ML20127P173
| ML20127P173 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/1992 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Rogers NRC COMMISSION (OCM) |
| References | |
| NUDOCS 9212020115 | |
| Download: ML20127P173 (17) | |
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%,,,,,8 June B, 1992 MEMORANDUM FOR:
Commissioner Rogers FROM:
James H. Taylor Executive Director for Operations
SUBJECT:
OPTIONS FOR EXCHANGE OF INFORt.ATION WITH THE NATIONAL ASSOCIATION OF REGULATORY UTILITY COMMISSIONERS (NARUC)
The purpose of this memorandum is to provide you with a status report on discussions with representatives from the National Association of Regulatory Utility Commissioners (NARUC) on a NARUC/NRC dialogue on issues of mutual interest and to provide options for future exchanges of information with NARUC and individual State utility regulatory commissions.
The Commission met with representatives from NARUC on March 4, 1992. The Commission discussed a variety of economic issues associated with nuclear power plant operations and construction, as well as the high-level radioactive waste program.
The issues under discussion included: short-term expenditures to achieve long-term operational improvements; development of standards that meet beth economic criteria and safety considerations; rolling prudence reviews for new plant construction; and the effect of integrated resource planning (IRP) or least cost energy planning (LCEP) on license renewal and new plant construction.
Suggestions were made at the meeting by NRC and State Commissioners that NRC and State representatives should meet to discuss these and other issues in greater detail.
There was a general acknowledgement that NRC and NARUC should look for opportunities for exchanges of informaticn which could benefit NRC and State utility regulatory commissions in carrying out their respective responsibilities.
Subsequent to the Commission meeting with NARUC, the Commission issued a staff requirements memorandum, dated March 24, 1992, which directed the staff to work with NARUC in a task force-type arrangement to identify areas in which a further exchange of information would be productive.
In addition, the staff was directed to identify possible methods by which such information exchanges could occur.
During this process, the staff was directed to keep you informed of activities in this area. Once work 4ble options for how such excharges ;,T information are structured, including areas in whieb f:.:rt ivr coordination with NARUC is desirable, the staff was tn pr G you with options for your consideration and : t r. u m presentation to the Commission. The staff has
- h u ied a variety of options for further dialogue with NARUC on a number of issues of interest to both the NRC and NARUC.
Contact:
Spiros Droggitis, OSP S04-2367 c 00 u 0 a.
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4 Comissioner Rogers 2
State Programs staff reviewed the transcript from the March 4, 1992 Commission teeting with the representatives from NARUC to identify issues discussed as possible areas to pursue with NARUC.
In addition, the State Programs staff tret with representatives from NARUC and NRC staff from the Office of Nuclear Reactor Regulation and the Office for Analysis and Evaluation of Operational Data to identify further potential discussion issues. The list of issues identified during this initial screening is included as Attachment 1.
While NARUC remains very concerned with the status and cost of the high-level waste program, that issue is not addressed in this effort, furthermore, in consultation with you, State Programs developed a statement of proposed-objectives for this dialogue with NARUC.
Shelden A. Schwartz, Deputy Director, Office of State Programs, met with representatives from the State utility regulatory commissions of Michigan, Ohio, Illinois and Georgia in April and May.
Mr. Schwartz discussed the proposed objectives and potential list of issues to get reaction from the State Comissioners and staff.
There was general agreement on the proposed objectives.
The objectives of a NARUC/NRC dialogue are as follows:
EUgRtL STATEMENT 1he Nuclear Regulatory Commission (NRC) and State utility regulatory comissions under the auspices of the National Association of Regulatory Utility Commissioners (NARUC) have a common interest in safe and economic nuclear pNer plant construction, operations and decommissioning.
While recognizing that the NRC and State utility regulatory commissions have distinct regulatory responsibilities, NRC and NARUC further recognize the value of a continuing dialogue between the economic regulators and the safety regulator.
In this regard, focused discussions between NARUC and NRC for information exchange would be beneficial to State utility regulatory commissions and NRC in carrying out their respective responsibilities.
QEJECTIVE The objective of this NARUf /NRC dialogue is to exchange information between NARUC or individual State utility regulatory commissions and NRC by:
- Identifying issues of common interest;
- Determining which issues should be pursued and where exchanges of information would benefit NRC and NARUC; and
- Providing such information exchange.
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i DISCUSSION ISSUES The complete list of candidate issues for NARUC/NRC discussions follows:
Need for NRC _e_nd_ State reaulators to be better informed.
NRC and State Commissions and.itaffs would benefit from a better understanding of-how each other operates and to be better informed of each other's activities.
Health and safety relationshio to financial considerations.
Related to the-issue above is an intuitive conclusion that there is a relationship between radiological health and safety and financial decisions by licensees and economic regulators.
Being better informed on how-each other operates would allow this safety and financial interrelationship to be better understood by NRC and State utility regulatory commissions in carrying out their responsibilities.
Rollina prudence reviews of new construction: more information availgble uo II2nl.
Rolling prudence reviews are considered by some to give more certainty to the process by " signing off" on construction in progress.
Others are concerned that these " sign offs" shift the financial risk from the utility constructing the plant to the ratepayers and the State utility commissions.
Recognizing these differing views and that some State Commissions may be restricted by law from implementing rolling prudence reviews, there-nevertheless appears to be general agreement that having more and better information during a construction project would be a beneficial first step.
Settina rates which crovide incentives to make caoital investments for safety, A dialogue is suggested between the NRC and NARUC on a generic basis regarding the possibility of setting rates which give incentives to utilities to make capital investments for plant safety.
Performance standards that meet economic criteria and safety considerations.
NARUC and NRC can explore the possibility of developing performance standards that meet both the economic criteria that State utility regulatory commissions are concerned about and the safety considerations that-the NRC is statutorily obliged to enforce.
Intecrated Resource plannina-license renewal & new olant construction, Integrated Resource Planning (IRP) or Least-Cost Energy Planning (LCEP) is a r
State utility regulatory commission process-that _ requires. detailed utility-plans-for demand-side controls and supply-side expansion. 'The IRP review process requires utility companies to give the sar- '.?nsideration to all-energy sources, including conserve. tion programs, a.
a.ay do to new power plants when planning for future energy use.
IRP could have a.significant effect on license renewal and new plant construction.
The recent_ agreement to shut down San Onofre-1 is partially a result of an IRP process.
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Cost recovery of plant imorovertents near the end of olant life.
The cost recovery of a utility for plant improvements near the end of plant life such as at San Onofre-1 was identified as another issue.
This, too, could have an effect on license renewal as many State utility regulatory commissions assume no life extension when reviewing the cost of such plant improvements.
Independent Power Producers (IPPl. An issue identified is the possibility of an unregulated (by State utility regulatory commissions or the Federal Energy Regulatory Commission) independent power producer running nuclear power plants with a contractual obligation to provide electricity to a utility at a fixed price with no backup generating source available.
The question arose as to whether the IPP would be inclined to run a plant closer to the safety margin in order to meet these contractual obligations. An additional concern would be the long-term financial stability of the IPP.
Economic Performance incentive Proarams.
This issue was addressed by the Commission in a July 24, 1991, policy statement which raised potential safety concerns with certain elements of economic incentive programs (e.g. the use of sharp thresholds, the measurement of performance over very short time intervals, the lack of " null zoner," and inappropriate reliance on systematic assessment of licensee performance (SALP) scores or other performance indicators).
The policy statement suggested that State commissions be mindful of these potential negative effects on plant safety and discuss proposed programs with the NRC. We should continue this dialogue to ensure that these performance incentive programs do not provide an unintended negative effect on nuclear power plant safety.
Adeouacy of ooeratina and maintenance funds.
Assuring sufficient operating and maintenance (0&M) funds for nuclear power plant operation has been identified as another issue for discussion.
Decomissionino Costs. Another issue identified during discussions with State commission staff members was the uncertainty with decommissioning costs and whether utilities are maintaining adequate reserves for decommissioning.
Uncertainty about decommissioning reserves is exacerbated by related concerns regarding high-level and low-level radioactive waste disposal.
OPTIONS FOR EXCHANGES OF INFORMATION i
i The staff has ide.'tified a variety of options for exchanges of information with NAROL and individual State utility regulatory commissions.
The proper option will depend on the issue. The suggested apprnaches follow:
-- Tutorials / Seminars:
These could be used for providing basic information exchange and a general understanding of how each other conducts business. NARUC maintains a regulatory studies program through
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Michigan State University, a national regulatory research institute at Ohio State University, as well as its Washington, DC office, which all can be explored.
Contractors are also available to provide basic utility financial information.
NRC can explore with NARUC the most i
appropriate ways of providing this general information to NRC, State Commissioners and Commission staff.
In addition, NARUC holds three national meetings a year.
Since many State Commissioners and Commission staff attend these meetings, opportunities can be explored for discussing issues of interest and providing basic background information at these NARUC meetings.
For example, you brief the NARUC Subcommittee on Nuclear Isrues/ Waste Disposal on the status of NRC activities.
John Martin, Region V Administrator, met with the Subcommittee in the Summer of 1989 to discuss the NRC inspection process and the factors considered in placing nuclear power plants on the " watch list".
Other senior NRC staff have briefed this Subcommittee on issues of interest.
-- Workshops:
Hold workshops on specific issues with the appropriate NRC staff and State commission staff and develop recommendations for Commission and NARUC consideration.
-- Regularly scheduled sessions that are State / utility specific conducted by the Regions:
Regional Administrators could meet with State Commissions once a year to discuss generic and plant / utility specific issues.
For example, representatives from the Michigan Public Service Commission have met with Region til over the last several years to discuss generic issues and issues specifically concerning the nuclear power plants in Michigan.
Regions could also conduct a periodic meetings similar to State Liaison Officers meeting in the region to discuss generic issues.
-- Plant / Utility Specific Rate Cases:
NRC response to State-Commission requests concerning NRL participation in individual rate cases or prudence reviews has varied in the past.
NRC should develop uniform guidance on how, whether and to what extent NRC should respond to requests for information and NRC participation in individual ratemaking cases and prudence reviews.
-- Regular. Commission Briefings on Progress:
The-Annual-NARUC/NRC meeting in February / March should continue as an opportunity for the Commission and NARUC Commissioners to review the status of activities and provide further guidance to staff.
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Commissioner Rogers 6
In order to carry out the Commission's direction in the March 24, 1992 staff requirements memorandum, the staff is planning the following near-term activities:
la) Plan an education session for NRC senior managers on how State utility regulatory commissions perform their economic regulatory responsibilities, Ib) Explore with NARUC appropriate education opportunities to provide State Commissioners and Commission staff with background on NRC's safety role and esponsibilities.
- 2) Arrange a Working Group meeting with representatives from NARUC at NRC Headquarters to review the list of identified issues, set them in order of pr qrity and discuss the most appropriate options for addressing each issue.
The Office of the General Counsel has reviewed this memorandum and has no legal objection, Ia} I cb E ecutive rirector for Operations
Attachment:
As stated cc:
The Chairman Commissioner Curtiss Commissioner Remick Commissioner de Planque SECY OGC
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$ e ISSUES IDENTIFIED DURING MARCH 4. 1992 COMMISSION MEETING (The Commissioner making the suggestion and the pages from the transcript of the meeting are in parentheses)
Performance standards that meet economic criteria and safety considerations (Brown pp. 5; 82-83)
Rolling prudence reviews of new construction; more information up front (Selin pp.38-40; 43-48; 84; Rogers pp. 34-35; Curtiss pp. 51-52; &
Robinson pp. 40; 83)
Setting rates which provide incentives to make capital investments for safety (Selin pp. 19-21)
Need for State regulators to be better informed (Robinsoa p. 22 &
Shishido-Topel p. 50)
Integrated Resource Planning-license renewal & new piant construction (Shishido-Topel pp.28-34) 1:ealth and safety relationship to financial considerations (Curtiss pp.
77-80)
ADDITIONAL ISSUES IDENTIFIED Independent Power Producers (IPP)'
Cost recovery of plant improvements.near the end of plant life Economic Perfcrmance Incentives Programs-
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AGENDA far NARUC/NRC DIALOGUE OCTOBER 19.1992 PMomac_Jan - Rockville. Maryhuld 8:30 a.m.
Welcome - Opening Remarks Sheldon Schwartz, Deputy Director, Ollice of State Programs Commissioner Lynn Shishido-Topel Illinois Commerce Commission 8:45 a.m.
Logistics, Meeting Format, Objectives -
Nicholas Mann, Resolution Dynamics, Inc.
Facilitator 9:00 a.m.
NRC's Role and Reiponsibilities -
Martin Malsch, Office of the Gem ral Counsel 9:30 a.m.
State Utility Commissions' Roles and Responsibilities -
Commissioner Cas Robinson Georgia Public Service Commission 10:00 a.m.
Break 10:15 a.m.
Quick Review ofIssues and Begin Issues Discussion (See attached)
Working Lunch 3:30 p.m.
Summary and Adjournment t
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ISSUES FOR DISCUSSION 1.
ticed_foI E C and G_lai.e reglaJ d prs to be bettpI__ig qrAed liRC and State ComInissions and staffs wouJd benefit from a a
better understanding of how each other operates and to be bottor informed of each other's activities.
2.
Perform _ange standards thd mpe t_gg.gno_ln i c crj t erla_Ani.M[dy
.90Rsl.d era tion s.
NARUC and NRC can exp. lore the possibility of developing performance r.tandards that meet both the economic criteria that State utility regulatory commissions concerned about and the safety considerations tha' the are
!GC is statutorily obliged to enforce.
3.
En t eg r a t e d_ Rep ou r c e F i n n tl i n_g - l_lg e n s e_r e n e w al_and_ne w pj a n t cons t ru ct ioJb Int egrated Resource planning (IRP) of Least Cost Lnergy Planning (LCEP) is a State utility regulatory commission process that requires detailed utility plans for cmand-side controls and supply-side expar'sion.
The ikP review process requir es utili ty uompanies to give the e.no consideration to all energy source:3, including conservation programs, as they do to new power plants when planning foi future energy use.
IRp could have a significant effect on license renewal and new nlant construction.
The recent
-agreement to shut down bon Onoire-1 is partially a result of an IRP process.
4.
cost recovery o f_p_1_a n t i mpIo v e m e n t s_ n ta r t i e._eftd_9LD.la nt t
1ifn.
The cent recovery of a uti1ity for plant i mprovernen t s near the end of plant life such as at San Onort e-1 was identified as another issue.
This, tuo, could have an effect on license renewal as many State utility regulatory commissions assume no 11 % extension when reviewing the cost of such plant improvecern s.
5.
Mequacy_of opgraling_and_mai ntenance fun h Assuring culticient oporating and maintenance (OLM) funds for nuclear power plant operation has boon identified as another issuo for discussion.
i 6.
R_olling_prud e n c e reviews of new toAs t r u c t i o n;__,glorg
,information available up_fr_out.- Rolling prudence reviews are considorod by some to five more certainty to the process by " signing off" on construction in progress.
Others are concerned that these " sign offs" shift the financial rish f rom the utilit.y constructing the plant to the ratepayers and the State utility commissions.
Recognizing these differing views and that some State Commissions rnay be r estricted by law f rom implementirig rolling prudence reviews, there nevertheless appears to be general agreement that having more and better information during a const ruction project. would be a beneficial first step.
7.
Peo no_mj_q_Pe r f o rm3 n c e Incent,1ya Procrams.
This issue was
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e addressed by the Commission in a July 24, 1991, policy statement which raised potential safety concerns with certain elements of economic incentive programs (e.g. the use of sharp thresholds, the peasurement of performance over very chort timo intervals, the lack of " null zones," and inappropriato reliance on systomatic assessment of licendee performance (SALP) scores or other performance indicators).
'Ihe policy statement suggest.ed that State comnissions be mindful of these potential negativo offects on plant safety J
and discuss proposed programs with the NRC.
We should centinue this dialogue to ensure that these performance incentive programs do not provide an unintended negative
&4 clicct on nuclear power plant safety.
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Decommissioning _ costs.
Another icuue identified during b3 discussions with Stato commission staff r; embers was the uncertainty with decommissioning costs and whether utilitius are maintaining adequate reserves for decommissioning.
Untertainty about decommissioning reserves is exacerbated by related concerns regarding high-level and low-level radioactive waste disposal.
9.
Heal.th_and_pafety_rclationnhip_to_tingacial connidgratioRL Related to the issue abo \\e is an intuitive conclusion that there is a relationship between economic regulatorn Boing better informed on how each other operates would allow this safety and financial interrelationship to be better understood by NRC and State utility regulatory commissions in carrying out their tenponcibilities.
10.
p e t t j ng_r a t e s_w h i c h_prov i d e _i nc e rtt i v_qs to make cap _i_tal i nv e s tmen t g_f or Rafaty_.
A dialogue is suggested between the imC and NARUC on a generic basis regarding the possibility of setting ratcs which give incentives to utilities to make capital investments for p} ant safety.
11.
I nd ep e nd e n t ___. Powe r P_ rod u c e r s ( I P P )._
An issue identified is the possibility of an unregulated _ (by State uti)ity regulatory co' 'issions or the Federal Energy Regulatory Conission) i
?ondent power producer running nuclear power plants with L
'ntractual obligation to provide electricity to a utility at a fixed price with no backup generating bource availah'e.
The question arose as to whether the IFP would be inclined to run a plant closer to the safety margin jn order to meet these contractual obligations.
An additional concern would be the long-term financial stability of the IPP.
Discuss.ISS
s Commissi'oner Kenneth C.
Rogers U.S.
Nuclear Regulatory Commission Remarks Before the NARUC Subcommittee on Nuclear Issues / Waste Disposal November 15, 1992 Good morning Madam Chairman and members of the National Association of Regulatory Utility Commissioners (NARUC)
Subcommittee on Nuclear Issues / Waste Disposal.
Once again, it is a pleasure to be here before the Subcommittee to provide you with a status report on recent activities at the Nuclear Regulatory Commission (NRC).
When we last met in July in Seattle, I provided the Subcommittee with an NRC staff report on " Options for Exchange of Information with the National Association of Regulatory Utility Commissioners".
That report identified eleven discussion issues wnich were developed,from the March 4, 1992 Commission meeting with NARUC, and separate meetings with representatives from NARUC, public utility commission stafft and the NRC staff.
Also 0
identified in the staff report were various options for continuing a NARUC/NRC dialogue.
At that July meeting, I suggested that NRC staff and representatives from NARUC get together to explore the eleven issues in further detail and to discuss ways of furthering a meaningful exchange of information.
a I am pleased to report that the initial NARUC/NRC dialogue took place on October 19, 1992 in Rockville, Maryland.
I note that the NARUC delegation was ably represented by you, Madam Chairman, commissioner Robinson, Commissioner Arthur and staff from various State commissions.
A copy of the list of attendees is attached.
I regret that a previously scheduled out of town engagement precluded my participation, but Myron Karman of my office did attend and reported that he thought it a very successful meeting.
The NRC staff has prepared a draft summary of the October 19 meeting.
I understand that all meeting participants have received a copy of the draft summary and are now providing us with their comments.
Without prejudging the outcome of that report, I will offer you some preliminary thoughts.
The primary goal of the initial. dialogue was to identify areas in which a continuing exchange of information concerning economic issues associated with nuclear power plant construction, operations and decommissioning (including high-level waste disposal) would be productive.
I understand that the need for NRC and State regt'lators to be better informed of each others' activities was clearly established.
The meeting participants benefitted by learning each others' perspectives on common issues.
I believe that NRC and NARUC should continue to look for opportunities for such ir. formation exchanges and that meetings, seminars and workshops on specific, more narrowly defined issues would be of benefit.
I further understand that the meeting participants thought that presentations and discussions before
NARUC meetings or regiona'l associations of Stato commissions provide other opportunitias for information exchange and that plant / utility specific meetings with NRC's regional offices and individual State commissions or staff should be encouraged.
I am told that a theme which emerged from this initial dialogue was that if progress could be made on ways of arriving at the cost associated with an acceptable level of safety, then public utility commissions (PUC) and the NRC would be in a better position to discuss performance standards that meet both economic and safety considerations, determine adequate operating and maintenance funds, develop reasonable and safe economic per f orraa nce incentive programs, make assessments on the health and safety relationship to financial considerations and help in setting rates which would provide incentives for safety.
The draft summary of the meeting concludes that "This will not be an easy task and could very well be an impossible task.
However, as NARUC and the NRC develop a better understanding of how each other conducts its business, then possibly further insights into this issue will come to light."
As I mentioned earlier, a draft of the meeting summary is undergoing review and comment.
I appreciate NARUC's interest and participation in this effort.
I look forward to a final report and suggestions for a further dialogue.
I would ask members of the Subcommittee to help identify issues where exchanges of information would be helpful.
j I would like to just brie' fly provide the Subcommittee with the status of a couple other issues at the NRC before Myron provides you with a report on nuclear-related legislation adopted in the last Congress.
The NRC issued a proposed rule on reactor site criteria for public comment on October 20, 1992.
The NRC is proposing to amend its regulations to update the criteria used in decisions regarding power reactor siting, including geologic, seismic and earthquake engineering considerations.
The proposed rule primarily consists of source term and dose considerations and seismic and earthquake engineering considerations of reactor siting.
I understand that members of the Subcommittee have been provided copics of the proposed rule.
The comment period ends on February 17, 1993.
Another issue which I believe the Subcommittee may be interested is the Commission's recent approval of a final policy statement on integrated schedules.
The policy statement describes how the Commission intends to promote voluntary implemer;tation of licensee integrated schedules for regulatory requirements and other activities.
The Commission believes the iwplementation of integrated schedu]es on a plant specific basis will provide a systematic method of coordinating, managing, and scheduling major modifications and activities initiated by both the NRC and licensees.
The priorities are based upon general considerations such as safety significance, cost, availability of the plant and l
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The Subcommittee was also provided a copy of this policy which becomes effective on November 23, 1992.
Thank you very much.
I now turn to Myron for a legislative report.
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_s NARUC and NRC Meeting Participants October 19, 1997 NAME ORGAMIZATION Commissioner Cas Robinson Georgia Public Service Commission Commissioner Lynn Shishido-Topel Illinois Commerce Commission Commissioner Warren D. Arthur, IV South Carolina Public Service Comm.
John V. Stutsman Illinois Commerce Commission
-George Dunn CT DPUC Gayle Nichols SC PSC Richard (Dyke) Farrow NY PSC Myron Karman Commissioner Rogers' Office /NRC Richard Vollmer Office of Policy Planning /NRC Darrel Nash Office of Policy Planning /NRC Anthony Gody, Jr.
Office of Nuclear Reactor Regulation /NRC Martin Malsch Office of the. General. Counsel /NRC Thomas Novak Office of Evaluation and Analysis of Operational Data /NRC Sheldon Schwartz Office of State Programs /NRC Spiros Droggitis Office of State Programs /NRC Dennis J. Zaanoni Office of State Programs /NRC 4
Nick Mann Resolution Dynamics, Inc.
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