ML20057D595
| ML20057D595 | |
| Person / Time | |
|---|---|
| Issue date: | 09/17/1993 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20057D596 | List: |
| References | |
| NUDOCS 9310050024 | |
| Download: ML20057D595 (2) | |
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NUCLEAR REGULATORY COMMISSION g ef W ASHINGTON. D.C. 2055M001
...o Septater 17, 1993 MEMORANDUM FOR:
NRR Technical Staff FROM:
Thomas E. Murley, Director Office of Nuclear Reactor Regulation 1
SUBJECT:
COST BENEFICIAL LICENSING ACTIONS As licensees begin to come to grips with the significant rise in plant operational and maintenance (0&M) costs, they frequently express concern that some regulatory requirements provide little or no safety benefit but incur significant implementation costs.
Furthermore, licensees believe that in some instances they have "overcommitted" to meet regulatory requirements and that revisions to these commitments could result in cost savings. The purpose of this memorandum is to explain the NRR position on the review of such licensee requests, called cost beneficial licensing actions (CBLAs), that in the past have had a low priority for review.
Licensees have described both direct and indirect safety benefits if allowed to be relieved from requirements or comitments that they view to be marginal to safety. A direct benefit is one in which the costs averted could be directly applied to safety enhancements in other areas.
For example, a licensee described how $11 million not spent on low safety enhancements to the control room would be spent on improving its independent plant examination (IPE) and on flooding prevention measures. An indirect benefit is one in which the costs averted would result in a reduction of OEM costs and a more j
efficient organization.
In the past, licensees' re:,uests for relief from regulatory requirements or for changes in their commitments have, absent any significant safety issues, received a low priority (level 4) and were scheduled on an "as 'available" basis.
This resulted in many requests not being expeditiously worked, with a resultant loss or delay in realizing any direct or indirect safety benefits.
As an initial step to recognize the connection between costs averted and plant safety, I raised the priority of such licensing actions to level 3 in my memorandum of June 6,1993, on priority determination for NRR review efforts.
I established the CBLA task force to study how the NRR staf'f are currently handling high-cost / low-safety-significant issues and what changes, if any, should be made to the NRR review process to provide a more timely and efficient review of all licensing issues, including the CBLAs.
In addition, the task force will ensure that the CBLAs are given the appropriate staff i
attention.
The CBLA task force is considering several options to improve this process and will report its recommendations in the fall of 1993. This report will be made j
available to the project direcicrates (PDs) and technical branches for their review and comment. Until the report is issued and any process-oriented improvements or clarifications are implemented, the current procedures for assigning work are not being changed.
i Project managers (PMs) should work with licensees to ensure that CBLAs are clearly identified and prioritized within the overall licensee agenda and that only significant CBLAs that actually need NRC review are submittad.
Each CBLA m
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Hultiple Addresses Septtrtxr 17, 1993 should be considered on a case-by-case basis on its technical merits. Cost information should be used only as a basis for prioritization, not as a basis for either approving or disapproving the licensee's proposal. Also, the staff should identify issues that are generic and that should be worked in a generic manner to further improve our efficiency. These issues should be brought to the attention of either the PD organization or to the CBLA task force.
The CBLA task force does not, in any way, replace the PH in working with the-licensee to manage proposed work or replace or augment the technical staff or PM as a technical review path. The current procedures for assigning work to the technica! branches or PMs and the criteria that the licensees' requests are evaluated against are not being changed by this memorandum.
Where licensees determine that significant resources may be saved by changing i
the manner in which their facilities are licensed to operate, the NRR staff i
shnuld be receptive to reviewing the proposed changes. This NRR position may, result in improved safety for the operating plants by (1) reducing the application of significant licensee resources to low safety significant issues (i.e., allowing licensees to effect direct and indirect benefits) and (2) more efficiently using NRR staff resources on the important licensing issues, including those with significant economic impact to the licensees.
There are other efforts also underway that may affect what is finally decided about CBLAs.
These include, for example, the Regulatory Review Group report recommendations and the current licensing basis task force. Since many CBLAs are licensees' requests to change their commitments, questions have arisen about the need for staff to review these changes; the results of these efforts will be carefully weighed and factored into the CBLA work, where appropriate.
If you have any recommendations concerning CBLAs, please contact Tad Marsh at 504-1340, MS 13D18.
g Thomas E. Murley, i
Office of Nuclear Reactor Regulation cc:
J. Taylor J. Sniezek Regional Administrators
.