ML20246F291
| ML20246F291 | |
| Person / Time | |
|---|---|
| Issue date: | 01/10/1989 |
| From: | Conran J Committee To Review Generic Requirements |
| To: | Bernero R, Goldberg J, Jordan E Committee To Review Generic Requirements, NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| NUDOCS 8907130204 | |
| Download: ML20246F291 (4) | |
Text
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.e 707sgpnn January 10.
1989 MEMORANDUM FOR:
Edward L.
Jordan. Chairman Robert M.
Bernero. NMSS Jack R.
Goldbero. OGC Carl J.
Pap er i el. l o.
RIII Denwood F.
Ross. PES James H.
Sniezek. NRR FROM:
James H.
Conran Senior Program Manager (CRGR STAFF)
Office for Analysis and Evaluation of Operational Data
SUBJECT:
ISSUE IDENTIFICATION SHEET FOR MEETING NO. 155 AGENDA ITEM Enclosed for your information is an Issue Sheet relating to CRGR review of proposed Mark I improvements. scheduled for revi ew by the Committee at Meetini No.
155 in Room 013 at Nicholson Lane from 11:00 a.m.
to 1:00 p.m.
on Wednesday. January 11.
1989.
If there are any auestions. call me at 492-0855
(
James H.
Conran Senior Program Manager (CRGR Staff)
Office for An al ysi s and Evaluation of Operational Data
Enclosures:
As stated cc:
C.
Sakenas M.
Taylor OFo3 l 'I? ' f B907130204 890210 r,
r PDR REVOP NRCCRCRl '
NiiG HLE CENTEPs COPY
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CRGR Meeting No. 155 - January 11. 1989 l
l The-staff' revised the proposed Mark I Commision Paper, and Enclosures 4 and 7 of the ' Commi ssi on Paper, in response to CRGR comments provided at Meeting No.
152.. -(The revised material, dated January 4 1989. was distributed to Committee' members on January 5.
1989.)
On the basis of a preliminary review of the revi sed package..the CRGR staff has identified the following principal residual cuestions/ issues:
1.
Consistent with a CRGR comment provided at Meeting No. 152. the staff eliminated. in the Januarv 4' revision. the generic letter that was to i
precede rulemaking under the earlier approach, and recommended the norma.
rulemaking approach as the new preferred alternative.
However, RES has
' subsequently informed the CRGR staff that the package will be further l
revised (in accordance with what RES believes to be EDO instruction) to include an implementation option that uses plant-specific Orders to
_ expedite implementation of the backfits that are approved finally as a result of the. full working of the current r evi ew process.
Complete information on this development will not be available from RES officiall-until Meeting No. 155.
The best information available at this point, however, is that the principal features of the new implementation option will be roughly as f ollows:
a.
Mark I licensees will be notified individually, under the provision' of MC 0514 (NRC Plant-Specific Backfitting Procedures). that the staff intends to impose plant-specific backfits to upgrade the severe accident capability of Mark I containments, and to conduct a rulemaking to make the intended backfits mandatory, if necessary.
Licensees will be encouraged to begin implementing voluntarily the intended backfits to speed the upgrade process.
The backfits identified for imposition will be those approved f i nal l y as a resul*
of the full working of the internal review process (including the CRGR review at Meeting Nos. 152 and 155 of this issue.)
b.
It.is expected that a number of licensees will voluntarily commit tt implement the backfits identified by the staff in the letters sent to individual utilities.
Those commitments by willing licensees will be confirmed by plant-specific Orders.
(This will, of course, put pressure on the remaining licensees to do likewise, lest they bt perceived'by the public. Congress. etc. as being less willing to do things for safety recommended by the NRC staff.)
c.
The 0514 appeal process will be available for those licensees who, despite the peer pressure alluded to in b.
above, and are still unwilling at that point to commit volunt6 11v to implementing the planned backfits.
In parallel with any exercize of the appeal
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process, the staf f 'will initiate a rulemaking to make mandatory for all Mark I licensees the intended upgrades.
(The course of action. outlined above was chosen, instead of issuing plant-specific Orders mandating the. proposed Mark I backfits immediately, because a finding of "necessary for cdecuate safety" is necessary to Justify the more direct course of action.)
RES has. inf ormed the CRGR staf f that this new option will be identified in the (further) revised package as the staff's preferred approach.
The Committee may wish to consider whether this new implementation optior differs in its essence from the " generic letter to precede rulemaking" approach already rejected by the Committee at Meeting No. 152.
Both approaches seem to presume too blatantly the outcome of the intended rulemaking process
...in a way that could undermine the credibilty'and
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perceived f airness/obj ectivity of all NRC rulemakings.
And both seem to
" stretch" the intended purpose of existing regulatory mechanisms /
procedures (e.g.,
the generic letter in the first instance, and MC 0514 in the second instance)
...to a degree that could undermine the Agency's credibility with respect to backfit control and the commitment to maintai:, a continuing discipline in NRC's backfitting activities.
2.
In response to a CRGR recommendation at Meeting No. 152. RES has providec-additional detail regarding the benefits / costs associated with the separate Alternatives (i thru vi) treated in the Regulatory Anal ysi s accompanying this package.
Even with this additional.information, however, it is still not clear whether the staff's recommended al ternati ve. (i. e.. Alternative vi, which ggmbings Alternatives ii thru v) is fully justified.
Alternative vi is cost-effective. in total: but it includes several of the separate alternatives' examined that do not, by themselves, meet the $1000/ person-rem guideline that is commonly used to judge cost-effectiveness.
Speci f i call y.
Table 1 at p.
13 of the Regulatory Analysis for this package, indicates the following costs per person-rem for the' vari ous al ternati ves examined:
Alternative ii
- $1010/ person-rem Alternative iii - $104/ person-rem to $246/ person-rem Alternative iv
$3448/ person-rem to $13889/ person-rem Alternative v
- $5263/ person-rem to $16129/ person-rem So Alternative 111 is very cost-effective. Alternative ii just meets the guideline, and Alternatives iv and v (by themselves) clearly are not cost-ef f ecti ve.
For the combination, of all four alternatives ( i. e.,
Alternative vi), the staff estimates a cost-benefit ratio of
$254/ person-rem to $508/ person-rem.
This is still well within the guideline for cost-effectiveness; but it is only half as cost-effective as Alternative iii separately.
Since the objective of the CRGR process is'to assure the most cost effective use of licensee and Agency resources, the question posed by these circumstances i s, "Is the staff's recommended Alternative vi really justified?"
Another more useful form of that cuestion might be. "If Al t er n ati ves ii, i v, and v were not
9 C-i .
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l inclubed in the staff's recommended Alternative. would the Commission's
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$gigty @ggly still be met?
The Committee should pursue these cuestions (or suitable variations thereon) with the staff to assure that the necessary discipline i s maintained in the AQency's backfitting acti vi ti es.
If the staff is not recuired to demo 7 strate clearly that gli of the elements of the recommended Alternative vi are needed to reasonably satisfy the Safety Goals. it could become a common practice in cases like this (i.e.,
where the proposed backfits are not judged necessary for adeouate safety) to load non-cost-benefici al " riders" (even previously rejected backfit proposals) onto legitimate. clearly cost-beneficial, backfit packages until the slOOO/ person-rem cost-benefit guideline is just met.
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