ML20058K688

Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments

ML20058K688
Person / Time
Site:	Calvert Cliffs
Issue date:	12/03/1993
From:	Denton R BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-58FR47159, RTR-NUREG-BR-0058, RTR-NUREG-BR-58 58FR47159-00010, 58FR47159-10, NUDOCS 9312160004
Download: ML20058K688 (2)

Text

, - - . . . -

F

,e Q \

) {

BALTIMORE GAS AND Q % ([l [f

.Q J0 1650 CALVERT CUFFS PARKWAY LUSBY, MARYl.Nb 20657-4702

~)

RostRT E. DENTON vict Parsom December 3,1993 N./CLE AR E04ERGY I4 c) 260 4 4 5 *.,

U. S Nuclear Regulatory Commission Wa.hington, DC 20555 ATTENTION: Regulatory Publications Branch, Division of Freedom of Information and Publications Senice, Office of Administration

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Comments on Reculatorv Anahsis Guidelines. NUREG/BR-0058 i

'Ihe Nuclear Regulatory Commission published the proposed Revision 2 to the Regulatory Analysis

- Guidelines, NUREG/BR-0058 and asked for public comment. Baltimore Gas and Electric Company appreciates the opportunity to express our views on the draft Guidelines because of their substantial effect in shaping future regulation and consequent impact on our business as a nuclear power plant licensee.

We support the comments offered by Nuc1 car Utilities Management and Resources Council ,

(NUMARC) and the additional comments provided by Nuclear Backfitting and Reform Group ,

(NUBARG). As a member of both groups, we have reviewed their inputs and believe that their insights into both the strengths and weaknesses of the proposed Guidelines are accurate. We encourage Nuclear Regulatory Commission to accommodate their comments in going forward. l We would specifically add comment on the treatment of Averted Onsite Cost. We believe that this issue is crucial in developing a rational basis for considering new regulation. Using the proposed i method of subtracting Averted Onsite Cost from the implementation cost to licensees makes this a dominant term in the analysis. This is inappropriate from several perspectives, which the NUMARC and NUBARG address in detail. The greatest disadvantage is that as a practical matter, it makes most analyses heavily dependent upon this relatively subjective and unproven estimate, thereby minimizing the impact on the equation of the ve.y concrete costs of implementation faced by the licensee and its customers. Our own strategic planning does not treat averted costs in this manner.

We strongly urge that the methodology be n vised to more effectively compare the benefits of proposed regulation to their real costs.

Should you have any further questions regarding this matter, we will be pleased to discuss them with you.

Qry truly yours, N N

[ I:L,,

RED /JMO/jmo/bjd 9312160004 931203 I PDR NUREO BR-OO58 C PDR

1. Document Control Desk

/

December 3,1993 Page 2 cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC l l

D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R. I. McIzan, DNR J. II. Walter, PSC l

I l

l l

l l

.,m, y .rn ,-, , - - - - ,