ML20125E197
| ML20125E197 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/1992 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9212160238 | |
| Download: ML20125E197 (68) | |
Text
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION w
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BRIEFING ON LICENSE RENEWAL REGULATORY GUIDANCE ISSUES LOC 3tiO1l Rocxv1LLE, MARYLAND h3(6l DECEMBER 8, 1992 W
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DISCLAIMER 4
't i
This is an unofficial transcript of a meeting of l_
the United States Nuclear Regulatory Commission held on l
December 8, 1992 in the Commission's office at one White Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may I
contain inaccuracies.
4 The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matte,rs discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with l.
the Commission in any proceeding as the result of, or i
addressed to, any statement or argument contained herein, except as the Commission may authorize, i
I g.
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Ul:ITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION i
3 4
5 BRIEFING ON LICENSE RENEWAL REGULATORY GUIDANCE ISSUES 6
7 PUBLIC MEETING 8
9 Nuclear Regulatory Commission 10 One White Flint North 11 Rockville, Maryland 12 13 Tuesday 14 December 8, 1992 15 16 The Commission met in open session, pursuant to 17 notice, at 9:30 a.m.,
the Eonorable IVAN SELIN, Chairman i
18 of the Commission, presiding.
i 19 20 COMMISSIONERS PRESENT:
21 IVAN SELIN, Chairman of the Commission 22 KENNETH C. ROGERS, Member of the Commission 23 JAMES R. CURTISS, Member of the Commission 24 FORREST J. REMICK, Member of the Commission 25 l
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1 STAFF AND. PRESENTERS SEATED AT THE COMMISSION TABLE:
(
2 SAMUEL J. CHILK, Secretary 3
MARTIN MALSCH,. Deputy General Counsel for l
4 Licensing Regulation 4
5-JAMES TAYLOR, Executive Director for Operations l
6 DR. THOMAS MURLEY, Director, NRR' 7
JOHN CRAIG, Director for License Renewal PD) NRR.
8 WARREN. MINNERS, Director, Division of ' Safety l-9 Issue Resolution 10 e'
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(9:33 p.m.)
3 CHAIRMAN SELIN:
Good morning, ladies and 4
gentlemen.
Today we have a continuation ot the briefings 5
or discussions on plant life extension. We are pleased to '
6 welcome members of the staff to brief the Commiesion on 7
the second set of license renewal issues.
As I mentioned 8
yesterday, this is the second briefing. The third will be 9
later on in this month.
10 Yesterday's briefing concerned Part 54 11 rulemaking issues, in which the staff provided a short 12 description of their plans to identify major issues 13 associated with the implementation of 10 CFR Part 54, and 14 to provide for their resolution.
At the end of the 15 session, maybe we'll have some general discussions of 16 timetables and some idea how much time we're looking 17 forward to seeing these issues resolved.
18 Today is a potpourri of issues.
First, we'll f
19 start on the Part 51 rulemaking, which is the 20 environmental impact statement, and what I expect will be 21 a relatively short status report, and then go on to 22 L ense renewal regulatory guidance issues.
23 Industry initiatives for license renewal will be 24 discussed in the third briefing, scheduled for December 25 18th.
These briefings are designed to provide the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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Cor"nission 'a status report and a summary of staf f plans to j
2 address i'ssues that have emerged since publication of the
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3 final licenso renewal rule, and to 'make it clear just how p
4 important we. expect these.' to be,. ~and how desirable. and 1i
.5 important it is that the-results.
be relatively-l.
'6, straightforward, relatively understandable,.and clearly i
7 consistent with the guidance behind the original rule.-
i 8
Today we will hear from the -' Of fice of the l-9 General Counsel concerning 'the craf t generic environmental 10 impact atatement'and;the-proposed Pcrt 51 environmental-.
i 11
. protection rulemaking for license ~ renewal.-
The General-j
~12 Counsel has.been working very-diligently to address the t
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- 1. 3 concerns' raised by'the Council.on Environmental; Quality, t
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14 the Environmental Protection Agency, and others, in their-r l
15 commento on the Proposed; Rule.
F 16 Then we-will hear from the: staff on;the status
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of the draf t regulatory guidance on the format and content; j
18 of license renewal application and a standard review plan 19 for:llcense renewal.
n 20-I-
nuderstand< copies):of--the~ Vu-grapbs' are 21
-available at'the' entrance to the' room.
I-22
' commissionersFdo you care-say anything?.
L
.m 23 (No response.)
L L
24-Who's on first?
Mr. Taylor?
.'25 MR. TAYLOR.t' Yes, sir.
Good morning. - As -you -
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said, Mr. Chairman, this is day two and counting. With ne L
2 at the table in the presentation today are Mr. Malsch, the t
3 Deputy General Counsel; Tom Murley, and John Craig, from 4
NRR, and Wwren Minners, from Research.
(Slide) 5 Slide 1 is an outline of what 6
you've deocribed, Mr. Chairman, what we intend to cover 3
7 today and, with that, I'll turn it over to Marty Malsch, 8
who will talk about the Part 51 environmental issues.
9 CHAIRMAN SELIN:
Welcome, Mr. Malsch.
10 MR. MALSCH: What I wculd like to do is describe 11 where we were in the approach in the draft GEIS and 12 proposed rule, summarize some of the critical comments we 13
- received, and then discuss - a possible approach for 14 accommodating those comments.
15 The draft generic environmental impact 16 statement, or GEIS, was a very ambitious effort to resolve 17 generically, environmental impr. cts,
alternatives and 19 benefits of license renewal, across the spectrum of all 19 possible license renewal candidates.
20 This evaluation was set forth in a draf t generic 21 environmental impact statement,- and the draft generic 22 environmental irpact statement in tu;n served as a basis 23 for a rule which would define thte scope of NEPA reviews.
24 for individual license renewal applications.
'l 25 T.n particular, the rule proposed to place all NEAL R. GROSS l
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NEPA questions into three categories.
There were so-2 called Category I, which were issues that were generically 3
addressed and no additional review was required for 4
individual renewal applications; Category II, which is the 5
same as Category I, provided that certain conditions or 6
circumstances were met with the review application, and 7
that would have to be assoased on a review application 8
basis, but provided certain conditions were met, the 9
impacto or NEPA considerationn were considered to be i
10 generically _ resolved; and then Category III, where no 11 generic evaluation was feasible and a case-specific s
12 evaluation was required in all cases.
13 Application-specific-renewal
- reviews, NEPA 14 reviews, the contemplation was they would normally be in 15 the form of an environmental appraisal rather than an l
16 envircumtntal.
impact statement, or supplemental 17 environmental impact stat.ement, and these appraisals would t
18 discuss any Category IIIs and any Category II - issues.
19 They would also take account of any site-specific 20 information that was necesacry, especially with regard to i
21 Category II and Category III issues, but might also take 22 into account possible arguments about application of the 23 rule in. a particular case, i
24 The' plan was Ge publish the draf t generic impact.
25 statement for comment, we publish the proposed rule for NEAL R. GROSS COUNT REPORTEnS AND TAANSCABEfB 1323 Ar400L 1st.Afl0 AVENUE N W R02} M4-443' W ASWNGTOri, is C. 20005 (202) 234 4413 I
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comment, and the concept was that based upon the comments, 2
we'd finalize the generic environmental impact statement 3
and publish the final rule.
4 Now, there were a number of concerns expressed 5
about this approach, especially from the President's 6
Council on Erwironmental
- Quality, or
- CEQ, the 7
Environmental Protection Agency, EPA, and some states.
8 And in general, their comments fell along the following g
9 lines.
10 First of all, there wr e concerns about the role j
11 of the generic environmental impact statement and its 12 actual use in individual renewal applications.
Would it 13 be used?
Not used?
What use would be made of it?
14 Secondly, there were some concerns expressed 15 about the concept of doing a generic environmental 16 evaluation so far in advance of site-specific renewal 17 applications.
And related to that, there were concerns 16 expressed about opportunities for public participation in 19 the NEPA considerations associated with license renewal, 20 especially with respect to cite-specific'considerationa, 21 that they could not be taken into account in any generic environmental evaluation, and certainly not in any generic 22 23
-environmental evaluation conducted so far in advance of 24 actual rencual applications.
25 There were concerns expressed about the precess j
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for changing the rule as new circismatances or new 2
information arose, and questions about how one would 3
resolve questions aboct whether the rule should be applied 4
in particular
- cases, in 1..
of case-specific i
5 information.
6 Then there wore some concerna expressed on the 7
part of some states with regard to whether the rule, and 8
especially its evaluation of alternatives and need for 9
power, could have the of feet of pre-judging or pre-empting 10 or unduly influencing considerations of these same matters 11 by local state 0;'.ility commissions.
12 Based upon these commente, we re-evaluated the 1.,
approach which was taken, and made some modifications to 14 reflect these comments.
We've retained the heart of the 15 r.vposal, whic.h was that generic environn:nntal impacts 16 would be reviewed and resolved generically, and that case-17 specific license renewal reviews would focus easentially
-specific information, but we have adopted, or we 18 on E 19 are thinking about adopting, an approach that would 20 enhance public y a"icipation in renewal decisions, 21 especially with regard to new information that's site-22 specific. And we've done this largely -- we would plan to 23 do t: ss largely by explaining in more detail exactly how 24 one vould challenge the rule in individual cases, and how 25 exactly the rule might be amended from time to time to NEAL R. GROSS COUR1 REPORTERS AND TRANSCRIBERS 1373 RHODE ISLAND AVENUE, N W.
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reflect new information.
2 What we're doing is, we are discussing at the 3
present time with CEO and with the Environmental 4
Protection Agency, a modified approach, and let me just 5
sketch out generally what the lines of this modified 6
approach would be.
Let me say, we have not actually 7
reached agreement with both agencies
- yet, on this 8
approach, but I think we're making progress.
9 First of all, as I indicated, we would still do 10 generic environmental evaluations of environmental impacts 11 to the extent justifiable, technically, and these would 12 still be set forth in a generic environmental impact 13 statement.
And this generic environniental impact 14 statement, or generic environmental evaluation, would 15 still be used as a basis, at least in part, for case-l 16 specific license rerawal NEPA evaluations
- but, most l
17 importantly, we are considering that we should, instead of 18 using an appraisal process for doing individual renewal 19
- reviews, we would instead do a
draft and final l-20 environmental impact statement that would supplement the 21 generic. environmental impact statement that we had done l
l 22 sometime before.
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23 CHAIRMAN SELIN: Does that mean it would include 24 the GEIS by reference?
25 MR. MALSCH2-It would include - the GEIS by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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CHAIRMAN SELIN:
So, it would be the full i
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document, some of which was printed in permanent paper, j
4 some of which were written specifically for the site?
5 MR. MALSCH:
That's correct.
The two together i
6 would consist of the soll adequate NEPA review for license i
1
'7 renewal, and it would follow NEPA case law and standards l
j_
8 for full environmental impact statements.
I we're calling it a i.
9 So, the case-specific 10 supplemental-environmental impact statement, it -would 2
l 11 supploment the earlier generic environmental impact l
12
-statement.
This would have a number of advantages, most i
13 particularly it would facilitate public_ comment because I
14 there would be public comment on the. draft supplemental 15 statement.
16 Secondly,-we would not -- we're thinking about 17 not including in -the generic-statement any overall 18 conclusion on the acceptability of environmental impacts.
l
-19 Now, that might have been difficult, in any event, under 20 the-earlier. proposal because~'there 'was -still_ the j-21 possibility -of -unreviewed Category III and Category-II l
22 issues which would
- have, at -most,=_
made Lan overall 23 conclusion tentative.
24 We're thinking now that, cince we are doing a 25 supplemental environmental impact statement, that we would p
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leave to that statement the overall conclusion about the 2
acceptability of environmental impacts and the like.
3 Thirdly, we would spell out in detail exactly 4
how we would consider site-specific information and new 5
information in individual renewal cases, and this we did -
we would propose to do, by spelling out in some detail 6
7 how the Gt
- w:,11d be reviewed and renewed in rulemaking, 8
and how we would consider challenges to the GEIS to 9
accommodate site-specific information in individual 10 renewal cases.
In particular, we would make -it clear that 11 we would always, in every single renewal review, consider 12 substantively any significant new site-specific 13 environmental information, even if it were necessary to 14 waive the rule to do so.
And, so, all comments along 15 those lines would be considered on their merits.
16 Also, all comments that were obtained on the 17 draft supplemental environmental impact statement that 18 pertained to the earlier generic environmental evaluation 19 which were not site-specific, but went tc generic 20 conclusions generically, we would, as before, endeavor to 21 resolve those by rulemaking but,-if they were important 22 enough, we could suspend the rule in the individual case 23 and do a case-specific evaluation, if that were feasible.
24 CHAIRMAN SELIN:
So, the GEIS does not
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which are covered in the GEIS.
Someone could argue that 2
some aspect of this GEIS did not apply to this particular i
3 site and, if we found merit, we could waive the rule on i
2 4
that particular aspect, for that site.
5 MR. MALSCH:
You could waive the rule.
Right.
6 If the information were new but not site-specific, then we l
7 would consider changing the rule by rulemaking.
So, it's 8
like a gate that one way you would go site-specific rulo i
9 waiver, the other way you would go generic evaluation in 10 a rulemaking context.
4 4
j 11 We also would propose to spell out in somewhat 12 more detail exactly how we would update the GEIS, if 13 necessary, every ten years.
- Now, as I said, we've 14 discussed this approach with CEQ and with EPA, and we hope 15 to reach some agreement on a revised approach within the 16 next month or so.
17 Now, separate from all this, we hope to also 18 resolve the concerns of the states, that have been f
i 19 expressed.
Now, the easiest way to do that is simply to 20 make it absolutely clear that if we are doing any generic 21 environmental evaluation and generic evaluations of need-22 for power and alternative energy sources, that this is our 23 opinion'and is not in any way intended to prejudice or 24 affect any state reviews on these subjects.
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1 they would be satisfied with such an express disclaimer, 2
and that might resolve the issue.
Ilow, separately from 3
this, though, we have a lot of comments on the actual 4
technical or substantive merits of the generic 1
5 environmental impact statements.
I think we have 6
something like over 130 comments.
Many of these go to 7
such issues as need for power, and we will need to l
8 consider all those comments on their merits, and reflect 9
them in both a final rule and final generic environmental 10 impact statement.
11 11ow, I think there's a meeting scheduled on 12 progress along these lines, with the commission sometime J
13 in mid-February.
I think the staff is working on a 14 Commission paper that would also outline some of the tasks 15 to be performed, and schedules in terms of working out all 16 these technical comments.
17 So, just to summarize, we are working on a 18 revised overall approach which will retain the heart of 19 the proposal to resolve generic impacts generically, but 20 enhance.
the process for public participation in 21 considering site-specific comments.
He are discussing 22 this possible revised framework with EPA and CEQ and, once 23 we get that framework in place, we'll then work in detail 24 resolving the many technical comments we've received, and 25 then go forward as had originally been proposed, with a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE. N W.
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final rule and a final generic environmental impact 2
statement.
3 CHAIRMAN SELIN:
Can I ask you a procedural 4
question, before the Commissioners start asking their 5
questions?
6 MR. MALSCH:
Um-hmm.
7 CHAIRMAN SELIN:
Would an agreement on the part 8
of CEQ and EPA be expected to be re-examined after the 9
staff considers the technical comments, or would the 10 agreement be a formal-agreement, agreement in form, about:
11 what is appropriate to-be in a-GEIS, and what isn't, and 12
-what is the appropriate way to use a GEIS of the type that 13 you just went through?
14 MR. HALSCH:
Well, I think we'd like to get 15 agreement in principle on the framework, with EPA and CEO, 16-and then with that framework in-place, start to approach' 17 the technical comments because it might influence how-we 18 deal with some of the technical comments.
But we would 19 like to get the; framework in place: first, and I<think 1
20 we're making substantia 1{ progress--to do that.
21 CHAIRMAN SELIN:
Obviously, you are very close.
22 with CEQ, based on the exchange of letters.
23
'MR. MALSCH:
Yes.
.24
- CHAIRMAN SELIN:
How would you characterize.the -
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MR. MALSCH:
We met with EPA last week and 2
briefed them on the proposal.
CEQ was also present.
And 3
we are planning on sending EPA a letter outlining our 4
proposed approach, and hope to get a respom,e back within 5
a reasonable time.
6 CHAIRMAN SELIN:
So, you don't really have a 7
statement of position from EPA?
8 MR. MALSCH:
Not formally.
Based upon the 9
meeting, I'm hopeful, but I wouldn't want to pre-judge 10 what their response would actually be.
11 CHAIRMAN SELIN:
Commissioner Curtiss?
12 COMMISSIONER CUR *ISS: I just have two questions 13 to clarify.
Upon the publication of the GEIS and at the 14 time that the supplemental EIS has been promulgated, 15 comments on the GEIS that we will entertain, in the 16 absence of site-specific information or new information, 17 are limited to the question of whether the analysis in the l
l 18 GEIS applies to that particular site, the so-called 19
" applicability test"?
l 20 MR.
MALSCH:
No.
If, in response to a
21 publication of a draft supplemental environmental impact l
22 statement, some were to file comments which went not to 1
23 whether the generic environmental evaluation was 24 applicable, but to whether it was. simply correct at all, 25 in light of 'information developed since, we would consider NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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that, but not likely on a case-specific basis because that
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2 would be specified in the rule.
3 What we would probably do is immediately embark l
4 upon assuming the comments had merit, embark upon a i
5 rulemaking proceeding to amend the rule, and we would, in
.i 6
all likelihood, delay the renewal action in the meantime, 1
7 until the rule could be completed.
Or, if that wasn't i
8 appropriate, we could always -- and the information were 9
sufficiently significant, we could always suspend the 10 rule, do evaluations in each case, which would probably 11 resemble each other and would be an inefficient use of 12 resources, but it would be a way to sort of keep things 13 going until the rule could be fixed, at which point we 14 would then have a new environmental evaluation that could 15 be used.
16 COMMISSIONER CURTISS:
Let me rephrase my 17 question.
In the absence of significant new information 18 indicating that the analys.is in the GEIS is incorrect, 19 comments on the issues addressed in the GEIS are limited 20 to the applicability of the GEIS to the particular site, 21 and not to the substantive analysis contained in the GEIS?
22 MR. HALSCH:
If there's no new information on 23 whatever we end up codifying in Category I and II, then we 24 would simply use those -- in f act, the staf f would, in its 25 draf t, be expected to use those, and the applicant, in his NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE (SLAND AVENUE N W.
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environaental report, would be expected to use those --
2 the absence of new information, significant new 3
information, not considered, we would go with the generic 4
ene.tronmental evaluation, and that would control both the 5
review and the proceeding later on.
6 COMMISSIONER CURTISSt Okay.
There's some sort 7
of significance test, though, at the. time of ---
8 MR.
MALSCH:
There would have to be a
9 significance test applied --
10 COMMISSIONER CURTISS:
Okay.
11 MR. MALSCH:
-- and that would be a matter of 12 judgment for the Commission.
13 COMMISSIONER CURTISS.
Okay.-
And
- then, 14 secondly, I +hink I understand what you're proposing, but i
15 the conclusions would be drawn not in the GEIS, but upon
-)
16 publication of the supplemental;EIS at that stage'of the 17
. process, 18 MR. MALSCH:
That's right.
In each renewal 19 case, one would draw upon a. co'mbination of the generic 20 impacts that had been evaluated in the1GEIS, and.take 21
' those~as a given, assuming they remain applicable; combine -
22 those with-the site-specific environmental evaluations,-
-23 considering.the site-specific-information, and._ draw an =
'24 overall co'nclusion. That overall conclusion would onlyl be :
1
~25 drawn in each individual supplemental environmental impact -
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statement.
2 CHAIRMAN SELIN:
Commissioner Remick?
3 COMMISSIONER REMICK:
No.
r 4
CHAIRMAN SELIN:
As you know, when we first 5
discussed publishing the rule, I expressed then what I --
6 in fact, I thought this was a terrific idea and a very 7
good piece of work, and I'm very pleased to see this 8
process has been working, that the basic concept still 9
seems to be holding up quite well, that the substance of 10 what you're doing is- _very much - af fected by the. public 11 comments and the progress in reconciling a - - number of 12 different points of view.-
So, I'd like to express my 13 support for what's going on and encourage the process to 14 keep going.
Thank you.
15 MR. MALSCH:
Thank you.
16 CHAIRMAN-SELIN:
Mr. Taylor?
17 MR. TAYLCRt John?
18 MR. CRAIGt Okay.
I'd like to go ahead to slide (Slide) -- and, before we leave Part 51 entirely, 19 4
20 there were some questions about waste management issues, 21 and what this slide depicts are some of the. central issues
_22 associated with ' waste -management issues and -license
-23
' renewal.
And as Marty' indicated, we have had a number.of 24
- comments on the suggested categorization of these issues.
~
25:
In the proposed rule, we had categorized the NEAL R. GROSS -
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storage of spent fuel on-site as a Category I issue, which 2
means that applicants would not have to addr eas it, and 3
also worker and population exposure from handling and 4
processing -from transportation is Category I.
The 5
adequacy of an interim storage space for low-level and 6
mixed waste was contingent upon access to a compact state, 7
or a compact disposal facility, and that would have been 8
a Category II_ issue -if they had access to a repository 9
and, if not, an applicant would have to evaluate the 10
_ impact of _- that issue, expanded 1on-site storage of low-11 level waste issues.
12 I think it's fair to characterize waste issues 13 as one of increasing interest at all
- levels, as 14 illustrated by Northern State Power's experience. with 15 Prairie Island dry cast storage facility and its impact.on-16 extended operation not only~for Prairie Island, but the 1*/
increased attention of that state legislature with respect.
18 to continued operation.of Monticello.
19 The comments that we have gotten-concerning 20 these issues can be boiled down quite' simply to solve the 21 waste issues before you relicense nuclear' power plants, 22 both for high-level and low-level waste..
23 The public, as I indicated, has a'significant 24 increase in interest-level. as a-result of ongoing 25 expansion for dry' cast storage for spent fuel, and
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=
20 i
i continued controversy over the ultimate disposition or 1
2 resolution of the high-level waste issue, as well as 3
continued controversy for low-level waste storage.
And i
4 oven in states where there had been relatively low levels 5
of interest, we see increasing interest now both on the 4
6 part of people making speeches about the impact of the 4
7 waste issues and increased interest expressed in the 8
various state legislatures with respect to what is viewed 9
as long-term storage of spent fuel on-site.
10 So, the issues and the categorization in the 11 proposed rule are laid out in Table 1-B.
As I said, for 12 the most part, they are Category I issues. And that's all 13 I intended to cover, or highlight, on waste.
14 COMMISSIONER ROGERS:
Just on the additional 15 volume from refurbishment, you didn't say anything about 16 that, but that could be something of a troublesome issue, 17 couldn't it? How much? What kind? How the licensees are 18 thinking about dealing with that?
What the off-site 19 disposal possibilities are, and so on?
20 MR. CRAIG Two aspects to the question.
The 21 first, volume from refurbishmant can be both high-or low-22 level waste.
With respect to the high-level waste,-all 23 sites have adequate room on-site to store the high-level 24 waste.
So, to the extent that there's adequate storage 25 facility on-site, that issue is addressed, but it goes NEAL R. GROSS COURT REPORTt!RS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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back to the same basic question, what do you do --
2 COMMISSIONER ROGERS:
Well, would it be easily 3
handled, though, in a form that would be 7sily handled?
i 4
If it's going to be high-level, they may need special ways l
l 5
of dealing with that.
It's not spent fuel, necessari.ly.
l 6
MR. CRAIG No, that's correct, but they have 7
room, and we believe that the methods to move it and 8
handle it are there.
They are not simple.
They are 9
cumbersome and costly, but they are there.
10 The low-level waste, of course, is the same 11 basic issue, accessibility to a repository.
12 COMMISSIONER ROGERS:
Yeah.
Okay.
13 COMMISSIONER REMICK:
In the low-level waste 14 area, you indicated that it's contingent upon access to a
(
15 compact or out-of-state site.
Were there any assumptions l
16 made in analyzing the volumes on whether there would be l
17 any recycling, or how were the volumes determined?
18 MR. CRAIG I'm going to have to defer that.
19 Warren?
20 MR. TAYLOR:
We may have to come back to you 21 with that, Commissioner.
I'm not sure whether --
22 MR. CRAIG:
Don Cleary, from the Office of 23 Research, I believe, can address the question.
24 MR.
CLEARY:
We have a scenario that was 25 developed for the refurbishment, and.that scenario' was l
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22 4
l 1
based -- the assumptions in that were based on experience i
l 2
from refurbishment activities, which we have plenty of
]
1 3
experience w1th.
j 4
l 4
COMMISSIONER REMICK Is that assuming no 1
l
\\
)
l 5
recycling of any materials that came out from 6
refurbishment, or assuming some recycling?
)
d l
l 7
MR. CLEARY The assumption is just storage, no l
8 recycling.
i j
9 COMMISSIONER REMICK No recycling.
Okay.
l l
10 Thank you.
)
i l
11 MR. CRAIGt With that, I'll jump to slide 6.
j 12 (Slide) l 13 We discussed a
little bit yesterday the 14 regulatory guide and_ standard review' plan to support l
15 license renewal, 10 CRT Part 54, and we'noted that they s
3 i
16 were previous 1v issued for.public comment in late 1990, i
l 17 and thay-have been revisedL to reflect changes in final l
18 rule, public comments, some experience that we've gained l
19 reviewing industry reports, and as a result of ACRS and j.
20 CRGR comments.
And Dr.
Murley _ discussed the. senior-21 management review-that's in process-right now, it's-_being 1
It will address some of the-policy issues that 22-
_ initiated.
4
- are embodied in both of these documents, and out-: intent is 24' to republish them-for publicLcomment, as_we previously
~25 discussed in SECY 91-330.
[
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Slide 7.
(Slide) 2 COMMISSIONER REMICK:
I'm sorry, when would you 3
republish it?
4 MR. CRAIG:
Following the NRR senior management 5
review, our intent is to revise them as appropriate, and 6
then they would be forwarded to the Commission before they 7
were issued for public comment.
8 COMMISSIONER REMICK:
So, the senior management 9
group would review those current drafts?
10 MR. CRAIG Yes.
11 COMMISSIONER REMICK:
Thank you.
12 MR. CRAIG:
And that's in process right now, 13 independent of the additional effort that Dr.
Murley 14 talked about.
15 CHAIRMAN SELIN:
I think it's fair to say the 16 Commission is going to want to be briefed on progress, and 17 about the issues that have been alluded but not 18 specifically addressed yesterday and today.
19 MR. CRAIG:
We'll do that, yes.
20 Our intent in developing a~ standard review plan 21 was to provide guidance to the staf f and focus the license 22 renewal. reviews on-the management, the identification-and 23 management, and the initiation of corrective action to 24 address age-related degradation, specifically age-related 25 degradation unique to license _ renewal.
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The previous standard review plan was prepared 2
after the staff had reviewed and approved operating 3
licenses for 35 or 40 nuclear power plante.
In an effort 4
to limit -- focus the review on renewal applications and 5
try and bring to bear the expertise that we have today, to 6
identify and address aging mechanisms, we developed this 7
one up front as a draft, and intended to use that as a 8
working document, and revise it after one or two lead 9
plants, and keep it a living document over time.
10 The document contains some differences from 11 existing standard review plan 0-800, and one of the keys 12 is a sufficiency review.
We've discussed previously the 13 Administrative Procedures Act, which allows that if an 14 application is both timely and suf ficient, even though the 15 agency had not completed its review of the application, 16 the initial operating license could continue in effect.
17 So, we have a section in there that describes the criteria 18 for a sufficiency review.
19 We address the methodologies and a review of the 20 methodclogies in a list required to be submitted as part 21 of the application, and we've tried to provide, from both 22 a
systems perspective and a
component. perspective, 23 evaluations in management of age-related degradation, and 24 that. was based largely on the early discussions - with 25 Yankee as they were going to -- their approach was to put NEAL R. GROSS COUAT REPORTERS AND TRANSCR:0EAS 1323 RHOOE ISLAND AVENUE. N W.
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25 i
i i
things in commodity groups, as we discussed earlier, i
2 Slide 8.
(Slide) l l
3 The draft regulatory guide is focused on 4
providing guidance to the applicant concerning the form 4
5 and content of the application and the performance of the i
6 integrated plant assessment. And we hope and believe that j
i
~
7 through working with the lead plants and revising this 8
document, that we will have quality and uniformity of j
4 9
future submittals.
And we think that that will result in 10 efficiencies both for licensees and for the staffs during i
11 the review.
i 12 Slide 9.-
(Slide) j 13 In one of the slides yesterday, we talked about 14 the staff reviews of license renewal applications and how l
15 they would be performed and conducted.
This slide is, in 2
16 a sense, a duplication of that slide, and the two points 17 that I'd emphasize here is that the reviews will be 18 focused on the technical adequacy of the actions to 19 identify and manage age-related degradation, and that 20 we've been directed by the Commission, after we have some 21 experience, to come back with suggested rule changes, and 22 we-have that'in the forefront-of our-reviews, to try to 4
23 identify those, and any other changes or subsequent staff 24 actions that might be necessary to revise the standard 25 review plan or the regulatory guide.
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l 26 4
1 Slide 10, please.
(Slido) 2 There were some questions on utilization of 4
3 aging research with respect to the development of license 4
renewal activities.
This issue has been discussed at 5
various times with the Commission, and this slide perhaps 6
presents a little different slant on how the results of 7
the aging research are being utilized.
j 8
I think one of the key aspects is that we've j
9 developed through our aging research program, centers of 10 expertise both within the staff and the various national 11 laboratories that we've used, both in the offices of NRR 12 and the Office of Research.
these individuals have been l
13 instrumental in development of the standard review plan 14 for license renewal, as well as the review of the industry 15 reports.
16 So, we've had a focused ef fort to look et issues 17 related to identification and management of age-related 18 degradation. We've also added a Section 6 to the Standard 19 Review Plan for License Renewal that references specific I
20 aging research reports, so that when we've done a program 21 for motor-operated valves and this section of the r
22 Standard Review Plan discusses motor-operated valves 23 there's a reference to that report to be used as general 24 information so that the' licensees and the staff will have, 25 if you will, a
handy list of references that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 HHODE ISLAND AVENUE, N W (202) 2344433 WA$HINGTON, D C. 20005 (202) 2344433
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i 27 I
applicable and appropriate and may provide additional j
2 information for that specific structure or component.
i i
I 3
Slide 12, please.
_(Slide) 4 The last part of the prepared agenda this i
5 morning is an overview of the status of the review of the l
6 industry reports, the reports that have been submitted to 7
the NRC by NUMARC to support t. heir license renewal.
8 And I'd like to start by going back to what were 9
the original expectations for these reports, that they 10 would be technically complete, comprehensive documents 11 that could be referenced by an applicant as it prepared a 12 license renewal submittal, that the reports would be 13 completed including final SERs by the staff issued by the 14 end of 1991, and that the reports were-never critical path 15 to review of lead plant applications, rather they would be 16 useful documents.
17 The status today is that eight of'the irs have 18 been revised and submitted,'and two more are on the way.
19
.Of the ten technical irs, there is one, the-lith IR was a
=20 screen methodology.
That document was revised before the 21-
_ final rule was issue'd, and there - is no' active-work to 1 22
' revise that' report today.:
'23 Late-this summer, we initiated a focused effort
-24 to develop irs for two of the industry reports, the BWR-25-
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l 1
I'll go into in just a minute on the next slide, we found 2
that these documents were particularly dif f.Leult to write a,
3 and prepare.
j 4
Slide 13. (Slide) i 5
The industry reports were prepared, for the most l
6
- part, before the final rule was issued, and so the 7
methodology to screen and evaluate the components to j
8 components covered within the scope are inconsistent with l
9 the final rule on license renewal.
j 10 They state as their purpose that they equivalent 1
11 or a substitute for the integrated plant assessment and, 12 yet, they don't meet the requirements of the integrat nd 13 plant assessment and the license renewal rule.
They are 14 focused on safety-related equipment and safety-related 15 functionn as opposed to the equipment and the functions 16 which are important to license renewal, so that nonsafety-17 related equipment which could have an effect on safety-18 related have been screened out.
Portions that are 19 necessary for tech specs LCO have been screened out and 20 they are not addressed.
21 The use of ef fective programs is one that is in 22 controversy.
There are general descriptions of programs, 23 existing programs, with the assertion that they are 24 effective, and the specific elements of the. current 25 programs which would be necessary to manage aging aren't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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clearly identified.
s
..N f
2 There is a lack of bounding assumptions ar >
1]
3 criteria in the industry reports.
The statements t.
}
4 require that applicants should assure that assumptions anu 5
criteria which are applicable are reviewed, but the 6
assumptions, for the most part, and criteria are not 7
clearly identified when the specific degradation 8
mechanisms of the components are discussed in subsequent 9
sections of the IR.
10 As a result, the irs are going to be of limited 11 usefulness to renewal applicants.
As the staff tries to 12 prepare a
balanced safety evaluation report which 13 identifies the portions which are inconsistent with the 14 rule, and also identifies those age-related degradation 15 mechanisms which have been adequately addressed, we're 16 finding that a difficult and - a challenging task, and 17 that's why we focused the effort on two of the irs.
18 DR. MURLEY:
I'd like to add that I intend to go 19 back to NUMARC and ask whether they think it is still 20 worth our effort to review these irs and write safety 21 evaluation reports on them.
22 I had a meeting with NUMARC earlier, I think 23 probably this spring, or this summer, and they mentioned 24 at the time that they had spent a lot of money on these 25 reports and they would like SERs, so I committed to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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e 30 i
1 that.
2 It's a lot of staff effort to do it.
John 3
estimates that we've only expended maybe 15 percent of the i
j 4
ef fort that's ultimately needed to write SERs on this, and i
5 it looks now for very little benefit.
And, so, I'm going I
6 to have to decide whether to continue doing this or not, 7
but it's a resource effort and, in my mind, it's going to 8
delay getting on with reviewing, for example, the B&W l
9 Ousers Group effort.
It's going to delay other 10 activities, and for very little benefit, that I see, but 11 I need to explore that further with NUMARC.
1 12 MR.
TAYLOR:
That concludes our formal J
13 presentation.
14 CHAIRMAN SELIN:
First, I would like to make 15 some general comments and then hear what my colleagues 1
16 have to say, before I make the full closing remarks.
r 17 First of all, I'd like to encourage you, Dr.
18 Murley, to move in an expeditious fashion, to settle the 19 known policy issues as you discussed yesterday.
20 DR. MURLEY:
Yes.
{
21 CHAIRMAN SELIN:
In my opinion, if you choose a 22 bifurcated approach -- in other words, if you choose to go 23 simultaneously with the review of the policy groups and 24 the support for the Babcock and W.ilcox ovners Group -- I l-25 would admonish you to make sure that you have a vertical NEAL R. GROSS l
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31 1
process.
By that I mean that both efforts, the top-down 2
policy and the sort of bottom-up review of the semi-l l
3 generic issues, be done at more or less the same level, so l
l 4
that you don't end up with, for instance, the B&W Owners l
l 5
Group being on a very low level, and not informing the G
work that's done at your level and Mr. Russell's level and t
l 7
Mr. Craig's level --
8 DR. MURLEY: I'm going to have periodic meetinge 9
with the B&W Group.
I met with them yesterday afternoon.
10 I plan to be involved during that review, yes.
11 CHAIRMAN SELIN:
And the second is that it:s I
l 12 clear that there haven't been adequate communications, 13 vertical communications, through the process, so far, and 14 I think that perhaps can be attributed obviously, t
l 15 there's been a tremendcas amount of work in NRR, but it l
16 can be attributed to a point of-view with which I'm not 17 completely in accord, and that is, from where I sit, the 18
-process of doing not only the generic documents, but the 19 first application, or the first couple of applications.
20 It's like statute law and case law.
You don't really have l
21 law until you have the first couple of precedents, and the 22 first couple of documents that are done, even beyond the 1
l 23 policy documents, are policy documents themselves.
We 24 don't know, hnd the industry doesn't know, what Part 51 25 and Part 54 really mean until it's been applied a couple-NEAL R. GROSS COURT REPOH7ER$ AND THAN3ORGERS 1323 RslovE ISLAND AVENVE, N W.
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j 32 1!
M times.
j 2
- And, s c,,
to my
- view, end I
hope to the 3
Commission as a whole, we look at this not as execution so 4
tauch as it is filling out and defining at the next level 5
of detail what the policy means.
And in the execution, I 0
would say that perhaps it has been looked at a little bit 7
too much as a mechanical process of reading the statement 1
8 of consideration, reading the rule, turning the crank, 9
And I don't read it that way.
I think it's very important 10 that we all understand that as theso documents are 11 developed and as experiences develop, we are filling out 12 ]
the basic policy documents, and it's of interest frcm the 13 top of the Commission to the bottom of the branch that's l
14 doing the work.
15 And, therefore, I would hope that we would be 16 able to follow an imaginative and flexible approach to the 17 project management of these projects, to keep in mind the 18 real objectives, and to come back to yourself, to the 19 Commission, as appropriate when issues come upc instead oi 20 just saying, "Well, you kncw, that's what the statement of 21L consideration says, and we had to do it this way".
We've 4
22 learned a lot since the two rules were issued.
The 23 treatment was really 54, 50,'then 51 in draft, and the i i
24 maintenance rule, and execution is policy until the first l
25 couple are done.
So, keep in touch,_I guese, is what I NEAL R. GROGS COUHT REPORTERS AND TRANSCR BERS 1323 RHOCE ISLAND AVENUE. N W.
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would say, 2
And, finally, I'd just like to make a couple of 3
other fairly obvious points, but it's still worth making 4
it.
The first is that, license renewal is essential not 5
only to plant life extension, but to what I call "J1censo 6
attainment",
that as licensees are faced with major i
7 capital investmento or, in fact, sometimea just m,*.jor 8I operating costs, the question of the time period in which 9
they can look forward to amortizing these investments 10 beco no critical in uhat they ere doing.
So, it'e not just 11 will plants go from the year 2012 to the yea.: 2032, but 12 what will happen between now and then.
Other then l
13 inspection of current plants, I don't thinx there's l
l 14 anything before the commission that's as important aa -
l l
15 or more important, in any event, than this effort, and I
16 it's not just important in the sense of the resourms that 17 it requiren, et cetera, but the continued 4ttention of the 18 Commi.ssion.
l l
19 Second, I was aciually quite pleased to haar l
l 20 your remarks about the industry reporte end the SERs not l
-21 because I agree or disagree with the substance of them, I 22 don't have a position on that, but given the priority of l
23 thi.s effort and the natural limitation of resources, a 24 continual re-evaluation of where the resources are going, 25 how thLy can be used most pt;oductively, is highly to be NEAL R. GROSS COURT REPORTERS AND TPANSCRIBERS 1323 RHOOE t$tAND AVENUC, N W.
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34 1
commended.
2 The third noint I'd like to make, I think I can 3
make in two words, and that is " move quickly".
I mean, f
4 just because it's a long time before we expcot the first i
5 application, there's a lot to be done, ano the Commission 6
has got to decide, or reiterate, or ratify some of these 7
basic points so that the industry knows where we stand, 8
the general publi: knows where we stand, and not al]ow i
9 this to be dragged out any more than the technical stuff 10 requires.
11 The fourth is, I uutt'Ld repeat the point I made 12 before, about keeping in touch with us for status when 13 revolution of issoss Le needed. And the fif th is, there's 16 a lot of positive history to be learned in the maintenance 15 rule not only the substantive incorporation of as much of 1
16 the maintenance reeults-aa seem appropriate into the 17 licenne renewal, but also the process, that I hope that 18 you will keep in touch with Northern States, with NUMARC, with other interested parties.
i 19 26 There -sas a lot of very -- both the industry 21 position and tae' Commission position going into the l
maintenance rule, were far less informed than what seems 22 23 to be ceming our. of that work.
And I think there's a lot 24 to be learned by following the maintenance model as much g
25 as possible, as well as incorporating the substantive NEAL R, GROSS CoutJ AEPORTERS '.Hb TRANSCH:BERS 1324 RHOOE ISLAND /*?(ENLE. N W.
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35 I
results of the maintenanco work.
2 1 think it's extremely useful that va've had 3
these two sessions.
I look forward to the industry 4
session as well, but yoit've raid all the right things, and 5_
now we look forward to carrying them out.
)
6
But the one point I'll repeat, as Yogi Berra 7
said, it't. " repeating myself all over again", is that it's 8
not micromanegement to want to know in some depth about l
9 how this is going.
11ntil we've done a couple of the'n, 10 it's further formulation of policy, and un'll be very 11 interested not just in overseeing what's going on, but 12 having yon come back and say, "If we can intnrpret this 13 this way, it will make lif e a lot more productive, it will 14 be much closer to the original sense of the rule than the Ib ot.her way".
16 Commissioner Rogers?
17 CO!O!ISSIONER ROGERS:
Well, just to reiterate 18 that same point, I'm not going to say it all mer again, 19 but I de think that we - I don't feel we're at a point 20 that the Commiusion understood all-the possibilities of 21 i what it was doing at the time that the license renewal was 22 formalated, and that it is only by werking with it that we 23 really understand ourselves better scue of the issues, and 24 no I don't think that it's the time to regard the work of 25 the policymakers as having been done, and now it is simply WiAL R. GROSS COUM REPOMER$ AND TRANSCRIBERS 1323 f1HCOE ISLAND AVENVf f..W.
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an implementation of that policy.
2 I think we need still to rethink and look at 3
what it is we've done, and see that it's perfectly clear 4
what it is to all that -- of what we intended.
5 Just on the matter of schedules, I received this 6
morning the memorandum from Mr. Crutchfield to Dr. Murley, 7
on the augmented license renewal implementation issues if I could ask a 8
task schedule, and I was a little 9
couple of quest Mns about what the --
10 DR.
It it;Y:
Yes.
I would say that that 11 memorandum is inoperable.
12 (Laughter.)
i 13 CHAIRMAN SELIN:
Quit asking questions.
14 DA. MURLEY:
I can forestall a lot of questions, 15 I think.
16 COMMISSIONER-ROGERS:
All right, fine.
17 DR. MURLi:,i':
We're going to redo the whole 18 thing, and I'm going to be acting this week on that 19 matter.
20 COMMISSIONER RCGEL.:
All right.
Well, I just-21 hre one general comment, and that is. then, without any 22 details, I was a little confused as to what 60 days meant, 23 and 30 days meant, whether those were calendar days --
24 DR. MURLEY:
It doesn't mean anything.
25 COMMISSIONER ROGERS:
- Well, I mean in the NEAL R. GROSS CnURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N W.
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future, when we get something.
Is it calendar time?
Is 2
it working days?
What do they really mean, because the 3
dates didn't seem to quite jibe with -- it wasn't quite 4
clear what the meaning of that was.
So --
5 DR. MURLEY:
No, it's not what I had in mind, 6
a.d we need to go back, and I want to make it clear what 7
we would mean.
8 COMMISSIONER ROGERS:
All right.
So, when you 9
give us a schedule, if we do see one, we would like dates, 10 I think, as much as possible, rather than days, because it 11 isn't always so clear whether dayu are working days or 12 calendar days, and there's a substantial difference 1
l 13 between them.
That's all I have.
14 CHAIRMAN SELIN:
Commissioner Curtiss?
l l
15 COMMISSIONER CURTISS:
I don't have any 16 questions on the materials that were presented today.
I'd 17 join the Chairman in commending the work that's been done 18 on Part 51.
I think that's hopefully moving along l
l 19 smartly.
20 What I think -I'll do is just summarize my l
21 observations from these two days of briefings, and the 22 effort to determine where we are in the implementation of i
23 Part 54, and I have. six thoughts in particular that I 24 thought I'd go through.
25
- First, I
- thought, I think, and subject to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE IGLAND AVENUE, N W.
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38 I
hearing on December 18th from the B&W people about the 2
details of their effort, this process that we've gone 4
3 through here in this two-day period, I think, has been an 4
4 extremely healthy process.
It makes sense, I think, in 5
any area like license
- renewal, or any other major 1
6 regulatory initiative, for us as a Commission to do this 7
kind of thing and do it on a regular basis, so that as we 8
see the agency move forward with the implementation of a 9
particular rule, we are able to understand,
- address, J
i 10 adjust, to the policy questions that come up in the e
text of the implementation of that rule.
And it's 12
- us a number of them have come up, which I will get to minute.
I think this process in particular, in this 15 context, is going to, when all is said and done, as you go 16 through the senior management process and come back to the 17 Commission with your recommendations, going.to hopefully 18 lead to the kind of regulatory stability, well defined, 19 hopefully
- generic, perhaps in
- advance, criteria 20 expectations, what have you, that we would like to see met 21 in the context of license renewal. 'This is an extremely 22 important initiative.
In my view, it's on par with the 23 advance reactor work tht
.e're doing in this agency, if 24 not more important, but it deserves, in my judgment, that 25 kind of senior level attention.
And the most gratifying NEAL R. GROSS COURT REPORTERS ANO TRANSCRIBERS 1323 RHOOE ISt AND AVENUE, N W (202) 234 4433 W ASHINGTON. C C. 2000$
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thing that I've seen about this discussion here is that 2
that is now occurring.
3 secondly, in the context of the discussion those 4
two days, I haven't heard anything that, in my view,- calls 5
into question the two fundamental principles on which the 6
license renewal rule is based. Those two principles, f rom 7
what I've heard and from what I know independent of these 8
meetings, remains sound today, and I think the basic 9
regulatory framework in the license renewal, and those two 10 principles in particular, we ought to take great pride in 11 saying remain sound today after we've gone through a much 12 more detailed application of that rule and the framework 13 of that.
That's for the purpone of commending those of 14 you who were involved in the-formulation of that rule 15 based upon those two fundamental principles.
16 Third, having said that, in my view, what we've 17 seen in these two days of meetings and what's emerged from 18 the interactions with the specific licensees that have 19 approached us about the possibility of renewing their 20 licenses, is that there are significant policy questions 21 that have arisen out of the implementation of this-rule.
22 And I say that that way, and I share the Chairman's 23 phraseology in that regard, these are important policy
^
24 questions about this initiative that have arisen as a 25 result of the implementation of this rule, and we might NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE. N W.
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l
-40 1
expect that to happen in a complex area-like this.
?
2 There are a number of them in-particular.-
I-i 3
won't through all of the ones: that. I have hnd; an 4
interest in.
I will highlight the ones in particular --
5 you have my thoughts in the memo that I sent down to-the j
6 staf f last month, detailing in much more extensive.f ashion l
7 my thoughts on each one of-those.
8 First and foremost, I think we need to spend a i
9 good deal of time now, and the time is ripe to do it, to i
10 focus on the relationship of this effort to the l
11 maintenance rule which is now on the books,:the guidance i
12 has been developed, the V & V program is moving forward, 13 and there-is great potential, in my view, to move in the
~
l 14 direction of greater harmonization of the maintenance rule 15 and the license renewal. rule,-for the sake-of achieving 16 ef ficiencies-both f rom our standpoint as well as frc a the-l 17-standpoint of licensees who might wish to pursue' license
~
18-renewal.
3 i
19 I think-we need:to focus-more attention on how I
20 we look at the issue of age-related degradation unique to i
-21 license renewal and how, in particular, we're interpreting i
22 and applying thatLas-we implement this rule.
EQ and'-
~
23 fatigue are the two obvious questions where that issue is 24 implicated.
Not a whole lot.to discuss at this point in 25 time, but that's an issue tnat, it seems to me, we need to-
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E I
l 41 1
come back to when we revisit'the question.
4 l.
2 The scope of the SSCs and, in particular, the 3
issue having to do with tech spec operability, is one that 4
4 we discussed yesterday, I think - that-one needs to be d
5 addressed, thought about in more detail.
And there are a 4
6
-whole. host of other questions, but-those are the major j -
7 ones that I see at this point in time.
8 I would add to-that the question of_what the 3
1 l
9 significance is of a renewed license in terms of the 10 technical requirements that we as an agency believe ought l'
11 to'be-imposed.
Is it simply procedural, as-the lawyers 12 have advised us, I think, when the rule was -formulated, or i
13 is there something that goes along with that in-terms of 4
14 the-kinds of substantive technical requirements that ought 15 to be imposed in the license renewal context.
i 16 Fourth, I believe that the approach that Dr.
f 17 Murley has ' outlined and that we'11 hear about, -I think,. in 18 more-detail as it begins to move forward,-;is exactly the h
~ 19-right approach at this point in time... one might argue-4-
j-20; that it might have been helpful to'do it' earlier-but, in e
- 21 any ' event, -I think it's now evident that senior management
- 22 is-fully engaged in.that approach that you_have in; mind; 23 and_the schedule in particular,.which will call-for that.
4
~
24-to be completed in the two-to three-month _ time _ frame,_I l
25 think, is something that, we ought - to ' view as f a high NEAL R. GROSS-COURT F'EPORTERS AND TRANSCRIBERS 1-1323 RHODE ISLAND AVENUE N W.
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42 1
priority.
2 I will repeat a comment I raised yesterday.
I 3
hope we take advantage of whatever. information we-receive 4
in the context of the B&W effort, for the purpose of 5
informing our evaluation of the policy questions, but not 6
get so deeply entrenched in the review of yet another 7-application or another initiative, that the major policy 8
questions get overtaken by the interaction with - that 9
particular group of licensees.
10 I expressed my view in the memo, I'll repeat it 11 here.
I think we need to emphasize the importance of 12 developing generic criteria. to the extent possible in 13 advance, and get out of the " bring me a rock" posture that 14 I think we've been in in the two cases that we've pursued 15 to date.
And that, it seems to me,.the one danger of 16 getting -into a full-fledged review of the B&W effort 17 before - we have gotten the policy questions thoroughly 18 ventilated and resolved.
19 Fifth, let me touch on a question that-I know 20 has been of great interest and some controversy, and that 21 is the issue having to -do with whether = changes to-the 22 license renewal rule -itself are necessary or appropriate.
23-As I indicated at'the outset, I think the two 24 fundamental principles on which the rule is based remain-25 sound today, and I haven't seen anything today, yesterday, NEAL R. GROSS.
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or in my review of this effort, that would suggest that 1
{
2 those two fundamental principles need in any way to be 3
revisited.
I think they remain sound, and ought to be the 4
linchpin of what we do in this area.
5 Having said that, I have three comments in this 6
context.
First, I wouldn't personally think that your 7
senior level review ought to be constrained in 8
recommending approaches that you believe are reasonable, 9
including approaches to integrating your ef fort here with 10 the maintenance rule, by the fact that a rule change might 11 be required.
12 I personally am of an open mind on the question 13 of whether adjustments to the rule, fine-tuning if you i
14 will, what have you, changes that, in my view, don't 15 require changing the fundamental principles.
I'm prepared 16 to entertain those if there are reasonable approaches that 17 you would recommend, that might require changes in the 18 rule.
19 The point here I guess I would leave you with 20 is, I wouldn't feel constrained from recommending sensible 21 approaches simply because the rule might have to be fine-22 tuned.
Secondly, I personally believe, based upon what I 23 know to-date, I look forward to what OGC in particular has 24 to say, but there may, in fact, be instances where we've 25 talked about things that we think may make sense, where L
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 13l'3 RHODE ISLAND AVENUE, N W.
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_ _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - ^ ~ - ~ ~
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44 1
the rule itself may need to be fine-tuned.
We talked 2
yesterday about the tech spec operability question, for 3
example, and whether you could apply that to those SCs 4
that are necessary to mitigate or prevent design-basis 5
events.
I've had the opportunity to take a good, hard 6
7 look at whether you can implement the license renewal 8
- rule, taking advantage of what we've done in the maintenance context and, in particular, to rely upon the 9
10 maintenance rule as an effective program, without going component-by-component analysis of aging 11 through a
12 degradation.
That's a question that seems to me needs to 13 be analyzed carefully as well.
14 There may be some instances of those two in 15 particular but, beyond that, other instances where the 16 rule itself may need to be fine-tuned.
I'm personally not 17 opposed to that.
It's logical, in a complex area like 18
- this, where mid-course corrections either in the 19 implementation of the rule or perhaps the rule itself 20 will, in the long run, provide for greater stability and 21 a better product.
Third, and finally, I'd emphasize, as I said at 22 23 the outset, I don't see anything in the context of things 24 that we've talked about that, if the rule is amended, would implicate the two fundamental principles upon which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W WASHINGTON. D C 20005 (202) 234 4433 (202) 234-4433
45 1
the rule is based.
I think that presents a more 2
problematic proposition, and I'm pleased to hear that 3
nothing that we've talked about in terms of fine-tuning l
4 needs to implicate those two principles.
5 Sixth, and finally, in terms of timing, it's 6
obvious, and I think the Chairman has indicated, that we 7
need to revisit this question at the conclusion of_your 8
senior management review, when you've had an opportunity 9
to get away and think about these policy questions and put 10 down on paper your thoughts about how we ought to proceed.
11 From what you've described, that sounds like it might be 12 in the late-February time frame, as you work your way 13 through this process.
14 I think another opportunity to come back and, in 15 briefings focused on these questions and the ones that 16 came up yesterday, would be timely at about that point in 17 time.
So, I share the Chairman's view that we need to get 18 going on this effort as expeditiously as possible, with a 19 thorough and comprehensive review of where we stand and 20 where we're going.
21 CHAIRMAN SELIN:
Commissioner Remick?
22 COMMISSIONER REMICK:
Mine is certainly an easy 23 task this morning and, in the spirit of ef ficiency, I can 24 say that I associate myself with the comments made by all the five points by Chairman 25
.three of my colleagues NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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Selin; the emphas!.s by Commissioner Rogers that you 2
shouldn't assume that the policymakers are finished with
-3 their job, and shouldn't hesitate to come back to us; the 4
six points by Commissioner Curtiss, one that I might have 5
a little reservation although I'm not opposed to 6
considering fine-tuning the rule.
I view that as -- very 7
seriously, as a matter that you should look at perhaps as 8
a matter of last resort, but if we have to do it, we 9
should not hesitate to consider it.
But I'm happy to 10 associate myself with the comments already made.
11 One request I would have, Dr. Murley, yesterday 12 you indicated that perhaps additional resources might be 13 needed, and I realize you aren't prepared to address that 14 at this moment, but for my own information, and assuming 15 that the other Commissioners would be interested if they 16 already don't have-that information, I'd be interested in 17 the amount of FTEs that have been expended on this ef fort, 18 say, in the last two fiscal years, so I can put it in 19 perspective.
And I'm not thinking so much of the age-20 related research effort, but I'm thinking more into your 21 review under the rule of separate out the Yankee ' Row 22 portion that had to do - with license renewal and the 23 Northern States Power effort.
I'd be interested in the 24 amount of FTEs that we -- or resources, if we had contract 25 money expended, and it need not be at this time.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234-4433 WASHINGTON D.C. 20005 (202) 2344 433
l 43 1
or in my review of this effort, that would suggest that 2
those two fundamental principles need in any way to be 3
revisited.
I think they remain sound, and ought to be the 4
linchpin of what we do in this area.
5 Having said that, I have three comments in this 6
context.
First, I wouldn't personally think that your 7
senior level review ought to be constrained in 8
recommending approaches that you believe are reasonable, 9
including approaches to integrating your ef fort here with 10 the maintenance rule, by the fact that a rule change might 11 be required.
12 I personally am of an open mind on the question 13 of whether adjustments to the rule, fine-tuning if you 14 will, what have you, changes that, in my view, don't 15 require changing the fundamental principles. I'm prepared 16 to entertain those if there are reasonable approaches that 17 you would recommend, that might require changes in the 18 rule.
19 The point here I guess I would leave you with 20 is, I wouldn't feel constrained from recommending sensible 21 approaches simply because the rule might have to be fine-4 22 tuned.
Secondly, I personally believe, based upon what I 23 know to-date, I look forward to what OGC in particular has 24 to say, but there may, in fact, be instances where we've 25 talked about things that we think may make sense, where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS -
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I 44 0
1 the rule-itself may need to be fine-tuned.
We talked
[
2 yesterday about the tech spec operability question, for 4
i 3
example,-and whether you could apply that to those SC s --
1 i
4 that are necessary to mitigate or prevent design-hsis 5
- events.
6 I've had the opportunity to take a good, hard 7
look at whether you can - implement _ the - license renewal l
8
- rule, taking advantage of what we've done-in the 9
maintenance _ context and, in particular, to rely-upon-the L
l 10
-. maintenance rule as--an effective program, without going 11 through a
component-by-component analysis of- _ aging-12 degradation.
That's a question that seems to-me needs to be analyzed carefully.as well.
13 j
14 There may-be some instances of those two in L
l 15 particular - but, beyond that, - other. instances - where the 16 rule itself may need to be fine-tuned.
I'm personally not g
.17
. opposed 1 to that.
It's logical;-in a complex _ area like_
l
.18
- this, where mid-course _ corrections either ' in Lthe L
19 implementation of the ruleL or. perhaps the rule: itself-
[
20 will, in the long-run, provide-for. greater stability (and 21.
a_better:-product.
l.
' 22 Third, and finally,JI'd emphasize, as I'said at;
{
23
-the outset, I don't see anything in-the context of things
(
i
-24
. that we've talked about that, if:the rule is amended,_
25-
- would -implicate the two fundamental principles--upon which -
NEAL R. GROSS
- COURT REPORTERS AND TRANSCRIBERS
- 1323 RHODE ISLAND AVENUE, N W l
. (202) 234 4433 WASHINGTON, D.C. P0005 -
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the rule - is based.
I think that presents a more l
2 problematic proposition, and I'm pleased to hear that i
=
3 nothing that we've talked about in terms of fine-tuning 4
needs to implicate those two principles.
i 5
Sixth, and finally, in terms of timing, it's 6
obvious, and I think the Chairman has indicated, that we 7
need to revisit this. question at the conclusion _of your 8
senior management review, when you've had an opportunity 9
to get away-and think about these policy questions and put 10 down-on paper your thoughts about how we ought to proceed.
11 From what you've described,-that sounds like it might be j
12 in the late-February time frame, as you work your way 13 through this process.
1 14 I think another opportunity to come back and, in 15 briefings _ focused on these questions and the ones that i
16 came up yesterday, would be timely at about.that point in i
17 time.
So, I share the Chairman's view that we need to get 30 going on this effort as expeditiously _as possible,_with a 19 thorough-and_ comprehensive review of where we_ stand and r
20 where we're going.
21 CHAIRMAN SELIN:
Commissioner-Remick/
I 22 COMMISSIONER REMICK:
Mine is certainly an' easy-23 task.this morning and, in the spirit of. efficiency, I can i
-24
-say that I associate myself with the comments made_by_all-le 25
.three of - my colleagues -- - the five points' by Chairman
' NEA!. R. GROSS
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u.. -
46 f
1 Selin; the emphasis by Commissioner Rogers that you 2
shouldn't assume that the policymakers are finished with 3
their job, and shouldn't hesitate to come back to us; the 4
six points by Commissioner Curtiss, one that I might have 5
a little reservation although I'm not opposed to 6
considering fine-tuning the rule.
I view that as -- very 7
seriously, as a matter that you should look at perhaps as 8
a matter of last resort, but if we have to do it, we 9
should not hesitate to consider it.
But I'm happy to 10 associate myself with the comments already made.
11 One request I would have, Dr. Murley, yesterday 12 you indicated that perhaps additional resources might be 13 needed, and I realize you aren't prepared to address that 14 at this moment, but for my own information, and assuming 15 that the other Commissioners would be interested if they 16 already don't have that information, l'd be interected in i
17 the amount of FTEs that have been expended on this ef fort, 18 say, in the last two fiscal years, so I can put it in 4
19 perspective.
And I'm not thinking so much of the age-20 related resecrch effort, but I'm thinking more into.your 21 review under the. rule of separate out the Yankee Row 22 portion that had to do with license renewal and the 23 Northern States Power effort.
I'd be interested in the 24 amount of FTEs that we -- or resources,-if we had contract 25 money expended, and it need not be at this time.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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)I 47 1
DR. MURLEY:
That's just Part 54?
2 COMMISSIONER REMICK:
Part 54, yes.
3 DR. MURLEY:
Yes, I think we can send that up to 4
the Commission.
My intention is to have this review done 5
very quickly, so I think we could, in fact, come back to 6
the commission in late February.
It's just the right time 7
to do it because we've had this expertience with Yankee Row 4
8 and with Monticello who, I think, for their own rea.,ons, 4
9 different reasons -- and I have to say I don't think it's 10 because of the difficulty in the rule or the 11 implementation -- that caused them each to stop, for their 12 own reasons.
But now we're moving into what I regard ha 13 a more serious effort, and that is the B&W Owners Group 14 work, and I ' d like to get these policy issues sattled 15 before we move into that.
I think the Commission wants to 16 do that, and the sconer the better, 17
- Also, I have to mention that we're in. the 18 proceos of reviewing our resources and schedules for the e
19 advance reacter reviews, and we've committed to come back 20
-the Commission in the next couple of months on that.
21-And, so, I have to think of these resources all together.
22 That's taking much. more effort than anyone had 23 anticipated.
So, when we're thinking about this effort 24 and the advanco reactor ef fort together, I'll'have to put 25 those resource considerations together.
And I'm very NEAL R. GROSS COURT REPORTERS AND TRANSCRISERS 1123 RHODE ISLAND AVENUE, N W.
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1 interested to hear that - the-Commission regards this at-2 least as important, and maybe more isoportunt, than'the 3
advance reactor review, and I'll keep that in mind.
4 CHAIRMAN SELIN: If this 'isn't done right, we'll 5
never get to the' advance reactor.
6 DR. MURLEY:
Yes, I understand.
7 CHAIRMAN SELIN:
This meeting has taken on the O
sound of a Chinese-Leap Year, you know, with the-five h
-9 principles and the six points and the_eight treasures and i
10 the ' four modernizations, but it's very -- I mear., it's 11-
- really_very serious work,:so we'd=like.to-thank the staff j
12 for an illuminating and quite frank-and open discussion of l
13 where we stand. on these questions, and Deputy General-L 14-
-Counsel for his presentation this morning.
15 As you just said,_Dr. Murley,_the' issues we're 16 discussing in these three briefings are considered by-the r
L l'
H 17 Commission to be of'the very-highest priority, and-I'd-18 like to-repeat - the desire that we have for a-stable, 19 predictable, -and reasonable regulatory process within 20-
'which each utility can consider license: renewal..
I
- 21.
I would commend the staff for -- the-- excellent 22 briefings, for_ just laying the cards on the-table, seeing
. 23 where we stand.
We realize the enormous-amount of effort 24 that's (going __
on both on-the part
-of:
industry-L 25 '
representatives and 'the staf f,, to resolve the issues NEAL R. GROSS--
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_ discussed.
And let's just keep talking about this.
2 We'd like to thank you again for these very 3
informative briefings, open
- approach, non-defensive 4
approach, of where we stand, where we've made progress, l
5 where we have worked to go forward.
We look forward to 6
the third license renewal briefing on December 18th, and 7
to presentations sometime in late-February presentation, 8
as a seqttence of ongoing communications on this terribly 9
important topic.
Thank you very much.
10 (Whereupon, at 11:35 a.m.,
the meeting was 11 adjourned.)
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CERTIFICATE OF TRANSCRIBER This is to certify that the-attached events of a meeting of the United States Nuclear Regulatory Commission entitled:
TITLE OF MEETING: BRIEFING ON LICENSE' RENEWAL REGULATORY 4
GUIDANCE ISSUES PLACE OF MEETING: ROCKVILLE, MARYLAND.
DATE OF MEETING:
DECEMBER 8, 1992 were transcribed by me. I further certify that said transcription 1
is accurate and complete, to the best of my ability, and t:at the i
transcript is a true and accurate record of the foregoing events.
l
- f6LC'Yt Cy U
u y
c Reporter's name:
PHYLLIS YOUNG l
1 r
l i
4 h
r I
l l
. NEAL R. GROSS -
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20005
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i-
REVISED AGENDA LICENSE RENEWAL ISSUES BRIEFINGS FOR THE COMMISSIONERS DAY 1 -- RULEMAKING ISSUES o
- PART 54
-- Background
-- Scope of SSCs 12 /7 /M.
-- CLB
- Definition
- How to Maintain CLB
-- Resolution of Technical Issues
-- Maintenance vs License Renewal rules
-- Maintenance rule lessons learned DAY 2 -- PART 51 RULEMAKING & REGULATORY GUIDANCE ISSUES o
- PART 51 Environmental issues
-- GEIS and " states rights" 12.[f[92
-- Refurbishment Activities and Waste Disposal
- Standard Review Plan & Reg. Guide
-- Staff Reviews
-- Aging Research l
-- Industry Reports DAY 3 -- INDUSTRY INITIATIVES AND RESOURCES o
l l
- Lead Plant Activities l
- B&WOG Generic License Renewal Program g
qt
- Staffing and Resource Needs l
i i
l December 2,1992 ENCLOSURE
W ""h t
g e
ew e
2 D
o a
rp
$, o ag.9
-~i g
7 V'+9 j\\
e LICENSE RENEWAL ISSUES 1
DECEMBER 8,1992 i
i
DAY 2 AGENDA l
PART 51 RULEMAKING & REGULATORY GUIDANCE ISSUES PART 51 ENVIRONMENTAL ISSUES
- Responses to CEQ and EPA
- GEIS and State concerns
- Refurbishment. activities and waste disposal STANDARD REVIEW PLAN AND REGULATORY GUIDE
- Staff reviews
- Aging Research
- General Research
- Nuclear Plant Aging Research INDUSTRY REPORTS 1
i STATUS OF PART 51 TENTATIVE AGREEMENT REACHED WITH CEQ ON. PROPOSED APPROACH SEPARATE COMMISSION MEETING ON PROGRESS TOWARD' RESOLUTION OF PUBLIC COMMENTS AND SCHEDULE FOR COMPLETION OF PART 51 RULE AMENDMENTS.
i MEETINGS WITH EPA TO BE SCHEDULED TO DISCUSS i
~ RESOLUTION:OF THEIR SPECIFIC CONCERNS i
GEIS WILLBE MODIFIED TO.lNCLUDE RESOLUTION; l
l
):
OF PUBLICiCOMMENTS q
GEIS POSITIONS RAISE STATE CONCERNS L
- Need for power l
- Alternative energy sources
- Cost-benefit considerations l -
2i j
f INITIAL CEQ & EPA COMMENTS
- , CODIFICATION OF CATEGORY 1 ISSUES CODIFICATION OF; COST-BENEFIT. ANALYSIS USE OF 2.758 THRESHOLD FOR PUBLIC COMMENTS NUMEROUS TECHNICAL ISSUES FROM EPA f
i 4
9 3
e.
WASTE VIANAGEMENT ISSUES ADEQUACY OF INTERIM STORAGE SPACE FOR LLW AND MIXED WASTE ON-SITE SPENT FUEL STORAGE IN LIEU OF PERMANENT OFF-SITE DISPOSAL ADD T!ONAL VOLUME FROM REFURBISHMENT
-WORKER AND POPULATION EXPOSURE FROM HANDLING AND PROCESSING AND FROM TRANSPORTATION PENDLNG RESOLUTION OF HLW AND LLW ISSUES, PLANT WILL NEED ADDITIONAL ON-SITE STORAGE CAPACITY PUBLIC INTEREST-
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- - CHANGES IN FINAL RULE
- PUBLIC COMMENTS
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- ACRS/CRGR SENIOR MANAGEMENT REVIEW RE-PUBLISH REG. GUIDE & SRP-LR FOR COMMENT (COMMISSION APPROVED IN SECY 91-330) i 6
STANDARD REVIEW PLAN FOR LICENSE RENEWAL (NUREG.1299)
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DRAFT REGULATORY GUIDE GUIDANCE TO LICENSEE ON:
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STAFF REVIEWS OF RENEWAL APPLICATIONS REVIEWS TO BE BASED ON REQUIREMENTS OF FINAL RULE o
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- Review crit.eria will be revised to recognize new techniques or technical information l
POTENTIAL RULE CHANGES
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-Industry and public actions s
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UTILIZATION OF AGING RESEARCH
. CENTERS OF EXPERTISE
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- National laboratories j
r DEVELOPMENT OF SRP-LR AND REG. GUIDE l
l REVIEW OF INDUSTRY REPORTS
-NRR/RES
-National labs SPECIFIC AGING REPORTS REFERENCED IN SRP-LR 10
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BWR VESSEL INTERNALS IR TO BE COMPLETED I
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MAJOR OPEN ISSUES WITH THE INDUSTRY REPORTS INCONSISTENT WITH THE RULE i
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- - INADEQUATE JUSTIFICATION FOR TECHNICAL CONCLUSIONS-THEREFORE, irs WILL BE OF LIMITED USEFULNESSTO RENEWAL APPLICANTS l
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