ML20151V121
| ML20151V121 | |
| Person / Time | |
|---|---|
| Issue date: | 06/15/1998 |
| From: | Mcgaffigan E 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 9809140082 | |
| Download: ML20151V121 (2) | |
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POLICY ISSUE h#
(NEGATIVE CONSENT)
Aonl9.1998 SECY-98-075 40eeeeeegeg@9000GO90000 EQB:
The Commissioners RELEASED TOTHE PDR 7/8M bd i
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L. Joseph Callan l
Executive Director for Operations dato inl
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SUBJECT:
- DSI-24 IMPLEMENTATION: INNOVATIVE REGULATORY APPROACHES AND
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RISK-INFORMED, PERFORMANCE-BASED CONCEPTS APPLIED TO DECOMMISSIONING PURPOSE:
To provide the Commission with the staff's plan for addressing innovative regulatory i
approaches to decommissioning, as requested in tha Staff Requirements Memorandum (SRM), dated April 3,1997, for Direction-Setting issue No. 24 (DSI-24), " Power Reactor Decommissioning."
BACKGROUND:
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 relemaking 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 14RC 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 learned and available data from recently decommissioned facilities (e.g., survey costs).
4 CONTACT:
Anthony W. Markley, NRR/PDND NOTE: TO BE MADE PUBLICLY AVAILABLE 415-3165 WHEN THE FINAL SRM IS MADE AVAILABLE 9909140082 990615
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i Commissioner McGaffigan's Comments on SECY-98-075, "DSI-24 lmolementation: Innovative Regulatory Approaches and Risk-informsd, Performance based Concepts Applied to Decommissioning i
l l approve in part, disapprove in part. I agree with the overall thrust of Commissioner Diaz's l
comments. Rulemaking in this area should nel take as long as projected, but even more importantly from my perspective piocessing licensing actions, including exemptions, for those l
licensees in active decommissioning must become much more timeiy.
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l understand that the staff currently places decommissioning plants behind operating plants for l
priority in allocating review resources on the grounds of lower safety significance. Because permanently shutdown facilities do pose significantly lower health and safety risks than operating plants, a prioritization scheme based solely on safety significance will delay the granting of relief from requirements that are clearly no longer appropriate and therefore unnecessarily consume imensee decommissioning funds. Precisely because of the lower risk of shutdown plants, granting relief in such areas as emergency preparedness, security, defueled technical specifications, quality i
assurance, and staffing, should be straightforward with even minimal staff resources. The staff l
should not postpone taking regulatory action that could benefit a spacihe licensee in active decommissioning because we are waitir.g on formal rulemakings as the vehicle to resolve an issue generically. The staff should consider developing a standardized template to expedite the processing of routine licensing actions under current rules, similar to what was eventually done for the improved standard technical specification program (e.g., the Robinson safety evaluation template), if that would speed the process.
I I agree with Commissioner Diaz that the staff should p proceed without delay in providing the Commission with an overall plan for addressing the initiatives that are either under development or contemplated in the decommissioning arena. In the plan, I propose that the staff prioritize the initiatives using the process described above and include specific timeliness goals for licensing acbons for the plants in active decommissioning - Big Rock Point, Maine Yankee, Trojan, Haddam Neck, etc. The staff should also identify any policy guidance it needs from the Commission to expedite either licensing reviews or rulemakings.
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