ML20151E515
| ML20151E515 | |
| Person / Time | |
|---|---|
| Issue date: | 07/12/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8807260103 | |
| Download: ML20151E515 (74) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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Title:
BRIEFING ON POLICY PAPER FOR PLANT LIFE EXTENSION Location:
ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND
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Datei TUESDAY, JULY 12, 1988 Pages:
1-53 Ann Riley & Associates Court Reporters 1625 i Street, N.W., Suite 921 Washington, D.C. 20006 (202) 293-3950 726 880712
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DISCLAIMER This is an unofficial transcript of. a meeting of the United States Nuclear Regulatory Commission held 7-12-88 on in the ' Commissions ' office at One White Flint North, Rockville, Maryland.
The meeting was open to public attendance and cbservation.
This transcript
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h'as not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, i t is not -part -of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as thd result of, or addressed to, any statement or argument contained herein, except as the Commission.may authorize.
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1 UNITED STATES OF: AMERICA 2
NUCLEAR REGULATORY' COMMISSION 3
4 BRIEFING ON POLICY PAPER FOR PLANT LIFE hXTENSION
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PUBLIC MEETING
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Nuclear Regulatory Commission 9
One White Flint North 10 Rockville, Maryland 11
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12 TUESDAY, JULY 12, 1988 13 14 The Commission met in open session, pursuant to 15 notice,.at 2:00 p.m., the Honorable LANDO W.
ZECH, Chairman of 16 the Commission, presiding.
17 COMMISSIONERS PRESENT:
18 LANDO W.
- ZECH, Chairman of the Commission 19 THOMAS M.
ROBERTS, Member of the Commission 20 KENNETH CARR, Member of the Commission 21 KENNETH ROGERS, Member of the Commission 22 23 24 25 e
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' STAFF:AND PRESENTERS SEATED AT THE COMMISSION TABLE:
2 J.
HOYLE 3
W.
PARKER' J
a6 T.
SPEIS 5'
B.
SHERON-6 D.
CLEARY
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7 V. STELLO-8 T.
MURLEY 9
10 AUDIENCE SPEAKERS:
11 R.
BOSNAK
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12 G.
ARLOTTO 13 4
14 15 16 l
17.
4 18 19-l 20 21 22 23 24 1
25-n 5
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1 PROCEEDINGS 2
(2:00 p.m.)
3
' CHAIRMAN ZECH:
Good afternoon, ladies and gentlemen.
4 The purpose of the meeting this. afternoon is for the NRC staff
-5 to brief the Commission on the licensing renewal rule-making, 6
This paper requests the Commission approval to 7
publish an advanced notice of proposed rule-making ~and to
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8 solicit public comment on NUREG-1317, Regulatory Options for 9
Nuclear Plant License Renewal.
10 After a day's meeting, I'd request the Commissioners 11 vote on whether or not to publish the rule and to seek comments 12 5n RUREG-317.
I understand the copies of slides are available 13 at the entrance of the meeting room.
Do any of my fellow 14 Commissioners have opening comments to make?
15 (No response.]
16 If not, Mr. Stello, you may proceed.
17 MR. STELLO:
Thank you, Mr. Chairman.
Looking at the 18 table today, starting over at'my far left is Dr. Murley and to 19 my immediate left, Dr. Speis and Brian Sheron on my immediate 20 right, who will do the briefing and the Project Manager 21 responsible for getting this job done on the far right is Don 22 Cleary from research.
23 The subject of the briefing is to explain to the 24 Commission something that we see coming into the future which 25 we think has the potential for being a very significant issue
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'l for the Agency as:well as for the ind'ustry.
2 As you are aware, and we will show'you in the 3
briefing, the number of operating plants whose-license will 4
expire at the turn of.this century is-a steep curve.and'hence.
5 the question is raised; how many and what number of these 6
plants may wish to extend the operating life'beyond the~ current 7
40-year licensed life of the plant.
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8 With today's climate with capital investment for new 9
generating capacity with 100 plus plants in operation at a cost 10 of a ' replacement plant today in the neighborhood of $5 billion; 11 it's obviously very, very significant.
Increasing the life
' l 12 6xtension of plants for even a modest period of' time of 5 or 10 13 years, has the potential for a very large savings to the-14
.American public on behalf of capital investment in new-plants 15 and to the rate payers.
16 It is an issue that is an important issue to us and 17 to the industry -- us for planning to be able to do it,.which 18 brings us to the subject of this meeting, which is how we are,
' 19 in fact, going to develop a licensing basis for~ renewal.
It's 20 obviously very closely coupled to the question of. plant aging 21 and what are those issue that we have to deal with.
22 It is~to me, an important subject that we would best 23 serve to have the Agency issue the proposed rule-making. events 24 notice to get conments and get the industry and members of the 25 public to come in early in the process.
It sounds like it's a
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1 long time away, but what.we have been told by the industry is 2
that this is a decision that they will be making in the very 3
near future in plans.
4 If they are not going to be able to renew the-
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license, then they have to get replacement generating-capacity 6
so that the time with which they have to make decisions, is j
7 well in advance of the time the license expires, in order for
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8 them to be able to reasonably plan.
In fact,.some of them have 9
indicated that they would like to be able to be prettv firm 10 about what the process would be, before they would make that 11 decision, hence the need to resolve this issue.
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12 With that introduction, I will ask Brian to take us 13 through the briefing and I think it will become more apparent, 14 with the sense of urgency about-it, is as you see, the~ data 15 that he will present in the briefing.
Brian?'
16 MR. SHERON:
Thank you.
The two topics I'll talk 17 about are the staff activities that are underway right now and 18 our schedules and the regulatory options that we are looking at 19 for relicensing.
On the second slide, you will see what Vic 20 was just talking about.
Most utilities have a 12-year planning 21 horizon for deciding their new generating capacity needs.
22 We have the Department of Energy and EPRI, both 23 heavily interested in this.
In fact, DOE is in the process of 24 putting out, I believe, a request for proposals to fund like a 25 demonstration plant for license renewal starting in 1991.
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The first operating plant that will have.its
.2 operating license expire is Yankee'Eowe.
With the extension' l
3 that was. granted, which starts their 40-year life from the CP, i
4 moved up to the operating license, their operating license 5
would expire in the year 2000.
If we assume that there's a 2--
-6 year'NRC review required, which is an approximate number right i
7 now for a license renewal review, and that there's a 12-year 8
lead time, then if you look at the number of plants that would-l 9
.potentially come in for a renewed license application before 10 the year 2000, it's 35 plants.
11 On Slide 3, this a graphical illustration of the' 12 Humber of plants that will have their OL's within 12 years of 13 expiration, versus the calendar year as shown.
You.can see, as 14 Vic said, that starting.around the year 2000, a very, very 15 steep rise in the number of applications which represents the 16' number of plants that were licensed around 1980 and right after 17 TMI, 1983 and so forth.
We expect to see the first application 18 in very soon and we expect to see a number of them coming in 19 within the next several years.
20 CHAIRMAN ZECH:
Is the staff in place to accommodate 21 these requests?
22 MR. STELLO:
No, sir.
23 CHAIRMAN ZECH:
When are we going to do that?
24 MR. STELLO:
We will need to answer the question in 25 terms of budget space, probably starting in next year's budget
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cycle, to really accommodate it.
We can handle a modest' number i
2 of licenses.
I'd ask Tom is you could' speculate within the 3
next three of four years, the number of-applications you think 4
you could. accommodate within what we already have.
5 MR. MURLEY:
Probably -- we expect to get one or two 6
or three lead applications.
We could.do that with what we've 7
got, but we'd soon -- I think it-would take more than the i
8 resources that we have, watching operating reactors.
9 CHAIRMAN ZECH:
How long do you think it will.take to
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10 accomplish license renewal?
Do you have an estimate?
How many 11 people are involved here.
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12 MR. MURLEY:
I think once, Mr. Chairman, once we get 13 through the first plant or two and have a prototype under our 14 belts, it shouldn't take too long.
I would be guessing, but my 15 feeling is maybe a couple of years.
The first plant -- we have 16 to frame the issues, and that's why I think it's important that 17 this rule be settled as quickly as we can so we can frame the 18 issues and how we're going to go about it.
19 MR. STELLO:
It probably depend a great deal upon 20 what the final rule is on this subject, as to what the scope of 21 the licensing renewal review process is.
If you recall, as 22 Brian just said a moment ago, we are assuming that we will use 23 two years to do the review in terms of planning.
It will take 24 us two years to get through the review and then the 12 years 25 for the planning horizon is how you could get the number to 35.
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I don't think any of us could tell-you that we know
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2 that two years is a bad guess', but based on prior experience, 3
it's not unreasonable..That is, we get toward the tail end of 4
the process, I'm sure we'll be doing a lot better with it.
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'really need to plan for a very steep curve which is toward the
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6 end of the century.
7 CHAIRMAN ZECH:
General Counsel has a question.
8 MR. PARLER:
Mr. Chairman, I realize that my time 9
will come later, but I think it's very important to learn some j
10 lessons from the past, the lessons that were learned during the 11 initial licenses of these plants.
I don't think you want to 12 wait or the Commission would want to wait or it would be sound 13 policy to wait until the applications get here; then to decide l
14 what the issue will be.
15 I thought that the very heart of this policy 16 discussion, that perhaps eventually will come on the scene as a 17 rule, would be to decide, among other things, what the 18 licensing basis -- that is, what the technical requirements for 19 licensing the renewal of these plants are.
That's the point 20 that I wanted to make.
21 CHAIRMAN ZECH:
Okay, fine.
I agree.
Well, along 22 the same line, on the first slide you nentioned DOE's 23 participation in the lead plant?
24 MR. SHERON:
Yes.
25 CHAIRMAN ZECH:
CouldLyou explain that just a little
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bit more?
What is their role?
Are they going to sponsor it?
2 How are they involved?
3 MR. SHERON:
My understanding is that'they_are 4
planning to sponsor a lead plant financially, by, I think, 4
5 banically providing-them so many dollars.
I don't know what 6
the number is -- over a certain amount of time -- to support j
7-
-their license renewal activities.
Primarily, it's a 8
demonstration type of a plant.
9 CHAIRMAN ZECH:
Is that their plant or one of our's?
10 MR. SHERON:
It would be a commercial plant.
11 CHAIRMAN ZECH:
A commercial plant -- well, getting j
l 12 6ack Eo the General Counsel's gr9stion, it seems to me we do 13 need to lay in place a pretty solid foundation, rather than 14 wait for applications.
We have a fair amount to do, it seems 15 to me.
That's, I guess, what you're going to tell us.
It is 16 important that we be well prepared for this.
I would imagine 17 that this is a cather significant task and certainly, we should 18 be preparing for it now.
I presume --
19 COMMISSIONER CARR:
We're.behind in our_ work already.
20
, Twelve years and there's plant coming up in 12 years from 21 today.
22 MR. STELLO:
Well, the first one is, in fact, 12 23 years from today -- that's Yankee Rowe.
24 COMMISSIONER CARR:
I visited them last week and they 25 said, what are we going to do about renewing our license?
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a timely meeting.
2 MR. STELLO:
And one for which we're trying to 3
suggest to the Commission that what we'd like to do is quickly 4
and crisply get on with developing the rule.
That's the 5
purpose of this meeting and that'was the reason for my opening 6
comment, to suggest that if you look at when the large number 7
of plants are going to be looking for license renewal.' If you 8
look at the curve, it looks like it's a long way off, but it 9
really isn't.
I think that's the point you're making.
It's 10 now and I agree with you.
11 MR. MURLEY:
I think we need to clarify a point.
It 12 does not take us 12 years to make a decision, but the utiliPy 13 has know whether to replace that plant -- where to start 14 replacing that plant; that's the 12 years.
We can, of course -
15 16 COMMISSIONER CARR:
It doesn't take us 12 years to l
17 make our decisions.
I'm trying to figure out what's going to i
18 take 2 years.
Is it 2 years per plant or 2 years to get the i
19 procedures in place and then we can do the plants with a little 1
20 more rapidity than that.
21 MR. SHERON:
I'll jump ahead here.
The schedule that 22 we're proposing is to put regulations in place that would be 23 available so that the industry would know what the NRC 24 requirements are, by about 1991 at the latent.
This allows 25 some uncertainty in whether there's a public hearing required J
11-1 or something like that.
2 This is consistent with our understanding of when the 3
industry needs to have these regulations.in place.
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4 discussed this with the industry.
NUPLEX, I'believe is the 5
industry organization.
I have a letter from Mr. Niles which 6
indicates that our current schedule appears reasonable to them
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and doesn't really produce any hardships.
8 MR. STELLO:
Brian, I think the Commissioner's 9
question was, how long will it take us to do the reviews.
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MR. SHERON:
We're assuming about 2 years.
We're 11 estimating 2 years.
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12 COMMISSIONER CARR:
What review are we talking about?
13 MR.'STELLO:
From the time the application comes in 14 asking for a license extension, till we review it and get an 15 approval out -- 2 years to do that.
16 COMMISSIONER CARR:
When that application comes in, s
17 we will have told them what we want in it.
It will take us 2 18 years to review all that data?
19 MR. STELLO:
Yes, until we're finished.
20 CHAIRMAN ZECH:
Will we tell them ahead of time what 21 we expect?
22 COMMISSIONER CARR:
You have to.
23 MR. STELLO:
Yes.
24 CHAIRMAN ZECH:
This is what I think we need to do.
25 When the application comes in, I recognize that we need review
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time, but before they put in an application, it seems to me we 2
have~an obligation to put out what are the requirements -- what 3
do we expect and what.are we looking for?
4 MR. STELLO:
That's our plan.
5 CHAIRMAN ZECH:
When are we going to have that?
Is
'6 that all in thic?
7 MR. STELLO:
We're going to tell you how we're going
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8 to develop that in the briefing and that guidance in the body 9
of the rule.
-l 10 CHAIRMAN ZECH:
That's. going to be in place by 1991?
11 MR. STELLO:
Yes, the final rule, which will --
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12 CHAIRMAN ZECH:
Which will give the standards, the l
13 expectations ano the requirements that were anticipated.
14 MR. STELLO:
That's correct, yes.
15 CHAIRMAN ZECH:
All right, well let's go ahead then, 16 I guess.
17 MR. SHERON:
On Slide 4, I just wanted to bring to 18 your attention here that we have tried to pick up some time in 19 our schedule by eliminating the issuance of a policy statement, 20 but rather coing directly to a proposed' notice or rule-making.
21 We recognize that the policy approach would have declared ^the 22 Commission's intent in this matter in producing such.as policy 23 for you to issue.
24 However, whet: we looked at 'he overall picture of t
25 license renewal, we felt that a' rule offered substantially more g -, -,
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benefit to the industry as well as to the staff in providing 2
more definitive guidance.
3 NRR made the suggestion, we took a lesx at it, and we 4
agreed that, indeed, we could probably pick up at least six 5
months on the schedule by going directly to a proposed notice 6
of -- advanced notice of proposed rulemaking.
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7 CHAIRMAN ZECH:
Well, did you think about the 8
necessity of going through the advanced notice of rulemaking as 9
opposed to just going through proposed rulemaking?
And what 10 was your rationale with going through with the advanced notice 11 of proposed rulemaking?
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12 MR. SHERON:
The fact that we were studying options i
13 for rulemaking, and I'll get to those in a couple slides.
One 14 of the things that we wanted to do was to solicit the public's 15 comments on this whole process.
16 We've been trying to do this in a very open form to 17 make sure that we properly considered comments on relicensing 18 from all different organizations that are interested.
19 CHAIRMAN ZECH:
Well, we certainly want to do that, 20 but can't we do that in a proposed rulemaking also?
We solicit 21 comments.
We have comment period on proposed rulemaking.
22 That's my understanding.
23 MR. SHERON:
But we did not have a specific rule 24 prepared at this time.
Our schedule was calling to have a 25 specific rule with specific requirements, etcetera, available
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in about a year from now.
2 We did have an options paper prepared, which is the-3 NUREG, which you've seen, and we felt it would advantageous to 4
solicit comments on those options, make sure that we've covered i
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'5 all the options and, therefore, we could factor the public 6
comments when we develop this final proposed rule.
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CHAIRMAN ZECH:
Okay.
I'm not finding fault with 8
what you're doing.
I just want you to explain the rationale 9
that you came up with.
10 MR. SHERON:
We really couldn't have prepared a rule
.I 11 any quicker than what we're doing right now.
What we are doing 12 In thIs stage is actually being able to consider public comment i
13 much earlier in the process.
14 CHAIRMAN ZECH:
All right.
Let's proceed, j
15 MR. SHERON:
On slide 5, as I said before, when we 16 take a look at the current regulations that are in place, we i
17 don't believe that they really provide adequate guidance to the 18 industry with regard to relicensing a plant that has operated 19 for 40 years.
20 Our program right now is designed to develop 21 regulations and sufficient regulatory guidance for the industry.
22 so that we can start processing their applications beginning in 23 the 1991-1992 timeframe.
i 24 And as I said before, based on our discussions with 25 the industry, this appears consistent with their needs.
On J
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15 1-slide 6, just to point out that in the Commission's policy and 2
planning guidance, as far back as
'86, NUREG 0885, we were 3
provided I guess guidance to proceed with the developing of 4
license renewal rules and regulations.
5 Also in the PPG of 1987, it has retained'the same 6
wording.
On slide 7, you'll see-th'at there is just a history 7
of some of the things we've been doing in license renewal.
l 8
We started this back in November of 1986.
We issued 9
a Federal register notice with a number of questions regarding 10 license renewal and solicited public comment on those.
11 In SECY 87-179, which we sent to you last July, we 12 gave you a status of the activities that were. going on in the 13 licensing renewal rulemaking activities.
14 As I said before, in February, we analyzed the rule 15 versus policy anu decided we could substantially reduce the 16 schedule by going directly to a proposed rule.
17 And as you have before you, SECY 88-180 presents the i
18 regulatory options and the advanced notice of proposed 19 rulemaking.
20 on slide 8, what we have here is our proposed 21 schedule.
And what we are preposing is to complete our draft 22 of the proposed rule by February of next year, which is about 7 23 or 8 months.
24 We will taxe it through CRGR, ACRS and the like, and 25 we would propose to have it before you in June of
'89, just in e
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about 11 months.
2 We would hope to got your approval and be able to 3
publish the rule, the proposed rule, by September.
We are 4
proposing to hold some public meetings once the rule is issued 5
s6 we can again solicit public comments on the proposed rule, 6
as well as to receive them by written comments.
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7 And we would like to publish the final rule in 1991.
8 We will, in parallel to preparing the rule, be al.co preparing 9
regulatory guides and standard review plans that we can have 10 issued in the early 1990's.
11 We fon't have any definitive schedule yet for each 12 guide",'but che thougnt is to get them, the important ones you 13 might say, the key ones that_the industry needs, out on the 14 street in about the same timeframe as the rule.
15 COMMISSIONER CARR:
For the industry's planning, 16 won't the rule stand alone?
17 MR. SHERON:
The rule will provide the basic 18 guidance, but ycu typically need regulatory guides to provide 19 clear interpretation of what constitutes an acceptable 20 submittal.
21 COMMISSIONER CARR:
But if those don't come out till 22 the 1990's, and that goes all the way to 1999, you know --
23 MR. SHERON:
Well, I said -- I'm sorry.
Early 24 1990's, if you -- on the slide.
Our plan is to issue the reg 25 guides around the same timeframe as the rule.
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COMMISSIONER CARR:
I guess I was really worried.
2 Why does it take a year to get the rule out, or is that by 3
1991.
Is that December '91?
4 MR. SHERON:
Right now. I would not want to hazard to 5
guess which part of 1991.
There are a lot of uncertainties, as 6
you're aware.
7 COMMISSIONER CARR:
Well, let's say you hold all the 8
dates befote that, and that public meeting takes place in 9
November or December
'89.
10 MR. SHERON:
It could be as early -- it could be 11 early 1991 then.
If we had very little public comments and we
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12 could incorporate them very easily, we could have a proposed 13 rule down in early 1991.
14 COMMISSIONER ROBERTS:
I think it will be unrealistic 15 to assume there's going to be little public comment.
16 MR. SHERON:
Well, that's why we didn't try and --
17 COMMISSIONER ROBERTS:
I undetstand.
I'm not taking 18 issue with you.
19 CHAIRMAN ZECH:
Let's proceed.
20 MR. SHERON:
On slide 9, within the NRC, the Office 21 of Research has the principal responsibility for developing the 22 renewal rulemaking, and also the conducting of the aging 23 research program whica vi'l provide substantial support with 24 regard to technical aidence to the. industry on the content of 25 the applications for the rulemaking.
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We have been down and advised the ACRS on everal 2
occasions of the license renewal activities.
We have very 3
close coordination with the other program offices within_the.
4 Commission.
5 We have a number of steering groups in this area 6
'which are designed to make sure that we coordinate all of the 7
activities.
8 Slide 10, please.
The question that we are s
9 struggling with right now, and I guess is central to the e
10 renewal issue, is what should be our' approach in requireme"nts
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11 for renewed' licenses in order for continued assurance of public 12 healtK and safety.
13 That's the basic question that we have to answer.
On 14 the next slide, you'll see that we have tried to bracket the
.i 15 alternatives with what we would call reasonable possibilities j
16 here.
17 The first one is an approach which would perpetuate 18 the original licensing basis of the plant, just modified the 19 way it's been amended over the years.
20 A second approach, which is sort of at the other end 21 of the spectrum, would be that a plant that has run 40 years 22 would be considered a new plant and, therefore, would have to 23 meet the licensing requirements for new plants, that new plants 24 would have to meet at the time they proposed to submit their 25 renewal application.
4.
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00MMISSIONER ROBERTS:
Well, if you use that, you 2
won't renew any.
3 MR. SHERON:
That's,probably correct.
A third 4
-approach is one in which we look at_the original licensing 5
basis and modify it as necessary to take into account any-6 significant safety concerns that one m3ght have with the aging
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7 process or beyond 40 years of_ life.
8 one may want to employ a PRA,;for example, to 9
identify the risks, significant components, and systems and to 10 nake sure that they're not subject to any accelerated aging.
13 Also, another area we're looking at is that some 12 plants may commit and only want to run two more years.
Others 13 may commit and want to run 10 years.
14 And the question is_do we want to set the same 15 requirements for both types of plants, or do we want to have a 16 graded approach.
17 COMMISSIONER CARR:
What was the basis for the 40 18 years?
19 MR. SHERON:
My understanding, it was an economic 20 consideration.
21 MR. PARLER:
The 40 year provision in Section 1039(c) 22 of the Atomic Energy Act, it was not based on the technical 23 grounds or safety considerations at all.
24 There is a good little bit of lag'slative history on 25
'he subject which is contained in one of the earlier reports.
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It goes.by the name ofithe NESP-Report that was done in 1986.
2 In order to save time, the 40 year period was based 3
on essentially the financing practices,-amortization, etcetera.
4 It has noti'ing at all to do with the technical considerations 5
or with public health and safety.
6 COMMISSIONER CARR:
So we're going to try to find a
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7 technical reason to extend the non-technical license.
8 MR. MURLEY:
We did review the plants, though, on the 9
basis that we had to be satisfied they could last 40 years.
So 10 even though the original did not have a technical basis, once 1
11 the rule was in place, then we've been reviewing it so that the 12
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13 COMMISSIONER CARR:
But that review was at least 40 14 yea.s, I assume.
15 MR. MURLEY:
I'm not following you.
j 16 COhN1SSIONER CARR:
You had to make a determination i
17 that they would last at least 40 years.'
18 MR. MURLEY:
At least 49 years, that's right.
19 MR. SHERON:
Keep in mind that at the time the plants 20 were reviewed, a couple things.
One is that certain cocponents 21 were actually designed for 40 year lives.
22 Like for example, thermal sleeves were designed for 23 so many thermal cycles.
Ono needs to know have they hit that 24 thermal cycle limit?
Have thu exceeded it?
How far away are 25 they?
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The other thing is that even though we did review 2
plants for 40 years, we did not have any information on aging 3
at that time.
4 And as plants have been operating, we have been 5
accumulating information on the aging process, and as we learn, 6
we see that aging does have an'effect on safety and I think we 7
need to take that into account now once we go beyond 40 years.
8 CHAIRMAN ZECH:
What kind of a research basis do we 9
have for making regulatory decisions on the plant aging?
Do we 10 have strong research base?
Do we have a -- is industry 11 participating in it in a strong way?
Has DOE got any 12 participation in it?
What is our research program and what are 13 other research programs, what kind of a research confidence 14 factor do we have?
15 Please identify yourself for the Reporter.
16 MR. BOSNAK:
I'm Bob Bosnak.
The Division of 17 Engineering, Office of Research, we have a -- between our aging 18 research program, which is about an 00 million program per 19 year. we also have the pressure vessel integrity program which 20 has aspects of aging and aging research.
21 We are cooperating and coordinating our efforts with 22 the EPRI, Electric Power Research Institute.
The Department of 23 Energy also has'research functions.
24 So the answer to your question, we feel we have a 25 strong program in aging.
We're identifying, or trying to
22 1
identify, the areas that we need to look at.
Which areas need 2
to prioritized.
3 There is also a strong tie-in to the maintenance rule 4
that's coming before the Commission.
Obviously, maintenance 5
plays a strong role in managing aging.
6 If you have a good program for maintenance and you 7
are replacing things before they fail, you have confidence that ~
8 the plant is going to be operated and run safely.
9 CHAIRMAN ZECH:
Are we working with the international 10 nuclear organizations?
11 MR. BOSNAK:
Yes.
We've presented papers before 12 IAEA.
In fac., the international organization is following the
~
13 approach that the NRC has taken in looking at how aging should 14 be managed.
15 COMMISSIONER CARR:
Those major components, the 16 reactor vessel and the containment, are the research programs 17 for those going to be completed in time to support this piece 18 of paper that's going to tell then what they need in their 19 license renewal application?
20 MR. BOSNAK:
Well, the two major components, the 21 reactor vessel and the containment, the work is continuing on 22 those.
23 I don't know if we'll have all the enswers in place 24 by the time that the rule will be out, but we expect to do the 25 best that we can.
- y
23 1
We are answering the questionsfon, for instance,, low.
2 upper shelf.
The fact that some vessels:may need to be 3
annealed.
Some vessels will approach the-point in their life 4
that they will have to do something, either flux reduction.
5 This is'one of the things that' going to be inc1bded, 6
or it will have to bh included, _ in any rule., The consideration I
7 of the vessel and also, of course, containment with respect to 8
any degradation mechanisms.
9 COMMISSIONER CARR:
Yes.
It's the timing that's got 10 me worrir,d.
11 MR. STELLO:
I think the utilities have sufficient 12 Information today that if they are going to plan for life 13 extension, they know what the lifetime fluence they're going to 14 accumulate in 40 years, and where they will be with respect to 15 our requirements for vessels today.
16 So if they do plan, they will know they either are l
17 going to have to get a flux reduction program early to 18 accommodate additional lifetime of the vessel, or they're going 19 to have to make plans on annealing the vessel.
It can be done.
)
20 I think the Soviets have already done, _as I recall, I
21 two of'them.
They've annealed them.
They've had actual i
22 experience with vessels.
23 But those are the choices.
The utilities, with 24 rAspect to-the pressure vessel,-I think, today,_ based on the 25 research we've already done, has the technical information
s-
' 24
_1
- available to them now to make those kinds:of_ decisions, i
2 COMMISSIONER CARR:
So you must have'it available to 3
lput it in the rule.
4 MR. STELLO:
We already have a rule in place.
The 5
Trul'e is in place and it does dictate how to do a calculation 6
for pressureEvessel lifetime due to fluence with time.
7 So there is enouch information, I think,_for the d
8
. utilities to make those kinds of decisions now.
And those are 9
the only two components that you really need-to worry about.
10 Essentially, the rest of the-components you_can
- 11 replace.
You can replace-piping, steam generators.
~
~
9 12 COMMISSIONER ROBERTS:
Putting a drill on in some 13 instances to replace steam. generators.
14 MR. STELLO:
But, nevertheless, it's a real 15 possib'ility if they haven.'t.taken care of them, they're sloppy i
16 on water chemistry --
17 COMMISSIONER ROBERTS:
I feel like when I was adding i
18 on to my house and I wanted to change and I asked the builder 19 and ne said, Roberts, with your time and my money, we can do 20 anything.
21 MR. STELLO:
But they do know if they.really are 22 going to plan for life extension on a steam generator, and they-23 want to use those steam generators, they'd better be very 24 careful about water chemistry.
25 Because if they're not careful, then tha likelihood f
~
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4-25 1-is they're going to have to replace steam generators.
They rt 2
won't last 40 years and they may not last 30.
3 There are some of them that you obviously.are_ aware 4
of that had to be replaced already.
So the care that the 5
utilities place with respect to components will dictate to what 6
degree they're going to have to replace those.
~
7 But nevertheless, they are replaceable.
So the big 8
components are pressure vessel, the steam generator, and the 9
containment.
10 If they give them proper care now, theyfre not going i
11 to be a problem. and I think they have enough information to 12 know that, l
13 COMMISSIONER CARR:
And we're running from l
l 14 shippingport, La Salle, all those, and their pressure vessels?.
15 MR. STELLO:
Yes.
16 CHAIRMAN ZECH:
How about just the knowledge of 17 piping and cables itself as far as aging is concerned?
I know 18
,they can bc replaced, of course, but what knowledge do we have 19 that would give us the confidence that certain cable could last 20 a certain number of years, or piping would retain its 21 resilience and strength over a perind of time?
l 22 MR. BOSNAK:
Again, we have ongoing research in the 23 crea of electrical components with respect to how long they're 24 going to last, what is their-probable failure mode, and when l
l 25 should they be replaced.
l l
l l
1
i 26 1
CHAIRMAN ZECH:
All right.
Thank you.
Proceed.
2 MR. SHERON:
On slide 12, the regulatory topics that 3
were examining the technological ones.
Verification of design 4
adequacy of a plant to be relicensed.
1 l
5 This is what we were just talking about here, the 1
6 residual life of components and systems, the replaceable versus 7
the non-replaceable components and structures, particularly the -
8 reactor vessel in the containment building.
i 9
And then the other thing we are looking at is how we l
l 10.
should compensate for uncertainties related to the aging i
11 process, and how do we take that into account in our licensing 12 process.
13 Also, recognizing though that we have an imperfect 14 knowledge of the aging mechanisms, although we are learning 15 more with our research.
16 We want to make sure that we can either predict the 1
17 age related failures before they occur, or to make sure that 18 have a compensating program.
19 And I would think of something like very aggressive 20 maintenance, surveillance, replacement program to make sure we 21 catch them before they really fall.
22 COMMISSIONER CARR:
What is the age of the oldest 23 fossil plant in the country, do we know?
24 MR. SHERON:
Well, I would imagine it's over 60 25 years, but I don't know for sure.
l
{
1
27 1
MR. STELLO:
We'll try to find out and get the answer 2
to you.
3 CHAIRMAN ZECH: ~All right.
Let's proceed.
4 MR.-SHERON:
On slide 13, the other regulatory topic 5
which we are currently evaluating is the scope of the 6
environmental review that might be needed for the plants.
7 Can we just do an update or our environmental impact
~
8 assessment or do we have to do a complete new impact assessment 9
for the renewed license.
10 We don't know yet, but it's just an issue that we 11 have to deal with.
On slide 14 --
~
~
12 MR. PARLER:
Do you want me to comment on that?
13 CHAIRMAN ZECH:
Please do.
14 MR. PARLER:
There are three aspects of the 15 Environmental Policy Act problem that we have identified and 16 Mr. Sheron is quite correct that we haven't finished our work 17 yet and haven't reached any conclusions, but the guidance is 18 clear to me.
19 First of all, in connection with the proposed 20 rulemaking, certainly my judgment would have to be an 21 environmental ass 2ssment.
22 If that environmental assessment concludes that the 23 rule does not have any significant impact on the environment, 24 perhaps that would be good enough.
There would be no need for 25 an environmental impact statement.
A
1 28 1
For the individual plant,that may be renewed, 2
sometime in the 1990's, the current rule in Part 51 indicates 3
that there would be an environmental impact statement required.
4 Whether or not that should be changed should be and 5
is being evaluated.
At the very least, for the individual 6
plant licenses, there should be an environmental assessment.
~_
7 And I say, under t' a existing rule, there would have 8
to be also an environmental impact statement.
Beyond those two 9
things, however, it would seem to me that considerations should 10 also be given to whether there should be an overall look-see at 11-environmental considerations.
~
~
12 This is known as a generic of a programmatic 13 environmental impact statement.
There are arguments, legal 14 arguments, that could be made, pro and con, as to whether or 15 not such a generic statement should be prepared.
16 I think that my conclusion probably would be that as 17 a matter of law such a generic statement need not be prepared.
18 However, one should not lose sight of the benefits of a generic 19 statement.
20 The harder the look you give these sorts of issues, 21 that would lessen the issues and the burdens that are placed'on 22 the licensing process, the renewal process for individual 23 planta.
24 We have our analysis of these topics, our legal 25 analysis of these topics, in a very advanced stage of our
29' 1
research and preparation, and this one, as well as the other 2
things that I may talk about later, we have a target to be 3
finished by September of this year.'
4 CHAIRMAN ZECH:- Very good.
5 COMMISSIONER CARR:
I'm worried about the environment 6
encroaching on the plant over a period of 40 years like they do
~
7 on airports.
8 MR. PARLER:
That's a question -- as far as I know, 9
Commissioner Carr, this agency has not dealt with explicitly in 10 its siting criteria, in 10 CFR Part 100.
My impression, and I 11 wish that I would be corrected if my impression is incorrect, 12 that we have, for the most part, relied on local zoning 13 requirements, etcetera.
14 That was a subject that the task force that was 15 looking at upgrading our siting requirements in 1979 16 considered, or was considering, but that particular project was 17 overtaken by the event of March 28th of 1979.
18 COMMISSIONER CARR:
Okay.
19 CHAIRMAN ZECH:
All right.
Proceed, please.
20 MR. SHERON:
Okay.
On slide 14, under the regulatory 21 topic, we have some procedural questions which, again, we have 22 te, address.
23 These are listed here.
The form of the licenta 24 renewal.
The length of renewal term, which I discussed 25 previously.
Questions like what is the latest date for the
i 30 J
1 renewal application to be submitted?
What is the earliest 2
date?
)
3 There has been some consideration _that a plant'that 4
has operated 30 years might wish to come in and ask for renewed 5
license for another 30 years.
6 In other words, I'd like to turn in my license for 30 7
years and get a new one for 30 years, for an effective 8
operating time of 60 years.
Is that something we would allow?
9 What would be the effective date of a renewal?
The
~j 10 use of the backfit rule.
If it's a new plant or if it is a l
1 11 plant that's undergoing relicensing, would we use the backfit 12 rule If we felt that additional improvements were needed for 13 the renewal period.
14 Public hearings.
Will we be required, will we be l
i 15 petitioned to hold public hearings?
We don't know.
l 1
1 16 MR. MURLEY:
Brian, could I interject there?
l 17 MR. SHERON:
Yes.
l 18 MR. MURLEY:
The two year period that we were talking 19 about really dealt with our staff review.
It, of course, did j
20 not deal with any length that public hearings might add and i
21 what contentions might be brought up in those hearings.
I just 22 wanted to clarify that.
l i
23 CHAIRMAN ZECH:
Thank you.
24 COMMISSIONER CARR:
This talk about relicensing, we t
l 25 haven't made the decision yet whether we're going to -- what l
l l
l l
l
s 4
31 1
we're going to call this thing.
An extension or a -- not 2
necessarily a relicensing that wc're talking about though, is 3
it?
4 MR. PARLER:
Well, there has been a good bit written 5
in the-new Reg 1317, and in the NESP Report of-1986 about the 6
subject, whether it should be called a new licensa, a renewed
~_
7 license, or an amendment to the existing license.
8 I think that the crucial question which has already 9
been identified by Mr. Sheron on slide 10 is what is the 10 licensing basis for the plant going to be.
And I think that is 11 really the important thing and not what the thing is called.
~
~
12 I think if, as Mr. Roberts indicated, the thing is 13 treated as a nev license so that it will have to meet current 14 requirements, you're really talking about something quite 15 different from a renewal of an existing license, whether the 16 plant has operated presumably, in accord with our requirements, 17 for 25, 30, or perhaps 40 years.
18 COMMISSIONER CARR:
That's what worried me about the 19 term relicensing and implied to me there was going to be a new 20 license.
21 CHAIRMAN ZECH:
Lot's proceed.
22 MR. SHERON:
Other procedural topics we're dealing 23 with, material alterations.
Utility makes substantial 24 alterations to the components of a plant and the like, to what i
25 extent do we nave to look at that.
l l
J
-- k
\\
e
\\
32 1
How does that effect the licensing reviews.
2 Emergency planning.
Do the emergency planning requirements 3
have to be re-looked at for beyond 40 years.
4 Decommissioning.
Right now, as I understand, a 5
plant, within about three years of the end of its license, is 6
supposed to submit an application for decommissioning.
7 We would have to waive that requirement if there was 8
relicensing.
Antitrust review.
Do we have to do another 9
antitrust review?
10 And then I guess there was a question as to the Price 11 Anderson Act, does it cover the extended period.
My 12 understanding is, right-now, we think it does.
13 MR. PARLER:
Mr. Chairman, these are -- many of these 14 are the items that we are looking at.
Do you want me to talk 15 about them now or wait till Mr. Sheron has concluded?
16 CHAIRMAN ZECH:
I think we ought to talk ab,
.t it 17 right now.
18 Mk. PARLER:
Ctarting at the end of the list, Price 19 Anderson coverage.
Even if the Price Anderson Act is not 20 extended, as I assume that it will be, any plant whose 21 construction permit was issued prior to August 1987 would be 22 covered by the Price Anderson Act.
23 Section 170(c) of the Price Anderson Act so provides, 24 and I assigned a legal interpretation to that effect that we 25 sent to the Congress I believe sometime last year.
e
.. 2 m.
+
e i
33 1
So we have that essentially covered from the legal 2
standpoint.
Antitrust-review, pre-licensing antitrust review.
3 Both from the legislative history and from the language in the 4
Atomic Energy Act, I think that the act of renewal itself will 5
not cause or be the cause of an additional antitrust review.-
1 6
The antitrust review that has already taken place 7
should be adequate, and if plants were exempted from antitrust l
8 review because they were developmental plants, that, it seems 9
to me, probably should stand the test.
l 10 The material alterations.
The problem there is that t
1
\\
11 presumably, if there is a material alteration to a plant, there 12 will have to be a construction permit either issued or a l
13 modification made to the construction permit.
14 When you start talking the issuance of a construction 15 permit, under the Atomic Energy Act, that raises a whole host 16 of legal and procedural issues.
17 For the past three decades, this hasn't been a j
18 p.roblem even though there have been extensive modifications
]
O 19 made to existing plants.
l 1
20 I believe that there is only one instance where a 21 research reactor, or a small university-type reactor was a 22 modification to a construction permit issued.
23 So I don't believe that that should be a problem.
As 24 far as public hearings are concerned, a number of type of i
Y 25 questions there.
m FA&
e 34 1
Should hearings be held?
If so, what type?
Whether' 2
the hearing has to be finished before or after the licensing 3
action takes place.
4 One thing that's very important to remember here is j
5 that if there is an existing license and there is a timely 6
request for the renewal of that license, the old license 7
continues in effect until the regulatory action is completed.
8 Therefore, at least the kinds of problems that'we I
9 have experienced at the operating license stage, having the
~ !
10 hearing, holding up operations, should~not be present in the 11 environment that we're talking about.
~
~
12 As far as the type of hearings are concerned, I will-13 repeat again what I suggested to the Commission in the briefing 14 on June the 27th on the standardization rule.
15 I would favor moving in the direction, as much as we 16 can, of reducing the procedural complexity of our process, 17 including the formality of hearings.
18 I think that hearings, formal hearings though, would 19 have to be held on issues where there are disputed facts that 20 are material to the licensing decision.
21 And certainly we can learn from our experiences in 22 the hearing area over the last 20 or so years,.
Having said i
23 that, however, I would also emphasize that the process has to 24 be an open one and the decisions have to be made on the basis 25 of a public record.
-w
a 35 1
And the test under our statute.to request hearing is' 2
a very broad one.
Any person whose interest may be effected by
.]
3 the proceeding.
4 As far as the backfit rule is_ concerned, we're still 5
looking at that.
I don't see any major problems there.
6 The earliest date for renewal application centers on
~
7 a provision in our rules at the present time that Y;alk about at 8
least 30 days prior to the expiration of the existing license.
9 It seems to me obvious that we need more -- the staff would
-.i 10 need more than 30 days, at least, perhaps a number of years.
11 That issue would seem to me to be largely an academic one for 12 utilities that wanted a decision to be made at least 12 years 13 in advance.
14 The earliest date -- the effective date of the 15 renewal; that issue is one that can be easily addressed and 16 solved.
It essentially is whether the license, the existing i
17 license would run its course and would be replaced by the 18 renewed license, or whether there would be an extended period 19 tacked on the existing license prior to it expiration.
20 Legally, it could provide for both.
21 Let me see if there are any others here.
So, J
j 22 essentially from the legal standpoint, Mr. Chairman, we have 23 the legal authority to accomplish the regulatory policy 24 objective here.
No legislation is needed.
25 About 12 issues of the type I've just talked about, W
l 36 1
as I've already said, we have been analyzing.
We have an i
2 advance research and memorandum prepared in an advanced stage
{
3 of completion.
I don't anticipate any problems.
The problems j
4 that I'm aware of have been identified and are readily 5
manageable within our authority.
6 I would like to emphasize, however, that there is a l
~
7 need to have a clear identification of what the procedures.are 8
going to be in place ahead of time.
Until the answer to the 9
question on Slide 10 is given, I think.that whether it be one 10 year, two years, three years, or how many years, to complete 1
11 the review would be speculation.
It would have to be 12 speculation, because no'one knows at the present time, what the 13 criteria will be for the renewal.
14 CHAIRMAN ZECH:
Thank you very much.
15 COMMISSIONER CARR:
May I ask one question of the 16 General Counsel?
j 17 CHAIRMAN ZECH:
Sure, please do. '
10 COMMISSIONER CARR:
On the hearing, I assume that the 19 hearing -- what we put in the rule would be uhat would be 20 contended at the hearing -- that they hadn't complied with the 21 rule we make?
22 MR. PARLER:
I would hope so.
That would be the 23 essential reason why I think that the crucial question was 24 asked on Slide 10 is so important.
Otherwise, perhaps 25 everything would be fair game and you'd be back to square one,
~
37 1
doing in 1995 what perhaps_was examined at length in 1972.
If 2
that were done, you'd be talking about a different kind of 3
process from the one that I have in mind.
We're trying to work i
1 4
with the technical staff to come up with procedures to 5
accommodate it.-
6 CHAIRMAN ZECH:
Thank you again.
You may-proceed.
7 MR. SHERON:
I'm on Slide 15 right now and I just --
~
i 8
our concluding points in the briefinq here.
One is that we 9
fully recognize that we need to have timely development of the 10 regulations for license renewal.
Getting out our regulatory I
11 guidance is important to the industry and to the regulatory 12 stability.
13 We've looked very hard at our currenu schedule.
As I 14 said before, we've discussed it extensively with the. industry.
15 We understand that our schedule is consistent and-appropriate 16 for their needs, so we're following on that basis.
On slide' i
17 16, as we said before, we're developing regulatory guide and 18 standard review plans.
They will be done on a somewhat, 19 probably longer schedule than the regulation.
20 Some will be out at the time of the regulation.
21 Keeping in mind that as the research informatica is received 22 and assimilated, both from our own research program as well as 23 the industry's research program, we will be trying to put that 24 into guidance packages, so that plants that will be applying for licenses later on, will have the benefit of the knowledge 25 4
4 9
i 38 1
that we've gained.
2 Also, as we go through a couple reviews, we will be 3
learning.
4 COMMISSIONER CARR:
That concerns me that we're going i
l L
5 to give them a moving target.
The guy who applies is not going l
l 6
to know whether or not he's got it all in the box or not, as l
~
~
[
7 long as we say'that we're going to keep that open and keep i
bI 8
adding things to the box.
i 9
MR. SHERON:
Well, I think that even if you look at i
10 our current regulations on the regulatory guide system, they
- l 11 evolved over a number of years and they did not all kind of 12 appear at once and I think that it's only reasonable that as we 13 gain information and gain experience in the relicensing 14 process, we'll be able to issue guidance documents which 15 provide even better guidance to the industry.
j 16 It won't be anything new, like we've changed our 17 requirements all of a sudden.
Rather, it's going to be more of 18 the documentation of what we ultimately accepted, say, on the 19 first several plants, so that the plants coming down the road l
20 are going to know what it is that they need to provide.
21 MR. STELLO:
Maybe there's a shorter answer.
The 1
22 rule is what they're going to have to meet.
We don't expect to 23 be changing the rule, but as you develop guidance and you learn l
24 more, you obviously can say more about what you've learned in 25 terms of reg guides.
The rule --'I don't think we're 9
39 1
suggesting that we're going to go back and change-the rule.
2 MR. PARLER:
Mr. Chairman, may I make a comment?
3 CHAIRMAN ZECH:
Please do.
4 MR. PARLER:
At least from a legal perspective, the 5
learn as you license, perhaps was appropriate and essential l
l 6
during the developmental stage of this technology, but it would
~
l 7
seem that if we're talking about renewing the licennes of 100 8
or so plants that have been operating for 30-40 years, we must 9
have a pretty good idea as to what has to be done to pass
-10 muster from the standpoint of adequate protection of the public 11 health and safety.
1 12 The circumstances are substantially.different in my
~
l 13 non-technical judgment, on that point, the reviewing point, 14 than was the case when we had to start out with nothing in the 15 1960's and develop requirements as we gained experience.
1 16 CHAIRMAN ZECH:
Thank you very much.
I think that's i
17 a good comment.
18 MR. STELLO:
Let me add, Mr. Chairman, you recognize 19 that we have 100 plants out there that are different.
We have 20 plants that we licensed in the early 60's.
What one may or may l
21 not need to do for those plants --
l 22 COMMISSIONER CARR:
Every one of these is going to be 23 a specific renewal.
24 MR..STELLO:
Well, as you start to get --
25 COMMISSIONER CARR:
No doubt about that.
1.
i 40 1
MR. STELLO:
Back into the 70's, I think that the 2
plants tended to be more consistent.
At that time, we-did have 3
a standard review plan and a lot of things were in place.
As 4
you look at some of these early' plants, I see a tough job.
I 5
don't want to minimize it.
I think the rule that we can write 6
and --
~
7 COMMISSIONER CARR:
That's why I ask if it'F a stand- -
8 alone document.
If they comply with the rule --
t 9
MR. STELLO:
By definition, that's vhat they have to 10 do.
11 COMMISSIONER CARR:
I hate to keep nibbling them with
~
12 a new guide every once and a while.
13 MR. STELLO:
We don't want to do that either.
j 14 CHAIRMAN ZECH: ' General Coursel.
15 MR. PARLER:
MaybefMr. Stello has made the point that
]
16 I wanted to make, at least for transcript.
That is, that the l
17 rule could distinguish among the plants.
If plants that were l
18 licensed in a particular era would be subject to something 19 different than others, that's one of the things that the rule 20 should spell out.
What would not be recommended, at least by 21 me on the basis of experience starting with the process 22 starting in 1960, would be to develop these things on a case-23 by-case basis.
24 Develop the requirements and make the distinctions on 25 a case-by-case basis.
To the extent that we can do it, it
5 41 1
should be done in the rule.'
2 CHAIRMAN ZECH:
Right.
I thir;k everyone would agree 3
with that.
We certainly want the rule'to be standing alone as 4
much as it possible can and not require an awful lot of 5
modifications and explanations.
The rule should be,.as near as 2
r 6
possible, a stand-alone rule and cover as broad a cpectrum as
~
7 it can.
Of course, I recognize that's a tall order, but this 8
is a very important issue and I think we should approach it 9
just that way.
10 All right, have you concluded, Mr. Sheron?
11 MR. SHERON:
Just ny last three bullets here, is that 12 on Slide 16, and that.is that we are continuing with additional 13 research and data gathering.
We are very much stressing the 14 importance of the industry-sponsored research.
This is 15 something we don't think that NRC should shoulder alone.
We 16 think that the benefit for-renewed licenses is with the 1
17 industry and that it's incumbent upon them to provide us with j
18 the information that we need to draw the conclusions that we 19 have to.
20 CHAIRMAN ZECH:
Are they doing a reasonable job in 21 that are as far as you're concerned at this time or should they 22 do more?
23 MR. SHERON:
From what we've seen, they appear to be 24 doing a. reasonable job on developing the.information.
25 CHAIRMAN ZECH:
EPRI has the lead in this program?
i I
42 1
Is that correct?
2 MR. BOSNAK:
I believe it's a joint EPRI/ DOE program.
3 CHAIRMAN ZECH:
Perhaps you could step to the 4
microphone so that the reporter can hear you better.
Thank 5
you.
6 MR. BOSNAK:
I believe it's a joint DOE /EPRI program.
7 CHAIRMAN ZECH:
8 MR. BOSNAK:
9 CHAIRMAN ZECH:
All right, thank you very much.
10 Well, why don't you get back to the microphone, please.
Do you 11 think they're doing enough from a research standpoint.
~
~
12 MR. BOSNAK:
From a research standpoint, I do believe 13 they could be doing more than they are doing.
14 CHAIRMAN ZECH:
Are they doing sufficient as far as l
15 you're concerned?
Will what they're doing be srfficient to i
16 help you make good recommendations or will you be left feeling 17 that they have not done enough?
18 MR. BOSNAK:
Right now, we've been working with them 19 to identify what we're doing and what they're doing so that the 20 two programs complement each other and they don't duplicate.
1 21 That's what we're sorting out now.
22 CHAIRMAN ZECH:
Arc we telling them what we think 23 that we would like them to do if they're not doing enough?
In 24 other words, if you're concerned about them not doing enough, 25 are you telling them about that and asking them to do it?
Are
43 1
you getting responsive answers?
2 MR. BOSNAK?
In our own program, we're trying to 3
uncover the areas that we think that there are prse. ms.
Once 4
we do find problems, we're going to ask them to solve.. +ho 5
problems.
6 CHAIRMAN ZECH:
Are you doing that?
~
7 MR. BOSNAK:
Yes, this is what we're doing, sir.
8 CHAIRMAN ZECH:
All right.
Thank you.
9 MR. STELLO:
Mr. Chairman, we're finished and we just 10 suggest that the Commission agree to move zware alth this.
11 As you can see, I think the earlier we can get things moving, 12 the better off we're going to be.
I think if the Commission is 13 able to agree to move forward, we'll make some progress and get 14 on with it.
15 CHAIRMAN ZECH:
All right, thank you very much.
16 Questions from my fellow Commissioners?
Commissioner Roberts?
17 COMMISSIONER ROBERTS:
Nobody in the U.S. has ever 18 done the in situ annealing?
19 MR. STELLO:
To the best of my knowledge, I do nat 20 believe that we have ever had an in situ annealing of a vessel 21 for the purpose of offsetting irradiation damage.
There has 22 been in situ annealing of vessels when they were manufactured.
23 We had ve+3els built in place, on-site and I recall,. I think 24 thero were a couple of them that were, in fact, annealed on 25
- site,
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MR. MURLEY:
There was a military vessel that was 2-annealed, but it was 3
CHAIRMAN ZECH:
Could you step to the microphone, 4
please and identify yourself to the reporter.
Thank you.
5 MR. ARLOTTO:
Guy Arlotto.. The specific answer to 6
your question, Mr. Roberts is, to our knowledge, there's been 7
no in situ annealing of a commercial vessel.
Whether or not'it -
8 has been done in the railitary, we nave some signs that it may 9
have been done, but because of the operation, particulttrly of 10 the nuclear Navy, we are not very privileged to discuss it very 11 much here.
~
~
12 CHAIRMAN ZECH:
Thank you.
13 MR. STELLO:
Guy, may I ask you before you leave, am 14 I correct, were there not some of the vessels that were 15 fabricated in the field and annealed in the field during 16 fabrication?
17 MR. ARLOTTO:
To my knowledge, there were none in 18 that category that I know of.
There was some work done on the 19 N.S.
Savannah that may have fallen in that category regarding 20 the containment vessel, but not the pressure vessel.
21 CHAIRMAN ZECH; Thank you very much.
Commissioner 22 Carr?
23 COMMISSIONER CARR:
I'm concerned about the reg 24 guides and SRBs lagging the regulation and I would suggest, Mr.
25 Chairman, tie add enough resources to the budget to bring all of
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45 1
those out at the same time.
I think we can make a case for 2
that with the Congress if we got a lot of work cut out for us 3
that we've got to take care of.
1 4
CHAIRMAN ZECH:
Let's let the staff respond on that.
b 5
MR. MURLEY:
We'll do everything we can to do that.
6 Our plans are that they will.
Let me give an example of the 7
type of rule that may come out of this.
It could be a risk-8 based rule, for example.
Not that I'm leaning that way, but 9
there's, in fact, a comparable risk _ argument with a certain 10 intellectual appeal to it.
11 If that were the form that the rule were to take, 12 Ehen Ehere would have to be some pretty complicated and 13 detailed guidance on how to do risk analyses that would. meet 14 this rule.
In that case, it would not be a simple thing to 1
15 write the guides and they could well lag a year or so after.
l 16 I only mention it as an example of --
i 17 COMMISSIONER CARR:
Well, I can't imagine anybody l
18 applying for an extension without at least v -
you-call a l
19 Level 3 PRA in the first place.
I would think that that would 20 be a part of his economic decision.
21 MR. MURLEY:
I agree.
Whether that's adequate enough 22 for us to make a licensing decision based on a risk-based rule, 23 I'd have to think about that.
24 COMMISSIONER CARR:
Well, I don't -- if we're held up 25 for other than resources, that's a different question.
If we O
4 y
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46-1 don't have enough bodies to put on this to get_the problem 2
.solveu, I recommend we seriously consider adding money and 3
bodies to the budget?
4 MR. STELLO:
kny don't wo take that and work exactly 5
what you said into our plan -- look at what it would take to 6
get the standard review plan and the reg guide developed 1
7 contemporaneously with the rule.
It is a difficult task 8
because it depends, as Dr. Murley has already said,.what the 9
form of the rule is, because then that's the form of the 10 guidance of the standard review plan.
11 Let's look at how to integrate those in the schedule.
12 If it~is truly an issue of resources, then let's bring that up 13 and the Commission can decided to add those resources and we 14 can get it done to the extent we can.
15 CHAIRMAN ZECH:
We'll ask the staff to look at that 16 and give us your thoughts on that because certainly, if it's 17 resources, the Commission should be aware of that and let us le take that on as our responsibility.
If it's not resources, of 19 course, we should know that too.
20 MR. STELLO:
It is clearly not only resources.
21 CHAIRMAN ZECH:
Would. you look at this subject and 22 give us perhaps a paper on that that could talk to this issue 23 straight out so that we'll know exactly your views on it and 24 your recommendations?
25 MR. STELLO:
Yes, sir ~.
9 t -
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47 1
CHAIRMAN ZECH:
Atd whethertresources would assist in 2
bringing them all together in a focused way.
Anything else 3
Commissioner Carr?
Commissioner Rogers?
4 COMMISSIONER ROGERS:
Just coming back to this 5
question of how long it will take the NRC to hot on a licensing 6
application -- extension appl'ication.
It's a 2-year period.
I 7
know that's not hard and fast, but that's an estimate period 8
now.
Is that to include a hearing period as well, or-is that 9
simply for staff action?
10 MR. STELLO:
Staff review.
11 (Commissioner Roberts left the room at 3:10 p.m.)
~
12 COMMISSIONER ROGERS:
What impact would you expect 13 the hearing process would have?
4 14 MR. PARLER:
The hearing process would depend upon 10 the issues, the extent to which there are material, factual 16 issues that are in dispute.
It's an unknown, even if you have j
17 a discipline process.
However, as I mentioned earlier, if.the 18 application for renewal is timely filed, the existing license 19 remains in effect, even while the hearing is going on and 20 operation can continue if the plant otherwise satisfies our 21 requirements and is okay with the other regulatory staff.
22 COMMISSIONER ROGERS:
There's no limit as to how long 23 that would stay in effect?
24 MR. PARLER:
That is a question that perhaps one 25 might want to think about.
There's no precise limit.
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1 Obviously, everything --
2 COMMISSIONER ROGERS:
It could go on for 10 years,-
3 for example?
4 MR. PARLER:
That's my obvious point that I was going 5
to make.
Everything has some reasonable-bounds to it.
I guess 6
perhaps in legal theory, it could go on for 10 years, b'tt I
~
7 would
.. ink that if we got into something like that, a hard 8
look should be taken at it.
9 Under the law that we are subject, if there is a 10 timely and sufficient application for renewal of an existing 11 license, the existing license remains in effect until the 12 Agency reaches its decision.
We are under the directions of 13 the Administrative Procedures Act to proceed with reasonable 14 dispatch to do that, but we have been under that direction for 15 the last 25 or 30 years and some of these hearings go on for a 16 long time.
17 COMMISSIONER ROGERS:
Well, it just occurs to me timt 18 one should at least think through the possibility of a strategy 1^
that says you should wait till the last minute and then have a 20 prolonged hearing period that gives you another 5 years j
21 automatic extension, i
22 MR. PARLER:
As I have mentioned, the existing 23 requirement in our rule 2.109, I believe; it talks about 24 waiting until 30 days before the expiration.
That obviously 25 has to be changed.
The application for the renewal should be a..-.
i
)
1 49 1
submitted long-before 30 days, but I agree with your point, 1
2 Commicsioner Rogers, that our. procedures that we come up with j
3 should guard against the happenstance that you mentioned.
4
[ Commissioner Roberts returned to the room at 3:15 1
1 5
p.m.]
6 COMMISSIONER ROGERS:
Let me add that if there is any 7
question we think that the plant is unsafe, notwithstanding 8
anything else, we could shut it down.
9 MR. PARLER:
That's always the case.
10 COMMISSIONER ROGERS:
But of course, there's.still 11 another possibility.
~
~
12 MR. STELLO:
If utility wanted to wait 31 days and 13 tene an application and suggest that well, while we're 1
14 reviewing and there's a hearing and he could operate if he 15 hasn't demonstrated the case and we don't agree, it just won't 16 work.
17 COMMISSIONER ROGERS:
Well, I don't think that we 18 want to discuss all the possible ramifications of 19 eventualities, but I think one could imagine a number of 20 different scenarios here that should be considered.
21 MR. STELLO:
Yes, that's why the General Counsel 22 highlighted the 30-day requirement on the rule.
I think we 23 would definitaly want to get rid of that one.
24 COMMISSIONER ROGERS:
Well, I think that it might 25 take more than that.
The other point I'm a bit uncomfortable L
50 l
1 about is becauseuit seems to me that we have a little 2
conceptual difficulty here, in that we have this very broad i
3 spectrum of plants that may be coming up fo:e relicensing.
i i
4 As Dr. Murley pointed out, this process is going to 5
involved some learning as we go through it and the.first ones 6
we're going to be learning on are those that are plants that 7
are going to be quite different in many ways from those at the
~
8 tail end of the cycle.
i 9
I'm just wondering how one rolls that learning into 10 the business in a reasonable way.
Commissioner Carr has 11 pointed out that you don't want to present a moving objective, 12 reall7, for the perspective licensees to head for.
Somehow it 13 ought to be firmed up.
We're talking about a quite precise l
)
14 definition of a rule and yet we're talking about a learning 15 process and I don't know -- it seems to me that it's somewhat 16 contradictory, unless there's some provision for adjustment in 17 the rule.
18 This process that we're talking about here is going 19 to run for a long time, from the year 2000 until the last plant 20 that presently is in existence that might be coming up for a 21 license extension comes up, one of the later ones.
I'm just a 22 little puzzled as to how this whole thing is supposed to fit 23 together, accommodating what undoubtedly will be some new 24 factors that we won't be able to predict at the outset of this 25 thing that we have to take into' account in the licensing a
Ma.
4 8
51 extension, pinning down the rule very hard and fast right away 1
2 at the beginning of the process.
3 I'm just a little puzzled as to how this is all going 4
to work, because it seems to me that we have some conflicting 5
objectives in this regard.
6 MR. STELLO:
It's going to be very difficult.
~
7 COMMISSIONER ROGERS:
It's a comment, it's not a 8
solution to the problem.
9 MR. STELLO:
But if we would permit, for example, if
.-l 10 the rule would allow a utility that has say only 10 or 15 years
.l
'l 11 or operation to apply at that time for-a license that would l
12 511ow him to operate for say 40 more years, you would be 13 getting some of the ve'ry new plants as well as some of the very 14 old plants.
15 And you could get that experience all very early in 16 the p,rocess and perhaps one could, DOE already has indicated a 17 desire to support us on this activity.
18 Perhaps DOE may consider broadening it to allow 19 getting thct kind of experience to cover the spectrum, and that 20 might be v9ry, very helpful.
21 Perhaps DOE would consider that.
So depending on the 22 form of the rule, if that's permitted, we may be able to find 23 ways to make at least that task easier.
24 CHAIRMAN ZECH:
Well, let me'thank the staff for an 25 excellent presentation.
I thought, Mr. Sheron, your briefing a
52 was exceptionally good.
1 2
We all know,_Mr. Stello, what an important issue this 3
is and I know that the staff is going to continue giving it a 4
very important priority.
S' And'it isn't very far away.
That's the thing I think 6
we're all very aware of.
I'd like to that..c the General Counsel
~~
7 for his discussion and resume of the procedural issues.
That 8
was very helpful.
Appreciate it.
9 When we consider.that the utilities may be submitting 10 applications reasonably soon, the dates we suggested here today 11 are not very far in front of us, certainly early '90's is not 12 very far away, it seems to-me that it's awfully important that i
13 we maintain the scheduled for the final rule, 1991.
14 That's not very far away either.
And that we really 15 pull that up in front of us continually to recognize that 16 that's a challenge that we have and there are a lot of unknowns 17 we're involved in here.
18 I'd also like to say that I certainly would expect 19-that the industry, utilities and industry combined,'would take 20 a lead role in trying to address some of the technical research 21 challenges that are right in fron't of us in order to put in i
22 place a responsible license renewal rule.
23 So I would suggest that our staff continue to work 24 very closely with the industry in that regard ~, and that they 25 have what I would I think is a heavy responsibility to share y
n er,
0 53 1
that burden, because we are in a field that will require our 2
judgments.
3 We want as much technical research and as much 4
scientific evidence and fr 's as we can possibly muster.
So I 5
would ask that my fellow Commissioners review the NUREG 1317 6
carefully and perhaps we'll be able to vote on it here very 7
soon.
I'd like to do that if at all possible so we can move
~
8 ahead with this very important program.
9 MR. PARLER:
Mr. Chairman?
10 CHAIRMAN ZECH:
Yes.
11 MR. PARLER:
If the NUREG 1317 is going to be put out 12 Es a Basic document for purposes of the advance notice of 13 proposed rulemaking, it was prepared some months ago and 14 certain parts of it, such as a proposed decommissioning rule, I 15 would suggest should be updated at least by footnotes.
There 16 are a few things like that in the document.
17 CHAIRMAN ZECH:
Fine.
Well, certainly we would want 18 to make sure that we're satisfied with that and perhaps other-19 things as we review it, but appreciate that comment.
20 Are there any other comments?
21 (No response.]
22 CHAIRMAN ZECH:
If not, thank you very much.
We 23 stand adjourned.
24 (Whereupon, at 3:23 p.m.,
the hearing was concluded.]
^
25
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CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of'the U.S. Nuclear Regulatory Commission entitled:
TITLE OF MEETING: BRIEFING ON POLICY PAPER FOR PLANT LIFE EXTENSION PLACE OF MEETING:
Washington, D.C.
DATE OF MEETING: TUESDAY, JULY 12, 1988 I
were transcribed by me.
I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events, s-i
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