ML20237L146
| ML20237L146 | |
| Person / Time | |
|---|---|
| Issue date: | 07/21/1987 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20235X977 | List: |
| References | |
| FOIA-87-615, FRN-55FR29043, TASK-PII, TASK-SE AD04-1-103, AD4-1-103, SECY-87-179, NUDOCS 8708200099 | |
| Download: ML20237L146 (31) | |
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July 21, 1987 l POLICY ISSUE [ECY-8f-179 For:
The Comissionergggg )
From: Victor Stello, Jr.
Executive Director for Operations <
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Subject:
STATUS OF STAFF ACTIVITIES TO DEVELOP A LICENSE RENEWAL i l POLICY, REGULATIONS AND LICENSING GUIDANCE AND TO REPORT l
- ON PUBLIC COMMENTS
Purpose:
To inform the Comission of staff plans and activities to '
develcp a policy on the renewal of power plant licenses that I will expire after 40 years pursuant to Section 104(c) of the j i Atomic Energy Act and develop implementing regulations and j l licensing guidance. Also, to inform the Comission of responses ;
, to the November 6,1986 request for coments on license renewal l l policy development published in the Federal Register. !
l Sumary: The staff has initiated a program for license renewal policy l i development in response to the Comission's 1986 policy and ]
l planning guidance. The proposed schedule provides for i publication of a final policy statement in 1989,' publication of -
l final implementing regulations by 1992, and issuance of licensing ;
guidance documents by 1995. In the fall of 1987 the staff will l send to the Comission a paper on policy options for relicensing l and request approval to issue it for public coment. The schedule provides for public input at several points during the development of policy and regulations for license renewal. The first request for public comments published November 6, 1986, resulted in 58 written responses from the U.S. electric utility .
industry, public interest groups, private citizens, independent j
, consultants and government agencies. The nuclear power industry, l one public interest group and some individuals supported the ;
concept. One public interest group and several individuals opposed license renewal. ]
l Discussion: The staff has initiated a program for license renewal policy i development in response to the Comission's 1986 Policy and Planning Guidance. Although a policy. option of no license
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renewal was ; identified in public coments, the staff is i
proceeding with the program on the assumption that a viable i i
license rene'wal policy and regulations can be developed. The proposed schedule provides for a careful development of the !
license renewal policy, implementing regulations and licensing !
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Contact:
Donald P. Cleary, RES
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o 1 To The Commissioners i guidance documents which will allow for license renewal and ;
assure the continued safe operation of ' relicensed nuglear power 1 plants ~and continued compliance with the National' Environmental. j l
Policy Act. The program provides.for: _ coordination within NRC,- l l especially with the power plant aging research program and with j the Office of the General Counsel; public. input during the' course l of the program, especially through' requests for. public coments;.
, and information exchanges and coordination with industry in an:
l oper and professional manner. Industry representatives met'with: .
i the staff and'its contractor -(MITRE) on April 22, 1987 to present i i
their. views;on' regulatory considerations for. extending the life i
. of nuclear power plants. An industry briefing on this topic was held for the EDO and senior NRC management on'May 27, 1987..- .l In addition the. staff discussed its activities regarding .
l j license renewal policy development with the'ACRS on June 5, 1987.
The staff believes that the program schedule is compatible with:
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the need of utilities to be informed of license renewal require-ments sufficiently early to prepare for license renewal.or to- ;
pursue an alternate source of generating capacity. Major future 1 milestones are: identify policy options and request Comission _ l approval to issue them for public coment, fall 1987; propose a l
l license renewal policy to the Commission for public-coment, September 1988; publish final license renewal policy and-issue i proposed regulations for public comment, September 1989; publish ~_
final regulations,1992; and, complete issuance of licensing guidance documents by 1995. A fuller discussion of. plans and l l activities is provided in enclosure 1.
As a first step in public involvement a solicitation for ,
comments on seven major issues was published on November 6 '
1986, " Request for Comments on Development of Policy for Nuclear Power Plant License Renewal," Federal Register, Vol. 51, No.:215, pages 40334-40335. - The extended coment period closed on. ;
February 2, 1987. A total of _58 written coments were received.
A sumary report is provided as enclosure 2.. Comments were
- received from a cross section'of the U.S. electric utility .
industry, public interest groups, private citizens, independent-consultants, and government: agencies.- Forty-three responses I were from the nuclear power industry. In general.1the industr l consensus was represented by the Atomic Industrial Forum (AIF)y and the Nuclear Plant Life Extension (NUPLEX) Steering Committee, which provided detailed responses.' These coments indicated that the NRC should establish a renewal policy by the late 1980s' with detailed regulations by the early 1990s, and that ,
applications for license renewal should be allowed any time up to one year before license expiration. -Also, the basis.for
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license extension should Le the original licensing basis and any new technical issues should be limited to safety-significant L
aging effects. Over half of the industry respondents stated
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theirsupportoftheLAIFandNUPL$Xpositions',withlittleor-n$
additional .comentary. On:som6 4/sestions, however, jndividual'.
. industry respondents expressed: ther viewpointsLon sech issues as the scope and use of p%nt p :rformance historical data in license renewals, the extent to which risk-assessment should be f '
used im identifying aging-telsted safety concerns, and the '
durations of license renewal l periods.
' Y NonNdustryperspectiveswerelimited.- Thethreegovef,ume)n,.p p
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agencies providing coments-Were: the U.S. Department of y '.
Energy, ~ the U.S. Department of the Interior -(U.S.(MIogidg1 -
Survey), and the State of Wisconsin ~ Public Service '
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3 The . Department of Energy response' closely para 11elbd the t<
j industry position as stated in the NUPLEX coments. cThe,ths./I '
n i Geological Survey provided a- brief. statement on the need\tc update. groundwater data around nuclear plants for license .
renewals, and the Wisconsin'Public Service Comission provided -
detailed responses to several-of the NRC solicitation questions.
Two public interest groups.provided written comments. One, Ecology Alert, stated itt, Apposition to license renewal, and the.
other- group, Ohio Citizens for Responsible Energy (OCRE) provided detailed _ coments. In general, OCRE supported the concept of license renewal, but. advocated a cautious approach on-timing, technical, and procedural issues. Of the ten
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1 individuals commt# ting, six were opposed to license renewal..
while the.others ' clearly favored renewal or provided responses i to specific questions without expressing an overall position on-renewal. 'l'
< 8 Coordination: The Office of the General Counsel has reviewed,this paper. and has no legal objection to it. r CAh
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- VctorStel(lo,Jr.W 1
Executive Director ;
, for Operations- ,
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Enclosures:
As Stated O (re
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9 i f\ ENCLOSURE 1
'l STAFFACTIVITIESTODEVELOPAPROPOSEDPOLICYANDIMPLEMENTJNG i REGULATIONS FOR POWER PLANT LICENSE RENEWAL-A STATUS REPORT.-MAY 30, 1987 ;
INTRODUCTION
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Comission guidanceV'.n goals, policies and planning for license renewal is provided in the PPG (NUREG-0865, Issue 5). Strategic Goal 2.12 includes development of the process necessary to renew plant operating licenses. I Policy item 23 states:
"Rekunsts for.
will require a,an operating dvanced license' planning renewal are and analysis.. ThetoComission be anticipated and intends to continue development of the policies and criteria to define. requirements for operating license extensions to help assure that industry's efforts in this area are" focused on the primary regulatory concerns (GOALS 1.13; 2.12)." r f
Planning Guidance' Item 22 provides the following instruction to the staff:
"In' view.of industry initiatives to address operating license renewals, the' staff should. propose policy guidance and develop licensing criteria to define requirements for operating license extensions. The staff q should work with industry to ensure that key regulatory issues are 1 identified (GOAL,2,12)."
The staff has developed a program plan and has initiated activities in response
/. to the Comission's 1986 policy and planning guidance on license renewal. The plan' cal,ls for publication of a policy statement in 1989, publication of final-imphementfng regulations by 1992, and issuance of revised or new regulatory guides and standard review plans by 1995. Program responsibility for the
. development of a proposed policy on license renewal and implementing regulations is assigned to the Office of Nuclear Regulatory Research, Division j1 of Reactor and Plant Systems, Reactor and Plant Safety Issues Branch. i
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! BACKGROUND 4' s Definitions
, License Renewal - The issuance of a new license to operate beyond the 40 year term of an existing license.
License Extension - Extending the termination date of an existing operating license to allow 40 years of operation starting with the date of issuance of
- , the full-power license.
R y J't:".lfeExtensionerPlantLifeExtension(PLEX)-Involvesextendingtheeconomic i -
life'of a plant as well as license renewal, y f i
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Need for a License Renewal Pc ,
The'nuclearindustryinitiatefaneffortdesignedtoextendthelifeof existing reactors beyond their original license term of 40 years. The. primary motivatiogis econoc;ic. There are ever 100 nuclear power plants in operation '
representing capits? investments 'of over $200 billion. A recent Department of -
Energy study esti~ md that license. renewal for 20 years conservatively would . j result in a net national benefit of $230 billion through the years 2030 when compared to new coal plant construction.
,,{ STAFF ACTIVITIES, FLANS AND SCHE,0VLES r .s
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The' activities and\chedulef describedi alow are designed to provide for the careful . development efa lWense renewal policy and implementing regulations which will allow forylicehse' renewal' and assure continued safe operation' of nuclear power plces and continudd compliance'with the National Environmental Policy Act. They also prod de opportunity for considerable public input during the course of the program. This is designed for consideration of divergent views earlier rather than later which should result in a proposed policy and re.1ulations which would be more widely acceptable. The plan provides for information exchange and coordinatiomwith industry but in an open and ;
professional manner necessary to ensure credibility of the policy and !
regulations ultimately proposed. The staff believes that the program schedule is compatible with the need of utilities to be informed of license renewal :
requirements sufficiently early to be able to either prepare for license-renewal or pursue an alternative source of generating capacity.
x Activities, !
g Overview: The staff began a systematic ' effort on license renewal policy I
develosiaant in June 1986. Activities have included initiating work on a ,
program plan, familiarization with NRC aging research and' industry life '
extensionactivities,establishingproceduresfor.informationexchangeand coordination inside and outside of NRC, requesting and reviewing public !
L conwnts, and initi# ating i techd, ,eal assistance with the MITRE Corporation. ,
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Program Plan: Oc\ February 26h MS7*a memorandum outlining staff plans for license rentwalg p.1 1 1cy developer.t wastoncurred in' by the Director of the i Offich of Nuclear Reactor Regu14 tion. Ethat time responsibility for license ;
renewal policy dryelopment cesfed in the Division of Safety Reviey and i Ovedfaht, Office of Nuclea'r LTctor Regulation. Subsequent to the recent organization of NRC, that responsibility now resides in the Division of RedciMr'and Plant Systems of the Office of Nuclear Regulatory Research. The plan has undergone revision md refinement since the February memorandum and will continue to be refined and more' fully developed to'. assure that the major milestones identified below will be met.
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1 Schedule: The following major milestones have been proposed to assyre the Comission is kept. informed and that there.is adequate opportun.ity for public !
' input as a license-renewal policy and.. implementing regulations are developed.
License Policy Development Staff Schedule Major Milestones- .l 1
Send Information Paper' to Comission Discussing - June 1987 License Renewal Issue, Staff Approach to 1 Policy and Regulatory Development, Schedules, j and Analysis of Public Comments on License "
Renewal Federal Register'Motice-Identify Policy Options for. Relicensing and Fall 1987 .i Meet with Comission to Discuss Option,'.get l
(,ommission Guidance i s
Propose a License Renewal Policy to September 1988 Comission,' Issue Proposed Policy for ,
Public Coment 'q Consider Public Comments, Conduct Internal October 1988 Review and Refinement of Proposed Policy. August.1989 i Start Development of Proposed Regulations ;
to Implement Policy i Publish Final License Renewal Policy Issue September 1989 Proposed Regulations for Public Coment 4 Publish Final Regulations 1992 Complete Issuance of Regulatory Guides and 1995 Standard Review Plans Technical Assistance Contracts: Due to 11mitad availability of staff much of the work in developing license renewal policy and regulations must be accomplished with contractors. In early April 1987 the MITRE Corporation began 3 providing technical assistance under ' contract number NRC-03-85-060, -a = task i order contract previously negotiated. During the first phase of work MITRE a will produce two reports. The first report will identify policy issues for d license renewal -and the second report wil's progress to the identification of-regulatory options for license renewal. These reports are to be completed by !'
' September. The report on policy options will' provide the basis for a Federal Recister notice to request public coments on the options.. The second phase of work for MITRE includes .a detailed evaluation of the regulatory options, i consideration of public coments, synthesis of the options into a proposed !
license renewal policy for public coment, and revision of the proposed policy resulting;in a' final policy for publication. Contract assistance is also anticipated to be required to develop regulations for license renewal
4 consistentwiththefinalpolicystatementandlikelywilleventuallybe required to produce licensing guidance documents to implement the regulations. i While it is conceivable that MITRE could continue providing technical !
assistance through the end of the program, the long range contracting strategy l has not yet been formulated. We have Degun discussing this matter with the i Division of Contracts. '
In addition to contractual support in the area of policy analysis, there will likely be identified a number of issues requiring contracting for specialized expertise. One important set of issues already indentified is the extent to which probabilistic risk assessment (PRA) can account for aging degradation and l be used to predict future safety levels. The need to contract for this assist-ance will be determined after review of other programs involving efforts in PRA. !
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Coordination with the Aging Research Program: Two major aging research programs are being conducted in the Division of Engineering, Office of Nuclear Regulatory Research. The Nuclear Plant Aging Research Program (NPAR) is focused on components, systems and civil structures. The other program is i focused on vessels, piping, steam generators and non-destructive examination '
techniques. Coordination between the research programs and license renewal i
policy development is being emphasized. The NPAR Program Plan, NUREG-1144, I
Revision 1 (in draft), specifically considers the license renewal policy l development program as a user of agirg research results. As issues are identi-fied within the license renewal policy development program which fall within i the scope of the aging research programs, the Division of Engineering will be requested to incorporate them within its research program. Similarly, identi-fication of issues within the scope of responsibility of any other divisions '
within the Office of Nuclear Regulatory Research will lead to a request for that division to incorporate the issue into its research program. A user need letter concerning nuclear plant aging research was sent from NRR to RES on April 9,1987 requesting RES to consider in its aging research programs the risk significance to public health and safety of the aging process and the potential for risk reduction due to various corrective actions. It also requests that the programs & velop information which permits extrapolation of the aging process and associated risk to the time periods expected to be requested for license renewal.
TIRGALEX: At the request of the Executive Director for Operations, an interoffice executive level Technical Review Group for Aging and Life Extension (TIRGALEX) was formed in May 1986. TIRGALEX developed a report titled " Plan for Integration of Aging and Life Extension Activities." This plan has been reviewed by RES and was recently released. TIRGALEX will be replaced by an interoffice committee of executive level management responsible for monitoring agency wide integration of aging, life extension, and license renewal related l activities. The comittee will be chaired by the Deputy Director, Division of Engineering, RES. -
Coordination with OGC: Numerous legal considerations in the development of license renewal policy and regulations make it necessary to coordinate closely with the Office of the General Counsel. Several meetings with OGC staff have l
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. been held and the attorney assigned to follow license renewal polic.y development is invited to all significant meetings. A memorandum requesting guidance on major legal issues in license renewal policy was sent to OGC in June.
ACRS: The Advisory Comittee en Reactor Safety has been and will continue to be periodically informed of progress and significant developments in the license renewal policy development program. The sub-comittee on licensing was given a overview of our plans on March 5,1987. A briefing was given to the full comittee on June 5,1987 and a briefing on policy cptions is anticipated for the sub-comittee on reliability in August.
Coordination with Industry: Industry plant life extension programs are being followed by the staff. The focal point for these programs is the Nuclear Utility Plant Life Extension (NUPLEX) Steering Committee. License renewal responsibilities are handled by the Licensing Subcommittee of NUPLEX. Two information exchange meetings have been held between NRC staff and NUPLEX and in August 1986 staff members attended a three day industry seminar on plant life extension. NUPLEX has briefed the MITRE Corporation, which is providing technical assistance ,on license renewal to the staff. On May 27, 1987 NUPLEX briefed the E00 and Senior NRC staff. The staff is sensitive to the need to maintain an arm's length relationship with industry relative to license renewal policy development. Meetings with industry will be noticed and open to the public. Procedures for exchange of technical research information and possible research coordination are being considered by the Division of Engineering, RES.
It is the staff's intent that future interaction with industry involving regulatory considerations be within a process open to the interested public.
Public Involvement: On November 6, 1986, a " Request for Comments on Development of Policy for Nuclear Power Plant License Renewal" was published in the Federal Register, Volume 51, No. 215, pages 40334-40335. The extended coment period closed on February 2,1987. A total of 58 written comments were received. These comments have been analyzed and a report is provided as enclosure 2 to this Comission Information Paper. As shown on the schedule provided above, an opportunity will be provided for public coments on policy options, on a proposed license renewal policy, and on propo:ed regulations for license renewal. The staff is considering the possible merits of also holding one or more public workshops at some point. These workshops would be well focused and would likely involve authoritative panelists representing a variety of constituencies. All memoranda and reports produced by the staff and its contractors will be placed in the Public Document R6cm files for access by interested members of the public.
Resource Requirements: In planning and staffing the license renewal policy development program, consideration is being given to the limited availability of staff, the need to coordinate closely with related NRC programs, and the need to depend heavily on contracts for technical assistance. License renewal policy development has considerable economic and safety significance to the nuclear industry and to the public and therefore is politically sensitive.
Because of this, the Director of the Division of Reactor and Plant Systems and
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the Chief of the Reactor and Plant Safety Issues Branch are closely, involved in the program. The program is managed on a daily basis by one full-time Task Manager in the Reactor and Plant Safety Issues Branch. A staff attorney from OGC has been designated to provide legal advice and consultation part-time.
While no specific elements of work have been yet identified for additional staff members, it is certain that occasional consultation and review time will be required over time from a variety of staff members with certain technical expertise and organizational responsibilities. A request has been made to NRR to identify a single individual at the management level as a point of contact for license renewal policy development coordination.
Technical assistance activities were discussed previously. In FY 1987 $150,000 was designated for partial funding of work identified for MITRE. An additional
$150,000 is being sought for FY 1987. The tentative technical assistance budget for license renewal through FY 1990 follows. As license renewal issues and associated technical assistance requirements become better defined, the technical assistance budget, especially that for FY 1990 and beyond, will be revised accordingly.
Technical Assistance For License Renewal Development
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Contractor FY87 FY88 FY89 FY90 Policy Analysis (MITRE) 300 530 200 Regulations Development (TBD) 370 600 Special Technical Studies (TBD 200 300 300 Total W5 7 75 FF T65 INDUSTRY ACTIVITIES AND POSITIONS RELATED TO LICENSE RENEWAL industry plant life extension activities are, for the most part, coordinated by the Nuclear Utility Plant Life Extension (NUPLEX) Steering Committee. NUPLEX is made up of senior nuclear utility staff, and reports to NUMARC on the progress and needs for fulfilling life extension objectives. NUPLEX has three subcommittees. A Technical Subcommittee is responsible for reviewing and coordinating plant life extension research conducted by individual utilities, DOE, EPRI, Owner's Groups and NRC, to the extent possible, and to promote the exchange of technical information. A Codes and Standards Subcommittee is responsible for identifing and recommending utility industry criteria for any changes to current codes and standards necessary for plant life extension. A Licensing Subcommittee is responsible for identifing and recommending consensus utility industry positions concerning NRC license renewal policy and regulatory criteria.
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1 The NUPLEX Licensing Subcommittee has subsumed the responsibilities of the Atomic Industrial Forum's (AIF) National Environmental Studies Project's (NESP). l Subcommittee on License Renewal, a reconstitution of the NESP task force which !
oversaw the development of the report '" Regulatory Consideration for Extending the Life of Nuclear Power Plants," AIF/NESP-040, December 1986. This AIF report has been adopted by NUPLEX as its position on license renewal policy.
Both AIF and NUPLEX submitted the report as an attachment to their response to i the NRC's request for public coments on the development of a policy for nuclear power plant license ' renewal. NUPLEX and the AIF contractors who wrote AIF/NESP-040 have made two presentations to the NRC staff on that report. The ;
first presentation, in April 1987, was for NRC staff directly involved in license renewal policy development and staff members of the MITRE Corporation <
who are assisting NRC. The second presentation, in May 1987, was for the ECO j and senior management.-
A number of points were emphasized in those presentations. NUPLEX would like NRC to publish a license renewal policy, regulations, and licensing guidance by the early 1990s se that a pilot application for license renewal ;
could be prepared, submitted and acted on by the mid-1990s. A three tiered' 1 approach to establish a license renewal process is recomended. The first tier j is to establish policy.- The second tier is to develop and/or modify regulations. l The third tier is to provide guidance to licensees on the contents of a license renewal application. Technical end legal studies have resulted in the emergence of two basic themes which NUPLEX believes should guide license renewal policy l development. The first is the " continuity" theme.
" Extending plant life beyond 40 years is a reaffirmation of the ongoing and continuous process of hardware renewal that is an .
integral part of every nuclear power plants operating program...
The practices of focusing on specific degradation mechanisms and establishing criteria to assure continued safety of the public is thus already an established policy at the NRC. License renewal can be viewed as a continuation of this policy, and an opportunity to oversee its overall application to be sure nothing has been missed."
The second theme is that of " extent licensing basis."
" Based on the overall safety record of nuclear. power plants during their initial terms, it does not seen appropriate for NRC to include new criteria in the safety evaluation of individual components or structures for. license renewal. It is recomended that the overall comission policy be established on this premise."
With regard to timing considerations a certain degree of flexibility is desired. Utilities may want license renewal assurance as much as 10 years in advance of license ex)f ration. Two approaches to the effective date of a renewed license have seen suggested. A " tack on" license would become effective at the expiration of the original operating license. A
" supersession" license would become effective whenever the NRC made a
determination on relicensability of a plant and would imediately replace the existing license. It is also proposed that there be flexibility in'the term of i renewed licenses. Some utilities may want to operate'a plant only several i years beyond the original 40 year license. Others may want to operate an d additional 20 or even 30 years. With regard to hearings, NUPLEX proposes that an approach resembling that of a license amendment be used. Hearings would be held only after a favorable determination on license renewal is made, and only 3 if a hearing is requested, and would be focused only on contentions admitted. 1 Relative to National Environmental Policy Act considerations, NUPLEX concluded that a programmatic environmental impact statement is neither called for nor '
appropriate for license renewal rulemaking; and that an environmental assessmert rather than the more comprehensive in-depth environmental impact statement is required. If significant environmental impacts are identified in the environmental assessment, then a full blown environmental impact statement would be developed. J l
In summary, the key elements of NUPLEX's position are-
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- Renewal process deals with a known entity !
Focus on age-related degradation of safety-related equipment
- Maintenance of the existing levels of safety ;
- Maintenance of the existing license / design basis 1
- Flexibility needed
- Environmental assessments are adequate !
Process should look like an amendment l 1
P0i. ICY AND TECHNICAL ISSUES IN LICENSE RENEWAL POLICY DEVELOPMENT The staff and its contractor are currently in the proceIs of defining policy j l and technical issues which must be addressed in developing a license renewal ]
policy, regulations and licensing guidance documents. The initial effort will ;
be concluded in the next several months, but the process of refinement and ;
identification of further issues will continue throughout the program. The i following issues are some of the more important ones identified so far. Some of them are the same as those raised in the AIF/NESP report " Regulatory Considerations for Extending to Life of Nuclear Power Plants" and by NUPLEX, and some have also been raised in public comments by others.
Policy Issues
- Does the renewed license have to be a completely new one or,can it be essentially an amendment to the origin 41 license? ;
- To what extent can and should the license renewal process resemble the present process for granting an operating license or the present license amendment process?
- What should trigger public hearings, at what point in the process should they take place, and what kind of hearings should be granted?
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- Is a programmatic environmental. impact rtatement required for rulemakings j en license renewal?- 1 '.
- On a case-by-case basis, is an environmental assessment adequate or will -l a full-blown environmental impact statement be required?- q
- How far in' advance of license expiration'(if,at all) should the NRC .
give a qualified approval for. the license renewal? What should belthe- !
substance of the qualification? 1
- How far in advance.of license expiration ~ (if at'all);should a utility -
be' required to submit 'a license . renewal application? ]
What should be the term of a renewed license? Should r,pplicantt be
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- I given flexibility to request different tems? - !
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- Should renewed licenses require that licensees meet all regulations and.
licensing guidance' existing at the. time of license renewal, or.is' it sufficient to require only that licensees meet theiregulations and 1 licensing guidance which were required in the original licensing of the- o plant plus subsequent addition and changes during the life.of the' plant?' -]
- 'To what extent if any, should. license renewal be divorced 'from or.-
covered by the backfit rule?
- What role, if any, should the safety goal play in license renewal a criteria?
- What weight should be given to' management performance and the physical condition of the plant when considering license renewal?'
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- Does license renewal in any way change emergency planning requirements? .
- How should decommissioning be accommodated in the context of license renewal?- -
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- How should the increasing inventory of high level' waste be accommodated? !
Should renewal policy development and " national" disposal policy be i linked? !
- What are the Price-Anderson implications of ' interim operation during the review of renewal applications?'
Technical Issues q
- What components, systems and~ structures should be the focus of license-renewal evaluation? Should the focus be only'on those subject to ;
age-related degradation?- J
- What evaluation methods should be applied to these components, systems and structures?
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- What role should operational performance play in the license renewal'-
evaluation? How will variance in the quality of- operating.rdcords be-accommodated?
- What was the' original design life of c'omponents, systems and structures )
and how should that-information,'or lack of it, be accommodated in the 1 1
license renewal evaluation?
- To what extent should probabilistic risk assessment be used in the license renewal evaluation?
POLICY OPTIONS The staff plans to send to the Commission a paper discussing policy. options for license renewal in the fall of 1987. This paper will provide the basis for-requesting public comment and involving interested parties in the development of a proposed ifcense renewal policy.' Although ~a policy option of no license. I renewal was identified in the previous set of public comments, the staff is ;
proceeding on the assumption that a viable license renewal policy and. 1 regulations can be developed. Several examples of policy options which are- l being examined follow. !
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- Require utilities to meet all licensing criteria. applicable to their .
plants that exist at the time of applying for license renewal. i 1
- Require a review modeled on the Integrated Safety Assessment Program j (ISAP). j
- Require a review based on a detailed, thorough probabilistic risk ;
assessment (PRA), n,odified to accomodate time as a variable, to show that a plant will meet safety goals.
- Put emphasis on required enhancements in maintenance, surveillance, and replacement programs to ensure age-related degradation is minimized. 1
- Do nothing differently in regulating the plant. Continue the sac regulatory approach beyond the original 40-year license. '
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- ENCLOSURE 2 j 4 1 I
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SUMMARY
OF PUBLIC COMMENTS ON. l THE DEVELOPMENT OF A LICENSE RENEWAL POLICY .]
FOR~ NUCLEAR POWER PLANTS '!
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May'1987 a
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The MITRE Corporation 7525 Colshire Drive McLean, Virginia 22102 l l
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SUMMARY
OF'PUBLIC COMMENTS
'ON-THE DEVELOPMENT OF A LICENSE' RENEWAL POLICY FOR.. NUCLEAR;P0FER PLANTS 1 ,
- 1.0 IgISODUCTION L
The United States' Nuclear Regulatory Commission'(NRC) is developing a:
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l policy and regulations'for the renewal of operating licenses (OL) for-nuclear power plants beyond their present 40-year term. In support ofl this policy development' initiative, the NRC has solicited comments from the public on various issues;that;will. require timely: resolution in the-policy development process. The solicitation ofLcomments'was published in the Federal Remister-(51 FR 40334) on 6 November,1986, and thecextended -
comment period closed on 2 February, 1987; Fifty-eight,(58) written responses were received and docketed by NRC' ;
under Proposed Rule PR-50. Comments were provided~from a, cross.section of j the U.S. electric' utility industry, public interest groups, private .
citizens, independent consultants, ' and agencies of government. . Table'1 summarizes the number of respondents in each of five' general' categories, q and Attachment A is a. listing of respondents by category. q 2.0 NATURE OF RESPONSES As evidenced in Table 1, the majority of responses were received from a the nuclear power industry (74 percent)' In general, the industry concensus was represented by the Atomic Industrial Forum (AIF) and the Nuclear Plant Life Extension (NUPLEX) Steering' Committee, which provided 3 detailed responses. Over half of the industry respondents stated their '
j support of the AIF and NUPLEX positions, with little or no additional commentary. On some questions, however,~ individual: industry respondents .!
expressed other viewpoints on such issues as the scope and use of plant performance historical data in license: renewals, the extent to which risk <
assessment should be used in identifying aging-related safety concerns, '
and the durations of license renewal periods.
Non-industry perspectives were limited:-' government agencies, public interest groups, individuals', and independent' consultants comprised only g~ slightly more than one quarter of the respondents. The three government-agencies providing comments were: the U.S. Department ' of Energy, the U.S.'
Department of the Interior (U.S. Geological Survey), and: the' State. of Wisconsin'Public Service Commission. The' Department of Energy response closely paralleled the industry position as stated in the NUPLEX comments.-
The Geological Survey provided a brief statement on 'the need to update groundwater data and uses around nuclear' plants for license rtnewals,'and the-Wisconsin Public Service Commission provided detailed' responses to'-
several of the 'NRC Solicitation questions. Two public interest groups 1
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TABLE 1 SUMNMRY OF RESPONDENTS AND AFFILIATIONS .
NRC Request for Public_ Comments on Nuclear Power
. Plant License Renewal Respondent Category Number.
e Private Citizens 7 o Public Interest Groups 2 e Government Agencies
- Federal Government 2
- Public Utility Commissions (State) 1 o Independent Consultants 3 ..
e Nuclear Power Industry !
Nuclear Utilities / Parent Companies 31 (
Industry Groups (AIF, NUPLEX) 2 NSSS Vendors 2 Owners Groups 2 Industry / Society Codes &
Standards Committees 2 A/E Constructors 2 Law Firms Representing Utility Companies 2 Total '58 Respondents 1
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- 1 provided written comments. One, Ecology Alert, stated its' opposition to licerse renewal, and the other group, Ohio Citizens for Responsible Energy.
'.0LRE).provided detailed comments. In general, OCRE supported the concept of license renewal, but. advocated a cautious approach onLtimin's,
. technical, and procedural issues. Of the tan individuals commenting, six were opposed to license renewal, while.the others' clearly favored renewal, or-provided responses to specific. questions without expressing an overall' position on renewal. I l
3.0 ' DETAILED RESPONSES TO THE NRC' 50 LICITATION The NRC Solicitation was. comprised'of 21 questions under seveni i general issue headings ( Attachment B). The following subsections !
summarize'the detailed' responses received in'ench of.the seven issue categories,' ar.d ~ Attachment C' is a tabulation of the response summaries.-
- 1. Timeliness of Poliev. The concensus et those favoring license renewal'(including non-industry respondents) wasLthat NRC should-proceed immediately to. establish a' renewal policy by the late 1980's and detailed regulations by the early.1990's'(1993). 'One .
utility industry respondent stated that NRC need only' affirm a licensing policy based on the existing' amendment process.' Eight utilities' stated their intent to apply.for renewals; the _
remaining industry respondents were awaiting NRC regulations and-results.cf aging research studies.
- 2. Timina and Lenath of Licensa Extension Reauests. Industry responses on the issue of renewal application timing favor maximum flexibility: filing of' applications should be allowed at any time up to one year before license expiration. Non-industry-respondents felt that applications should be required "well in.
advance" of expiration; additional comments included a five year minimum to allow for " adequate public involvement" in the renewal process, and a three-year " probationary" period'before renewals.
Concerning the question of " sufficiency" of renewal applications, !
industry respondents stated that NRC regulations should determine j requirements for the application, but that'the ' focus of.the application should be limited to aging of plent safety' items.
The single public interest group (OCRE) commented that sufficiency should entail a full-scope review (using'SRP methodology), comparable'to that given for the original operating license. ,
a on the. question of interim, or post expiration,' oper'ation .during renewal review, industry' cited theLAdministrative Procedures Act for continuance of a licensed-activity, and'that' safe operation 1 i
.was assured through routine'NRC inspection and. enforcement.
- Non-industry viewpoints included OCRE, which stated that a
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. l two-year maximum should be imposed to avoid " frustration and delay" of the renewal process. An individual respondent raised !
the issues of legality of interim operation and Price,-Anderson I implications of " unlicensed" operation.
- 3. Accentable Level of Plant Safety. There was a concensus among all respondents that previous plant performance data and risk I assessment should be considered in the renewal process.
Differences arose in the scope and degree of application. Among industry respondents, most felt that performance history should be limited to demonstrating conformance with the original license requirements, and that new performance-b-ased criteria be strictly limited to evaluation of safety-significant aging effects.
However, a few industry respondents commented that the. full 25-30 year performance history be considered and that management and personnel factors be included.
Comments on the use of risk assessment (PRA) were in general agreement among both industry and non-industry respondents: it should be used as an " adjunct" to screen plant items for safety significance of eging only. Seversi commenters also raised the issue of data validity in qualifying PRA value.
On the question of conformance to regulations in effect on the date of renewal application, industry and wen-industry viewpoints contrasted sharply. 7ndustry respondents strongly felt that satisfaction of the original licensing basis should be the major concern and that any new requirements be subject to backfit considerations. Non-industry commenters (OCRE and one individual) felt that plants should be required to meet all regulations in place at the time of renewal application.
Concerning the consideration of extended plant life in generic backfit decisions, all respondents commented that this should not be a factor until renewal applications have been filed: that
" intent" is impossible to determine in advance.
- 4. Scone of Plant Life Extensions. On the issue of license renewal durations, industry supported maximum flexibility: renewal duration should be chosen by the licensee for any period up to a 40-year maximum. Of the two non-industry respondents, OCRE stated that renewals should be for a maximum of 10-15 years, and a single individual stated that the licensee should choose the duration.
Concerning the nature of requirements for renewals and their possible dependence on duration,' industry representatives affirmed the position of conformance with the licensing basis as the major criterion, and that thin should not vary substantially 4
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. I with renewal duration. Non-industry viewpoints ranged.from "all ]
NRC' licensing criteria'are appropriate" (OCRE) to "no major new 4 investigations" (Wisconsin Public Service Comm.). In addition, j OCRE stated that technical standards for renewals she'uld be j driven by results of aging research. J
- 5. Technical Considerations for Plant Life Extension. The industry concensus on technical considerations was that: (1) only " safety I significant" plant items subject to aging effects should be reviewed, (2) that any parameters and criteria applied be limited to evaluating operating license compliance, (3) that adequate :
plant monitoring and maintenance programs addressing aging effects were already in place, and (4) that existing codes and j
l standards were generally adequate'and aging-rtlated revisions (
should be limited in scope and determined by' aging research ]
results. Non-industry respondents commented that further aging 1 studies were needed to identify technical requirements for l
renewals and that establishment of requirements was premature at this time.
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( On the question of aging research coordination, industry favored I I early coordination and information transfer with the NRC. The i single non-industry commenter (OCRE) expressed the need'for NRC !
l to adequately fund independent.research to avoid a potential industry bias in researc.h results.
- 6. Schedule for Resolution of Issq13 Industry respondents commented that NRC should: (1) issue a final policy on renewals by 1988, (2) issue LNfinitive guidance by 1993, and (3) complete review of the first t ' eval by 1995. One non-industry respondent (OCRE) stated that all issues should be resolved five years before the first license expiration, and another individual I stated that setting a schedule was premature, and that aging l
studies should drive the policy development schedule.
- 7. Erpeedural considerations. Two sets of recommendations were '
i provided one from industry, and one from a public interest l group (OCRE). Industry's position was that major changes were not required in the current body of regulations, and that NRC need only affirm certain aspects of its current, procedures for license renewals:
e Utilize the license amendment process e Consider only aging degradation of safety significant items e Licensee to choose " tack-on" or " supersession" renewal 5
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' 1 e Environmental Assessments to determine need for Impact Statements >
e Significant hazards' determination to decide need or public hearings e Filing deadline to be one year before: operating license expiration OCRE provided the following procedural recommendations:
e Treat renewals in the same manner as the original operating license (FSAR, GRP's) e Resolve apparant conflict between the Administrative l' Proceduren Act and Atomic Energy' Act on continuing a licensed activity during " renewal review" versus "no significant hazard" finding e Authorize Atomic Safety and Licensing Boards to call their own witnesses and raise significant safety issues e Allow reopening of hearings after initial decisions e Abolish limitations on " discovery and subpoena" against NRC staff and consultants e Repeal Backfit Rule 4.0 FURTHER ISSUES Other issues raised in the Public Comments were: <
Decommissioning: How should decommissioning be accommodated in the context of license renewal?
High-Level Waste: How should the increasing inventory of high level waste be accommodated? Should renewal policy development and
" national" disposal policy be linked?
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Interim Operation: What are the Price-Anderson implications of interim operation during the review of. renewal applications?
Public Interent Groups: Should " interveners" be provided with public funding to allow equal access to expert witnesses in licensing proceedings?
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ATTACHMENT A l
'l LIST OF RESPONDENTS BY CATEGORY i
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i LIST OF RESPONDENTS BY. CATEGORY' i
Private' Citizens l
. George A. Rubano, Sound' Beach, New York l Evelyn Rubano, Sound Beach, New: York
' Royal S. Graves,. Hartford, Connecticut Anthony Fuoer. .
Marvin Lewis, Philadelphia, Pennsylvania- <
Dorothy Klee, Levittown, New York Phyllis H.,Porritt, Simsbury, Connecticut .i
! Independent Consultants:
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,I David Marcus, Berkeley', California !
J.B. Gardner, Bethany/ Connecticut i William A. Johnson Associates, Woodside, California '
i Government 1
U.S.-Geological < Survey (J.F. Devine)
U.S. Depar,,trefnt of Energy (A. David Rossin) .
Sta,t,3 of'91sconsin Public Service Commission (Jacqueline K. Reynolds) ,
1ndustry Pennsylvania Power & Light Co.
l Baltimore Gas & Electric Co. '
Babcock & Wilecx Georgia Power Co. '
Babcock & Wilcox Owners Group Bechtel Western Power Corp.
Wisconsin-Electric Power Co.
Yankee Atomic Electric Co.
I Northern States. Power Co.
Public Service of New Hampshire Atomic Industrial Forum, Inc.
Commonwealth Edison Co, Combustion Engineering, Inc.
i Northeast Utilities i Nebraska Public Power District
. Detroit Edison Co.- i Washington Public Power Supply System Long Island Lighting Co.
Sargent & Lundy Engineers Rochester Gas & Electric Corp.
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LIST OF RESPONDENTS BY CATEGORY 4
Industry (Concluded) , ,
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i Carolina Power & Light Co.
Snell & Wilmer (Law Offices)
Philadelphia Electric:Co.
Consumers Power Co.
South Carolina Electric & Gas Co. I Virginia Electric h Power'Co.
Consolidated Edison Co. of New York, Inc. '!
Duke' Power Co. .
O Pacific Gas of Electric Co. '
GPU. Nuclear Portland General Electric Co. '
Florida Power / Corp. I Illinois Power Co. {
Westinghouse Owners Group. 'I Iowa Electric Light & Power Co.
Florida Power & Light Co.
l Bishop, Liberman, Cook, Purreell & Reynolds (Law Offices) !
New York Power Authority Houston Lighting & Power Co.
IEEE Power Engineering Society, Nuclear Power Engineering Committee' Middle South Utilities, Inc.
Nuclear Plant Life Extension Steering Committee ASMI, Codes and Standards e
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ATTACHMENT B 1
LIST OF QUESTIONS FROM THE NRC SOLICITATION OF PUBLIC COMMENTS 1
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o LIST OF QUESTIONS;FROM'THE' NRC SOLICITATION OF PUBLIC COMKENTS
- 1. Timeliness of Poliev ,
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't (a) To what extent should the NRC proceed at-this time in defining the regulatory policy which would be applicable to requests by .
utilities to extend the operational life of comme'rcial light-water power reactors beyond the current forty-year operating license period?
(b). Is an effort by the Commission to formulate such a policy well in advance of the expiration of operating licenses appropriate? '
(c) When must such a policy be.in place? What is the basis for this time?
(d). To what extent are the individual reactor licensees or industry groups acting on behalf of licensees actively ~ planning at this time to request NRC permission for extended operation beyond the expiration of power reactor licenses?
- 2. Timina and Length of License Extension'Recuests
- j (a) What criteria should be applied to judge that a request for license extension is both timely and sufficient?
(b) Current regulations do not define a time limit beyond the initial 40 year term for which plants could operate ~while being considered for license extension. Should'there be such a limitation? If so, what should the limiting period beyond the 40 year term be during which a plant could continue operation while undergoing license extension review?
- 3. Accentable Level of Plant Safety (a) In addition to NRC's current requirements, how should the NRC incorporate performance based information coupled with insights derived from probabilistic risk assessment into the decision making process?
(b) Should plants applying for life extension be required to demonstate conformance to regulations in effect on the date of the extension application? On what basis should a licensee not have to. demonstrate continued conformance with applicable rules and regulations B-1 l
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(c) Should the intent to operate in excess of a forty-year operating period be factored into current and future benefit / cost analyses and safety findings for backfitting considerations? I If not, why not?
- 4. Scone of Plant Life Extension Aeolications (a) Should a life-extension application be for a specific period of time? If so, for what length should it be? Should the Commission specify varying requirements based on the period requested for life extension?
(b) Which, if any, of.NRC's licensing criteria are not appropriate for the purpose of reviewing plant life extension requests?
l (c) How and to what extent should the prior operating history of the plant be factored into considerations for license extensions?
l 5. Technical Considerations for plant Life Extension
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{ (a) Which components and structures will require residual lifetime evaluations in consideration for license ettensions? What are the criteria for the selection of these components and structures?
(b) What are the major technical parameters and criteria which should be considered in NRC reviews to permit power reactor operation beyond the expiration of licenses? !
(c) What additional monitoring and maintenance programs will be needed to assure safety during extended life?
I (d) Which of these technical factors, including degradation i
processes and methods for detecting such degradation, are major 1
) "leadtime" items requiring data accumulation over the years l prior to expiration of power reactor licenses? l (e) How should codes and standards be revised to support license extension?
l (f) What investigations and research have been or are going on that address nuclear plant life extension? What mechanisms should be established to assure timely information exchange with the NRC ;
i to encourage communication, early consideration and avoid
! duplication?
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- 6. Schedule for Resolution of Issues- -l 6
l (a) What overal1~ schedule is appropriate to achieve majok milestones 1 and for resolution of the issues relative to nuclear plant license extension?
- 7. Procedural Considerations j (a) -Should there be any procedural changes regarding future '
operating license extensions and current treatment of initial l operating license applications? If so, what changes should be .
made? i l
(b) Please be as specific as possible, e.g., identify the specific J l
i- procedural requirement.and. describe'how it should~be changed; '
identify whather such change can be accomplished under the a current provisions of applicable statutes or whether it would i involve a statutory change.
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ATTACHMENT C '!
1
SUMMARY
OF PUBLIC COMMENTS i
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