ML20236K961
| ML20236K961 | |
| Person / Time | |
|---|---|
| Site: | 07003091 |
| Issue date: | 06/17/1998 |
| From: | Murray A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9807100157 | |
| Download: ML20236K961 (2) | |
Text
T D
h June 17,1998 e .
MEMORANDUM TO: File
_ 3 y c7/ I FROM: Alex Murray b M TWRS Section Special Projects Branch, FCSS/NMSS i
SUBJECT:
TELEPHONE CALL
SUMMARY
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l l had a telephone conversation with Ann Hansen of H&R Associates in Oak Ridge, Tennessee (the "H" in "H&R," [423] 966-0438, ahansen@handrtech.com), on June 12,1998. Ann is the contractor supporting the Regulatory Unit (RU) on several regulatory transition issues, including Issue #9 conceming regulatory transition effects upon the TPA and its milestones (the subject of f
her call).
Ann mentioned the lawsuit over the TPA that has been recently initiated by the State of 4 Washington against the DOE. She noted this has raised concems within the RU about the l potential impact of regulatory transition to the NRC, and, in particular, the potential for NRC imposition of additional regulations resulting in schedule impacts and facility nonoperation for a period of time, with a subsequent impact upon TPA commitments. Ann could see two approaches to alleviate these concems: (1) conduct regulatory transition and have the NRC assume regulatory authority for TWRS as soon as possible, or (2) arrange an agreement between the DOE and the NRC restricting or eliminating the potential for facility nonoperation j during regulatory transition at a future date.
Ann brought up the subject of the gaseous diffusion plants (GDP's). She indicated the RU did not want to see a repeat of the GDP experience at TWRS, and have potentially hundreds of millions of dollars of expensive backfits in order to meet NRC regulations. I gently corrected her, l noting that I did not think the NRC wanted a repeat of the GDP experience either, because most l of the $200 Million cost associated with the NRC assuming regulation of the GDP's involved bringing the GDP's into compliance with the DOE regulations and standards, with only a small cost involved with NRC regulatory requirements. The GDP's were advertized as meeting DOE regulations and standards, but, in fact, did not, and it fell upon the NRC to enforce them based upon its mispon of protecting public safety and the environment. I also reiterated the NRC's potential concem of future regulatory transition of TWRS facilities that may already be noncompliant with DOE regulations and requirements, and that regulatory transition would be simpler if TWRS would be designea, constructed, and operated to NRC requirements using f proven principles of regulation. g Ann also mentioned the difficulties experienced by the RU and the DOE in the negotiations with BNFL. Apparently, the negotiations are going slowly, and BNFL is being very difficult and /// [.
conceding very few items.
Ann thought the RU should consider changing its regulatory philosophy from a top level to a rule based approach, and encourage BNFL away from a monetary focus and towards a risk-informed, performance based approach. Ann speculated that if BNFL were to focus on safety and meeting milestones, then the economic aspects would fallinto place with little effort. Ann also mentioned the unusual approach with the proposed 250 ft stack and its use of distance to mitigate accident scenarios - she did not think this was a good design path to follow, and she was also concerned about its seismic resistance and fall area.
9007100157 900617 PDR ADOCK 07003091 C PDR
2 Ann stated that she was still familiarizing herself with the issues surrounding TWRS, and that we should continue discussions in the future. I agreed. Ann indicated she had approximately two months to work on this (and the other issues assigned to her), with the RU finalizing her contributions sometime in late August or early September.
Docket 70-3091 cc: M. Tokar, SPB/FCSS W. Pasciak, SPB/FCSS Distribution:
Docket 70-3091 Central Fife DAHoadley Public i
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