ML20212D196
| ML20212D196 | |
| Person / Time | |
|---|---|
| Issue date: | 12/04/1986 |
| From: | NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| References | |
| SECY-86-348, SECY-86-348-ERR, NUDOCS 8612310311 | |
| Download: ML20212D196 (8) | |
Text
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. :s 4 DECEMBER 4, 1986 C
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E TO ALL HOLDERS OF SECY-86-348 - FINAL RULEMAKING FOR REVISIONS TO OPERATOR LICENSING - 10 CFR 55 AND CONFORMING AMENDMENTS ATTACHED FOR YOUR USE IS ENCLOSURE G TO SECY-86-348 WHICH WAS INADVERTENTLY OMITTED FROM SOME COPIES OF THE PAPER.
ATTACHMENT:
AS STATED THE SECRETARIAT 7(ojM3 8PP-
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Y ENCLOSURE G REGULATORY ANALYSIS OF PROPOSED CHANGES TO 10 CFR 55 4
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u REGULATORY ANALYSIS OF PROPOSED CHANGES TO 10 CFR 55 Prepared by Analysis & Technology, Inc.
under NRC Contract No. RS-NRR-83-107 a
Summary of Regulatory Analysis The purpose of this regulatory analysis is to describe the values (benefits) and impacts (costs) of implementing the revisions to 10 CFR 55. Since the accuracy of these estimates is limited by the lack of extensive data on human performance improvement associated with improved operator licensing examinations, these quantitative measures are qualitatively compared to related information from other sources of verification.
The major regulatory alternatives censidered for the regulatory analysis were the following:
Alternative A.
Take no action and maintain the status quo (used as baseline case in the cost-benefit analysis).
Alternative B.
Implement operator licensing examination changes through changes to 10 CFR 55.
In the cost-benefit analysis, the status quo alternative (Alternative A, no action) was used as the baseline case. The incremental costs (impacts) and benefits (values) associated with Alternative B were determined relative to this baseline. The practical benefit considered was the public exposure (person-rem) avoided that.is associated with potential accidents.
The principal costs were industry and NRC implementation and operating costs incurred.
The value/ impact ratio was calculated as a measure of the total net safety value of Alternative B in terms of public dose avoided (person-rem) in ratio to total NRC and industry costs.
The safety impcrtance (reduction of public risk) is based on the expectation that improvements in the operator licensing examination process will result in improved operator performance (in terms of reduced personnel errors),
resulting in reductions in accident frequencies. Probabilistic risk assessment (PRA) studies provide the best available methodology for linking human performance to reactor safety and, therefore, were used in quantifying the benefits of the expected improvements in human performance. The metnodology used is described in NUREG/CR-2800 and was developed to calculate, using PRA information, the risk and cost impacts of implementing the resolutions to reactor safety issues (for both hardware and human performance areas).
This methodology involves:
(1) estimating improvements in human performance as measured by a reduction in human error rates, (2) determining affected parameters of the risk equation for representative plants via a review of the minimal cut sets for the dominant accident sequences (i.e., the minimum number of component failures and operator errors that cause the accident sequences that dominate the risk associated with plant operation, based upon a combination freauency of occurrence and accident severity), (3) adjusting these risk equation parameters based upon the estimated reduction of the rate of human error, and (4) summing the resulting reduction of risk per facility across the estimated remaining lifetimes of affected facilities.
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I "Affected facilities" for the proposed written examination changes are all 125 power generating units that are now or are expected to be operational.
For the proposed operating test changes, "affected facilities" are only the 35 units for which acquisition or upgrading of simulation facilities would be required.
Estimated costs to the industry for implementation include the efforts required to acquire simulation facilities for facilities not already having plans to acquire a simulator and for upgrades to older simulators to meet ANSI /ANS 3.5 (as endorsed by Reg Guide 1.149) requirements.
Estimated industry operating costs include both simulator operating costs related to operating tests and cost savings due to both improved plant availability and changes in licensing examinations and renewals.
NRC cost estimates include administrative implementation costs and operating cost savings due to changes in licensing examinations and renewals.
The quantitative decision factors determined in this analysis support the decision to implement the proposed changes to 10 CFR 55 on operators' licenses. These positive decision factors include the following:
(1) Public risk reduction estimated is tignificant (Alternative B best estimate = 13,000 person-rem from off-site and 18,100 person-rem from occupational exposure for a total of 31,100 person-rem);
(2) The estimated industry and NRC operating cost savings are greater than estimated implementation costs resulting in a best estimate of a net cost savings of $29.1 million (present value discounted at 10-percent);
(3) Value/ impact ratio is high. The lower bound of the value/ impact ratio is 3500 person-rem /$ million with the value impact ratio beina negative (positivebenefitandnegativecosts(e.g.,retcostsavings)}forbest estimate and upper bound cases.
Other quantitative benefits and costs not included in the value/ impact ratio are avoided occupational exposure and avoided property damage. All quantitative factors are summarized in Table 1.
Some of the qualitative decision factors cited in the regulatory analysis that support the decision to implement the proposed changes include:
o Increased confidence in examination and testing procedures due to consistency provided by simulation facilities.
o Increased concentration on performance indicators in training and drills.
o Increased management and employee commitment to performance-based training and practice due to simulator relevance and availability.
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w Although the rulemaking considered by the regulatory analysis is exempt from 550.109 "Backfitting," the following analysis was considered using the nine points contained in the backfit rule.
1 (1) Statement of the specific objectives of this rulemaking.
a.
To improve the development of operator licensing written examinations and operating tests by deriving the content from job task analyses and associated learning cbjectives; b.
To provide the NRC with an improved basis frr administering operating tests through the use of simulation facilities acceptable to the NRC; c.
To codify existing operator licensing practices and streamline the licensing process; d.
To respond to specific direction given by Congress in Section 306, Nuclear Waste Policy Act of 1982, Public 1.aw 97-425, to promulgate regulations and guidance in the area of operator licensing examinations, simulators, and requalification programs.
(2) General description of the rules, a.
Content of written examinations and operating tests:
Examination content based on the learning objectives derived from job-task analyses would form the basis for licensing written examinations and operating tests at a facility. These job-task analyses are being performed as part of the performance-based programs being implemented by facility licensees as part of the industry supported accreditation program. While these programs are being developed and reviewed for accreditation, the NRC has parallel and complimentary activities underway to improve the content validity of NRC examinations and operating tests.
b.
Simulation facilities: To provide an environment in which to conduct performance-based operating tests, the operating test would be conducted using a simulation facility acceptable to the NRC.
In addition, a plant walk-through will continue to be required as part of the operating test.
c.
Medical requirements: The procedure for the review of the medical condition of applicants and operators would be simplified.
For the usual case, a brief certification by the facility on Form NRC-396 would be required.
d.
Requalification: Operators would continue to be required to maintain proficiency throuah an NRC-approved, facility-conducted requalification program.
Under this rule, the program could be performance-based.
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(3)
Potential change in the risk to the public from the accidental off-site release of radioactive material.
The potential change in the risk to the public from the accidental off-site release of radioactive material is calculated as a reduction of 13,000 person-rem.
(4) Potential impact on radiological exposure of facility employees.
Rather than an increase, the potential impact of radiological exposure of facility employees is calculated as avoided accidental occupational exposure of 100 person-rems and avoided routine occupational exposure of 18,100 person-rem.
(5)
Installation and continuing costs associated with the action, including the cost of facility downtime or construction delay.
Costs associated directly with the rulemaking are primarily associated with the acquisition, upgrading, and operation of simulatiot, facilities.
Other operating costs would result in a cost savings due to some assumed improvement in plant availability due to reductions in operator error rates; fewer licensing examination failures; fewer renewals from six year rather than two year expiration of licenses; and improvements in the development of requalification programs.
The best estimate of total industry implementation costs for acquiring simulation facilities based on the number of affected plants and upgrading current simulators at 10 percent discount rate is $36.8 million.
The operating costs, present value, best estimate at 10 percent discount rate are $.7 million.
Fewer operator errors calculated as a cost sovings due to improved plant availability and, discounted at 10 percent over the 24 remaining years of average facility lifetime staring in 1988, are calculated at a cost savings of $46.1 million.
Other cost savings are calculated at a total best estimate for the 10 percent discount rate of $13.9 million. Therefore, the total costs best estimate is a savings of $22.5 million.
(6) The potential impact of changes in plant or operational complexity, including the relationship to proposed and existing regulatory reouirements.
The revisions to Part 55 and Part 50 complement existing requirements.
Many provisions have been simplified based on current industry efforts.
Moreover, the certification for the medical requirements is in response to an industry petition (PRM-55) to simplify the medical requirements.
(7) The estimated resource burden on the NRC associated with the proposed action and availability of such resources.
The best estimate of NRC total implementation and operating costs, assuming a 10 percent discount rate, is $1.0 million implementation plus
$2.a million for reviews of simulation facilities minus $4.7 million iv i
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savings from fewer requalification examinations minus $.3 million savings from fewer reexaminations minus $1.7 million from fewer license renewals. Therefore, the total best estimate is a cost savings of $3.3 i
million.
(8) The potential impact of differences in facility type, design or age on the relevance and practicality of the proposed action.
No significant differences are anticipated.
(9) Whether the proposed action is interim or final.
This :is a final rulemaking.
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