ML20072B387
Text
ENCLOSURE i
i EARLY SITE PERMIT PROGRAM PLAN l
(ESP 8) l PREPARED BY:
BARRY ZALCMAN, PROGRAM MANAGER EARLY SITE PERMIT PROGRAM DECOMMISSIONING, NON-POWER REACTORS &
ENVIRONMENTAL PROJECT DIRECTORATE I
DIVISION OF ADVANCED REACTORS AND SPECIAL PROJECTS i
0FFICE OF NUCLEAR REACTOR REGULATION ISSUANCE:
FY-91 3RD QUARTER RELEASE 91-01 USER'S NOTE:
This is a living document that will be updated on a frequent basis. The Tier 1 and Tier 2 documents will be distributed on a routine basis; the third tier predecisional release restrictions) ject to draft and (the working level materici not sub will be available in the PDNP Early Site Permit Program Reading File, the PDR, and Central Files. Future releases of this Plan will reflect changes from the prior release only.
9408160102 940629 PDR COMMS NRCC CORRESPONDENCE PDR
CONTROL SHEETS DATE
'ELEASE NUMBER 07/26/91 91-01..........................
O a
O 9
O I
O l
J EARLY SITE PERMIT PROGRAM PLAN l
(ESP 3) l TIER 1 - SENIOR MANAGER'S OVERVIEW 1
l l
ISSUANCE:
FY-91 3RD QUARTER RELEASE 91-01
"=-
i i
INTRODUCTION
}{
In the National Energy Strategy -(NES), the U.S. Department of' Energy (DOE) tated that nuclear power supplies nearly 20 percent of the nation's electrical J
energy demand. Nuclear power ranks second among the sources that meet the demand; coal ranks first. Nuclear power is expected to continue to be an i
important source of electrical energy for the foreseeable future. Aggressive' I
power plant construction programs and the economic stagnation after the two i
snergy shocks of the 1970s resulted in a large reserve capacity margin. The I
continued economic expansion and a decrease in the number of new. power plants j
constructed since the early 1980s continue to deplete the reserve margin.
j Despite improvements in electrical usage efficiency,- new conservation efforts, j
and demand-side management, new baseload capacity may be needed at the turn of j
thz century. As the current generation of power plants are retired, replacement-capacity will be needed. To meet these demands, power suppliers must make l
complex decisions regarding the selection of the type of power sources to i
provide baseload capacity..
i l
A stable and well-founded licensing environment:is necessary if nuclear power j
is to meet a portion of the demand for capacity. The increase in public-
{_
participation in the siting and construction of energy facilities _ of any source j
type has increased the scope of permitting and licensin processes and has added
- to the burden of prospective power producers. -Recent C een Air legislation and
}
an increasing concern with global environmental problems such as climatic change j
aay become increasingly more important factors in making decisions regarding j
fossil-fueled power plants. However, nuclear power plants also present i,
potential environmental concerns.
\\
l [.
'he NRC devotes a significant amount of resources to overseeing the safe j
operation of the nation's nuclear electrical generating capacity through its i
safety, inspection, and enforcement programs. The license renewal program is j
expected to draw considerable attention if the industry elects to operate i
current plants beyond current license terms. The new regulations for advanced j
reactor designs and for the early resolution of site-related issues provides the electric generating industry with additional options to consider in making j
decisions regarding increasing capachy. The NRC is taking steps to enhance its capability to review new applications. This early site permit program l
plan (ESP 8) outlines the tasks the staff will perform to clarify the early site permit regulatory process and to make the licensing program more stable j
and predictable.
l This tier 1 document will be an overview for senior managers who participate i.
in the process to make decisions regarding the NRC's policy and resources. A 1
complementary tier 2 document will inform task managers of the relationship of j
individual tasks to the overall program. Finally, the tier 3 is the repository i
for the working level background documents, interface agreements, correspondence, j
task reports, _and related documents for the individual task plans.
i i
i 1
i i
l
4 l,
BACKGROUND l
n 1988, the staff formed a steering group to determine its readiness to review
)
future license applications. The steering group examined the adequacy of 1
the staff's existing procedures and review guidance that would support early site permit (ESP) application reviews, recommended items for updating, and 3
N proposed that certain regulatory requirements be changed. After the NRC promulgated the final rule for Part 52 of Title 10 of the Code of Federal l
Regulations (10 CFR Part 52), the U.S. Department of Energy (D0E) notified the l
NRC that it would sponsor a demonstration program to test the rule.
j Subsequently, the staff formed a task force to reevaluate its readiness to l
review an ESP application and to provide the Comission with recomendations j
for a program to review ESP applications under Part 52, in general, and to review the DOE-sponsored application, specifically.
j The Comission decided the approach for the staff to use to review ESP applications end expressed the importance of integrating the ESP program within l
the broader context of other agency initiatives. The Comission offered guidance on a variety of issues including emergency plann,ing, alternative sites, and human resources.
1 j
An industry team responded to the DOE solicitation for a candidate site to test the ESP process and expanded upon the original work scope.
In addition i
to identifying a candidate sitFto test the rule, industry proposed to examine the regulatory process and the status of regulatory guidance because much of 3
the material that was used to license the last generation of nuclear power i(
olants was not kept current. DOE is evaluating the response.
1 l
Representatives of the Industry Siting Group (ISG) met with the NRC staff to discuss its composition and its Action Plan on Siting (part of the Nuclear i
Pewer Oversight Comittee's Strategic Plan). The D01-sponsored program is an i
important component of the ISG Action Plan.
In addition, the ISG provides advice to the industry team that responded to the DOE solicitation. At this public meeting, the industry stressed that prospective applicants, before being 1
wtlling to submit applications, must be assured that the licensing process is stable and predictable. The industry views its proposal, including the review as a service to utilities and i
of the process and update of regulatory guidance, fort would be a "roadmap" l
other interested parties. One product of this ef through the NRC's licensing process that could be used by parties considering the nuclear power option and by parties actually submitting an application.
l The efforts of the industry team and the ISG under the Strategic Plan generally j
conforms to the efforts that the NRC envisioned in the ESPs, 4
i PROGRAM PLAN j
ESP 8 is a broad effort to capture the range of issues that need to be reconsidered if nuclear power plant siting, environmental and emergencf
" planning requirements are to be tested again.
It is a comprehensive program that focuses a portion of the agency's attention on some issues that it had not addressed for more than a decade.
It addresses four major types of tasks:
i j
Processissues(forexample,revisingrulesandregulations) j Technical guidance issues (for example, updating regulatory guidance)
Human resources issues (for example, staffing site safety specialties) i Development and training issues (for example, developing a course on ESP issues) i 5
1
i
~,
The NRC is prepared to accept and review an application for an ESP and, with the implementation of the ESP 8, it will enhance its capability to review a new application. The ESP 8 will be the internal guidance to improve the capability i (-
before receiving the initial ESP application (s)plete all elements of the ES of the staff. The staff does not expect to com and will continue to implement the ESP 8 while performing the initial licensing reviews.
The 27 individual task plans addressed in the ESP 8 are listed below and described in greater detail in the Tier 2 document:
l ESP 8 TASK PLANS l
Plan ID Process Issues P-01 Review and Prepan Guidance for the Licensing Process P-02 Review Land Use and Environmental Statutory Dyironment P-03 Rule: Alternative Site Reviews P-04 Rule: Decoupling of Siting and Design - Step 1 P-05 Rule: Decoupling of Siting and Design - Step 2 '
P-06 Rule: Geosciences Siting Criteria Update P-07 Rule: Clarification of Emergency Preparedness Regulations
'P-08 Rule: Decoupling of EP Exercise from COL P-09 Rule: Fuel Cycle and Transportation of Waste Environmental Data Update i
j P-10 Petition for Rule: PIRG, ET AL on Population Density
~
P-11 NRC and State lateraction Jm. Siting Issues Tectmical Guidance Issues T-01 Siting Lessons Learned Summary Report T-02 Federal-Level Energy Facility Siting Task Force T-03 Federal-Level Siting and Environmental Issues Workshop T-04 Standard Review Plans (SRPs) and Environmental SRPs Update T-05 Emergency Preparedness Evaluation Criteria Update Early) Site Permit Issues Regulatory Guides Update T-06 (Pre-Construction Inspection Program Update T-07 T-08 Model Project Management of an Early Site Permit T-09 Project Manager's Handbook Update Human Resources Issues H-01 Early Site Permit Overall Program Management H-02 Maintaining Access to Siting and Environmental Expertise H-03 Staff Augmentation in Early Site Pemit Issue Areas H-04 Federal Interagency Agreements on Early Site Permit Issues Development and Training Issues D-01 Seminar on Siting and Environmental Issues l
D-02 Comprehensive Course on Early Site Pemit Technical Issues D-03 Maintaining Early Site Permit Issues Expertise
[
l
p i
The ESP 8 will involve significant coordination among the following NRC offices:
Nuclear Reactor Regulation, Nuclear Regulatory Research, l
%neral Counsel,luation of Operational Data, Nuclear Material Safety and 31ysis and Eva In feguards, Governmental and Public Affairs, Personnel, and Controller.
l addition, staff from other executive branch agencies and departments will i
All tasks,-subject to the approval of participate in a number of tasks.
j management, will be included in the Five Year Plan; those not currently q
acc:modated within the Five Year Plan or those that can be accomodated by 1
reprograming will be coordinated with the Dffice of the Controller to ensure resource effects have been identified.
l The ESP 8 recognizes the organizational responsibility of operating units for This program plan will not redirect missions, programs, and projects.
Instead, ESP 8 management or direct the implementation of individual tasks.
j will facilitate the integration of the results of such efforts into the ESP j
program.
STATUS OF ESP 8 TASKS 1
j The staff previously initiated a number of the tasks identified by this plan and may have clearly defined a method, such as a rulemaking, to implement j
For other tasks, especially those initiated solely to support those tasks.
j, the ESP 8, flexibility exists to focus the effort to meet specific objectives and to cast its products to simplify reporting. The tier 3 of the ESPs d:cuments will include the status of each task and detailed information on the j
The following j
schedule, interim milestones, and planned accomplishments.
table is a summary status of each task. The status categories reflect ilestones or progress reports that should be common to each task.
f As the. program progresses, reports will be published periodically reflecting the status of each task as determined by the task manager within the organizational r
I i
unit charged with lead responsibility for the task. The responsible Management will resolve any organization will set the schedular targets. conflicts such as multipurpose tasking j
j agreements.
I I
l l
l-4 l
l i
l 5
"1 l
l
+
t ISP3 3TATUS i
LEAD STATUS P3 TASK PLANS 0FFICE A B C D E F G H I'(
OGC XXX Review and Prepare Guidance for the Licensing Process f
XXX Review Land Use and Environmental Statutory Environment OGC RES XXX
~
j Rule: Alternative Site Reviews RES 00NN0+
Rule: Decoupling of Siting and Design - Step 1 RES 00NN0+
j Rule: Decoupling of Siting and Design - Step 2 RES 00NN0+
1 Rule: Geosciences Siting Criteria Update RES 00NN0+
j i
Rule: Clarification of Emergency Preparedness Regulations RES 00NN0+
]
Rule: Decoupling of EP Exercise from COL RES XX Rule: Fuel Cycle and Transportation of Waste 4
Environmental Data Update j
Petition for Rule: PIRG, ET AL on Population Density RES XX i
GPA XXX l
HRC and State Interaction on Siting Issues NRR XX l
Siting Lessons Learned Sumary Report GPA XXNNX+
Federal-Level inergy facility Siting Task Force j
Federal-Level Siting and Environmental Issues Workshop GPA XXX
~
Standard Review Plans (SRPs) and Environmental SRPs NRR XXNNX+
4 i
Update NRR XXX i
Emergency Preparedness Evaluation Criteria Update RES XXX Early) Site Permit Issues Regulatory Guides Update NRR XXXXX+
(Pre-Construction Inspection Program Update
{(
.odel Project Management of an Early Site Pamit NRR XX NRR XX j
Project Manager's Handbook Update t
NRR XXXXX+
l Early Site Permit Overall Program Management NRR XXXXX+
Maintaining Access to Siting and Environmental Expertise NRR XX 1
I Staff Augmentation in Early Site Pemit Issue Areas GPA XX Tsderal Interagency Agreements on Early Site Permit l
Issues
'AEOD X X l
Seminar on Siting and Environmental Issues AEOD X X Comprehensive Course on Early Site Permit Technical d
i Issues OP XXXNO+
i Maintaining Early Site Permit Issues Expertise J
KEY:
j A - staff discussions initiated B - task plan outlined 4-C - management endorsement obtained i
D - organizational concurrence obtained on detailed plan i
E - task initiated F - schedule (+/-/o on schedule /off schedule / progress not defined) i i
G - task completed i
l H - results integrated into ESP program X - status achieved i
0 - predates April 9, 1991 Staff Requirements Memo j
N - not available/not applicable i
i r
ii t
l EARLY SITE PERMIT PROGRAM PLAN l
(ESPs) t TIER 2 - TASK MANAGER'S SUPNARY DOCUMENT i
I I
t i
i l
l l
l i
l
- s l
l l
ISSUANCE:
l FY-91 3RD QUARTER RELEASE 91-01 I
I.
1 j
INTRODUCTION
{
l{
The U.S. Nuclear Regulatory Consnission NRC has not roceived an application for j
i a new nuclear power plant since 1978. Current public policy, outlined in the
[
National Energy Strategy (NES) by the U.S. Department of Energy (DOE),l energy includes i
nuclear power as an important element in the distribution of electrica scurces. While the NES encourages increased efficiency and other conservation practices to reduce demand, growth is expected to increase the overall demand for energy. Conservation alone will not likely maintain the nation's reserve i
fl
-margin. Recent brown-outs and black-outs in growing regions of the country L
have taxed the nation's electrical power producers and has illustrated the delicate status of the reserve margin.
i Heightened awareness of the environmental factors associated with the combustion of fossil fuels may affect the public's perception of the options to i
g produce electrical energy. The recent amendments to the Clean Air Act to reduce l
i emissions from major stationary sources and the desire to preserve air quality j
related values in pristine areas of the country may have increasing importance-j in decisions regarding fossil-fueled power plants. Concerns-regarding global H
warming and climate change have fueled the debate on power production options.
i However, global environmental concerns are less likely to influence the
}
selection of source type in the U.S. than is the search for clean and healthful j.
air. Nevertheless, all of these elements contribute to the public policy i
debate and give the public reason to view nuclear power option' more favorably j
today than in its recent past.
4 i
The NRC continues to devote significant' attention to maintaining the nation's I
nuclear power capacity through its safety programs and the license renewal e
the Code of Federal Regulations (gated'new regulations, Part 52 of Title 10 of program.
In 1989, the NRC promul j.
10 CFR Part $2)', "Early Site' Permits; Standard l
1 Design Certifications; and Combined Licenses for Nuclear Power Plants." These rsgulations were built on the licensing process used for the recent generation
~i j
of nuclear power plaots and provide prospective applicants additional options j
to consider in seeking licenses for the next generation of plants. The public l
policy debate on the NES and a variety of legislative initiatives to' implement portions of it will continue. The NRC continues to undertake efforts to enhance its capability to review new applications.
i This program plan outlines tasks and interfaces, key strategies, and the underlying philosophy to be implemented to clarify the early site permit (ESP) l regulatory process and to make the NRC's licensing program more stable and 1
predictable. ESPs recognizes that a number of activities were initiated solely j
to support the ESPs, that some marginally touch upon the ESP process, and that j
others lie in between. This program plan'will not redirect management or direct the implementation of individual tasks.
Instead, ESP 8 will facilitate the integration of the results of such efforts into the ESP program, i
l i
i k
e
}
i l
I J
1
]
1i BACKGROUND hile performing the rulemaking for 10 CFR Part 52, the Comission expressed
.oncern that the staff was not capable or ready.to review an application for a new nuclear power plant.
In 1988, at the request of the Chairman (COMLZ-88-27),
i the staff formed a steering group to determine its readiness to review future j
license applications. The steering group assessed the staff's resources, procedures, and review guidance for myiewing ESP applications. The steering i
group also recomended updating the procedures and guidance, and proposed that 4
certain regulatory requirements be changed. The staff provided a summary of the steering group findings and its report to the Commission in SECY-89-104,
" Assessment of Future Licensing Capabilities."
i On April-18, 1989, the NRC promulgated the final 10 CFR Part 52 rule. While 1
i the courts, in NIRS v. NRC, inave clouded Subpart C of the rule (Combined j
Licenses for Nuclear Po 7w Plants), Subpart A (Early Site Permits), the focus of this effort, remains unchallenged and untested.
l In a letter of June 5, 1990, to the Chairman, William Young, Assistant Secretary for Nuclear Energy,' DOE, discussed plans for inn ESP demonstration program. This a
j discussion prompted the NRC to reevaluate its readiness to review a new i
application under the ESP process. The NRC discussed the details of the i
program with DOE. Subsequently, The Office of Nuclear Reactor Regulation (NRR) formed an ESP Task Force to define the staff's actions required to support an i
1 ESP application. On July 16, 1990, DOE offered its request for quotation l
(RFQ-69-9795) through Sandia National Laboratories for the " planning, management, and execution of a program intended to obtain an Early Site Permit under l
10 CFR~ Part 52 for a representative U.S. site for a future ALWR nuclear-power plant."
l In response to questions raised by a Comissioner on September 10, 1990, the staff outlined preliminary recomendations to enhance its readiness:to review a DOE-sponsored application. The ESP Task Force developed a management plan i
cut 11ning the steps to prepare for an _ application within the schedule outlined l
in the DOE initiative, the options for updating specific guidance documents, i
and the relationship of the ESP program with other continuing initiatives.
In i
SECY-91-041, "Early Site Permit Review Readiness," the staff provided its recommendations for a program to review esp applications under Part 52, j
generally, and to review the DOE-sponsored application, specifically. The i
Commission, in its staff requirements memorandum (SRM) of April 9,1991, i'
decided the approach for the staff to use in reviewing ESP applications. The Commission expressed the importance of integrating the ESP program within Part 52 in its entirety and of coordinating the ESP program effort with l
continuing initiatives, including the decoupling of siting and' design, the determining of the " level of detail" required for applications, and the defining 1
j of "large releases." The SRM included additional guidance regarding emergency planning, alternative sites, and human resources.
Initially, the industry expressed little interest in responding to the RFQ by j
DDE and Sandia. DOE and Sandia extended the period for response to January 14, 1991, and later to April 15, 1991. In a prets release of April 12, 1991, the i
U.S. Council for Energy Awareness outlined the essential elements of the i
l i
k 4
i I
j industry's response to the RFQ:
1)
A team comprised of the following organizations:
lk a
Electric Power Research Institute - technical management b
Nuclear Management and Resources Council - program management c
Joint utility contractors (JUC) comprised of:
- 1) Southern Electric International. Inc. (Southern Co.)
.~
1
- 2) Commonwealth Research Corp. (Commonwealth Edison Co.)
i
- 3) Public Service Electric and Gas Co. (of New Jersey)
I 2)
A program comprised of three irhases:
i a) Evaluation of Part 52 Subpart A, regulatory process and j
development of a "roadmap" for prospective applicants b)
Identification of candidate site (s)
{
c) Preparationofapplicationandlicensesite(s) 1 A2therequestoftheNuclearManagementandResourcesCouncil(NUMARC)ffon
{
representatives of the Industry Siting Group (ISG) met with the NRC sta j
June 21, 1991, to discuss the ISG's composition and its Action Plan on Siting j
(part of the Nuclear Power Oversight Comittee's Strategit Plan for Building New Nuclear Power Plants). The ISG is comprised of 12 utility and other non-utility representatives from diverse regions, and is supported by NUMARC j
andtheElectricPowerResearchInstitute(EPRI). The DOE-sponsored 3
demonstration program is an important component of the'ISG Action Plan. _In addition, the ISG interacts closely with the team responding to the RFQ. Each l
member of the JUC participates on the ISG, which would advise the Program i
Management Council that would manage the program to implement the industry's iroposal.
I At the public meeting, an open dialogue on siting and related issues important
)
for the ESP program was initiated. The ISG described the industry's proposal j
in the response to the RFQ as "not exactly" the proposal sought by DOE and Sandia, but as one that would meet the ultimate objective of the solicitation:
i I
that s' site be identified to test the Part 52 ESP process. The ISG indicated j
that prospective applicants, before being willing to submit applications, must j
be assured that the licensing process is stable and predictable. The ISG also indicated that a review of the regulatory uidance was important to limit l
uncertainty with the ESP process and that t could do the work even without j
the cost-sharing support of DOE, although on a less ambitious schedule.
l The process outlined by the ISG under the Strategic Plan and the process described in the industry's response to the DOE RFQ generally conform to the i
efforts of the NRC as envisioned in the ESP 8 Similar to the ESPs, the industry j
effort does not attempt to limit the scope of issues and activities. Rather it attempts to ensure that all issues and activities are captured to preclude unaddressed issues. This objective is compatible with a concern raised by the Comission in its SRM to preclude " problems at the combined license stage" and j
with the rationale for an encompassing ESPs. The NRC staff indicated that any proposed changes in the regulatory framework would be discussed openly, that it would encourage future meetings among the industry and NRC staffs, and that i
meeting notices and summaries would be available in the Public Document Room j
should other members of the public desire to participate.
I i
i
/
4
~~
_ - ' ~ ~ ~
~
I PROGRAM PLAN 1991. The iP8 addresses each of the issues identified in the SRM of April 9, ing the ttention on identify
,taff developed an approach that increases the a i
stage."
Therefore, the ESP 8 will be broader than the earlier s j
to define f issues that i
a reasonable universe of tasks to encompass the full range o
- iting, should be considered if the requirements for nuclear power plant s i ited anew. The environmental protection and emergency planning were to be v s ience NRC will likely reflect the knowledge gained from plant operating exper For example, resource-by allocating resources differently from past practice.
l intensive assessments were performed for certain postulated environm ther impacts expected to due to plant operation that never materialized; ie cases, there are more land use and environmental statutes that may requ detailed investigation and review.
The NRC developed ESP 8 to revisit site-related issues that had not bee C anticipates new addressed recently and that need to be reconsidered if the NR The ESP 8 addresses four types of issues:
applications.
Process Issues
~
Technical Guidance Issues Human Resources Issues Development and Training Issues d in a A brief sumary of the elements of the four types of issues is provide
{
task The lead responsibility for managing an ESP 8Cert I
discussion which follows.
However, the
- an reside with any of six offices.
of staff from a number of other offices or from sister agencies.
The ESP 8 Program Manager will coordinate a number of t h task.
ill The NRC is prepared to accept and review an application for an ESP a If an application continue to be prepared to review an application at any time.
i that were to be submitted in the immediate future, the NRC could rev ew d program application under the existing regulations and with the staff anAs time h
support currently available. capability to review a new application and t The staff may not complete all elements of the ESP 8 before re If this happens, the staff will continue to guidance.theinitialESPapplication(s). implement the program w Process issues i
der In addition to using the existing regulations for licensing tw facilit es u i
f 10 CFR Part 50, applicants for new nuclear power plants can ose a These lightly tested and new licensing procedures to resolve issues.
t S2, Appendix Q procedures inclade Part 52, Subpart A (early site pe The staff has not andPart52,SubpartC(combinedlicenses).
suitability);lications to test or refine the process since the Part 52 rules The staff expects to outline the process under the most received app ted likely licensing paths and to discuss the process with the public and were promulgated.
parties.
~-
~~
P PROGRAM PLAN iPs addresses each of.the issues identified in the SRM of April 9, 1991. The
,taff developed an approach that increases the attention on identifying the Therefore,theESP8willbebroaderthantheearlierscopingeffortstode'ge."
suite of iscues that could result in " problems at the combined license sta ine a reasonable universe of tasks to encompass.the full range of issues that-I i
should be considered if the requirements for nuclear power plant siting, environmental protection and emergency planning were to be visited anew. The NRC will likely reflect the knowledge gained from plant operating experience by allocating resources differently from past practice. For example, resource-intensive assessments were performed for certain postulated environmental impacts expected to due to plant operation that never materialized;. in other cases, there are more land use and environmental statutes that may require detailed investigation and review.
The NRC developed ESP 8 to revisit site-related. issues that had not been addressed recently and that need to be reconsidered if the NRC anticipates new applications. The ESP 8 addresses four types of issues:
Process Issues Technical Guidance Issues Human Resources Issues Development and Training Issues A brief sumary of the elements of the four types of issues is provided in a-discussion which follows. The lead responsibility for managing an ESP 8 task
- an reside with any of six offices. Certain tasks will require the participation of staff from a number of other offices or from sister agencies. However, the ESP 8 Program Manager will coordinate a number of these. initiatives. The 4
subsequent table provides the expected organizational involvement for each task.
The NRC is prepared to accept and review an application for an ESP and will _
continue to be prepared to review an application at any time.
If an application were to be submitted in the imediate future, the NRC could review that i
application under the existing regulations and with the staff and program support currently available. As time permits, the staff will enhance its capability to review a new application and the ESP 8 will provide the internal guidance. The staff may not complete all elenants of the ESPs before receiving the initial ESP application (s).
If this happens, the staff will continue to implement the program while performing the initial licensing reviews.
Process issues In addition to using the existing regulations for licensing new facilities under 10 CFR Part 50, applicants for new nuclear power plants can use a variety of lightly tested and new licensing procedures to resolve issues. These procedures include Part 52, Subpart A (early site pemits); Part 52, Appendix Q dearly site reviews); Part 2, Subpart F (early partial decisions on site suitability); and Part 52, Subpart C (combined licenses). The staff has not received applications to test or refine the process since the Part 52 rules The staff expects to outline the process under the most were promulgated.
likely licensing paths and to discuss the process with the public and 'Jnterested parties.
l l
This lack of interest and need has prompted the staff to delay or suspend a
.)
Suneer of regulatory initiatives.
In other cases, the NRC delayed new i
i tulemakings until severe accident rese:.ch is completed. The staff expects i'
that a nuder of rulemakings can now proceed. A number of States have i
instituted siting and energy facility permitting programs and may consider a cooperative arrangement with the NRC beneficial. A survey of the State processes will improve the NRC's understanding of extemal influences that may e
affect the ESP issues. Additionally, NRC denied one petition for rulemaking 1
(PRM-100-2) because it determined that "the need for additional rulemakings or
^
rule revisions will be considered in the context of a study on the readiness to j
resume licensing." With the transmittal of the study included in SECY-89-104,
)
i the steering group determined that the " issue was not mature enough for 1
resolution." The rulemakings included as tasks within the ESPs will include one j
additional task to specifically determine if the PRM should still be considered.
i l
Finally, Congress has enacted a nun 6er of new statutes regarding issues l
important to the ESP process over the last decade or more since a significant j
number of new applications were received. The staff expects to review the more than 30 Federal laws dealing with land use and environmental concerns j
j that may bear on the ESP process.
i Technical Guidance Issues j
i The staff will consider updating a number of guidance documeres that contein i
cbsolete material and that are affected by a number of rulemakings included in j
the ESP 8 These documents include some 50 regulatory guides in divisions 1 i
and 4 that touch upon ESP issues, assuming the current linkage between siting j.
and design; the Environmental Standard Review. Plans (NUREG-0555); the site safety subset of the Standard Review Plans (NUREG-0800); the Emerpency Planning i
Criteria (NUREG-0654) and the Standard Review Plan. The NRC shou,d establish l
specific criteria to define the conditions that warrant changes to regulatory l
guidance since the mere passage of time and accumulation of more data am insufficient bases to mandate change.
1 As part of the NES, the Council on Environmental Quality is charged with I
improving the guidance on energy facility siting; the ESP 8 will track NRC's i
l participation on the Energy Facility Siting Task Force and the staff will j
consider its findings in NRC's regulatory guidance. The NRC should make use i
of the lessons learned regarding siting and construction inspection; tasks are i
included to retain corporate experience and feed it back into the process to address and resolve a number of lingering issues such as early stage i
construction deficiencies and unresolved recossnendations of the Siting Policy Task Force. Likewise, sister agencies that have been active in the siting and environmental areas over the last decade could provide valuable insights to j
2 the NRC. Finally, to prepare for an ESP application, the staff could assist its PMs by developing a model for the managen.ent of an individual project (e.g.,
j the one resulting from the DOE-sponsored initiative) consistent with the overall i
ESP 8 concept and by updating the Project Manager's Handbook (NUREG/BR-0073).
l Human Resources issues During the 1980s, the mission of the NRC shifted from licensing to overseeing i
plant operations. A large percentage of staff members involved in siting and environmental issues moved into other mission and program areas, were il i
1 i
s retrained, or left the NRC altogether. Thus, the Office of Nuclear Reactor j
Regulation (NRR) no longer has a contingent of siting and environmental pecialists. Therefore, the ESP 8 includes tasks to ensure that NRR can gain
.ccess to "the core technical disciplines necessary to carry out the agency's l
mission," to develop a critical number of staff with the diversity of i
specialties and skills necessary to perform the agency's mission, and to j
develop Federal interagency agreements to assist the NRC in those specialty j
areas such as archeology that are far outside the NRC's realm of expertise.
i, I
The staff also recognized the importance of effective implementation of the program from the outset by integrating the ESP technical review and project management functions within a single operational unit. Thus, the Five Year j
Staffing Plan should program resources for the siting and environmental review i
j function and the resources to manage individual project ESP applications, i
Finally, program management of the ESP 8 pertains more.to human resources' l
management than any of the other. categories. Thus, the human resource category includes the task of coordinating and executing the ESPs, Development and Training Issues The staff should reevaluate the NRC's treatment of the ESP technical issues such as reacte siting (rather than engineering around deficiencies), and j
should embrace' environmental protection and sustainable development concepts.
4 i
The ESP issues are not the traditional "hard science and engineering" issues i
the NRC is accustomed to addressing. The ESPs identifies the NRC's existing
{
programs and future plans to train and develop staff and management. Basic skills are needed to make sound resource and policy ~ decisions affecting the ESP j),
issues, and expert skills are needed to withstand scrutiny as a hearing witness.
1' The full range of seminars, workshops with sister agencies, internal courses,.
and academic training opportunities may need to be considered to develop, f
i.
tprove and maintain the skill level of the agency's staff.
l RESOURCES
]
l A significant number of the tasks defined as elements of the ESPs have been f
approved by management, included in the Five Year Plan, and initiated. However, j
some tasks are new initiatives that require NRR/DAR/PDNP to initiate a task j
interface agreement if significant resources are to be applied by other units i
l within NRR or an interoffice agreement if significant resources are to be j
applied by other NRC units outside NRR. A comprehensive agreement may need to he instituted for many tasks. The staff will resolve task and resource l
co mitments during 1991.
i The staff will coordinate with the Office of the Controller to identify the j
manner in which resources will be affected by those tasks that are not 4
i accommodated within the current Five Year Plan or those that can be accommodated i
by reprograming. Management may need to determine the appropriate level of i
prior;ty of these tasks with respect to other program initiatives.
i i
i f
i
}
i 3
b i
ORGANIZATIONAL INVOLVEMENT IN TASK PLANS j
\\SK PLAN INTERNAL ORGANIZATIONS EXTERNAL ORGANIZATIONS GC NR R5 AE NM g G/5 01 OC CEQ FEMA DOI DOC EPA PROCESS ISSUES P-01 Review and Prepare Guidance for the Licensina Process (L) (x) ( ) ( ) ( ) ( ) ( ) ( ) (x)
()
()
()
()
()
l P-02 Review Land Use and Environmental Statutory Environment i
(t) (x) (x) ( ) ( ) (x) ( ) ( ) (x)
(x)
()
(x)
()
(x)
P-03 Rule: Alternative Site Reviews (x) (x) (L) ( ) (x) ( ) ( ) ( ) (x)
()
()
()
()
()
P-04 Rule: Decoupling of Siting and (x)(gn-Step)1()()()()()
()
()
()
()
()
Desi x) (L) (
P-05 Rule: Decoupling of Sitihg and (x) (gn - Step)2()()()()()
()
()
()
()
()
Desi i
x)(L)(
l P-06 Rule: Geosciences Siting Criteria Update (x) (x) (L) ( ) ( ) ( ) ( ) ( )'( )
()
()
(x)
-( )
()
'o
).
P-07 Rule: Clarification of Emergency (x)(x)_(L)()(ulations)()()()() ()
(x)
()
()
()
Preparedness Rec KEY:
z GC
- Office of the General Counsel NR
- Office of Nuclear Reactor Regulation i
l RS
- Office of Nuclear Regulatory Research AE
- Office for Analysis and Etaluation of Operational Data NM. - Office of Nuclear Material Safety and Safeguards G/F - Office of Governmental and Public Affairs / Federal Liaison G/S - Office of Governmental and Public Affairs / State Programs OP
- Office of Personnel DC
- Office of the Controller-CEQ - Council on Environmental Quality FEMA - Federal Emergency Management Agency DOI - Department of the Interior DOC - Department of Commerce EPA - Environmental Protection Agency L or x - Lead Responsibility or Participatory Involvement 4
m
.m- - -- -
er
.+-,e
t ORGANIZATIONAL IN'!0LVEMENT IN TASK PLANS ASK PLAN INTERNAL ORGANIZATIONS EXTERNAL ORGANIZATIONS GC NR R5 AE NM G/F 5/5 OP DC CEQ FEMA.
DOI DOC EPA PROCESS ISSUES i
1 P-08 Rule: Decoupling of EP Exercise from COL (x) (x) (L) ( ) ( ) ( ) ( ) ( ) ( )
()
(x)
()
()
()
P-09 Rule: Fuel Cycle and Transportation of Waste Environmental Data Uodate (x) (x) (L)-( ) (x) ( ) ( ) ( ) (x)
()
()
()
()
()
P-10 Petition for Rule: PIRG, Et Al on Population Density ( ) ( ) ( ) ( ) ( ) (~ )
'(-)
()
()
( )' ()
(x)(x)(L)
P-11 NRC and State' Interaction on Siting Issues
-(x) (x) ( ) ( ) ( ) ( ) (L) ( ) ( )
()
()
()
()
()
TECHNICAL GUIDANCE ISSUES T-01 Siting Lessons Learned Sussnary (x) (L) (x) ( ) ( ) ( ) ( ) ( ).(x)
()
()'()
()
()
(
T-02 Federal-Level Energy Facility Siting Task Force (x) (x) ( ) ( ) ( ) (L) ( ) (-) (-)
(x)
()
-(x)
(x)
(x)
)
T-03 Federal-Level Siting and Environmental IssuesWorkshop(x)()(x)(L)()()()
(x)
-( )
(x)
(x)
(x)
(x) (x)
KEY:
GC
- Office of the General Counsel NR
- Office of Nuclear Reactor Regulation RS
- Office of Nuclear Regulatory Research AE
- Office for An61ysis and Evaluation of Operational Data NM
- Office of Nuclear Material Safety and Safeguards G/F - Office of Governmental and Public Affairs / Federal Liaison G/S - Office of Governmental and Public Affairs / State Programs uv
- uffice of Personnel OC
- Office of the Controller CEQ - Council on Environmental Quality FEMA - Federal Emergency Management Agency l
DOI - Department of the Interior-DOC - Department of Commerce EPA - Environmental Protection Agency L or x - Lead Responsibility or Participatory Involvement
l ORGANIZATIONAL INVOLVEMENT IN TASK PLANS EXTERNAL ORGANIZATIONS j
- j GC NR R5 AE NM 5/F G/5 OP OC
\\
{ECHNICALGUIDANCEISSUES T-04 StandardReviewPlans(SRPs)and
}
Environmental SRPs Update l
(X) (L) (X) ( ) ( ) ( ) ( ) ( ) ( )
()
()
()
()
()
j T-05 Emergency Preparedness Evaluation Criteria Up(dateL) (X) ( ) ( ) ( ) ( ) ( ) ( )
()
(X)
()
()
()
(X) j T-06 Early Site Permit Issues Regulatory l
Guides Update j
(X) (X) (L) ( ) ( ) ( ) ( ) ( ) (X)
()
()
()
()
()
}
T-07 (Pre-) Construction Inspection Program Update i,
()(L)()()()()()()()
()
()
()
()
()
6 j
T-08 Model Project Mariagement%f an Early Site Permit (X) (L) ( ) ( ) ( ) ( ) ( ) ( ) (X)
()
()
()
()
()
j T-09 Project Mana er's Handbook Up(date)()(t()
()
()
()
()
( )-
(X) L) ( ) ( ) ( )
j e
i HUMAN RESOURCES ISSUES i
H-01 Early Site Permit Overall Program Management l
4:
()(L)()()()()()()()
()
()
()
()
()
i i.
KEY:
i GC
- Office of the General Counsel j
NR
- Office of Nuclear Reactor Regulation RS
- Office of Nuclear Regulatory Research AE
- Office for Analysis and Evaluation of Operational Data NM
- Office of Nuclear Material Safety and Safeguards G/F - Office of Governmental and Public Affairs / Federal Liaison l
G/S - Office of Governmental and Public Affairs / State Programs j
OP
- Office of Personnel i
OC
- Office of the Controller CEQ - Council on Environmental Quality i
FEMA - Federal Emergency Management Agency DOI - Department of the Interior DOC - Department of Comerce EPA - Environmental Protection Agency f
. or X - Lead Responsibility or Participatory Involvement t
I ORGAN 17AT10NAL 1NVOLVEMENT IN TASK PLANS
}
EXTERNAL ORGANIZATIONS iK PLAN INTERNAL ORGAN 17AT10NS GC NR R5 AE NM 5/F 5/5 OP OC CEQ FEMA DOI _ DOC EPA a
5 HUMAN RESOURCES ISSUES H-02 Maintaining Access to Siting and Environmental Expertise
()(L)(x)(x)(x)()()(x)()
()
()
()
()
()
i i
j H-03 Staff Augmentation in Early Site Permit Issue Areas
( ) (t) ( ) ( ) ( ) (-) ( ) ( ) ( )
()
()
()
()
()
i H-04 Federal Interagency Agreements on Early Site Pemit Issues (x) (x) ( ) ( ) ( ) (L) ( ) ( ) ( )
(x)
()
(x)
(x)
(x) i i
1 DEVELOPMENT AND TRANING ISSUES j
D-01 Seminar on Siting and Environmental I
(x) (x) ix) (L) k) ( ) ( ) ( ) (x)
()
()
()
()
( )~
Issues i
t f
D-02 Comprehensive Course on Early Site Permit Technical Issues (x) (x) (x) (L) ( ) ( ) ( ) ( ) (x)
()
()
()
()
()
l(
l D-03 Maintaining Early Site Permit Issues Expertise (x) (x) ( ) ( ) ( ) ( ) ( ) (L) ( )
()
()
()
()
()
i l
4 i
i-j t
j KEY:
GC
- Office of the General Counsel NR
- Office of Nuclear Reactor Regulation
- Office of Nuclear Regulatory Research j
RS
- Office for Analysis and Evaluation of Operational Data AE
- Office of Nuclear Material Safety ard Safeguards l
NM
- Office of Governmental and Public Affairs / Federal Liaison G/F
- Office of Governmental and Public Affairs / State Programs j,
G/S l
OP
- Office of Personnel OC
- Office of the Controller i
CEQ - Council on Environmental Quslity l
FEMA - Federal Emergency Ma.nagement Agency DOI - Department of the Interior
- i DOC - Department of Comerce EPA - Environmental Protection Agency L or x - Lead Responsibility or Participatory Involvement
TASK PLANS Tier 3 includes the working e individual plans for each ESP 3 task follow.
To obtain information
.evel documentation that can be released to the public.
e that is considered " Draft" or "Predecisional," the individW task manager should be contacted.
O j
f
\\
4 P-01
'l TASK PLAN:-
Review and Prepare Guidance for the Licensing Process CROSS
REFERENCE:
LEAD ORGANIZATION:
OGC ALTERNATE TITLE (S):
None DISCUSSION:
A National Energy Strategy goal calls for streamlining the licensing process and ensuring that there is stability and predictability in the process.
It is unlikely that a prospective applicant will consider venturing into the nuclear power arena in the near future without an improved understanding of the licensing options (i.e., Part 52, Subpart A; Part 52 ).
Subpart C; Part 52, Appendix Q; and Part 2, Subpart F A review of the guidance should be performed to determine whether additional information or interaction should take place with the public to clarify the regulatory process. The ocutanding legal interpretations under the concept of Res Judicata and Collateral Estoppel would be accomplished under this task.
(
IMPACT:
Absent revisiting the existing licensing process in the context of this~new licensing option, it is unlikely that stability and predictability will be improved.
KEY MILESTONES:
TBD STAFFING REQUIREMENTS:
FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
In mid 1991 initiate a request of OGC to determine whether and what additional guidance is needed to clarify the licensing process for the public and the staff approach to disseminate such information.
l l
P-02
,)
IASK PLAN:
Review Land Use and Environmental Statutory Environment CROSS
REFERENCE:
j LEAD ORGANIZATION:
OGC ALTERNATETITLE(5):
None DISCUSSION:
A significant change in the statutory environment has taken place since the last CP application was filed.
Site suitability and environmental issues may need to address a wide range of Federal statutes not previously considered.
It is recognized that jurisdiction may have been delegated to States for a n:nber of these i
statutes and that States may have enacted legislation affecting these areas as well.
It is essent'al to address the Federal regulatory requirements implementing the suite of relevant laws.-
IMPACT:
Absent a review by 0GC of the relevant environmental and.related statutes, and regulatory requirements of j
other Federal agencies, it is unlikely that the staff can adequately address the issues on its own.
KEY MILESTONES:
TBD STAFFING REQUIREMENTS:
FYP MISSION AREA:
RESOURCES:
l ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
In mid 1991 initiate a request of OGC for a comprehensive review of those statutes affecting the ESP program.
Coordinate NRR review of OGC paper on interpretation of applicability.
l 1
i
j l
P-03
- l(
TASK PLAN:
Rule-Alternative Site Reviews CROSS
REFERENCE:
]
ALTERNATE TITLE (S):
Licensing and Aegulatory Policy and Procedures for Environmental Protection, Alternative Site Reviews l
DISCUSSION:
Reinitiate rulemaking to amend Part 51 regulations to
{
provide procedures and performance criteria for the review of alternative sites for nuclear power plants i
under the National Environmental Policy Act (NEPA).
Proposed rule was published on April 9, 1980; i
rulemaking was terminated on July 10, 1986.
Alternative site issue needs to be codified to i
j resolve NEPA issue on siting of facility.- When addressed, the scope should consider the requirements i
of the other siting programs in the NRC (e.g., low j
level waste disposal).
IMPACT:
Absent action, the licensing requirements for an environmental review prior to granting and Early Site Permit would remain ambiguous.
II KEY MILESTONES:
IIRR to work with itM55 to determine the scope of i
rulemaking request for RES in late 1991.
Proposed Rule to Commission in mid 1992.
j Final Rule to Counission in mid 1993.
1 i
STAFFING REQUIREMENTS:
TBD FYP MISSION AREA:
]
RESOURCES:
j ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
In mid 1991 initiate coordination with NMSS (low-level 4
waste siting) for rulemaking request.
In late 1991 prepara user need request.
j Coordinate effort within_NRR and participate in i
rulemaking effort.
4 4
i 1
i
P-04 4
(
ASK PLAN:
Rule: Decoupling of Siting and Design - Step 1 CROSS
REFERENCE:
RIN 3150-AD92 RM 267 l
~
tEAD ORGANIZATION:
RES/DSIR/SAIB j
ALTERNATE TITLE (S):
Change to Part 100 -to Add Site Criteria, Update Appendix A and Remove Dose Calculations; Interim Change to Part 50 to Add Source Term and Dose Calculations DISCUSSION:
Rulemaking initiative to amend Part 100 and Part 50 regulations to decouple the source term and dose calculations from reactor siting (Part 100). This task will remove the current design element of siting and consequently focus ESP's on ktrictly siting elements. The primary activities involve the procedural shift of a number of Part 100 issues to Part 50 and the codification of the criteria articulated in R.G. 4.7.
4 IMPACT:
Absent action, the staff will continue to use the 1962 Technical Information Document (TID) 14844 source terms and Part 100 dose values for siting purposes.
If task is on schedule, it is likely to have a beneficial impact on the ESP program; if it i
becomes a contentious issue and is delayed, the initial ESP's must continue to perform the dose assessments under current practice.
KEY MILESTONES:
Proposed Rule to Commission in early 1992.
Final Rule to Commission in early 1993.
ST7fFING REQUIREMENTS:
Already included in Five Year Plan.
FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
Coordinate effort within NRR (primarily with DREP) and participate in rulemaking effort.
4 a
.n--,
y,-
s
~
pq
.ASK PLAN:
Rula: Decoupling of Siting and Design -
ep 2 CROSS
REFERENCE:
RIN 3150-AD91 RM 268 LEAD ORGANIZATION:
RES/DSIR/SAIB ALTERNATE TITLE (S):
Change to Part '5D to update Source Term and Replace Dose Calculation DISCUSSION:
Extend rulemaking initiative to amend the Part 50 regulations that were transferred from the Part 100 i
regulations in Step 1 (i.e., design elements decoupled from siting) and to use the updated source term insights (from NUREG-1150) for advanced and evolutionary LWR's. This task will introduce additional tequirements for future LWR's regarding Severe Accidest Mitigation Design Alternatives (SAMDA).
IMPACT:
Absent action, the staff will continue to use the
~
1962 Technical Information Document (TID) 14844 source terms and Part 100 dose values for siting purposes. If task is on schedule, it is likely to have a beneficial impact on the ESP program; if it becomes e contentious issue ud is delayed, the initial ESP's must continue to perform the dose assessments onder current practice.
KEY MILESTONES:
Proposed Rule to Commission in late 1992.
i Final Rule to Comission in late 1993.
STAFFING REQUIREMENTS:
Already included in Five Year Plan.
FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
Coordinate effort within NRR (primarily with DREP) and participate in rulemaking effort.
e
P-06 i
ASK PLAN:
Rule: Geosciences Criteria Update CROSS
REFERENCE:
RIN 3150-AD93 RM 147 LEAD ORGANIZATION:
RES/DE/SSEB ALTERNATE TITLE (S):
Seismic and Geological Siting Criteria for Nuclear Power Plants DISCUSSION:
Rulemaking initiative to amend Part 100 and Part 50 regulations to improve currency, to provide general guidance in Part 100, and to shift detailed information to regulatory guides and standard review plans. Criteria not associated with site selection or establistcent of the safe shutdown earthquake would be transferred to Part 50.
IMPACT:
Absent action, the staff will necessarily continue to 4
use Part 100, Appendix A.
The proposed revision would help avoid unnecessary delays in the licensing process.
KEY MILESTONES:
Proposed Rule to Commission in late 1991.
Final' Rule to Commission in late 1992.
STAFFING REQUIREMENTS:
Already included in Five Year Plan.
FYP MISSIDH AREA:
~
RESOURCES:
ESTIKATED EFFORT:
NRR/DAR/PUNP ACTION:
Coordinate effort within NRR (primarily with DET) and participate in rulemaking effort.
O f
4 g
i P-07 4
j
.SK PLAN:
Rule: Clarification of Emergency Preparedness Regulations J
CROSS
REFERENCE:
RIN 3150-AD40 RM 200 1
l LEAD ORGANIZATION:
RES/DSIR/SAIB ALTERNATETITLE(S):
l Rulemaking initiative to amend Part 50 regulations to
}
DfSCUSSION:
clarify the linkage between the " reasonable assurance" clause and the 16 planning standards in j
50.47(a) and (b), and clarify terms that include
{
" range of protective actions," monitoring of j
evacuees, actions for recovery and reentry, i
notification of the public, evacuation time j
l'-
estimates, and exercise frequency.
Absent action, the Comission is concerned that there j
IMPACT:
is some ambiguity in the exercise scope prior to full I
power licensing.
KEY MILESTONES:
Proposed Rule to Comission in early 1992.
Final Rule to Comission in mid 1993.
STAFFING REQUIREMENTS:
Already included in Five Year Plan.
i j
FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFORT:
Maintain awareness of NRR participation (primarily l
NRR/DAR/PDNP ACTION:
DREP) and participate in rulemaking effort, if
{
i requested.
i 5
i l
~
l 1
l
.l
't 7.
y
1 i
)
l
^
P-08
- '(
(ASK PLAN:
Rule: Decoupling of EP Exercise from COL CROSS
REFERENCE:
RIN 3150-AD48 i
RM 201 l
LEAD ORGANIZATION:
RES/DSIR/SAIB 1
l ALTERNATE TITLE (S):
Emergency Planning Regulations for Part 52 Licensing 4
DISCUSSION:
Rulemaking initiative to amend Part 50 regulations /to decouple those portions of emergency plans which Cdnnot be exercised prior to issuance of a Part 52 combined license.
IMPACT:
Absent action, the licensing requirements for an emergency preparedness exercise prior to a COL is 3
ambiguous, j
KEY MILESTONES:
Proposed Rule with the Commission (since early 1990).
Final Rule to Commission one year after action.
1 STAFFING REQUIREMENTS:
Already included in Five Year Plan.
i FYP NISSION AREA:
4 RESOURCES:
S 4
i ESTIMATED EFFORT:
1 i
j NRR/DAR/PDNP ACTION:
Maintain awareness of progress of issue and participate in rulemaking effort if requested.
I i
1 I
i i
i 4
i l
i
P-09 TASK PLAN:
Rule: Fuel Cycle and Transportation of Waste Environmental Data Update CROSS
REFERENCE:
RES/DRA/RDB ALTERNATE TITLE (S):
Amendment to 10 CFR 51.51 and 51.52, Tables S-3 and S-4, Addition of Radon-222 and Technetium-99 Radiation Values, and Addition of Appendix B.
DISCUSSION:
Rulemaking initiated to amend Part 51 regulations to update uranium fuel cycle data and transportation of fuel and waste environmental data. This task should also consider the currency of earlier estimates and the range of environmental data applicable for advanced and evolutionary designs.
IMPACT:
An applicant would need to submit an assessment demonstrating that it would fall within the envelope
~
of the assumptions outlined in the existing regulations. This could be resolved on a generic basis in the same manner as the 551.51 and 151.52 generic rulemaking. Though not essential, it would be useful to update.the environmental data to reflect
(
current emission information and the two species not previously resolved.
KEY MILESTONES:
NRR to work with NMSS to determine whether to press for completion of this task in late 1991.
Proposed and Final Rule predicated on decision of above.
l STAFFING REQUIREMENTS:
Proposed rulemaking is proceeding based on available resources, no specific schedule has been established for completion.
FYP MISSION AREA:
l RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
In late 1991 initiate coordination with NMSS to determine whether rulemaking is important for ESP effort.
If so, in early 1992 prepare user need request.
Coordinate effort within NRR and participate,in l
rulemaking effort.
l
/
l 4
4 i
P-10 Petition for Rule: PIRG, Et Al on Population Density (ASK FLAN:
i CROSS
REFERENCE:
PRM 100-2 SRM 10/20/88 LEAD ORGANIZATION:
RES/DSIR/SAIB I
ALTERNATE TITLE (S):
None DISCUSSION:
PIRG, et al., filed a petition for rulemaking on June 1, 1976, to set numerical limits on allowable j
population density around nuclear power plant sites.
In denying the PRM on November 29, 1988, the EDO on behalf of the Consission, stated that "the need for additional rulemakings or-rule revision will be considered in the context of a study on the readiness to resume licensing..." On February 24, 1989, the
~
i i
" Report on NRC Readiness to Process Future Applications for Construction Permits or Operating Licenses" determined that the " issue was not mature enough for resolution..." at that time.. This task is to detemine whether additional rulemakings, other than those already identified in other tasks, are necessary for the next generation of applications, i
IMPACT:
A considerable numbir of rulemaking efforts are envisioned to address concerns of the ESP program; in 2
the absence of a reaffirmation that the NRC has adequately considered the merits of the petition for 1
- i rulemaking, it is not clear that this issue would have been resolved.
KEY MILESTONES:
TBD STAFFING REQUIREMENTS:
FYP MISSION AREA:
RESOURCES:
4 ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
In late 1991 initiate a request for RES to determine i
whether the issue outlined in the petition is subsumed by planned actions, whether it could be, or whether it should be.
If there is to be a rulemaking, participate in the process.
a z
P-11
(
TASK PLAN:
NRC and State Interaction on Siting Issues l
CROSWEFERENCE:
Hemo June 19, 1991 NUREG's-0195-0204
)
NUREG-1052 State Perspectives on Energy Facility Siting -
Current State Practices State Perspectives on Energy Facility Siting -
Polic;y Directions LEAD ORGANIZATION:
SPA /SP ALTERNATETITLE(S):
Statt involvement in Reactor Licensing DISCUSSION:
It was recogniz6d under the Part 52 rulemaking that the NRC's ESP regulations would enable State and local agencies to participate effectively in an ESP.
)
Many States have instituted siting programs of their own and have legislation end regulations that can result in a parallel licensing process as that-in Part 52 or Part 50. GPA/SP is exploring various methods for identifying State siting laws, regulations,
-and organizations to identify any issues where State-NRC cooperative actions could enhance and stabilize the regulatory process.
IMPACT:
For those matters where the NRC and a State agency have mutual jurisdiction and concerns, the l
opportunities for a cooperative arrangement could substantially reduce the duplication of effort and increase the efficiency of the use of resources of Federal, State, and other entities. This review j
would benefit the NRC as well as State and local entities in defining the breadth of cooperative arrangements that can be agreed upon and afford a measure of stability on the scope issues.
KEY MILESTONES:
GPA/SP program plan development in mid 1991.
4 Draft interim Interagency Task Force (see T-02) report in late 1991.
Final Interagency Task Force report in mid 1992.
STAFFING REQUIREMENTS:
TBD FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
NRR to work with GPA/SP and OGC in to outline the scope and level of support for SP dialogue with State and local officials.
3 T-01 l
l j i.,
/ASK PLAN:
Siting Lessons Learned Sunnary Report CROSS
REFERENCE:
NUREG-0625 - Report of the Siting Policy Task Force LEAD ORGANIZATION:
NRR/DAR/PDNP l
ALTERNATETITLE(S):
None DISCUSSION:
The NRC had initiated a Siting Policy Task Force to l
assess the siting policy established in 1962; in the
(
absence of new applications and the fallout after the i
TMI event, there was little effort to revisit the siting issue until the recent Part 52 rulemaking. As site analysis work was depleted it was envisioned j
that the regulatory lessons learned by the first generation of site analysts would be documented for future consideration. This task would capture the corporate lessons learned emphasizieg the regulatory 4
experience of licensing reviews and plant operational l
. performance.
IMPACT:
Absent action, the staff will continue to review to the level of detail and consume resources based on
!j the experience of the most recent CP and OL i
applications. Updates of SRPs and ESRPs may not
!(
adequately capture c~orporate knowledge without a structured task to reflect on lessons learned.
l Issues raised in NUREG-0625 which were not included j
in the recent Part 52 rulemaking should not go j
unresolved and become the subject of-litigation.
l KEY MILESTONES:
Identification of Lessons Learned-Working Group and l
Group Leader in late 1991.
l Final Report to Direc+' r PDNP in early 1992.
i l
STAFFING REQUIREMENTS:
FYP MISSION AREA:
4
)
RESOURCES:
Working Group comprised of four (4) ex-Site Analysts i
and one (1) Environmental Health Physicist from NRR j
and RES; Group Leader to be one of the ex-Site J.
Analysts.
2
)
ESTIMATED EFFORT:
Group Members - 0.3 FTE i
Group Leader - 0.3 TTE j-Total Effort: 0.6 FTE i
NRR/DAR/PDNP ACTION:
Provide administrative support for Group Lead'er.
f Coordinate with PMAS for SRP and ESRP updates.
L i
1 4
T-02
)
.1 TASK PLAN:
Federal-Level Energy Facility Siting Task Force CROSS
REFERENCE:
National Energy Strategy Memo June 20, 1991 LEAD ORGANIZATION:
GPA/FL ALTERNATETITLE(S):
None J
DISCUSSION:
The Council on Environmental Quality is charged with the responsibility under the NES to coordinate an Interagency Task Force effort on energy facility siting.
1
)
IMPACT:
Although NRC may not have current experience in i
facility siting, its historical perspective and the i
controversial nature _ of the commodity will provide J
useful insights. Absent participation, the NRC would j
have no significant opportunity _to contribute to the Task Force report.
KEY MILESTONES:
Draft interim report in late 1991.
Draft final report in early 1992.
Final report to the Economic Development Council in mid 1992.
l STAFFING REQUIREMENTS:
TBD FYP MISSION AREA:
4 t
i RESOURCES:
~
i ESTIMATED EFFORT:
l NRR/DAR/PDNP ACTION:
Support GPA in their role as Interagency Task Force a
member; participate as requested.
l i
i 1
-1 e
1 d
i l
T-03 iASK PLAN:
Federal-Level Siting and Environnental Issues Workshop CROS$
REFERENCE:
LEAD ORGANIZATION:
GPA/FL ALTERNATETITLE(S):
None DISCUSSION:
Numerous Federal statutes and implementing regulations affecting siting and environmental issues have been enacted, promulgated, or amended since the last generation of NRC's licensing of nuclear power plants. Other Federal agencies have current experience that would be invaluable to the NRC. This task, coordinated by the NRC's Federal Liaison (GPA/FL) in concert with the Council on Environmental Quality (CEQ), would help' define the current universe of ecological and social issues that are relevant to the ESP program and would improve the understanding of their treatment by sister Federal agencies.
IMPACT:
The insights gained by sister Federal agencies over the last decade in dealing with NEPA-like issues l
would be of particular importance for NRC staff involved in a program (ESP) that is emerging into an existing environment. Absent an opportunity to f
improve the NRC's understanding of the current climate for major Federal actions, the staff will i
operate on the basis of prior experience.
l KEY MILESTONES:
GPA/FL and CEQ to begin discussions in late 1991 to conduct a workshop for NRR, RES, and OGC staff I
involved in the ESP program.
GPA/FL to host workshop in mid 1992.
STAFFING REQUIREMENTS:
TBD FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
In late 1991 assist GPA/FL in defining scope of needs and workshop forum.
Coordinate participation of NRC staff.
I
T-04 TASK PLAN:
Standard Review Plans (SRPs) and Environmental SRPs Update CROSS
REFERENCE:
TAC 40047 FIN 1-1858 NUREG-0800 NUREG-0555 LEAD ORGANIZATION:
NRR/PMAS/PTSB ALTERNATE TITLE (S):
Technical Assistance in Support of the Standard ReviewPlanUpdateandDevelopmentProgram(SRP-UDP)
DISCUSSION:
As part of the overall program to ensure that the NRC saintains the capability to thoroughly review a future nuclear power plant license application, the NRC will review and update the Standard Review Plan (NUREG-0800) and the Environmental Standard Review-Plan (NUREG-0555)torefivetexistingrequirements contained in NRC regulations, regulatory guides, I
technical specifications, letters, bulletins, etc.
The (E)SRPs will also be revised to contain necessary review criteria for future reactors or reactivated plants.-
f IMPACT:
ESRPs have not been' updated'since 1979 and SRPs governing the site suitability and emergency preparedness issues have not been updated since 1981.
In a number of areas (e.g., geosciences) significant chances in technology and assessment methods warrant inclusion in the review guidance to reflect current practice and policy. Absent action, the staff will continue to use outdated review guidance and guidance that is preliminary in nature Le.g., alternative sites).
KEY MILESTONES:
Develop Guidance Document in mid 1991.
Undertake Pilot Programs in mid 1991.
Reviewdocumentsforinclusionin(E)SRPs(ongoing).
STAFFING REQUIREMENTS:
Already included in Five Year Plan.
FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
Participate as lead contact for the entire ESRP and primary or secondary contact for site suitability and emergency preparedness issues.
T-05
(
(ASK PLAN:
Emergenry Preparedness Evaluation Criteria Update CROSS
REFERENCE:
SRM April 9.1991 NUREG-0654 LEAD ORGANIZATION:
NRR/DREP/EPB ALTERNATETITLE(S):
None DISCUSSION:
The regulations related to the emergency preparedness elements of an ESP application affords three options at 152.17(b). This task will define the planning standards and evaluation criteria to clarify the "significant impediments" and " major features" terminology for the "obviously superior" and alternative sites as a supplement to NUREG-0654.
IMPACT:
Absent action, there will be uncertainty in the standards the NRC would use to review conformance with the regulations.
KEY MILESTONES:
Proposed Supplement for Public Comment in late 1991.
Published Final in late 1992.
STAFFING REQUIREMENTS:
Already included in Five Year Plan.
FYP MISSION AREA:
Working Group comprised of two (2) Emergency ) FEMA RESOURCES:
Preparedness Specialists from DREP and two (2 1
1 representatives; Group Leader to be one of the DREP
~
staff members.
ESTIMATED EFf0RT:
Total Effort: 1.7 FTE HRR/DAK/PDNP ACTION:
Maintain awareness of MRR actions and participate in working group meetings.
l 9
.f,
--_z_,
-=
T-06 ASK PLAN:
Early Site Permit Issues Regulatory Guides Update CROSS
REFERENCE:
~
LEAD ORGANIZATION:
RES/DRA/ARGIB ALTERNATETITLE(S):
flone DISCUSSION:
flearly 5D Regulatory Guides (in Divisions 1 and 4) have a direct or indirect bearing on siting, environmental, or emergency planning issues related to power reactors. In the assence of the rulemaking decoupling siting from design, each of these should be reviewed to determine whether it is necessary to update or otherwise modify the guidance; this would be even more compelling with the completion of the i
rulemaking. The mere passage of a decade and existence of new data, information, and/or methods are insufficient bases to require an update. The criteria defining the conditions that would require a.
substantive change in regulatory guidance need to be established.
i i
IMPACT:
Having no rompelling Teason 1:o update the siting and l
environmental regulatory guides, little effort was made over the last decade to maintain currency.
Absent action, the Agency's guidance will continue to be outdated.
l KEY MILESTONES:
Individual schedules to be established.
l STAFFING REQUIREMENTS:
A limited number of resources may already be included in Five Year Plan.
FYP MISSION AREA:
l RESOURCES:
l ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
Support PMAS staff in coordinating this effort in NRR.
I~
4 I
l I
-.u
.,>_n.
T-07 lASK PLAN:
(Pre-) Construction Inspection Program Update CROSS
REFERENCE:
Memo June 13, 1991 IMC-2511 IMC-2512
~
LEAD ORGANIZATION:
NRR/PMAS/ILPB ALTERNATE TITLE (5):
None j
DISCUSSION:
As part of the overall program to ensure that the NRC maintains the capability to thoroughly review a future nuclear power license application, the NRC will review the existing construction inspection program.
IMC-2511 has not been revisited since 1978 and IMC-2512 since 1986. This task, originally i
focused on IMC-2512, has been broadened to include IMC-2511. Site preparation work under a LWA-1, Environmental Protection Inspection, and Site Redress Plan need to be revisited as part of this task.
IMPACT:
Primary concerns related to construction deficiencies found by CAT or other team inspections late in the construction process. A project seeking an ESP may j
be a deferred or cancelled plant with an unknown
\\
status of quality activities. Lessons learned over the past decade need to be incorporated into the inspection program.
KEY MILESTONES:
Working group meeting in mid 1991.
Publish draft modules-in late 1992.
STAFFING REQUIREMENTS:
Already included in Five Year Plan.
l FYP MISSION AREA:
RESOURCES:
Working Group comprised of HQ and Regional construction inspection specialists.
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
Maintain awareness of NRR actions and participate in working group meetings through DAR contact.
4 i
T-08 i
fk lASK PLAN:
Model Project Management of an Early Site Permit j
CROSS
REFERENCE:
NUREG/BR-0073 - Project Manager's Handbook NUREG-0180 - Early Site Reviews for Nuclear Power
~
Facilities (DRAFT)
LEAD ORGANIZATION:
NRR/DAR/PONP i
ALTERNATE TITLE (S):
None DISCUSSION:
The NRC has insufficient experience in exercising the j
licensing processes available for the early resolution of site related issues. A number of areas are expected to break new ground in the licensing i
review, project management, and hearing processes; it is important to develop the framework for the practice, procedures, and review options. The experienced licensing project managers and hearing counsels should formulate the template for a typical ESP for a variety 4
of cases (green site, reactivated site with or without i
a CP, etc.).
IMPACT:
Absent action, the staff will continue to follow an outmoded practice based on the CP/0L process. A detailed project plan could bridge the gap from the concept spelled outain the regulations to a schedular 4
and conmitment framework in practice. Without a structured task to capture the corporate knowledge and establish the framework, the first one or more applications would be treated on a non-standard basis.
i KEY MILESTONES:
Identification of Project Management Working Group and Group Leader in late 1991.
]
Final Report to Director, in mid 1992.
STAFFING REQUIREMENTS:
2 FYP MISSION AREA:
l RESOURCES:
Working Group comprised of two (2) senior licensing
~
project managers, one (1) ex-environmental project manager, and two (2) counselors. The Group Leader would be from~0GC.
ESTIMATED EFFORT:
Group Members - 0.3 FTE Group Leader - 0.3 FTE Total Effort: 0.6 FTE NRR/DAR/PDNP ACTION:
Provide administrative support for Group Leader and participate as requested.
i
~
T-09 k
TASK PLAN:
Project Manager's Handbook Update CROSS
REFERENCE:
WUREG/8R-0073 - Project Manager's Handbook LEAD ORGANIZATION:
NRR/PMAS ALTERNATETITLE(S):
None DISCUSSION:
The early site permit and combined operating license processes will evolve with the development of the program. These need to be reflected in the formal guidance provided to the staff and made available to the general public.
IMPACT:
Absent action, the staff will have inconsistent guidance for the treatment of licensing activities under the new licensing regime. i KEY MILESTONES:
Draft Update to ADP in mid 1992.
Final Update to ADP in late 1992.
STAFFING REQUIREMENTS:
Already included in Five Year Plan.
FYP MISSION AREA:
o RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
Provide technical and model project management insights to staff and participate as requested.
I t
I
L
~ '.
)
i j
H-01 1
a;
)
TASK PLAN:
Early Site Permit Overall Program Management I
CROSS
REFERENCE:
SECY-91-D41 4
j LEAD CRGANIZATION:
NRR/DAR/PDNP 1
l ALTERNATE TITLE (S):
None DISCUSSION:
As outlined in SECY-91-041, a Senior Project Manager would be designated as the overall ESP Program Manager i
to develop the ESP 8, manage, coordinate, and participate in all matters related to the ESP program l
and the DOE-sponsored pilot program to test the Part 52, ESP process. A variety of miscellaneous issues (relationship of ESP issues to severe accident i
program /SAMDA's, relationship of Subpart A issues to
]
the balance of Part 52, etc.) warrant tracking and.
courdination; should such issues evolve to the level j
requiring promotion to a discrete task, it would fall within the responsibility of the ESP Program Manager.
3 t
i IMPACT:
In spite of the DOE pilot program to test the Part 52 process and the lack of interest demonstrated by industry, there are a significant number of tasks
- (
that need to be undertaken to enhance the NRC's capability to review future license applications.
i i j
Absent a central focus, the tasks would lack j
direction and accountability within NRR.
KEY MILESTONES:
Periodic status report for individual task plans.
4 Routine coordination among NRC offices.
j Cooperation with DOE counterpart and interaction with other Federal agencies through GPA/FL.
STAf g REQUIREMENTS:
Already included ir. Five Year Plan.
FYP MISSION AREA:
i RESOURCES:
4 l
ESTIMATED EFFORT:
4 t
NRR/DAR/PDNP ACTION:
Designate the ESP Program Manager and coordinate the i
ESP 3 i
i 5
H-02 i
- -i',
TASK PLAN:
Maintaining Access to Siting and Environmental f
Expertise j
CROSS
REFERENCE:
SRM April 9, 1991 NRR OL 906 i
)
j LEAD ORGANIZATION:
NRR/DAR/PDNP ALTERNATETITLE(S):
None i
DISCUSSION:
As the agency shifted from a licensing mode to an J
operational oversight mode, significant corporate expertise was lost with the reassignment and 2
i departure of staff. While there remains a token level af work in the site safety and environmental areas, it is generally performed by project managers with the advice and support of those with technical expertise. NRR recognized the importance of ensuring that it maintained access to such expertise; pursuant 3
l to NRR Office Letter 906, the environmental designee will establish and maintain the roster of siting and i
environmental specialists who may be called upon to i
assist in developing regulatory guidance, conducting licensing reviews, and training agency staff in their j
area of expertise. "This task will require the update i
of this roster on a quarterly basis, j
l IMPACT:
Absent maintaining access to agency assets with key expertise, NRR would rely upon contractor support to 2
conduct reviews, develop regulatory guidance, and 1
i oversee research. This is inconsistent with the Commission's direction for maintaining the capability to review an ESP.
1 I
KEY MILESTONES:
NRR environmental designee to publish quarterly j
updates of the roster of agency experts in site I
safety and environmental areas.
STAFFING REQUIREMENTS:
Already included in Five Year Plan.
1 1
i FYP MISSION AREA:
RESOURCES:
i ESTIMATED EFFORT:
l NRR/DAR/PDNP ACTION:
In mid 1991 request of OP personnel data base search of staff with designated technical specialties.
}
Identify environmental designee and publish quarterly updates of roster.
4
\\
)
i
i j
H-03
/
i
.ASK PLAN:
Staff Augmentation in Early Site Permit Issues Areas 3
CROS$
REFERENCE:
SRM April 9, 1991 LEAD ORGANIZATION:
NRR/DAR/PDNP ALTERNATETITLE(S):
None DISCUSSION:
Planning for long-term staff augmentation specifically for ESP applications is not meaningful since none have been submitted and none are foreseeable on the short-term planning horizon. A rational approach for staff augmentation involves 1) a reassessment of the environmental mission in PDNP; 2) the return of review responsibility (6ndrecaptureoffractionalFTE's)for i
the operating plant EA and EIS workload to the environmental mission area (PDNP); and 3) the actual rwviews for all new site safety and environmental issues for each progrannatic initiative (including licenserenewal).
Implemented in stages and based on.
prior experience and projections, the activities should be sufficient for a base workload for a critical number of siting and environmental specialists.
Built upon a base workload, an ESP application would be reviewed only to the level of detail warranted.
k IMPACT:
Absent a base workload, staffing up in anticipation of an application may result in staff review at a level of detail that is unwarranted for the program. Assembling a staff only subsequent to submittal od an application could result in an inappropriate mix of specialists and lacking experience to complete the review and hearing on schedule.
KEY MILESTONES:
Redefine NRR siting and environmental responsibilities in late 1991.
Begin staff augmentation in late 1991 and continue pace supported by backlog, workload, and new staff.
Reassessment of project management and technical review activities.
STAFFING REOUIREMENTS:
TBD FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
In late 1991 initiate DONRR directive on work'ioad.
Participate in development of Five Year Staffing Plan.
/
j H-04 4
I' TASK PLAN:
Federal Interagency Agreements on Early Site Permit Issues
)
j CROSS
REFERENCE:
m j
LEAD ORGANIZATION:
GPA/FL i
ALTERNATETITLE(S):
None i
l DISCUSSION:
Consistent with past practice, the NRC is unlikely to 1
undertake certain review activities related to the ESP program for those areas of responsibility which i
overlap with other Federal apncies and covered by a Memorandum of Understanding.,e.g., the Corps of Engineers), or where the issues are far outside the realm of the agency's mission and expertise (e.g., the American Antiquities Act). While the NRC will i
ultimately remain responsible for the assessment of j
the potential impact of the agu cy action, it may be i
i better served by utilizing thz expertise that exists ~
elsewhere in the Federal Govemment. This task would identify candidate areas for the Commission's j
consideration and then pursue an intersgency i
agreement or Memorandum of Understanding.
i(
IMPACT:
The diversity of sp5cialists and the depth of expertise l
required to review certain issues and participate in j
the hearing process for an ESP has been estimated on the basis of prior experiet:e. There is some uncertainty with the level 9f effort and variety of areas that must be considered. Absent an early initiation of a dialogue with other Federal agencies i
for assistance or to minimize duplication of effort, the NRC may delay an ESP that it is obligated to l
review thoroughly.
1 KEY MILESTONES:
GPA/FAC to initiate dialogue in late 1991 to identify candidate agencies for cooperative arrangements.
3 Options Paper to Comission in mid 1992.
Cooperative arrangements in place in late 1993.
i
]
STAFFING REQUIREMENTS:
!~
FYP MISSION AREA:
I RESOURCES:
s ESTIETED EFFORT:
WRR/DAR/PDNP ACTION:
In early 1992 ass *.st GPA/FAC to define scope knd level i
of support sought.
j Assist in negotiating interagency agreements for those candidate issues accepted by the Comission.
i
D-01 (ASK PLArt:
Seminar on Siting and Environmental Issues CROS5
REFERENCE:
SRM April 9, 1991 LEAD ORGANIZATION:
AE0D/DOA/TTC 1
j i
ALTERNATE TITLE (5):
None l
DISCUSSION:
A general overview on siting and environmental
{
statutes, regulations, and technical issues is warranted for the Agency as a whole (low-level waste i
disposal siting,) license m newal environmental j
assessment, etc. and NRR staff and management i
peripherally involved in the ESP process in i
particular. It is envisioned that a i day seminar would serve as the overview or as a refresher for 4
those involved in the last generation of licensing.
This wwTd become a module that could be incorporated i
into a foral NRC training course or stand alone as a j
~
seminar on Siting, NEPA Compliance, and Environmental Regulations.
IMPACT:
Absent a formal program to heighten the awareness of the staff and senior managers of the importance of.
}(
siting and environmental protection as serious public policy matters, it is unlikely that these issues will i
gain the level of credibility within the agency for a successful program, i
i KEY MILESTONES:
TTC to contract for or otherwise develop a suminar on i
Siting, NEPA Compliance, and Environmental i
Regulations in late 1992.
]
Include seminar as part of training curricula for NRC staff in early 1993.
4 i
STAFFING REQUIREMENTS:
TBD l
FYP MISSION AREA:
3 RESOURCES:
ESTIMATED EFFORT:
WRR/DAR/PDNP ACTION:
In late 1991 participate with NRR Training Advisory Group in discussions with the Technical Training Center to define training neds for general staff and senior managers and schedular needs.
3 i
i D-02 l [
TASK PLAN:
Comprehensive Course on Early Site Permit Technical Issues CROSS
REFERENCE:
SRM April 9, 1991 LEAD ORGANIZATION:
AE0D/D0A/TTC ALTERNATE TITLE (S):
None DISCUSSION:
The Commission expressed concern regarding the i
erosion of the staff technical capability as it j
embarks on the ESP program. A comprehensive course j
onESPelements(siting,environmentalandemergency
[
planning issues and the hearing process) addressing the Wtutes, sAtuiti. urdsrs eild inter 69 hcy v
i responsibilities, and regulations is necessary for i
the ESP project managers and the technical review r
i staff supporting ESP s.
It is envisioned that a 3-4 day course offered periodically would provide the introduction to the staff seabers who would be j
heavily involved in the ESP program.
1 IMPACT _:
It is essential to recognize that the ESP program represents the next generation of licensing within i
the NRC. Only a limited-number of individuals j(
experienced in the ESP issues remain on the staff at I
the level to manage a project or perform technical i
reviews.
It is realistic to at:ticipate that those j
who will be involved in the ESP program will have j
little hands-on experience on the issues.
KEY MILESTONES:
TTC to develop a course for ESP project managers and i
technical reviewers in early 1993.
{
Include course as a requirement of the job analysis j
for NRC staff involved in ESP in late 1993.
j STAFFING REQUIREMENTS:
TBD 1
4 i
FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFORT:
NRR/DAR/PDNP ACTION:
In late 1991 participate with NRR Training Advisory i
Group in discussions with the Technical Training center i
to define training needs for ESP project managers and technical reviewers and schedular needs.
i i
i 1
D-03
,l l
TASK PLAN:
Maintaining Early Site Pemit Issues Expertise CROSS
REFERENCE:
SECY-91-016 DT-91-902 Career Planning USNRC/0P LEAD ORGANIZATION:
OP ALTERNATE TITLE (S):
Technical Recruitment, Development, and Retention Planning and Japlementation/NRC Career Management System DISCUSSION:
The Comission expressed concern regarding the' erosion of the staff technical capability as it embarks on the ESP program. As workloads increase in'the siting, snvironmantal and emergency preparedness areas, it is important to ensure the staff has professional growth opportunities to maintain and improve its capability.
Jl As part of the NRC's human resources strategic planning process, OP will be issuing a five year staffing plan-call. In the five year staffing plan, managers should be identifying staffing / skills requirements for the outyears. Based on plan projections', OP will modify the career management s stem's recruitment, development and retention programs uch as the Intern or Graduate 4
Fellowship Programs to ensure new and challenging skill and staffing requirements are met. Timely identification of ESP issues areas in relation to staffing plan input j
should result in the necessary modifications in career l
management system programs to accommodate recruitment i
i and development activities.
IMPACT:
Unlike the mainline mission areas of the agency where professional peer interaction is abundant and staff turnover is sore easily absorbed, the ESP issue areas cannot support a high staffing level without an increase in applications and cannot withstand staf'*ng level fluctuations. Therefore, the operating s tironment for the staff performing ESP reviews and management must be particularly appealing to cultivate and retain stable staff resources.
KEY M:LESTONES:
OP to issue Five Year Staffing Plan call in late 1991.
OP to assist NRR in tailoring career management programs to reacquire resources in core technical disciplines in early 1992.
OP to continue development of its Human Resources Strategic Planning guidance for supervisors.
d s--
If.
D-03(Continued) otAFFING REQUIREMENTS:
Already included in Five Year Plan.
)
FYP MISSION AREA:
RESOURCES:
ESTIMATED EFFDRT:
NRR/DAR/PDNP ACTION:
Provide required input to OP for the five year staffing plan, assist OP in recruiting staff resources, and in outlining opportunities for. staff training, academic j
' advancement, and professional growth.
s
- e
l l
D r
l l
)
)
l/
\\
l l
i i
1 I
I 1
t
\\
I I
i I
I
6/>
rac_!
COMMISSION BRIEFING ON PROPOSED REVISION TO 10 CFR 100 REACTOR SITE CRITERIA THOMAS L.
KING LEONARD SOFFER ANDREW J. MURPHY U.S.
NUCLEAR REGULATORY COMMISSION g,
c, JUNE 24, 1992 0
d
<?
a
OUTLINE OF PRESENTATION i
1 o
BACKGROUND o
NON-SEISMIC ASPECTS EXPERIENCE WITH CURRENT REGULATION PROPOSED REVISION BASES o
SEISMIC ASPECTS EXPERIENCE WITH CURRENT REGULATION PROPOSED REVISION o
SCHEDULE o
CONCLUSIONS
r f
BACKGROUND I
o STAFF RECOMMENDED (SECY-90-341) THAT 'C0lWIISSION DECOUPLE DOSE CALCULATIONS AND SOURCE TERMS FROM
- SITING, AND SPECIFY SITE CRITERIA DIRECTLY, FOR FUTURE PLANTS.
- SEISMIC
- NON-SEISMIC o
TWO STEP RULEMAKING PROPOSED:
-STEP 1 PART 100, INTERIM PART 50.34 AND PART 50 APPENDIX S.
-STEP 2 FINAL PART 50 o
COMMISSION DIRECTED STAFF (JAN, 25, 1991 SRM)
TO PROCEED WITH RULEMAKING.
3 i
t OVERALL DECOUPLING PLAN REVISE PT 50 AND PT100 (SEISMIC) y
- STEP 1 PROPOSED Rule FINAL Rule DECOUPLING (6/92)
~
(EARLY 1993) d REVISE PT 100 AND MOVE DOSE CRITERIA TO PT 50 ON INTERIM BASIS (NON-SEISMIC)
UPDATE SOURCE TERM FINAL DRAFT
=
ST (12/92)
(DRAFT FOR COMMENT)
SECY-92-127 (4/10/92)
AND REVISED PT 50 ESF CRITERIA (2/93)
H PROPOSED RULE FINAL RULE STEP 2 (EARLY 1993)
(EARLv 1994)
- DECOUPLING L
ANPR-SA CRITERIA DRAFT PT 50 (7/92)
PRESENT REACTOR SITE CRITERIA o
PRESENT REGULATION IS 10 CFR PART 100 (APRIL 1962) 0 REQUIRES THAT EVERY REACTOR HAVE
- EXCLUSION AREA 2 77, u> -7 IMMEDIATE ZONE AROUND REACTOR.NO RESIDENTS, BUT TRANSIENT ACTIVITIES PERMITTED.
- 9 -
DISTANCE TO EXCLUSION AREA BOUNDARY DETERMINED BY aneg'11,9 #
DOSE CALCULATIONS, AND IS NOT FIXED.-
g.#w /
p,
~
~
r ZONE OUTSIDE EXCLUSION AREA.
MAY CONTAIN j~
RESIDENTS, BUT NOT DENSELY POPULATED CENTE SIZE
'Q ef 0F LPZ DETERMINED BY DOSE CALCULATIONS, AND IS NOT
'bh FIXED.
pgN udes nynb w m p,, w tra POPULATION CENTER DISTANCE DISTANCE TO NEAREST DENSELY POPULATED CENTER MAY BE NO CLOSER THAN ONE AND ONE-THIRD TIMES THE LPZ RADIUS.
5
REACTOR SITE CRITERIA (CONTINUED) i o
FISSION PRODUCT RELEASE WITHIN CONTAINMENT POSTULATED.
DOSES TO HYPOTHETICAL INDIVIDUALS AT EXCLUSION AREA BOUNDARY AND LPZ OUTER RADIUS MUST MEET VALUES (25 REM WHOLE BODY AND 300 REM THYROID) STATED IN PART 100.
o PART 100 IS VERY FLEXIBLE AND HAS NO NUMERIC CRITERIA FOR THE EXCLUSION AREA, LPZ AND POP.
CENTER DISTANCE.
o CURRENTLY, PART 100 AFFECTS PLANT DESIGN MORE THAN THE SITE PARAMETERS.
o PART 100, APPENDIX A SPECIFIES SEISMIC AND GEOLOGIC SITE CRITERIA:
- REQUIRED INVESTIGATIONS
- DESIGN BASIS 4
6 i
i i
MAJOR AREAS OF SITING EXPERIENCE (NON-SEISMIC) o PROXIMITY TO LARGE POPULATION CENTERS o
FISSION PRODUCT CLEANUP SYSTEMS AND EXCLUSION AREA SIZE o
MAN-RELATED HAZARDS o
RELATIONSHIP OF SITING TO EMERGENCY PLANNING i
7 i
i
r ELEMENTS OF PROPOSED RULE
~
-(NON-SEISMIC) 1 o
PROPOSED RULE CONSISTS OF TWO SUB-PARTS
- SUB-PART A.
APPLICABLE TO EXIST 1]NG PLANTS; IDENTICAL TO PRESENT RULE.
- SUB-P. ART B.
APPLICABLE TO FUTURE PLANTS.
i o
SUB-PART B
- SOURCE TERMS AND DOSE CRITERIA DELETED FOR SITING.
PRESENT SOURCE TERM AND! DOSE CRITERIA MOVED ON AN INTERIM BASIS TO PART 50.34 FOR PLANT EVALUATION.
- MINIMUM EXCLUSION AREA SIZE OF 0.i4 MILES.
LOW POPULATION ZONE DEFINITION DELETED.
I 8
4 5
1
ELEMENTS OF PROPOSED RULE (NON-: SEISMIC)
(CONTINUED) o SUB-PART B (CONTINUED)
+
-POPULATION DENSITY AT INITIAL SITE APPROVAL OR SITE RENEWAL NOT TO EXCEED 500 PERSONS PER SQUARE MILE OUT s(,n g)e'TO 30 MILES (FROM REG. GUIDE 4.7).
PROJECTED DENSITY 1 9
p oJ ~
NOT TO EXCEED 1000 PERSONS PER SQUARE MILE 40 YEARS T
AFTER SITE APPROVAL.
-PHYSICAL CHARACTERISTICS THAT COULD POSE SIGNIFICANT IMPEDIMENT TO DEVELOPMENT OF EMERGENCY PLANS TO BE IDENTIFIED.
-N0 METEOROLOGY EVALUATION FOR SITE SUITABILITY.
(BUT MET.
DATA TO BE COLLECTED AND USED FOR OTHER PLANT EVALUATIONS)
-NEW SECTION REQUIRING EVALUATION OF MAN-RELATED HAZARDS.
o REGULATORY GUIDE 4.7 UPDATED FOR CONSISTENCY.
i 9
s
BASES FOR PROPOSED RULE (NON-SEISMIC) o STAFF EXPERIENCE TOGETHER WITH RISK INSIGHTS HAVE SHOWN WHICH SITING ASPECTS ARE KEY TO ASSURING LOW RISK.
0 POPULATION DENSITY VALUES FROM REG. GUIDE 4.7 CAN LEAD TO LOW RISK WHILE ALLOWING GOOD SELECTION OF SITES IN ALL REGIONS OF NATION.
o EXCLUSION AREA SIZE OF 0.4 MILES, TOGETHER WITH TYPICAL ENGINEERED SAFETY FEATURES, PROVIDES ASSURANCE THAT DOSES OF PART 100 COULD BE MET.
o INCLUDES RECOMMENDATIONS OF SITING POLICY TASK FORCE.
o COMMENSURATE WITH PRESENT STAFF PRACTICE FOR MAN-RELATED HAZARDS.
o SITE CRITERIA SATISFY THE QH0's 0F THE SAFETY GOAL.
o CRITERIA PLUS RISK CHARACTERISTICS OF!PRESENT REACTORS PROVIDE ASSURANCE OF LOW SOCIETAL IMPACT DUE TO LAND CONDEMNATION.
10
i CONCERNS REGARDING POPULATION DENSITY o
SOME STAFF CONCERNS EXPRESSED REGARDINS ADVISABILITY OF HAVING NUMERICAL P0ULATION DENSITY VALUES IN THE RULE.
o PROS-VALUES IN THE RULE WOULD LIMIT LITIGATION IN INDIVIDUAL SITE HEARINGS.
o CONS-NUMERICAL VALUES IN THE RULE IMPLY A GREATER PRECISION THAN MAY BE WARRANTED, AND MAY BY IMPLICATION, RAISE CONCERNS FOR SOME EXISTING SITES.
l 0
STAFF RECOMENDS ISSUANCE OF PROPOSED RULE WITH POPULATION DENSITY VALUES INCLUDED.
FEDERAL REGISTER NOTICE IS REQUESTING COMENTS IN THIS AREA.
11 l
i L
-_.. _ _ _ _ _ _ _ _ _._ _ _ 7 REVISION OF APPENDIX A TO 10 CFR PART 100 SEISMIC AND GEOLOGIC SITING CRITERIA FOR NUCLEAR POWER PLANTS o
THE MAJORITY OF CURRENT NUCLEAR POWER PLANTS HAVE BEEN SUCCESSFULLY LICENSED USING THE CURRENT APPENDIX A T0-1 PART 100 (ISSUED IN 1973);
- HOWEVER, THERE HAVE BEEN SOME DIFFICULTIES.
o DIFFICULTIES WITH THE CURRENT REGULATION IN THE EARTH SCIENCES AREA:
IN SOME SECTIONS APPENDIX A IS T00 DETAILED AND INFLEXIBLE; IN OTHER SECTIONS THERE IS A LACK OF CLARITY LEADING TO CONFLICTING INTERPRETATIONS.
THIS HAS LED TO TIME CONSUMING DISCUSSIONS AND ADJUDICATION BY THE LICENSING PANELS.
APPENDIX A DOES NOT REFLECT ADVANCES IN THE SCIENCES OF SEISMOLOGY AND GEOLOGY (FOR EXAMPLE, PALE 0 SEISMIC DISCOVERIES AND PROBABILISTIC HAZARD ANALYSIS),
AND EVOLUTION OF THE LICENSING PROCESS THROUGH ADJUDICATORY PROCESS.
12
REVISION OF APPENDIX A (CONTINUED) o DIFFICULTIES WITH THE CURRENT REGULATION IN THE ENGINEERING AREA:
THE MULTIPLE DEFINITIONS OF THE OP.ERATING BASIS EARTHQUAKE (OBE)
(LIKELIHOOD OF OCCURRENCE MINIMUM FRACTION OF THE SAFE SHUTDOWN EARTHQUAKE ($SE);
AND FUNCTIONALITY OF STRUCTURES, SYSTEMS AND COMPONENTS)
HAVE RESULTED IN THE OBE CONTROLLING PLANT DESIGN APPENDIX A REQUIRES PLANT SHUTDOWN IF THE OBE IS EXCEEDED;
- HOWEVER, EXCEEDANCE CRITERIA ARE VERY IMPRECISE AND RESTART GUIDANCE ISiNONEXISTENT l
13 4
.____._..__.____._._.___._..____.___._._.___.__q REVISION OF APPENDIX A (CONTINUED) o OBJECTIVES OF THE REVISION REMOVE SOURCES OF CURRENT MISINTERPRETATION DECOUPLE SITING FROM DESIGN 1
INCREASE THE EASE FOR UPDATING THE TECHNICAL GUIDANCE PROVIDE STABILITY IN LICENSE REVIEWS COMPLETE REVISION FOR EARLY SITE REVIEWS
.i l
14
s.,s'h>
p
- i.,
v*,v&
IMAGE EVALUATION ftp O
////
Y~
$gk/
TEST TARGET (MT-3)
/
[8 de
/
f,
/////
1 i
l 1.0 lt a Esa Il3 ll:0llm =2.2 t
- t..
tu l.1 l-_
l.25 1.4 1.6 2--
4 150mm 6"
+
e#<$
- 72
,43 z,
a 47////
x k
ef, 7
[ ke g
"e. :
qqi PHOTOGRAPHIC SCIENCES CORPORATION 6
"0^
6 O
770 BASKET ROAD J{d*
"g ?
t P.O. BOX 338 yp WEBSTER, NEW YORK 14)d0 T
(716) 265-1600
REVISION OF APPENDIX A (CONTINUED) o SCOPE (REGULATIONS)
THE LICENSING BASIS FOR EXISTING PLANTS WILL REMAIN AS APPENDIX A TO PART 100 GE0 LOGIC AND SEISMIC SITING REQUIREMENTS FOR NEW APPLICANTS WILL BE DESIGNATED AS APPENDIX B TO PART 100 EARTHQUAKE ENGINEERING CRITERIA FOR NEW APPLICANTS WILL BE DESIGNATED AS APPENDIX S TO PART 50 i
15
REVISION OF APPENDIX A (CONTINUED) o SCOPE (REGULATIONS)
THE LICENSING BASIS FOR EXISTING PLANTS WILL REMAIN AS APPENDIX A TO PART 100 l
GE0 LOGIC AND SEISMIC SITING REQUIREMENTS FOR NEW APPLICANTS WILL BE DESIGNATED AS APPENDIX B TO PART 100 EARTHQUAKE ENGINEERING CRITERIA FOR NEW APPLICANTS WILL BE DESIGNATED AS APPENDIX S TO PART 50 15
REVISION OF APPENDIX A (CONTINUED) o SCOPE (REGULATORY GUIDANCE)
DEVELOP A NEW REGULATORY GUIDE THAT WILL CONTAIN THE DETAILED HAZARD CHARACTERIZATION GUIDANCE CURRENTLY IN APPENDIX A, AND GUIDANCE ON HOW TO PERFORM THE DETERMINISTIC AND PROBABILISTIC EVALUATIONS REVISE SRP SECTION 2.5.2, VIBRATORY GROUND MOTION REVISE GUIDE 1.12, NUCLEAR POWER PLANT INSTRUMENTATION FOR EARTHQUAKES DEVELOP NEW GUIDES ON PLANT SHUTDOWN (CRITERIA AND PROCEDURES)
AND RESTART (RECOMMENDED EVALUATIONS)
REVISIT EXISTING GUIDES; IDENTIFY THOSE REQUIRING CONFORMING CHANGES 16
REVISION OF APPENDIX A (CONTINUED) o HIGHLIGHTS OF CHANGES IN THE EARTH SCIENCES REGULATION RETAINS DETERMINISTIC GEOLOGICAL INVESTIGATIONS REQUIRES PROBABILISTIC SEISMIC HAZARD ASSESSMENTS REGULATORY GUIDE GUIDANCE ON APPLICATION OF EITHER EPRI OR LLNL i
PROBABILISTIC SEISMIC HAZARD ASSESSMENT TO PROPOSED SITE APPLICATION OF EXISTING / APPROVED COMPUTER CODE UTILIZATION OF EXISTING COMPUTER COMPATIBLE DATA BASES IN THE PROPOSED RULEMAKING PROBABILISTIC AND DETERMINISTIC ANALYSES HAVE EQUAL WEIGHT 17
REVISION OF APPENDIX A (CONTINUED) o HIGHLIGHTS OF CHANGES IN EARTHQUAKE ENGINEERING APPLICANT SELECTS THE OBE VALUE IF OBE IS 1/3 SSE NO EXPLICIT RESPONSE OR DESIGN ANALYSIS I$ REQUIRED IF OBE IS GREATER THAN 1/3 SSE, EXPLICIT RESPONSE AND DESIGN ANALYSIS ARE REQUIRED (CURRENT REQUIREMENTS)
IF OBE IS EXCEEDED, ORDERLY SHUTDOWN IS REQUIRED DRAFT REGULATORY GUIDE CONTAINS EXCEEDANCE CRITERIA AND SHUTDOWN GUIDANCE DRAFT REGULATORY GUIDE CONTAINS RESTART GUIDANCE 18
PART 100 SCHEDULE o
JULY 1992-PUBLISH PROPOSED RULE FOR 90 DAY COMCNT PERIOD.
o OCT.1992-CLOSE OF COMENT PERIOD.
o FEB.
1993-ACRS/CRGR REVIEW FINAL RULEMAKING PACKAGE.
o MARCH 1993-FINAL RULEMAKING PACKAGE TO COMISSION.
19
CONCLUSION" o
PART 100 SHOULD BE UPDATED TO REFLECT CURRENT STAFF PRACTICE.
o THE PROPOSED RULE DOES NOT REPRESENT A SIGNIFICANT CHANGE IN PRESENT SITING PRACTICE, BUT PRIMARILY CODIFIES IT.
o REC 0l# LEND THAT COMMISSION APPROVE PUBLICATION OF PROPOSED RULECHANGE FOR COMENT.
20
+6
\\-
_ _ _ _ _ _ _ _ _ _ _ _ _ _