ML20211G736
| ML20211G736 | |
| Person / Time | |
|---|---|
| Issue date: | 04/28/1997 |
| From: | Jordan E, Silber J NRC - REVIEW GROUP (AFFILIATION NOT ASSIGNED) |
| To: | Callan L, Funches J, Galante A NRC, NRC OFFICE OF THE CONTROLLER, NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20211G717 | List: |
| References | |
| NUDOCS 9710030224 | |
| Download: ML20211G736 (8) | |
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% UNITED STATES
[ } NUCLEAR REGULATORY COMMISSION 3 g WASHINGTON, D.C. ensas w i Q
4, ,*f April 28, 1997 isMORANDUM FOR: Leonard J. Callan, Executive Director for Operations Jesse L. Funches, Chief Financial Officer Anthony J. Galante, ChiefInformation Officer -
Hugh L. Thompson, Deputy Executive Director for Regulatory Programs Edward L. Jordan, Deputy Executive er ector for
- Regulatory Effectiveness, Frogram Oversight, Investigations &
Enforcement Karen D. Cyr, General Counsel F
Carlton R. Stoiber, Director Office of antemational Programs Ronald M. Scroggins, Director, Office of tb Controller dy,Yg., '
- N '
Car? A. Paperiello, Director, Office ofNuclear Material Safety 9 and Safeguards Samuel J. Collins, Director, Office of Nuclear Reactor Regulation i
' David L. Morrison, Director, Orfice of Nuclear Regulatory Research Edward L. Ha! man, Director, Office of Administration l
Denwood F. Ross, Diredor, Office for Analysis and Evaluation of Operational Data James Lieberman, Omce of Enforcement Guy P. Caputs, Dn ector, Office ofInvestigations Paul E. Bird, Director, Ofhee ofPersonnel Irene P. Little, Director, Office of Small Business and Civil Rights Richard L Bangart, Director, Office of State Programs FROM: w .
No-chairman Strateg'. Astessment and ebasch S Comfnu Ca a J equ me . Sd er, chairman trat ic Assessment and Rebaselining Steering Committee
SUBJECT:
ASSIGNMENT OF OPENISSUES During the first phase of the Strategic Assessment and Rebaselining S'.cering Committee (the Committee) initiative, a listing of 202 issues that require resolution was compiled. Of the 202 issues, PO remain open and are being transmitted to you for resolution. The purpose of this memorad.:a is to prcvide an organization specific listing of open issues (see attached), to etWde jp unce on requirements of tracking and resolution, and to pavide some background isormation.
9710030224 970926 PDR ORO NE ED PDR m i
e .
1 2- April 28,1997 In order to ensure documented closure of all the issues, the Executive Director for Operations' (EDO) Administrative and Correspondence Branch will track these issues in the Work Item Tracking System (WITS). The WITS number for each issue is listed on the attachment. l l
Ifyou are designated the lead Office or have sole ownership of an issue, you will need to: l
- 1. review the issue to determine what action is necessary for resolution. In some cases, an additional new action may be necessary, in others no additional action may be necessary.
In all cues it is necessary to document how the action was completed. You will need to submit this document to the EDO and include M. Bridgers and C. Schum on distribution.
Ultimately these records will reside with the Strategic Assessment files.
- 2. determine a genuine due date for resolution and provide that date to Margo Bridgers.
- 3. ensure that the input from the other designated assignment ofdce is obtained.
On May 31,1996, the Strategic Assessment and Rebaselinir,3 Phase I Report, Volume I, was transmitted to Office Directors and Regional Administrators. The majority of the remaining open issues identified by the Committee are discussed in the Phase I Report. The remaining issues were identified in Commission papers and referred to the Committee in the subsequent Staff Requirements Memorandum (SRM). The pertinent papers are SECY-95154," Report on Parts Two and Three of the National Performance Review: Phase II Study Plan - NRC Functions and Efficiency Review," dated June 14,1995, SRM dated August 30,1995; SECY-95 175, " Senior 2xecutive Review Committee Initiatives," dated July 11,1995, SRM dated August 10,1995; SECY 95176,"Informa; ion Technology Planning Agenda," dated July 12,1995, SRM dated August 17,1995; and SECY-95-268," DOE Part 810 Request for Westinghouse Electric Corporation to Transfer Technology for Pressurized Water Reactors (PWR) and PWR Fuel to Ukraine," dateo November 8,1995, SRM dated November 30,1995. The " Basis" section of the attached listing identifies the appropriate paper for you, t
Attachment:
As stated -
4
uceme na <,.<1 c u pier s 8.6 LICENSE RENEWAL APPLICANTS 8.6.1 Licensing Lit *..ing Must (1,5) Ccre .
Strateoic Issue:
Miat is the appropriate level and mix of technical resources to effectively conduct the license renewal program, including development of the regulatory infrastructure, in an environment where the number and timing of license renewal applications'is uncertain?
DESCRIPTION:
This function includes activities associated with reviewing license renewal applications and issuing renewed licenses, licensing actions, and licensing activities. The staff activities, associated with processing renewal applications are similar to those during initial li8ensing, but are limited in scope by the operative regulations. The regulations require lice m renewal appiicants must provide detailed technical infortation for review by the i
staff. These reviews encompass a broad spectrum of technical disciplines, r
such as mechanical, electrical, structural, chemical, materials engineering, and radiological /nonradiological environmental requirements.
Although there has been considerable interaction between the industry and the i
NRC, no applications for renewal of an operating license have been formaMy submitted. The Commission has focused on license renewal to assure regulations and the requirements are clear and predictable. Utilities interested in renewal will look for assurance chat the cost for venewal is predictable. See Section 8.3.7 of this report for a discussion on rulemaking ir response to licensees' concerns relating to the original verstu ef the license renewal rule (10 CFR Part 54) and proposed changes to envirunmental review requirements for license renewal (10 CFR Part 51). The objectives of these regulatory initiatives have not been fully tested.
Between 2010 and 2030, the licenses for 100 plants expire. With f. t exceptions, most licensees are aligible for license renewal. It is expected to take three to five years to process a license renewal application. The reviews will rely predominantly on engineering disciplines, but will also require specialized expertise for the environmental reviews. One or two applications for renewal are expected to be submitted within the next 2 to 3 years. Beyond that, the number of plant specific applications depend on economic conditions and regulatory environment at the time the decision to submit an application would be made. Under high economic growth assumptions, the best estimate of the total number of plants which will apply for license renewal is on the order of 75 percent of ooerating nuclear power plants, or approximately 81 plants. Recent discussions with industry representatives suggest that the actual number may be lower due to tne external factors discussed below. The staff believes that if a substantial number of licensees--more than 15--submit applications in the over the next decade, the IRC !ill be challenged to process the applications in a timely manner because af .esource constraints.
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Chapter 8 IJcense Renewal
' LASES:
Licensing functions associated with the renewal of operating commercial nuclear power plants are functions that the NRC MUST do. Section 103.c of the Atomic Energy Act of 1954 (AEA) and National Environmental Policy Act of 1969 (NEPA) provide the statutory framework for the renewal of operating commercial nuclear power plants. The AEA limits the duration of operating licenses for nuclear power plants to a maxin.um of 40 years but permits their renewal. The NRC implementing t egulations for renewing commercial power reactor operating licenses can be found in 10 CFR Part 54, Part 51, and Part 2. Part 2 entails the licensing hearing process; Part 51 contains the environmental review requirements for an application; and Part 54 prescribes the technical requircments for a license renewal application.
EXTERNAL FACTORS / IMPACTS:
Economics:
The principal decision on whether to rensw the license of an operating reactor most likely will be driven by the following external economic factors, each of which is individually important to the overall decision:
The cost of nuclear compared to other generation alternatives License renewal, aside from uncertainty.concerning regulatory requirements, is generally viewed as beneficial from a cost standpoint.
After capitalir.ation costs have been recovered or substantially reduced, the cost of nuclear generation relative to other generation alternatives is very competitive. Production costs, which include O&M plus fuel for energy produced from nuclear fuel, have been declining over the past two years where they are now essentially equal to energy produced from coal plants and substantially lower than gas or alternative energy feels.
New construction of any baseline facility would be at an immediate disadvantage to a fully-depreciated operating nuclear plant.
Increasingly competitive environment in the electric utility industry, including the impact of deregulation (Public Utility Regulatory Policies Act of 1978 and the Energy Policy Act of 1992). Unless the majority of nuclear facilities are (1) allowed accelerated depreciation to coincide with a time-table for a competitive bulk power mat ket or (2) substantially relieved of stranded cost burdens, license renewal will not be a viable option and may result in premature plant shutdown.
for economic reasons.
r
- Growth of electricity demand by region and potential sources The growth of electrich." e mand in some regions of the United States is expected as the economy i p.nds. In turn, this is expected to make license renewal attractive to licensees in regions with a heavy nuclear presence and increased demand for energy--notably the Southeast.
Continued safe operation of reactors--domestic and international The continued safe operation of power reactors in the U.S., and to some extent worldwide, is important to whether many of the economic factors discussed above will be favorable or uafavorable to the continued use of Phase ifinal Report PREDECISIONAL - NOTTOR RELEASE Page 8-63
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- Uceme Renew!
CWer a nuclear electrical' generation. Not only would a high visibility event have a profound im)act on the support of Congress, the public, and the financial markets cut resultant regulatory requirements could delay licensing activities, particularly renewals. An accident at any facility, foreign or domestic, could make the economic balance even more unfavorable to nuclear.
Leaislative/Ruulatorv:
Resolution of high level waste issues is discussed in Chapter 9 of this report. The development. of spent fuel management is essential for license-renewal and continued operation of some operating reactors. Development of dry cask storage is an important element in reducing cost of overall spent fuel management.
Advocacy Grouns:
1 The positions of advocacy groups are a major factor in decisions of licensees to maintain and seek additional nuclear capacity. While serious challenges'to Part 54 have been notably absent during the rulemaking process, challenges to individual plant applications for renewed licenses seem more likely. Some advocacy groups argue that plants applying for license renewal should be evaluated against current standards. These groups question the adequacy of the licensing basis and whether licensees are complying with it.
Several advocacy groups argus that electricity generation by nuclear power has external costs that should be included in weighing alternatives. External costs are defined as-being costs to society that are not included in the producers' costs. Whether there are, in fact, significant external costs of '
nuclear generation is a subject of disagreement among opponents and proponents of nuclear power. Advocacy groups would like this to be'an issue in-environmental hearings for license renewal. As with governmental support and
. opposition, changes in viewpoints can occur over the span of a decade -- the direction of change is unknown.
Conaressional. Executive. and State coverrment:
Political support for various electric energy generating sources has shifted, often dramatically from one to another, since the end of World War II..
Various sources have enjoyed strong political support, including hydro, nuclear, coal, oil, and back to coal,- renewable sources at various times, and-now natural gas and renewables. Currently, the Department of Energy, the energy policy agency of the Administration, does not include new nuclear power
-plants or license renewal in its strategic plan as a source-of additional energy services (reference: Fueling a Competitive Economy, Strategic Plan, United States Department of Energy, April 1994). Concerns ever greenhouse gases and other air quality problems of fossil burnin1apparently is not strong enough to consider nuclear as a partial solution. Over the horizon of
.this assessment, other shifts in political support may occur.- In spite of congressional efforts for over 20 years to develop a national energy policy, the lack of consistency of policy causes great difficulty in planning over a time horizon that is needed for generating capacity planning.-
Political support or opposition also varies at the State level. Some major public utility comissions:(PUB) are requiring utilities to provide ,
integrated resource plans for new construction. These plans'are closely Pzge 8-66 PREDECISIONAL - NOTFOR RELEASE Phase i Final Report
Oqter 8 Llw ur Renewal i
scrutinized by various State agencies and advocacy groups. PUCs in some major States require additions to be nade to the cost estimates of power plants for
' environmental adders." Nuclear power is rarely credited with external j 1
benefits. There is much more political pressure to count external costs against nuclear plants. Demand side management in use by some States has the effect of discouraging new construction and at least in one ,o was a factor in the early shutdown of an operating reactor. Some statt ernment decisions are in agreement with advor.acy groups who urge 1. shutdown of nuclair power plants. For example, the Prairie Island decision by the Minnesota state legislature to limit onsite spent fuel st'orage could result in premature shutdown of two units. Other State PUCs look upon the continued operation of nuclear plants as an important part of the state's energy mix.
In general, the political climate regarding nuclear power has a temporal nature. The current overall impact of Federal and State government positions !
provida limited support for license renewal.
INTERNAL FACTORS / IMPACTS:
Commission Direction:
Sustained Commission interest in license renewal continues to be a significant internal factor. In June 28, 1993, staff requirements memorandum the Commission stated that it is essential tc have a predictable and stable regulatory process clearly and unequivocally defining the Commission's expectations for license renewal. The Administration further emphasized the need for governmental efficiency as part of its regulatory reform initiative associated with Phase 11 of the National Performance Review. For license renewal, the NRC must balance governmental efficiency with its primary mission of protecting public health and safety and the environment.
A draft Commission paper is nearing completion-that forwards the proposed final amendment to Part 51. The Part 51 rulemaking effort will-define the breadth of the environetal review required for license renewal applicants and will define the type ind amount of staff resources necessary for review.
The objective-of the-rule amendment is to reduce tne ourden associated with license renewal applications, resulting in net savings to licensees and the
-NRC.
Resolution of Technical Issues:
Timely resolution of technical issues--such as environmental qualification, steam generators, core shrouds, vessel head cracks, control rod drive housings, and fatigue--impact licensee decisions regarding license renewal.
The priority and resources assigned to resolve such technical issues significantly impacts license renewal.
Resource Innacts:
As discussed above, if a substantial number of licensees submit license-renewal applications in the over the next decade, the NRC will be challenged to process the applications in a timely manner because of resource constraints. In addition to the level of resources needed to perform the reviews, an appropriate mix of technical skills necessary to review applications is also needed. This issue was also discussed in the Human Resources Strategic Plan for 1995-2004.
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License Renewal ChaptY8 As discussed in Section 10.5 of this report, the availability of a capable, knowledgeable staff and management that licensees can interact with is a challenge the agency faces as efforts to downsize the federal government i continue. I CORE / ENHANCEMENT:
Licensing functions associated with the renewal of operating comercial nuclear power plants are CORE functions because of the impact on nuclear health and safety opportunity.
STRATEGIC ISSUES /0PTIONS:
As discussed above, the principal decision on whether to renew the license of an operating reactor most likely will be driven by the external economic factors. The number of plant specific applications depend on economic conditions and regulatory environment at the time the decision to submit an application would be made. While the external factors are generally outside the sphere of the Commission's influence, the regulatory environment is directly affected by Comission decisions in the near future.
A strategic issue arises from some choices the NRC can make that affect the governmental efficiency associated with license renewal. The strategic choices involve decisions whether to invest FTE now to realize FTE savings in the future, or maintain current priorities and to respond to demands on an as-needed basis when license renewal applications are received.
One strategic choice is whether to pursue resolution of technical issues that impact license renewal licensing reviews generically or on a plant-specific basis. On one hand, the Commission could decide to pursue generic resolution l of technical issues that impact license renewal reviews on a high priority i bases. This course of action would er sura a more predictable licensing i
environment exists for plant-specific license renewal applications by resolving certain technical issues generically prior to plant-specific applications. As a result, the NRC would realize net savings in. FTE during the review of an application because certain technical issues would have been
, previously resolved. On the other hand, the Commission could decide to maintain the current priority associated with resolution of technical issues that impact license renewal. If and when plant-specific applications are received, the NRC could reassign resources as needed to resolve any technical issues that arise-during the plant-specific reviews.
Similarly, strategic choices must be made regarding the mix of technical staff needed to complete licensing reviews. Licensing reviews typically require specialists from various technical disciplines. See Section 10.5, " Human Resources Management," for a detailed discussion of this strategic issue.
Another strategic choice involves the level of effort associated with developing the regulatory infrastructure that supports the license renewal licensing reviews. Regulatory infrastructure includes regulatory guides, standard review plan for license renewal, and inspection procedures. The Comission' could assign a higher priority to the continued development of the regulatory infrastructure for license rer.ewal. This would enable the NRC to more accurately plan for resource needs associated with license renewal i
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Chapter 8 Licerue Renewal application reviews. The Commission could also choose to stay the current course by developing portions of the regulatory infrastructure concomitant with the review of the initial plant-specific license renewal applications.
Issue: What is the appropriate level and mix of technical resources to effectively conduct the license renewal program, including development of the regulatory infrastructure, in an environment where the number and timing of license renewal applications is uncertain?
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