ML20006E319
| ML20006E319 | |
| Person / Time | |
|---|---|
| Issue date: | 01/30/1990 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| FRN-55FR29043, REF-10CFR9.7 AD04-1-029, AD4-1, AD4-1-29, NUDOCS 9002220642 | |
| Download: ML20006E319 (97) | |
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ll Attached are copies of a Comissicn meeting transcript and related meeting 4
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NEALR.GROSSANDC0.,INC.
COURT REPORTERS AND TRANSCRIBERS 1323 Rhode Island Avenue, Northwest Washington, D.C.
20005 (202) 234-4433 4
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DISCLAIMER.
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b This is an unofficial transcript of a meeting of f
the : United' States Nuclear-Regulatory Commission he'1d on January 30, 1990, in the Commission's office at One White Flint.~ North, Rockville, Maryland.
,The meeting was i
open to public attendance and observation.
This transcript has not been - reviewed,. corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal' record.of decision of l
the - matters discussed.
. Expressions of opinion in this transcript do not necessarily reflect final determination or-beliefs.
No pleading or.other paper may be. filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
-t e'-
I NEAL R. GROSS court REPORTERS AND TRANSCRISERS 1323 RHoOf ISLAND AVEMUE, N.W.
(202) 234-4433 WASHINGTON. O.C.
20005 (202) 232-6600
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. UNITED-STATES OF AMERICA NUCLEAR' REGULATORY COMMISSION-N 3
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BRIEFING ON. STATUS OF PROPOSED RULE ON LICENSE RENEWAL PUBLIC MEETING-3 Nuclear Regulatory Commission One White-Flint North Rockville, Maryland a
Tuesday,' January 30, 1990 v
The Commission met in open session, pursuant L
to notice, at 2:00 p.m.,
Kenneth M.
Carr, Chairman,-
Lj presiding.
L COMMISSIONERS PRESENT:
[
KENNETH M.
CARR, Chairman of the Commis'sion THOMAS M.
ROBERTS, Commissioner
'KENNETH C.
ROGERS, Commissioner JAMES R.
CURTISS, Commissioner FORREST J.
REMICK, Commissioner i
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
(202) M WASHINGTON. O.C. 20005 (202) 232 6
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L STAFF SEATED AT: THE' COMMISSION TABLE:
r 4
-SAMUEL J.
CHILK,' Secretary WILLIAM C.
PARLER,-General Counsel JAMES-TAYLOR, Executive Director for Operations ERIC BECKJORD, Director, Office of Research DR. THOMAS MURLEY, Director, Office-of Nuclear Reactor Regulation
'DR. WARREN MINNERS, Deputy Director, RES/DS'IR i
DONALD CLEARY, Senior Task Manager, RPSIB,-RES WILLIAM TRAVERS,~ Chief, Emergency Prep.-Branch, NRR t
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NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE N W.
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2:00 p.m.
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'3 CHAIRMAN CARR:
Good afternoon, ladies and "j
4 gentlemen.
5 The purpose of today's meeting -is' f or the
- (
6 NRC staff to brief the Commission on the status of 7
rulemaking on license renewal.
The Commission was-8 l'ast briefed on, the subject of license' renewal 9
rulemaking on June 22nd, 1989.
In October of 1989, 10 the Commission agreed to hold a public workshop to-l 11 discuss the NRC staff's preliminary, regulatory 12 philosophy, a conceptual license renewal rule and' a schedule.
14
- Today, the staff plans to brief the 15 Commission on the comments provided at the workshop 16 and discuss a proposed course of action and schedule 17 for license renewal activities.
I understand that 18' comments received during and subsequent to the 19 workshop indicate general agreement with the staff's 20 regulatory philosophy and approach to license renewal.
21 During the meeting,. I would ask staff to e
22 focus on those areas where there are divergent views 23 and explain the Jasis for the staff's position on 24 these issues.
25 Copies of the slide presentation and the NEAL R. GROSS l
COURT REPORTERS AND TRANSCRIBERS 1323 HHODE ISLAND AVENUE, N W (202) 234 4633 WASHINGTON, D C. 20005 902) 232-6600
7
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s ta f f _'s
- paper,
SECY-90-021, are available at the 2
entrance-to:the meeting room.
3 Do-my fellow Commissioners-have any opening 0
4 comments?
5 If not, Mr. Taylor,-please proceed.
6 MR.. TAYLOR:
Good afternoon.
With me'at'the j
7 table, starting from my far right, from the Office of j
8
- Research, Don Cleary, Warren Minners, and the P
9 Director, Eric Beckjord.
To my left, Tom Murley and 10 Bill Travers from the Office of NRR.
'f 11-The regulatory approach-that the staff j
12 proposes for license renewal is founded on two key 13 principles.
The first principle is that-the current 14 licensing basis at a specific reactor provides and L
15 maintains a level of safety for operation during the-i l
16
-initial term, which is sufficient to provide adequate 17
-assurance of public - health and : saf ety, and that.the 18 same level of safety is also adequate ~ for continued-19 operation during any renewal period.
D 20 The second,:and equally important, principle-21 is that any license renewal policy must provide l
l L
22
' assurance that the level of safety provided by-a 23 nuclear power plant's current licensing basis will not 24 degrade during the renewal period.
25 With those two principles, I'll now turn the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W-(202) 234 4433 WASHINGTON. O C. 20006 (202) 232-6600 I
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- 1-meeting =. over to Eric' Beckjord f rom, the ' staf f for.
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2 presentation.
4 3
MR. BECKJORD:
Thank you.
4-Mr.
Ch' airman, Commissioners, we're 5
' presenting to you today the-report on the license 6
renewal workshop of November 13th and 14th ' of last
~
7 year and the proposed revision to the program plan and 8
schedule for rulemaking.
The full report is included 9
in the Commission paper, SECY-90-021, dated January-10 17th,.1990.
11 Mr.
Taylor has already stated the basic i
12 approach.
-I'll go on and say that the workshop was-
-j i
13 attended by more than 200 representatives of industry 14 and we received their views on the many aspects of I
L
- 15 this important endeavor.
16 We're recommending changes in the program 17 plan as a result of what we heard at that meeting.
We 18 are accepting some of the positions suggested by.
L 19-industry representatives and standing firm on others.
20 The program plan is a better one for having held that l-
. 21
- meeting, 22 The schedule of the program is tight.
The o
23-staff is resource limited for this activity and faces 24 a considerable challenge to meet the proposed i
I 25 schedule.
We intend to do everything reasonably NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W.
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'possible'to' meet that schedule.
We do not'have much!
-2
. margin to respond to upsets or additional requirements
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.beyond what we've described in the paper.
4 With : that ', I.think we're ready.to proceed.
5-Mr. Minners?
6 DOCTOR - MINNERS :
(Slide) Could I have the s
7 second slide, please?
8' I think the objective, Eric has already 9
stated it.
10 (Slide)-
And on the third slide,.this lists
- 11 the topics to be discussed, to go over these subjects 12 and we'll end up with the important part of it, which 13 is the program plan and schedule that 'the staff now 14-proposes to follow.
15-(Slide)
On the fourth slide is a general
. outline of the workshop ' which was noticed in the 17 Federal Register in October 13th and it's Enclosure 1 g
18 to the Commission paper.
'k'he agenda of the workshop 19.
focused on aging and that was the subject of the
'20 discussions.
But also included was a conceptual rule, 1
- 21 a previous version than the'one that's included in the 22-Commission paper.
That was discussed also at the-
)
23 workshop.
24 The workshop sessions are described in l-25 to the paper and it was held on November NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W lf (202) 23M33 WASHINGTON D.C. 20005 (202) 232 6 l
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1 13th.
As I said,= focused on' aging and ito was a 2
. cooperative exercise-by.NRR and Research and OGC, and r,"
3
'they were' generally co-session leaders or co-leaders i
4-of each session as appropriate.
The co-leaders 5
-developed sets of questions which were put into a 6
packet-and distributed to attendees and then these
(
7 wera used during.-'each session to lead people and' kind s
8 of guide the discussions.
9 Three hundred people were invited to the 10 workshop.
About 200 attended.
They, of course, were r
11 mostly industry people f rom NUMARC,
the utilities, 12 nuclear steam supply system vendors,-
13-architect / engineers, lawyers to the industry,.
14 consultants.
-We, of course, had NRC staf f there.
l 15L There were some NRC contractors there because they're
. 16 doing some work at license renewal for us.
We-had a 17 public interest group, the Nuclear Inf ormation-and 18 Resources Group.
We had another federal agency., DOE 19 attended, and people from four states attended.
The-l l
20 press was represented and we had one investment 21 counselor.
1.
22 There was a transcript of the meeting taken 1
23'
- and, in addition to that, 12 written comments were 24-submitted by various attendees.
These are being 25 reviewed and a report is being developed that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W (202)234.4433 WASHINGTON. 0.C. 20005 (202) 232 4600 O
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1-summarizes the workshop.
And' the staff will also g
2 produce a'second report which will give' the staff
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responses to each of these summarized comments.
These i
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reports will be part of the package.that 's submitted j
5 along with the rule when it's presented to the r
6 Commission and put out'for public comment.
7-(Slide)
May I have.the fif th slide,- please?:
-f
. the many comments that were given at the
'8 Of 9
workshop, we believe' at this time there are eight -
10 major issues which I'd like to discuss.
They are 11' discussed in more detail in Enclosure 3 to the-paper.
12 (Slide)
The first issue-is on slide 6 and 13 it's what we call the generic environmental document.
14 which is~the critical path in the schedule.
Both the 15 technical work required to do the document and the 16-procedural aspects of doing things at certain times 17 makes up the critical path.
18 COMMISSIONER REMICK:
Excuse me, Warren.
Is L
19 there any significance to the use of the word 20
" document" versus " report"?
One usually thinks of'an i
21 environmental report and I see this is environmental-22 document.
Any significance attributable to that?
23 DOCTOR MINNERS:
I'm not a big man on 24 environmental law, but I understand environmental 25-report is usually reserved for the report that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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.1 licensee produces > in. his plant.
We call this. a-
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document because we don't know whether to call it an-g ':
3 assessment or an impact statement or maybe it will 4
-just be some kind of a document that 's-ref erenced'.
'I' 5
guess its legal status is not entirely settled at this 6
time _how we're going to use it.-
So, we've tried to 7
give. it a-kind of amorphous name that doesn't mean-8 anything at the moment.
9 COMMISSIONER REMICK:
Is this the first-10 we've used that terminology?
Just curiosity.
11 MR.
PARLER:
As f ar.as I-know.
The l
,12 explanation that Mr. Minners gave is essentially.
13 correct, at least as I understand it.
It isn't clear i
1 4
14 yet whether.an assessment will do the job or whether 15-an environmental impact statement would be ' required.
16
'If you call' something an environmental impact 17-statement, there's an-established routine that you-18 have to go through.
So, the approach here is to find'
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19 out a little bit more what the Agency would have.to j!
20 have to do the requisite job to comply with NEPA and 21-then proceed.
It's kind of like a -- so, it's being~
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22 used for that purpose.
1
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-23 COMMISSIONER REMICK:
So, it's 24 characteristics are more like an environmental impact 25 statement or assessment versus an environmental repor_t NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) N WASHINGTON, O C. 20005 (202) 232 6000 t
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-thatJa licensee:might' submit?.
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~MR; PARLER: lThat.'s true.
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-3' COMMISSIONER REMICK:
I see.. Okay.
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DOCTOR MINNERS:
We're writing the.. document:
4 b
.is what label: to put on the 5
and the only question 6
front page.
s 7
Since it's.the critical path, we were'trying-
'8 to find some way of speeding'up the proceedings.
In 9.
the previous SECY. paper,89-275, we presented Option 10 2, which decoupled the license renewal rulemaking from 11 the : environmental rulemaking.
That's what we're j
12 proposing to do now.
So, what.we intend to do is to.
1 13 work.two separate paths.
One will be a Part 54,
14 Rulemaking which will supplement the current 5051' rule-15 f or. license renewal, and provide standards: and 16 procedures for. license renewal and applicants.
There-17 will also be some conforming changes-to 2.109, 50.109 18 and 51.20.
This -rulemaking will be supported by an 19 environmental assessment which is essentially done.at 20 this time, and the objective is to have this rule out-21' in May. of '91 so that it will be in place before we 22 receive the first license renewal application from i
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23 Yankae-Rowe.
24
- Now, in parallel with that is the 25 environmental rulemaking.
This.will be supported by E
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NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS 1323 RHOOE ISLAND AVENUE. N W.
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- 1' this ? generic 'environmentali document.
The schedule---
y 4
2 the. limitations, first of all, we have to go out for='a
=J Federal -Register - notice with : a notice of intent and' e
4 follow some procedural things.-
Then just, as I say, 5
the. work to develop this document means that we can't' a
6.
get-it done until-April of
'92.
But that will be 7
before we issue the first license.
.l 8
The industry supports our goals in producing:
~ 9 the generic environmental document.
That is to try to 10 generically take care of as many environmental issues 11 as;possible in that document and not have to litigate 12.
them'in each' individual license renewal.
.13 But they want to have a license renewal rule 14 issued' before the first application is tendered in r
we're all agreed that that's
. 15 June of
'91.
So that 16 what we're going to try to do.
And as Eric. said, 17 that's a-tough schedule and'doesn't have much slack in 18_
it, but we're going to try to do it.
19 COMMISSIONER CURTISS:
Warren, two questions.
20-on the approach.
You've indicated that you haven ' t
,21 yet decided whether there'll be significant
= 22 environmental impacts in the Part 51 rulemaking.
L 23 Presumably what you're looking at now is an 24 environmental assessment-type review, even though you L
25 call it a GED here.
In proceeding down that path, are
[
NEAL R. GROSS IJ COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W (202) N WASHINGTON, D.C. 20005 (202) 232-6600
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'you, trom-the: standpoint.of~ issues like scoping of_the f
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EIS process, are you treating this as if it's an EIS
- 3 so_that if-you get to the stage where you find-that-4 significant impacts.will,.in fact,_ result, but in turn-
-5 require an ' EIS,
you will have done all those i.
.?
-6 procedural steps along the way?
7 DOCTOR MINNERS:
That's correct, yes.
8 COMMISSIONER-CURTISS:
Okay.
9 COMMISSIONER REMICK:
Warren,.I'm not sure I 10 understand why rulemaking is required for Part 51.
11 What in'51 needs to be revised?
12-DOCTOR MINNERS:
Well, Part 51-now requires j(.
13 an impact statement _ to be written.
We are changing-14
.the Part 51 to allow an environmental assessment to be 15
-made.
That 's' ' proper, if we _ can make that finding.
16 But-I think the bigger thing-is is that what we are-d 17 trying -- not so much-what has to be changed, is that
'18 -
we want to provide a generic rule-that takes care of-19-these issues and we' don't have to do it in individual 20 cases.
21-COMMISSIONER CURTISS:
I take it what you're 22 looking at is' an S type - table that would plug into 23 Part 51?
24 DOCTOR MINNERS:
Yes.
I (.
25' COMMISSIONER CURTISS:
The same kind of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.
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concept?
i 2
DOCTOR MINNERS:
That concept, yes.
3 (Slide) on slide 7, is a discussion of the 4
regulatory guides that will be in support.of 5
rulemaking.
These will be on; a - separate-schedule w
l 6
which will be not accelerated along wi~th the Part 54 g
7 rulemaking, and it whil be more on a schedule like the-8 Part 51 rulemaking, e",
9 We now are working on a regulatory-guide
-10 which will provide the format and content for license 11 renewal and applications.
The Commission should see a 12 draft of this. in December of
' 90 and then with 'a 13 review and approval process and comment period, that i
14 will allow it to be issued in April of
'92, about the 15 same time that Part 51 is finalized.
This delay is 16 necessary because you can't really write the format 17 and content' document until you know what the rule is 18 going to contain.
So, the rule's draft will be out in 19 June of '90 and so then we can really begin to write
.20 this reg guide.
.i i
21 Another very important guidance for license 22 renewal is a screening method.
This is to go through-V l
1 23 and determine which components are safety related, are 1
24 subject to degradation and need additponal programs to l
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25 assure that their degradation is not detrimental.
l NEAL R. GROSS I
COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2M 4433 WASHINGTON, D.C. 20005 (202) 232-6600 j
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This screening ' method report is '. being. developed - by L*
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2' NUMARC.
In fact, they submitted it last October. _Our F,
3-intent is to review it and issue an SER endorsing-it p
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'4 or' modifying it as necessary and then that will become
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5 the licensing guidance that applicants can use.
6 COMMISSIONER REMICK::
It seems to me that 7'
that particular-document could be subject to 8
challenge.
What are - you doing from'the staff's
.,i 9
standpoint to make _sure Lthat that's as thorough 10
' analysis a n d - c o n s i d e r a t i o'n as can be given so that 11 later challenges would not be successful to it?
i 12.
DOCTOR MINNERS:
Well, I think we're giving 1
13 it as good a technical review as we can and that would 14 be' documented in the SER.
I guess that's similar to 1
15 the way that we have done other topical reports and i
16 the way that we have done applications.
'And the 17 defense of the report, I guess, will have to be-from 18 the SER.
19:
COMMISSIONER REMICK:
How broad is that 20 review within the staff?
Do you have an internal peer how do you assure that you get l
21 committee of 22 adequate staff review of this?
i l
23 DOCTOR MINNERS:
Well, I think we're sending i
'24 it to all of the technical branches in both Research i
25' and in NRR and getting people's comments in that way.
l l
NEAL R. GROSS l-COURT REPORTERS AND TRANSCRIBERS t
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MR.
TRAVERS:
-I might justL. add that in 4
addition to that, we're also going to the _ ACRS for 5
review of each of these documents.
We're going to be 6
interacting with them in all' stages of'these reviews.
i
_7 COMMISSIONER ROGERS:
Excuse me.
That' i
8' report, is that the one that's entitled, " Methodology 9
to' Evaluate Plant Equipment?"
10 MR. TRAVERS: No, sir.
I o
11 COMMISSIONER ROGERS:
No?
12 COMMISSIONER-CURTISS:
Let me ask a related
-i
~ 13 procedural question on that.
If it -- as I understand 14 your intention, the bulk of the screening process will' 15 be set-forth in one of these reg. guides.
Does that, 16
.in turn, mean that the -- even subject to the scrutiny 17 that the technical staff gives the document, that the 1
18 decisions that are made on screening,-which would be a
'19 very critical part of the process, are, in turn, 20 subject to litigation of the proceeding, that it'd be 21 fair game for the proceeding?
'22 MR. PARLER:
I suppose since the magic word 23
" litigation" was mentioned, that I,
instead of Doctor 24 Minners, should answer the question or try to answer 25 the question.
I think that if the product of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoOE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON, D.C. 20005 (202) 232-6600
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s creeningD-e f f ort, as I understand-it, are supposed to i
2 be technical aids, degradation requirements in a new g
. :Those requirements, after they go through a 3-Part 54.
'4
-rulemaking proceeding, would not be subj ect. to.
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5 challenge ~ and litigation in an individual plant L
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renewal proceeding.
7 However, as you may recall, we have another-8 provision in our rules that provide for somebody to j
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try to challenge, and it's kind of difficult, an 10 existing regulation because of special circumstances, t
11~
I assume that the kind of background question that you.
'12 asked' might be the predicate for somebody to try and 13 show special circumstances and that theref ore the b
14 existing regulatory requirements were not adequate to 15 deal with the-special circumstances and therefore the-s 16 procedures in 275(a) should be evoked.
17 COMMISSIONER CURTISS:
Okay.
18-COMMISSIONER REMICK:
It wasn't clear to me, 19-however, that the screening methods would be in the-Il 20 rule.
Is that the intent?
i..
21-DOCTOR MINNERS:
A requirement to have a 22 screening method would be in the rule, but the details 23 of the screening method would be in this report.
24 COMMISSIONER REMICK:
The technical l.
25 requirements would be in the report and that's why I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 6600
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~ thought'that might -- if not thoroughly done, it might o
2 be subject to challenge at a later date.-
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_3 COMMISSIONER CUF.TISS: ~ I take it: it would be 4
subject to challenge.
5 DOCTOR MINNERS:
I would think so.
~
6 COMMISSIONER CURTISS:
If the requirement to-
,7
'have a screening process, which is a simple statement 8
that there shall be a screening pro. cess, is what the 9
rule c >ntains with the details of what the screening
-i 10 process entails set forth.in a reg. guide, I take it 11 while the rule itself cannot. be challenged except 12 under rare circumstances, that the actual process of 13' going-forward and applying the reg, guide for 14 screening to an individual plant would be fair game in 15.
the adjudicatory proceeding.
16 DOCTOR MINNERS:
Well, it certainly would be r
_17-part of tne. staff's technical review, whether we agree L
18 with their screening.
-i 19 COMMISSIONER CURTISS:
Okay.
20 DOCTOR MINNERS:
In addition to this report,
{'
H 21 the industry is developing ten other technical reports h
22-which discuss the aging management requirements for 23 other components, like the vessel, the containment, 24 things like that, j-25 We have received two of these already and we 1-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l
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.18 n
1 are - scheduled to have them all by August ' of
'90.
2 That's a recent revision of-the industry schedule and 3
-we're working on a schedule to review these and we're 4
going'to have a meeting next week to try to set that 5
schedule on the review of the reports which will then-L 6'
be used'in license applications and can be referenced I
7 by applicants as the ' way that they're going to do 8
their aging management, i
9 COMMISSIONER REMICK:
Excuse me.
Go ahead, t.u 10 CHAIRMAN CARR:
I notice you shif ted the 11 responsibility for those from Research to NRR.
Can 12
.you --
13 DOCTOR MINNERS: 'The review of those?
14 CHAIRMAN CARR:
Yes.
15 DOCTOR MINNERS:
Yes, sir.
16 CHAIRMAN CARR:
Why did you see fit to do 17 that?
18 DOCTOR MINNERS:
Well, I'm not sure of all 19 the reasons.
I think.that NRR has both the' technical 20 expertise-and probably a closer perspective on i
l 21 licensing requirements than Research does.
I don't 3*.
22 know if NRR wants to make a comment on --
23 CHAIRMAN CARR:
Well, am I wrong?
Is there 24 not Research back-up required to make those figures?
6 I
25 DOCTOR MINNERS:
Research is -- NRR is the NEAL R. GROSS l'
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lead'in=that and Research'is participating in it.
We 2'
are giving them our'. technical review, yes.-
But the 3
4 CHAIRMAN CARR:
I guess my concern is that 5
we get enough-interaction in there that we don't miss 6
our dates of who's waiting-on.whom, you know.
I know 7
if Research has got both ends of the ball, I can~ point i
8 to him.
But if I start to beat on him and'he says,
~9 "Research is holding me up," I'm going to worry.
1 10 MR. TAYLOR:
They're both staff.
We'11 work a
11 on it.
12 DOCTOR MURLEY:
Typically, NRR is the 13 responsible office for issuing SERs.
Of course
-14 we've --
15 CHAIRMAN ~ CARR:
But. the one up 'above you 16 won't be primarily responsible for it, right?
17 DOCTOR MURLEY:
The Guide on Format and 18.
Content?
19 CHAIRMAN CARR:
No, the screening report.
20' It was my understanding you're only on the ten at the
-21 bottom.
Is that right?
22 DOCTOR MURLEY:
No.
23 CHAIRMAN CARR:
NRR's got all of them?
4 24-DOCTOR MINNERS:
All of the industry reports 25 are --
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
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CHAIRMAN CARR:
Okay.
2 MR.
BECKJORD:
Ten reports plus the e
3 screening.
4-DOCTOR MINNERS:-
Research is doing the. reg.
5-guide'on format and content.
6 COMMISSIONER ROGERS:
Just.before you leave 7
that topic, are there how do those. topics - get
?
L 8
decided upon that those reports are being written?
9 How did that list get generated and do you expect any.
10 additions to that list?
11 DOCTOR MINNERS:
Well,-I-think that's-one of'
,a e
12 the things that we have to decide and whether there' 13 should be additions to the list.
People have to-14 decide that we've covered al1 ~ of the important 15 components and issues.
16 COMMISSIONER ROGERS:
Is this an industry 17 initiative to begin with --
- l.
18 DOCTOR MINNERS:
Yes, it was.
19 COMMISSIONER ROGERS:
-- and offered to 20 produce the list and --
t 21 DOCTOR MINNERS:
Yes, sir.
~
22 COMMISSIONER ROGERS:
So we're taking - them 23 as they come in?
I'm just a little unclear as to what 24 the process is that's at work here.
25 MR. BOSNAK:
Commissioner Rogers, my name is i:
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W (202) 234-4433 WASHINGTON, D C. 20005 (202) 232 6600
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Bob..Bosnak of. Office of Research.
.2 CHAIRMAN CARh*
I' missed your nale.
3 MR. BOSNAK:
One of the things that we've 4
been talking about -- pardon me?
J 5
CHAIRMAN CARR:
I missed your name, i
1 6
MR.
BOSNAK:
It's Bob Bosnak, Of fice of 3
7 Research.
p-0 8
Our Division has been responsible for the' 4
9 ANPR Program, the aging research program.
One of the 10 reasons why the Office of Research is involved is that-11' we've been doing and interacting with the contractors 12 performing the research on where thing: degrade, how 13 fast they degrade, what's important to look at.
So,
'i 1
14 those things are involved.
15 We.'ve talked with the industry'several times 16 abt n whether or not. the topics.that they have are the 9
17 right ones.-
You could cut.the area a different way 18 and look -- at things like fatigue, but they'.ve decided 19 to cover those in all of their reports.
So, there are-
- a
.i 20 a lot of different ways of looking at it.
We hope by
-l l
21 the time we're all through that everything will be D
Lf
-(
22 covered.
.l c:
23 COMMISSIONER ROGERS:
Well, but that just
]
e' y
24
- leaves me a-little uncomfortable.
Do ypu have to wait 25 until the end of the process to make that decision?
a i
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1 Do you have to get all the reports in to dacide
'p 2
whether you have an adequate collection or not?.
Isn't iL 3
it possible to reevaluate this as you go along --
4 MR. BOSNAK:
These are the critical areas.
5 I think we've identified those as being the critical i
6 areas.
So, on that, we're happy.
It's a question of 7
whether or not each of the reports will cover key 8
areas.
That we're not sure of until we see the 9
reports.
10 COMMISSIONER REMICK:
Before leaving this 11 area, I had two questions.
I had a concern related to i
12 Chairman Carr.
I shouldn't say concern, but an 13 observation, also noting that NRR was going to be i
14 doing this.
But I kind of leaned in favor of that I
i 15 because I think NRR is familiar with licensing 16 reviews.
But it does raise the questions where you 17 have two offices involved in the same thing and that's 18 coordination and management of that.
Have you l
19 considered anything like a task force or anything to 20 make sure that time schedules are met and people know 21 who is reviewing what at what time, since there are 22 two offices involved?
23 MR. BECKJORD:
Well, we have that.
Doctor 24 Speis is taking the lead on this and Bill Travers, I 25 believe, is going to be performing in that role for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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NRR.
I i'
2 COMMISSIONER REMICK:
They have the 3
authority from the EDO to --
l 4
MR. TAYLOR:
Yes.
F 5
COMMISSIONER REMICK:
knock heads and so 6
forth as necessary?
7 MR. TAYLOR:
I help.
8 COMMISSIONER REMICK:
All right.
Good.
9 Another question.
You indicated you 10 received two of these industry reperts.
Based on a t
1-11 preliminary evaluation, do you have any views on l
12 adequacy or thoroughness or anything that we should
[
e 13 know at this time?
14 DOCTOR MINNERS:
Well, I don't think there 15 are any fate. flaws in the reports.
I think the staff f
16 has come up with some very usual kind of comments.
17 That would be my impression.
i 18 Bob, do you have a different view?
19 MR. BOSNAK:
No.
I agree there are no fatal 20 flaws.
I think the things that we have to go back 21 on -- there's two that we've looked at.
One is a 22 containment and the other is a BWR vessel.
The 23 degradation mechanisms, we think, in both repor'ts are 24 very well covered.
Some of the criteria on which the 25 individual plants will have to take action are not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1373 RHODE (SLAND AVENUE, N W (202) 2M WASHINGTON.D.C 20005 (202) 232 6600 P
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well icovered and those are the things we have to I
2 interact with NUMARC on.
3 CHAIRMAN CARR:
Thank you.
l 4
DOCTOR MINNERS:
All of this licensing t
5 guidance here will be also supported by SRPs, which 6
will be used by the staff during the application 7
review to guide the staff on how to use this guidance.
8 (Slide)
Another subject which I think the I
9 Commission also has a great interest in is the use of 10 probablistic risk assessment in license renewal.
I 11 think everybody agrees that PRA is useful.
We believe 12 now that no PRA requirement specifically for license 13 renewal purposes will be required in the rule.
The.
r 14 basis for this is that the method for incorpor a ting 15 time dependent aging failure rates into a PRA is still 16 evolving, which makes these ' PRAs even more uncertain 17 than our snapshot PRAs.
Also, there are no criteria 18 that people have agreed to on how to use the results 19
'of the PRA, what components or systems would be 20 identified as being in need of attention.
21 But this does not mean that PRA won't be 22 around.
As you know, all of the licensees must do an 23 individual plant examination and that will be 24 available.
A later slide discusses severe accident r
25 closure.
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1 COMMISSIONER REMICK:
Excuse me.
I 2
certainly agree.
I don't see a need for a PRA 3
requirement list, but it seems to me if you did have a 4
PRA you could feed into that different estimates of 5
aging and see what importance that might have to 6
reliability of a system or to risk and so forth.
So, 7
it seems to me that,
- one, if you havt e PRA it 8
certainly might be useful to analyze the importance of 9
aging information.
10 MR. BECKJORD:
We will have the PRA through 11 the independent --
12 COMMISSIONER REMICK:
IPE, yes.
plant exa:r.in a t ion, which 13 MR. BECKJORD:
14 will be completed --
15 COMMISSIONER REMICK:
Yes.
16 MR. BECKJORD:
-- before this.
17 COMMISSIONER REMICK:
I just wanted to make 18 sure we didn't belittle PRA possibilities of providing 19 useful insight of aging.
20 DOCTOR MINNERS:
We believe it's useful, but 21 we believe it's a little too uncertain to have as a j
22 requirement.
23 COMMISSIONER REMICK:
Yes, I agree.
24 DOCTOR MINNERS:
(Slide)
On slide 9,
this 25 is the current licensing basis which Mr.
Taylor il NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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. Eric discussed.
The guiding principle i
1 discussed and o
2 here is that the current licensing basis, except for 3
age-related degradation concerns, is sufficient to 4
assure adequate protection in the renewal term as well 5
as in the current license.
6 At, I guess, a lot of the behest of OGC, we l
7 are now in a large effort to write up a demonstration t
8 that this is so, that the current licensing basis will r
9 continue to be adequate in the renewal term.
We 10 expect to have an extensive discussion in the Federal l
ll Register notice statement of considerations that 12 demonstrates this.
i 13 MR. PARLER:
May I make one comment, since 14 he said at the behest of OGC7 It seems like it's just 15 a needless -- I'm sure you didn't intend this -- but a p
16 needless legalism, a waste of scarce resources.
17 As I understand it, the objective here, of 18 course, is not only to have renewed plants which could 19 operate safely, et cetera, but to arrive at that 20 result without having the need to litigate unduly 21 specific either environmental issues or technical 22 issues in the individual plant life extensions.
In 23 order to reach that result, if somebody wants to 24 challenge it, you have to have something better than 25 simply a statement that the staff believes that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON. O C. 20005 (2c;) 232-6600
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iP l.
1 current licensing basis is adequate, period.
The 2
other side might say they don't believe that it is, 3
"Let's litigate it."
i 4
So, what the lawyers are trying to have done 5
is to have in the explanatory statement a rationale as t
6 to why the current licensing basis is adequate.
7 MR. TAYLOR:
The staff considers that good e
8 guidance too.
We intend to do that.
l-9 DOCTOR MINNERS:
No, I didn't mean to t
i 10 belittle the comment.
It was just that we didn't give 11 it the proper emphasis until it was brought to our t
12 attention.
l
- 13 MR. TAYLOR:
It was pointed out to us as a 14 fault.
We agree.
15 COMMISSIONER ROGERS:
Are you going to say 16 more about that or are you going to turn to something 17 else?
r 18 DOCTOR MINNERS:
Well, I was going to make 19 one more statement.
The current licensing basis, we 20 are going to have a requirement in the rule that there 21 be a description of the current licensing basis in the 22 application.
We believe this can be done mostly by b
23 reterence to things like the updated final safety 24 analysis report and we believe that this listing of 25 the current licensing basis in the application is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. D C. 20005 (202) 232-6600 4
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1 necessary so that the requirements of the current 2
license are identified clearly and can be carried 3
forward in the renewal term.
4 COMMISSIONER ROGERS:
I just the SECY j
5 left me a little question in my mind as to whether it E
6 was something I was not fully appreciating in that on 7
page 6 you stated, "The version of the conceptual rule 8
provided for the workshop required a description of 9
the current licensing basis in a license renewal 10 application and a staff determination that the basis 11 has been completely and accurately described."
12 And then -you later on said, "Now, staff 13 proposes that applicants describe the current 14 licensing basis in their application."
15 DOCTOR MINNERS:
Correct.
16 COMMISSIONER ROGERS:
And then you go on to 17 say that, " Staff now believes-that a determination of 18 completeness and accuracy is not necessary because 19 each license renewal applicant must perform a plant 20 evaluation."
21 So, I'm trying to understand how you're 22 going 't o judge t'he acceptability of the current 23 licensing basis statement if you don't apply some kind 24 of standards of completeness and accuracy and just how 25 you propose to deal with that.
Do you think that what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W 4
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you've included in the conceptual rule in the latest 2
version that you gave us that the Part 54.23 standards l
?
3
.for issuance of a renewed license in the conceptual 4
rule, do you think that's sufficient?
Is that what 5
you're going with now?
I'm trying to understand what 6
the difference is between looking for completeness and 7
accuracy in the description and what it is that you're 8
' going to look for.
j i
9 DOCTOR MINNERS:
- Well, I. think that's the l
10 big change from the previous version of the rule.
I 11 don't think that now we believe that the staff has to i
12 do a review of that licensing basis.
We expect the 13 applicant to provide. a complete and accurate 14 description of the licensing basis.
We believe that 15 that can be done and that in order to do his screening 16 procedure, the starting point is really his licensing 17 basis.
So he has to know what his starting point is.
18 So, we think that there will be a good review and t
19 evaluation of that licensing basis by the applicant 20 and it's not necessary for the staff to do that.
21 COMMISSIONER ROGERS:
Well, do you think i
22 there's going to be any question about what basis you 23 will find something acceptable and not acceptable, 1-
!~
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looking for?
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2 DOCTOR MINNERS:
Well, I think the rule does
]
3 define what should be submitted as part of the current L
4 licensing basis, if that's what you mean.
I think 5
that's a fairly good description of what is required.
t 6
COMMISSIONER ROGERS:
Well, it's really just
{
7 a question of completeness and accuracy, to what 8
extent you're going to make that judgment.
9 DOCTOR MINNERS:
As I say, the staff is not 10 going to do a review.
So, I don't think we have any 11 specific standards set forth in that, no.
12 DOCTOR MURLEY:
Except, Commissioner, we did 13 put the language in 54.15 in an attachment that describes T
14 what we expect to see in applications in terms of the 15 identification of the current licensing basis.
So, we 16 took out that - language and instead put in the draft i
17 rule what we expect to see.
i 18 COMMISSIONER CURTISS:
I guess I come at it-19 from a different angle.
I think it's a move in the 20 right direction from what you originally circulated.
21 As I underctand it, we're now going to require the 22 licensee to certify the current licensing basis in his l
p 23 application.
I take it that the principle here is 24 that it's not the current licensing basis that we're 25 concerned about litigating here.
We are assuming, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 HHODE ISLAND AVENUE N W.
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subject to the generic description in the statement of f
2 considerations, that the current licensing basis in t
3 fact provides adequate protection to public health and 4
safety.
5 The question I guess I have, coming at it 6
from a different. angle, is if that's true, why is it
[
i 7
that we need to require submission of all the 8
information, even by reference, if we don't intend to 9
examine those. questions?
To put it differently, with i
10 all that. inf ormation sitting in there in the 11 application, doesn't that, in effect, invite the 12 licensing board to ask why it's in there and, in turn, 13 ask whether it's accurate?
7 14 DOCTOR MINNERS:
Well, I think we probably 15 look at it and maybe this is a legal opinion I'm l
16 not qualified to give.
But if we're giving them 17 essentially a new license, and I understand that's the 18 legal theory behind it, I think the staff used it as 19 that you ought to have a good description of what the 1
e 20 licensing basis is t.o start out with.
I think that's l
l 1:
21 about the sum of it.
22 MR. PARLER:
And not to leave that basis to l'
23' one's imagination, to have the there are the old 24 FSARs, et cetera, that may have been issued 15 or 20 l
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'in' its application,. at least ref erence what it 2
believes the licensing basis is.
Il 3
COMMISSIONER CURTISS:
That leads though to 4
the point that Commissioner Rogers raised, and that is 5
how do you know that it's accurate and complete and 6
thorough and necessarily l'eads into a discussion, not 7
just from the staff's technical review, but in the' 8
proceeding itself, as to the adequacy of the current 9
licensing basis?
Isn't that the result of open,ing i
~
10 that door and asking for all that information to be 11 put on the table?
12 DOCTOR MINNERS:
Well, as I said, I think we 13 do have some assurance that it will be complete and 14 accurate, but we're leaving that assurance mainly-up t
15 to the licensee through his plant evaluation that he 16 has to do.
We're putting most of the responsibility Y
17 where we believe it should be, on the licensee.
18 CHAIRMAN CARR:
It's certainly not going to 19 be the same for every plant.
30' DOCTOR MINNERS:
No.
That's correct.
We'll 21 have 100 different licensing bases at least.
22 COMMISSIONER ROGERS:
- Well, I'm still 23 uncomfortable here because I don't know what you're 24 going to do with it.
Age you going to weigh it?
Are 25 you going to count mines?
It's there.
What will you NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234.4433 WASHINGTON, D.C. 20006 (202) 232 6000 1
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do with it?
I mean, you say you're, not going to 2
examine it.
What-will you do with it?
3 DOCTOR MINNERS:
I don't think it's what we 4
the - NRC do with it, Commissioner, that makes much 5
difference.
It's what the licensee does with it is 6
the important thing.
He's the one responsible for 7
safety.
I would presume he would look at his 8
licensing basis and be assured that he is meeting his 9
licensing basis and that when he goes further, that he 10 knows what his starting point is for this screening 11 method that he's going to do.
He has to have a 12 starting point someplace and he has to have the 13 licensing -- he has to gather this information anyway, 14 and all we're asking him is to do the administrative 15 task of making a list of it and sending it into us, 16 which we think is not much of a burden.
17 COMMISSIONER CURTISS:
I guess I presume 18 that he'll do that with that big room full of 19 documents that he's got, wherever he's got his 20 licensing basis.
When he submits the application,
-l 21 he'll go to that big room full of documents and use 22 that as the point of departure.
I presume we know l
23 what the licensing basis is for these plants.
24 Well, the question is, assuming they'll do 25 that, because it's a prudent and wise ching to do, and NEAL R. GROSS CoVRT REMTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W.
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assuming we know what the licensing basis is and that 2
this isn't for our benefit, what is the purpose of 3
then requiring that big room of documents to be 4
transported down here to the Commission?
F S
DOCTOR MINNERS:
Well, it's not going to be 6
the big room of documents.
It's only going to be a l
7 list of those documents that has to be transported.
8 COMMISSIONER CURTISS:
I understand that.
9 CHAIRMAN CARR:
I think it's just a contract 10 between the two parties at the timo that says, "This 11 is where we start it."
12 DOCTOR MURLEY:
If I may add, I think we 13 could, no doubt ourselves, reconstruct this licensing 14 basis for each plant, but it would take a lot of work, 15 When we say the current licensing basis, we mean not 16 just the FSAR, but all the commitments they've made to 17 us, all the small exemptions that they've gotten from 18 parts of regulations and so forth.
We want to make 19 sure, because some of these actions go back, as the 20 General Counsel said, 20 years or more.
We want to 21 make sure that we have the same understanding about 22 what's required of that plant right now that the 23 licensee does.
24 Now, we don't intend -- we're not committing 25 that we review every document, but we will look them NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoOE ISLAND AVENUE. N W (202).M WASHINGTON.OC 20006 (202) 232-6000 l
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over._ No question that we will look over to make sure 2
that we have the same understanding that the licensee 3
has of what's required.
4 COMMISSIONER ROGERS:
Well, does this mean E
5 that you'll I'm just trying to I'm not being
[
6 critical.
I'm just trying to understand what this 7
process is here that we're envisioning.
It sounds to 8
me as if you'll look over the list of documents to see 9
whether the list is complete.
Not whether the 10 contents of - the documents are complete, but whether 11 the list is complete.
Is that correct or not?
Lo you 12 intend to do that or not do it?
13 DOCTOR MURLEY:
My intention now is that we 14 would be doing some selective look into the documents 15 themselves, just to satisfy ourselves that what we 16 understand _the current licensing basis is the same as 17 they've described it.
18 COMMISSIONER ROGERS:
- Well, I've had some 19 experience in the past in which a licensee didn't 20 really know what its commitments were that it made and 21 had to go back and reconstruct those and found that it 22 had made some that the NRC didn't even know about at 23' the time.
And I just wonder how we're dealing with 24 that kind of thing.
Are we going to review the list 25 of topical the topical list, or the names of the NEAL R. GRCSS COURT REPORTERS AND *.MNSCRIBERS 1323 RHODE ISLAND AVENUE. N W g) m WASHINGTON, O C. 20005 (202) 232 4 600 i
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1 36 7
I 1
documents, see whether it's complete or not?
Are we L
2 just --
3 CHAIRMAN CARR:
You want the books at least 4
balanced.
5 COMMISSIONER ROGERS:
All I want to know is 6
what we're going to do first, and then I'll criticize 7
it later.
But I don't know, when we say we're not 8
going to examine that list for completeness, does that 9
mean we're not going to look at the comp.leteness of
-10 every document, or does it mean that we're not going 11 to look at the completeness of the list itself?
12 DOCTOR MURLEY:
Oh, we're going to look at 13 the completeness of the list, yes.
And for example, 14 it could very well be that we're familiar with the 15 latest update of the FSAR, so we could decide, well, 16 yes, we agree.
We've looked at that and we don't need 17
-to look at that.
But there could be some list of 18 commitments that they've made to us that our memory 19 may be a little foggy on.
We may-go in and look at 20 that in some detail to make sure that our records 21 agree with theirs in terms of what's --
22 COMMISSIONER ROGERS:
Well, that was what I 23 wanted to find out about, because I couldn't tell from 24 what was said whether we were going to look at the 25 completeness of that list or not.
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1 MR. TAYLOR:
The possibility does exist.
t I
2 There would be some commitment that he made that was 3
not executed and not incorporated, and then that would 4
certainly be a problem.
That would be an inadequacy i
5 in the current condition.
I mean, that's a
6 possibility, considering the numbers of modifications, l
7 changes, and commitments that have been made over the i
8 period of the current license, COMMISSIONER ROGERS.
Sure.
9 10 MR. TAYLOR:
-- recognize that.
And I think j
11 some of these would be a template.
That is, here is 12 the listing and there'd be a commonality of generic 13 issuances that people have committed to that we would.
v 14 expect to see across a whole series of licenses.
.On 15 exception, we may see something that has not been, and 16 you may call up and say, "Didn't you commit to that 17 bulletin of 1969 or '75 or something?"
And so, that 18 has those possibilities, but it's --
-19 COMMISSIONER CURTISS:
If we anticipate that 20 problem arising, that's probably a good thing to do 21 for all of our licensees, not just those that are 22 applying for plant life extension.
23 MR. TAYLOR:
I think we're going to learn 24 when we do this.
But it would be part of the i
25 gathering together to seek a renewal.
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1 COMMISSIONER CURTISS:
This provides a i
I 2
procedural opportunity to get that information,
)
i 3
undertake that kind of review.
What I was groping j
4 for, though, is what the nexus is between plant life 5
extension initiative and the process of going back and 6
actually evaluating whether everybody's complied with 7
the commitments that might be spread out in the 8
various documents, some of which we're familiar with 9
and some of which --
10 CHAIRMAN CARR:
Well, I think it's fair to 11 say that plants are scrambling right now to put this 12 thing together to figure out what their licensing 13 basis is.
14 COMMISSIONER REMICK:
It seems to me it 15 would be beneficial for the licensee and for the NRC 16 to know what the licensing basis is.
Has any thought 17 been given, though, to whether it should be a part of 18 the application or something independent of it?
I 19 think that was the point Jim was getting at.
20 COMMISSIONER CURTISS:
That's my point.
It the plant life extension 21 seems to me that by the 22 process, obviously, is a potentially useful vehicle 23 for doing a lot of things.
But I guess I wonder if we 24 are concerned about the problem of clearly identifying 25 where the commitments have been made and whether NEAL R. GROSS CoVRT REPORTERS ANO TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON. D C. 20005 (202) 232-6000
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they've been met.
That's a generic problem, unrelated 1
I r
2 to plant life extension, although plant life extension i
3 may provide a vehicle.
4 I think we need to consider in more 'etail d
5 just what the nexus is between the findings that we're t
I r
6 trying to make in. plant life extension; the point of 7
departure for those findings, which is the current 8
licensing basis; and the need to get these documents 9
either delivered or referenced in whatever the 10 licensee's submit.- That concern is compounded by what i
11 I think will be some proclivity on the - part of the 12 participants to the proceeding in the Board itself to-13 look at the application, which will include references 14 to the current licensing basis.
l 15 And where there may be questions that arise 4-16 in your mind, there may be questions that arise in the 17 Licensing Board's mind or in the mind of others.
And l
18 we may find ourself very quickly litigating questions 19 about the adequacy of the curr'ent lictnsing basis or 20 commitments made there.under, rather than focusing on l
l 21 what I think ought to be the principal focus of the 22 plant life extension, which are the technical 23 questions relating to age considerations.
24 MR. TAYLOR:
We understand that.
We'd like 25
.to avoid it.
Maybe as we proceed here --
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1 COMMISSIONER CURTISS:
Well,. think about' a j
2 way to do that between now and --
3 MR. TAYLOR:
And we're still dealing with 4
the concept, as you can-tell.
5 COMMISSIONER CURTISS:
That's all I have.
5 CHAIRMAN CARR:
Well, they're like the bank.
i f
((
7 They send us a statement.
We may want to balance it 8
before we say okay.
r s 9
MR. TAYLOR:
Before we open our account.
10 CHAIRMAN CARR:
That's right.
11 COMMISSIONER REMICK:
Before we leave the 12 subject, one last question.
Am I correct that ideally and if people updated their FSAR, 13 with tech specs 14 which I believe is annually if yoy had those two 15 documents, ideally you should have the licensing 16 basis, shouldn't you?
Is there anything shouldn't 17 commitments be in there, ideally?
c 18 DOCTOR MINNERS:
- Well, if they're at a 19 higher level, they would be.
But if you have some 20 very detailed commitment that you're going to have 21 some nut and bolt put in place, I mean, that might not 22 get in the FSAR or the tech spec.
23 COMMISSIONER REMICK:
So it takes more than 24 a --
i
~
25 MR. TAYLOR:
It takes more.
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DOCTOR MINNERS:
(Slide)
Can,we go on to h
2 slide 10?
3 This is the issue of severe accidents.
As I P
4 discussed, there will be individual plant b
5 examinations, but there is not now any requirement in f
l 6
the rule for having nevere accident closures 7
completed.
We consider severe accident closure to be l
8 part of the current licensing basis, and any results i
9 of the IPE will be dealt with in that context and that 10 will change the licensing basis so that at the time of 11 application severe accidents should be concluded.
But 12 that will not be a required action in tne rule.
f 13 However, we do intend to we expect the 14 IPE results to be either implemented or scheduled 15 before an application is tendered.
We intend to 16 emphasize that in the. statement of considerations.
17 COMMISSIONER CURTISS:
Will that be a 18 prerequisite for issuance of a plant life extension, 19 commitment to schedule?
20 DOCTOR MINNERS:
I guess I'll have to say 21 what I said before.
It's not a requirement, but it's 22 an expectation.
23 COMMISSIONER CURTISS:
I was confused about 24 the language, the difference between a standard and a 25 prerequisite that was used in the earlier draft.
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1 DOCTOR MINNERS:
Well, if it's not in the 2
rule, I guess we can't require it, if that's what you 3
mean by a prerequisite.
But I think NRR is going to 4
strongly urge people to have severe accidents closed 5
before we deal with their application.
And I think 6
the argument would be that if you don't have severe 7
accidents closed, you don't know what your licensing 8
basis is, so we don't know where we're starting from.
8 9
(Slide) on slide 11, one of the more 10 important things in this screening process, and the.
11 industry had some comments at the workshop that we had 12 not given adequate credit for existing programs in our 13 formulation of the rule.
So we have modified the rule 14 to give more credit for existing programs.
15 And the industry was also concerned that the 16 license renewal rule not become a de facto maintenance 17
- rule, and we agree with that.
That is a little 18 difficult to follow, but we are trying to follow that 19 path, but would note that a maintenance rule or reg 20 guide or some industry initiative would be very 21 helpful in license renewal to define maintenance 22 practices in the renewal term as well as in the 23 current term.
24 And the details of the screening process, as 25 I think we've discussed,- will be in this industry NEAL R. GROSS COURT REPORTERS AND TRANSCRIDEPS 1323 RHODE ISLAND AVENUE N W (202).M WASHINGTON, D C. 20005 (202) 232 6600
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screening report, which we intend to_ review and issue
'2 an SER on.
3 (Slide)
Slide 12 is-the perennial question 4
of backfit.
The industry comments at the workshop 5
were that they would like to have the backfit rule l_
6 apply to the renewal application.
And our advice from 7
OGC'is that the backfit rule is not applicable to the 8
application.
It's treated as kind of a new' license.
9 You start it off fresh.
And the backfit rule does not 10 apply.
Of course, after a renewal license is issued, 11 the backfit rule would apply if we want to put any 12 additional stuff on after the license was issued.
13 The staff does recognize a need to provide 14 guidance for the review of the license renewal 15 application, and we intend to have an SRP which_will 16 preclude reconsideration of the adequacy of the 17 current licensing basis during the license renewal 18 reviews.
19 (Slide)
Slide 13 --
20 CHAIRMAN CARR:
Before we leave that one, 21 let's give the OGC a chance to explain why he thinks 22 it shouldn't apply there.
23 MR. PARLER:
Well, the statement was that it L
24 does not apply to the application for the renewal.
25 The backfit does apply to the existing license which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS, 1323 RHODE (SLAND AVENUE. N W.
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1 would be renewed, and it does apply to the renewed 2
license after it is renewed, the backfit rule does.
3 The purpose of the backfit rule is to l
4 provide for regulatory' stability and a disciplined 5
"approachinchiangingcurrentrequirementsfromafloor
'6 which is deemed to provide adequate protection to the L
7 public health and safety.
If there is such a floor 8
which exists for a license that has been applied for j
9 to be renewed, it isn't entirely clear to me what that 10 existing floor is.
The floor is that we're going to 11 review the application, assuming that the current 12 licensing basis could be accepted.
And the addition 13 to that would be the age degradation requirements, and 14 it would seem to us that that's not a situation that 15 requires a backfit type analysis.
You're talking j
16 really about new requirements not changing existing 17 requirements.
That is explained --
18 CHAIRMAN CARR:
I guess I fail to see the 19 disadvantage of having it apply.
I l
20 MR.
PARLER:
- Well, if one wants to go 21 through the backfit type analysis, you would quickly 22-reach the conclusion from looking at what is ths key 23 first principle here, that is that the current 24
_ licensing basis, which we will explain someplace, is i'
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1 degradation requirements.
And presumably, we need i
2 those in order to ptovide adequate protection.
)
i
, 3 CHAIRMAN CARR:
Yes.
4 MR.
PARLER:
Under your theory, you apply 5
the backfit rule.
The backfit rule says that you 6
don't have to have a backfit analysis in order to t
7 demonstrate adequate protection.
So that's the end of i
8 it.
If you want to take that unnecessary detour, I l
9 assume that that is all right.
But I guess our i
10 suggestion, which is explained on page 7 of the paper j
11 in enclosure 3,
I believe, page 6,
is that you don't 12 need to do that.
13 CHAIRMAN CARR:
Okay.
14 COMMISSIONER REMICK:
A related question 15 comes to mind.
I realize that OGC. has decided that 16 this should be a new license or a renewal, not an.
17 extension or amendment, yet I believe in the case of 18 non-power reactors you have extended the expiration 19 date and therefore, I guess, is an amendment.
Now is 20 that because the non-power reactors are licensed under Section 104 of the Atomic Energy Act?
21 Part 104 22 What's the difference?
My understanding is non-power 23 have been done as an amendment.
24 MR.
PARLER:
The non-power reactors, the 25 statutory language between 104 and 103 differs, so we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. D C. 20005
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do have a legal analysis of that question prepared 2
which I would be glad to share with you and with your 3
staff.
4 COMMISSIONER REMICK:
But no simple answer 5
to whether non-power reactors -- the expiration date 6
was extended because they're under Section 104?
Is 7
that the reason?
Or is that in your analysis?
It's a 8
question of curiosity on my part.
9 HR. PARLER:
It's the renewal language in 10 the Statute that we're operating under here.
That',s I
11 what is the subject of our analysis.
12 COMMISSIONER REMICK:
I must admit I don't 13 understand, but I'll read the analysis, then I'll have 14 an answer.
15 MR. PARLER:
Well, it is rather difficult, 16 It seems, at least from my standpoint, if you are 17 implementing a statute that says that the Commission 18 may renew a license for a term, and the term may be an
-19 additiodal term up to 20 years by policy choice or 20 legally up to 40, to simply say that's an amendment to 21 that license, you're really giving the thing new life
{
22 for an additional term.
23 COMMISSIONER REMICK:
I don't differ with 24 that, but why wasn't the same determination for non-1 i
25 power reactors -- if I'm right, the way it was handled NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLA@ AVf NUE,N W (m) 234-4433 '
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1 there was an amendment by extending the expiration 2
date.
It seems to me to be an inconsistency.
3 MR. PARLER:
Because the statutory language 4
for the two different kind of reactors differ.
That's j
5 why.
6 COMMISSIONER REMICK:
Okay.
All right.
I 7
CHAIRMAN CARR:
Let's proceed.
8 DOCTOR MINNERS:
(Slide)
Slide 13 tries to 9
explain how we intend to apply this theory.
The way 10 we view it is that the renewed licensing basis will be 11 the sum of the current licensing basis or the part of 12 it that's not age-related, plus the age-related 13 licensing basis.
And our intent is that the current 14 licensing basis, the part that's not age-related, will 15 not be reopened as part of the review of the renewal 16 application.
And any changes to the current licensing 17 basis would be done as part of the current license, 18 and they would be done under the backfit rule.
19
- However, the age-related portion of the 20 renewed licensing basis, that is what we're going to 21 review during the application.
And that -- obviously, 22 we're going to have additional things, and that's what 23 these industry technical reports are supposed to 24 provide and the screening method is supposed to 25 identify.
But any of these additions will not be done NEAL R. GROSS COURT REPORT [RS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) N WASHINGTON. D C. 20005 (202) 232-60'O
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1 through'the backfit rule, because it does n : spply.
2 Therefore, once the renewed licenn ng basis 3
is established with these additional requirements for 4
age degradation, that can again only be changed under 5
the backfit ruling.
6 COMMISSIONER CURTISS:.
Warren, your second 7
bullet there indicates that the objective of'the age-8 related licensing basis is to maintain a current level 9
of safety throughout the renewal term.
10 DOCTOR MINNERS:
Yes, sir.
11 COMMISSIONER CURTISS:
Take an issue like 12 fatigue, where you may let's say at the point of 13 renewal you're at ten percent of the regulatory limit.
14 Clearly, on an issue like fatigue, your level of 15 safety at the time of renewal is ten percent of a 16 regulatory limit, but because of continued fatigue you 17 may in fact see a decline in safety, albeit within the 18 regulatory limit.
You'd be within the regulatory 19 limit over a period of 20 years.
20 Do you really mean "to maintain a current 21 level of safety," or are you talking about maintaining 22-the current licensing basis?
l 23 DOCTOR MINNERS:
It's really the current 24 licensing basis and an acceptable level of safety.
1 25 COMMISSIONER CURTISS:
Okay.
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1 CHAIRMAN CARR:
But you would put a license 2
condition in there if you saw in that 20 years they
[
}
3 were going to have to do something with some 4
component, wouldn't you?
5 MR. TAYLOR:
Yes.
6 DOCTOR MINNERS:
We could take some actions 7
to bring the level back up, yes.
t 8
MR.
TAYLOR:
You might _ have less if an l
.9 extension was for 20 years, but that component might 10 be good for ten.
11 COMMISSIONER CURTISS:
My question really 12 went to the current level of safety.
You're going to 13 have a current level of safety at the time that you
[
14 issue the application that in many respects may be --
3 15 DOCTOR MINNERS:
Acceptable level of safety 16 is the proper --
17 MR. TAYLOR:
Yes. You're point is well taken.
18 CHAIRMAN CARR:
Once you've said that, then if you apply the backfit rule through 19 I don't see 20 that period, you can require them to do anything if 21 you maintain it's an adequate level of safety item.
22 And the backfit rule you wouldn't have to go into.
23 DOCTOR MINNERS:
It's not an adequate level 24 of safety, it's an acceptable level, which may be i
25 higher than adequate.
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The curren, teensing basi's is generally 2
above a level of-adequate safety, and that's what we'
-i 3
are trying to maintain is the current licensing basis, i
- 4 CHAIRMAN CARR:
I've got some problems, I 5
- guess, with that statement that you -just made'.
6-Amplif y ' that a little, what we're regulating - to r
7 require.
l 8
DOCTOR HINNERS:
(Slide)
Well, I have a-9 back-up. slide number 1.
Pardon m e,- back-up slide 10 number 3.
.11 This is, hopefully, illustrative of what 12 we're talking about.
The upper jagged line is the 13 level of safety that the plant has.
The next
.c t
14 horizontal line is the current licensing = basis, which 15 sometimes we modify either up or down.
And below that 16 is the level of safety that is adequate.- The line is
^
17 jagged, because as you-do surveillances~, maintenance, 18 repair, replacements, the level of safety goes up or 19 down.
And even 'sometimes it could go above the 20 current licensing basis, and then we'd have to take 21 some action.
We may shut them down.
We may not shut 22 them down.
That's at our discretion.
i 23 Presumably you see out there where the upper 24 -
jagged line splits.
What we cre trying to do is keep 25 1t more or less where it was before.
And presumably, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W-(202) 234-4433 WASHINGTON, O C. 20005 (202) 232-6600 e
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a t xe 3
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,,7
- r.,
if.we didn't have these. additional measures to control
'2
~ degradation, it would slowly trend downward and go 3
below the current licensing basis and eventually.even 4'
go below the level of adequate.
1 1
5 So the intent of this chart or graph is to 6
try to show how we're trying to keep that ' current.
7 licensing basis or that current level of safety which 8
varies up and down about where it. is and above the.
9 current licensing basis, r
10 So we always have a margin.
Utility will 11 always keep a margin between its level of safety and 12 the. licensing basis,'so they don't risk limits on your 13 operation.
14 CHAIRMAN CARR:
Okay.
15 DOCTOR MINNERS:
And the way. we have 16 regulated in the past is that the current licensing 17 basis we have enhancements to safety which are above 18 what is necessary to maintain adequate protection.
So in I would say all licensing bases,
-19 there is some
'20 some margin between current licensing basis and a-21 adequate safety.
22 COMMISSIONER REMICK:
Is this a new thought?
23 CHAIRMAN CARR:
How did we get from adequate 24 to current licensing basis?
25 DOCTOR MINNERS:
Because we put some things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W.
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'l on which -. are -.not necessary for adequate protection,
[
2 but are enhancements which are cost-beneficial.
?
3 COMMISSIONER CURTISS:
Those are backfits, 4
in effect'.
Is that right?
5 DOCTOR MINNERS:
Or they could be frontfits.
6
' COMMISSIONER CURTISS:
Okay.
But backfits u
7 would be included within that?
8 DOCTOR MINNERS:
In backfits, we have to 9
prove it.
In frontfits, we don't have to prove --
10-COMMISSIONER CURTISS:
Okay.
Fair enough.
11 COMMISSIONER REMICK:
They're conservatisms.
12 Is'that --
13 DOCTOR MINNERS:
No.
They're cost-14 beneficial.
We looked at it and said, "I can increase 15 safety --
16 COMMISSIONER REMICK:
Some of these would 17 rot be backfits.
They're impositions at th'e _ original 18 license.
I 19 DOCTOR MINNERS:
They may be.
L 20 COMMISSIONER REMICK:
I assume it's because
'21 of conservatism in our licensing basis.
22-DOCTOR MINNERS:
We didn't have as quite a l
23 formal procedure in most of these original licenses, 24 but I think the same thought process there.
I don't 25-believe that everything that was imposed on the NEAL R. GROSS COURT REPCRTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON, D C 20005 (202) 212-6600 n.
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53 1
. original licenses was put - on there because it.was L:.
.i 2
-necessary for adequate safety.
I think there was some.
L
-3 cost benefit, albeit maybe qualitative thoughts behind 4
those things.
I 5
MR.-TAYLOR:
And conservatisms.
6 DOCTOR MINNERS:
And conservatisms,.yes.
r 7
DOCTOR MURLEY:
Before we leave slide 13, I 8
think I want to make sure that we all understand--
9 commissioner Curtiss brought up the point.
There is 10 an error on this slide.
We're going to maintain an 11 acceptable level of safety, not the current level, j
- j 12 DOCTOR MINNERS:
(Slide)
Slide 14 was the-
{
[
l'3 last of the eight subjects discussed, and from the 14 comment's at the workshop the industry wanted some 15 special hearing procedures for a license renewal 16 hearing.
They wanted some limits on the hearings, to 17 limit the number of interrogatories, to change the 16 standards for summary dispositions, to have strict 19 hearing ' schedules.
And they' wanted to have an ASLB
-i 20 decision within 300 days of the SER as kind of a fixed 21 =
thing you had to do.
22 I understand our position is that the 23 current Part 2,
which was recently changed, is 24 adequate and will provide for timely, efficient 25' hearings.
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-1 In addit;Lon, I think we'd note that because c
2 of _ ' the timely renewal provisions this. precludes any 0
3' concerns regarding i terruption of the operation of a 4
-plant due to protracted hearings.
So~
think that we 5
the current -Part 2 procedural rule is perfectly 6
adequate for a renewal license application.
7 CHAIRMAN CARR:
Are we looking at those for 8
possible generic application sometime?
I mean,-are
'9 there some good ideas in there we ought to be 10 considering?
e 11' MR. PARLER:
These good ideas were looked at 12 by a' regulatory reform task force a - number of years-13-ago..
They may be good ideas, but I'll leave that to 14 others to judge.
I'm not implying that they are-bad 15 ideas, but the ideas good and bad were put on the 16 Commission's table' by this regulatory reform task 17 force.
And the final changes were put out within the 18 past year, and they are being challenged now in the 19 courts.
I would suggest that you might want to wait 20-and see how that challenge comes out before we move 1
21 boldly in a different direction.
22 I might add, also, in addition to the timely 23 renewal feature of the law, which as Doctor Minners 24 has pointed out is very important here, because you 25 don't have the leverage of holding up things by NEAL R. GROSS COURT REPORTERS AND TRANSCR!BERS 1323 RHOOE ISLAND AVENUE, N.W.
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'(-
1 beyond.that-I gather from this staff..
1' litigationi-but 2;
. paper and from the discussion here that major efforts-i f 3~
will'be undertaken.
And if_they are successful,-a lot i
_4 of issues _could not be litigated in the current 5-licensing basis, and I emphasize "if" the approach is 6
successful.
7 The age degradation requirements.
If a rule 8
is-put into place, we could put in our.' notice of 9-hearings for these proceedings what the framework, the 10 contested issues should be, or the boundaries.
i 11-So I would think that the experience of the-12 past that is, the experience that we've had in 13~
initially licensing these plants by no means-14 picture what a renewal hearing and renewal litigation 15 would be like.
Even if it is nothing else, it would 16-be much more narrow, much more focused, and much more 17 efficient.
18 But we are always looking for ways, either l
19
.from court decisions or from administrative conference 20 recommendations, to streamline our procedural process.
j i
i l
21 CHAIRMAN CARR:
- Well, I must admit I'm
,22 somewhat sympathetic to the schedule.
Give them j
i 23 enough time and hold them to it.
It seems like a l
'24' reasonable approach.
25 MR. PARLER:
That is one of the regulatory i
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.ref orm s suggestions. that';- was ~ definitely-made and was o
i C
'2
_put before the4 Commission, I believe, in-the early 3
'80s.--
'And I believe, if my recollection is correct, 2
4 that the leadership of the Licensing -Boards at the 5-time suggested -that a firm schedule was not ' a - good 6
idea.-
Give them a target goal and that would be all 7
- right,
.We-do have built into our procedures now 8
_ target goals.
9 COMMISSIONER CURTISS:
It might make sense 10 to do something along the lines of what we did on the 11 high level ' waste proceeding, where it wasn't-a firm 12 target but in.Subpart J where the model schedule was 13
. aid out and what dates roughed out in the schedule 14 itself.
I don't know-where I come down on that issue 15 in this context, but it might be. something that the i
-16 staff takes a look at as it prepares the proposed rule 17 for-our consideration.
It would provide some i
18 additional' guidance-in~ terms of.the general framework 19 and schedule framework that we would expect'ought to-20 be met absent other considerations in a proceeding of l
21 this nature.
22 MR.
PARLER:
The bottom line point about 23-schedules -is that a schedule is really meaningless K
24 until you know what the complexity of the hearing is l
\\
25 going to be.
As Malsch has cold me, if you have one NEAL R. GROSS l
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1 minorLissue the schedule.can be tight.
On the other 2
, hand, if you have 100 ' highly contested issues 'in a 3-complicated-case, a model schedule doesn't mean a lot, i
4^
CHAIRMAN CARR:
- Well, since these are
= i 5
. special' cases we haven't faced before, we might need 6
it.
.7 NR. PARLER:
Right..That could be done.
'8 CHAIRMAN CARR:
Something we c o u l d -. d o ' t o 9
help.
r i
E 10' All right.
Let's proceed.
t
.11 DOCTOR MINNERS:
(Slide)
Slide 15 is a l
12 summary of the staff actions as a result. of the 13.
workshop.
14 We have modified the conceptual rule, and
~
15 that's provided in enclosure 4 to the paper.
16 We now are going to have a schedule which 17
'decouples the Part 54 rulemaking from the Part 51 18 rulemaliing.
19 We will produce one reg guide on format and-20 content.
l 21 And the other licensing guidance will be h
~22 through SERs o n' the NUMAd reports, which is the t;
23 screening report we've discussed, and the ten 1
24-teci.nical reports.
25 (Slide)
On slide 16, which is shown in more l
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detail'on Enclosure'5 to the paper, as we.said,-we're p.
2 going, to separate Part 51, environmental rulemaking,
'from the Part 54, license renewal, in order-to 3
4 accelerate the Part 54 rule.
5 The reg-gu' de i
on f ornat and content, the 6
NUMARC reports on screening, and the SRP that pulls 7
that.all together would be on a slower track than the 8-54 rule.
And the industry technical reports would be fit-in there to be available'and useful about the same 9
10 time =as the Part 51 rulemaking.
And we have to work 11' out those detailed schedules.
12 The resources to do all of this are budgeted 13 and we: don't need to request any: more resources.
14 CHAIRMAN CARR:
When you're putting out'the 15 reg guide, the final reg guide, that part after the f
16 final rule, are they going to have enough information 17 in the' final rule.that-they'll be able to submit their
-' 18 application and have it --
19 DOCTOR MINNERS:
I think on-slides --
20 CHAIRMAN CARR:
assurance that they're 21-going to be in compliance with the reg guide too?
22 DOCTOR MINNERS:
S'lide 17, I think, will 23 hopefully illustrate that.
It shows a little more 24 details of the schedule.
We would be getting the 25 proposed rule to the Commission in May of this year in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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order-.to: meet our May of '91 ' ate to get it before ther l
d
'f 2
application _which would be in June of
'91.
1 n
.3 Now the reg guides in the SRP are going to:
'4 follow that, but there will be a draft published in t
15 December of
'90, which will be six. months before the 6
application is tendered, and so the applicant'can have.
7 a good idea - of what the reg guide is going to be, a
8 albeit in a draft form.
9 NRR is now doing predocketed reviews of'the 10 leads plants at Yankee and Monticello.
We'll i
11 certainly learn something from that that can be fed 12 back into this guidance.
13 (Slide)
On slide 18 is the schedule for 14.
Part 51.
The controlling action is that first bullet s
/
15 where we have to put out a Federal Pegister notice 16-which is a notice of intent.
That's a procedural 1
17 requirement in case we want to call it an impact
~
18' statement.
That can't be done until June of this year 19 and then when you just put ' the review and comment 20 template on top of that,.that kind of forces us to 21, have a final rule not before April of
'92, which will 9
.22 be before any renewed license is issued.
23 So, that is our plan and our purpose.
It's 24 a very tight schedule to do this.
One of our purposes u,
25 in presenting this to the Commission today is to try
'NEAL R. GROSS COURT REPORTERS ANO TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) N WASHINGTON, D.C. 20006 (202) 232 6600 s
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60 1-
-to get some feedback now if the Commission desires-any if 2.-
changes so we can get. a little jun.p. on that.
If we t
3 get changes late in~the process, we may not be able to
~
4 meet the' schedule.
5' COMMISSIONER CURTISS:
Just o n e.. q u i c k 6
. question on that last chart.
On the Part: 51 7
rulemaking, will the generic environmental document 8
and'the S table that you intend to use should be on 9
the books before the actual' hearing begins for the 10 pilot plants?
J 11 DOCTOR MINNERS:
Yes.
Yes.
12 COMMISSIONER CURTISS:
Okay.
How much.
13 time -- I recall the dates for submission of the 14 applications.
How much time are you projecting for 15' review of the SERs in the two pilot plant cases?
16 DOCTOR MINNERS:
The review of the SERs?
17 You mean of the application --
L 18 COMMISSIONER CURTISS:
Preparation of the.
19 SERs.
20 DOCTOR MINNERS: 'Say again?.
21 COMMISSIONER CURTISS:
Preparation of the w
22 SERs before you get into the area.
l1 23 MR.
TRAVERS:
The SERs for the industry l
24 technical reports are estimated to take approximately 25 a year for internal review, including coordination NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W j
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e F
A 1-through-the'ACRS.;
2 COMMISSIONER CURTISS:
And will-you prepare l
3 an SER then on the application once'it comes in?
- =
c L.
4 DOCTOR MINNERS:
Yes.
v.
'S MR. TRAVERS:
Yes.-
6 DOCTOR.MINNERS:
We expect about.a two year c
p-P 7
review.
8-COMMISSIONER CURTISS:
Two year?
Ohay.
9 DOCTOR MINNERS:
I think that was the i-10 number.
But we haven't fixed on that.
That's a 11 tentative.
12
= COMMISSIONER CURTISS:
Okay.
13 DOCTOR MINNERS:
That's all I have to
+
14 present.
Thank you.
15 CHAIRMAN CARR:
All right.
Any questions?
a 16 Commissioner Remick?
i 17 COMMISSIONER REMICK:
-Well, one.
I-18 certainly f avor ' the staff proposal that we've heard 19 today.
O'n the matter of' the screening criteria, I t
.' 2 0 would urge the staff to do as thorough a job as you
'21 po'ssibly can because I think it's important to the J
).
i s-22 process and hopeful 2.y prevent later challenges to 23 them.
I would like to ask you to give consideration 24 to the pros and cons of requiring that list of 25 licensing basis documents either in the application or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE. N W 1
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Jseparately, to give -; considera tion to the advantages J
2 and' disadvantages.-
- ?,
And the concern I have, since-there are-4.
various of fices. involved, including the Commission 5
office of OGC, that I do urge that you have some tight 6'
management control backed by the EDO so that you're 7
' able to maintain the schedules that you've proposed.
.t 8
CHAIRMAN CARR:
Commissioner Roberts?
9 COMMISSIONER ROBERTS:
- None, f
- 10 CHAIRMAN CARR:
Commissioner Rogers?
11 COMMISSIONER ROGERS:
Where does the r
e 12 research ' agenda stand with respect to any issues for.
F
- 13 licensing renewal?
Are there any outstanding research
' 14 issues that have to be cleaned up before we're ready L
15 to move?
1 t
16 MR. BOSNAK:
.There are really no outstanding L
17 what I'd call show stopping research efforts that we 18
- think have to be completed.
We're continuing with the s
aging research program, both the ANPR Program and the 19 20 Materials Program.
21-COMMISSIONER' ROGERS:
Well, there were some 22 questions-about the availability of surveillance 23 samples in some plants.
Is that going to be a 24 difficult issue to deal with, lack-of those?
25 MR. BOSNAK:
It's an issue that would have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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r a
ill tofbe dealt with with respect to the end of life or-i 2:
life assessment for the vessel.
I think it will ba a i
3 case - by case sort of thing as we approach each r
-4 licensee.
S COMMISSIONER ROGERS:
I mean we'll just have
'6 to face that one when it comes up, is that-it?
7 MR.. BOSNAK:
Yes, sir.
It will be one of i
'8
- the. things that will have to be covered; in the j
i
~-l
.9-application obviously.
j 10 COMMISSIONER ROGERS:
We'll put more of the
)
J' 11-responsibility for that on the licensee to come up 12 with an adequate demonstration of some sort.
Is that
-13 what-you're saying?
'i
.1 14 Where do the ASME and ANSI codes -- how are N
15-they going to be used in this process with respect to-W
-v' y \\ c.
16-degradation phenomena such as erosion / corrosion?
- M
};
'17 MR.
BOSNAK:
You asked about m
J 18 erosion / corrosion.
They have produced a. subsection of d
q.
19 Section 11 now, Subsection IWT.
'Ehat will eventually l
i 20 be picked up in our regulations as a normal course, j
I i
.21=
irrespective of license renewal.
So, that would be 22 handled that way.
i I
23 They have a group on aging and life 24 extension looking at things tnat need to be included, 25 things that need to be changed within the IEEE and NEAL R. GHOSS COURT REPORTERS AND TRANSCRIBERS I
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{~
1 ASME codes and'. s tandards with respect to continuing 2
life..
They are' not really focusing on calling it 3'
They're' focusing on. the aging f
4 aspects of. extended life, how do you assess the 5
remaining life of a given component knowing where you 6
- started, the various transients that it has 7-experienced during its service life, that sort of 4
?
E 8
thing.
9.
COMMISSIONER ROGERS:
But that has not been c
10-completed yet?
11 MR. BOSNAK:
That part of-it h r.s not been i
12 completed.
The part on~ erosion /corror, ion has been 3
-13 completed.
We'will eventually pick that up as a 14 normal process when we modify 50.55 6).
i 15 COMMISSIONER ROGERS:
Is it conceivable that
'1'6 there could be a problem with that with respect to.any
'17 particular license renewal application?
18 MR. BOSNAK:
I don't believe so.
The code e
19-itself only covers class 1,
2 and 3 component 5i.
It 20 does not cover balance of plant'.
So, we would have to 21' be able to look at the application to balance of plant 4
22 components, which are important as-we use it in the 23 conceptual rule, which are important to license 24 renewal.
So, that's really basically part of the 25' screening process.
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COMMISSIONER - ROGERS :
Just in this general-j l
2-area'of degradation, I haven't seen too much on q
i 3
electrical systems.
It seems to me that the-focus has
~4-tended to be on cables, environmental and aging 5
effects on cables.
But what about other electrical ~
r 6-components?
Some of.these plants are pretty old and i
7-
'their control systems are old fashioned and I suspect 8
there.are some paper-wound capacitors in some of those 9
systems.
What is our thinking about that?
I haven't
-j 10' seen anything on.it and in this --
11 MR. BOSNAK:
Well, you're correct, sir.
The
-12 cable area is one for which.there will be a NUMARC 13 technical report because that was looked at as being a 14 difficult area, an expensive area if you had to l
15 replace those things.
The smaller items-that have 16 shorter finite lifetimes are supposedly covered within
.17 existing. programs.
I 18 So, to answer your question, if you --
- j
'19 COMMISSIONER ROGERS:
It's part of a 20 maintenance program essentially.
l
.21 MR.
BOSNAK:
It's part of the maintenance u
j 22.
program.
In the' conceptual ~ rule, we call it an 23 effective established program.
But the criteria for 24 those programs, when you decide that something has to i
25 be replaced, that is something that the staff is still NEAL R. GROSS COURT REPORTERS ANO TRANSCRIBERS 1323 RHOOE ISLAND AVENUE N W (202) N WASHINGTON, D.C. 20005 (202) 232 6600
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2-COMMISSIONER ROGERS:
Okay.
Just on a
'3' li'ttle dif f erent topic, the tech specs.
Do you 4
contemplate any changes in tech specs that.will.become
- 5 part of the license renewal conditions?
The 6
. conceptual rule provided a draft section on that,
~7 54.15.
Do you think that there will be a possibility 8
of. tech spec changes -as part of.the license : renewal l
. 9 approval?-
t 10
~ DOCTOR MINNERS:
It's possible.
I don't 11 think anybody that I.know of has identified any ~ tech 12 spec change at this time.
But conceptually, yes.
As 13 a means of compensating for degradation, yes, you
- 14 might change surveillance intervals or-LCOs or 15 something.
16 COMMISSIONER ROGERS:
So, it's possible.
s 17 I-think that's all that I have.
J18 CHAIRMAN CARR:
Commissioner Curtiss?
-j 19 COMMISSIONER CURTISS:
I just want to add my 20 voice to Commissioner Remick's and commend the staff.
21
-It.seems to me you've done an excellent job of pulling.
22 together the results of the workshop and in fairly 23 short order presented an excellent overview of the 24 issues and the direction that we're taking.
It seems 25 to me like the biggest part of your job lies ahead of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON, D.C. 2000$
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you -in terms of scheduling r e s ourc e s.. and it 's an.
g N
2 aggressive:scheduleiand I encourag'e you.to do what you 3
can;to meet tha' en'the importance of the issue.
U 4
I woald, tetween now and when the proposed
?
5 rule comes back before the Commission, encourage you t
6 to take-a-look at two issues that I'm-interested-in.
+
'7 First, if you'could, take a look at the. possibility of 8
. including as much of the screening - criteria in the 9
regulatory' f ramework itself as opposed to the reg 1
-10 guide.
It does seem to,me that some -- although there i
i 11-
.are technical tradeoffs in doing that, there are some
. 12 potential benefits from the standpoint - of how much 13 time we spend litigating the screening process;versus-14 the subsequent issues with. less likelihood of that happening the more.it's included in the rule.
15 16
- Then, in addition, on the question of the 17 current ' licensing basis, what's required in terms of the discussion here 18 the documentation.
I guess I 19 was helpful, but I'd like to see a more thorough 20 discussion of just what the nexus is between requiring 21 the documentation in terms of the decisions and 22 actions that the staff. thinks need to be taken in the 23 context of plant life extension.
It wasn't quite l.
l 24 clear to me from this discussion what that nexus is, I
L 25 but if you can beef that up, that would be helpful for NEAL R. GROSS COURT REPORTLRS AND TRANSCRIBERS il 1323 RHODE ISLAND AVENUE. N.W (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 6600 I'
m 68~
-it s
l L
l.1 -
.me.
'2?
That's all I have.
lA
'3
" CHAIRMAN - CARR:
All right.
I.would say in 4-
.the two' pilot cases you're g'oing to look at early on, 5
you might get a lot of. lessons-learned out of your
_6 current licensing basis. match.and you may want to be a 7
little more ' thorough as a kind of a quality control l
8.
check on whether that system works or not or what you l
9-want to do with it.
l l:
10 The other thing I'm concerned about is 11.
the. -- the way I read - it,- if a guy comes in.at the 12-five year period for.an extension and you won't extend i
13 it beyond. 45 years, it says. not 'more than 40 years l
of.his
-14 total in the extension and now more than 15 total life, and not more than 20 years.
The words are kind of interesting. and I gather you were trying to
. 17 put a bound on it.
18 It says, " Renewal term means the period of
^
?i9 time which is the sum of the remaining number of years l}
'20 on the operating license currently-in effect, plus the i
21 additional amount of time'beyond the expiration of the
'22 operating license not to exceed 20 years, which is
2 3 requested in the renewal application. The total number j
24 of years for any renewal term shall not exceed 40 25
' years."
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1-So, if he - ' came ~ in any time before the 20 2
year period, he's only going to get less 20 plus 3
whatever's between him and 20,. huh?
4 DOCTOR MURLEY:-
That 's correct.
By the
'S
Atomic Energy Act, we can only issue a license for a 6
period of 40 years.
So, if he comes in before 20 7
years has. expi' red and we act before 20, then we can 8
only give a 40 year license.
9 CHAIRMAN CARR: ' Total?
Beyond that point?
10 DOCTOR MURLEY:
Yes.
11 CHAIRMAN CARR:
Whatever point he.comes in.
' obviously ' 20 years is not a number we 12 That's why 13 know a lot about.
Why did you pick 20 andLis there 14 some --
I'm concerned always about picking. an 15 arbitrary number.
At this point it seems like a great 16 number, but when that guy's license begins to expire 17 and he's going to want.to change-it again, is 25 all 18 right?
l 19 M R '. BECKJORD:
Mr.
- Chairman, I think to-I 20 begin with, the 40 year life was arbitrary at the time i
21 it was selected.
}
l 22 CHAIRMAN CARR:
Oh, but they did design
'23 components toward that life, didn't they?
24 MR. BECKJORD:
I think that --
25 CHAIRMAN CARR:
I mean they knew at the time l
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p.y
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- j 70 x
i l they.were going to -
2 MR. BECKJORD:
I think the development _ of 3-codes was going on in parallel with that.
So, i
14 recalling sometof the work that was'done at that time,.
5 I
think it would - be difficult to say that the 6
requirements were all preordained.
It seems ' to me a
7 that with respect to the 20 year' I think that people 8
have the feeling, looking at experience, that it's a 9
reasonable expectation and I think that's where the 10-number'comes from.
j 11 CHAIRMAN CARR:
That's just today's firm 12 look.-
13 DOCTOR MURLEY:
Yes.
14 CHAIRMAN CARR:
Twenty years f rom now, 15 they're going to look at it differently.
t 16 DOCTOR MURLEY:
They may.
17 CHAIRMAN CARR:
All I'm worried about is are 18 we putting a number in there that we don't really need 19
'to tie ourselv'es to arbitrarily.
You might give that 20' some thought when you take --
21 DOCTOR MURLEY:
Personally, I think that the f
22
' designers need a fairly firm guideline so they don't 23 have an open-ended target, for example, to design
'24 mitigation systeis
- for, design their vessel 25 embrittlement systems for and that sort of thing.
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.1-CHAIRMAN CARR:
- Well, I ' _ guess what.I'm-j
' 1
' s,. if -the guy can. come ~in 'wi t h. good
~ t
'2
- saying:
i v:
3 documentation;to go for 23 years, we ought to look at-
~
g
-4
.it rather than.just arbitrarily say, " Twenty years is 5
all -. " -
I mean if you're going to say 20, why not-6'
=saf ten?
'7 DOCTOR MURLEY:-
Well,' it makes it very 8
difficult' for the staff because we 'have to have our 9
own basis for reviewing his application against.
He-10 may very t well make a good case for 23 years.
-His 11 neighbor may make a good case for 26 years.
I think 12 I'm arguing in kind of as a plea almost for the 13 staff to have some kind of framework so that we can 14 ~-
guide our research program and have a 60 year life.
I 15-admit it's arbitrary, but it --
16 MR. TAYLOR :
This came up early on in the 17-
. discussion and that's how it got selected really.
-It 18 came up early as a basis, right?
[
19 DOCTOR:MURLEY:
Yes.
20 MR. TAYLOR:
As I recall, from when we first 21 talked.about it.
It's been the basis of discussion D
p 22 with-the industry.
I understand your point.
We'll 7y 23 take a look at it, but that number came up in the i
p 24 earliest of discussions of this whole subject, as I l
25 recall.
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PW
'h e,.
a ;;,
j 72-1 g.
'l Isn't that-true, Tom?'
r t.
That's correct, yes.-
~2 DOCTOR MURLEY:
t
[
3 MR. TAYLOR:
And it seemed like a good, fair
~4 target.
5 CHAIRMAN CARR:. Twenty years away?
6 MR. TAYLOR:
Some of us won't-be here.
7 COMMISSIONER REMICK:
Is' there anything ~ to 8'
prevent a renewal of a renewal?
9 DOCTOR MURLEY:
No.
10 MR. TAYLOR:
No.
11 CHAIRMAN CARR:
Eric?
1 12 MR. BECKJORD:
Just a point on Commissioner 13 Rogers' question on tech specs.
The only case that I-14' can think of-where there would b'e a change would be
~15 relating to the aging degradation, if there were some 16 requirement that it would.be revisable to include for 17 reasons of aging.
But other than that, I wouldn't--
18 I don't know of any changes that would be made.
.j d
19 CHAIRMAN CARR:
Well, I'd like to also thank i
20 the staff for the briefing.
It appears that the 21 license renewal rule workshop was successful and that-
-1 22
'you got good comments from that activity and it was t
lf 23 obviously a very important activity as a rule.
'24 I'm supportive of the staff's plan in the
{
p.
25 schedule which would result in publication of the l
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.2
L;
. (:
L'b 73-1 final license renewal rule in May of
'91.
I'm 2
uomewhatJconcerned, as you noted,.that the final rule 3
won't-provide everything the licensees. might need'to p
4 proceed with a license renewal application.
The
[
5 regulatory guide on the format and content of the
.6 application and the staff's safety evaluation' reports 7
on the industry technical reports will provide 8
.important regulatory guidance.
-l 9_
I request you-look closely at the schedule 10 for completion of these documents to see what can be 11 so they'll be useful to the early license renewal
?
12 applicants.
13 I also believe it would be worthwhile to 14 incorporate the schedule for the industry-technical 15 reports and the staf f 's safety evaluations in the p
16 overall. program plan and schedule for completion of 17
'the renewal activities.
18 It appears that offices of Research, NRRLand 1
'19 Occ are working closely together to come to a well 20 thought out, as well as a timely,. licensing renewal.
l l
21 rule and I commend you for this.
I urge you to l
22
' integrate the result.s of the aging research into this-l l-23 process on a continuing basis as more information-4 24 becomes available.
25 I also request you interact as early as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i
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-74 t
'1
' pos sible :: withl. the - Advisory Committee ' on> Reactor -
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.Are there any additional comments?
I 4'
If'nct, we stand' adjourned.
5 (Whereupon, at 3:37 p.m.,
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CERTIFICATE OF TRANSCRIBER This.is to certify that the attached events of a meeting.
of the United States Nuclear Regulatory Commission entitled:
TITLE OF MEETING:
BRIEFING ON STATUS OF PROPOSED RULE ON LICENSE RENEkAL PLACE OF MEETING:
ROCKVILLE, MARYLAND
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DATE OF MEETING.
JANUARY 30, 1990 were transcribed by me.'I further certify that said transcription is accurate and complete, to the best of my ability, and that the I
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