ML19345F659
| ML19345F659 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 01/29/1981 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Ewing T PUBLIC SERVICE CO. OF OKLAHOMA |
| References | |
| NUDOCS 8102180826 | |
| Download: ML19345F659 (2) | |
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NUCLEAR REGULATORY COMMISSION WASMNGTON, D. C. 20555
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0E Decket Hos. STN 50-556/557 Mr. T. N. Ewing, Manager Black Fox Station Nuclear Project Public Service Ccmpany of Oklahoma P. O. Box 201 Tulsa, Oklahoma 74102
Dear Mr. Ewing:
SUBJECT:
ACRS REPORT ON REQUIRENENTS FOR HEAR-TERM cps A copy of a letter to Chaiman Ahearne dated January 12, 1981 concerning the Advisory Committee on Reactor Safeguards' review of the requirements for Near-Term Construction Permit applications, is enclosed for your information.
incerely
/ fggf/d84 A. Sc'hwencer, Chief Licensing Branch No. 2 Division of Licensing
Enclosure:
As stated cc w/ enclosure:
See next page fg'th'tb
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9 Mr. T. N. Ewing, Manager Black Fox Station Nuclear Project JAli 3 3 jeg7 Public Service Company of Oklahoma P. O. Box 201 Tulsa, Oklahoma 74102 cc: Mr. Vaughn L. Conrad Andrew T. Dalten Jr., Esq.
Public Service Company of Oklahoma 1437 South Main Street P. O. Box 201 Tulsa, Oklahoma 74119 Tulsa, Oklahoma 74102 Joseph R. Farris, Esc.
Paul M. Murphy, Esq.
Green, Feldman, Hall & Woodard Isham, Lincoln & Beale 816 Enterprise Building One 1st National Plaza Tulsa, Oklahoma 74103 Suite 4200 Chicago, Illinois 60606 Sheldon J. Wolfe Esq.
Atcmic Safety and Licensing Board Mr. Joseph Gallo, Esq.
U. S. Nuclear Regulatory Commission Isham, Lincoln & Beale Washington, D. C.
20555 1050 17th Street, N. W.
Washington, D. C.
20036 Dr. Paul W. Purdom, Director Environmental Studies Group Dr. M. H. Robinson Drexel University Black & Veatet 32nd and Chestnut Streets P. O. Box 8405 Philadelphia, Pennsylvania 19104 Kansas City, Missouri 64114 Mr. Frederick J. Shon Mr. Maynard Human Atomic Safety and Licensing Board General Manager U. 5. Nuclear Regulatory Comnission Western Farmers Electric Cooperative Washington, D. C.
20555 P. O. Box 429 Anadarko, Oklahoma 73005 Jan Eric Cartwright, Esq.
Attorney General Mr. Gerald F. Diddle State of Oklahcma General Manager 112 St.te Capitol Building Associated Electric Cooperative, Inc.
Oklahoma City, Oklahoma 73105 P. O. Box 754 Springfield, Missouri 65801 ATTN: Charles S. Rogers, Esq.
Ms. Carrie Dickerson Citizens Action for Safe Energy, Inc.
P. O. Box 924 Claremore, Oklahona 74107 Ms. Ilene H. Younghein 3900 Cashion Place Oklahoma City, Oklahoma 43112
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UNITED STATES
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January 12, 1981 Honorable John F. Ahearne Chainnan U.S. Nuclear Regulatory Commission Washington, D. C. 20555
SUBJECT:
REQUIREMENTS FOR EAR-TERM CONSTRUCTION PERMIT APPLICATIONS
Dear Dr. Ahearne:
During its 249th meeting, January 8-10, 1981, the ACRS again reviewed the status of the requirements fo-near-term construction pennits (NTCPs). The Conuittee reported to you previously on this subject in a letter dated May 6, 1980.
In the cresent review we had the benefit of a Subconnittee 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 apolicant for a manufacturing license (ML).
In our letter of May 6, 1980 we noted that the utility representatives had advised the Connittee that thcre was a need for resolution of several policy issues which related to how and whether construction pennit applica-tions would be processed in the near tenn. The principal policy issues identified dealt with siting, degraded core conditions, reifability and risk assesanent, and emergency planning.
In May 1980, the utilities expressed a l
desire to have the chance to propose an acceptable interim approach to resolu-l tion of these issues. However, the utilities did not present any common proposal *r dealing with this matter during the next several months.
The NRC Staff did develop a proposed policy and on October 2,1980 the NRC published for comment in the Federal Register " Proposed Licensing Requirements for Pending Construction Pennit and Manufacturing License Appifcations." The Federal Register notice identified the following three options as having been considered by the E C Staff.
Resume licensing using the pre-TMI CP requirements augmented by the 1.
applicable requirements identified in the TMI Action Plan, NUREG-06o0.
In effect, this treats the Cending CP and ML appifcations 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 the Action Plan have been com-pleted. This would, in effact, treat the pending appifcations as the first of a new generation of nuclear power plants.
Resume licensing using the pre-TMI CP and ML requirements augmented 3.
by the applicable requirements identified in the TMI Action Plan, NUREG-06c0, and require certain additional measures or commitments in related areas, e.g., those that would be the subject of rulemaking.
BIDit w3r8
Honorable John F. Ahearne January 12, 1981 1
The MC Staff favored Oction 3 as a suitable compromise and identified their current positions for NTCP and ML plants with regard to siting, degraded core rulmaking, reliability engineering and emergency preparedness.
The coments from representatives of the nuclear industry on the proposed licensing requirements generally opposed the Staff's preference for Option 3, and favored Option 1.
In addition to opposing additional requirements for NTCP plants, the industry representatives argued that the Staff's position concerning degraded core rulemaking was open-ended and would lead to protrac-ted delays and case-by-case adjudication of the satter at ASLB hearings.
Industry representatives provided a varied set of comments concerning relf-ability engineering and argued against adoption of tne EC Staff's position on siting. Offshore Power Systems favored Option 1 but stated that they believed they could live with Option 3.
During the 249th ACRS meeting, the RC Staff advised the Comittee that it now favored adoption of a revised Option 3.
The new NRC Staff position was described as follows:
Emergency Precaredness rne Commission nas adopted a rule which addresses this subject. The NTCP Applicants will be required to comply with this rule.
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Siting In viGw of the demographic and hydrological characteristics of the proposed sites, no additional measures with regard to siting would be rer,uired in cP1nection with these construction pernit applications.
Reliability Engineering Eacn applicant would be required to submit a site / plant probabilistic l
risk assessment as part of the application for an operating license.
l Degraded Core Rulemaking In oroer to minimize foreclosure of plant modifications in the struc-tural design area, at least thnse applicants wtose designs incorporate a relatively low-design-pressure reactor containment would have to strengthen the containment structure against internal pressure.
In addition, all applicants would be required to constit to making provi-sions for an approximately three foot diameter, or equivalent, contain-ment penetration which could be used 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 accroach on siting. 'de al so l
agree with the current NRC Staff position on reliability engineering. During the discussion with us, the RC Staff indicated that, although they did not propose making a formal requirement to that effect, one intent of the ;:roposed position on reliability engineering was to strongly encourage each applicant l
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Honorable John F. Ahearne January 12, 1981 to perfor n the relevant portions of the probabilistic assessment early enough that the results could be factored into a safety-related reliability optimi-zation of the design. We strongly support this point of view and recommend that each appifcant give high priority to such efforts.
The NRC Staff's position on the degree of containment strengthening that should be required had not yet been definitively fomulated by the time the 249th ACRS meeting was held. Since the NRC Staff's position was new, industry representatives did not have time to review the position and provide comments.
Furthermore, we were advised by representatives of the Houston Lighting and Power Company, the Applicant for the Allens Creek Nuclear Generating Station, that they had authorized a study of possible 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 of 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 degraded core rulemaking on NTCP plants.
However, we believe that the EC Staff needs to define its proposal more precisely. We believe that both the RC Staff and the ACRS should have the benefit of further discussions with the NTCP and ML applicants.
Hence, we recanmend that the Nuclear Regulatory Commission defer any final action on the overall matter at least until after the 25Cth ACRS meeting on February 5-7, 1981 during which this matter is scheduled for discussion.
Sincerely, j
h J. Carson Mark
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Chaiman e
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