ML20008F567

Urges Inclusion of OPS Mfg License Application in Proposed Rulemaking Defining TMI accident-related Requirements for Pending CP & Mfg Licenses

ML20008F567
Person / Time
Site:	Atlantic Nuclear Power Plant
Issue date:	02/24/1981
From:	Collier A OFFSHORE POWER SYSTEMS (SUBS. OF WESTINGHOUSE ELECTRI
To:	Ahearne J, Bradford P, Gilinsky V NRC COMMISSION (OCM)
Shared Package
ML20008F565	List: ML20008F567
References
ARC-81-985, NUDOCS 8104210261
Download: ML20008F567 (2)

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ARC-81-935 Offshore Power Systems February 24, 1931 ,

John F. Ahearne, Chairman Victor Gilinsky, Commissioner Peter A. Bradford, Commissioner -

Joseph M. Hendrie, Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555

' Gentlemen:

A. R. Ctllier ornet Re: Policy on Proceeding with Pending Construction Permit and Manufacturing License Applications The Commission currently is considering whether 'he t Offshore Power Systems application for a Manufacturing License should continue to be included within the scope of applicability of the rules presentiy under consideration for proceeding with pending Construction Permit and Manufacturing License applica-tions. The Manufacturing License is included in the published Notice of Proposed Rulemaking (45 FR 65247); exclusion of the

'Jffshore Power Systems application would constitute a laterial departure from that notice.

Offshore Power Systems believes that simple fairness as well .,

as our right to equitable treatment under the Commission's regulations require that the standards which will be adopted for near-term Construction Permit applications should remain

applicable to the Manufacturing License application, as originally proposed. Because of the importance of this question to the future of the standardized Floating Nuclear Plant concept, Offshore Power Systems is compelled to express its views to the Commission.

By any measure of licensing progress, the Manufacturing License application is properly included in the near-term group.

Actions to obtain the Manufacturing License have been viar-ously pursued since 1973. The public hearing record is complete, except .for post-TM1 matters, and presently stands at nearly 8000 pages of transcript. Proposed findings cf fact

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have been submitted to the hearing board by both Offshore Power Systems'and the Staff. Offshore Power Systems responses to the post-TMI requirement published in NUREG-0660 were L

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February 24, 1981 submitted for Staff review in July 1980. In this important regard, the Offshore Power Systems applica-

, tion is one of the most advanced of the entire near-term group. j Offshore Power Systems has made a substantial investment in the Floating Nuclear Plant concept. To date 125 million dollars have been invested in the manufacturing facility at Jacksonville, Florida. In addition over 2000 man-years of .

effort and an additional 63 million dollars have been devoted to design and licensing of the Floating Nuclear Plant. These commitments were based in part on our belief that the standards which would be applied to the Manufacturing License are those which apply to other similar light water reactors with only such distinctions as are set out in 10CFR50, Appendix M. In our view, the question before the Commission suggests that you do otherwise.

Implicit in the eleventh-hour suggestion to segregate Offshore '

Power Systems from the other near-term applicants is an arbitrary standard of commercial success which is completely at odds wi?.h the Manufacturing License concept a.5 embodied in the Commission's regulations (principally 10CFR50, Appendix M).

Under the Manufacturing License concept, manufacturers are encouraged to license total plant designs for sale and ultimate manufacture. Having obtained Commission approval, in the form of a Manufacturing License, the manufacturer is able to offer a standardized product of proven viability. This is the manufacturer's incentive to make the substantial investment ,

required to construct a manufacturing facility and license the product.

The Manufacturing License appears to be a pre-requisite for the sale of a Floating Nuclear Plant. Failure to apply the pre-

, sently proposed standards to the Manufacturing License will delay a decision to the indefinite future and in our view is tantamount to denial of the licens~e.

Offshore Power Systems will be pleased to provide any further l' information the Con. mission may desire in connection with this l

. important matter including appearance at a Comission meeting if desired.

Sincerely, i

A. R. Collier

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