ML20058G621
| ML20058G621 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, Waterford  |
| Issue date: | 12/06/1993 |
| From: | Dewease J ENTERGY OPERATIONS, INC. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR47159, RTR-NUREG-BR-0058, RTR-NUREG-BR-58 58FR47159-00007, 58FR47159-7, CNRO-93-00036, CNRO-93-36, NUDOCS 9312100006 | |
| Download: ML20058G621 (4) | |
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17 December 6,1993 L-p EEC 0? Ds3 b L
Mr. Samuel J. Chilk Secretary of the Commission Ove wha I
U.S. Nuclear Regulatory Commission
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Attention:
Docketing and Service Branch
Subject:
Solicitation of Comments, Draft " Regulatory Analysis Guide' 'es" NUREG/BR-0058 Revision 2,58 FR 47159 CNRO - 93/00036
Dear Mr. Chilk:
q Entergy Operations, Inc. has reviewed the request for public comment published in the
- Federal Registeron September 7,1993 (58 FR 47159) concerning the proposed revision to the Regulatory Analysis Guidelines, NUREG/BR-0058. We wish to submit
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the following on behalf of Arkansas Nuclear One Units 1 & 2, Grand Gulf Nuclear Station, and Waterford 3 Steam Electric Station.
Entergy Operations, Inc. has provided input to the Nuclear Management and Resources
- Council (NUMARC) and the Nuclear Utility Backfitting and Reform Group (NUBARG) for l-their comments on the proposed revision to the Guidelines. We endorse their comments, which agree with our own.
Because we concu,'with the NUMARC and NUBARG comments, we have provided
- only some additional specific comments in the Attachment rather than repeating those provided by NUMARC and NUBARG. Our main concern, that the draft Guidelines utilize principles such as averted onsite costs which appear to have been explicitly rejected by the Commissioners in the rulemaking process for 10 CFR 50.109, is well described by NUBARG.
9312100006 931206-PDR NUREG BR-MDB C-PDR y
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.i Solicitation of Comments, Draft " Regulatory Analysis Guidelines" NUREG/
BR-0058 Revision 2,58 FR 47159 December 6,1993 CNRO-93/00036 Page 2 of 2 l
We appreciate this opportunity to express our views on the draft revision to the Regulatory Analysis Guidelines and the Commission's consideration of our comments.
Sincerely, Yh' X G. bc-em JGD/hek attachment cc:
Mr. T. W. Alexion Mr. P. W. O'Connor Mr. R. P. Barkhurst Mr. N. S. Reynolds Mr. R. H. Bernhard Mr. R. L. Simard Mr. R. B. Bevan, Jr.
Ms. L. J. Smith Mr. J. L. Blount Mr. D. L. Wigginton Mr. S. D. Ebneter Mr. J. W. Yelverton Mr. E. J. Ford Central File (GGNS)
Mr. C. R. Hutchinson DCC (ANO)
Mr. R. B. McGehee Records Center (WF3)
Mr. J. L. Milhoan Corporate File [ 5 )
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Solicitation of Comments, Draft " Regulatory Analysis Guidelines" NUREGI l
BR-0058 Revision 2,58 FR 47159 December 6,1993 i
Attachment to CNRO-93/00036 Page 1 of 2 Spacific Comments by Entergy Operations. Inc.
i Section 2Ra_ge_2d t
The Guidelines suggest that revisions to a regulatory analysis need only be documented in a memo to the CRGR. Since the regulatory analysis is made available to the public for their review during the comment period for a rulemaking, it is important that the regulatory analysis be complete and include the resolutions to all internal NRC comments. The Guidelines should include that regulatory analyses should be revised and reissued with sequential revision numbers and changes identified, as appropriate.
i Snttion 2.3. Page 2.5 i
NRC Management Directive 8.4 is not included in NUREG-1409 as Appendix B. However, Manual Chapter 0514 (same as Management Directive 8.4)is included as Appendix D in NUREG-1409.
i The following comments concern the use of safety goals in regulatory analyses:
Section 3.3. Page 3J
.j The draft Guidelines state: "However, the safety goals are not requirements and, with the Commission's approval, safety enhancements may be implemented without strict adherence to the Commission's safety goal policy statement."
l It should be stressed that approval to deviate from the safety goals would only be expected in extremely limited cases. Cri,ria for deviation and/or l
examples illustrating acceptable justification for deviation should be j
included in the Guidelines.
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i Solicitation of Comments, Draft " Regulatory Analysis Guidelines" NUREG/
BR-0058 Revision 2,58 FR 47159 December 6,1993 1
Attachment to CNRO-93/00036 j
Page 2 of 2 l
Section 3.3.1. Page 3.9 and Figure 3.2. Page 3.12 It appears contrary to the purpose of the safety goals if options are provided for overriding the numerical cutoffs given by estimated reduction i
in the CDF. The option for management discretion for those proposed actions with CDF reductions < 10-5 should be eliminated (as stated by l
NUMARC).
If management discretion to override results in the range of 10 to 10~5 is i
4 retained, criteria for discretion and/or illustrative examples should be
- i provided in the Guidelines. The Guidelines should be applicable to management decisions affecting the regulatory analysis rather than to just the development of documentation, and should not be subject to arbitrary j
disregard.
Figure 3.Lfassad2 It is not clear from the figure, or explained in the corresponding text, whether an action with a ACDF 210~5 and an estimated conditional containment failure probability (CCFP) $; 10 requires no additional action, 2
a management decision, or proceeding with the regulatory analysis. This situation should require no additional regulatory action, but this should be clarified in the Guidelines.
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