ML20049H728
| ML20049H728 | |
| Person / Time | |
|---|---|
| Issue date: | 02/25/1982 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20049H724 | List: |
| References | |
| NUDOCS 8203030488 | |
| Download: ML20049H728 (4) | |
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ENCLOSURE 2 UNITED STATES
[4
)
g NUCLEAR REGULATORY COMMISSION E
WASHINGTON, D. C. 20555 z
February 25, 1982 MEMORANDUM FOR:
Victor Stello, Deputy Executive Director Regional Operations and Generic Requirements FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
REVISED RULE REQUIRING APPLICANTS TO IDENTIFY AND EVALUATE DIFFERENCES FROM THE REVISED STANDARD REVIEW PLAN (SECY 81-648)
In response to your memorandum of February 17, we have reconsidered the subject rule which would require OL applicants to identify and evaluate differences from the revised Standard Review Plan (SRP) acceptance criteria by discussing how their proposed different methods satisfy the requirements of the regulations.
The principal factors we considered in j
our reevaluation were the following.
l o
Safety Benefits l
l The NRR staff now conducts its safety reviews of OL applications in I
accordance with the SRP; that is, we audit the application against l
the acceptance criteria of the SRP, identify differences between the SRP criteria and those proposed in the application and, through meetings and correspondence, require the applicant to document how the different measures proposed satisfy the requirements of the regulations. Thus, we use the SRP criteria as " templates" to help identify those areas where particular attention should be concentrated in our safety reviews.
For this reason one of the primary safety benefits of the rule is that it would enable us to focus our review principally on departures from acceptable design concepts and practices, rather than using staff resources to independently review the SAR in order to identify such differences.
Another important safety benefit that would accrue from the rule is that it would require applicants to perform or have performed what is, in effect, a quality assurance check of the proposed plant design and procedures before the SAR is submitted for NRC review.
We would expect the applicant's systematic review against the SRP criteria to be more thorough and complete than the staff's current audit review, and that this quality assurance check would result in an early indication to applicant management of areas where its attention should be focused and/or areas where the applicant may wish to modify or improve plant design or procedures.
One cannot quantify either of these principal safety benefits of the rule with any degree of precision. The difficulty in quantifying these safety benefits is due principally to our inability to measure in any quantitative way how good a job we currently do in our licensing reviews.
If we now do a perfect job of identifying all differences from the SRP and requiring an adequate justification for 8203030488 820301 PDR REVGP NRCCRGR PDR
. all differences, the safety benefit from the rule would be limited to a better and more organized documentation of how the plant differs from the SRP acceptance criteria.
However, improved and better organized documentation of differences from the SRP criteria and the accompanying bases for accepting such differences of and by itself would significantly benefit post-licensing safety reviews of l
these plants.
In particular, such documentation would greatly I
facilitate transferring the responsibility for operating plant I
licensing actions to the Regional Adninistrators.
On the other hand, if we now do a poor job in identifying and requiring justification for SRP differences in our audit review, the benefits of the rule would be a significant improvement in our licensing reviews and in plant safety.
In our view, the truth lies somewhere between these two extremes.
Note that the rule would not elevate the status of the SRP to that of a regulation, nor would it require that proposed alternatives be justified by showing that they provide equal or better protection to the public health and safety than the SRP criteria. The rule would only require an identification of differences from the SRP criteria and an evaluation of how the alternatives proposed provide an acceptable method of complying with the Commission's regulations that underlie the corresponding SRP acceptance criteria.
o Industry Costs The estimated costs for industry to comply with the rule are uncertain due principally to the difficulty in quantifying the effectiveness of our current safety reviews. We remain of the view that a 10 to 40 staff-year estimate per application for the cost of industry compliance is high, and that the actual cost would be at the lower end of this range.
Such industry costs should not include either the cost of changes in plant design or procedures resulting from the applicant's systematic comparison of the plant with the SRP criteria, or the cost of changes resulting from the staff's evaluation of these differences. Also, the initial costs should
)
decrease as industry (particularly NSS vendors and AE's) gained experience in the application of the rule to their product lines.
Attached is the most recent staff estimate of industry costs for compliance with the revised rule which was prepared by staff members having significant industry experience in this field.
- Cost Benefit Ratio The cost-benefit ratio related to the revised rule is essentially unchanged whether either the high or low industry cost estimates are considered to be valid.
If the current staff audit reviews identify and require justification by applicants of most of the differences from the SRP, the incremental cost to. industry of complying with the rule would be small and the corresponding safety benefits would be modest.
If, on the other hand, industry costs of compliance are truly high, the effectiveness of the current staff audit reviews should be significantly improved by adopting this rule, and the safety benefits of the rule would be very high.
o Conclusions and Recommendation 1.
On balance, we conclude that the safety beriefits and administrative effectiveness that would accrue from the rule warrant its adoption in an orderly manner.
Therefore, I recommend that the rule be made applicable to OL applications not yet under review by the staff.
To this end, the revised rule should be modified such that it would apply only to 0L applications docketed after the effective date of the rule.
I would also support any other change to the terms of the rule that would have a substantially similar effect.
2.
It is questionable whether all 2nd and 3rd duplicate units at the same site having plant completion dates between January 1, 1983 and January 1, 1984 should be covered by the rule, since their inclusion could result in unwarranted licensing delays for contested first units.
(See Joe Scinto's memorandum of February 11,1982). Accordingly, I recommend that such units be dropped from the scope of the rule.
3.
As currently written, the rule covers only OL applications.
It has always been our intent to apply the same requirements to Standard Plan applications, where the safety pay-off would be maximized.
I recommend that the rule be modified accordingly.
. If you need any further information, please let me know.
hY w
Harold R. Denton, Director Office of Nuclear Reactor Regulation cc:
W. J. Dircks
Enclosure:
As stated O
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