1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 *** 4 BRIEFING ON STATUS OF LICENSE RENEWAL 5 *** 6 PUBLIC MEETING 7 *** 8 Nuclear Regulatory Commission 9 Commission Hearing Room 10 11555 Rockville Pike 11 Rockville, Maryland 12 13 Thursday, June 12, 1997 14 15 The Commission met in open session, pursuant to 16 notice, at 9:35 a.m., the Honorable SHIRLEY A. JACKSON, 17 Chairman of the Commission, presiding. 18 19 COMMISSIONERS PRESENT: 20 SHIRLEY A. JACKSON, Chairman of the Commission 21 KENNETH C. ROGERS, Member of the Commission 22 GRETA J. DICUS, Member of the Commission 23 EDWARD McGAFFIGAN, JR., Member of the Commission 24 NILS J. DIAZ, Member of the Commission 25 . 2 1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE: 2 KAREN D. CYR, General Counsel 3 JOHN C. HOYLE, Secretary 4 JOSEPH CALLAN, EDO 5 SAM COLLINS, Director, NRR 6 MARYLEE SLOSSON, Acting Director, Division of 7 Reactor Program Management, NRR 8 DAVID MATTHEWS, Chief, Generic Issues and 9 Environmental Projects Branch, NRR 10 STEPHEN HOFFMAN, SR., Project Manager, License 11 Renewal Directorate, NRR 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . 3 1 P R O C E E D I N G S 2 [1:33 p.m.] 3 CHAIRMAN JACKSON: Good afternoon. I don't 4 usually name names, but good afternoon, Marylee, Steve, Joe, 5 Sam, and Dave. 6 The purpose of today's meeting between the 7 Commission and the NRC staff is to discuss the status of 8 activities associated with the implementation of the license 9 renewal rule for nuclear powerplants, which is 10 CFR Part 10 54. 11 Since the original license renewal rule was issued 12 in December of 1991, the staff and the nuclear power 13 industry have been working to implement the requirements of 14 the rule effectively. After about two years of experience 15 with activities related to implementing the rule, the staff 16 and the nuclear power industry identified several key issues 17 that needed to be resolved in order to provide a more stable 18 and predictable regulatory process for license renewal. 19 In February 1994 the Commission directed the staff 20 to proceed with rulemaking to amend 10 CFR Part 54, and in 21 May 1995 a revised license renewal rule was published. The 22 revised rule focused on the management of the effects of 23 aging on certain systems, structures, and components during 24 the period of extended operation. Since the revised rule 25 was published in 1995 the staff and the nuclear power . 4 1 industry have continued to work on acceptable strategies and 2 guidance to implement the requirements of the rule 3 effectively. In SECY 97-118, entitled "Activities 4 Associated with the Implementation of 10 CFR Part 54," the 5 staff has provided the Commission with an update on the 6 status of ongoing staff and industry initiatives associated 7 with the license renewal rule. 8 The Commission therefore looks forward to the 9 discussion with our staff on license renewal activities. In 10 particular, the Commission is interested in first 11 understanding what if any potential policy issues might 12 require Commission decision, and, second, understanding how 13 all the ongoing activities associated with, for example, 14 regulatory guide development, standard review plan 15 development, the license renewal demonstration program, 16 industry report template development, will all coalesce into 17 timely, clear, and coherent implementation guidance. 18 Now I understand that copies of your presentation 19 are available at the entrances to the meeting, and so unless 20 my fellow Commissioners have any opening comments, Mr. 21 Callan, please proceed. 22 MR. CALLAN: Well, Chairman, you covered all the 23 points I was going to make at the outset. 24 CHAIRMAN JACKSON: Good. We'll go on the next 25 person. . 5 1 MR. CALLAN: In fact, you even identified 2 everybody at the table. 3 [Laughter.] 4 But I'll go through it again and provide their 5 full names and their titles. 6 Once again, Sam Collins; he's the Director of NRR. 7 Marylee Slosson, the Acting Director of the Division of 8 Reactor Program Management. Dave Matthews, the Project 9 Director of the Generic Issues and Environmental Projects 10 Branch. And then finally Steve Hoffman, the Senior Project 11 Manager in the License Renewal Project Directorate. 12 Marylee Slosson will begin the presentation for 13 the staff. 14 MS. SLOSSON: Thank you. 15 Good afternoon. I'm going to go ahead and start 16 with the second slide, because the Chairman very aptly went 17 through the kind of the history and brief summary of the 18 license renewal a little, but I was going to go through, so 19 if we could go ahead and have the second slide, with the 20 license renewal program as with any program, the program is 21 developed on key principles. 22 In the case of license renewal, the two principles 23 on which the staff has proceeded are based on some 24 significant Commission determinations during the rulemaking 25 process as outlined on this slide. The first principle of . 6 1 license renewal is that with the possible exception of the 2 detrimental effects of aging on the functionality of certain 3 plant systems, structures, and components in the period of 4 extended operation, and possibly a few other issues related 5 to safety only during the extended period of operation, the 6 regulatory process is adequate to ensure that the licensing 7 basis of all currently operating plants provides and 8 maintains an acceptable level of safety so that operation 9 will not be inimical to public health and safety or common 10 defense and security. 11 The second principle of license renewal is that 12 the licensing basis must be maintained in the same manner 13 and to the same extent during the period of extended 14 operation as it was during the original licensing term. 15 Issues that may arise relevant to current plan operation 16 must be addressed as part of the current plant license and 17 cannot be deferred to a renewal review. For example, the 18 issues that have resulted from Millstone and Maine Yankee 19 lessons-learned reviews related to 10 CFR 5059, licensing, 20 and design bases are being addressed as part of the 21 operating reactors program. Any process improvements that 22 are realized as a result of the lessons-learned initiatives 23 will carry forward into the renewal term. Therefore, this 24 approach fully supports the principles upon which license 25 renewal is based. . 7 1 If I can have the third slide, please. 2 We'd now like to begin the status portion of 3 today's briefing, during which we'll discuss ongoing 4 industry and staff activities and plant-specific and owners 5 groups areas. We'll also discuss development of 6 implementation guidance, environmental activities, and our 7 planned future activities. If there are not any questions 8 at this time I'd like to turn the presentation over to Mr. 9 Stephen Hoffman. 10 CHAIRMAN JACKSON: Before you go -- 11 [Laughter.] 12 So given what you were just saying about the 13 licensing basis issues coming out of the various initiatives 14 that are already under way, would you say that given what we 15 already are doing that there's nothing in our recent 16 regulatory experiences since the Commission laid out these 17 principles that have caused us to reexamine the adequacy of 18 those principles? 19 MS. SLOSSON: That's right, I don't believe within 20 any of the Millstone lessons-learned issues we've identified 21 anything. 22 CHAIRMAN JACKSON: Okay. And then the second 23 question is whether you can give us some sense in the 24 aggregate of whether industry interest in pursuing license 25 renewal has decreased, remained the same, or increased as a . 8 1 consequence of the economic deregulation and restructuring 2 in the industry, and a related question is I notice that the 3 CE owners group appears to be the only owners group not 4 sponsoring a license renewal effort, and do you know if they 5 plan to do so, and are they supportive of the BG&E license 6 renewal effort? 7 There are only five questions. 8 MS. SLOSSON: Only five questions to answer. 9 I guess with respect to economic deregulation I 10 think it's -- 11 CHAIRMAN JACKSON: Let's leave it -- let's just 12 put it in a more neutral tone. 13 Have you noticed any change over the last year, 14 couple of years in terms of any waning or increase of 15 interest in the license renewal area in an active way? 16 MS. SLOSSON: Do you want to -- 17 MR. HOFFMAN: I'd say generally it's stayed the 18 same or maybe we've actually gotten a little more certain 19 interest from licensees in the process. 20 CHAIRMAN JACKSON: What about the question related 21 to the CE owners group activities? 22 MR. HOFFMAN: They have not approached us as to 23 any intent to submit anything with the staff. I think they 24 are letting BG&E take the lead. 25 CHAIRMAN JACKSON: Are they providing support for . 9 1 that effort? 2 MR. HOFFMAN: That I can't answer. 3 CHAIRMAN JACKSON: Okay. Thanks. 4 MS. SLOSSON: All right, Steve, if you can go 5 through the status. 6 MR. HOFFMAN: All right. Industry approach to 7 date for license renewal has been to actually submit 8 technical reports and methodologies for staff review and 9 approval in advance of actually submitting a formal 10 application. The intent is that, and it's allowed by the 11 rules, that once they obtain this approval, they could 12 incorporate by reference these reports that have been 13 accepted by the staff. This gives them better information 14 on which to decide whether to continue operation after the 15 current license term and give them some idea as to the cost 16 of the aging management programs. 17 As was indicated in the previous slide, we've got 18 two licensees that are three owners groups that have been 19 preparing reports and submitting them to the staff. Other 20 licensees we are aware of have also been active supporting 21 the owners groups activities as well as the NEI generic 22 effort like on the Reg Guide, but we've gotten no formal 23 indication from them as to, you know, planned submittals at 24 this time. 25 The slide on BG&E, please. . 10 1 Baltimore Gas & Electric has been active since 2 practically 1990 in license renewal. They incorporated 3 license renewal as part of their life-cycle management for 4 program for Calvert Cliffs. Although no decision has been 5 made yet to submit an application by BG&E, they currently 6 expect to complete preparation of their application by fall 7 of 1997. So it will be ready. They actually made their 8 first submittal back in 1993 with their methodology for 9 performing the integrated plan assessment. We were 10 reviewing that when the staff decided to go back and amend 11 the rule. After the rule was issued they revised that 12 methodology, resubmitted it, and we have reviewed it and 13 found it acceptable in a final staff safety evaluation 14 report. BG&E's approach has been to prepare the reports for 15 the systems structures and in some cases major components 16 such as the vessel internals that they handle in separate 17 reports. 18 As part of a demonstration program for the Reg 19 Guide, which I'll talk about a little bit more later on, the 20 staff was on site, and we looked at some of the reports that 21 they were preparing, and we found that in a number of areas 22 they contained sufficient information for the staff to begin 23 its technical review and submit it, but there was some 24 concern in a couple areas as to whether or not there was 25 enough detail there. . 11 1 In response BG&E agreed to prepare a formal and 2 content template, and between May of '96 and January of this 3 year the staff and BG&E worked to review that report and to 4 resolve implementation issues based on some examples they 5 used to implement that. We concluded that if that template 6 is properly implemented, the reports that are prepared on 7 that and submitted to the staff should have sufficient 8 information for us to begin our renewal review. 9 In parallel with that template review they asked 10 and we agreed, they actually submitted five technical 11 reports and asked for us to review them in the area that we 12 did not have any concerns identified as part of the 13 demonstration program. That review is going on. We have 14 issued a request for information and they're responding. 15 End of May we just received four new reports. 16 These were prepared using the template and we've just begun 17 our review on that. 18 Their plan is to submit a total of 28 technical 19 reports by fall of this year, which will constitute pretty 20 much the technical portion of a renewal application. 21 CHAIRMAN JACKSON: Let me ask you this question, 22 can you give us some sense of what level of staff resources 23 and over what time frame will be necessary to complete the 24 review of the BG&E technical reports? Have you been able to 25 consider that? I don't know who wants to answer that. . 12 1 MS. SLOSSON: I will answer that. 2 We anticipate that the review of the reports will 3 be completed by the end of 1999 if we get them on the 4 schedule as indicated. And our level of effort for license 5 renewal for '98 is approximately 20 FTE and $900,000 and, in 6 '99, approximately 25 FTE and a million dollars for review 7 of those reports. 8 CHAIRMAN JACKSON: Let me ask you the next 9 question. And this has to do, really, with kind of 10 stability of the regulatory framework. So that is the 11 context in which I am asking this question. And it may be a 12 bit early to address it and, if it is, you know, tell me and 13 then I'll ask you, you know, in another meeting or in 14 another way, can you discuss the relationship 15 between -- which you have said the staff has basically 16 approved between the BG&E report template, NEI guidance 17 91-10, which has been, I guess, reg guide endorsed, and the 18 draft license renewal standard review plan? 19 You know, there is a NUREG 1568, owners groups 20 topical reports and the plant-specific application. Now, 21 that's a lot. 22 But I guess, you know, and I'm not asking you 23 necessarily to go through each one chapter and verse but I 24 want to understand the sense in which these things are all 25 consistent or not consistent so that we are not in a . 13 1 position where things get approved and then a standard 2 review plan or some other guidance comes along that is a 3 little different, et cetera, et cetera, because our staff 4 needs to know what they are going to review against and the 5 industry needs to know going forward beyond BG&E's template 6 is that going to be the game? You know, what it is they are 7 going to be reviewed against? 8 MR. HOFFMAN: Okay, if I leave anything out let me 9 know. 10 Regarding BG&E's template, BG&E actually was 11 further along when we started the reg guide in review of NEI 12 95-10, so their template, their methodology is more plant 13 specific, it is equivalent to the staff is making sure that 14 what is in their approach is consistent with what we are 15 doing with 95-10. 16 As far as the various documents, they all really 17 are interrelated. You know, if we are looking at something 18 on an owners group report or for BG&E, it turns out it is 19 also typically coming up like in the review of NEI 95-10 or 20 it's an area that we are looking at for incorporating the 21 guidance in the SRP. So as we go through this, the rest of 22 the presentation, you are going to see there are a lot of 23 activities going on and we are trying to pull it all 24 together at the same time to come up with consistent 25 guidance that will be of use to both the staff and the . 14 1 industry. 2 CHAIRMAN JACKSON: Right, and it is important that 3 they are all knit together, so that you are not all doing 4 this one and then the next guy, you know, you tell him to 5 bring you his rock and you're going to review it against 6 some separate criteria and that's what the concern is. 7 MS. SLOSSON: And the first two review cycles that 8 we are going through are very, very important because they 9 do provide us with specific issues that we are using to 10 develop that guidance that will be used generically. 11 CHAIRMAN JACKSON: So it is almost like a pilot? 12 MS. SLOSSON: It is very similar to a pilot. 13 CHAIRMAN JACKSON: All right. 14 MS. SLOSSON: And the resource numbers I gave you 15 were for the entire license renewal, it wasn't just for 16 BG&E. 17 CHAIRMAN JACKSON: I see. Okay. 18 MS. SLOSSON: That was a total effort. But I 19 wanted to clarify that. 20 [Laughter.] 21 MR. CALLAN: Including environmental. 22 CHAIRMAN JACKSON: Is that right? 23 MS. SLOSSON: Right. 24 CHAIRMAN JACKSON: Okay. 25 MR. HOFFMAN: Slide five, please. . 15 1 Duke Power Company has also been very active in 2 license renewal since around early 1993, not only on 3 Oconee-specific activities but they have also been 4 supporting the NEI effort, the B&W Owners Group and 5 Westinghouse Owners Group activities. 6 Their approach is a little different than BG&E. 7 They are preparing one report with five major sections. 8 They are taking a discipline approach similar to the format 9 of the FSAR. They are going to be evaluating all of the 10 electrical instrumentation and control components in one 11 group, mechanical components, the structures and then they 12 will address the reactor building and reactor coolant 13 systems separately. 14 They have indicated that they intend to 15 incorporate by reference the topical reports that are under 16 review by the B&W Owners Group and one of the Westinghouse 17 Owners Group topicals. 18 Their goal is to complete the application and be 19 prepared for a submittal in late 1998 if the company makes 20 the decision to formally apply. They have indicated that 21 some of their considerations they are looking at besides 22 technical and environmental include the regulatory aspects, 23 the financial and the political concerns associated with 24 actually applying for renewal. 25 In July of '96, they submitted their first section . 16 1 on the reactor building. The staff looked at it and found 2 that it didn't have, in some areas, sufficient information 3 for us to begin our review. In response, they committed to 4 preparing this generic format and content document using the 5 reactor building as a guide. Kind of like the BG&E template 6 effort to establish the -- what's necessary for a report to 7 begin review. They submitted that in late '96. We reviewed 8 it. Actually went on site in January of '97 to look at some 9 of the backup documentation and how it was being implemented 10 and we found that between the document itself and some 11 commitments they made in response to comments that it should 12 provide the guidance necessary to prepare reports sufficient 13 for our review. 14 They revised the reactor building report and 15 submitted it in March of this year and we are currently 16 reviewing that. 17 The remaining four sections are scheduled to come 18 in by fall of this year with essentially complete -- there 19 may be a couple holes. But those will be finished by the 20 end of the year. And, again, that should constitute pretty 21 much the technical portion of an application. 22 CHAIRMAN JACKSON: Let me ask you this question. 23 You mentioned that Duke may incorporate by reference both 24 B&W Owners Group and Westinghouse Owners Group topical 25 reports. Are there any concerns vis-a-vis proprietary . 17 1 material? 2 MR. HOFFMAN: Not with these reports. 3 CHAIRMAN JACKSON: And the other question is, 4 would an a la carte, you know, approach be allowed where an 5 applicant can pick and choose sections of topical reports 6 and, if so, will this facilitate or complicate our reviews? 7 MR. HOFFMAN: Well, Duke has been very active in 8 the B&W Owners Group effort and so I wouldn't expect them to 9 be taking parts of the topicals. If they chose not to use 10 the entire topical, we would have to look at it more as a 11 plat-specific submittal as opposed to a preapproved approach 12 because we have discussed with the industry and it is in the 13 guideline that, if you are going to use a topical, you have 14 to show how you are enveloped and how any site-specific 15 commitments are being made before you can use it. 16 Okay, next slide. 17 Babcock & Wilcox Owners Group is active. They 18 were actually the first owners group to make a submittal. 19 They've got a generic program for five operating plants 20 which are the three Oconee units of Duke's, GPU's CMI-1 and 21 Entergy's two Arkansas units. They have submitted three of 22 the four planned component topical reports on reactor 23 coolant system piping, pressurizer and the reactor vessel. 24 Based on the review, we have already found one acceptable on 25 the final safety evaluation report. We have issued another . 18 1 draft and we are working on a second final safety evaluation 2 report and draft. We expect the final report this month on 3 the vessel internals. 4 Our review -- actually what they have indicated 5 is, in the future, after they complete the topical work, 6 they will take on the longer term generic issues that may be 7 identified in renewal as well as provide support to Duke and 8 the other licensees who may apply for renewal. 9 A review of the reports to date has been more 10 advanced on B&W than the others because they have been in 11 longer, has been that generally existing programs have been 12 sufficient. 13 We have found in some cases where enhancements 14 have been needed, say on small bore piping and augmented 15 inspection but in general the existing programs have been 16 sufficient. 17 CHAIRMAN JACKSON: Is the B&W generic license 18 renewal effort still broadly supported by the members? 19 MR. HOFFMAN: It's been supported for some time by 20 three of the five. 21 One member, Florida Power, was involved early on, 22 but our understanding is that they dropped out due to 23 financial reasons, not for lack of interest. 24 One never was involved -- Toledo Edison. 25 Westinghouse Owners Group -- their program has . 19 1 been very active too. They are preparing 15 topical reports 2 for major components and structures. The intent is to bound 3 all Westinghouse plants with the reports. 4 Their reports give the attributes of an acceptable 5 aging management program as opposed to B&W's, where with the 6 smaller population of plants they have actually made 7 commitments to specific programs. 8 They have submitted four topical reports that are 9 under review. We're preparing a draft safety evaluation 10 report on the reactor coolant system supports and the 11 remainder in various stages of requests for information and 12 responses. 13 The fifth report on the vessel internals is 14 scheduled to be submitted this month, and then they have 15 indicated that they plan to submit an additional two to 16 three reports. 17 The Boiling Water Reactor Owners Group program was 18 based on preparing topic reports for reference design. They 19 picked the BWR Mark I and an applicant that came in, if 20 there were any differences would justify those in their 21 plant-specific application. 22 They submitted the first of their six planned 23 reports on the containment in December of '95 which the 24 Staff reviewed and issued a request for additional 25 information on in February '96. That review was put on hold . 20 1 by the BWR Owners Group initially because of funding. 2 We just received a letter from them in May 3 indicating that they are going to maintain that hold on 4 their program and let the implementation issues, the process 5 issues that have been identified as part of their report 6 review and the Reg Guide, let them be resolved by the lead 7 plant reviews. 8 CHAIRMAN JACKSON: So that is all BWR Owners Group 9 license renewal activities? 10 MR. HOFFMAN: In the Owners Group, yes. 11 CHAIRMAN JACKSON: And if some of the technical 12 issues are associated with the BWR containments, how does 13 suspending action resolve those issues? 14 MR. HOFFMAN: Well, some of them deal with the 15 interpretation of the guidance, which I will get into more 16 in the Reg Guide effort and where -- what is going to be 17 necessary in an application. 18 CHAIRMAN JACKSON: Okay. 19 MR. HOFFMAN: So they are going to let the lead 20 plants take those on. 21 The regulatory guide development began in earnest 22 in May of '95 when we amended the rule. A little bit of 23 background for you. About that time Nuclear Energy 24 Institute approached us and indicated they were preparing 25 the industry guideline, NEI 95-10, and requested our review . 21 1 and endorsement if it was found acceptable. 2 We agreed to that, and there were extensive 3 interactions between August of '95 and March of '96 that 4 resulted in us preparing the draft Reg Guide that was 5 published for comment in August of '96 that proposed 6 endorsement of NEI 95-10, rev. zero. 7 During this development process, that was March to 8 August of '96, we participated in a trial application of the 9 95-10 guidance. NEI sponsored an industry demonstration 10 program in which six utilities participated. That was 11 Baltimore Gas & Electric, Duke, Southern Nuclear, Wisconsin 12 Electric, Philadelphia Electric, and Virginia Power. 13 The Staff actually sent a team out to each of the 14 licensees with the exception of Virginia Power, which chose 15 not to participate in the Staff site visit but underwent an 16 NEI-led peer review. 17 The intent was to look at, assess the adequacy of 18 the guidance and the ability of the participants to 19 implement the guidance and obviously identify any needs for 20 revision. 21 In the demonstration program the licensees used 22 the guidance to select certain system structures and 23 components and then they kind of ran it through the process 24 of doing the integrated plan assessment, evaluated time 25 limited aging analysis, and prepared sample application . 22 1 materials that the Staff reviewed. 2 Generally what we found was that the 95-10, rev. 3 zero contains the basic guidance needed to prepare an 4 application, but we did see some inconsistent application of 5 the guidance as well as some areas where improvements could 6 be made or additional clarification would avoid conflicts in 7 the future. 8 We did publish our lessons learned in a NUREG 9 Report 1568. 10 During the public comment period we also conducted 11 a public workshop to allow as much opportunity for the 12 public to be involved in this. We discussed the rule, the 13 Reg Guide and 95-10 guidance, and the demonstration program 14 lessons learned, since that was being completed towards the 15 end of the public comment period. 16 The comment period ended at the end of November of 17 '96 and we received comments from NEI, five licensees, two 18 owners groups, and the Department of Energy. No comments 19 from the general public. 20 The comments received on the Reg Guide raised some 21 issues with interpretation of the wording and some of the 22 guidance contained in the draft Reg Guide and 95-10. 23 Discussions with industry on the issues raised by 24 the comments helped establish a better understanding of the 25 differences in interpretation in some of the areas. . 23 1 Examples of some of the areas that were discussed 2 were the amount of information needed to demonstrate the 3 adequacy of existing programs being credited for aging 4 management, the amount of detail needed in an application 5 versus onsite available for Staff inspection, and the level 6 at which intended functions must be maintained and whether 7 component failure was allowed. 8 After extensive discussions with the industry, the 9 Staff now believes that the issues associated with the 10 guidance can best be resolved through trial application of 11 the draft guidance on specific structure and component 12 reviews. 13 Therefore, we have modified our approach for 14 developing the final Reg Guide and instead of issuing it 15 final in September of '97, as currently planned, we intend 16 to focus on plant-specific and owners group reviews using 17 the draft Reg Guide and the working draft standard review 18 plan for license renewal that I will talk about next to gain 19 the needed experience with implementation of the rule and 20 use that to help finalize the Reg Guide as well as the 21 standard review plan. 22 CHAIRMAN JACKSON: So then where would that track 23 you to when you think you would finalize the Reg Guide? 24 MR. HOFFMAN: What we would expect to do is 25 actually the guidance would not just sit. We would . 24 1 incorporate a lot of that guidance that has been developed 2 and is being developed into the working draft of the 3 standard review plan, which is scheduled to be updated and 4 put in the public document room in September. 5 CHAIRMAN JACKSON: How appropriate would it be to 6 incorporate or to endorse, to publish a Reg Guide that 7 endorses those portions of 95-10 that we feel are 8 appropriate and then to supplement the Reg Guide on the 9 issues that have yet to be resolved at a later date? 10 MR. HOFFMAN: We considered that, but what we are 11 seeing is the interpretation by some of the -- like the 12 commenters that there's some principles that run throughout 13 that if we did that it would get the guidance out there, but 14 we are not certain that it is really a document that the 15 industry in the majority would embrace and would feel would 16 be useful for pursuing renewal. 17 What we are finding is that we have got two 18 licensees and two owners groups that are proceeding using 19 the guidance that is available. They have indicated that 20 they don't need the Reg Guide in order to proceed. 21 Generally what we find is that when we focus on a 22 specific structure on component with a licensee or an owners 23 group that we can work through these issues and we can come 24 to agreement as to what is acceptable for an application. 25 It is when we go back up and start talking in broad terms, . 25 1 broad policy type statements that we then start debating 2 interpretations of the wording. 3 CHAIRMAN JACKSON: And that is why you are saying 4 that you want to incorporate the experience gained from 5 implementing it on plant-specific and the owners group. 6 You were going to make a comment, Sam? 7 MR. COLLINS: No. 8 CHAIRMAN JACKSON: Just showing your interest? 9 MR. COLLINS: Right. 10 CHAIRMAN JACKSON: Okay. 11 COMMISSIONER McGAFFIGAN: What would be the 12 plan -- it will be several years before you try to 13 finalize -- but there would be another round of public 14 comment at that point where you would put out a new revised 15 draft and go through a process at that point? Is that the 16 thought? 17 MR. HOFFMAN: I think we'll have to. 18 We haven't really looked at it in detail but it is 19 most likely we would. 20 We wouldn't terminate actually the process with 21 Nuclear Energy Institute. The idea is not to stop. It's 22 just to -- I think it would be better to focus our resources 23 on these lead plant reviews and finishing the owners group 24 topicals, and then continue the interaction with NEI, just 25 not on as high a priority basis. . 26 1 During the draft work we were meeting with them 2 weekly. We had -- it was a very intensive effort trying to 3 produce the final document, so we would continue the effort 4 with NEI during this time. 5 CHAIRMAN JACKSON: Okay. 6 MR. HOFFMAN: We have already covered part of 7 this. We placed -- the original draft standard review plan 8 for license renewal was issued for comment back in 1990 but 9 it was based on the '91 rule so we updated that to reflect 10 actually it was the '94 proposed rule wording and agreements 11 that were reached from -- back in that timeframe there was a 12 NUMARC initiative in which were prepared industry reports 13 that addressed aging management for some structures and 14 components. 15 The Staff had been doing a review. We 16 incorporated the agreements from that into that working 17 draft standard review plan. 18 Currently we are working on updating and expanding 19 that to capture -- there were some modifications for the 20 final '95 amended rule wording, the experience we have 21 gained from the plant and owners group reviews to date, the 22 experience from the draft Reg Guide development and also 23 some additional administrative requirements and that should 24 be in the PDR by September. 25 The current schedule is to publish the draft . 27 1 standard review plan for public comment after the review of 2 several renewal applications to allow experience to be 3 gained. 4 Next I would like to discuss two areas that we are 5 monitoring for potential effect on implementation of the 6 license renewal. 7 That is use of risk insights and maintenance rule 8 experience. 9 Regarding the use of risk insights, the Staff 10 recently received Commission approval to publish the draft 11 regulatory guides and standard review plan that provide 12 guidance for using probabilistic risk assessment and risk 13 informed decisions on plant-specific changes to the current 14 licensing basis. 15 These Reg Guides and SRPs were submitted to the 16 Commission in SECY 97-077. 17 Once issued final, licensees will be able to use 18 this guidance to make changes to its COB during the current 19 operating term, and, consistent with the principles of 20 license renewal, the regulatory process carries forward into 21 the renewal term so a renewal applicant would be able to use 22 this guidance in preparing its application as well as in the 23 renewal term. 24 Specifically for license renewal, when the amended 25 license renewal was issued, the Commission stated in the . 28 1 statement's consideration that PRA could be used by a 2 renewal applicant when assessing the relative importance of 3 a structure or component subject to an aging management 4 review and for developing the aging management program. 5 The PRA Reg Guides that were just approved for 6 issuance for draft for comment could also be used for 7 guidance for an applicant in performing these assessments. 8 We also plan to use risk insights when we develop 9 the inspection program for license renewal, which I will 10 talk about again in a minute. 11 Maintenance rule experience -- the license renewal 12 relies on existing licensee programs, in particular the 13 maintenance rule -- that was clear in the amended '95 14 rule -- to conclude that active components can be 15 generically excluded from the scope of renewal review 16 because the effects of aging are more readily detectable. 17 Although passive structures and components are 18 technically within the scope of the maintenance rule, the 19 Commission at that time believed that there was insufficient 20 experience regarding the evaluation of long-term effects of 21 aging on passive functions to be able to generically exclude 22 them from renewal review. 23 Because of this dependence on the maintenance 24 rule, license renewal staff is monitoring the implementation 25 of the maintenance rule and the baseline inspections being . 29 1 performed to determine how lessons learned from the 2 maintenance rule can best be factored into the license 3 renewal process. 4 One example of an issue identified by the 5 maintenance rule, inspections, has been the need for 6 additional guidance for monitoring the structures. That was 7 described in the maintenance rule status paper, SECY 97-055. 8 In that case license renewal staff has been 9 participating in the Staff activities to develop guidance 10 for both operating reactors as well as for the renewal term. 11 The help the exchange of information, both the 12 maintenance rule and license renewal staffs have been 13 monitoring and participating in each other's activities. 14 Maintenance rule staff was active in our development of the 15 draft Reg Guide and participated in the demonstration 16 program for the Reg Guide. 17 License renewal staff is going to be participating 18 in a maintenance rule baseline inspection, and we are 19 monitoring the results of their ongoing inspections for any 20 lessons learned. 21 Okay, Inspection Program Development. The intent 22 is to prepare a draft of the inspection program for license 23 renewal to support review of the first application. We're 24 using the ongoing dialogue with industry and the experience 25 gained from reviews of the owners group and plant-specific . 30 1 documents to help staff know where to focus its inspection 2 efforts and where there's a need for new or modified 3 programs both for the renewal review as well as on into the 4 renewal term. 5 We also like I said plan to use risk insights in 6 establishing that program, consistent with like the SRP we 7 would finalize that inspection program after we've gained 8 the experience of several renewal application reviews. 9 If there's no additional questions, I'll let Dave 10 Matthews discuss environmental. 11 MR. MATTHEWS: Good afternoon. 12 Before I present a description of the status of 13 our environmental review activities associated with license 14 renewal, I think it would be helpful to review just briefly 15 in contrast to the Part 54 rulemaking activities that there 16 was a companion rulemaking activity in the environmental 17 protection area associated with an amendment to Part 51 to 18 address license renewal. 19 Part 51 was revised finally to address license 20 renewal issues in December of 1996, just last year. That 21 rule revision was based on a generic Environmental Impact 22 Statement to address the environmental impacts attendant to 23 license renewal, which was issued in final form in May of 24 1996. In turn that GEIS was based on operating experience 25 from an environmental perspective of the 118 reactors that . 31 1 were either operating at the time or planned in 1991 when 2 this effort was undertaken. 3 The result of that rulemaking activity and GEIS 4 development focused on 92 impacts associated with license 5 renewal that related to environmental protection. Those 92 6 impacts were sorted and classified in the final rule into 7 two categories. Category 1 impacts, and there were 68 of 8 those that were dealt with by the Commission's approval in a 9 generic capacity, and 24 site-specific impacts, referred to 10 as category 2 impacts, that were to be left for 11 determination during the site-specific evaluation of the 12 environmental impacts. 13 I think it would also be helpful if I could turn 14 to background slide 6, to just briefly describe the process 15 that is outlined in part 51 for a plant-specific review. 16 And the major steps are the staff's environmental review of 17 an application. In this case we're talking the licensee's 18 environmental report. That would then result in the staff 19 issuing a site-specific supplemental Environmental Impact 20 Statement in draft form addressing those 24 issues that were 21 left to site-specific review. 22 The staff at that point following the draft and 23 the scoping process and public comment would issue a final 24 Environmental Impact Statement and would make a 25 determination of the acceptability of the license renewal . 32 1 action. At that point the responsibility turns to the 2 Commission to issue a record of decision based on that 3 Environmental Impact Statement and the staff's conclusion, 4 and the wording of that record of decision that's called for 5 in Part 51 relates to preserving the option of license 6 renewal for energy-planning decision makers. That is a 7 little different from the traditional cost-benefit balancing 8 that is usually done in environmental reviews, and that's 9 articulated in the final rule. 10 Turning back now to the status slide, which is 11 slide 12, at the time that the Commission approved for final 12 publication the revisions to Part 51 they also requested the 13 staff to address the issue of guidance associated with the 14 implementation of that rule, and the two elements of that 15 guidance and the staff responded to the Commission with a 16 schedule for these, were the environmental standard review 17 plan, which we plan to publish for public comment in August 18 1997, and we're on schedule to do that, and the hope is 19 provided the comments are such that we can resolve them 20 expeditiously, is to issue a final environmental standard 21 review plan in August of 1998. In addition a regulatory 22 guide is under preparation, with the planned schedule for 23 that of being published for public comment in July of 1997, 24 with a reg guide to be finalized in March of 1998. 25 Consistent with the approach you've just heard . 33 1 with regard to Part 54 review efforts, we have had 2 discussions and extensive interaction with Baltimore Gas & 3 Electric on a template process for the format and content of 4 an environmental report that would support an application. 5 The goal of that process was to ensure that an environmental 6 report when submitted would be considered suitable for 7 further staff review as part of an actual application. So 8 we weren't making determinations on the acceptability of the 9 material contained therein, only acceptability of its scope 10 associated with the staff's ongoing review. 11 We concluded that template process through a 12 management meeting which took place on Thursday, June 5, 13 where we provided our assessment to BG&E management that we 14 thought the process had culminated in a format and content 15 document that they had prepared that if they were to prepare 16 an environmental report along those lines it would meet that 17 requirement, namely that it would pass our acceptability 18 review. 19 We've had interactions with NEI and Duke. With 20 Duke with regard to the fact that they have under 21 preparation an environmental report to support a possible 22 application, and we've also talked with NEI with regard to 23 their desires to consider the development of guidance for 24 the industry in this area. 25 COMMISSIONER McGAFFIGAN: Does that conclude the . 34 1 environmental part? 2 CHAIRMAN JACKSON: I think so. 3 Do you have a question? 4 COMMISSIONER McGAFFIGAN: Can I ask a question? 5 CHAIRMAN JACKSON: Sure. 6 COMMISSIONER McGAFFIGAN: I've gone back and 7 looked at Part 51, and one of the issues that you've 8 mentioned in the paper before us on page 7, an area that 9 needs some clarification, and you're discussing it with 10 industry, is the generic and cumulative impacts associated 11 with transportation operation in the vicinity of a 12 high-level waste repository site. 13 That's one of these category 2 items under the 14 rule that was published. And it strikes me that sort of 15 puts people in a pretty tough situation in that it probably 16 should be dealt with generically maybe by ourselves. And so 17 how do we get ourselves out of the fix that we're probably 18 not going to deal with the generic transportation issues of 19 Yucca Mountain for a few years yet, and yet some of these 20 folks are on a time line to come in as early as late this 21 year or next year? So do you have any thoughts as to how we 22 deal with that issue? What has been the nature of the 23 discussions? 24 MR. MATTHEWS: Yeah, based on our discussions with 25 BG&E and with Duke, it is clear that that is probably, if . 35 1 there is an -- what appears at this point in time to be an 2 issue that's unresolved in this area, although there are 3 some other ones the resolution of which isn't completely 4 clear, this one would be less clear than the others. 5 However, this situation was anticipated in 6 conjunction with the approval of the final rule in December 7 of last year. The staff and the Commission found themselves 8 in the position of not having a sufficient generic analysis 9 upon which to base a finding that this could be considered 10 as a category 1 issue. However, the Commission expected, 11 and they expressed in the statement of consideration, that 12 as part of its efforts to develop regulatory guidance for 13 this rule, the Commission would consider whether further 14 changes to the rule are desirable to generically address the 15 issue of cumulative transportation impacts. And that's 16 exactly what the staff is going at this juncture. 17 CHAIRMAN JACKSON: So let me make sure -- so what 18 is it that the staff is doing? 19 MR. MATTHEWS: I was going to move on to that. 20 COMMISSIONER McGAFFIGAN: Well, we'll both let you 21 go. 22 MR. MATTHEWS: The staff has obtained and is 23 currently evaluating information from DOE which we 24 anticipate will provide the basis for a generic analysis of 25 cumulative effects of transportation in the vicinity of a . 36 1 high-level waste repository. 2 CHAIRMAN JACKSON: And are you going to bring a 3 paper forth to the Commission on this? 4 MR. MATTHEWS: Yes, and in fact I will get to the 5 issue of what options might be available. 6 CHAIRMAN JACKSON: Okay. Good. 7 MR. MATTHEWS: And certainly the Commission will 8 be involved in the determination of the chosen one 9 COMMISSIONER McGAFFIGAN: And what is the timing 10 for -- 11 MR. MATTHEWS: I wanted to make a comment that 12 it's important, given that DOE has not yet issued an 13 Environmental Impact Statement that would go the full 14 distance in addressing this issue -- 15 COMMISSIONER McGAFFIGAN: And won't for some -- 16 MR. MATTHEWS: For some time. 17 COMMISSIONER McGAFFIGAN: Yes. 18 MR. MATTHEWS: We're of course concerned that we 19 not act too precipitously, so we do want to have an analysis 20 performed by the staff based on information that we receive 21 from DOE as opposed to just quote "adopting" what they've 22 provided. So we do want to do that. 23 COMMISSIONER McGAFFIGAN: Is an option for dealing 24 with the early appliers though -- this is something that 25 obviously should be dealt with generically. We can't deal . 37 1 with it generically yet. Is this an area where we're going 2 to have to use an exemption to -- or some sort of an 3 approach -- 4 MR. MATTHEWS: I think there's a potential for 5 that. The staff really hasn't considered what the 6 implications of granting an exemption in this area is, and 7 we'll certainly consider it if the need arises. 8 CHAIRMAN JACKSON: Is that one of the options on 9 your list? 10 MR. MATTHEWS: Yes. But I wanted to say we think 11 that there's probably time to perform an analysis and 12 proposed to you the possibility of an expeditious rulemaking 13 that will resolve this issue. 14 CHAIRMAN JACKSON: I see. 15 MR. MATTHEWS: That was what was expected at the 16 time that the issue was not sufficiently dealt with in 17 December, and our expectation is that provided the analysis 18 of DOE's input and our analysis would provide a sufficient 19 basis for that, that's the road that we'd like to go down. 20 COMMISSIONER McGAFFIGAN: I've heard expeditious 21 rulemaking -- 22 [Laughter.] 23 COMMISSIONER DICUS: No, no, no, I have both of 24 you on either side, so I don't have to worry about it. 25 No, I'm not clear on the timing in here. You . 38 1 said, you know, we have to wait -- we had to wait a little 2 bit, you know, obviously with DOE and other things to get 3 the Environmental Impact Statement and then you talk about 4 an expeditious rulemaking, so I'm not -- 5 MS. CYR: If I could say something, I mean the 6 Commission and -- I mean, the obligation to examine this 7 under NEPA is fundamentally ours, and we provide by 8 regulation that licensees have to provide an environmental 9 report to give us information basically that shortens our 10 process, so, I mean, in a sense this is a slightly different 11 situation if you were to quote "grant an exemption" if 12 that -- in that context -- but what the Commission has done 13 in the past is -- most notably in the waste confidence 14 proceeding -- was where we had a generic issue that came up 15 which the Commission decided that they wanted to address 16 generically. 17 They just provided that during the proceeding that 18 issue in the rulemaking you would not address it in 19 individual license proceedings and this licensing proceeding 20 would be subject to whatever the outcome of that generic 21 proceeding was, so we at least -- we have a situation in the 22 past where we have just provided that the individual actions 23 would be subject to whatever the outcome of the action was, 24 if in fact the license -- their proposal to amend the 25 existing findings in part 51 didn't terminate prior to the . 39 1 time that you had an application come in. 2 MR. MATTHEWS: And I might clarify that I hope I 3 didn't leave the impression we thought we needed to wait on 4 DOE's final Environmental Impact Statement for us to review 5 the issue and the associated environmental impacts, and we 6 the NRC issue a generic document that would reflect the 7 generic treatment of that issue short of DOE finalizing 8 their activity. And that would be the document upon which a 9 potential rulemaking would be potentially based. However, 10 short of that, there might be an option of issuing such a 11 generic environmental analysis that could be referenced by 12 the utilities in individual environmental reports. But, 13 again, the staff would then turn in development of their 14 draft environmental impact statement of having to deal with 15 that issue on a generic basis. 16 So that is why I made the comment exemptions, 17 while we haven't considered them in detail, may not really 18 be the option. 19 COMMISSIONER McGAFFIGAN: Could I clarify? 20 What does expeditious rulemaking mean in this 21 context? 22 MR. MATTHEWS: Well -- 23 COMMISSIONER McGAFFIGAN: I mean, when would it 24 begin and when would it end, just approximately? 25 MR. MATTHEWS: I think that is the options that we . 40 1 would have to consider among us, NOGC, in terms of how 2 expeditious such a rulemaking could be performed. 3 COMMISSIONER McGAFFIGAN: If I am a licensee 4 listening to this discussion, BG&E or Duke, what am I to 5 take away from it in terms of is this a problem for me or 6 not and do I have to include very much on this in my draft 7 report to the Commission or do I not? 8 MR. MATTHEWS: In the current regulatory arena 9 with the regulation as it exists, they need to address this 10 issue in the environmental report and address what's phrased 11 the generic and cumulative impacts so there is an obligation 12 for them to do that. However, as I explained with regard to 13 the process, we then, as Karen has pointed out, we the staff 14 then assume the obligation for doing a sufficient 15 environmental review and so we can bring to that review 16 additional information that we may develop as well. 17 CHAIRMAN JACKSON: I think perhaps a way to get at 18 this is if you were -- well, let me ask two questions, a 19 question and then make a comment. 20 When were you expecting to propagate the options 21 paper to the Commission? 22 MR. MATTHEWS: Well, I have to admit that until I 23 have a better feeling for when the staff can complete their 24 environmental assessment of the information received by DOE, 25 it is difficult for us to commit to what might be the next . 41 1 step and that was the difficulty I -- 2 CHAIRMAN JACKSON: I think we need a couple of 3 things from you. I think one is that we need to have that 4 readout of when the staff can complete its review of DOE's 5 environmental assessment and it's tied into what they are 6 doing. But I think we also need a readout relative to 7 various options that the Commission would have, but 8 particularly one related to rulemaking. 9 We need to have some sense of what is possible in 10 terms of speed and that may require input from OGC so we 11 understand, you know, what the legal bounds are. And so if 12 you could do that? 13 MR. MATTHEWS: That was the path we were headed 14 upon and we will proceed expeditiously. 15 CHAIRMAN JACKSON: Sure, apace. Right. Thank 16 you. 17 MS. SLOSSON: If we could go to the last slide? 18 In summary, the staff plans to focus its resources 19 on the plant-specific and owners group reviews and 20 applications if we receive it and use the information from 21 those reviews to make sure that we have clear and concise 22 guidance from the industry to use in pursuit of license 23 renewal and in the development of that guidance, certainly, 24 if we identify any policy issues, we will bring them forward 25 to the Commission. . 42 1 CHAIRMAN JACKSON: Thank you. 2 Commissioner Rogers? 3 COMMISSIONER ROGERS: I don't have anything. 4 CHAIRMAN JACKSON: Commissioner Dicus? 5 COMMISSIONER DICUS: I have one more question. 6 I recognize at the onset this is not specifically 7 related to license renewal but I am particularly interested 8 in learning a little bit more about the subject so, for 9 information purposes, I would like to bring it up. This has 10 to do with EQ, which I recognize is an ongoing issue with 11 operating plants and was taken out of the renewal bin for 12 that reason, at least that is what I understand. 13 But what do you expect licensees or how do you 14 expect licensees to address this in their renewal 15 applications? 16 MR. HOFFMAN: Well, EQ, actually that generic 17 issue was identified as part of the early license renewal 18 reviews along with, like metal fatigue which is another 19 generic issue that we have identified. 20 When we amended the rule, the statements of 21 consideration talks about unresolved generic issues and it 22 does state clearly that a renewed license can be issued with 23 an unresolved issue. A couple options, it discusses like 24 BG&E or Duke could use would be to -- they could come up 25 with a plant-specific resolution of the issue or they could . 43 1 give us a more or less a justification of why they can 2 continue to operate until some period in the future when 3 they could then incorporate the final resolution. 4 We have been involved, you know, even though it 5 has been taken out of more or less the license renewal's 6 responsibility, we continue to be involved in the ongoing 7 activities with research and the technical branches of NRR. 8 COMMISSIONER DICUS: How many unresolved generic 9 safety issues are there? 10 MR. HOFFMAN: We are still looking at that. We 11 are talking about -- well, unresolved generic issues that 12 have to be addressed for renewal are only those that involve 13 structures and components subject to the -- you know, within 14 the scope of the rule and that involve aging effects. So we 15 are talking passive, long-lived components with applicable 16 aging effects. So it narrows it down quite a bit. 17 Some initial cuts show less than 10, in that 18 ballpark. And some reviews have shown two. It depends on 19 who is doing the review right now. So we haven't got that 20 final list. 21 CHAIRMAN JACKSON: Okay, Commissioner Diaz? 22 COMMISSIONER DIAZ: Yes, let's see. Following on 23 that question, I think aging is the key issue on relicensing 24 versus not the matter of aging but aging gracefully, that 25 whole issue. . 44 1 [Laughter.] 2 COMMISSIONER DIAZ: A concern that some of us have 3 of late. But, you know that I think it is important to, and 4 I don't quite see though, how are we developing the body of 5 knowledge necessary to systematically use some criteria to 6 determine the degradation, not aging, per se, as a 7 degradation of safety systems. Instead, is that process 8 being developed with significant focus? 9 MR. HOFFMAN: There have been a number of 10 activities. To clarify, we are looking at the aging 11 effects. 12 COMMISSIONER DIAZ: Aging means degradation due to 13 aging, right? 14 MR. HOFFMAN: Right. 15 We are looking at the effects as opposed to the 16 mechanisms themselves because we want to ensure the 17 functionality of structures and components. 18 There -- and the intent is that we maintain that 19 functionality in accordance with the current licensing basis 20 and, in particular, the design basis. So that when you are 21 looking at the effects of aging in a number of areas, you do 22 go back and see what the design intent is and ensure that 23 function can be maintained. 24 There have been some additional -- it's really, 25 like before, in renewal, everything seems to be kind of . 45 1 interrelated. The NUMARC reports in which they did some 2 studies on specific structures and components have added to 3 it, the Office of Research has had their Nuclear Plant 4 Research -- I forget the exact name of it, that they have 5 been developing. There was a generic aging lessons learned 6 document that has been produced. 7 So we are pulling all of that data in as part of 8 this ongoing process and looking at it. 9 COMMISSIONER DIAZ: And are we starting to assume 10 some criteria of pass, no pass, going to watch it? I mean, 11 there should be some body of knowledge that we develop 12 systematically that will not only allow us to look at the 13 first one but will actually allow us to, in a critical 14 manner, analyze the functionality and/or potential 15 continuing effects. Because I think aging becomes the 16 critical component of the process; is that correct? 17 MS. SLOSSON: Aging is the critical part of the 18 license renewal review we do for the passive, long-lived 19 components. So we are evaluating and developing guidance 20 for how the staff will look at and what criteria will we use 21 to determine if an aging management program is effective. 22 So that is being done as part of the regulatory guidance 23 development. 24 MR. HOFFMAN: And the Standard Review Plan will 25 be, for the components and structures looked at, it will . 46 1 contain specific guidance as to -- 2 COMMISSIONER DIAZ: I think that body of knowledge 3 is critical to the entire process, to maintain it and 4 upgrade it and develop it to a point that will be useful in 5 a continuous manner because you are going to go back to it 6 over and over again. 7 CHAIRMAN JACKSON: Commissioner McGaffigan? 8 COMMISSIONER McGAFFIGAN: Given how much time was 9 devoted to the last question that was spurred by this 10 sentence, I am not sure I want to keep going on it, but 11 there is a list of other issues other than transportation 12 issues that you have been discussing with the industry and 13 the sentence that follows says, good progress has been made 14 on these issues and dialogue continues. 15 Are any of the other issues on the list, do they 16 rise to the same level that the transportation issue rises 17 to in terms of possibly involving Commission guidance or 18 whatever? 19 MR. MATTHEWS: Not based on what discussions we 20 have had to date. 21 CHAIRMAN JACKSON: Well, I would like to thank the 22 NRC staff for providing a very informative briefing to the 23 Commission regarding activities associated with the 24 implementation of the license renewal rule. It was 25 important in 1994, when the Commission directed the staff to . 47 1 revise the rule and it is just as important today that the 2 Commission provide a stable and predictable license renewal 3 process. 4 So I commend the staff for its perseverance in 5 these license renewal efforts and the staff should continue 6 to work with the nuclear power industry to resolve the 7 technical and other implementation issues. And, as you have 8 heard and you have heard specific ones, should the staff 9 identify policy issues associated with the license renewal 10 rule implementation or with the environmental related 11 requirements contained in 10 CFR Part 51, the staff should 12 forward these issues promptly to the Commission for timely 13 resolution along the lines that we have already discussed. 14 So, unless my fellow commissioners have any 15 further comments, we are adjourned. 16 [Whereupon, at 2:36 p.m., the briefing was 17 concluded.] 18 19 20 21 22 23 24 25
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