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Mr. CASE. We can provide it. For each application, as you undoubtedly know, we look at cost of the electricity that will be produced by that plant, taking into account the entire fuel cycle and decommissioning cost. What we can do is put together some averages based on the environmental statements that we have in addition to that.

Mr. Hunt. It might be better to perhaps use some that are currently in service. I was wondering whether there was a range of error, you know $800, or $900, or $1,000 a kilowatt plus or minus 20 percent.

Mr. Case. There is such a number but I don't have it with me.
Mr. HUNT. I would appreciate it if you could supply it.
Mr. CASE. We will be glad to.

Mr. Hunt. In the development of the Environmental Impact Statement associated with licensing what, if I may ask, are the general planning horizons that are used to determine whether indeed the demand is needed from that particular generating facility. Do you take into account the presence of power pools?

Mr. Case. We look at the load demands and the load forecasts prepared by the utility and make an independent evaluation of the need for the electricity in the timeframe in which the plant would come into operation.

Mr. Hunt. When you say of the utility, do you require that they look at the alternative such as joining a power pool where indeed the reserve margin might be reduced substantially?

Mr. CASE. We look at reserve figures. The entire spectrum of things that might affect the need for power is looked into, sir.

Mr. Hunt. Only within the range of that one specific applying utility or on a regional basis?

Mr. CASE. On a regional basis, taking into account the utilities in that region and needs of the region.

Mr. Hunt. And the nature of their construction plants?
Mr. CASE. Yes, sir.

Mr. Hunt. Has there been any analysis, at least in the latest ones, brought forward relative to, say, such opportunities as conservation and load leveling techniques which look to be within the potential basis of the managing utility or power pool ?

Mr. Case. Yes; the potential effect of conservation and various techniques of reducing requirements such as time-of-day pricing are taken into account.

Mr. Hunt. In the analyses have any recommendations been made relative to the utilization of such demand management techniques which might obviate the need for construction of that plant at that point?

Mr. CASE. Not to my knowledge. We have not made recommendations on that.

Mr. Hunt. They have been analyzed but they have not been found to be a viable alternative from the standpoint of the analytical work?

Mr. CASE. The potential effects are taken into account. We think it is more a function of the State public utility commission.

Mr. Hunt. You would rely basically on their decision relative to that?

Mr. CASE. Yes,

Mr. ROWDEN. Let me add an observation in that regard because this is a matter which is part of the study to which I made reference in my

prepared remarks. This is the Federal-State siting study. One of the recommendations which has been strongly forwarded by the State participants, and which we will be giving serious consideration to, is making the so-called need for power question a State responsibility rather than one which is conducted, as it is now, duplicatively by the State or regional siting authorities and by NRC in terms of its Federal licensing responsibility. That is one major area of overlap.

This, of course, would encompass not only a projection as to demand—need for power—but necessarily would have to take into account the role that conservation plays in that.

Mr. Hunt. When, may I ask, is this study expected to be completed ?

Mr. ROWDEN. The study is projected to be completed by the end of next month in terms of our staff coming forward with recommendations to the Commision. That will in turn be the basis for our examining any administrative changes we can make—that is without new legislation, in our licensing proceses—and any legislative recommendations which are appropriate to make to the Congress.

Of course before we make any legislative recommendations we would like to consult with the administration so that we can integrate what we are doing in this regard with administration energy policy initiatives.

I think it is reasonable to expect that the Commission will see some desirable areas for legislative change in this process.

We are very much concerned, as are the States, about the amount of duplicative work that is being done in the environmental review process. We have a very comprehensive NEPA environmental review process which we conduct and at one time that was the only environmental review process that was given to a nuclear powerplant.

Over the last 5 or 6 years since the enactment of EPA, quite a number of States have undertaken their own environmental analyses. We find ourselves in a situation where we are both essentially doing the same things and I think a rather logical question arises as to whether the system cannot be better constructed in terms of conservation of resources.

It is clear what our responsibilities are and what the States' responsibilities are. I think we will be coming up with some positive recommendations.

Mr. Hunt. It would occur to me you would be capable of looking quite clearly beyond State boundaries while indeed the State itself might suffer the myopia of saying I am a single State.

Mr. ROWDEN. That is a possibility. I think any system that is restructured in this regard has to take into account that meeting energy demands is as much a regional as a State consideration.

Mr. Hunt. Thank you very much. You brought up the issue of coordinating with other agencies. It is our understanding that there have been some problems basically in the past, or one of the issues associated with the long lead times that are involved in the construction of a plant has stemmed from open questions relative to methods of cooling towers or indeed what is the best available technology which does not, I believe, by statute fall within your jurisdiction.

Have there been revisions basically made within the last year or so in the way in which you work with the Environmental Protection Agency?

Mr. RowDEN. There have been significant positive steps taken in this regard. Quite obviously, as evidenced by the pending Seabrook proceeding, they are not completely effected because they have not been completely implemented. The problem stems from the fact-if indeed you can characterize it as a problem, since it is a deliberate course of action charted by the Congress——that we have certain environmental review responsibilities, which include at least a gross assessment of the impact on water quality, in our EPA cost-benefit analysis, whereas the determination as to what the appropriate cooling system should be is exclusively that of EPA, or by delegation of the States and of the discharge permit system.

We have attempted with some success, but not complete success, to address this by entering into an agreement initially with EPA so that their discharge permit determination can be made as early in the process as is possible--and as a matter of fact at a point in time hopefully before any construction authorization is given by the NRC-and it is working in quite a number of cases.

But the EPA system is not fully implemented in this regard. There has been some question as a result of court action with respect to the closed cycle cooling regulations which the agency had earlier adopted.

In addition to that, although EPA basically requires closed cycle cooling, there is also, because of the provisions of the Federal Water Pollution Control Act, a provision for granting of variances or cxemptions. When that remains a residual question, you can run into a problem where one agency might be taking an action which conflicts with a determination made later on by another agency-essentially what happened in the Seabrook proceeding. We are making measurable progress with respect to EPA.

Another area, more complicated because it involves more parties, is of the States, because EPA under the act has delegated its permitting authority to, I think, about half of the 50 States, perhaps more. So we are now in the process of seeking to work out comparable arrangements with the individual States.

One of the difficulties, and I think this is one of the realities in looking at the nuclear licensing process, is that you do not have one authorizing agency. The NRC is not the only actor in the game. The States exercise very considerable authority in this regard, and it is remarkable the number of permits and authorizations that are required by a utility before it can begin the construction of a nuclear rowerplant.

I mentioned the Seabrook proceeding before. There were some 43 separate approvals that were required to be obtained by that utility before it could move forward. As it happened, 42 of those were forthcoming and the 43d, of course, came into question.

But that whole sitting process is badly in need of what I would characterize as rationalization. We are going to make what we believe to be some constructive suggestions in this regard. Some of them are going to call for congressional action. I welcome the opportunity to deliver a few advance comments on this general subject, because it is one in which I think some positive action is necessary if we are going to do what the President said he is intent on doing, and that is measurably shortening the nuclear plant cycle.

Mr. Hunt. It is my understanding that there are at this point some 120, if I am not mistaken, outstanding unresolved safety issues associated with nuclear power generating stations. Am I in the range of the number or not?

Mr. ROWDEN. Perhaps Mr. Case can address himself to numbers. Mr. Case. The number varies depending on the person's definition of the term, Mr. Hunt. A hundred is a fair number for a reasonable interpretation of the term, yes.

Mr. Hunt. I am going toward the direction again of this question of how much indeed we can standardize plants and by so doing hopefully shortening the licensing procedure. Have these unresolved safety issues been categorized to determine which are the most critical and actually might require revisions in designs down the road!

Mr. Cast. We are in the process of doing that now, sir. We are coming up with priority lists with that connotation.

Mr. HUNT. With that criteria in mind?
Mr. Case. That is one of the criteria.

Mr. HUNT. The issue I guess is what are considered the probabilities of finding an acceptable design in the light of these unresolved safety issues basically which could be ginned out by cookie cutter and indeed what other problems associated with the standardized design do you see?

There are obviously site questions involved. I would appreciate if you could address yourself to that question.

Mr. Case. Let me make sure there is a clear understanding of the unresolved safety question. That does not mean for any given application there is a safety question that remains prior to its licensing. A solution is adopted for any individual plant on such an issue while further study is given to that issue to see if there is a more optimum or better solution to the problem, but for each plant the problem is solved.

So, for a given period of time a standardized plant can be developed with an adequate solution to one or all of the generic issues while further study is going on. That study may result in some relaxation of the requirement on the basis of which you could change the design of the standardized plant, or indeed it is possible that a more severe requirement would be developed and it would have to be backfitted to all operating plants.

This is the nature of the nuclear business. It is a dynamic industry with new information being developed. We have a system for incorporating the new information and any changes in design that result from that into the process and into all operating plants.

Under these conditions standardized plants can be developed. They will save time in our opinion not only in licensing but also during construction and result in a safer operating plant and obviously, we believe, result in a shortening of the overall licensing process.

We see that there are advantages to standardization and we believe that this is the direction that the industry should take, itself.

Mr. ROWDEN. I might make an additional observation in that regard. Although shortening the licensing process, the overall licensing process, remains an important objective of our Commission and obviously it is an important objective of the industry and those who pay the

rates for electricity because time is money in that regard—the industry is also equally intent on stabilizing the licensing process in the sense of conferring a greater degree of consistency and predictability on the process. They say, “Let us know the ground rules so that we can plan.” That in some aspects is more important in the longer time frame. Standardization can confer immeasurable benefits also. It is not the panacea to everything. We believe it is a course that ought to be aggressively pursued.

We have had a program structured in the last several years implementing it with some measure of success. Standardization of design has thus far proceeded only as respects preliminary design. We have not gotten to standardized final design yet. That is some time down the road. We believe that concept in and of itself, if it could be coupled with early site review, would immeasurably aid utility planning and also eventually, we hope, take our licensing process completely off the critical path of utility planning, thus cutting up to perhaps 3 years from the overall nuclear plant cycle.

Mr. HUNT. Do I take from that, sir, that the licensing process is now one of the major constraining elements relative to construction?

Mr. RowDEN. Our licensing process is on what we would call the critical path at the present construction approval stage. It is not the only critical path item because there are a number of other approvals that utilities have to get, as I mentioned. It is at that point

Mr. HUNT. Preconstruction.

Mr. ROWDEN (continuing). the preconstruction approval stage that our licensing process is a critical path item. On that the preconstruction review and approval runs in the range of up to 21/2 to 3 years, including the hearing time. If the process of site review and site approval could be done prior to the utility's filing a construction permit application-several years prior to that point in time—and if the utilities could pick off the shelf, so to speak, a standardized design which had been prereviewed and preapproved by our Commission prior to the filing of a construction permit application, then when that application is filed, when the need ultimately arises, the two could be married, and because of the prereviews, preapprovals, including necessary, hearings, the utility could proceed fairly rapidly to construction.

That is what I mean by saying "getting us off the critical path” at that juncture of the process. That is not to say that there might not be other agencies on the critical path at that time. Part of our challenge is to work out arrangements with those other agencies so that they can perform their task in a way that they don't impact on the process at that juncture in time.

Mr. Hunt. The real savings in time you are addressing is basically the utility having approval for a given site, the property in hand and basically coming to you at that stage.

Mr. ROWDEN. That is one element of it so far as our licensing process is concerned. Another element is the amount of time that the utility might save utilizing a standardized design approach in the construction phase. That, of course, is a process which is influenced by matters essentially beyond our control; it is not totally unrelated to regulatory requirements, but other considerations become the dominant factor there.



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