ML19289C827
| ML19289C827 | |
| Person / Time | |
|---|---|
| Site: | 05000484 |
| Issue date: | 01/12/1979 |
| From: | Licitra E Office of Nuclear Reactor Regulation |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7901250249 | |
| Download: ML19289C827 (8) | |
Text
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united starts NUCLEAR REGULATORY COMMisslON i.
WASHINGTON, D. C. 20555 s....,
JAN 121979 MEMORANDUM FOR: Harold R. Denton, Director, Office of Nuclear Reactor Regulation TliRU:
Domenic B. Vassalo, Assistant Director for Light Wate Reactorc, Division of Project Management FROM:
Emanuel Licitra, Project Manager, Light Water Reactors Branch No. 3, Division of Project Management
SUBJECT:
SulPARY OF MEETING HELD WITH POST-CP APPLICANTS TO DISCUSS OL REVIEW MATTERS At the request of Mr. Harold Denton, Director, NRR, a meeting was held on December 13, 1978 in Bethesda, Maryland with representatives of the utilities, listed in Enclosure 1, with pending OL applications. The purpose of the meeting was to discuss (1) staff policies regarding the review of the pending OL applications, and (2) the criteria for establishing priorities for the review of those applications. The areas of discussion are identified in. provides a list of the attendees.
Introduction Mr. Denton stated that we recently held meetings with applicants, for whom we are currently reviewing CP or OL applications, to discuss review schedule matters and staff resources. At those meetings, we had discussed the scope of OL review matters, including the resolution of recurring issues, and the method for establishing review priorities. Since the matters discussed at those meetings are applicable to the review of pending OL applications, Mr. Denton indicated that he thought it a9propriate to also discuss those matters with the post-CP applicants.
Review Scope We stated that we currently use the Standard Review Plan in our review of applications. Since issuance of the Standard Review Plan, staff manocwer requirements have increased due to its use. Experience gained from currently operating reactors have also increased staff manpower requirements for case reviews. For example, in 1975, DSS needed about 500 man days to review an OL application but now takes about 1700 man days. Evaluation of novel features, such as a computer protection system, further increase staff manpower requirements.
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Harold R. Denton JAN 121979 Our review of OL applications will include an evaluation cf Standard Review Plan deviation > - Since most, if not all, plants currently in the post-CP stage were origi.. lly reviewed prior to issuance of the Standard Review Plan, certain aspects of these applications may have been accepted on some other defined basis.
Therefore, where deviations with the Standard Review Plan exist, the staff will be required to identify the basis for acceptance in the SER.
During the course of our OL reviews, we will also consider Category 2, 3 and 4 items. Category 2 and 3 items per'.ain to new regulatory guides or branch technical positions, or changes to existing guides and positions, which the Regulatory Requirements Review Comittee (RRRC) has approved for backfit on all plants (Category 3) or backfit on a case by case basis
' Category 2). Category 4 items pertain to matters which have not been processed through the RRRC but have been approved by Mr. Denton for application on a case by case basis. Copies of the current Category 2, 3 and 4 items have been transmitted to the post-CP applicants so that they may be considered in the preparatinn of their FSAR's. Mr. Denton pointed out that future considerations by the RRRC on new guides and positions will include a period for public comment before any final decisions are made.
An additicnal review requirement has been imposed by an Appeai Board decision regarding generic issues (ALAB-444). That decision states that with regard to unresolved generic issues, the staff should provide the basis for continuing licensing and plant operations while the generic issue is being resolved.
Therefore, this matter will also be considered in our review of OL applications.
Mr. Denton stated that we have proposed a list of 14 items to the Comission that are currently considered " unresolved safety issues." These issues are a subset of the generic issues which are encompassed by the ALAB-444 decision.
We stated that, because of the above considerations, the staff review of an OL application currently takes about 24 months to complete.
In order to minimize staff manpower requirements, we attempt to perform a common review for similar plants or plant features, where appropriate.
In this regard, Mr. Denton stated that the post-CP applicants should maintain an awareness of how we are resolving issues for plants currently under review which are similar to their plants.
Mr. Denton stated that industry can help minimize manpower review requirements by facing up to review issues sooner and by utility management focussing attention on these issues. He added that, with the existence of the Standard Review Plan, the identification of Category 2, 3 and 4 items, and the public awareness of matters to be considered by the RRRC, our requirements for acceptance are all out in the open.
In this regard, Mr. Denton stated that we would not resort to " arm twisting" to resolve issues and that we would be prepared to go forward to the ACRS or to hearings with differences of opinion if the staff and an applicant cannot reach agreement on an issue.
Harold R. Denton JAN 121979 In response to a question, we stated that if an applicant requests an appeal meeting regarding differences of opinion between the staff and the applicant, ti.e appeal process should start from the lower levels and proceed up to the next level until the issue is resolved. Appeals of Category 2, 3 or 4 items should go directly to Mr. Denton's level since the Director of NRR has already approved these items for consideration in the review process.
Another suggestion for minimizing schedule delays was to have applicants present novel ideas as soon as possible. We also suggested that industry should think of and recommand other ways to streamline the review process.
In this regard, General Electric plans to meet with us shortly to present their views on the subject.
Submittal of OL Applicants and Establishment of Review Schedule We stated that an applicant should submit its GL application about 30 months before the projected fuel load date. This submittal time will accommodate a 24 month staff review period, but time only for a limited hearing, if required.
In order to provide the staff with realistic fuel load dates for manpower planning purposes, we utilize the NRC's Caseload Forecast Panel. This panel has established a model which is useful in estimating the fuel load date based on past experience.
In order tc allocate available staff resources, the panel's forecasted date is also utilized in establishing priorities for the review of OL applications.
In establishing review priorities within NRR, operating reactors receive top priority, followed by OL applications and then CP applications.
Where the Caseload Forecast Panel's forecasted fuel load date differs significantly from an applicant's forecasted date (usually because an applicant will use the earliest achievable date), an attempt is made to reconcile the difference via a site visit prior to OL tendering.
In any case, the initial review schedule will be established on the basis of at leart meeting the Caseload Forecast Panel fuel load date.
In response to a question, we stated that adjustments to the review schedule (and priorities) can be made, if necessary, but not before the Q-1 phase of review nas been completed. Also, the Caseload Forecast Panel will reassess its forecasted fuel load dates on a regular basis, based on changes in the status and pace of construction. The next reassessment is planned for around March of 1979.
Harold R. Denton JM i g 1979 Other Discussion Items Dr. Mattson stated that one of the major "ecurring issues during an OL review has been the issue regarding environmenta: qualification of electrical equi pment. He is concerned that industry's performance to date in resolving this matter has been unsatisfactory. This is an issue that an applicant clearly should have control over. An applicant should not depend on the NRR audit of the qualifications as a substitute for the applicant's QA function.
Dr. Mattson recomended a more conserted effort on the part of the utilities to resolve this matter. He cautioned against "re-inventing the wheel" on every case. Once it is determined that an item of equipment is environmentally qualified for one plant, it is quite likely that the results may be applicable to other similar plants.
Mr. Denton discussed the accelerated review which is being performed for Palo Verde 4 & 5 in accordance with the recommendations of NUREG-0292. The review process includes dedicated reviewers and public meetings near the site area. Public meetings have also been held for the Fort St. Vrain and Duane Arnold plants. Additional public meetings for other plants are tentatively planned on a monthly basis (i.e., each month hold a public meeting for a different plant).
Mr. Denton pointed out that, with regard to Category 2, 3 and 4 items for Palo Verde 4 & 5, the applicant has indicated that it will also implement these items on Palo Verde 1, 2 & 3.
He stated that the Palo Verde applicant estimates that the total cost of implementing applicable Category 2, 3 and 4 items on Palo Verde 1, 2 & 3 is about $25 million for all three units and that most of this expense is due to the requirements for industrial security, fire protection and venting of the main steamline compartment.
Mr. Denton stated that the Commissioners set their regulations to be minimum standards which should be met. Exemptions froni these regulations will be considered if the health and safety of the public is not affected.
If such exemptions are required, they should be identified early since they require Mr. Denton's approval and, possibly, Comission approval.
Mr. Denton pointed out that the Comission receives various petitions from the public proposing actions for the Commission to take (either on a generic basis or en an individual license application). Such petitions are acted on expeditiously. Any petitions filed by industry (regarding proposed Commission action or changes in regulation) would receive similar prompt attention.
In response to a question, Dr. Mattson stated that if an applicant finds that it is not getting timely attention from members of DSS, the applicant should bring the situation to his attention.
M I 2 573 Harold R. Denton 5
Other matters dicsussed included:
(1) Tooical Reports - Applicants should focus on any referenced topical reports in an FSAR which we have not yet approved.
These topical reports will recuire utility attention to assure that the vendors resolve any problems with the reports in a time frame that is compatible with the schedule for cocpletion of the FSAR review.
(2) Pretenderino Meetings - We stated that we would be receptive to pretencering meetings with an applicant for the purpose of providing guidance in specific areas to assist in the preparation of an FSAR.
(3) Standard Format - Revision 3 to the Standard Format for Safety Analysis Reports was recently issued and should be followed for SAR's submitted after one year of the Revision 3 issuance date.
However, changes are in substance, not format, cccpared to Revision 2 of the Standard Format.
(4) Blue Book - The blue book will be made public shortly. (It is published every other month).
W Emanuel Licitra, Project Manager Light Water Reactors Branch No. 3 Division of Project Manage.ent
Enclosures:
As Stated
List of Attending Utilities Decemben 13, 1978 Meeting Carolina Power and Light (Harris 1-4)
Cleveland Electric Illuminating (Perry 1 and 2)
Duquesne Light (Beaver Valley 2)
Florida Power and Light (St. Lucie 1 and 2)
Gulf States Utilities (River Bend 1 and 2)
Illinois Power (Clinton 1 and 2)
Jersey Central Power and Light (Forked River)
Kansas Gas and Electric (Wolf Creek)
Niagara Mohawk Power (Nine Mile Point 2)
Northeast Nuclear Energy (Millstone 3)
Northern Indiana Public Service (Bailly)
Northern States Power (Tyrone)
Philadelphia Electric (Limerick 1 and 2)
Public Service of Indiana (Marble Hill 1 and 2)
Public Service of New Hampshire (Seabrook I and 2)
Rochester Gas and Electric (Sterling)
Union Electric (Callaway 1 and 2)
Virginia Electric and Power (North Anna 3 and 4) m
ENCLOSURE 2 AGENDA MEETING WITH POST-CP APPLICANTS DECEMBER 13, 1978 OPENING REMARKS POLICIES AND PRACTICES ON CONDUCTING OPERATING 8.)
(dSE REVIEWS -
Standard Format and Content Guide - applicability of Rev. 2 and 3.
Category I through 4 matters - handling of.
Proposed approach to handling Regulatory Requirements Review Comnittee (RRRC) matters.
Use of Standard Review Plan (SRP).
Handling of SRP deviations - implementation of Office Letter No. 9.
Generic items - handling of by staff and participation by applicants and industry in resolving.
Referencing of Topical Reports.
- Handling of applicant appeals of staff positions.
SCHEDULING
- Optimum time for docketing of OL application.
Use of NRC Case Forecast Panel in establishing construction completion dates for developing OL review schedule.
Development and use of staff review priority list.
APPLICANT COMMENTS
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ENCLOSURE 3 LIST OF ATTEN0EES NRC REPRESENTATIVES H. Denton NRR NRR, DPM R. Boyd NRR, DSS R. Mattson NRR, DSE R. DeYoung NRR, DPM D. Ross D. Vassallo NRR. 004 NRR, DPM E. Licitra NRR, DPM H. Berkow NRR, OPM B. Kirschner PLA S. Kari ACRS Staff P. Boehnert UTILITY REPRESENTATIVES Rochester Gas & Electric Corporation John Arthur Paul Wilkens Rochester Gas & Electric Corporation Virginia Electric & Powar Company E. Ashby Baum SNUPPS ( Also representing Northern States Power Co.)
E. Beckett SNUPPS N. A. Petrick Public Service of New Hamoshire Bruce Beckley Public Service of New Hampshire D. N. Merrill Northern Indiana Public Service Comcany E. M. Shorb Northern Indiana Public Service Company R. J. Bohn Gulf States Utilities Cc. :any J. E. Booker W. G. Counsil Northeast Utilities Servi:e Company Northeast Utilities Serv e Company J. P. Cagnetta Jim Coughlin Public Service of Indiar D. R. Davidson Cleveland Electric Illu
.atinq Company Gary Groscup Cleveland Eleccric Illum;aating Company J. A. neMastry Florida Power & Light Company C. S. Kent Florida Power % Licht Compary Orin F. Pearson Florida Power & Liqht Company Robert C. Hagan Kansas cas & Electric Company Gene P. Rathban Kansas Gas & Electric Company Philadelphia Electric Company H. D. Honan R. H. Logue Philadelphia Electric Company P. W. Howe Carolina Power A Light Company M. A. McDuffie Carolina Power & Light Company S. F. Manno Niagara "ohawk Company C. V. Mangan Niagara Mohawk Company E. J. Woolever Quouesne Liqht Company R. E. Martin Ouquesne Light Company Ted J. "yers GPU Service Corporation Edward Wallace GPU Service Corporation A. C. Passwater Union Electric Company D. F. Schnell Union Electric Company