ML20055D550
| ML20055D550 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1990 |
| From: | Remick NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9007090091 | |
| Download: ML20055D550 (5) | |
Text
N0TATI0N V 0.T.E....................
RELEASED TO THE POR RESPONSE SHEET :
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T0:
SAMUEL J. CHILK, SECRETARY OF THE COMISSION FROM:
C0MISSIONER REMICK
SUBJECT:
SECY-89-102 - IMPLEMENTATION OF SAFETY GOAL POLICY APPROVED X/in part DISAPPROVED X/in part ABSTAIN i
NOT PARTICIPATING REQUEST DISCUSSION COMENTS:
PLEASE SEE ATTACHED COMMENTS n
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RRESP NDEN E PDC
/ SIGNATURE April 26, 1990 V0TE SHEET CAN BE RELEASED DATE q
ENTERED ON "AS" YES 4 _
NO
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COMMISSIONER REMICK'S COMMENTS ON SECY-89-102 I HAVE REVIEWED SECY-89-102 AND THE AVAILABLE V0TE SHEETS ON THIS SUBJECT.
AFTER CAREFUL CONSIDERATION, I SUPPORT MOVING FORWARD WITH IMPLEMENTATION OF THE COMMISSION'S SAFETY GOALS POLICY STATEMENT.
I APPROVE IN PART AND DISAPPROVE IN PART THE STAFF'S PROPOSED IMPLEMENTATION OF THAT STATEMENT AS DESCRIBED IN SECY-90-102.
My CONCEPT OF THE SAFETY GOALS AND THEIR IMPLEMENTATION IS AS FOLLOWS:
PRINCIPAL ELEMENTS OF THE SAFETY GOALS 0
THE COMMISSION'S SAFETY GOALS POLICY STATEMENT SHOULD CONSIST OF THE FIRST THREE LEVELS OF THE ACRS PROPOSED HIERARCHY DESCRIBED ON PAGE 9 0F SECY-89-102.
THAT IS:
00 QUALITATIVE SAFETY GOALS.
00 QUANTITATIVE HEALTH OBJECTIVES.
00 LARGC RELEASE GUIDELINE (AS A GENERAL PLANT PERFORMANCE OBJECTIVE).
O THE LARGE RELEASE GUIDELINE SHOULD BE INCORPORATED INTO THE SAFETY G0AL POLICY STATEMENT (CURRENTLY IT HAS BEEN PROPOSED BY THE COMMISSION FOR FURTHER STAFF EXAMINATION) AS FOLLOWS:
00 "THE OVERALL MEAN FREQUENCY OF A LARGE RELEASE OF RADIOACTIVE MATERIALS TO THE ENVIRONMENT FROM A REACTOR EVENT SHOULD BE LESS THAN 1 IN 1 MILLION (10-6)
YEAR OF REACTOR OPERATION."
O A LARGE RELEASE (AS ESSENTIALLY PROPOSED AS ONE OPTION BY THE STAFF) SHOULD BE DEFINED IN THE SAFETY GOALS POLICY STATEMENT AS:
00 "A LARGE RELEASE IS ANY RELEASE FROM A REACTOR EVENT INVOLVING SEVERE CORE DAMAGE, PRIMARY SYSTEM PRESSURE BOUNDARY FAILURE AND CONTAINMENT (OR CONFINEMENT)
FAILURE."
0 THE LARGE RELEASE GUIDELINE IS IN ESSENCE A MORE PRACTICAL, SITE-INDEPENDENT SURROGATE FOR THE QUANTITATIVE HEALTH OBJECTIVES ANd COULD BE DETERMINED DIRECTLY FROM A FULL-LEVEL 'I, PRA.
/
- SCOPE, l
0 IT IS ESSENTIA., THAT THE POLICY STATEMENT INCLUDE A CLEAR STATEMENT THAT THE COMMISSION WILL CONTINUE TO INSIST ON t
l 2-MULTI-BARRIER, DkFENSE-IN-DEPTH DESIGNS WHICH PROVIDE A BALANCED ENGINEERED APPROACH TO ACCIDENT PREVENTION AND MITIGATION AS APPROPRIATE TO THE SPECIFIC DESIGN CLASS.
IlIPLEMENTATION OF THE SAFETY anats 1
1 0
THE SAFETY G0ALS POLICY STATEMENT IS TO BE USED AS THE
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COMMISSION'S DEFINITION OF A LEVEL 0F RADIOLOGICAL RISK FROM 4
THE OPERATION OF NUCLEAR POWER PLANTS BEYOND WHICH IT WILL GENERALLY NOT BE NECESSARY TO EXPEND RESOURCES TO REDUCE FURTHER RADIOLOGICAL RISKS.
i 00 IT IS THE COMMISSION'S STATEMENT OF "HOW SAFE IS SAFE ENOUGH" FOR THE ENSEMBLE, OR POPULATION OF NUCLEAR j
POWER PLANTS IN THE UNITED STATES.
l 00 THE SAFETY GOALS ARE TO BE USFD TO JUDGE THE EFFECTIVENESS OF NRC REGULATIONS IN PRODUCING PLANTS WHICH, AS AN ENSEMBLE, MEET THE QUALITATIVE GOALS AND QUANTITATIVE HEALTH OBJECTIVES.
00 THE SAFETY GOALS ARE NOT TO BE USED SOLELY IN A DETERMINISTIC SENSE IN INDIVIDUAL LICENSING ACTIONS.
00 IN DEVELOPING AND REVIEWIRG REGULATIONS AND REGULATORY PDACTICES-THE STAFF SHOULD ROUTINELY CONSIDER THE l
JIDANCE PROVIDED BY THE SAFETY GOAL POLICY STATEMENT.
J 0
FOR THE PURPOSE OF IMPLEMENTATION, THE STAFF MAY ESTABLISH SUBSIDIARY QUANTITATIVE CORE DAMAGE FREQUENCY AND CONTAINMENT PERFORMANCE OBJECTIVES THROUGH PARTITIONING OF s
i THE LARGE RELEASE GUIDELINE.
THESE SUBSIDIARY OBJECTIVES WOULD ANCHOR, OR PROVIDE GUIDANCE ON'" MINIMUM" ACCEPTANCE CRITERIA FOR-PREVENTION (E.G. CORE DAMAGE FREQUENCY) AND MITIGATION (E.G. CONTAINMENT OR-CONFINEMENT PERFORMANCE) AND
)
WOULD ASSURE AN APPROPRIATE DEFENSE-IN-DEPTH BALANCE IN DESIGN.
O SUCH SUBSIDIARY OBJECTIVES SHOULD BE CONSISTENT WITH THE LARGE RELEASE GUIDELINE, AND NOT INTRODUCE ADDITIONAL i
CONSERVATISM SUCH AS TO CREATE A DE FACTO NEW LARGE RELEASE
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l GUIDELINE.
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I STRONGLY SUPPORT AS SUCH SUBSIDIARY OBJECTIVES THOSE l
RECOMMENDED BY THE ACRS WHICM IN ESSENCE WERE:
00 CORE DAMAGE FREQUENCY OBJECTIVE OF LESS THAN 10-4 PER REACTOR YEAR (TO ASSURE h MINIMUM ACCEPTABLE STANDARD l
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3-I h
FOR PREVENTION).
A CONTAINMENT PERFORMANgE OBJECTIVE OF LESS THAN ONE oO CHANCE IN TEN (1.E. 10~ ) FOR A LARGE RELEASE (FROM
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CONTAINMENT OR CONFINEMENT) FOR AN APPROPRIATE FAMILY 0F CORE DAMAGE SCENARIOS, CONSISTENT WITH THE ABOVE OVERALL MEAN FREQUENCY OBJECTIVE OF A LARGE RELEASE.
O WITHIN A PARTICULAR DESIGN CLASS (E.G. LWRS, LMRS, HTGRS)
THE SAME SUBSIDIARY OBJECTIVES SHOULD APPLY TO BOTH CURRENT AS WELL AS FUTURE DESIGNS.
A SPECIFIC SUBSIDIARY OBJECTIVE MIGHT DIFFER FROM ONE-DESIGN CLASS TO ANOTHER DESIGN CLASS i
TO ACCOUNT FOR DIFFERENT MITIGATING CONCEPTS (E.G.
CONFINEMENT INSTEAD OF CONTAINMENT). THE LARGE RELEASE GUIDELINE WOULD APPLY TO CURRENT AS WELL AS FUTURE DESIGNS.
t 0
THE SUBSIDIARY OBJECTIVES NEED NOT BE INCORPORATED INTO THE SAFETY GOALS POLICY STATEMENT, BUT SHOULD BE BROUGHT TO THE COMMISSION FOR REVIEW AND APPROVAL.
O I STRONGLY SUPPORT CHAIRMAN CARR'S STATEMENT THAT:
"THE COMMISSION HAS MADE IT CLEAR THAT IT EXPECTS ADVANCED DESIGNS TO REFLECT: BENEFITS OF UIGNIFICANT i
RESEARCH AND DEVELOPMENT WORK; HUMAN FACTORS CONSIDERATIONS; EXPERIENCE GAINED IN OPERATING THE MANY POWER AND DEVELOPMENT REACTORS; AND THAT '/ENDORS ACh! EVE A HIGHER STANDARD OF SEVERE ACCIDENT SAFETY PEAFORMANCE THAN THEIR PRIOR DESIGNS.
THE INDUSTRY'S GCAL OF DESIGNING FUTURE REACTORS TO A CORE DAMAGE Pl.0BASILITY OF LESS THAN 1 IN 100,000 PER YEAR OF Rl' ACTOR OPERATION (EPRI FOR ".'.WRS AND GE FOR THE ABWR) 11 EVIDENCE OF INDUSTRY'S COMMITMENT TO NRC'S SEVERE AC7IDENT POLICY.
THE NRC SHOULD NOT IMPOSE INDUSTRY'S DESIGN OBJECTIVES AS NEW REQUIREMENTS."
OTHER COMMENIS E
O I SUPPORT THE USE OF AVERTED ON-SITE COSTS AS AN OFFSET AGAINST OTHER LICENSF.E COSTS (AND NOT AS A BENEFIT) IN COST-BENEFIT ANALYSES.
HOWEVER, I AM AT A LOSS WHY THE STAFF RAISES THIS ISSUE AS PART OF SAFETY GOAL IMPLEMENTATION, AS THERE IS NO LONGER A COST-BENEFIT ELEMENT TO THE COMMISSION'S SAFETY GOALS POLICY STATEMENT.
IT IS AN APPROPRIATE ISSUE IN BACKFIT ANALYSES.
O I SUPPORT CHAIRMAN CARR'S STATEMENT THAT:
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4 "IN ORDER TO ENHANCE OUR REGULATORY PROCESS FOR THE CURRENT GENERATIONS OF PLANTS, THE STAFF SHOULD STRIVE FOR A RISK LEVEL CONSISTENT WITH THE SAFETY GOALS IN DEVELOPING OR REVISING REGULATIONS.
IN DEVELOPING AND APPLYING SUCH NEW REQUIREMENTS TO EXISTING PLANTS, THE BACKFIT RULE SHOULD APPLY.
DEVELOPING AND APPLYING REQUIREMENTS TO FUTURE DESIGNS THAT ARE CONSISTENT WITH THE SAFETY GOALS WITHOUT APPLYING THE BACKFIT RULE WILL PROVIDE AN INCREASED LEVEL OF ASSURANCE THAT FUTURE DESIGNS MEET THE INTENDED LEVEL OF SAFETY PROVIDED IN THE SAFETY GOAL POLICY STATEMENT."
O I SUPPORT CHAIRMAN CARR'S STATEMENT THAT:
l "BOTH THE STAFF AND ACRS AGREE THAT THE SAFETY GOAL OBJECTIVES AND OTHER POSSIBLE OBJECTIVES SHOULD BE USED TO EFFECT CHANGES IN THE REGULATIONS; HOWEVER, THE TASK 0F UNDERTAKING A REVIEW 0F THE WHOLE BODY OF REGULATIONS AND REGULATORY PRACTICES APPEAR TO BE A J
MASSIVE, RESOURCE INTENSIVE EFFORT.
THE STAFF SHOULD-
. DESCRIBE IN MORE SPECIFIC DETAIL A PLAN FOk ASSESSING THE CONSISTENCY OF OUR REGULATIONS WITH THE CAFETY GOALS IN A REASONABLE FASHION THAT WOULD INCLUDE A PROACTIVE APPROACH TO IDENTIFY AND POSSIBLY ELIMINATING UNNECESSARY REQUIREMENTS, AS WELL AS MODIFYING REQUIREMENTS THAT MAY NOT BE SUFFICIENT.
A TRIAL CASE OF LIMITED SCOPE MAY BE USEFUL WAY TO PROCEED WITH THIS REQUEST."
O THE SAFETY GOALS POLICY STATEMENT NEED NOT BE MODIFIED l
EXCEPT TO INCORPORATE THE DEFINITION OF A LARGE RELEASE GUIDELINE AND THE DEFINITION OF A LARGE RELEASE, AS WELL AS TO CLEARLY STATE THAT THE COMMISSION WILL CONTINUE TO IN!!s" ON MULTI-BARRIER, DEFENSE-IN-DEPTH DESIGNS WHICH PROVADE A BALANCED ENGINEERED APPROACH TO ACCIDENT PREVENTION AND
_ MITIGATION AS APPROPRIATE TO THE SPECIFIC DESIGN CLASS.
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