Why doesn’t VY have to adhere to the same licensing requirements that a new plant being licensed would have to adhere to?
The NRC frequently updates its regulations as a result of improvements to technology and based on operating experience. When requirements are changed, the NRC applies a rigorous evaluation standard to determine if the safety benefit of the new requirements justifies imposing the changes on existing licensees. For example, VY was licensed before the final General Design Criteria (GDC) were adopted. At the time it was licensed, VY was evaluated by the NRC on a plant-specific basis, and was determined to be safe. When the final GDC were approved, the Commission stressed that the final GDC were not new requirements but were promulgated to more clearly articulate the licensing requirements and practice in effect at that time. The Commission determined that imposing the final GDC on plants licensed prior to issuance of the final GDC would provide little or no safety benefit. However, when a new regulation provides a substantial increase in safety other cases, the NRC has imposed new regulati
