NUREG-0885, Notifies of NRC Feb or Mar 1985 Site Visits W/Bmnl to Obtain Util Views on Any Regulatory Requirements Believed to Have Marginal Importance to Safety & Burdensome to Util,Per Encl 841003 Fr Notice
| ML16152A399 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, McGuire, 05000000 |
| Issue date: | 01/22/1985 |
| From: | Stolz J Office of Nuclear Reactor Regulation |
| To: | Tucker H DUKE POWER CO. |
| References | |
| RTR-NUREG-0885, RTR-NUREG-885 NUDOCS 8502040400 | |
| Download: ML16152A399 (7) | |
Text
- JAN 2 2 W5~~DQ Dockets Nos. 50-269, 50-369, 50-413 DISTRIBUTION 50-270, 50-370, 50-414 and encket FileT RIngram 50-287 NRC PDR HNicolaras L PDR Gray File ORB#4 Rdg EBlackwood Mr. Hal B. Tucker DEisenhut Hornstein Vice President - Nuclear Production OELD RBirkel Duke Power Company EJordan Klabbour Post Office Box 33189 PMcKee AMTse 422 South-Church Street JPartlow CTrammell Charlotte, North Carolina 28242 ACRS-10
Dear Mr. Tucker:
Re:
Oconee Nuclear Station, Units 1, 2 and 3; McGuire 1 and 2; and Catawba 1 and 2.
The Commission's Policy and Planning Guidance for 1984 (NUREG-0885, Issue 3) states:
"Existing regulatory requirements that have a marginal importance to safety should be eliminated" (section IV.A, Planning Guidance No. 3).
To implement this item, the NRC staff has initiated a program entitled "Effectiveness of LWR Regulatory Requirements in Limiting Risk". This program was announced in the Federal Register on October 3, 1984. A copy of that notice is enclosed.
As part of that program, we plan to visit a sample of utilities to obtain their views on any regulatory requirements that are believed to have marginal importance to safety but which have high burdens on the utilities or the NRC. Two contractor personnel from Pacific Northwest Laboratories, plus Dr. Anthony Tse from NRC's Office of Research, an NRC project manager from the Division of Licensing and possibly one additional NRR representative would participate in a one-day visit in your corporate offices. More details concerning this proposed visit are also enclosed. We anticipate that the visits would take place in February or March of 1985.
No response to this letter is necessary. We will be contacting you by telephone to see if you are interested in participating in this phase of the program, which is entirely voluntary.
Sincerely, OWIGIVAL SIG= B jamW F. ST014 John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing
Enclosures:
- 1. FR Notice
- 2. Visit Details cc w/enclosures:
See next page 0A D
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- DL HN i aras;cf JSt ell
//-85/
5 85 8502040400 850127 PDR ADOCK 05000269 P
Duke Power Company cc w/enclosure(s):
Mr. William L. Porter Duke Power Company P. 0. Box 33189 422 South Church Street Office of Intergovernmental Relations Charlotte, North Carolina 28242 116 West Jones Street Ral-eigh, North Carolina 27603 Honorable James M. Phinney County Supervisor of Oconee County Walhalla, South Carolina 29621 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission, Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control Regional Radiation Representative 2600 Bull Street EPA Region IV Columbia, South Carolina 29201 345 Courtland Street, N.E.
Atlanta, Georgia 30308 Mr. J. C. Bryant Senior Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, South Carolina 29678 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 Manager, LIS NUS Corporation 2536 Countryside Boulevard Clearwater, Florida 33515 J. Michael McGarry, III, Esq.
Bishop, Liberman, Cook, Purcell & Reynolds 1200 17th Street, N.W.
Washington, D. C. 20036
39066
-Proposed Rules F*d** Ro*s Vol. 4o. No. 19s Wednesday. October 3. 1984 Thes season of Vs FEDERAL REGISTER appropriately modified. would improve assess their safety benefits and the NRC conta" nos es to te pic oft the efficency and effetiveness of the and indusy cost of implementation. At proposed aanca of rues Md NRC regulatory program for nuclear the and of I& the NRC will ascertain repuiaons The purpose of a s e
power plants without adversely the useflness of this program ad at ir"aso ~p""~:
an affectin safety. A number of existing determine whether any of the identified progms I"sess the adequacy of candidates should be pursued further rra pnrfo Iwpppresent regulations. However, these a rulemaking.
ooprogams am t specifically designed As par of the program. the NRC will to weed out existing regulations or solicit suggestions from the regulated NUCLEAR REGULATORY latorytequimments which do not industry as to candidau requirement COMMISSION reduce risk aa~ifirAntly. Irutlly. this that might be eliminated or modified to program Ir designed to ti) improve tha eflavumen and the 10 CFR Part 60 systmaticaly sce an current effieny oi the regulatory program The regulatory requirants associated with NRC will alab conider any other pubfic Pubke Noae of Avail ty of 10 CFR Part So and to assess the comments received. Al suggestions will Progam Pin to Review EffecUarm imporesn of elected requirements be evaesated by the staff, but none wil of LWR Regutery RequemIn t based fi n their cnibution to be cidered as petitions for LkIM9 Rs assuring that nuclear powe: plants am rulemaking or sa faaial comments that Anovet Nc e
ty safely designed. constrcted, and requiu ltpoosr.
Any petitions for operated siid second on their impact on rulemtaking must be submitted as COmmsson.
lcenses. applicant. and NRC resoiireu directed in I 2,882 of 10 CyR part 2 o AcTow Notice of availability.
and (21 identify and propose appropriate the Comaussiom regulations suAmuAy The NRC staff intends to modifications to eliminate duplication.
Any sugges would be welcomed initiate a review of the risk importance requrent d tr fcsaab and shoud be sent to Dr. A.
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at Washington DC. this ftho day c Light Water Reactors (LWR). This N
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reduced subrmntlly by the Initially. this progrm will systematically assess the risk importance of selected current safety mains or conservatisms which regulations in 10 CFR Part so and related can be reduced without measurably regulatory requirements. The NRC staff increasing the level of risk. In suob cases is seeking public ommt on mheodificado could produce a significant Program Plan prepared by the tanf to safety benefit sice the attention and describe the review progmr.
of lcenses. applicant& and
- A w A copy of the Program Plan is the NRC that an now direc to these available for public inspection and area could be redirected to other areas copying in the NRC Public Document of poster safety significance.
Room. 1717 H Street NW. Washington.
The initial work, to be completed in DC. Copies may also be obtained by FY 1W& will Inlude a sivey of writing to Dr. Anthony Tse at the regulatory requirements associated with address listed below.
10 CR Par 50 to categorize them PO pea NM WPOWUTOM eOMCr.
according to their relative safety Dr. Anthony N. Tse. Regulatory Analysis significance. In a parallel effort. several and Materials Risk Branch. Division of requirements that appear to be good Risk Analysis and Operations, Office of candidates for modification or Nuclear Regulatory Research. U.S.
elimination w.ll be evaluated in detail to Nuclear Regulatory Commission.
Washington. DC 20555; telephone: (301) 1 liitlude (1) the Cerdric Ise and acaac 443-7902.
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REVIEW OF REGULATORY REQUIREMENTS FOR LIGHT WATER REACTORS BACKGROUND The NRC's Policy and Planning Guidance for 1984 (NUREG-0885, Issue 3) states that "existing regulatory requirements that have a marginal importance to safety should be eliminated." Other statements in the same document, as well as several initiatives undertaken in recent years, indicate the NRC's commit ment to the goal of improving regulation of the nuclear industry, in order to ensure that
- requirements imposed on the regulated industry contribute significantly to the health and safety of the public
- unnecessary regulatory burdens are avoided
- NRC and licensee resources are utilized in a manner which effectively and efficiently achieves protection of the public health and safety.
The NRC recently initiated a program to implement the policy and planning guidance quoted above. Pacific Northwest Laboratory (PNL) is providing tech nical assistance to the NRC staff in conducting this program. PNL's work in the first phase of the program consists of two tasks. In the first task, existing light water reactor regulatory requirements will be screened to iden tify potential candidates for elimination, or, if appropriate, modification.
The bases for screening the requirements will include their importance to risk, the burdens they impose on industry, the resources required for the NRC to license and inspect against them, and other relevant factors. In the second task, PNL will conduct comprehensive evaluations of selected regulatory requirements that may warrant elimination or modification. Cost-benefit assessments of the consequences of changing or eliminating the requirements will form an important part of these evaluations; public risk, industry burdens (including costs and occupational exposure), and NRC resource requirements will be among the factors considered in the cost-benefit assessments.
As part of the first task, i.e., screening the existing requirements to iden tify candidates for elimination or modification, PNL will conduct a series of interviews to obtain the views of various parties* for example, utilities, reactor vendors, architect-engineers, contractors, and NRC staff.
The follow ing paragraphs give a brief sketch of the expected scope of the interviews and the topics that will be discussed.
SOOPF OF THE INTERVIFWS In the first phase of the program, the scope of the review and screening is limited to regulatory requirements and guidance associated with 10 CFR Part
- 50. However, within this boundary, the scope is broad and may include any existing requirement or guidance, for example, regulations, regulatory guides,
-2 technical specifications, standard review plan sections, branch technical positions, and codes and standards.
The idea of reexamining existing regulatory requirements is not news of course, nor is it unique to the nuclear industry. In fact, a wide variety of sugges tions have been made along these lines over the years. Among the many examples that could be cited, three are discussed briefly for illustrative purposes.
Technical Specifications. The possibility of streamlining and optimizing tech specs is of considerable current interest and is the subject of several ongoing studies by the industry and the NRC. Possible modifications under study include surveillance intervals, action statements that may require shut downs unnecessarily, allowable times for equipment to be inoperable, and definitions of operability.
Extreme Loads in Design. There has been much recent interest in the role of extreme loads in design.
The highly conservative nature of some of the assumptions associated with the use of these loads in the design process has been noted, along with the resulting cost impact. This topic has been under study for some time and revisions of the design bases are under consideration.
Source Terms.
In the last few years# there has been extensive research aimed at reassessing the source terms for reactor accident consequence analyses.
This work is nearing completion and its implications for the existing regu---
latory structure are being discussed. Some observers have suggested, for example, that changes in current emergency planning requirements should be considered.
During the interviews, PNL staff will be interested in identifying other regulatory requirements, guidance, or areas of regulation that may be suitable candidates for reexamination and possible elimination or modification. In some instances, the suggested candidates for reexamination may already be the subject of ongoing studies, as is the case for the examples mentioned above. In other instances, the suggested candidates may not currently be under consideration in any formal program. It is hoped that candidates of both kinds will be identified.
It is also hoped that the suggestions will cover a broad spectrum of regulatory requirements, including those related to design, construction, and operations. Some observers maintain that most of the good ideas for regulatory improvement have already been suggested and are already being pursued. Based on our previous work with industry, PNL staff believe that this is unlikely and that many possibilities are not currently being pursued.
CRITERIA FOR IDENTIFYING CANDIDATES FOR REEXAMINATION The basic goal of the interviews is to obtain a broad spectrum of constructive suggestions for improving regulation of the nuclear industry by eliminating or appropriately modifying certain regulatory requirements. To assist in identifying suitable candidates for reexamination, it may be useful to consider briefly some tentative criteria. These criteria may be helpful in focusing the search for suitable candidates.
Rijk. Regulatory requirements that have negligible impact on risk may be potential candidates for reexamination. In fact, some observers have raised
-3 the possibility that certain requirements may actually be counter-productive from the standpoint of risk. It should be stressed that the concept of risk has multiple dimensions, including, for example, offsite radiation exposure, core melt, core damage, challenges to safety systems, defense-in-depth, and so on.
Occupational Exposure.
Certain requirements may be particularly burdensome from the viewpoint of occupational exposure to radiation. If they also con tribute negligibly to the protection of the public health and safety, then they may be suitable candidates for reexamination.
Industry Costs. Certain requirements may have particularly adverse economic impacts. If they also make only a negligible contribution to the protection of the public health and safety, they may be suitable candidates for reexami nation.
NRC Costs.
Some requirements result in especially high demands on NRC resources for licensing and/or inspection. If they also make a negligible contribution to the protection of the public health and safety, they may be suitable candidates for reexamination.
Regulatory Stability. The predictability and stability of the regulatory process are important considerations. Certain requirements may have particu larly negative impacts from this standpoint, while contributing only negligb4y to the protection of the public health and safety, and thus may be suitable candidates for reexamination.
Improvements in Knowledge. As a result of operational experience, technical progress, research findings, or other developments, certain requirements may now be ripe for reassessment. PNL staff believe that this is a particularly useful criterion for identifying promising candidates for reexamination.
Duplication.
Regulatory requirements may In some cases duplicate or overlap other requirements. Such requirements may be suitable candidates for reexam ination to eliminate duplication.
These criteria are intended only to assist in identifying potential candidates' for reexamination and possible elimination or modification. Recommendations on whether to eliminate or modify certain regulatory requirements will be formulated by the NRC staff at a later time and would be based on comprehensive evaluations of the consequences of such regulatory changes. Developing a list of potential candidates is the first step in the process.
PLANNED FOLLOW-UP ACTIONS After all the interviews are completed# PNL will compile the suggestions and prepare a summary of them. This summary of the suggestions along with a brief questionnaire will then be sent to the organizations participating in the interviews. The purpose of this step is to
- provide feedback to the participating organizations,
- confirm the findings of the interviews,
-4
- obtain (through the questionnaire) an approximate, Judgmental evaluation of the costs and benefits of eliminating or modifying the requirements,
- seek additional suggestions of requirements that may be candidates for reexamination but were not covered in the interviews.
PNL plans to maintain contact with the participating organizations, keeping them informed as the work proceeds.