ML20155A138
| ML20155A138 | |
| Person / Time | |
|---|---|
| Issue date: | 10/13/1977 |
| From: | Gossick L NRC |
| To: | |
| Shared Package | |
| ML20154N521 | List: |
| References | |
| TASK-TF, TASK-URFO NUDOCS 9810280154 | |
| Download: ML20155A138 (25) | |
Text
7 TESTIMONY OF LEE V. GOSSICK EXECUTIVE DIRECTOR FOR OPERATIONS
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U. S. NUCLEAR REGULATORY COMMISSION SUBCOMMITTEE ON NUCLEAR REGULATION COMMITTEE ON ENVIRONMENT AND PUBLIC WORKS UNITED STATES SENATE OCTOBER 13, 1977 Introduction Mr.' Chairman,1 am pleased to have this opportunity to describe how the NRC staff, in its licensing and other regulatory activities, keeps the Commission's licensing boards and parties to their 1
_ proceedings informed of new information that is material and relevant.
In' retrospect', the questions on the specific North Anna case are relatively straight forward because we have all the necessary facts of that case'before us.
But as you know, the NRC is responsible for
-the regulation of a large number and a wide variety of nuclear facilities.
The question of board notification is more complex when.
viewed in that broader context of our day-to-day operations because L
E each of the many facilities.under licensing review may be at any one of several phases of the licensing process.
To help sort r
p through 'these complexities, I have provided a brief sunnary of our i
process for licensing of facilities pursuant to the Atomic Energy f
Act, the Energy Reorganization Act and the National Environmental l'
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Policy Act.
This sumary is submitted as Enclosure A to my prepared testimony.
l 1 want to describe at some length how new information arises in the licensing process, either from inside the NRC or from outside sources, and how that new information is acted upon by the staff depending upon its significance to public health and safety or the environment.
I will use some specific examples from the early 1970's through the past year which chronicle our continuing efforts to keep the Atomic Safety and Licensing Boards, the parties to their proceedings, and others, informed of new information.
I will also address changes that have occurred in our practices to facilitate the timely notification of the boards and parties to their proceedings of material and relevant information.
We believe this matter deserves continuing attention, and I will describe considerations ongoing in the staff for assuring that Commission policy and guidance are fully implemented.
It is important to recognize that in acting on the information i
before the NRC staff, we must exercise judgment as to the relative importance of various individual pieces of information to overall l
I safety and environmental protection.
The recent record in keeping l
the Licensing Boards and parties to their proceedings informed of material and relevant information is good, and it is not being I
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. challenged'in these hearings.
Rather, we are concerned today with the handling of information developed in 1973 and subsequent l
actions by the staff.
With the procedures now in place, as I will describe below, I am confident that the recent good record can be maintained.
-I wish to underscore the fact that the primary focus of the staff's attention when new information arises must always be on evaluating -its safety. implications.
In fact, as Chairman Hendrie noted in his remarks, this was the case in our handling of the information regarding the fault at North Anna.
We must, in our current procedures and actions, assure continuation of this primary focus.
Staff Action on New Information Before giving some specific examples of how new information has been provided to the licensing boards, I will describe in general terms the sources of new information and our procedures and priorities for acting on it.
New information arises in the regulatory process continually.
One source of new information is experience with operating facilities.
Another source is new ideas, facts, or engineering formulations generated by license applicants, their contractors, or the NRC staff 1
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Other new information can i'
come from interested citizens, anonymous sources, or foreign govern-ments.
The priorities and processes for dissemination of new information depend primarily upon the safety significance of the information and not upon -its source, as I will describe next.
The first priority of the staff in reviewing new information is to decide whether a matter of immediate safety concern exists for operating reactors.
The staff then assures that the information is reasonably will characterized and categorized for plants at various stages of licensing review.
Finally, a plan for a resolution of any safety or environmental problems is developed for action on a time scale consistent with the significance of the issues involved.
The information is made available to the public, affected licensees or applicants, and hearing boards and parties to their proceedings in a variety of ways and at several stages in its processing by the staff.
I will first summarize how our licensees or applicants and the public are routinely kept up to date on new information being reviewed within the regulatory process,.then I will turn specifically to the question of informing the licensing boards.
Operating information of safety significance is rapidly provided to the NRC and is, in turn, widely disseminaied.
The large number of Licensee Event Reports required by our regulations is reviewed, l
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5-and some are identified as Abnormal Occurrences, using procedures specified in the Commission's policy Statement of February 23, l
1977 '(provided for the record) and reported to the Congress in accordance with Section 208 of. the Energy Reorganization Act of f '.
In addition, the reporting of defects pursuant to Section 206 of the Energy Reorganization Act is presently required by NRC.
When prompt ~ action is needed for operating plants on the basis of such data, there is wide public dissemination of information about these actions.
If the data indicate the need for further evaluation, supportive information is requested by letter to the affected licensee, at-a class of licensees if there is a generic problem.
Copies of such correspondence are available in the Public Document Rooms in Washington, D. C. and in the locality of each nuclear plant.
In some cases license amendments or orders are issued and noticed in the Federal Register.
Routine operating information and new information developed in the course of licensing reviews is documented in incoming corres-pondence or in staff summaries of meetings.
These documents are placed in the Commission's Public Document Rooms.
Some time lag in documenting information can occur because of the need to coordinate among several technical disciplines within the staff.
The possible
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6-l generic implications of the information are considered as a part of this technical coordination. The most comon disposition of information relevant to a plant in the licensing process is by its l
inclusion in the staff's Safety Evaluation Report or supplements.
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These are the principal staff input to the proceedings of the licensing boards.
l During the technical appraisal of new information and in the flow of information between the staff and applicants or licensees,
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judgments must be exercised continually on whether the new information 1
is significant to the consideration of matters ongoing before f
licensin'g boards.
First there is the question of whether information specific to l
l one plant is material and relevant and therefore must ce made avail-able to the licensing board for tnat particular plaat.
For operating l
plarts generally, the question of formal notification to boards is not applicable since these plants are not usually involved in pending licensing hearings.
For facilities still involved in licensing proceedings, all correspondence !;etween the staff and the applicant is sent directly to all parties in the proceeding and routinely placed in the public Document Rooms.
Parties are also given the opportunity to stay on the service list for routine correspondence even after the proceeding is ended.
It has been our judgment that p
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not all such information'is sufficiently important or new to i
warrant bringing it specifically and immediately to the atter.: ion of.the' licensing board, especially since anything of importance l
will be provided later in the staff's Safety Evaluation Report or its supplements.
Matters do arise which are new or outside the scope of normal staff review, and these warrant special attention.
It.is staff practice under current Commission guidance to inform the boards and parties to their proceedings of significant information of this sort in advance of the i
development of a solution to any significant safety.or environmental l'
issues that it generates.
Next there is the question of new information, possibly generated on a specific facility, but having more general significance to other j
l facilities.
This can-be information from operating plants or' an.y other source.
For generic issues of serious-safety significance, action is taken by the staff on the time scale of hours or a few L
days to assure continuing protection of public safety for operating plants, as explained above.
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The most formal mechanism available to the Commission for informing the licensing boards of new generic information requiring i
-action in a number of proceedings is to issue additions or changes l
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to the Commission's regulations.
This mechanism requires relatively complete evaluation and documentation of a basis for the proposed rules, but it can be accomplished on a relatively short time frame.
Two examples which serve to illustrate this mechanism are the l
Interim Acceptance Criteria for Emergency Core Cooling System issued in June of 1971 and the Final Acceptance Criteria issued in December of 1973.
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For plants still in the licensing process and not operating, more deliberate processing of generic information is appropriate, but licensing boards and parties to the proceedings are to be supplied. material and relevant information in a timely way.
For generic items considered to warrant further evaluation before a particular licensing action takes place, there is dissemination of this information to the board and the parties by incorporation in staff Safety Evaluation Reports, and by providing the parties to the proceeding with copies of correspondence to the applicant informing l
him of needed additional information.
There can be a delay between the identification of an item in the Safety Evaluation Report and its resolution.
However, there generally is low potential for adverse impact on the licensing board or parties since all information flowing between the staff and applicant is routinely served on all parties to the proceeding and since there is usually some time between l-l l
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the issuance of the Safety Evaluation Report and subsequent action in the hearing process. In addition, counsel which represents I
the staff before licensing boards attempts to assure that for
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matters clearly relevant to highly contested issues the parties are informed promptly, usually in the informal discovery process.
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Information produced in the discovery process is generally not brought to the special attention of licensing boards.
On the other hand, if there has already been staff testimony on such an issue l
in the proceeding, before the generic item was identified, and if the information is relevant, the staff promptly notifies the board and the parties.
Evolution of Practice I will now turn to a summary of the evolution of specific procedures for informing the licensing boards and parties to-their i
proceedings of material and relevant information.
I will include some examples to show how this information was provided to the boards in the past and how the process is working today.
First, I will describe the practices that were used prior to about 1975 for making licensing information available to the public, i
and especially to the licensing boards.
I will indicate how these practices have evolved to their present state, and why.
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I I During the earlier period, and continuing to the present, the Commission staff routinely made all incoming and outgoing written correspondence between applicants or licensees and the staff available in the Commission's ?ublic Document Room in Washington, D. C. and in the local public document rooms situated near each proposed facility site.
For example, in the North Anna proceeding, we established two local public document rooms; one in Louisa, Virginia in August 1971 and the second in Charlottesville, Virginia in January 1974.
Copies of meeting summaries and trip j
reports are also put in the Public Document Rooms.
This was done in the North Anna case in'1973, as it is today.
In addition,-
we today serve these documents on all parties to the proceedings.
Although the information contained in exchanges of correspondence and meeting minutes was routinely available to the public, it was not formally provided to the boards.
Rather, it was provided in the staff's basic testimony at the licensing hearing in the form of the Safety Evaluation Report and its supplements.
These documents were further supplemented by additional testimony as the need During the period of 1972 and 1973, any new information arose.
which was material and relevant and which was obtained while a hearing was in progress was first evaluated by the staff and the results of the evaluation and the staff's conclusions were presented w
. to the' board and parties by legal brief, testimony, or affidavit.
l This practice was followed whether the new information came to light in the hearing record or from other sources.
In those days, the reasoning of the AEC was that before such information would be of significant use in the decisionmaking process it needed evaluation.
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This approach to handling new information was not limited to the florth ' Anna proceeding.
Another example is provided by the operating license hearings for the Pilgrim, Unit i reactor in Massachusetts.
These hearings opened on December 6,1971.
In the spring of 1972 the staff determined, as a result of work performed at Brookhaven National Laboratory, that' the calculational model for reactivity worth of control rods used in the applicant's Final Safety Analysis Report was not suitably conservative.
As a result of further review, the staff concluded that the analysis of a postulated rod drop accident in the Safety Evaluation Report was no longer correct.
At the licensing board hearing on June 27, 1972, the staff corrected its testimony, stating the current understanding of the situation and indicating that it was including a condition in the facility license to correct the matter.
The practices for handling new information obtained during a proceeding began to change in late 1973 as a result of a decision by_the Atomic Safety and Licensing Appeal Board on September 6, 1973 i
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! l in the proceeding for the McGuire plant in North Carolina.
This followed the North Anna time frame of interest here today by about l
one month.
In that decision, the Appeal Board noted that the staff l
and applicants should inform the Licensing Boards and the parties i
of new information that is relevant and material to matters being adjudicated, so as to assure that the Boards would be acting upon evidence accurately reflecting existing facts.
The Appeal Board admonished the staff for not being sufficiently prompt in advising the Licensing Board of a change to the applicant's quality assurance organization.
Specifically, the Appeal Board stated that the t
change "should have been brough to the attention of the Licensing Board much earlier than it was, and in any event prior to the l
issuance of its initial decision."
In relating this Appeal Board i
guidance to the specifics of the North Anna case, it should be noted that the staff did inform the board of North Anna about the fault before the initial decision could have been issued, in accord with the Appeal Board directions.
In response to the 1973 Appeal Board decision on McGuire, the I
staff altered its practices regarding the handling of new information in ongoing proceedings.
Since that time a greater effort has been made to inform the Boards and parties of material and relevant L
matters promptly.
Although no specific rule or procedure was developed at that time, the direction of the Appeal Board was carried out.
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. For example, the staff notified the licensing board in the Shearon Harris proceedings of a minor geologic fault in August,1974, prior to determining whether it was capable or not.
The same procedure was followed in the Limerick proceeding in 1974.
The first example concerns the Construction Permit proceeding-for the Shearon Harris plant in North Carolina.
The staff was notified by the applicant on July 11, 1974 of the identification of a minor geologic fault in the excavation of the waste processing building.
On July 25 the staff visited the site to inspect the excavation.
The Licensing Board was notified of the situation on August 13, 1974.
As a result of two subsequent visits to the site and a review of considerable information submitted by the applicant, the staff concluded in a Supplement to the Safety Evaluation Reoort that the fault was not capable and did not change the previous staff conclusions on the safety of the plant.
The Shearon Harris proceeding, subsequently delayed for other reasons, has now been reactivated and is still before the Board.
The second example concerns the Construction Permit proceeding for the Limerick Plant in Pennsylvania.
On February 21,1974 an NRC staff geologist observed a fracture zone at the Limerick excavation during a routine visit to the site.
The site visit report was prepared on March 6 and the Licensing Board and parties were notified on April 3.
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This time frame-shows that it took some time to sufficiently characterize the new information, but the important point is that the new information went to the Board before the staff requested additional information from the applicant to complete its_ evaluation l-of the new'information.
In addition to increased emphasis on informing the boards and L
parties of new information material and relevant to the proceedings, the Safety Evaluation Reports themselves have become considerably more comprehensive in racent years, and all outstanding items in the review are carefully outlined and clearly stated.
This improvement.
I believe,' goes far in informing the boards and parties of all matters we judge to be material and relevant to the proceedings.
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I On April 9,1976, Mr. Anthony Roisman, representing the intervenorin a proceeding involving. Indian Point Units 1, 2 and 3 in New York, wrote to then Acting Chairman, Marcus Rowden that the staff did not inform the Indian Point Licensing Board and parties of information developed in another proceeding that he alleged to be relevant to the Indian Point proceeding.
Mr. Roisman requested Mr. Rowden to. ascertain what specific written procedures had beer. established to assure that all data developed in any licensing proceeding, or otherwise, is freely made available in other proceedings where its relevance is apparent.
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I As a result of that letter, the Commission directed the staff to review the coordination and disclosure of technical infonnation relevant to more than one proceeding and to develop appropriate recommendations.
The staff reported its plans for developing formal procedures on June 17, 1976, and issued the procedure on November 2, 1976.
This procedure is in effect today and, as Chairman Hendrie noted, we are examining the details of the procedure to see whether revisions are necessary to reflect the year of experience in its implementation.
I will conclude the chronicle of staff performance in informing the boards by citing two recent examples.
One example concerns internally generated staff views on new safety issues.
On November 3, 1976, the Director of Nuclear Reactor Regulation directed his staff to perform a thorough review of internal views on safety l
issues to identify any which were seriously held by technical reviewers, but were not, in their opinion, being satisfactorily addressed in the ongoing licensing process.
A number of issues were identified and evaluated for ACRS review.
The two reports describing these generic issues were published in November and December 1976 and were provided to the licensing boards whose proceedings were in progress in late December 1976 (NUREG-0138 and 0153).
These reports served to inform
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the boards, and parties to their proceedings, well in advance of the
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development of long term solutions to some of these issues which will be undergoing further work by the staff over the next several years.
There is also a recent example of how material information coming from outside the agency is being made available to relevant boards in a timely way.
On July 21, 1977 the United States Geological Survey informed the staff of its conclusion that the 1872 earthquake in the Pacific Northwest must be considered in the design of the Skagit nuclear plant in the State of Washington.
In July and August the staff formally informed the boards and parties to the proceedings for the Washington Public Power Supply System Units 1 and 4 and Units 3 and 5, the Pebble Springs, and the Trojan nuclear power plants, also located in the Pacific Northwest, of this new information.
Staff evaluation of the new information and any required changes for the affected plants is still ongoing.
Conclusions After reviewing the facts of the matter, which have been well ventilated in the public record over the last several years, I am confident that the staff has met its responsibilities to assure the health and safety of the public.
The staff also has heeded the admonitions of the Licensing Boards, the Appeal Board, and the Commission itself, and has conformed staff practices for informing
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the Boards and the parties on matters involving adjudication to l
their guidance.
As I have outlined previously, the NRC licensing process provides a variety of ways for disclosing all relevant safety and environmental information to the public, Congress, hearing boards, and parties to licensing proceedings.
In view of the massive amount of-information generated and provided to our agency, occasional audits of the process are warranted to assure that information is being disseminated in a timely way.
Further, if any changes to the current process, which is already comprehensive, are shown to be necessary, I will assure that they are implemented promptly.
i It has been proposed that we document the basis on which the staff determines whether information is material and relevant and should be provided to licensing boards.
This question must be approached with some caution to avoid an unnecessarily complicated procedure.
Identification of significant issues is already part of the process, but there are many sources of information that become available to the staff; such as, results of research, development of new criteria, findings by the nuclear industry, and occurrences at operating facilities.
This last source of information alone is voluminous.
Last year licensen reported about 3,000 such occurrences to the Commission.
Under existing procedures information from all these sources is reviewed L
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The material found to be relevant to a particular proceeding is brought to the attention of the licensing i
board and the parties to the proceeding.
To document on an item-by-
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item basis why hundreds of other items are not specifically brought to the attention of particular licensing boards would be an enormous undertaking with a significant impact on limited staff resources.
Caution must be exercised to assure that the primary mission of our agency, assurance of the safety and the environmental acceptability ofnuclearplants,isnothamperedbyproceduresthatproliferate paperwork,without real benefit to the central mission of the agency.
Nevertheless, careful attention to the need to provide prompt public dissemination of information concerning the safety of facilities is essential.
And we are giving special staff attention to one aspect of this responsibility -- keeping the boards infonned.
I have directed that copies of the NRC testimony to this Committee be provided to our staff to underscore the need to be sen,sitive and responsive in this area.
We will continue to monitor this process and any changes in the procedures that are required to be made will be made.
Mr. Chairman, I hope our testimony has made it clear that there is no question that the Commission's regulatory process is open.
Our principal emphasis has been and continues to be on assuring prompt evaluation by the staff of the safety and environmental significance of new information.
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.i I In recent years we have also recognized the need for increased staff sensitivity'.to the need for prompt disclosure of relevant information in:the hearing-process.
However, any suggestion that the earlier handling of the North Anna fault information involved improprieties is simply erroneous.
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Enclosure A OVERVIEW 0F REGULATORY PROCESS l
For background and for contexting the procedures and examples described in this testimony, it is useful to have a brief review of the NRC licensing process.
For simplicity, and because it is the primary area of interest to this subcommittee hearing. I will use the example of nuclear power reactors to explain the process.
A utility planning to build and operate a nuclear power plant must i
seek approval from the Nuclear Regulatory Commission (NRC).
The NRC licensing process is a two-stage procedure.
The initial stage consists of the filing by the utility and review by the NRC staff of an applica-tion for a construction permit.
The second stage consists of the filing l
by the utility and review by the staff of an application for an operating
- license, j
A construction permit application contains a detailed description of the proposed site and preliminary design of the proposed plant, an account of the financial qualifications of the utility and other informa-tion required by the Commission's regulations.
The utility also must submit an environmental impact report relating to the proposed plant.
In addition, the utility must submit information that will permit the Department of Justice to determine whether co.istruction and operation of the proposed facility would create or maintain an existino situation inconsistent with antitrust laws or policies.
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i A-2 The NRC arranges for documents and correspondence relating to each case to be available for public inspection at a local public docu-ment room in the vicinity of the proposed facility as well as in the NRC Public Document Room in Washington, D.C.
Each application is initially reviewed by the NRC staff to determine whether the application contains sufficient information to satisfy our requirements for a complete application.
If the application is not sufficiently complete the application is rejected.
If the application satisfies the requirements, it is fonnally accepted for detailed review.
The detailed review of the construction permit application is conducted according to the Commission's regulations and the Regulatory Guides and Standard Review Plans issued by the staff.
It is a thorough, and highly technical review requiring many months to complete.
The NRC is required by the Atomic Energy Act to hold a public hearino
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before a construction permit (CP) can be issued.
The hearing is conducted by a three member Atomic Safety and Licensing Board.
The Chairman is a lawyer qualified in the conduct of administrative proceedings; the second
'l member is either a reactor engineer or physicist; the third member is u
an environmental scientist.
Soon after acceptance of the application, the Commission issues a notice of the public hearing which will be held f
on environmental and safety aspects of the application after appropriate NRC staff reviews have been completed.
The notice of hearing identifies I
the basic issues that must be considered at the hearing, and tells how l
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interested members of the public may participate in the hearing -- as a party tupporting or opposing the construction permit application views, or in the form of a " limited appearance." The notice of public hearing is issued at this early stage of the licensing process, even though the actual hearing will not begin for several months, in order to provide for full public participation in the decision making process.
The NRC staff may hold meetings with potential intervenors as well as the utility to discuss matters of mutual interest.
About 60 days after publication of the notice of hearing in the Federal Register, a special prehearing conference is convened by the Licensing Board to consider any petitions to intervene; to permit identification of the issues in controversy; to detemine the need for parties to obtain further information and documents; and to discuss scheduling of future actions.
Meanwhile, comprehensive reviews of the sr.fety and environmental aspects of the application have begun, as described above.
Using the utility's environmental impact report as a basis, a Draft Environmental Statement is prepared by the staff.
The Draft State-ment gives detailed consideration to the environmental impacts which would be associated with construction and operation of the proposed facility and assesses them in tems of the available alternatives and the need for power.
It is circulated for review and comment by appropriate Federal, State, and ' local agencies and interested members of the public;
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I this is consistent with the requirements of the National Environmental Policy Act and NRC regulations implementing that Act.
A Final Environ-mental Statement normally is issued about seven months after receipt of the applicant's environmental report.
The NRC staff introduces the Final Statement into the record of the public hearing.
The public hearing on environmental matters and issues related to the suitability of the site.is held in the vicinity of the proposed facility.
If. after considering the evidence included in the record, l
the Licensing Board's findings are favorable, it may then authorize the NRC staff to issue a' Limited Work Authorization (LWA) to the appli-cant.
A LWA permits the applicant, at its own financial risk, to undertake preparation of the site for construction; installation of temporary construction support facilities; excavation for power plant structures; construction of service facilities; and construction of facilities not associated with the nuclear portions of the plant.
While the environmental review is in progress, other members of the'NRC staff review the safety aspects of the apolication.
This review results in a detailed Safety Evaluation Report which is made available to the public and is reviewed by the independent Advisory Committee on Reactor Safeguards (ACRS).
The ACRS furnishes its advice on the safety 4
of the reactor in a written report to the Commission which becomes a part of the public record.
Although the ACRS meetings are open to the public, its meetings are not public hearings and public participation is limited.
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Following completion of these safety reviews, the public hearing considers safety-related matters.
If the findings of the Atomic Safety and Licensing Board on safety-related issues are favorable, the Board may authorize the NRC staff to issue a construction permit.
The initial decision and appeals from the decision filed by any of the parties to the hearing, are considered by a three member Atomic Safety and Licensing Appeal Board.
Normally, the license application review process will end with a final decision by the Appeal Board; l
however, the Commission may, on its own motion or at the request of a party to the proceeding, review particular issues.
After about two years of construction work, the utility files a L
safety analysis report in support of its application for an operating i
license.
This report is subjected to the same kind of safety review by the NRC staff and the ACRS as was the case at the construction per-mit stage.
The environmental review takes into account matters which may be significantly different from those considered earlier.
i Soon after acceptance of the operating license application, the l
Commission publishes notice that it is considering issuance of the j
license.
The notice provides that any person whose interest may be affected by the proposed action may petition the NRC to hold a public hearing and specifies the period of time within which such petitions must be filed.
If no hearing is requested, the NRC staff may issue an operating license after the safety and environmental reviews are 4
completed, a quality assurance program for operations has been implemented and approved, and the facility has been inspected to be sure it has been L
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If a request for hearing is received and granted, issuance of an operating license is dependent 1
on favorable findings by the Atomic Safety and Licensing Board.
The Licensing Board's initial decision and any exceptions are again subject to review by an Atomic Safety and Licensing Appeal Board and possibly the Comission.
The NRC. staff, through its inspection and enforcement program, maintains surveillance over the facility during this entire process, l
'from start of construction through its lifetime, to ensure compliance l
with the specifications of the permit, license or NRC regulations.
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