ML20034B321
| ML20034B321 | |
| Person / Time | |
|---|---|
| Issue date: | 02/22/1990 |
| From: | Curtiss NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR29043 AD04-1-110, AD4-1-110, SECY-90-021, SECY-90-21, NUDOCS 9004270009 | |
| Download: ML20034B321 (3) | |
Text
{{#Wiki_filter:N 0 T A T I OLN-V 9.T.E............... RELEASEDTOTHE PDR RESPONSE. SHEET * -,,z j j g y g,
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6te Ini ..... 'e....... tK!s.... T0: SAMUEL J. CHILK, SECRETARY 0F THE COMISSION FRON: C0MISSIONER CURTISS
SUBJECT:
SECY-90-021 - REPORT ON LICENSE RENEWAL WORKSHOP AND PROPOSED REVISIONS TO THE: PROGRAM PLAN AND SCHEDULE FOR RULEMAKING L i I X/with APPROVED coment DISAPPROVED ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION l COMENTS: i See attached coments. $. W { SIGNATURE RELEASE VOTE /X / 2/22/90 DATE WITHHOLD VOTE / / ENTERED ON "AS" YES / NO $$o]lgg?99 22 D Fo 2-III
l. ~ Commissioner Cu_rtiss' comments on SECY-90-021: I concur with the staff's proposals concerning license renewal, subject to the following comments: 1) With regard to the scope of individual license renewal proceedings, I agree with the staff that these proceedings should be limited to matters pertaining to age-related equipment degradation over the license renewal term. On-this point, the Chairman's vote contains a statement that could be read to imply that we would address'non-age-related issues in these proceedings as well. ("The-backfit rule should apply to proposed: changes to the current licensing basis except where changes-necessary for license renewal can be shown to have a nexus to age related degradation."] It-is not clear to me whether this statement is intended to suggest that we would entertain non-age-related issues in license renewal proceedings. In my view, issues unrelated to age-related degradation should be addressed outside the-scope of the -individual license renewal proceedings.: In the event that staff should identify non-age-related safety enhancements during the course of the license renewal process that the staff desires to pursue, there should be a process for distinguishing these safety enhancements from the age-related matters that-will be the subject of the license renewal proceeding. I would recommend that we-ask OGC to explore how best to codify such a distinction, so as to ensure that it is understood at the outset that non-age-related issues are not properly within the scope of individual license renewal proceedings. One final point on the scope-issue: The staff's suggestion that we highlight our interest in seeing timely resolution of severe accident issues in the Statement of Considerations seems to confuse the important distinction between age-related and non-age-related issues by implying a relationship of some sort between license renewal proceedings and severe accident issues. Cleary, timely' resolution of severe accident issues is something that the Commission has endorsed. But in view of the statements already made to date by the Commission on this subject (gigt, " Policy Statement on Severa Reactor Accidents-Regarding Future Designs and Existing Plants"), it is unnecessary in my view to state once again our interest in seeing severe accident issues resolved in a timely manner, particularly if it might be read to imply that the Commission intends to entertain non-age-related issues in license renewal proceedings. Accordingly, I would recommend that we delete the discussion of severe accidents from the-Statement of Considerations.- 2) With regard to the renewal standard, I agree with the staff's recommendation to employ the current licenting basis. I agree with the Chairman's'recommendatica, hcVever,
...contd. SECY-90-021. ~ ~ on how we should approach documentation of the current licensing basis. 3) With regard to the backfit issue, I have two comments: i) I generally agree that.the backfit rule should not apply to the license renewal rulemaking.itself. 11) With regard to individual license renewal proceedings, however,.I believe that the backfit rule should apply. This approach would lead to the following results: o-The backfit rule would permit staff to impose Jage-related requirements that are necessary to ensure adequate protection during the extended life of 5 the facility without regard to cost. l Application of the " compliance exemption" of the e backfit rule (10 CFR 50.109 (a) (4) (i))- in those cirumstances where a clear showina can be made-that oronomed reauirements-to address ace-relateg. dearadatioq are necessary to ensure that the olant will onerate in accordance with the CLB'durina the license renewal term would permit the staff to. impose such requirements without. regard to cost as well. I Proposed requirements addressing age-related e i degradation issues that go beyond what is L necessary to ensure that the facility will operate in conformity with the CLB during the: renewal term would be subject to a'backfit analysis, including the cost-benefit analysis and justification provisions of the backfit rule. 4 4) During further development of the proposed rule,-staff should-seek to. incorporate as much of the screening. 5 methodology as possible in the rule itself. When the proposed' rule is-submitted to the commission for consideration, the staff should discuss the. extent to which i j this has been accomplished. 5) Finally, in view of the magnitude of the task and the ambitious schedule which confront the staff, the'need for j ongoing high-level NRC management involvement in coordinating the activities of both NRR and RES in the license renewal effort cannot~be overemphasized. Any-difficulties encountered in this regard, including any uncertainties which may arise concerning the scope of each office's responsibilities, should be raised to appropriate levels of management for prompt resolution. q i s a e =v. m.. a m.-- -. m- ,m-_ -= m
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