ML20127P164
| ML20127P164 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2279, NUDOCS 8505230711 | |
| Download: ML20127P164 (5) | |
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E DATE ISSUED: 3/7/85 wa ACRS REGULATORY POLICIES AND PRACTICES SUBCOMMITTEE MEETING MINUTES FEBRUARY 6, 1985 itASHINGTON, DC
Purpose:
lh9 purpose of the meeting was to review the NRC's proposed Rule on plant-specific backfitting.,
Attendees:
Principal meeting attendees included:
ACRS NRC H. Lewis, Chairman J. Tourtellotte C. Michelsot, Member T. Cny.
F. Renick, Member R. Ballard C. Wylie, Member G. Knighton i
G. Reed
- P. Boehnert, Stcff A. Cappucci, Staff l
- Part Time Meeting Highlights. Agreements and (:equests 1.
Mr. Tourtellotte discussed the provisions of the proposed Backfitting Pulo and including the public coments received.
Key points made by M'. Tourtellotto included:
- The Rule will require the ED0 to approve 'IRC information requests sent to licensees.
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4 RP&P Meeting Minutes February 6, 1985
- A Backfit:
(1)mustsubstantiallyincreasepublichealthand safety; (2) must be substantiated by a cost / benefit analysis, and; (3) can be implemented on an emergency basis, however, cost / benefit analysis must then be performed after the fact.
- Severe factors are listed in the Rule that must be considered as part of the cost / benefit analysis.
- Public comments have been received from industry, DOE, intervenor groups and members of the public. The debate ever the consideration of backfit costs will continue. The Union of Concerned Scientists contends cost consideration is illegal. Mr.
Tourtellotte stated that his reading of the regulations has not found any such prohibition.
- There is a regulatory " culture" that pervades all aspects of the Agency (ACRSincluded)whichfostersacontinuingtendencyto forcea"fix"(backfit)onlicenseesviaRegulatoryGuides, Branch Technical Positions, etc. Dr. Lewis said the SRP Regulatory Guides, etc. have their place by demonstrating a means to comply with the regulations. The problem is with people who I
will not consider alternatives to means of regulatory compliance l
specified in these documents.
Dr. Lewis asked what is meant by " costs", and how does one address the issue of "how safe is safe enough?" Mr. Tourtellotte said more than the straight costs of the hardware should be considered.
Future costs associated with a backfit should be accounted for as well. Concerning the second point, Mr. Tourtellotte said the Consnission must decide this point. He suggested that sufficient safety will be whatever the NRC (Consnission) says it is. He also said NRC should be directly involved in the design, manufacture, and construction of NPP's early-on, similar to what is done in the L
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c RP&P Meeting Minutes February 6, 1985 r
aircraft industry. Economics must be factored into regulatory i
practices.
G. Reed suggested that NRC adopt a designated representative system l,
in order to address the backfit problem.
I l
i In response to Dr. Remick, Mr. Tourtellotte discussed specifics of l
some of the public comments received on the proposed Rule. The Regulatory Reform Task Force (RRTF) will summarize the comments and send a Paper to the Commission by June 1985.
'Mr. Tourtellotte said the Manual Chapter (MC) should be made consistent with the Rule provisions as soon as possible in order to as'sure an orderly backfit process.
In response to questions, Mr. Tourtellotte said he believes the Staff needs clear direction on the backfit issue. He believes the Staff is still not following the direction of the Manual Chapter.
2.
T. Cox (ED0) discussed the revision of the draft Manual Chapter
.l 0514. The following major revisions have been made:
Applicable to operating plants and plants in construction.
- Regulatory analysis completed and approved at the Office / Region level before communicating the requirement to licensee.
The inclusion of written guidance with examples of what constitutes a backfit.
- Enhanced reporting and recordkeeping system - real time access to information at Headquarters and Regional Offices.
m-r 4
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RP&P Meeting Minutes February 6, 1985 The revised MC has been issued for Agency comment. A final version is scheduled for issuance by February 25, 1985. An agency-wide tracking system will be set up and implemented by late April 1985.
Mr. Cox said this MC revision is not in compliance with the Rule on a "line by line" basis.
Dr. Lewis took exception to a statement in the MC that the SRP, Branch Technical Positions and Regulatory Guides are NRC Staff
" applicable regulatory requirements".
In response to Mr. Wylie, Mr. Cox said if a backfit dispute arises in the Region the Program Office Director at Headouarters would resolve the issue.
3.
NRR addressed the issue of specific licensee contested b'ackfits for Beaver Valley Unit 2.
In particular, the possible maximum precipitation (PMP) specified for this plant is being contested by Duquesne Light. NRC indicated that using more recent National Weather Service estimates of PMP causes a potential flooding probleia at the plant.
J. Tourterlotte indicated that there is a controversy over the PMP estimates given by the National Weather Service. He cited a National Accademy of Science report that "near-PMP" probabilities are much lower than estimated by the NRC (10'O vs "approximately" 10-4).
4.
The Subcommittee, in open executive session, agreed to bring discussion of this issue to the full Committee. The Chairman stated he would draft a letter commenting on the proposed Rule and revised Manual Chapter.
c.
I s 5-February 6,1985 RP&P Meeting Minutes NOTE: Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document Room, 1717 H Street, N.W.,' Washington, D.C...or one can be purchsed from ACE-Federal Reports, 444 North Capitol Street, Washington, DC 20001(202)347-3700.
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