ML20151U296
| ML20151U296 | |
| Person / Time | |
|---|---|
| Issue date: | 05/22/1998 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| SECY-98-075-C, SECY-98-75-C, NUDOCS 9809100347 | |
| Download: ML20151U296 (2) | |
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Nils J. Waz 5/2.2,/98 (NEGATIVE CONSENT)
Aoril 9,1998 SECY 075 f.QB:
The Commissioners FROM:
L Joseph Callan Executive Director for Operations
SUBJECT:
DSI-24 IMPLEMENTATION: INNOVATIVE REGULATORY APPROACHES AND RISK-INFORMED, PERFORMANCE-BASED CONCEPTS APPLIED TO DECOMMISSIONING PURPOSE:
To provide the Commission with the staff's plan for addressing innovative regulatory approaches to decommissioning, as requested in the Staff Requirements Memorandum (SRM), dated April 3,1997, for Direction-Setting Issue Noi 24 (DSI-24), ' Power Reactor Decommissioning."
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BACKGRGUND:
The SRM, among other things, instructed the staff to consider innovative regulatory approaches to decommissioning. The SRM asked that the staff consider how decommissioning issues could be resolved more quickly and whether rulemaking activities could be consolidated. The staff was also asked to evaluate a performance-based approach to radiological site assessments and to consider whether placing an inspector on site during certain phases of decommissioning and centralizing the reactor decommissioning inspection program in headquarters would improve NRC oversight. Additionally, the Commission asked the staff to evaluate public comments that were obtained during the Strategic Reassessment that suggest improvements to existing practices and rulemakings.
The Commission also asked the staff to consider lessons leamed and available data from recently decommissioned facilities (e.g., survey costs).
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s CONTACT:
Anthony W. Markley, NRR/PDND NOTE:
TO BE MADE PUBLICLY AVAILA,BLE 415-3165 WHEN THE FINAL SRM IS MADE AVAILABLE T r> 4 (? q L;r b 9009100347 980522 PDR COMMS NRCC M hl CORRESPONDENCE PDR 11N z T4 g 6% tii 6 mmmmmMMMmmmmMMMME
4 COMMISSIONER DIAZ'S COMMENTS ON SECY-98-075: INNOVATIVE REGULATORY APPROACHES AND RISK-INFORMED, PERFORMANCE-BASED CONCEPTS APPLIED TO DECOMMISSIONING l
Approved in part, disapproved in part. Although I agree with the staff's treatment and proposals for the majority of the issues in this SECY, there is insufficient information conceming rulemaking and guidance development for me to make a judgment on the adequacy of the staff's plan. Furthermore, it seems incongruous that the fairly narrow-scope rulemakings being pursued should take as long to finalize as projected in the paper.
In refining its plans for rulemaking and guidance development, the staff should ensure that the various solutions under consideration are harmonized. The best available way to achieve this harmony would be through the application of risk-informed methods. To this end, the staff should maximize the advantages that will result from pending risk-informed changes to 10 CFR part 50.59 and regulatory guidance goveming FSARs. Several purposes will be achieved through this, including accurately reflecting the reduced risks associated with permanently shutdown and defueled plants, and a lowered demand on NRC resources for unneeded technical reviews and inspections. This approach will foster timely decommissioning while ensuring adequate protection of public health and safety and of the environment and giving ratepayers relief from unnecessary burden.
The NRC's decommissioning challenge is large and growing: the staff must not only proceed with increased vigor in developing rules and guidance, it must also implement the agency's decommissioning program, particularly with respect to performing licensing reviews and processing exemption requests in real time. I believe that management priority should be given to the decommissioning area in a manner responsive to the developing scenario, and, if necessary to achieve the results outlined above, should redirect staff effort, Finally, the staff should provide the Commission with an integrated set of milestones for implementing the various initiatives that are either underway or contemplated in the decommissioning aren i
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