ML20151S672
| ML20151S672 | |
| Person / Time | |
|---|---|
| Issue date: | 08/14/1998 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20151S662 | List: |
| References | |
| SECY-98-158-C, NUDOCS 9809090004 | |
| Download: ML20151S672 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER MCGAFFIGAN I
SUBJECT:
SECY-98-158 - RULEMAKING PLAN FOR IMPLEMENTATION OF REVISED SOURCE TERM AT OPERATING REACTORS Approved X Disapproved X Abstain Not Participating COMMENTS:
See attached comments.
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li, DATE Entered on "AS" Yes X No
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Commissioner McGaffigan's Comments on SECY-98158 l
l strongly support proceeding with rulemaking to allow the use of the revised source terms j
described in NUREG-1465. This effort has been several years in the making and offers the i
potential for significant burden reduction to licensees without any reductions in safety, it appears from the rulemaking plan (Attachment A) that the rule itself is essentially already written, if the Commission approves the staff recommendations (Options 1b and 2c). I approve those recommendations. However, I believe the schedule for completing the rulemaking can be significantly advanced. I recommend that the proposed rule package (without a regulatory guide) be submitted to the Commission by October 30,1998 and that the final rule package (including a regulatory guide and standard review plan developed in parallel with stakeholders while the rule is out for comment) be submitted to the Commission by July 31,1999. The regulatory guide and standard review plan will presumably discuss the NRC's expectations regarding the nature of the " evaluation and analysis" required by 50.95(c) when a licensee submits a license amendment to use a revised source term. Such expectations will presumably vary depending on the scope of the license amendment. The regulatory guide and standard review plan will presumably also deal with NRC's expectations regarding selective or limited use of the revised source term and the circumstances under which that would be permitted.
I do not agree with the staffs conclusion in the paper that "any implementation of the revised source term requiring detailed dose calculations should address all applicable aspects of the revised source term." Instead, the staff should approve licensee requests to implement changes based on a partial implementation of the revised source term, unless such requests involve non-conservative or technically unjustified applications. But this issue does not affect
- the proposed rule language, which would permit licensees to submit license amendments for selective use of the revised source term, and should be worked out in the regulatory guidance and staffs standard review plan for considering license amendments.
The staff should promptly complete the pilot initiatives and use that experience to assist in preparation of the regulatory guidance and standard review plan. The staff should grant technically-supported exemptions to the pilot plants during the course of the initiative and be prepared to process similar exemption requests during the rulemaking period.
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UNITED STATES y
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WASHINGTON, D C. 20555-0001 c
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September 4, 1998 OFFICE OF THE SECRETARY MEMORANDUM TO:
L. Joseph Callan Execut' Director for Operations FROM:
John o
cre ary SUDJECT:
STAFF REQUIREMENTS - SECY-98-158 - RULEMAKING PLAN FOR IMPLEMENTATION OF REVISED SOURCE TERM AT OPERATING REACTORS The Commission has approved the staffs proposed rulemaking plan (options ib and 2c) subject to the following comments.
The Commission disapproved the staffs conclusion that any implementation of the revised i'
source term requiring detailed dose calculations should address all applicable aspects of the revised source term. Instead, the staff should allow limited or selective application of the revised source term unless such requests involve non-conservative or technically unjustified applications. Licensees should be allowed to utilize the more accurate source term methodology in the most flexible manner consistent with the maintenance of a clear, logical, and
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consistent plant design basis. The issue of selective impicmentation should not affect the rule language and should be worked out in the regulatory guidance and standard review plan for considering license amendments. The staff should initiate the exploration of options that consider the use of risk information as a means of providing a risk perspective relative to increased applications of the new source term. This work should not delay the current rulemaking activities but should proceed in parallel to provide a basis for risk informing the current source term rulemaking or future source term rulemaking changes, when and if appropriate.
The staff should promptly complete the pilot initiatives and use that experience to assist in preparation of the regulatory guidance and standard review plan. The staff should grant technically-supported exemptions to the pilot plants during the course of the initiative and be prepared to process similar exemption requests during the rulemaking period.
The staff should work to expedite the schedule for this rulemaking and provide a draft rule to the Commission by December 15,1998. The final rule, regulatory guide, and standard review plan should be submitted to the Commission by July 30,1999. In order to ensure that stakeholders are kept up to date as this rulemaking proceeds, the staff should place the draft proposed rule, the initial draft regulatory guide, and the draft standard review plan in the PDR at the same time that those documents are forwarded to the ACRS for review.
(EDO)
(SECY Suspense:
Draft rule 12/15/98 Final rule, regulatory guide, and standard review plan:
7/30/99)
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cc:
Chairman Jackson Commissioner Diaz j
Commissioner McGaffigan OGC-ClO
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OCA-OlG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
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