ML20127N419
| ML20127N419 | |
| Person / Time | |
|---|---|
| Issue date: | 11/12/1992 |
| From: | Shewmon P Advisory Committee on Reactor Safeguards |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| RTR-NUREG-BR-0058, RTR-NUREG-BR-58 ACRS-R-1502, FACA, NUDOCS 9212010251 | |
| Download: ML20127N419 (3) | |
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- i, NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFkGUAHDS ACRSR-1502 PDR p, a WASHINGT ON, D. C. 205$5 04,, ,o#
November 12, 1992 Mr. James M. Taylor Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Taylor:
SUBJECT:
REVISED REGULATORY ANALYSIS GUIDELINES During the 391st meeting of the Advisory Committee on Reactor Safeguards, November S-7, 1992, we reviewed a draft of NUREG/BR-0058, Revision 2, " Regulatory Analysis Guidelines of the U.S.
Nuclear Regulatory Commission." Our Subcommittee on Safety Philosophy, Technology, and Criteria considered this matter during a meeting on October 28e 1992. During these meetings, we had the benefit of discussions with representatives of the NRC staff, and of the document referenced.
This brochure will be NRC's policy-setting document with respect to regulatory analyses. As such, it deals with a number of very important issues that bear directly on the overall NRC regulatory philosophy and approach. Some of the positions taken in the proposed guidelines represent departures from current practice, have never been formali ;ed before, or dif fer from the industry and the Office of Management and Budget (OMB) positions.
We believe this to be such an important document that even a draft version to be issued for public comment should reflect high levels of intellectual and technical content, coherence, and clarity of thought and presentation. Although the draft document does have much to conmend it, we believe the subject deserves better. We recommend that sutstantial additional ef fort be put into rethinking and redeveloping some of the regulatory positions and into developing a " showcase" document with respect to content, stvle, and quality of prose. We do not see any urgent need for, and recommend against, issuing the draft document at this time. We expect to review the revised document before- it is issued for public comment.
In its .pasentations to us, the staff identified some specific issues for particular attention. Altitcugh we agree with some of the positions taken on these in the document, we have fundamental differences with several of them. We provide you with our comments below.
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s tir . James M. Taylor 2 November-12,- 1992 Eafety Goal ImDlementation This document suffere from the absence of a clear statement of the means by which the Commission's overall regulatory philosophy will be implemented through the concepts of adequate protection, safety goals, the backfit rule, ALARA principles, etc. Whether here or elsewhere, such a statement is urgently needed.
The safety goal decision chart only deals with issues that result in changing the core-Jamage frequency. We believe it should also consider issues that could change the conditional containment failure probability.
Ouantification of Benefits Figure 3.1 of the proposed guidelines should include a step in which a determination is made on whether the proposed enhancement is something that can be evaluated by quantitative risk estimates.
If so, we believe that PRAs must be used to quantify the benefits.
If not, the analysis would go to a different decisionmaking scheme (e.g., expert opinion, engineering / regulatory judgment) .
Treatment of Voluntary Actions We agree with the position taken on voluntary actions in the proposed guidelines. However, we are concerned that this will tend to discourage voluntary actions. Some means, outside the regulatory analysis process, should be sought to promote and encourage such actions.
Discount Rate While the OMB directive of 1981 (which has never been rescinded) applied specifically to executive agencies, NRC ought to have good reasons for ignoring it. The fact that others do so is not a good-reason. We were told that efforts had not been made to better understand OMB's rationale. We recommend that this be dohe.
Simultaneously Satisfyina the Reauirements of the Backfit ' Rule and/or the Committee to Review Generic Recuirements We agree that regulatory analyses should be made in such a' manner that they also meet these other needs.
Treatment gf Averted Onsite Costs The staff intends to treat averted onsite costs (AOSC) as an off-set to the costs incurred by the utilities in implementing the associated requirement. We believe AOSC should-be included in the benefits column and not the costs column. We are concerned, however, that the methods and assumptions used for computing AOSC
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+ -Mr. James M. Taylor 3 November 12, 1992 are highly uncertain and can dominate the final answer.
Accordingly, we recommend that further effort be given to establishing definitive guidance for AOSC evaluations.
In the draft document, the staff recommends-that the results be presented in terms of not value (value minus impact) rather than as a ratio (value/ impact). This should not be an issue because these are entirely dif ferent measures and both should be part of the decision process.
Discount.i nct of Health and Safety Effects We are unconvinced by the arguments presented for the staff's position that health and safety effects not be discounted in the value/ impact analyses. Appropriate balancing of costs and benefits require discounting of each.
Monetary Value of a Person-Rem Avertegl There is, in principle, no problem with the staff's proposed interim position, " continuing to use the value of $1000/ person-rem until a final recommendation can be made after further review and analysis," except that such a position has existed for about 15 years, and can persist indefinitely. We recommend that an appropriate treatment of the monetary values to be associated with onsite and offsite health effects (both early and latent) and land contamination be developed promptly.
Sincerely, c M*
Paul Shewmon Chairman
Reference:
Letter dated September 11, 1992, from C. J. Heltemes, Jr:, Of fice of Nuclear Regulatory Research, to Raymond F. Fraley,_ Advisory Committee on Reactor Safeguards, transmitting:
(a) Draf t SECY paper (undated) for the Commissioners from James M.
Taylor, Executive Director for Operations, NRC,
Subject:
Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission (Predecisional)
(b) Draft NUREG/BR-0058, Revision 2 (undated), " Regulatory-Analysis Guidelines of the U.S. Nuclear Regulatory Commission" (Predecisional)
(c) Separate Enclosures (undated) on Averted Onsite Costs and Discounting of Health and Safety (Predecisional)