ML13308A669
| ML13308A669 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Dresden, Oyster Creek, Haddam Neck, Ginna, San Onofre  |
| Issue date: | 12/05/1980 |
| From: | Schaffstall R KMC, SEP Owners Group |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8101050160 | |
| Download: ML13308A669 (12) | |
Text
December 5, 1980 RICHARD E. SCHAFFSTALL_-'
Associat
~
Mr. Darrell G. Eisenhut Director, Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 CA
Dear Mr. Eisenhut:
This letter confirms the proposal made by the SEP Owners Group at the meeting on December 2, 1980 with members of your staff to assume a significantly increased involvement in the com pletion of the Systematic Evaluation Program (SEP).
Specifically, the licensees represented in the SEP Owners Group are prepared to complete 60% of the SEP topic assessments for the 9 plants represented by the SEP Owners Group by June 30, 1981.
This 60%
level includes those topics for which resolution has already been effected such as: draft SER, topics considered complete, topics not applicable or deleted, and generic issues outside the SEP scope.
The completion of this large number of topic assessments on such an accelerated schedule is contingent upon the NRC staff preparing, with licensee assistance, safety evaluations of SEP topics for a designated plant(s).
The licensees are prepared to complete topic assessments for the remaining plants essentially without additional staff guidance, using the SER from the desig nated plant(s).
In addition, both the staff and the licensees must assign adequate resources and develop mutually acceptable schedules which can accommodate the anticipated documentation volume.
As we discussed during the meeting, the SEP Owners Group is prepared to meet with the NRC SEP staff during the month of
- December, 1980 to reach mutual agreement on the assignment of a designated plant(s) for each SEP and following such identifica tion develop detailed schedules to meet the 60% goal.
The topics which the SEP Owners Group had selected as can didates for completion by June, 1981 were identified during the December 2, 1980 meeting.
Subsequent review of those topics has revealed that the completion of topic assessments, as proposed, provides for the completion of a topic assessment for at least one of the SEP plants by June, 1981 with the exception of approxi mately ten topics, some of which are long-lead.
In discussions 10 1.0519 KMC, Inc.
1747 PENNSYLVANIA AVE., N.W.
WASHINGTON, D.C. 20006 202/223-3163
Mr. Darrell G. Eisenhut December 5, 1980 Page 2 on December 3, 1980 between Mr. Wes Moody of Southern California Edison and Mr. Bill Russell of your staff, Mr. Russell felt that this group of 10 topics would be reduced as the result of the anticipated issuance by SEPB of certain draft safety evaluations in the immediate future. Further reduction of this list is ex pected in the December meetings between the staff and the SEP Owners Group. The SEP Owners Group is willing to work with the NRC staff in an attempt to develop a completed safety evaluation for each SEP topic by June, 1981 if it is so desired.
As discussed in the meeting, we are willing to meet period ically with your staff and others related to SEP to discuss progress in this accelerated schedule and would be pleased to discuss your intentions with respect to the planned integrated assessment.
Enclosed is a copy of the presentation material used by the SEP Owners Group during the December 2 meeting.
If you have any questions concerning our proposal, please let me know.
Sincerely, Richard E. Sch stall Executive Director SEP Owners Group encl.
PRESENTATION OUTLINE INTRODUCTION CURRENT STATUS PROPOSED PLAN FOR COMPLETING REMAINING SEP TOPICS SCHEDULE ADVANTAGES OF PROPOSED PLAN POTENTIAL PROBLEM AREAS
INTRODUCTION "LEAD PLANT" APPROACH (WITH PALISADES AS LEAD)
DISCUSSED NOVEMBER 3, 1980.
SEP OWNERS EXPRESSED RESERVATIONS WITH "LEAD PLANT" APPROACH AND PROPOSED A TOPIC-BY-TOPIC REVIEW.
SINCE NOVEMBER 3, 1980 MEETING, OWNERS AND SEP STAFF MEMBERS HAVE MET AND WORKED OUT THE TOPIC-BY-TOPIC REVIEW APPROACH AND SCHEDULE.
MAIN ELEMENTS OF APPROACH ARE DESCRIBED IN THE FOLLOWING VIEWGRAPHS.
CURRENT STATUS TOTAL NUMBER OF TOPICS 1370 (LACROSSE NOT INCLUDED)
NUMBER OF TOPICS WHICH
%500 ARE N.A. OR GENERIC NUMBER OF TOPICS COMPLETE
%170 REMAINING TOPICS
,700 OR.70 PER PLANT
PR0 OSED PLAN FOR COMPLETING REMAINING SEP TOPICS ESTABLISH "LEAD PLANT" FOR EACH OF REMAINING TOPICS TOPICS TO BE DISTRIBUTED AMONG SEP PLANTS LEAD PLANTS TO INCLUDE BOTH BWRs AND PWRs WHERE APPROPRIATE NRC TO PREPARE INITIAL SERs FOR EACH LEAD PLANT AND ALL TOPICS. INITIAL SERs WILL:
DEFINE TOPICS ESTABLISH REVIEW CRITERIA INCLUDE EVALUATION RESULTS FOR LEAD PLANT SEP OWNERS TO PREPARE SUBSEQUENT DRAFT TOPIC ASSESSMENTS FOR NRC REVIEW NRC TO REVIEW AND AUDIT DRAFT TOPIC ASSESSMENTS AND ISSUE FINAL SERs INTEGRATED ASSESSMENT TO BE PERFORMED AFTER COMPLETION OF TOPICS
SCHEDULE
- .MEET WITH SEPB STAFF OVER MONTH OF DECEMBER 1980 TO SET PRIORITIES AND SCHEDULE FOR TOPIC REVIEWS AND TO SELECT "LEAD PLANTS" FOR EACH TOPIC.
o OWNER MANPOWER COMMITMENTS TO BE BASED ON COMPLETING 60% OF THE TOPICS, TOTAL, BY JUNE 1981.
ADVANTAGES OF PROPOSED PLAN o
WILL ACCELERATE PROGRESS ON SEP o
WILL BETTER DISTRIBUTE MANPOWER REQUIREMENTS AMONG OWNERS o
WILL PRESERVE THE SEP OWNERS GROUP AND ITS ABILITY TO ACT ON GENERIC PROBLEMS o
WILL MINIMIZE RESOURCE REQUIREMENTS OF NRC STAFF AND OWNERS
POTENTIAL PROBLEMS PROBLEM AS PRESENTLY PLANNED, NRC'S INITIAL DRAFT SERs ON TOPICS WILL IDENTIFY DEVIATIONS BUT NOT MAKE JUDGMENTS OF ACCEPTABILITY. WILL RESULT IN LARGE NUMBER OF INSIGNIFICANT DEVIATIONS FOR LATER RESOLUTION AND INTRODUCE INEFFICIENCIES AND POSSIBLE DELAYS.
RESOLUTION THE MAJORITY OF DEVIATIONS IDENTIFIED IN INITIAL REVIEWS SHOULD BE ADDRESSED AND RESOLVED IN DRAFT SERs, LEAVING ONLY SIGNIFICANT DEVIATIONS FOR INTEGRATED ASSESSMENT.
ALTERNATIVE PLANT FEATURES SHOULD BE DOCUMENTED IN INITIAL DRAFT SERs.
POTENTIAL PROBLEMS (CONT'D)
PROBLEM SEPB DEDICATED STAFF KNOWLEDGEABLE IN DETAILS OF SEP PLANTS IS ESSENTIAL TO EFFICIENT COMPLETION OF SERs.
AT PRESENT, INSUFFICIENT DEDICATED STAFF HAS BEEN ALLOCATED TO SEP.
THIS PROBLEM IS MINIMIZED IN PROPOSED TOPIC-BY-TOPIC APPROACH, BUT IS STILL SIGNIFICANT.
RESOLUTION SEPB DEDICATED STAFF SHOULD BE INCREASED SIGNIFICANTLY IF PROGRESS IS TO BE MADE -
EVEN WITH OWNERS PREPARING 90% OF DRAFT TOPIC ASSESSMENTS.
POTENTIAL PROBLEMS (CONT'D)
PROBLEM LEAD PLANTS FOR TOPIC REVIEWS MUST BE SELECTED TO DISTRIBUTE TOPICS EQUITABLY AMONG OWNERS.
IF TOPICS ARE ASSIGNED TO OWNERS BASED ON CURRENT STATUS OF INITIATION OF REVIEW, THE MAJORITY OF TOPICS WOULD BE ASSIGNED TO PALISADES AS THE LEAD PLANT, EVEN THOUGH A SIGNIFICANT AMOUNT OF THE EVALUATION ON ANY TOPIC HAS NOT BEEN PERFORMED. THIS WOULD BE SIMILAR TO THE LEAD PLANT CONCEPT PREVIOUSLY DISCUSSED AND WOULD NOT BE WORKABLE.
RESOLUTION TOPICS SHOULD BE ASSIGNED TO LEAD PLANTS SO AS TO PROPERLY EVEN-OUT THE WORK LOAD AMONG THE OWNERS, EVEN IF THIS MEANS STOPPING WORK ON SOME TOPICS WHICH HAVE BEEN INITIATED FOR PALISADES.
PROJECTED STATUS AS OF JUNE 1981 WITHOUT LACROSSE WITHOUT AND DRESDEN 1 LACROSSE
. NUMBER OF TOPICS WHICH ARE 446 500 N.A.
OR GENERIC
. NUMBER OF TOPICS COMPLETE 158 174 (FINAL OR DRAFT ASSESSMENT)
AS OF DECEMBER 1930
. NUMBER OF TOPICS WHICH ARE 191 191 ARE CANDIDATES FOR COMPLETION BY JUNE 1981 TOPIC COMPLETED BY JUNE 1981 795 865 PERCENT COMPLETED BY JUNE 1981 795
=
64%
865 63%
1233 1370