ML19256A163
| ML19256A163 | |
| Person / Time | |
|---|---|
| Site: | 05000545 |
| Issue date: | 10/27/1978 |
| From: | Boyd R Office of Nuclear Reactor Regulation |
| To: | James Anderson WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| NUDOCS 7811030192 | |
| Download: ML19256A163 (4) | |
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UNITED STATES NUCLEAR REGULATORY COMMisslON y of 3 h..
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m Mr. Tom M. Anderson, Managar Nuclear Safety Department Westinghouse Electric Corporation P. O. Box 355 Nuclear Center - Bay 415 Pittsburgh, Pennsylvania 15230
Dear Mr. Anderson:
SUBJ ECT:
PROPOSED UPDATE OF RESAR-3S DESIGN On September 15, 1978, we met with you and members of your staff to discuss the future plans which Westinghouse has formulated for its standardized nuclear steam supply system (NSSS) designs. During this meeting, you informed us that Westinghouse desires to request a PDA extension for RESAR-35 and to update the RESAR-3S Safety Analysis Report by March 1979. This update would (1) describe a limited number of design changes, (2) assess the RESAR-3S design against the PDA extension review matters to qualify for a PDA extension, and (3) restructure the RESAR-35 Preliminary Safety Analysis Report to agree with the format of Revision 2 of Reguktory Guide 1.70, " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants." Four alternative licensing approaches were presented by Westinghouse regarding the update of the RESAR-3S design.
In response to your request for our comments, we have evaluated your four alternative licensing approaches in the light c/ the Commission's August 1978 Statement on Standardization. The following represents our thoughts regarding each of the proposed alternatives.
1.
RESAR-3S PDA Extension with No Fonnat or Technical Changes You expressed a concern that it may be difficult for the staff to review a utility-applicant's PSAR which confonns to Revision 2 of Regulatory Guide 1.70 but references the RESAR-35 PSAR, which conforms to Revision 1 of Regulatory Guide 1.70.
We do not believe this should pose a problem.
Since the RESAR-3S PSAR has already been reviewed and approved by the staff, there should be no need to re-review the RESAR-35 PSAR (outside the context of the PDA extension review).
The use of this alternative, however, would mean that any desired design changes would have to be described in the utility-applicant's PSAR as 780.930ftt
Mr. Tom M. Anderson Dr
> Y 7-exceptions to the appropriate sections of the RESAR-3S PSAR. Al though we discourage exceptions to approved reference system designs, we recognize that there may be circumstances where they are justified, We have, in the past, accepted utility applications with exceptions to reference system designs under the standardization program, pro-vided that such exceptions were considered absolutely necessary and were kept to a minimum.
In this manner, the design for which the PDA was issued would remain unchanged even though a small number of design differences might exist between individual plants that refer-enced the standardized NSSS design.
You stated that the desired design changes to RESAR-35 consist of matters that either have been t eviewed and approved in other s aff reviews (e.g., the Model r steam generator) or are of the type which occurred as the resuit of the development of the final design for RESAR-3S and which are being reviewed on a generic basis in the form of topical reports (the removal of part length control rods, B C control rod composition, and 4
Optinized Fuel). On this basis, we believe that exceptions such as the four discussed with us can be handled within the context of the review of the PSAR of a utility-applicant which references the RESAR-35 PSAR without any major difficulties.
In sum, we believe that the RESAR-3S PSAR could be referenced without format or technical changes other than those which may be necessary as a result of the PDA extension review.
- 2. RESAR-3S PDA Extension with the PSAR Revised to Agree with the Format of Revision 2 of Regulatory Guide 1.70 and to Accommodate a Limited Number of Technical Changes According to your explanation, this approach would consist of the following.
The material currently in the RESAR-3S PSAR and any additional material necessary to satisfactorily address the PDA extension review matters and to accommodate a limited number of technical changes to the RESAR-3S design would be arranged in the format specified by Revision 2 of Regulatory Guide 1.70.
The purpose of your reformatting the PSAR in this manner would be to make the staff's review easier since reviewers would probably be more familiar with the Revision 2 format.
This approach would result in a re-review of all areas of the RESAR-3S PSAR affected by any design changes.
In our view, the restructured application would create a potential difficulty in identifying those portions of the application which need not be reviewed. Consideration would have to be given to procedural ways to clearly identify the technical changes in the revised PSAR. We foresee that, even with
Mr. Tom A. Anderson i.t
- t reformatting the PSAR, the review of the PDA extension matters and the proposed design changes may require more than the eight months projected for the staff's review of the PDA extension matters alone.
A prolonged staff review of the RESAR-3S update could adversely impact the review schedule for any CP application referencing the RESAR-3S PSAR.
- 3. New PDA Applit.ation for a 3425 MW Standardizaa Design This would be an acceptable approach for haniling the design changes.
The application would be eligible for a 5-yeaa PDA.
However, the PSAR would have to conform to Revision 2 of Rtgulatory Guide 1.70 in content as well as format.
The review of such an application wou.d require more staff resources and manpower thar. the preceding two al terna tives.
In addition, it is likely to have a longer review schedule due to the larger scope of the review. The review of the new PDA application could impact the CP review schedule for a plant referencing the PDA application.
- 4. FDA Application for the RESAR-35 Design Tnis would be an acceptable approach for handling the design changes.
The FDA, when issued, would be for a five-year term. As with approach (3), the PSAR would have to conform to Revision 2 of Regulatory Guide 1.70.
This approach would conceivably treat the design changes as appropriate to the evolution from the preliminary stage (PDA) to the final stage (FDA) of the NSSS design. As with proposed approach (3),
the staff's review of the FDA application for RESAR-35 would require more staff manpower and resources than approaches (1) and (2). The FDA application would probably have a longer review schedule because of the larger scope of the review. The review of the FDA application could become a critical path item for the review of a CP application refen incing the FDA application.
Since the staff has had no experience to date with this licensing situation, we cannot accurately assess the potential problems with this approach.
Subsequent to our September 15, 1978 meeting, we have identified two other factors that you should consider. With regard to proposed alternative approach (1), we believe that the matter of modifications in the fuel design could be treated in a manner similar to that used in the review of GESSAR-238 Nuclear Island (Docket No. STN 50-447).
In that case, changes in the fuel design similar to the ones you described for RESAR-35 were identified, and we concluded that they were of the type that could be addressed in the utility-applicant's OL application or the FDA application.
Based on our understanding of the changes envisioned for the RESAR-35 fuel design, we believe that the same approach would be acceptable for RESAR-3S.
Mr. Tom M. Anderson M
- 7 I9 76 The matter of licensing fees should also be considered. The question of whether or not licensing fees will be assessed for the PDA extension reviews was not addressed in the Comission's August 22, 1978 Policy Statement on Standardization. The Comission has this matter under con-sideration.
We will advise you of the Commission's decision on this matter as soon as it becomes available.
In alternative approach (2),
your proposed course of action to include design changes outsica the context of the PDA extension review would, we believe, result in a license fee being charged for the review of such design changes. This license fee would probably be in the context of a PDA amendment which would allow for full cost recovery for the staff review. We would note that there is no ceiling in the current rule on fees charged for the review of PDA amendments.
In alternative approach (3), licensing fees appropriate for a new PDA review would be charged.
In this case, the fee would be limited to the $50,000 application fee until a utility application refer-enced that design. An appropriate licensing fee would be charged for the review of the FDA application discussed in alternative approach (4).
As in the case of approach (3), the fee would be limited to the $50,000 application fee until a utility application referenced the design.
From the limited information which you presented to us on September 15, 1978, all four of your proposed licensing alternatives offer means of accomplishing your stated objectives. The decision as to which approach will be used to update the RESAR-35 design is yours. However, based on the above discussion, approach (1) appears to warrant particular attention.
We hope that we have been responsive to your concerns.
If you have any questions concerning our comments, please let us know.
Sincerely, D Q.*J n
~
Roger S. Boyd,c j[ector Division of Project Management Office of Nuclear Reactor Regulation