ML20126C627
| ML20126C627 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1992 |
| From: | Harris C NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Felton J NUCLEAR LICENSING REPORTS |
| References | |
| FOIA-92-225 NUDOCS 9212230147 | |
| Download: ML20126C627 (2) | |
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COMME N T 5 9212230147 920623 PDR FOIA FELTON92-229 PDR
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FOIA-92-225 Al'I'ENDIX B DOCUMENT llEING l' LACED IN THE l*DH HU NilEH DATE DEGCilli'T I ON 1,
4/22/92 Letter from Taylor to Mitchell re 90-day moratorium and aunociated cost savings with attachment.
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.r f 3 Tl APR 2 21992 Ms. Nancy Mitchell Associate Director Council on Competitiveness Office of the Vice President Room 286, OE0B The White House Washington, DC 20501
Dear Ms. Mitchell:
This is in response to our telephone conversation or. April 20, 1992 in which you requested advance information about NRC's actions regarding the 90-day moratorium and associated cost savings.
As I explained. because of our independent responsibility in the area of public health and safety, NRC did not suspend rulemaking riuring this 90-day period. However, during the 90-day review period we conducted a special review of our regulations to determine whether regulatory burdens can be reduced without in any way reducing protection for the public health and safety or the common defense and security.
This review, which was performed by our Committee to Review Generic Requirements, drew upon previous studies and solicited comments from the public, other agencies, and the Commission's staff. A public meeting was held to discuss the comments received.
The Committee recommended revising our regulations in eight areas.
Each of those areas is identified in the enclosure with approximations of any savings which might accrue to our licensees.
I must caution that these are preliminary estimates to support your request for an expedited response and have not been thoroughly staffed or commented on by our lic1nsees.
l The Report on the Special Review is currently before our five member Commission for review and approval and response to the President next week.
l OriS$flC3t[Abb amdame'sk.' Taylor, EDO
Enclosure:
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Distribution:
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$80.7M Note: Represents present value savings / cost over life of plant (assumed to be 26 years) for 110 plants. Discount rate of 5%.
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ISSt!E 1:
Frequency of FSAR Updates (10 CFR 50.71)
RECOMMENDED ACTION (S):
Revise the requirements on safety analysis report updates to-provide for FSAR updates once per refueling cycle, rather than annually.
BACKGROUND:
10 CFR 50.71(e) requires that each licensee update the FSAR annually to assure that it includes the latest material developed for the facility; The updated FSAR sust include the effects of:
4 (a) changes-made in the facility or procedures described in the-FSAR; (b) safety evaluations performed by the licensee in support of license amendments, or in support of conclusions that changes did not involve an unreviewed safety question; and (c) analyses of new safety issues performed by or on behalf of the licensee at Commission request.
The updates must include all changes made more than 6 months prior to the date-of filing land may include more recent changes.
the updated FSAR provides a means for the NRC and the licensee'to arrive at a timely common understanding of the current. safety design configuration of the plant. The r1 commended action affects the interval, but not the character. of-the FSAR update.
BASIS FOR COST SAVINGS:
Licensees currently are required to submit about 85 reports covering 110 operating units each year.
If the requirements are changed, it tis assumed.
that these reports will be submitted at an average interval of 18 months,
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eliminating about 28 reports per year., (Many plantsiwill' eventually increase their refueling intervals to 24 months; however,2many: dual unit plants will continue to report annually because-of staggered refueling _ outages.) :It is -
estimated: that each report-which'is= eliminated will reduce. licensee cost;by-about $30,000 and will' reduce NRC staff review time by about 1 week ~(51,900).
Additional assumptions include an average remaining plantLlife of about-26 years.
It is estimated that changing the rule will involve a one-time NRC
- cost of about $100,000.~ A discount rate of 5% per. year is used, in accordance1 with normal NRC practice.
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4 RESULTS:
Licensee Resources NRC Resources One. time savings None
-$100,000 l
Recurring savings 5840,000/ year
$53,000/ year Total (present value)
$12.075,000
$662,000
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ISSUE 2:
Annual Design Change Report (10 CFR 50.59)
-RECOMMENDED ACTION (S):
Revise the requirements on design change reports to provide for reports once por refueling cycle, rather than annually.
BACKGROUND:
10 CFR 50.59(b) requires an annual report briefly describing any changes, tests or experiments, including a summary of the safety evaluation of each.
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BASIS FOR COST SAVINGS:
Licensees currently are required to submit about 85 reports covering 110 operating units each year, if the requirements are changed, it is assumed hat these reports will be submitted at an average interval of 18 months, eliminating about 28 reports per year.
(Many plants will eventually increase their refueling intervals to 24 months; however, many dual unit plants will continue to report annually because of staggered refueling outages.)
It is estimated that each report which is eliminated will reduce licensee cost by about $3,000 and will reduce NRC staff review time about 1/2 week (5950).
Additional assumptions include an average remaining plant life of about 26 It is estimated that changing the rule will involve a one-time NRC-years.
cost of about $100,000. A discount rate of 5% per year is used, in accordance with normal NRC practice.
RESULTS:
Licensee Resources NRC Resources One time savings None
-$100,000 Recurring savings
$84,000/ year
$27,000/ year Total (present value)
$1,208,000
$282,000
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- ISSUE 3::
LElimination of Unnecessary Event Reports RECOMMEND ACTION (S):
Anend 10 CFR 50.72 and 10 CFR 50.73 to eliminate-the unnecessary reporting of certain types of events at operating reactors (e.g., invalid actuations of some engineered safety features) that are unimportant to NRC in fulfilling its
-role to assure the protection of public health and safety.
BACKGROUND:
Currently,10 CFR 50.72 and 50.73 require that NRC licensees for nuclear power reactors report any event or condition that involves actuation of any engineered safety feature (ESF), including the reactor protection system (RPS), except for actuations that resulted from and were part of a preplanned sequence during testing or during reactor operation. The events'are required' to be reported via a telephone within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> _of discovery pursuant to 10 CFR 50.72(b)(2)(li),-and within 30 days in a Licensee Event Report (LER) in accordance with 10 CFR 50.73(a)(2)(iv).
Approximately 40 percent of the LERs (over 800) received annually involve ESF actuations; a similar number of telephonic event notifications are also made.
BASIS FOR COST SAVINGS:
The staff estimated about 150 invalid ESF actuation events per year would no longer be reported.
The industry indicated a cost of about 340 hours0.00394 days <br />0.0944 hours <br />5.621693e-4 weeks <br />1.2937e-4 months <br /> per repert. This results in an annual savings of $2,448,000. The staff savings-is-$1,000 per report, or $150,000 per year.
Additional assumptions include an average remaining plant life of 26 years.
It is estimated that changing the rule will involve a one-time NRC-costs of-about-$100,000.
A discount rate of 5% is used in accordance with normal NRC practice.
RESULTS:
Licensee Resources NRC Resources One time savings None
- -5100,000 Recurring savings 52,448,000/ year
$150,000/ year
-Total (present value)
$35,190,000
$2,080,000 a
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- c ISSUE 4:
Use of fuel with Zirconium-Based (Other Than Zircaloy) Cladding RECOMMENDEDACTION(S):
Revise 10 CFR 50.44, 50.46, and 10 CFR 50 Appendix K so that it is not necessary to obtain exemptions when using ZlRLO and (as a separate action on a longer term basis) for other Zirconium-based (other than Zircaloy) fuel cladding.
BACKGROUND:
Acceptance criteria set forth in 10 CFR 50.46,10 CFR 50, Appendix X relating to evaluation of emergency core cooling. systems performance are specifically identified as applicable to Zircaloy-clad fuel. The same is true with regard to 10 CFR 50.44 dealing with hydrogen generation and combustible gas control.
Because of this, fuel designs that employ other Zircontum-based cladding materials cannot be used in currently operating power reactors without exemption from these regulations, even though such use would be otherwise acceptable in every respect from a safety viewpoint.
The NRC staff has recognized that amendment of these regulations to broaden their applicability to fuels employing other acceptable Zirconium-based cladding materials would reduce burden without reducing in any way the protection of pubite health and safety.
BASIS FOR COST SAVINGS:
About six plants per year over the next 8 years are expected to begin using ZlRLO clad fuel-(or some zirconium-based cladding, not Zircaloy).
A licensee's cost for preparation and submittal of an exemption request is estimated to be about $50,000. An exemption would incur a one-time cost for each operating plant involved.
NRC review costs are estimated at about two weeks ($3,800) per exemption request.
A discount of 5% per year is used, in accordance with normal NRC practico.
RESULTS:
Licensee Resources NRC Resources One time savings None
-5100,000 Other savings
$300,000/ year
$10,400/ year (for8 years)
(for 8 yetrs)
Total (present value)
$1,938,000
-$35,000
f ISSUE 5:
Frequency of Radiological Effirent Reports (10 CFR 50.36a)
RECOMMENDEDACTION(S):
j Revise 10 CFR 50.36a.to change the frequency of Radiological Effluent Reports from semi-annual to annual.
BACKGROUND:
10 CFR 50.36a, Section (a)(2) requires that each licensee submit within 60 days after January 1 and July 1 of each year a report that specifies the quantity of each of the principal nuclides released to unrestricted areas in liquid and gaseous effluent during the previous six months of operation.
BASIS FOR COST SAVINGS:
Licensees currently submit a total of about 170 radiological effluent reports per year covering the 110 operating units.
If the required reporting frequency is changed as recommended, the result will be elimination of about 85 reports per year.
It is estimated that each report eliminated will reduce licensee cost by about $15,000, and will reduce NRC staff review time by about six person-hours ($288).
The average rem 4u.ing plant life for the affected facilities is assumed to be about 26 years.
It is estimated that changing the rule will involve a one-time NRC cost of about $100,000.
A discount rate of 5% per year is used, in accordance with normal practice.
RESULTS:
Licensee Resources NRC Resources One time savings None
-$100,000 Recurring savings
$1,315,000
$33,000 Total (present value)
$18,900,000
$374,000
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ISSVE 6:
Receipt Back of Processed Low-Level Waste (Amendment to 10 CFR 50.54)
REC 0mENDEDACTION(S):
Expeditiously provide a rule that authorizes power reactor licensees to receive back onsite low level radioactive wastes that have been sent offsite fcr processing.
BACKGROUND:
LLW generated by nuclear power reactor licensees is frequently processed at commercial off-site facilities before being sent to a disposal facility. Off-site processing, typically incineration or compaction, reduces the volume of the waste and the cost of disposal, which is based on volume.
Beginning on January 1,1993, and under the provisions of the low-level Radioactive Waste Policy Amendments Act (LLRWPAA), the three operating LLW disposal sites will close to many licensees in the country.
Instead of shipping LLW directly to the disposal sites, commercial waste processors will have to return LLW to the generators, for interim storage, until a regional or State disposal facility becomes available.
Existing nuclear power reactor licenses, however, do not allow the receipt of processed LLW. On January 30, 1992, the Commission directed the staff to promulgate rules setting forth procedures and criteria for on-site storage of LLW beyond January 1, 1996. These rules will require a licensee to document that he has exhausted all other reasonable waste management options, irrluding management of the LLW by the State and contracting for dispos ' of his LLW.
On-site storage beyond January 1, 1996, is to be considered :is an option of last resort.
In.the light of all these circumstances, the NRC staff has proposed an expedited rulemaking to amend 10 CFR 50.54 as the preferred approach for allowing receipt of processed waste by nuclear power reactor licensees who originally generated the waste.
BASIS FOR COST SAVINGS:
In the absence of this rule, licensees'would need to either amend their existing Part 50 license or apply for a separate Part 30 license.
Preparation of the application by the licensee is estimated to cost about $15,000, based on industry comments.
NRC review of the application and issuance of the amendment would be approximately six to seven staff-days for each request.
(Similar resources would be needed for 10 CFR Part 30 licenses.)
NRC estimates that approximately 70 nuclear reactor licensees would apply for license acendments to receive back processed LLW.
Based on the estimates above, licensees would expend approximately 51,050,000. NRC would expend as much as 490 staff-days in reviewing the applications, at an. estimated cost of
$188,000.
It is estimated that changing the rule would involve a one-time NRC cost of about $100,000 for a net savings of 588,000.
It is possible that some licensees would take additional actions, such as expanding on-site waste storage facilities -- e.g., they could be nearly out of room.
If taken, such actions would be far more expensive than the actions discussed above.
However, such more expensive actions are not included in
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this estimate because the less expensive option of a license amendment is-available.
RESULTS:
Licensee Resources NRC Resouregt One time savings
$1,050,000
$88,000 Recurring savings None None Total (presant value) 51,050,000
$88,000 O
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ISSUE 7:
Contamination Monitoring of Packages (10 CFR 20.1906(b)]
RECOMMENDED ACTION (S):
Revise the new Part 20 to citrify that contamination monitoring by a receiver (licensee) is not required for packages containing radioactive gases or special form sources.
BACKGROUND:
Section 20.1906(b) of the new Part 20 rule requires that each licensee who receives a package known to contain radioactive material shall monitor the external surfaces of the package for radioactive contamination and radiation levels, if the package is (1) labeled as containing radioactive material; or (2) has evidence of potential contamination, such as packages that are crushed, wet or damaged.
FLASIS FOR COST SAVINGS:
The population of NRC licensees most affected by the requirement to monitor packages containing sealed sources are the fixed and portable gauge users.
There are approximately 2250 NRC licensees and, at least an equal number of Agreement State licensees.
In addition, each licensee may authorize more than one place of use or storage.
In order to comply with 10 CFR 20.1906, licensees must have available a radiation survey meter.
At the current time, most of these gauge licensees do not possess a radiation survey meter. These licensees must purchase and maintain a survey eter and must provide training to the staff that will be responsible for u.ing the meter and interpreting the results of monitoring.. A radiation meter, capable of detecting radiation at the levels associated with this type of package, would cost approximately 5500; initial calibration costs approximately $50; and initial training fees would approximate $100.
Based on
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2250 NRC gauge licensees, the estimated cost to implement this requirement would be 51.47 million with a recurring annual fee for meter calibration of 50.11 million.
Assuming the regulation in 10 CFR 20.1906 is made a matter of compatibility for Agreement States and that there are at least an equivalent number of gauge licensees, the total cost for implementation would be as follows:
Initial Implementation - 52.94 million Annual recurring cost - 50.22 million (Note, cost savings to licensees receiving radioactive gases were not included since it is not possibic to clearly identify licensees receiving noble gases and in most cases these licensees would already be -required to possess a survey meter.)
It is estimated that changing the rule would involve a one-time NRC cost of about $100,000.
Additional assumptions include a period of 30 years and a l..
discount rate of 5% per year for the purpose of calculating the present.value of recurring costs.
RESULTS:
Licensee Resources NRC Resources On.' time savings.
$2,940,000
-$100,000 Recurring savings
$220,000/ year Hone Total (present value)
$6,330,000
-$100,000 D
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ISSUE 8:
Posting of Rooms Occupied by Diagnostic Nuclear Medicine Patisnts (10 CFR 20.1903(b))
RECOMMENDED ACTION (S):'
Revise the new Part 20 so that 20.1903(b) includes exceptions to posting requirements for rooms in hospitals occupied by patients administered radioactive materials for diagnostic studies, without any additional requirements or qualifications for personnel in attendance.
BACKGROUND:
Section 1903(b) of the new Part 20 rule specifies that rooms, or other areas in hospitals occupied by patients, are not required to be posted with caution signs provided that (1) the patient is bei:.g treated with sealed sources or has been treated with unsealed radioactive material in quantities less than 30 mci, or the measured dose rate at 1 meter from the patient is less than 5 mr/hr; And (2) there are personnel in attendance who will take the necessary precautions to prevent the exposure of individuals to radiation or radioactive material in excess of established Part 20 limits and operate within approved ALApA limits.
A straight forward interpretation of these new Part 20 requirements (although it appears unintended by the NRC staff) is that rooms occupied by diagnostic nuclear medicine patients (as well as patients undergoing therapy using radioactive materials) must have trained personnel in attendance to take "necessary precautions" unless the room is posted.
BASIS FOR COST SU INGS:
There are approximately 2,000 hospitals authorized by HRC for medical use of byproduct material. Assuming the new requirements are made a matter of compatibility for Agreement States, there are an addition 4,000 licensed hospitals that would be affected in a tnanner similar to NRC licensees.
If the rule is not changed as recommended, it is reasonable to assume that affected licensees would generally opt for posting of rooms occupied by patients rather than the more expensive alternative of providing for trained personnel in ettendance in each case.
(Preliminary estimates indict te the cost of that alternative to be greater than the cost of posting by a factor of ten or mort.)
@ der the posting alternative, the primary added cost would be for purchase of the cigns to be posted.
At an estimated cost of $100 in signs for each licer.see, the total initial cost would be about $600,000.
There would be r;o recurring costs, other than that associated with occasional replacement of signs.
It is estimated that changing the rule will involve a one-time NRC cost of about $100,000.
RESULTS:
Licensee Resources NRC Resources One time savings
$600,000
-5100,000 Recurring savings None Hone Total (present value) 5600,000
-$100,000 w
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