ML20141G338
| ML20141G338 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8604230364 | |
| Download: ML20141G338 (42) | |
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ORIGINAL
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UNITED STATES OF AMERIC.s NUCLEAR REGULATORY COMMISSION In the matter of. .
I COMMISSION MEETING Meeting with NARUC on Implementation of Nuclear Waste Policy Act (Public Meeting) s Docket No.
l Location: Washington, D. C.
Date: Tuesday, April 15, 1986 Pages: 1 - 41 8604230364 860415 PDR 10CFR q PT9.7 PDR ANN RILEY & ASSOCIATES Court Reporters
- 1679 T 9r .NW.
r s ;
1 D I SCLA I MER 2
3 l 4
i 5
l 6 l This is an unofficial transcript of a meeting o.f the 7 United States Nuclear Regulatory Commission held on l
l 3 4/15/86 ..
In the Commission's office at 1717 H Street.
9 N.W.. Washington, D.C. (
The meeting was open to pubile l 10 attendance and observation. This transcript has not been l
11 reviewed, corrected. or edited, and it may contain
/
12 inaccuracles.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.105, it is 15 not part of the formal or i n.f orma l record of decision of the 16 matters discussed. Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authori=e.
22 23 24 25
..r' s 1
1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ---
4 4 MEETING WITH NARUC ON IMPLEMENTATION 5 OF NUCLEAR WASTE POLICY ACT 4
e ...
7 PUBLIC MEETING 8 ---
9 Nuc1har Regulatory Commission 10 Room 1130 11 1717 "H" Street, N.W.
12 Washington, D.C.
13 14 Tuesdhy, April 15, 1986 15 16 The Commission met in open session, pursuant.to 17 notice, at 2:08 o' clock p.m., NUNZIO J. PALLADINO, Chairman of 18 the Commission, presiding.
19 COMMISSIONERS PRESENT:
20 NUNZIO J. PALIADINO, Chairman of the Commission 21 THOMAS M. ROBERTS, Member of the Commission 22 JAMES K. ASSELSTINE, Member of'the Commission 23 FREDERICK M. BERNTHAL, Member of the Commission i
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1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE: -
2 3 S. CHILK
-4 M.-MALSCH 5 E. ANDERSON 6 R. BRATTON 7 A. MEAD 8-9 AUDIENCE SPEAKERS:
10 11 V. STELLO 12 R. BROWNING 13' 14 15 16
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1 PROCEEDINGS 2 CHAIRMAN PALLADINO: Good afternoon, ladies and 1
3 gentlemen. Today the Commission is meeting at the request of 1
4 the National Association of Regulatory Utility Commissioners
~
5 known as NARUC. We are meeting with NARUC's subcommittee on 6 Nuclear Waste Disposal.
7 We will be discussing NARUC's views of NRC's '
8 approach to the licensing requirements of the Nuclear Waste 9 Policy Act as it impacts Department of Energy nuclear wasta 10 activities and associated resource expenditures.
11 NARUC has expressed interest in assuring effective !
12 project management and adequate cost controls for the nuclear i
13 waste disposal program's financial support that is ultimately 14 provided by the ratepayers.
15 Here today representing NARUC are Commissioner 16 Edwyna G. Anderson, Chairperson of NARUC's Electricity 17 Committee and Subcommittee on Nuclear Waste Disposal as well 18 as Commissioners Robert W. Bratton of the State of Washington 19 and Anne Mead of the State of New York.
20 Ladies and gentlemen, we thank you very much for 21 coming here to share your thoughts with us and unless there 22 are any other commissioner comments, we look forward to 23 hearing your presentation. Are there any other Commissioner 24 comments?
25 (No response.)
4 1 CHAIRMAN PALLADINO: All right. Then let me turn 2 the meeting over to, I gather you are going to be the 3 spokesman, Ms. Anderson.
4 MS. ANDERSON: Initially, yes. Thank you very 5 much. We are very grateful for the opportunity to meet with 6 you this afternoon to discuss some of our concerns and I will 7 be giving you a summary of how we got involved and why and 8 Commissioners Mead and Bratton will have some questions that 9 we would like to pose to you with regard to the Nuclear Waste 10 Disposal program and the NRC's role in it.
11 We would like to have this as informal as possible 12 in the sense that we have come to discuss. We have not come 13 necessarily just to present but are very much interested in i 14 your input.
15 The development and construction of a high-level 16 nuclear waste disposal facility is as important an issue as 4
17 any in our time both from a physical and a fiscal point of 18 view.
19 Creation by the Congress of the Nuclear Weste Fund 20 under Section 302 of the Nuclear Waste Policy Act of 1982 21 results as you know in the assessment for this project of one 22 mil,1 for each kilowatt-hour of electricity generated by 23 nuclear fuel.
24 Funds are to be used to dispose of all spent fuel 25 from commercial reactors. Despite frequent references to '
1 1
5 1 utilities which are called on to collect the' money, it is 2 ratepayers who are the source of all these revenues.
3 Recognizing this, the National Association of 4
Regulatory Utility Commissioners or the NARUC established, by 5 unanimous resolution at its 1984 annual mee. ting, its intention 6 to investigate and to monitor on an ongoing basis the national 7 nuclear waste disposal program.
8 To implement the resolution, a standing subcommittee 9- on Nuclear Waste Disposal was established and represents the 10 views and the positions of the NARUC as contained in this
- 11. statement.
12 The Subcommittee seeks to provide critical 13 information to commissioners in all states and to impart to 14 -tha Congress and to the Department of Energy the NARUC's-15 unique expertise in utility regulation so as to enhance the 16 conduct and cost effectiveness of the federal program.
-17 We are here today to open with you, the members of-1 18 the Nuclear Regulatory Commission, what we hope will be a 19 continuing dialogue on this matter of great importance.
20 The NARUC is a quasi-governmental, nonprofit 21 organization founded in 1889. Within our membership are the 22 governmental agencies of the fifty states and the District of 23 Columbia, Puerto Rico and the Virgin Islands engaged.in the 24 regulation of utilities and motor carriers.
25 Among other duties, the NARUC is the national 4
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1 representative of state commissions responsible for the 2 economic regulation of utilities now operating nuclear-powered 3 electric generating stations. As such, these commissions have 4 been charged under law with the task of ensuring that the 5 power provided by such generating stations is reliable and 6 reasonably priced, in short, that the public interest is 7 protected.
8 The driving force behind the NARUC's involvement in
- 9. this federally-mandated process, aside from the safe and 10 orderly removal of spent reactor fuel from temporary storage 11 at in-state nuclear reactor sites, is the concern for sound 12 fiscal management of the program.
13 Recognizing the technical complexity, the public 14 apprehension, the need for absolute assurance of safety, and 15 the necessity in the public eye for administrative 16 credibility, it is no wonder that this program represents a 17 vast financial commitment, now estimated to total $25 to $35 4
18 billion dollars.
19 My colleagues and I in commissions across the nation 20 are required by law to judge the fiscal bases for the 1
21 reimbursement by ratepayers of every penny of nuclear wasta 22 program payments made by utilities to date.
23 In attempting to place in focus the concerns and 24 recommendations of the NARUC on the high-level waste disposal 25 program and to suggest solutions to problems identified by us, !
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i 1 7
1 it is essential first to understand some of the painful 2 learning experiences that public service commissioners have 3
accumulated from a closely-related activity, nuclear power 4 plant construction review.
5 That this experience carries messages for the wasta 6 disposal program rests, to be sure, with the obvious nuclear 7
, focus of both arenas, but much more with the fact that this a
nation is once again moving toward construction of a very
'9 expensive first-of-a-kind technically complex nuclear facility 10 both proposed and licensed at the federal level.
11 Actions of the safety licensing agency, the NRC, 12 will very substantially affect program continuity, extent and 13 cost. The NRC may make changes in definition of an acceptable 14 final facility throughout and perhaps even beyond the 15 construction program.
16 The constructor, Mun DOE, while cost-conscious, has 17 -a task of taking nuclear waste by 1998.
r Thus, cost may be a 18 secondary concern.
- 19 However, all total costs are to be laid at the feed 20 of, or more aptly, in the pockets of ratepayers. Public 21 service commissions are faced with the unenviable task of 22 determining whether all future costs have been discovered and 23 whether, to date, program costs were prudently incurred.
24 Our review should not be understood as an assessment 25 of the nuclear option. The NARUC is painfully aware that the
8 1 national experience with nuclear power ranges from excellent 2 to abysmal. The popular press has made most citizens aware of 3 the troubled, expensive and checkered past of nuclear electric 4 generation.
5 Whereas nuclear construction costs have soared to 6 levels never imagined by anyone years ago, the even more 7
astounding fact is that despite massive infusions of capital, 8 many nuclear plants will never be finished.
9 Not so noticeable to the public but obvious to 10 public service commissioners is that not all nuclear plant 11 projects have been troubled.
12 Why have apparently similar companies had such i
13 different degrees of success? Are there reasonable answers or 14 explanations to the widely-varying results of performing 15 essentially the same job?
16 There are many reasons offered and perhaps all have 17 some relevance. They all point to, among the many factors, 18 the level of competence, ability and aggressiveness of project 19 management as a key factor in the success or failure of a 20 project.
21 Evidence from failures points to management. Some, 22 not all, that underestimated the size and scope of the task 23 i
before them and, as the challenges grew and complexity 24 increased, repeatedly continued to underestimate the challenco 25 and mismanage the projects.
9 1 We are sadder, but perhaps wiser, veterans of a 2 process in which gaps in interests and responsibilities among !
3 utilities, state and federal regulators and others appeared, 4 remained unresolved and which in the end will reduce 5 efficiency.and results, and will be left to public service i 6 commissions to overcome. ,
7 There are three central conclusions to be drawn from 8 this brief description of a lengthy, complex, arduous, 9 expensive and controversial experience. The first is that, 10 despite all the acknowledged changes, interruptions, 11 -diversions and reconsiderations, there are well-managed plants 12 whose overall costs are on an industry-wide basis within 13 reasonable limits. That proves that the job can be done.
14 Secondly, excellent management of a project is 15 mandatory if the project is to be successful.
16 Third, constructor and regulators, both state and 17 federal, must coordinate so as not to drag the system down.
4 ;
18 The NARUC seeks to reach out to overcome any 19 jurisdictional, management or regulatory gaps among major 20 partners in the was.te program without interfering with any 21 other entity's purview or prerogative.
22 That means we will not wait until 1990 or 2010 for 23 whatever price tag may. eventually result from the 24 deliberations, disagreements, deals and conclusions of other 25 parties. Our mandated responsibility to our ratepayers
10 1 requires our full involvement in the assessment of the nuclear 2 waste project to assure that cost-effective decisions are made 3 throughout the program.
4 With that introduction before you, we appear today 5' to open discussion on matters of waste disposal program 6 management, licensing and continuity.
.7 We have planned some questions for you that we 8 believe would help us carry out our responsibilities. We also 9 make ourselves available to you in a cooperative spirit in 10 hopes that this dialogue will contribute to a safe, deliberate ,
11 and cost-effective disposal of our nation's high-level nuclear 12 waste.
13 With that, I would turn to Commissioner Anne Mead.
14 I might indicate that we have with us also three of our staff 15 members to the subcommittee; Mr. Ron Callen, who chairs that 16 committee, Mr. Fred Haag of the State of New York and Ms. Kim 17 Hoover who is from the State of Washington. They are experts 18 in this field and would be also very responsive to any 19 technical or other kinds of questions and concerns that you 20 may have with regard to our activity and existence. i 21 Commissioner Mead. l 22 MS. MEAD: Good afternoon. In looking and reviewing 23 the waste management program, we have obviously reviewed the 24 role of NRC in the licensing process. We have several 25 concerns about that area. l i
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11 1 The first concern we have, I think, is how the NRC 2 commissioners, how do you view your role in assuring that 3 there will be an effective and efficient licensing process.
4 By that, I mean how will you oversee the staff in seeing that 7
5 precise definitions are arrived at, that there is some 6 precision in your requirements to DOE so that in their 7 responses to you, there would be enough precision in what you i
8 require so that any confusion or sending things back for <
9 further review and development and so forth might be avoided.
10 We just wonder how you view your role in this whole 11 licensing procedure?
12 CHAIRMAN PALLADINO: You would like us to answer 13 now?
14 Well, I could give you some preliminary thoughts and 15 my fellow commissioners are free to chime in.
16 We have not been down this road before as you have 17 indicated and so everything that we might do may not be 18 recognized at this time but we do have periodic meetings with 19 our staff and we do get periodic reports or significant memos 20 that they-generate.
21 We are encouraging and I believe the staff has been 22 having meetings with representatives of various groups to make 23 sure that we are getting the input from all groups that could 34 impact on our resources.
25 The staff is also looking at what it is going to
12 1 take for-them to do their licensing job and there are 2 disagreements between what the staff says and what DOE thinks 3 we can do. For example, we say the licensing process will 4 take us three years and DOE keeps saying, "Well, try for 27 5 months."
6 After listening to the staff, it seems to us like it 7 may -- and based on our experience, it may very well take the 8 three years plus some additional time.
9 The staff is also working on a tracking system or I 10 guess has pretty much developed a tracking system so that the 11 information that is developed and the information needed for 12 a dscision can be made available not only to staff but to 13 others that are interested.
14 This is in general how we work with our staff. When 15 it comes to important decision points the staff prepares 16 what we call SECY papers and it might be for information. It 17 might be for decision and we act depending on our feelings 18 about what they give to us and some times we send them back l 19 for further work.
20 Maybe some of my colleagues here would like *.o add 21 or we might even ask some of our staff people to amplify how ~
22 it looks from their vantage point.
23 COMMISSIONER ASSELSTINE: Joe, I would add just a 24 couple of thoughts. I would say, Anne, that I think the 25 Commission's involvement so far in the waste program has been
1 13 1 . fairly good and fairly intensive certainly since the Wasta 2 Policy Act was enacted and even before that. A lot of the 3 questions that we have discussed in our meetings with the 4 staff and you all have been issues that we focused on even 5 since before the Waste Policy Act was enacted.
t 6 The time that would be required for our licensing :
i 7 process, for example, is something that the Agency focused on 8 in its testimony before the Congress and we certainly have 9 paid a lot of attention to since the enactment of the i 10 legislation.
11 In terms of the oversight of the staff's activities '
12 and the program, I would agree with Joe's description of it.
A 13 We have been fairly involved in a number of briefings and 14 overseeing exactly what the staff is doing, looking at our 15 responsibilities under the Act, looking at the schedules that 16 are set out under the Act, and ensuring wherever we can that 17 we stick with those schedules or come very close to it or 18 exceed it in some instances.
19 I think we have been fairly successful on our 20 responsibilities, particularly the promulgation of our 21 technical and procedural requirements, our commenting on the 22 site selection guidelines and on the mission plan and more 23 recently on the MRS proposal.
i 24 One other thing that we do that might be helpful to L 25 you from the standpoint of your concern about fiscal
14 1 responsibility is that we do have to review and justify our 2 budget including the waste disposal program and I think that 3 provides another opportunity for the Commission to take a look 4 at the specifics of how many people we have, how much money is 5 being allocated to the wasta program, hcw that money is being i
6 used, how we are achieving progress in terms of carrying 7 forward our license responsibilities and we do that on an 8 annual basis as well.
9 Not only do we have to be satisfied but we also have 10 to convince our authorizing and appropriating committees that
- 11 our program is justified and is sufficient and is going-to be 12 carried out in an efficient manner.
13 Wherever the funds come from ultimately, we have to 14 get the Congress' approval for those funds.
15 So I would say those are a couple of other areas in 16 which, I think, the Commission has been involved and in which"'
17 we are trying to assure that this program is not only 18 effective but also is as efficient as it can be.
19 I would agree with Joe's comments as well on the 20 timing of the licensing process. I think we all do need to 21 recognize that the repository is a first-of-a-kind facility.
22 It is as I think you have recognized in some of your letters 1 23 to us a very complex proceeding involving very substantial 24 amounts of technical material and information and some '
25 difficult technical questions.
15 1 I think my own view and I think the view that the 2 Commission has consistently taken in' focusing on the issue is 3 the 36-month licensing process is probably realistic assuming 4 that we can do many things very, very well to master as much 5 of the information and identify as many of the issues as 6 possible early on in the process.
i 7 CHAIRMAN PALLADINO: Incidentally, in one of your 8 letters I think you had expressed concern about the fact that 9 if we go 36 months rather than 27 months this would impact on 10 ratepayers.
11 Could you expand the horizon a little bit for any 12 thoughts you have on what the nature of that impact would be 13 on ratepayers aside from the fact that it takes longer and 14 that that might use up some funds.
15 MS. MEAD: That's it. We have found that wherever 16 there are delays in the planning and construction of any kind 17 of a facility, that that translates into costs. The interest 18 keeps growing, you know. If wc take a Shoreham, $50 million 19 per month for each month that that plant does not come on 20 line, that type of thing keeps growing and it translates into 21 costs that go right back to the ratepayer from whom all manna 32 flows.
23 MS. ANDERSON: We think, too, the impingement of 24 that extended time on the final deadline for the first 25 repository, for example, may be significant in terms of the i
16 1 build-up of waste on site for utilities with additional .
. 2 funding being required there.
-3 We would be very careful to say that we do not think 4 that time should be a factor mitigating against safety. We 5 are equally concerned about safety and we want the process to 6 be as safe and as viable as we want it to be cost effective 7 and I can't emphasize that enough.
8 MS. MEAD: We don't just want hasta. WG want a 9 reasonable amount of time that assures safety but that does 10 not bog us down in horrendous costs.
11 CHAIRMAN PALLADINO: I think we have a common goal 12 in that regard to be as efficient as we can but we also found 13 that sometimes trying to cut short some of the processes ends 14 up in taking more time than if we follow the planned 15 procedures.
16 I think there will be a lot of interest and there 17 will be a necessity for hearings on a number of these points 18 and those are an important part of the process that extends 19 the time. <
20 Of course, if we have safety issues we want to 21 resolve them and I know you want to resolve them as well. We 22 don't want to get to a point and wish we had done something 23 different in order to provide the safety that we expect.
24 COMMISSIONER ASSELSTINE: Edwyna, your opening 25 statement focused also on learning the lessons from the past i
17 I 1 reactor experience. I think that is a very good point.
2 I think in a number of respects you can take some )
3 comfort from what the wasta management staff in the NRC is 4 doing. I think the focus really is on making sure that the 5 job gets done right but also in achieving efficiencies in the 6
licensing process wherever possible and learning from some of j 7 our experience in the reactor area.
8 One good example, I think, is quality assurance. I 9
am very proud of what the NRC staff is doing in the wasta j 10 program on quality assurance. They have really stressed the 11 need to DOE to have a strong QA program and to have that 12 program'in place now while they are beginning to collect the 13 data and information that they ultimately will rely on for 14 their application for the construction and authorization for 15 the repository.
16 I think that is a particularly good lesson and it is 17 one that does come out of the reactor area. That is an 18 example where, I think, the staff is taking a very forward-19 looking approach at how can we make sure when that application 20 comes in that it is a good application and that we can move 21 along on a reasonable licensing schedule such as the one we 22 have outlined.
23 I think at our February meeting the staff outlined 24 some other things that they were doing, one of which is an 25 effort to try and resolve issues generically through
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rule-making wherever that can be done'and also to identify 2'
issues early on while we are in this pre-licensing phase and .
3 Edo whatever we can to resolve those issues prior to the time t
4 of.the licensing hearing.
l 5 It strikes me again that those are lessons that we 6 have learned from the reactor area. You are never better off f'
7 if you are deferring issues to later on down the road. If you 8
can identify them, get them resolved in a way that is 9
technically responsible and defensible early on in the 10 process, it has to make the later licensing phase go much more 11 smoothly.
12 I think finally the effort to try and set up a 13 computer document system so that everyone is working from a 14 common base, I know that is an area you have had some concerns 15 about in terms of cost, but it strikes me that that is another 16 area where if the costs are reasonable, it ought to improve
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17 the efficiency and effectiveness of the licensing process. l 18 If everybody is working form the same basis of 19 information and everyone accepts that proposition at the 20 outset, it should make the licensing process go more smoothly 21 particularly where you have such a voluminous amount of 22 information.
23 MS. ANDERSON: That brings to mind the question that 24 Commissioner Bratton had with regard to the volume of data.
25 MR. BRATTON: I do have a question with respect to
19-1 that. You called it, Jim, computer document system and I 2'
assume, is that the same as you referred to as the tracking 3 system, Mr. Chairman?
4 CHAIRMAN PALLADINO: Yes, in part.
l 5 COMMISSIONER ASSELSTINE: That is part of it, yes.
6 MR. BRATTON: There are some estimates that have 7 heen given to our staff and I don't know the source of them.
8 I don't even know the accuracy of it but the numbers that we 9
have seen discuss tae potential of 300,000 to 400,000 10 documents developed by the NRC staff and then some potential 11 of up to 40 times as many documents to be developed by DOE 12 and/or others.
13 If that were to occur, using the maximum number, 14 that is something like 16 million documents and my quick 15 calculations sitting here this afternoon would indicate that 16 if you captured one cf them in machine-readable form in a i
17 minute, that would take 30.44 years.
18 COMMISSIONER BERNTHAL: That's probably about right, 19 isn't it?
20 (Laughter.)
21 MR. BRATTON: It just is beyond my comprehension how 22 that many documents could be generated. I guess if those 23 numbers are -- if I have them correctly and there is that kind 24 of potential --
25 COMMISSIONER BERNTHAL: Welcome to Washington.
20 1 MR. BRATTON: -- can you really develop this system 2 that will capture and have available through some index for 3 retrieval this quantity of documents?
4 CHAIRMAN PALLADINO: I wonder if Bob Browning might 5 comment on that.
6 MR. BROWNING: Regardless of the number of 7 documents, the actual quantity, there clearly are going to be 8 a lot of documents.
9 CHAIRMAN PALLADINO: Are they going to be in the 10 300,000 to 400,000 range from NRC?
11 MR. BROWNING: Those are the current estimates but I i
12 would like to indicate that one of our initiatives in looking 13 at making this whole process more efficient is to try to make 14 sure that the number of documents is kept to the absolute 15 minimum. l 16 One of the key elements of this whole program is to ;
17 make sure that these documents as they get generated are 18 available to everybody on a real time basis and instantly 19 available for recall.
l 20 The whole purpose of this computerized program which l 21 basically DOE has the lead for it will be to make sure that 22 everyone that is an interested party in this thing has access 23 to the documents on a real time basis so that when the time 24 comes for the licensing process, there will be no discovery
~ 25 period.
21 1- 'In most of the other licensing arenas, discovery 2 could and up being years and_with this kind of document base, 3 you can imagine how long it would take if, in fact, all the 4 documents had to be dredged out in the usual manner. <
5 So this is one of the initiatives we have been 6 working on very closely with DOE. It is going to be an 7 extremely cost effective thing in terms of time, real time a when it comes to the licensing process. ,
9 There also no question but what DOE and we need to 10 keep the number of documents down to the absolute minimum 11 necessary in order to do the job.
12 CHAIRMAN PALLADINO: Bob, is your estimate 300,000 13 to 400,000 from NRC alone? That is roughly 100 documents for 14 every person that works in the Commission, the whole Agency.
15 MR. BROWNING: But this is over a period of a long 16 period of time.
17 CHAIRMAN PALLADINO: Even that because not everyone 18 generates documents in this area.
19 MR. BROWNING: This includes memos, drafts and if we
- 20. have an efficient system --
21 COMMISSIONER BERNTHAL: It is everything, virtually 22 everything.
23 MR. BROWNING: -- it works into this computer 24 system, will essentially purge the system Of all irrelevant 25 documents. Typically in a discovery process, the lawyers tell l
22 1 las that the problem in these hearings is that all kinds of 2 drafts come up with marginal notes, et cetera. This system, 3 if it is put in and discipline is imposed on both DOE and our 4 systems, that kind of system will not be in place at the time
-5 discovery comes in and the hearing process taker place.
6 COMMISSIONER BERNTHAL: Let me just interject here a 7 comment or two so ycu understand what we are trying to do. It 8 is clear that if we had that many documents with the current 9 system that this agency has it would fall flat on its face.
10 We would be drowning in documents. The discovery process 11 'would never end.
12 I think we are going to be saved by technology here 13 and it took some fighting to get it done and I believe that we 14 are now embarked on a program in conjunction with DOE to try 15 to rationalize and computerize with the best technology li6 available our document system here.
17 So it isn't as bad as it sounds and I would just say 18 although I am not a defender of document generation, I am e 19 realist. That includes every memo and every letter, every 20 piece of paper basically that relates to the Nuclear Waste 21 Policy Act.
22 It sounds staggering but I am not surprised. That ;
i' 23 is the way this city runs.
24 If I may go on in a little bit more general vein, I ,
25 don't know what the latest estimate I got of the total 1
1 23 q l
1 fraction of cost in the Nuclear Waste Policy Act execution 2 that will be attributable to the NRC, I don't know what the 3 total fraction of that was, maybe Jim can help me out here,
-4 the number ten percent sticks in my mind but maybe it was 30 5 percent. What is that estimate?
6 COMMISSIONER ASSELSTINE: I think it is a lot 7 smaller than ten.
8 COMMISSIONER BERNTHAL: Does anybody know?
9 MR. STELLO: Four or five.
10 COMMISSIONER ASSELSTINE: Vic is saying four or five 11 percent.
12 COMMISSIONER BERNTHAL: Four or five percent, okay.
13 I have to say that the NRC's track record on timely licensing 14 is not what it is generally perceived to be on the outside.
15- It is odd that you would be hearing this from me because I 16 think I am very much on your side in your concerns and in the 17 general concerns of the public about the NRC, the efficiency 18 of the licensing program and what-not, but if you look at the 19 record this Agency by in large has not been responsible for 20 delaying plants per se because of the licensing process.
21 Now we can get into arguments over TMI imposed 22 backfits and things like that but the licensing process per se 23 has not necessarily been where the money has been spent in 24 .nany of these vastly too expensive nuclear power plant 25 projects.
24 1 Therefore, I'see no reason to make the judgment 2 ahead of time here that for the four or five percent of that 3 appallingly large amount of money, $25 to $30 billion dollars 4 I-just read, I believe, in your statement, Commissioner 5 Anderson, that for that four or five percent that the NRC 6
itself will not manage its four or five percent of that very, 7 very large quantity of money. We may not, but I would like to 8
think that at least we will follow the track record that I 9 think has characterized this Agency in recent years. Let's j 10 give us a couple of years after TMI and that is that we will 11 I do our job uith some degree of expedition here and sor.a degree l 12 of efficiency.
13 I would just suggest that it is the nat?p:e of the 14 process that has been set up that is costing $25 to $35 15 billion dollars and perhaps the real comparison to make and 16 the question to ask is what will the actual construction of 17 the repository -- what will the cost of that be along with 18 the licensing if you will?
19 I would not hazard a guess on that. I am sure DOE 20 l
would be'far better than I would be at it but the difference 21 between that and it is large and $25 to $35 billion dollars is '
22 the process that the Congress of the United States has set up.
23 Now we are paying a very large price for that l 24 process. That is the impact on the ratepayers in my 25 judgment. I see no way to avoid that because the nature of
25 1 .the system demanded that that process be set up and I think 2
Jim Asselstine appreciates that as well as anybody at the 1 3 table here.
4 I am sure that there will be delays. I hope that 5 they are not NRC induced delays. But you can almost count on 6 it. This process is going to go on and part of the reason is 7
that there is a-large segment of society in this country whose 8 very interest it is in to perpetuate the process.
9 There will be very much perpetuation of process as 10 we go through this in the next 20 years. I don't have a doubt 11 about that. All I can do as a Commissioner with a relatively 12 short term compared to the life of this whole thing is to give 13 you my assurances that we are going to try to manage this 14 Agency at least to the extent that I can and I think everyone 15 at this table in a way that is efficient.
16 I don't think though that even if we did our job 17 ideally perfectly here that that is going to be the big impact l L 18 on your ratepayers. l 19 Rather, it is this huge difference between what a 20 repository will actually cost to build and the total amount of i
21 money that this project is going to cost and that, I am 22 afraid, is built into the process itself. That was written 23 into the law. That may be discouraging but I think that is 24 the way it is and that is probably what we are going to have 25 to life with.
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- 1. MR. BRATTON: Our point with respect [to the number
,2 of documents was not that you haven't come up with the right 3 system in order to handle it. In fact, I think we commend
<4 your planning with respect to that. It is that estimate that 5' has us buffalced because to the degree that that estimate of 6'
the potential number of documents is realized, the ability of 7
your developing that system and in effect handling that number 8 of documents.
9 My little example of one minute per document taking 10 30.44 years is part of the problem and to the extent that this 11 system may not work, then we have delays and potentially some 12 issues that can potentially be litigated. They couldn't get )
13 their document. They tried and they couldn't.
14 If you follow what I am trying to say, it is the 15 sheer number and really will this system work and I suppose 1G- the rebuttal will be "if not that, what." I 17' COMMISSIONER ASSELSTINE: Yes.
18 MR. BRATTON: I don't know that but we are just so 19 overwhelmed or at least I personally by this $16 million 20 dollar figure.
21 CHAIRMAN PALLADINO: Our EDO has some comment he l
22 vould like to make. Mr. Stello, our Executive Director for 23 Operations.
24 MR. S*ELLO: I think the question is a very, very 25 good question and an important one and one that has led to
27 1 this whole issue of how is it that you.are going to manage 2 these documents.
3 Even if we were to develop the system which is in 4 fact developed at t2un present time, if all of the parties 5
don't agree to participate in it, we haven't gotten very far 6 and I will be telling the Chairman and the Commissioners that 7
hopefully by the end of this week, they will have a package 8
that is going to suggest that we want to do something 9 different here.
10 We are going to ask for a negotiated rule-making 11-process to bring in all of the parties and develop a proposed 1:2
-rule to get the commitment from all of the parties and the 13 Indian tribes that they, in fact, will participate and use 14 this system to avoid that very problem.
15 This means not only will -- and those documents are 16 not NRC, there are contractors and all the correspondence and 17 if you look at our files it really boggles your mind as to how 18 many documents we really deal with but it is a routine 19 process, but if all the parties participate in it and they 20 enter in also their documents into this system so that I
! 21 everybody has immediate access and the decisions can be made 22 on the basis of those documents that everyone has a chance to 23 see so that the decision is made on the best available 24 information, everybody knows what the basis for the decision 25 is and everybody can see it.
- l. - - - - - -
28 1 Then I expect to see rather substantial and 2 significant efficiencies in being able to get thic job done 3
with in my mind a very thorough sound basis that everybody 4 understands as the basis for getting the job done.
5 So I hope that we are successful and that parties 6 will, in fact, take the first step which is to agree to come 7
in and negotiate what ought to be in this rule-making to make 8
sure that everybody's equipment and systems that are in place 9 are compatible.
10 If everyone agrees to do that, I see a very 11 substantial improvement in our process and I will -- maybe I 12 jam exaggerating -- but orders of magnitude better than 13 anything that we can do with our conventional licensing
\
14 process today. I 15 COMMISSIONER ASSELSTINE: I think that is a very 16 good point that Vic raises and it ties in with a unique aspect 17 of this particular proceeding and that is that Congress made 18 the decision in this case that, as Bob I am sure you are aware 19 being from a potential host state, that the states and 20 affected Indian tribes were going to be funded and that they 21 were going to receive funding from the program sufficient to 22 hire their own independent experts.
23 What we have is the situation where states and 24 Indian tribes, in fact some within your own state, that I an 25 told are hiring some of the best experts that are available i
29
~
1 in some of these areas and they are going to be generating a 4
2 substantial amount of material and information.
3 We can to a certain extent control what we do. DOE
, 4 can control what it does but you are also going to have for 5 the first. time, I think, other participants.in the process 6 that are very well funded, that are equipped with some of the a
7 ' best technical talent that is available in .tte field and they 8 are going to have to be part of this process to make it work.
9 I think really this kind of an information ,
10 management approach that we are trying to put in place really 11 is an essential element. Otherwise, as you say, what else? I 12 don't know what the alternatives are.
4 13' But this to my mind holds out the prospect for some 14 management of what is obviously a very challenging task.
t i 15 CHAIRMAN PALLADINO: Incidentally, we would be 16 interested in any thoughts you have on our Information 4
17 Management-Tracking System either now or as you see it develop 18 because your input can be very helpful to us as well as the 19 input of many other people.
j- 20 MR. BRATTON: Thank you.
I 21 CHAIRMAN PALLADINO: Do you want to go to another 22 issue?
23 MS. MEAD: Yes. If I could return to the issue of 24 the involvement of the Commission. I think that question 25 arose because of our review of various documents, one of which I
30 1 was the Kemeny Commission Report which' indicated that the NRC 2 Commissioners at that time had largely isolated themselves 3~ from the licensing process and from the overall management of 4 the NRC.
5 So I think that I gather from what you said that 6 this Commission will taks a more activist role in this 7- licensing process and hopefully in management of the program.
8 Is that a correct assumption? ;
9 COMMISSIONER ASSELSTINE: I think it is and I think 10 there is one other important distinction that you should take 11 . away with you as far as this licensing process as compared I
l
{ 12 with the reactor process.
i 13 When the Commission first set up the licensing 14 process for the repository, it made a very conscious decision
- 15 to divide the process into two parts. One part is the formal !
16 part after we get a license application which will be several ,
17 years down the road. From that point forward then the i
1 18 Commission really is in the position of being the ultimate 4
19 judge in the case and at that point, you will have the l
20 hearings and the restrictions on Commission involvement in 21 those hearings-because we will be the ultimate judge of the 22 case or whoever is on the Commission at the time.
23 But the Commission also recognized that there was a
.i -
24 substantial period of time where significant information would 25 have to be developed before the formal licensing process
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31 1 . starts.
2 In that sense, that is the process we are in now.
3 The Commission made the conscious decision when it set up the 4 regulatory framework that it wanted to stay involved in that 5 part of the process. It wanted to oversee this informal, 6 pre-licensing portion. I think that is what we are doing.
7 I think that is a difference from the reactor area 8 because the reactor area, you always start with a license ,
9 application that has come into the Commission and the '
10 announcement of an opportunity for a hearing or a required 11 hearing and almost immediately you are into the formal p ocess '
t i 12 - where the Commission has to remain somewhat outside of the ;
I 13 direct involvement of the staff's review and the hearing 14 itself.
15 We have managed to avoid that, I think, by the way 16 that the repository licensing process is structured. The 17 result is more direct Commission involvement and oversight of 18 what is going on particularly in these crucial early stages.
19 MS. MEAD: As a follow-on to that, Commissioner, it 20 is my understanding, however, that you are going to use the 21 same licensing process; that is, a two-step process, the 22 construction and operating license, as you have used in the 23 reactor model.
24 We wonder whether or not you have looked at that as 25 maybe the proper vehicle for licensing a repository because-
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32 1 we think that the reactor and repository safety and construction and operation are not fully alike.
2 Recognizing.
3 the double procedural trouble in entering and maintaining 4 movement in the process, the legal and organizational 5 differences between the DOE and an investor-owned utility and 6 the length of a license years here, it is not 40 years but let 7 ~us say forever, we wondered whether a two-step type of 8 licensing process is a correct process or whether you have
.9 thought about that at all.
- 10 We wondered whether a more continuous type of 1
11 licensing where as things were completed, they would be 12 reviewed and there would maybe be a sign-off on that ;
i
- 13 particular area.
14 I refer again and I hope you will excuse me to the 15 Kemeny Report which said that licensing is a two-step 16 process. The company must obtain a construction permit and 17 several years later an operating license and the CP stage does 18 not require complete design plans and therefore, the full 19 safety review does not occur until the operating license 20 stage.
21 By then, and this is our concern, by then hundreds 22 of millions of dollars have been spent or committed in the 23 construction process and the ultimate safety review may be 24 influenced by economic considerations that can lead to a 25 reluctance to order major changes.
33 1 Now we know as a matter of fact that some major 2 changes have been ordered in the reactor area causing the 3- expenditure of a lot more money.
4 So I wonder if you have looked at that process as 5 the proper one for this project.
6 COMMISSIONER BERNTHAL: Let me just make a comment 7 - and I am sure there will be others.
8 There is a fundamental difference that Jim already 9 alluded to, I think, between what caused some of the problems 10 in nuclear power plant licensing and the licensing process 11' that I would envision here.
12 First of all, I would expect that the Commission 13 will be very much involved at every step of the way. I would 14 expect that our staff will be involved every step of the way 15 as the design develops for this repository.
16 But the fundamental difference is that this is a 17 first-of-a-kind. That does not apply to any nuclear power 18 plant that we licensed, I suppose, since the first one er 19 perhaps since the Clinch River licensing attempt.
20 CHAIRMAN PALLADINO: And even the first one had 21 prototypes before it.
22 COMMISSIONER ASSELSTINE: Yes, that is right.
23 COMMISSIONER BERNTHAL: So a one step licensing 24 process if that is what you are suggesting and that is what 25 the Commission is suggesting now for nuclear power plants
34 1 appears to be something that would work very well provided 2_ there is a backlog of experience and provided most importantly 3- that the utility comes in with a rather complete design..
4 That was not done back in the, 1960's and 1970's.
5 The utility came in and said or basically pointed to a GE BWR 6- or a Westinghcuse PWR, I won't get through all the vendors 7 here, but said, "We want one of those. We will get back to 8 you and let you know what the detailti of the design are 9 later."
10 That is the way the system was set up. That is the 11 way the utilities by in large preferred to proceed with the 12 system. We are not going to let that happen again here
. 13 either. This is a first-of-a-kind facility that we are going 14 to be licensing here.
15' I see no way other than continuous licensing maybe 16 and whether that is two-step or ten-step, it seems to me isn't 17 really the question. There has to be continuous exchange 18 between the NRC and the DOE licensee in this case just like 19 there was in the case of the Clinch River Breeder Reactor 20 which may be in some respects at least one of the better 21 analogies that we can draw at this point.
22 That is very different from doing the 101st or 105th 23 nuclear power plant license.
24 CHAIRMAN PALLADINO: Let me also add several 25 points. I wanted to make the point that this matter of a deep
35 1 geologic repository is a first-of-a-kind as Commissioner 2 Bernthal said and is a developmental process.
3 Actually, whether or not a one-step or a two-step 4 process is better, I don't think we have addressed as a 5
, Commission although there may be various views among the 6 Commissioners about whether or not a one-step process would be 7 feasible under this kind of a development program.
8 But the staff did address the one-step process in 9 dealing with the monitored retrievable storage and did feel 10 that perhaps a modified one-step process might work there but 11 it does not have the developmental characteristics that a deep 12 geologic repository has. i I
13 So while that might be a feasible thought for an MRS 14 that is completely designed in advance to my way of thinking 15 it is very questionable with regard to a deep geologic 16 repository because we have never seen one and the design is 17 being developed as information is being obtained and we are 18 trying to keep abreast of it and when we think it is ready to 19 get a CP license, we would like to see a lot more work done 20 before we say that it is ready to operate.
21 i
COMMISSIGNER ASSELSTINE: I would add one other 22 comment. I agree with both Fred's comments and Joe's on the 23 first-of-a-kind facility but I think one point that you make 24 to us is a valuable one and one that we should focus on 25 however many steps there are in the process. That is we !
. O 36 1 should make sure that we don't wait until right before 2- operation of the repository before we' identify or address 3 significant issues that may come up.
.4 This is bound to be a learning experience no matter 5
how good the site characterization is, it will only cover part 6 of the geologic area in which tne repository will be built.
7 That means that there are bound to be some surprises and some 8 -new information that comes to light during the construction 9 process for the repository.
10 However we structure the process, I think your point 11 is well taken. We need to have the ability to identify 12 problems and new information as soon as it comes to light and 13 make sure that if there are new questions that need to be 14 addressed that they get addressed right away. Don't wait 15 until the and of the process when the facility is basically 16 complete and ready to go into operation to be addressing new 17 problems.
18 I think regardless of how the process itself is 19 structured, that part ought to be built in and that is 20 something that we can and should focus on.
21 MS. MEAD: I think that is basically our point 22 because to go back and do a lot of expensive retrofitting 23 after all of these billions of dollars have been expended --
24 COMMISSIONER ASSELSTINE: No' question about that and 25 I.think that is something that the staff and DOE might want to
. s 37
.1 look at and how to go about that part of the process and now 2 probably is not too soon to start thinking about that. I 3
think a lot of our efforts has been focused on the 4
pre-construction phase that we are now in but it is probably 5 not too soon to start thinking about how to structure the 6
staff's involvement and the NRC's involvement in the on-going 7 construction program to make sure that any problems are 8 identified, surfaced and addressed right during that process 9 as soon as they come up.
10 MS. MEAD: We are mindful that it is a 11 one-of-a-kind. I don't think what I have suggested is an easy 12 -- I mean this is a very difficult area, I think, in terms of 13 how to handle it but I am glad that you are going to give it 14 some thought.
15 COMMISSIONER BERNTHAL: I would just say that if 16 there is anything that is burned in the institutional memory 17 around here, it seems to me, is the futility of Mcnday morning 18 quarterbacking when it comes to licensing.
19 It has happened a few times to the NRC. I don't 20 think that any of us right now are in a mood to let it happen 21 again at least not on our watch, that is certainly the way I 22 feel, and if your concern is that somehow the second license 23 for operation if indeed there is one were some step is the 24 step at which the Commission is going to say, " Hold everything 25 in 1997. You forgot something in 1987," we certainly are not
38 1 intending to let that happen. '
2 I think that we are extremely sensitive to that sort 3 of problem because we have been around that track a few times.
4 MS. MEAD: I think both you and all of us don't want 5 history to repeat itself. We should be learning from history 6 because we end up in the same situation you do as our 7 ratepayers attack us.
8 COMMISSIONER ASSELSTINE: You raised the point also 9- about the degree of completeness of the design and the 10 application.
11 MS. MEAD: Yes, I did.
12 COMMISSIONER ASSELSTINE: That is something that I 13 think we haven't really come to grips with yet. Under the 14 ideal situation, just as I think we are trying to approach in 15 the power reactor araa, you would want a virtually complete 16 design before you start to build the facility.
17 But I think that the first-of-a-kind nature of this 18 facility, the unknowns in terms of the geologic environment, ,
19 and some of the difficult technical questions are going to 20 limit our ability to do that.
21 Now where you draw that line in terms of how 22 complete an application we are looking for, I don't know. But 23 it strikes me that that is something that again is not too 24 soon for our staff to start focusing on.
25 How much design information realistically can we
eo 39 1 expect for this facility and how much would we like to have l
2 and what programs do we need to have or does DOE need to have 3 in place to meet our expectations in terms of the level of 4 completeness of the design and the application that they 5 submit?
6 Clearly the more we can get of good sound j 7 information to justify the design and
- 2 complete it, the l
! 8 better off we are going to be but that is another valuable, I 9 think, suggestion that you made that we could perhaps ask the 10 staff to look at.
11 MS. MEAD: It is also another difficult area.
12 COMMISSIONER ASSELSTINE: Yes. It is not easy.
!< 13 MS. MEAD: It is very difficult.
14 COMMISSIONER ASSELSTINE: That's right.
15 MS. ANDERSON:
i I think we have exhausted what we l
16 came here for today. I must say to you how grateful we are 17 that we had the kind of dialogue that we have had, that you 18 enabled us to raise issues and we were able to talk back and 19 forth.
20 We recognize sometimes the difficulty in the more j 21 formal setting and we are very appreciative of this 22 opportunity. I would like to request the opportunity in the 23 future to come back at some point and to talk further with you i
24 as this whole process develops.
25 We thank you very much.
.o 40 1 CHAIRMAN PALLADINO: We certainly thank you for 2- coming and sharing your thoughts with us. I hope you are 3 maintaining an en-going dialogue with our staff and they, in 4 turn, with you because that will give you the opportunity to 5 see what their thinking is even before we get it.
6 It gives you an opportunity to get some input at an 7 early stage and it also gives us an opportunity to get 8 important reactions and questions that we might tend to take 9 for granted whereas you might not take them for granted in the 10 same way.
11 So again, let me thank you for coming and let me see 12 if other Commissioners have any closing remarks?
13 COMMISSIONER ASSELSTINE: I was just going to ask 14 one question. Are you satisfied that the arrangements we have 15 been able to put in place over the past I guess year or so in 16 terms of having the opportunity to discuss with the NRC staff 17 the kinds of information or questions that you have or giving 18 you the information that you need --
19 MS. ANDERSON: You are very helpful and I must say, 20 Jim, that it has been excellent to have you on board with us.
21 COMMISSIONER ASSELSTINE: Thanks.
22 MS. ANDERSON: It is just an excellent opportunity 23 though to have the advantage of talking with each of you and 1
24 we appreciate that.
25 COMMISSIONER ASSELSTINE: Good.
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i 41 l' CHAIRMAN PALLADINO: Thank you. We will stand 2 adjourned.
3 [Whereupon, the commission meeting was adjourned at 4 3:05 o' clock p.m., to reconvene at the Call fo the Chair.]
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2 REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5 meeting of the U.S. Nuclear Regulatory Commission entitled:
6 7 TITLE OF MEETING: Meeting with NARUC on Implementation of Nuclear Waste Policy Act (Public Megting) 8 PLACE OF MEETING: Washington,,D.C.
9 DATE OF MEETING: Tuesday, April 15, 1986 10 4
11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the commission taken 13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.
17 18 $-- LLLfM h N lu.f------- ------------
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