ML20058G705
| ML20058G705 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/03/1993 |
| From: | William Cahill, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-BR-0058, RTR-NUREG-BR-58 TXX-93415, NUDOCS 9312100096 | |
| Download: ML20058G705 (2) | |
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-l Log # TXX-93415
- " 15::
File # 10004 L
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TUELECTRIC December 3, 1993
% miam J. Cahill. Jr.
Group l% c l%thlent U. S. Nuclear Regulatory Commission Attention:
Document Control Desk i
Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 COMMENTS ON PROPOSED REVISION TO NUREG/BR-0058
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REF: Letter to S. J. Chilk. NRC. from W. H. Rasin, NUMARC, dated November 30 1993 Gentlemen:
This letter transmits TV Electric's comments on proposed Revision 2 to NUREG/BR-0058
- Regulatory Analysis Guidelines of the U. S. Nuclear Regulatory Commission." TV Electric appreciates the opportunity to provide comments on these proposed regulatory changes.
TU Electric cor. curs with the comments provided by NUMARC in the referenced letter regarding the proposed revision to the Nuclear Regulatory Commission (NRC) Regulatory Analysis Guidelines, including the following specific comments:
1.
The NRC's primary role is to ensure adequate protection of public health and safety.
It is important to recognize the difference between the concept of " adequate protection" from " safety enhancements".
Codification of voluntary actions that enhance safety redefines the i
level of adequate protection, causing instability in the regulatory process.
2.
Codification of licensee voluntary actions will indeed result in the NRC's assuming plant management's function.
This will result in a reduction of the licensee's ability to respond to changing needs and pr.orities.
TU Electric considers retention of this ability to be vital in the ever more competitive electric power industry.
3.
Once NRC concludes that additional rulemaking is appropriate, full regulatory credit should be given f or voluntary licensee actions that achieve a particular safety enhancement.
4.
Averted On-Site Costs (AOSC) should not be considered in regulatory cost-benefit analyses.
Financial risk management is the responsibility i
of utility management, not the NRC.
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TXX-93415 Page 2 of 2
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As a final comment, while adequate protection for the public's health and safety should of course be maintained, it is important for regulatory agencies to not "over-regulate" plants to the point that private industry cannot afford to operate them, as they are currently this nation's second largest source of electricity.
It is in this light that TV Electric I
recommends that as an ongoing indicator of regulatory performance, the NRC should develop and maintain (not unlike other NRC Performance Indicators) an indicator representing the overall reduction in core damage frequency (CDF) for the industry as a function of the additional regulatory burden placed on licensees.
The development and use of this indicator will aid in the regulatory analyses of f uture codification evaluations.
i Sincerely,
,)
William J. Cahill, Jr.
By:
M R. D. Walker Regulatory Affairs Manager c-Mr. J. L. Milhoan, Region IV Resident Inspectors, CPSES (2)
Mr. B. E. Holian, NRR i
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