSON-REM IS 3X TRADEOFF COEFFICIENT USED lN REGULATORY ANALYSES: MODEST MARGIN FOR INITIAL UNCERTAINTIES 1
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