ML19274E846

Requests Info Re Fees Required for Final Design Approval for Standardization Design Under Ref Sys Concept

ML19274E846
Person / Time
Site:	05000447
Issue date:	02/20/1979
From:	Sherwood G GENERAL ELECTRIC CO.
To:	Donoghue D NRC OFFICE OF ADMINISTRATION (ADM)
Shared Package
ML19274E845	List: ML19274E846
References
MFN-045-79, MFN-45-79, NUDOCS 7904280147
Download: ML19274E846 (2)

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PROJECTS DIVISIO N GENERAL ELECTRIC COMPANY,175 CURTNER AVE. SAN 'OSE. CALIFORNIA 95125 '~

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February 20, 1979  :

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U. S. Nuclear Regulatory Commission ' " " " " .. oc'd...

Washington, D. C. 20555 "'id U-j Attention: Mr. Daniel J. Donoghue, Director Office of Administration Gentlemen:

SUBJECT:

FEES FOR A FINAL DESIGN APPROVAL (FDA) FOR A STANDARDIZED DESIGN UNDER THE REFEREllCE SYSTEM C011 CEPT During planning for the submittal of an application for a FDA, our review of Part 170 of Title 10 of the Code of Federal Regulations, concern-ing fees, raised several questions. There are no provisions for an application containing both the Nuclear Steam Supply System (NSSS) and a major fraction of the Balance of Plant (BOP), such as our fluclear Island (NI) design. Our NI design was the first standard plant docketed under the reference system concept and encompasses the entire plant except for the turbine building, the switch yard, and the site-related cooling water systems. The only fee provisions in Part 170 are for separate reviews for the NSSS and the BOP with an application fee for each. The review of a NI design is simpler than the review of separate NSSS and 80P designs. For example, the quality assurance program requires ',

only one review, and the number of interfaces is substantially reduced.

It is our feeling that in all fairness the fee for a NI design review should consist of one application fee, the fee for NSSS approval, and a reduced fee for BOP approval.

Another area of uncertainty exists with regard to footnote 3 to the table in paragraph 170.21. We are considering including several different sizes of reactors in our NSSS application and providing separate information for each size only where there is a dif ference due to size. Such a review for several sizes should not be much more demanding than a review for a sir.gle size. Footnote 3 could be interpreted to imply that each design would be subject to the maximum fee, the sum of the application fee and the approval fee. rather than limited to a fee reflecting only

,_ the actual costs incurred. Such an interpretation would, in our cpinion,

'."*.., _ 7 4 h sive and woulc. not reflect the fee schedule philosophy.

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GEi;EF. Al s.[ ELECTRIC U. S. Nuclear Regulatory Commission Page 2 In order to finalize our plans to submit an application for a FDA, we will need clarification of these uncertainties and would welcome the opportunity to discuss our thoughts with you.

Very truly yours,

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(<u .AHAY Glenn G. Sherwood, Manager Safety and Licensing Operation GGS:mm/948-949

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