ML20211G713
| ML20211G713 | |
| Person / Time | |
|---|---|
| Issue date: | 09/26/1997 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20211G717 | List: |
| References | |
| NUDOCS 9710030217 | |
| Download: ML20211G713 (6) | |
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NUCLEAR REGULATORY COMMISSION at WASHINGTON, D.C. 30h0001 44*****
,o September 26, 1997 MEMORANDUM TO:
L. Joseph Callan Executive Director for Operations FROM:
rector Office of Nuclear Reactor Regulation 0
SUBJECT:
RESOLUTION OF STRATEGIC ISSUE RELATED TO TECHNICAL RESOURCES FOR LICENSE RENEWAL APPLICATIONS (SECTION 8.6.1 OF PHASE I REPORT)
At the end of the first phase of tne Strategic Assessment and Rebaselining Steeririg Committee (the Committee) initiative, an issue related to the technical resources for the license renewal program remained open. The Committee referred this isrue and the other open issues from Phase i for resolution, in its memorandum dated April 28,1997, and designated this issue as WITS 9700143 to track closure. Specifically, the following question was posed relative to strategic planning:
What is the appropriate level and mix of technical resources to offectively conduct the license renewalprogram, including development of the regulatory infrastructure, in an environment where the number and timing oflicense renewal applicationsis uncertaln?
In Section 8.6.1, the Phase i report describes this strategic issue in some detail, and describes the substantial uncertainties related to whether or when licensees might apply to renew a power reactor license pursuant to 10 CFR Part 54 and file an environmental impact statement pursuant to 10 CFR Part 51. Among these uncertainties are significant changes in deregulation of the electric utility industry, shifts in political support or opposition, shifts in public support or opposition, shifts in national energy policies, the potential for protracted and costly litigation, and the potential for legislative or regulatory changes that could substantially affect the costs of a renewal application. Consequently, although the license exp! ration dates for operating power reactors are clear, it is very difficult to estimate the number and timing of renewal applications because these uncertainties may compel licensees to choose decommissioning over renewal.
in spite of these uncertainties, the NRC is obligated to perform a timely review of any renewal applications, and ap aly appropriate expertise to ensure that the licensing decisions are technically sound.
The Commission approved changes to 10 CFR Parts 54 and 51 in May 1995, and December 1996, respectively, which clarify and simplify the process for a :icense renewal application. The changes to Part 51 addressed many of the environmentalimpacts of license renewal O
generically, and clarified the issues that would have to be addressed in a supplement to the DFD3, [
environmentalimpact statement on a plant-specific basis. Similarly, the changes to Part 54 simplified the process to make license renewal more stable and predictable. A se eening review is required under Part 54 to identify " passive" and "long-lived" structures and 9
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L Joseph Callan 2-I components, as defined in the rule, for which the applicant must demonstrate that the effects of aging will be managed in such a wcy that the intended function or functions of those structures and components will be maintained for the period of extended operation. To demonstrate that the effects of aging will be adequately managed, additional programs may be necessary for a structure or component within the scope of the rule; these could include, for example, new monitoring programs, or new inspections. Another requirement for license renewal is the identification and evaluation of time limited aging analyses, which are those design analyses for systems, structures, and components based on the CJrrent operating license term.
As described in SECY 97-118, the staff has shifted its renewal efforts from further improvements to the license renewal regulatory guide (RG) and standard review plan (SRP), to the review of plant specific and owners group technical reports to acquire experience from which this regulatory infrastructure can be improved. The draft license renewal and environmental RGs and SRPs have been or are being placed in the public domain for trial use.
Currently, no licensee has made a formal application for renewal. However, the licensees for l
Calvert Cliffs and Oconee have submitted technical reports and requested that the staff prepare safety evaluations for those reports pursuant to Part 54, so that they may be referenced in a renewal application in the future. Both licensees have also met with the staff to describe their approact to the environmental review. Both licensees are preparing applications for submittal as early as mid 1998, following corporate decisions on whether to formally apply for renewal.
At least two other licensees are expected to pursue technical reviews or a renewal application within about the next year, but have not yet formally announced such intent.
The owners groups have similarly submitted technica' reports on particular structures and components (e.g., reactor vessel, reactor coolant system and piping supports, containment, pressurizar, and reactor internals) and requested staff evaluations pursuant to Part 54, so that these reports could be referenced in renewal applications. The industry and the staff are using these plant specific and generic reports to clarify the effort required to conduct a renewal review. This experience can then be used to identdy policy issues, refine the review guidance and process, and estimate resource needs.
The experience thus far has only provided a general idea c, the kind of technical expertise that will be needed for reviewing renewal applications. The technical review basically consists of systems engineers screening and identifying structures and components subject to an aging management review, and mechanical, civil, electrical, and materials engineers reviewing the aging effects, aging management programs, and time limited aging analyses. The environmental review, however, relies on a small core of general environmental engineers for coordination and on many specialized experts for a wide variety of topic areas such as socioeconomics, endangered species, land and water use, marine life and habitat management, and severe-accident management. The staffs continued efforts to refine the renewal guidance to gain stability and consistency in the renewal process will enhance the resource planning for the NRC as well as for the licensees.
Fundamental to the resource issue for renewal applications are the strategic choices for obtaining and allocating particular staff expertise and funds for technical assistance contracts.
L. Joseph Callan 3-The strat9gic choices identified in Phase I range from investing substantial effort in the near term to prepare for renewal applications, to investing minimal effort until resources can be applien on an as needed basis when the renewal applications are submitted. This memerandum focuses on the technical expertise needed for reviewing renewal applications, because the broader resource issue is also being addressed under the strategic issues in Sectl)n 10.5 of the Phase I report,' Human Resources Management.'
Sinco the renewal resource issue was identified, the Commission has submitted its Strategic Plan to Congress, and directed each office to develop a corresponding operating plan.
Although these operating plans are not yet fully developed or tested, they are expected to provide linkage between budgeted resources and planned products, and establish means to measure whether those plans are providing the desired outcomes. As such, the development of the operating plans provides a better understanding of the strategic choices and the means to manage the resource allocation in the future. In particular, measures of performance and i
outcomes should provide the means by which NRR and the NRC will be better able to manage change and adjust resource allocations as the need for particular expertise becomes evident.
l The NRR operating plan and resource allocations for FYg8 reflect a staged approach to addressing the renewal resource mix. This approach consists of three basic elements: (1) a core group of technical expertise and project management for license renewal, (2) allocation of renewal work assignments and team building to provide staff training and achieve efficiencies when there are issues with overlapping interests for operating reactor safety end aging management for renewal, and (3) specialized technical assistance from contractors (i.e., the technical assistance budget). The core group will concentrate on building the infrastructure and improving the process, and establishing efficient review practices. The renewal work assignments will serve to foster team building and renewal training among the core group, the NRR technical staff, and other NRC offices and the regions. The technical assistance contracts will be used as a resource for routine renewal work assignments, when the NRR technical staff is needed for higher priority work, and to provide very specialized technical expertise when it is not available or when it is inefficient to develop that expertise among the NRC staff. This specialized expertise will be needed primarily in the environmental review and materials issues, in this planning, the staff is mindful that where such specialized expertise is relied upon from contractors, there must be provisions to defend that work in the event of a hearing on that subject.
- d L. Joseph Callan 4-September 26, 1997 in summary, we conclude that this strategic issue is being appropriately addressed in the evolution of the strategic planning, implementation of operating plans and performance measures, and associated changes to the budget and staffing process, it was perceptive of the Committee to view the license renewal resource issue in terms of a mix of technical resources, because this !6 sue can be best resolved by providing a blend of staffing and budget approaches
- in the natural evolution of agency wide process improvements and measures to satisfy the Government Performance Results Act.
cc:
A. Thadani J.Funches
' A. Galante H. Thompson
- DISTRIBUTIOft Central File (w/originalincoming)
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PUBLIC (w/ incoming)
EDo r#
OCA LCallan NRR Mail Room (EDO#Wg700143 w/ incoming)
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PNorry MClark JBlaha MBrigers, DSI 18 SCollins/FMiraglia CSchum, DSl 18
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JRoe DMatthews CGrimes 4
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EDO ClGrime[h JWR [
fy Narne RSanders' LJCallan Date 9/19/97-g/22/97
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DOCUMENT NAME: A:\\W9700143. DOC (CGrimes/LLM Disk) 1
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L. Joseph Callan 4-In summary, we conclude that this strategic issue is being appropriately addressed in the evolution of the strategic planning, implementation of operating plans and performance measures, and associated changes to the budget and staffing process, it was perceptive of the Committee to view the license renewal resource issue in terms of a mig of technical resources, because this issue can be best resolved by providing a blend of staffing and budget approaches in the natural evolution of agency wide process improvements and measures to satisfy the Government Performance Results Act.
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cc:
A. Thadani J.Funches A. Galante H. Thompson I
. W TS TEM STRATEGIC ASSESSMENT ISSUE PAPER (051 18)
DUE:
WITS CONTROL:
9700143 NRR RECEIVED:
uAy ir,. 1997 I
ACTION:
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hbO NRR ROUTING:
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