ML20149G165
| ML20149G165 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1994 |
| From: | De Plangue E NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9410030147 | |
| Download: ML20149G165 (3) | |
Text
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s RELEASED TO THE PDR I
NOTATION V 0 T E:
RESPONSE SHEET
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JOHN C. HOYLE ACTING SECRETARY OF THE COMMISSION FROM:
C0mISSIONER DE PLANQUE
SUBJECT:
SECY-94-176 - ISSUANCE OF PROPOSF9 RULEMAKING PACKAGE ON SHUTDOWN ALJ LOW-POWER OPERATIONS FOR PUBLIC COM4ENT APPROVED x we mneDISAPPROVED Ass RAIN NOT PARTICIPATING REQUEST DISCUSSION C0144ENTS:
1 See attached comments l
C 9410030147 940902 C
SIGNAT(IRE
[8R,gs%eBeEECeon, RELEASE VOTE
/ xx /
September 2, 1994 DATE WITHHOLD VOTE
/
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/g No T
ENTERED ON "AS" YES 30001f3 k
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y Commi :ioner de Planque's Comments on SECY 94176:
I commend the staff on the extensive analysis of shutdown risk that provides the backaround for this proposed rule.
I agree with the Chairman's comment on the need to reassess the BWR backfit analysis conclusion; in addition, I believe two minor changes should be made before the rule is released for comment, to avoid the inefficiency that comes with misinterpretation.
First, the a)plicability of the rule should be clarified to exclude those plants that lave defueled for final shutdown, but still retain an operating license (i.e., those that are preparing for decommissioning).
Second, the wording of (c)(1) should be changed to read:
"Take measures to ensure that uncontrolled changes in reactivity..." The regulatory guide can provide any needed details on what " measures" a licensee might take.
t The staff's intention with the current wording, as I understand it, is to provide an unambiguous performance-based requirement.
Licensees, presumably, would use their discretion to establish outage programs designed to meet this goal. As currently worded, however, the proposed rule gives NRC no leeway to evaluate the licensee's preventive measures, in the event of a failure.
If, for instance, a leaking valve causes an " uncontrolled change" in reactor coolant inventory, the licensee has presumably violated the rule. The change I have proposed does not alter the licensee's responsibility: however, it allows the regulator flexibility to judge the overall spectrum of licensee performance that leads to such an event.
In addition, I recommend that several portions of the regulatory analysis discussion be reconsidered, as discussed below:
t a.
Despite the lower cost effectiveness of the proposed rule for BWRs, the staff recommends that " Improvement A" be implemented at all plants. As l
written (see p. viii and elsewhere), the staff's explanations are only margindily convincing.
From staff discussions, however, I understand l
(1) that under existing regulations, a shutdown BWR may be in compliance 4
while still slightly above the 10 risk of a core damaging accident with significant offsite release (due to the inability to close the BWR containment), (2) that implementing the proposed rule would be enough to l
4 reduce this risk to less than 10, thus making us more " comfortable" with shutdown risk at BWRs, and (3) that this is sufficient basis to recommend that BWRs implement " Improvement A." despite the lower cost j
effectiveness.
If my understanding is accurate I think the analysis could be strengthened by including these points in the discussion.
b.
In Section 4.2.2 (pp. 21-22), the staff discusses as a benefit the avoided occupational exposure (V2).
I find it curious that we tcke t
credit for reducing occupational exposure by not needing to clean up after the avoided accident, but take no credit for avoiding the potentially devastating near term exposure to workers that could occur with a severe core damage accident during shutdown (presuming a ground-level release),
I understand that this manner of presenting V2 might simply be due to the ready availability of previous analyses of post-accident cleanup. However, some analysis of the avoided near-term high I
'a i
i t
i dose to essential personnel-even if made with the caveat of broad i
assumptions -would strengthen the benefit of reducing shutdown risk.
c.
In Section 4.3.3 (pp. 24 26), the staff justifies assuming a zero cost based on the belief that the proposed requirements will not increase outage length industry wide. The analysis includes the statement:
Regulatory requirements, primarily technical specifications, have not traditionally been a principal factor in determining the length of an i
outage.
For licensees who already have learned to conduct efficient, tightly orchestrated outages, this statement may be more or less true.
Many of j
these licensees, in fact, are already complying with the requirements as stated in the proposed rule, and therefore would not be impacted in terms of outage length.
However, those licensees that already demonstrate difficulty in balancing regulatory requirements during I
shutdown, who routinely miss their completion goals (due to poor organization, poor planning, poor maintenance practices, etc.), will probably find this statement implausible, and will probably initially be t
even more negatively impacted by the proposed rule.
I believe the analysis in this area would be more acceptable by acknowledging this possible impact, and focusing on the long term positive benefit. By implemerting these requirements for reduced risk, coupled with improved focus on the " essential elements for an outage program" (described in NUREG 1449 and elsewhere), licensees with ineffective outage practices should actually become more efficient over time.
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