34
NuclearPlantJournal.com Nuclear Plant Journal, May-June 2014
updated at approximately 10-year
intervals, and was last revised in 2013,
so it is up to date. This well-established
process can also be used to evaluate the
environmental impacts of continuing
plant operations for a second 20-year
period.
The NRC Staff’s
Proposals
In January 2014, the NRC
Staff prepared an options paper
for consideration by the five NRC
Commissioners
(SECY-14-0016
–
Ongoing Staff Activities to Assess
Regulatory Considerations for Power
Reactor Subsequent License Renewal
(Jan. 31, 2014), available at
.
nrc.gov/reading-rm/doc-collections/
commission/secys/2014/2014-0016scy.
pdf). Overall, the options paper reaffirms
the existing framework in Part 54 as the
regulatory basis for subsequent license
renewal, concluding that “the license
renewal process and regulations are
sound and can support subsequent license
renewal.” “Option 1” would involve
no rule changes. However, the paper
recommends clarifications and updates
to the license renewal rules—labeled
Options 2 and 3. These changes would
apply to both first and subsequent license
renewal applications and would, for
example, update Part 54 to cover certain
post-1995 rule changes in other areas or
codify already-established NRC Staff
guidance.
The options paper recommends
what is labeled “Option 4.” This
recommendation includes the Options
2 and 3 changes, and would add more
substantive rule changes. First, the
Staff proposes additional requirements
for applicants to report aging-related
degradation to the NRC and to
demonstrate the effectiveness of aging
management activities. Second, the
Staff would reduce the time window
within which an applicant may submit a
subsequent license renewal application
before its existing license expires, from
the existing 20 years to a shorter period,
so, in the Staff’s opinion, applicants have
adequate aging management experience
before they submit subsequent license
renewal applications. And third, the Staff
expresses the concern that certain site-
specific characteristics, such as severe
weather and external hazards, may change
over time as a result of climate change.
Therefore, the Staff proposes to verify the
validity of certain original design input
parameters, primarily through an update
to Part 50 requirements (i.e., outside of
the license renewal process). But, if
necessary, the Staff’s paper suggests that
it may seek to consider the adequacy
of these aspects of a plant’s licensing
basis as part of the subsequent license
renewal review. If the Staff proceeds
with rulemaking, it currently envisions
publishing a proposed rule in 2016 and a
final rule in 2017, as the first application
for subsequent license renewal could be
submitted as early as the end of 2017 or
beginning of 2018.
This rulemaking proposal is
unnecessary and has the potential to
undercut the stable and successful
regulatory framework in Part 54. The
clarifications and updates that the Staff
proposes in Options 2 and 3 can easily
be addressed through Staff guidance,
outside the rulemaking process. Indeed,
some of these proposed changes are
already covered in guidance, and others
address unusual situations that will likely
affect very few plants, so there is no need
for a new across-the-board rulemaking.
As to Option 4, aging management
effectiveness can and should be verified
through existing processes, as envisioned
in the original Part 54 rules. Likewise,
there are existing requirements to report
age-related degradation. And the industry
has initiatives under way to enhance the
guidance on self-assessments of aging
management program effectiveness and
on the reporting of operating experience.
The proposal to reduce the time
window for applications, which is part of
Option 4, likewise is unlikely to lead to
any enhancement in safety. Most aging
management programs are already in
place at plants before the first license
renewal, and applicants for subsequent
license renewal will have accumulated
more operating experience with existing
programs than first license renewal
applicants. Moreover, as previously
noted, many plants throughout the country
are already operating beyond 40 years and
have implemented their remaining aging
U.S Commercial...
Source: Figure 23. License Renewals Granted for Operating Nuclear Power
Reactors, NRC Information Digest (2013), available at
/
reading-rm/doc-collections/nuregs/staff/sr1350/v25/sr1350v25.pdf
