NRC-90-0181, Comment Supporting Draft Policy Statement on Possible Safety Impacts of Economic Performance Incentives

Comment Supporting Draft Policy Statement on Possible Safety Impacts of Economic Performance Incentives

ML20024G006
Person / Time
Site:	Fermi
Issue date:	12/10/1990
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-90-0181, CON-NRC-90-181, FRN-55FR43231, RULE-PR-MISC 55FR43231-00029, 55FR43231-29, MISC-90-9, NUDOCS 9012270230
Download: ML20024G006 (1)

Text

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FQ uGCm.Gj(. "f 9We Decenber 10, 1990 NIC-90-0181 Secretary .

U. S. Nuclear Regulatory Commission Attn Docketing and Service Branch Washington, D. C. 20555

References:

1) Fermi 2 NIC License No. 50-341 NIC Docket No. NPF-43

2) . Federal Register Vol. 55, No. 208, FR Doc. 90-25376, dated October 26, 1990

Subject:

Draft Policy Statment on Possible Safety Inprts of Economic Pfrfprnm)se In ntives Detroit Edison has reviewed the Riclear Regulatory Cmmission draft policy statement on possible safety inpmts of econmic performance incentives and offers the following comnents. ,

Detroit Edison agrees the NIC should be concernM over prograns that-use NIC generated performance ratings and performance indicators.

Such use of- NIC ratings are not appropriate and places even greater attention on the nunerical ratings than alreMy exists. We agree with these portions of the draft policy statment that address this. issue, but believe the language should nore strongly state that SALP ratings

and performance indicators should not be used in performance incentive prograns.

Since the NIC's purpose is to regulate cafety and not to specifically pronote econmic inprovenents in power plant-operation, Detroit Edison believes. that for the NFC to encourage the establishnent of certain types of incentive prograns is inappropriate. By discussing

" desirable plans", the policy can be interpretd as endorsing perfornance incentive prograns that contain features discussed as desirable. The policy should discuss uMesirable features and acceptable features of performance prograns in regard to their potential effects on plant safety but should not eMorse particular types of incentives. For the benefit of state regulators who may be less informed than licensees on nuclear safety note detail on unacceptable features and why they are unacceptable would be helpful.

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Secretary

,i Decenber 10, 1990-NIC-90-0181 Pge 2 '

Detroit Edison acknowle3ges the NIC's concern that econmic perfornance incentive program might adversely.inpact plant safety.

Ilowever,' nuclear power plant safety is such a pervasive part of plant nanagenent and operation decision making that we believe it extrenely unlikely- that the existence of a well designed, realistic incentive would result in.a nuclear power plant being operated unsafely.

Detroit Edison agrees with the draft policy statement's characterization of programs having performance neasured over short tine intervals as being. undesirable. Prograns nes3 to cover a period of years to allow for inglenentation of major long term inprovenents without penalization. A three to five year period is.also necessary to handle- the differences in cycle lengths between plants in the conparison base.

In conclusion, Detroit Edison agrees with the rajority of the draft policy statenent. . Econmic perforrrance incentive programs do not necessarily adversely affect plant safety. Some incentives can cause concern, other program have no a3 verse inpact on safety. . Program that do not cause concern should be considered acceptable, but not encouraged by the Naclear Regulatory Camission. . The NIC should continue, to monitor incentive prograns and comnunicate informally with the licensees and state agencies on such program.

Yours truly, cw cc:- - NWAIC

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