ML20134C798
| ML20134C798 | |
| Person / Time | |
|---|---|
| Issue date: | 02/28/1996 |
| From: | Dudley N Advisory Committee on Reactor Safeguards |
| To: | Kress T Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20134B716 | List: |
| References | |
| ACRS-GENERAL, NACNUCLE, NUDOCS 9610080279 | |
| Download: ML20134C798 (2) | |
Text
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/ g UNITED STATES
! NUCLEAR REGULATORY COMMISSION
{ ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
! % WASHINGTON, D. C. 20055 k***.*
- 1 i February 28, 1996 l i l i
i MEMORANDUM TO: Dr. T. S. Kress, Chairman !
orage and Decosmissioning Subcommittee e uel
- FROM: Noel Dud ey i j Senior Staff Engineer
SUBJECT:
EDO RESPONSE TO ACRS LETTER CONCERNING PROPOSED RULEMAKING i ON DEC0f9tISS10NING
! J i The Committee issued a report dated March 17, 1995, to Chairman Selin i
' concerning proposed rulemaking associated with,decosmissioning of nuclear power plants [ attachment 1). In a less than timely letter, Mr. James Taylor, l Executive Director for Operations (EDO), responded to the ACRS report on i February ~15, 1996 [ attachment 2). The EDO response includcd a letter dated l March 24, 1995, from Brookhaven National Laboratory (BNL) to the staff ;
discussing comments made in the Committee report. l The SNCol-stter states that a decommissioning risk analysis is beyond the scope of the BNL program. However, SNL used a programmatic process that explicitly considered offsites consequences of four different spent fuel storage configurations. In NUREG/CR-4982, BNL applied simplified PRA analyses to quantify (1) the frequency of initiating events that could compromise spent i fuel integrity, (2) the fuel damage probability based on conditional !
probabilities of subsequent systes failures, and (3) the magnitude of radionuclide releases to the environment and the consequences of those releases. The uncertainty in the risk estimates are large.
The BNL letter states that consequence analyses for the four spent fuel storage configurations and the determination of the configuration 1 critical delay time were not complete. [ note: BNL prepared the letter a year ago.]
The EDO response included the following items, but does not specify a staff position or expected resolution:
a the use of the 50.5 fety evaluation process for controlling decoimeissioning acti .ies a the scope of the ongoing BNL risk evaluation
- the schedule for evaluating results of the BNL risk, evaluation and issuance of the proposed final rule Based on the unresolved issues mentioned in the EDO response the Committee may want to consider reviewing the proposed final decommissioning rule and the staff's use of a risk basis for reformulating the final rule.
9610080279 960326 PDR ACRS GENERAL PDR yA}
J l
Attachments: 1. Letter dated March 17, 1995, from Chairman T. S. Kress, ACRS, to Chairsan Selin, NRC,
Subject:
Proposed Rulemaking Related to Decommissioning Of Nuclear Power Reactors
- 2. Letter dated February 15, 1995, from James Taylor, Executive Director for Operations, to Chairman T. S. Kress, ACRS,
Subject:
Proposed Rulemaking Related to Decommissioning Of Nuclear Power Reactors cc via E-mail w/o atts:
J. Larkins R. Savio S. Duraiswamy ACRS Staff ACRS Fellows b
e 4
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\ NUCLEAR REGULATORY CottedtM40N UNITED STATES 4
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ASWIGORY 00ammTTEE ON REACTOR SaFSOUaADS j maswessetess o.c. asses g%.....
March 17, 1995 The Honorable Ivan Selin Chairman U.S. Nuclear Regulatory Comunission Washington, D.C. 20555-0001.
Dear Chairman Selin:
SUBJECT:
PROPOSED RU1BGutING REVISION TO 10 CFR PARTS 2, 50, AND 51 RELATED TO DECopetISSIONING OF NUCLEAR POWER REAC'! ORS During the 419th meeting of the Advisory Constittee on Reactor Safeguards, March 9-10, 1995, we reviwwed the proposed rule on deccouaissioning of nuclear power reactors. During ouh review, we had discussions with representatives of the NRC staff and the Nuclear Energy Institute. We had the benefit of the document referenced.
The proposed revision to the decommissioning rule appears to allow significant flexibility for dif ferent possible circumstances under which a nuclear plant may cease operation and transition into the decomunissioning mode. The proposed revision to the rule reduces unnecessary burdens on both the licensees and NRC staf f.
We believe that the proposed rule should be issued for public comunent . We are concerned, however, that the proposed rule has not been founded on a risk basis. Realistic risk analyses Consequent- for decom-missioning nuclear power reactors have not been done.
ly, there is no clear relationship between the requirements being retained in the revised rule and the realistic risks to the public health and safety and the environment posed by decomunissioning.
The revised rule suny still. isipose unnecessary burdens on licensees and any aske excessive danmaMs on NRC resources. We hope that steps can be taken in the near future to establish a risk basis f:r reformulating 10 CFR Parts 2, 50, and 51. We believe this is an issue on which comunent f root the industry and the public should be
- sought.
Sincerely,
, 1S M "
T. S. Kress Chairman
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