ML19343C172

Forwards ACRS to Chairman Ahearne Re Review of Requirements for near-term CP Applications

ML19343C172
Person / Time
Site:	Perkins
Issue date:	01/26/1981
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Dail L DUKE POWER CO.
References
NUDOCS 8102180858
Download: ML19343C172 (2)

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DISTRISIITint it KL/ t'UN L/PDR JAN 2 6196f LB#1 Reading 3 :.: tiSIC CMoon TERA MRushbrook o u:. ACRS Docket Nos.:

STN 50-489 MSe rvice and o ou-*:s GZech NHughes SCavanaugh Duke Power Comcany BJYoungbicod ATTN: Mr. L. C. Dail, Vice President Design Engineering P. O. Box 33189 Charlotte, North Carolina 28242

SUBJECT:

ACRS REPORT ON REQUIREMENTS FOR NEAR-TERM CP'S A copy of a letter to Chairman Ahearne dated January 12, 1981 conceming the Advisory Comittee on Reactor Safeguards' review of the requirements for near-tenn construction permit applications is enclosed for your information.

Sincerely, B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing

Enclosure:

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Duke Power Company Ccs:

William L. Porter, Esq.

Associate General Counsel P. O. Box 33189 Duke Power Conpany Charlotte, North Carolina 28242 J. Michael McGarry, !!!, Esq.

Debevoise & Libennan 1200 Seventeenth Street, N.W.

Washington,D. C. 20036 Willian A. Raney, Jr.

Special Deputy Attorney General P. O. Box 629 Raleigh, North Carolina 27602 Mary Apperson Davis, Chairman Yadkin River Committee Route 4, Box 261 Mocksville, North Carolina 27028 William G. Pfefferkorn, Esq.

2124 Wachovia Building Winston-Salem, North Carolina 27101 Elizabeth S. Bowers, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Connission Washington, D. C. 20555 Dr. Donald P. deSylva Associate Professor of Marine Scie. e Rosenstiel School of Marine and Atmospheric Science University of Miami Miami, Florida 33149 Or. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 l

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January 12, 1981 Honorable John F. Ahearne Chaiman U.S. Nuclear Regulatory Comission Washington, D. C. 20555

SUBJECT:

REQUIREMENTS FOR EAR-TERM CC1STRUCTION PERMIT APPLICATIONS

Dear Dr. Ahearne:

During its 249th meeting, January 8-10, 1981, the ACRS again reviewed the status of the requirements for near-tern construction permits (NTCPs).

The Comittee reported to you previously on this subject in a letter dated May 6, 1980.

I. the present review we had the benefit of a Subcomittee meeting on January 6,1981 and of discussions with members of the NRC Staff and with representatives of applicants for NTCPs and Offshore Power Systems, the applicant for a manufacturing license (ML).

In our letter of May 6,1980 we noted t1at the utility representatives hed advised the Comittee that there wa; a need for resolution of several pol lcy issues which related to how and,hether construction pemit applica-t tns would be processed in the near temt. The principal policy issues identified dealt with siting, degraded : ore conditions, reliability and risk assessment, and emergency planning.

In May 1980, the utilities expressed a desire to have the chance to propose an acceptable interim approach to resolu-tion of these issues. However, the uti'ities did not present any common proposal for dealing with this matter during the next several months.

The NRC Staff did develop a proposed po! icy and on October 2,1980 the NRC published for comment in the Federal Register " Proposed Licensing Requirements for Pending Construction Pemit and Manufacturing License Applications." The Federal Register notice identified the following three options as having been considered by the NRC Staff.

1.

Resume licensing using the pre-TMI P requirements augmented by the applicable requirements identified in the TMI Action Plan, NUREG-0660.

In effect, this treats the pending CP and ML applications as if they were the last of the present generation of nuclear power plants.

2.

Take no further action on the pending CP and ML applications until the rulemaking actions described in th Action Plan have been com-pleted. This would, in effect, treat the pending applications as the first of a new generation of nuclear power plants.

3.

Resume licensino using the pre-TMI CP and ML requirements augmented by the applicable requirements identified in the TMI Action Plan, NUREG-0660, and require certain additional measures or commitments in related areas, e.g., those that would be the subject of rulemaking.

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Honorable John F. Ahearne January 12, 1981 The NRC Staff favored Option 3 as a suitable c:mpromise and identified their current positions for NTCP and ML pl ints with regard to siting, degraded core rulemaking, reliability enginee-ing and emergency preparedness.

The comments from representatives of the nuclear industry on the proposed licensing requirements generally oppised the Staff's preference for Option 3, and favored Option 1.

In addition t3 opposing additional requirements for NTCP plants, the industry representa-ives argued that the Staff's position concerning degraded core rulemaking was open-ended and would lead to protrac-ted delays and case-by-case adjudica: ion of the matter at ASL3 hearings.

Industry representatives provided a raried set of comments concerning reli-ability engineering and argued against 1doptio.1 of the NRC Staff's position on siting. Offshore Power Systems favc ed Option 1 but stated that they believed they could live with Option 3.

During the 249th ACRS meeting, the NRC Staff advised the Committee that it now favored adoption of a revised Option 3.

The new NRC Staff position was described as follows:

Emercency Precaredness The Ccemission nas adopted a rul a which addresses this subject. The NTCP Applicants will be required to comply with this rule.

Siting i

In view of the demographic and h:>drological characteristics of the l

proposed sites, no additional me.sures with regard to siting would be required in connection with these construction pennit applications.

Reliability Engineering Each applicant would be required to submit a site / plant probabilistic risk assessment as part of the aaplication for an operating license.

Degraded Core Rulemaking In order to minimize foreclosure of plant modifications in the struc-tural design area, at least those applicants whose designs incorporate a relatively low-design-pressure reactor containment would have to strengthen the containment struc;ure against internal pressure.

In addition, all applicants would be required to comit to making provi-sions for an approximately three foot diameter, or equivalent, contain-ment penetration which could be ased in conjunction with a filtered venting design feature, should the latter be judged to be needed.

We agree with the NRC Staff's currently proposed approach on siting. We also agree with the current NRC Staff pos: tion on reliability engineering. During the discussion with us, the NRC Staf' indicated that, although they did not propose making a formal requirement o that effect, one intent of the proposed position on reliability engineering.as to strongly encourage each applicant i

Honorable John F. Ahearne January 12, 1981 to perform the relevant portions of the probabilistic assessment early enough that the results c >uld be factored inte a safety-related reliability optimi-zation of the des.gn. We strongly suppcet this point of view and reccamend that each applicant give high priority c such efforts.

The NRC Staff's position on the degree of containment strengthening that should be required had not yet been def nitively formulated by the time the 249th ACRS meeting was held. Since the NRC Staff's position was new, industry representatives did not have t me to review the position and provide comments.

Furthermore, we were advised by represe"catives of the Houston Lighting and Power Company, the Applicant for the Al ens Creek Nuclear Generating Stction, that they had authorized a study of pos:ible accident prevention and mitigation features for their plant in order to ascertain the advantages, disadvantages, and practicality of these features. The results of this study are to be presented to Houston Lighting and Power in mid-January and representatives af the company requested an opportunity to meet with the ACRS in early February to discuss these results.

We agree with the general approach outlined by Harold Denton at the 249th ACRS meeting concerning provisions for degraced core rulemaking on NTCP riants.

However, we believe that the NRC Staff ieeds to define its proposal more precisely. We believe that both the NR: Staff and the ACRS should have the benefit of further discussions with the NTCP and ML applicants.

Hence, we recommend that the Nuclear Regulatory C mission defer any final action on the overall matter at least until after the 250th ACRS meeting on February 5-7, 1981 during which this matter is schedu;ed for discussion.

3incerely, J. Carson Mark

hainnan I

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