ML20029C490
| ML20029C490 | |
| Person / Time | |
|---|---|
| Issue date: | 02/15/1990 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20028G725 | List: |
| References | |
| NUDOCS 9203250147 | |
| Download: ML20029C490 (2) | |
Text
i NOTATION V0TE 1
RESPONSE SHEET T0:
SAMUEL J. CHILK, SECRETARY OF THE C0fMISSION FROM:
CHAIRMAN CARR
SUBJECT:
SECY-90-021 - REPORT ON LICENSE RENEWAL WORKSHOP AND PROPOSED REVISIONS TO THE PROGRAM PLAN AND SCHEDULE FOR RULEMAKING APPROVEDMmmentDISAPPROVED ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION C0l41ENTS:
see attacned comments {
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4 SIGN TURE
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RELEASE VOTE
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O I f-30 DATE
-WITHHOLD VOTE
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ENTERED ON "AS" YES NO h~Y
Chairman a rr's cocments on 5ECY-90-021 I approve :he staff's program plan and schedule; nowever, I request the staff to evaluate the schedule for completion of the regulatory guide and safety evaluation reports on the industry technical reports, to determine i
if we can make improvements in providing this important regulatory guidance j
4 to the early renewal applicants.
'n addition, the staff should incorporate the schedule for completion of the industry technical reports and the staff's issuance of safety evaluation reports in the overall schedule for license renewal activities.
With regara to the conceptual rule, I do not find the staff's ciscussion on the need for documentation of the current licensing basis for the purposes j
of enforceability persuasive.
The staff should provide an alternative in the proposea rule to ensure the current licensing basis is enforceable for the term of the renewed license, such as incorporating a license condition in a renewed license that the licensee will comply with the current licensing Dasis in the renewed term. Within a month, the staff should provide a discussion of any other reasons why we should require licensees to document their current licensing basis. As part of the discussion, the staff should. evaluate whether we should request the two pilot plants to document their current licensing basis for the purpose of verifying that the screening methodology is adequately performed.
The backfit rule should apply to proposed changes to the current licensing basis except where changes necessary for license renewal can be shown to 4
have a nexus to age related degradation.
In order to ensure discipline anc consistency in the review of license renewal applications, I expect staff to clearly justify standards for addressing age related degradation and to employ a reasonable mechanism for handling disputes over such standards.
Following review of the two pilot applications, the staff should consider incorporating the standards for addressing age related degradation in an amended license renewal rule to the extent possible given the existing knowledge sase on age related degracation.
When age related degradatico standarcs are incorporated in the license renewal rule, the backfit rule should appiy in the review of individual license renewal applications.
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