ML20196A091
| ML20196A091 | |
| Person / Time | |
|---|---|
| Issue date: | 01/20/1988 |
| From: | Zech L NRC COMMISSION (OCM) |
| To: | Gejdenson S HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML20196A095 | List: |
| References | |
| NUDOCS 8802040252 | |
| Download: ML20196A091 (7) | |
Text
F Nb
[0,,
UNITED STATES t
NUCLEAR REGULATORY COMMISSION o
WASHINGTON, D. C. 20555 5
j
/
CHAIRMAN January 20, 1988 The Honorable Samuel Gejdenson, Chairman Subcomittee on General Oversight and Investigations Committee on Interior and Insular Affairs United States House of Representatives Washington, DC 20515
Dear Sir. Chairman:
As indicated in our response of December 2,1987, enclosed are answers to questions Sj and 6 of your October 27, 1987 letter concerning NRC's backfit rule.
Should you have any further questions, please let me know.
Sincerely, tv.
d.
Lando W. Zec Jr.
Enclosures:
As stated cc: Rep. Denny Smith p-l
~
8802040252 880120.
PDR COMMS NRCC CORRESPONDENCE PDR 1
QUESTION 5J. Are there any requirements in NRC regulations that go beyond adequate protection? If so, please identify them.
ANSWER.
Compiling a list of regulations that goes beyond adequate protection would be a lengthy task and such a list does not now exist. There are some requirements which clearly do go beyond adequate protection and, as discussed with your staff, some examples are provided below in lieu of a list.
Regulations and staff interpretations of them, such as Regulatory Guides and Standard Review Plans, typically have margins of safety built in such that they go beyond an adequate level of safety.
For example 10 CFR Part 20 requires that licensees maintain radiation exposure and releases of radioactive materials in effluents to unrestricted areas as far below the l
limits specified in our regulations as is reasonably achievable. There are also regulations that are intended to achieve a substantial increase in protection beyond adequate. Two examples are given below that are intended to go beyond the adequate protection standard. They are the Anticipated Transient Without Scram (ATWS) rule and the proposed Station Blackout (SBO) rule. These rules are aimed at preventing core damage accidents being caused by multiple failure possibilities.
l The rule (10 CFR 50.62 specifying requirements for Reduction of Risk from r
ATWS Events for Light-water Cooled Nuclear Power Plants) was implefnented in 1984. This rule requires equipment installation to reduce the likelihood of a failure of the reactor protection system and to reduce the consequences of its failure (e.g., severe core damage) in the very unlikely event that failure of the entire system occurs.
For pressurized water reactors this includes equipment to trip the turbine and initiate auxiliary feedwater independent of the reactor protection system (RPS), and diverse and independent reactor protection equipment.
For boiling water reactors this includes alternate methods of control rod insertion (independent of the RPS),
an enhanced standby liquid control system capacity, and recirculation pump trip equipment. The record on this rule development is very long. However, GEJDENSON/EDO 1/15/88
QUESTION 5J.
(Continued).
based on considerable evaluation, including cost-benefit analysis, it was finally decided that the additional overall safety protection was substantial and the burden of costs involved were justified in view of the increased l
1 protection.
Another example is the proposed 10 CFR 50.63, which addresses loss of all alternating current power (comonly call station blackout or SBO).
This proposed requir-mnt is based on information developed under the Comission's study of Unresobed Safety Issue A-44, Station Blackout. The rule would assure that a loss of both offsite power and onsite emergency AC power systems will not importantly contribute to the overall frequency of a core camage accident which could adversely affect the public health and safety.
Each AC power system by itself can support plant safety equioment and each generally meets the Comission's single failure criterion under Appendix A to 10 CFR Part 50 which provides the basic framework and criteria for ths ddequate protection standard. The rule, however, goes beyond this standard and considers that a failure of both systems may occur. This Proposed Rulemaking was initiated by Federal Register notice published on March 21, 1986. Public coments have been analyzed and the Comittee to Review Generic Requirements (CRGR) has recomended adoption of a final rule to the EDO. As with the ATWS rule (10 CFR 50.62), the staff has concluded that the additional overall safety protection is substantial and the costs involved are justified in view of the increased protection.
r GEJDENSON/EDO 1/15/88
QUESTION 6.
In a memorandum to the Commissioners of 5/19/86, the EDO stated that the staff does not believe that the revision to Part 20 will provide a substantial change in the radiation dose received by workers and members of the public. On August.29, 1986, the NRC published a draft backfit analysis which said that Part 20 should be promulgated even though it may not provide a substantial increase in the overall protection of the public health and safety. On December 3, 1986, the EDO wrote another memorandum endorsing the staff's backfit analysis. The staff concluded that the rule would result in a substantial increase in the overall protection of public health and safety.
(a) How do you reconcile these three statements?
ANSWER.
The first two statements should not be compared to the third. The first two statements were made with reference to SECY-86-48A, Backfit Analysis for Proposed Revision of 10 CFR Part 20, dated May 19, 1986. This paper involved a complete revision of the existing language in the rule to make it co'nform to reconinendations *>f the International Commission on Radiation Protection and Federal Radiation Guidance on occupational radiation protection.
The third statement was made with reference to SECY-86-360, Amendments to 10 CFR Part 20 to Require the Use of Accredited Personnel Dosimetry Processors, dated December 3, 1986. This latter paper involved the addition pf apew requirement to Part 20. Thus, the third statement addresses a distinct and separate issue.
The first statement is an NRC staff finding concerning the draft backfit analysis in SECY-86-48A.
In addition, the staff also states that, "taking all factors, quantitative and qualitative, into consideration, it is the staff's judgement that the benefits of promulgating the proposed 10 CFR Part 20 would outweigh the costs." The second statement, which appeared in both SECY-86-48A and an August 29, 1986 Federal Register Notice that published the draf t backfit analysis for public comment, reflects the Commission's view GEJDENSON/EDO 1/15/88
QUESTION 6.
(Continued) with respect to the staff finding. The purpose of the Federal Register Notice was to solicit public coments which the Comission could consider in arriving at a final decision on the draft backfit analysis. These statements do not conflict but rather reflect the deliberative process. inherent in any f
rulemaking proceeding.
Copies of the applicable SECY papers and the Federal Register Notice are attached for infonnation.
i r
GEJDENSON/EDO 1/15/88
QUESTION 6 (Continued).
(b) Did new information come to the staff's attention between May 19, 1986 and December 3, 1986.
If.so, what?
ANSWER No. The answer to (a) makes the situation clear.
N F*
QUESTION 6 (Continued).
(c) Please identify those members of the NRC staff who prepared the December 3,1986 backfit analysis of Part 20.
ANSWER Donald 0. Nellis prepared the December 3, 1986 Commission paper which contained a backfit analysis for personnel dosimetry processing. Others involved in comment or concurrence on the document were A. Roecklein, R.
Alexander, G. Marcus, K. Goller, D. Ross and E. Beckjord. All the personnel were in the NRC Office of Nuclear Regulatory Research.
V. Stello, EDO, approved and si5ned the document.
i r-
.