ML20028H349
| ML20028H349 | |
| Person / Time | |
|---|---|
| Issue date: | 12/20/1990 |
| From: | Harold Denton NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | |
| References | |
| SECY-90-414, NUDOCS 9012310097 | |
| Download: ML20028H349 (86) | |
Text
WMMMMMMMMMA!WMM(M.
RELEASED TO THE POR; L
- M /9/
cg_.
j ff..g#g I....D........) $,j 2
3
\\...../
POLlCY ISSUE I
(NEGATIVE CONSENT)
December 20, 1990 SECY-90-414 f_qr:
The Commissioners From:
Harold R. Denton, Director Office of Governmental and Public Affairs Subiect:
MEETING WITH INDONESIAN STATE MINISTER FOR RESEARCH AND TECHNOLOGY B. J. HABIBIE (OCTOBER 5, 1990)
Purpose:
To advise the Commission of (1) the discussions that took place during the subject meeting at NRC, particularly of Dr. Habibie's request for NRC regulatory oversight of any U.S. advanced reactor that might be ordered, and (2) the letter I plan to send Dr. Habibie in followup to the meeting.
Backaround:
At the request of the Department of State, I met on October 5 with Indonesian State Minister for Research and Technology B. J. Habibie, who was beginning a month-long U.S. technology tour with two days in Washington, to discuss nuclear power plant construction and operation, with specific reference to NRC's attempts to streamline the licensing process. Jim Shea and Donna Chaney from the Office of Governmental and Public Affairs, International Programs, and Susan Bilhorn from Commissioner Rogers' staff were also in attendance. We were advised shortly t,efore the meeting that Dr. Habibie would be accompanied by the delegation listed in Attachment 1.
Discussion:
Dr. Habibie indicated that indonesia plans to build twelve 600 MWe nuclear power plants over the next 15-20 years, with construction to start on the first in 1996 and operation projected for 2003. He is talkir.g with U.S, French, and German vendors.
In the U.S., his primary interest lics with the evolutionary Westinghouse AP-600 and General Electric (GE) SBWR designs.
Indonesia, at Westinghouse's invitation, has seven nuclear engineers assigned to Westinghouse-Pittsburgh on the design development team.
- BATAN, CONTACT:
D. Chaney, IP NOTE:
TO BE MADE PUBLICLY AVAILABLE x20644 WHEN THE FINAL SRM IS MADE AVAILABLEf*
4iC 30 *1 r ecs1 4 QO/zifoog 7,
- n qc2.
MMMMMMMMMMMMMMMMf
V e
The Commissioners Indonesia's National Atomic Energy Agency, 4 discussing a similar arrangement with GE on the SBkR development team, and will soon send another seven to the Nuclear Power Institute in the federal Republic of Germany.
Dr. Habibic also. advised that there is a site feasibility study underway in Muria, Jepara, in Central Java.
He was very interested in the NRC schedule for design certification of the Westinghouse and GE advanced reactors.
I advised him that the Commission was considering this matter and expected to make a decision later this year.
Since NRC was planning _to accept the designs for certification, he raised the question of whether NRC would oversee and certify the full reactor project, from excavation through operation, if Indonesia committed to one of the U.S. advanced reactor types, especially since it might well be the prototype. He claimed that the French and German regulators stood prepared to do this, if one of their designs is selected, and that he could not consider a U.S.
. reactor if NRC would not do the same.
I explained that NRC's regula. tory mandate is a domestic one, that neither our resources nor our-policy would allow undertaking such a project, that there would be serious. liability questions, and that the Commission has considered and. denied similar requests that-exceeded our authority and capabilities several times in the past, most recently with the Koreans.
I also pointed out that any country about to embark on a nuclear power program had to be prepared to exercise its own regulatory responsibilities as well. These had.to be developed and implemented hand-in-hand with the construction and operation of reactors, if a program is to be safe and successful. He asked that his request be brought to your attention, and I agreed _ to do so-after cautioning that I had no reason to expect any change of-position.
We are attempting to determine if the French and German regulators would indeed certify a foreign reactor project, as we have never heard this before; I also described for him some of the activities, such as on-the-job assignments -within the NRC staff, classes at the Technical Training Center in Chattanooga and technical-advice on. specific topics, that NRC has been able to provide to other countries just entering the nuclear power arena.
I also referred.htm to the IAEA for guidance and support. He asked for information on the type of " team" needed to -
license and. inspect a nuclear sower plant and I promised to send him some NRC data about t11s.- I plan to provide him, in the next two weeks, with a 1989 report (Attachment 2) on NRC's readiness to process future applications for
=-
t The Commissioners construction permits or operating licenses, which contains analyses of past and projected NRC manpower requirements during each year of construction for several reactor scenarios.
I also plan to reiterate at that time that NRC cannot accept responsibility for foreign reactor regulation as well as other points noted in our discussion (draft letter at Attachment 3),
f k
Harold R. Denton, Director Office of Governmental and Public Affairs Attachments:
1.
List of Non-NRC Meeting Attendees 2.
Memo dtd 2/24/89, Crutchfield to Stello, w/ accompanying Steering Group Report 3.
Proposed letter to Dr. Habibie SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Monday, January 7, 1991, that the Commission, by negative ccnsent, assents to the action proposed in this paper.
DISTRIBUTION:
Commissioners OGC OIG GPA EDO SECY
_. - -. ~ - -
s.
LIST OF INDONESIAN $ AND OTHER'NON;NRC PARTICIPANTS ATTENDING MEETING ON:0CTOBER 5, 1990,~AT 15.15 PM WITH MINISTER HABIBIE o
. 1.
-Ambassador A R. Ramly, Indonesian _ Ambassador to-the U.S-.
12, -
Dr. Burhan Napitupulu,-Senior Advisor _
3.
Dr. John Forgrieve, U.S. Technical Advisor (funded by AID) 4 ~.
Dr. Sabana Kartasasmita, Assistant Minister for Institutional Development 5.
, Prof. Dr. Harsono Wiryosumarto, Deputy Chairman, Agency for Advancement and. Assessment of Technology 6;
Prof.- Dr. A.' A.- Ludin, Assistant Minister for Research and Technology 1
7.
Ir. Zuhal 8.
Ir.
R. Yamin
~ 9.
Ir. Iyos Subki, Deputy Director General for Assessment of Nuclear Science and Technology, Indonesia National' Atomic Energy Agency
- 10..
Bachrun Subardjo, First Secretary, Embassy with:-
1; Aide 2..
M. Roem Husain, Second Aide 3.-
Achmud Halud State Jeffrey Lutz,tScience Counselor, U.S. Embassy, Jakarta 0
i
- Attachment 1 7
+
- N rw t
r w
- we e m ww-ce t+,=,
=-iw s-
t--.*e-e-se s---u
-w
,=--e-*
n-+=-rm4
<--r-.-
9*t--*r--
--,-we
.r.%
(g[ us UNITED STATES NUCLE AR REGULATORY COMMISSION g*
w Assiwot oN. D. C. 20556
%g
/
Fobruary 24, 1989 MEMORANDUM FOR:
Victor Stello, Jr.
Executive Director for Operations FROM:
Dennis M. Crutchfield, Chainnan
-Steering Group to Asser.s Future Licensing Capability
SUBJECT:
TRANSMITTAL OF REPORT ON THE READINESS OF THE NRC TO PROCESS FUTURE APPLICATIONS FOR CONSTRUCTION PERMITS OR OPERATING LICENSES In your September 21, 1988 merrorandum to Chaiman Zech, you indicated that a group would be fomed to assess the staff's readiness to process future applications for construction permits or operating licenses.
The enclosed report prepared under the direction of the Steering Group, provides that assessment.
As noted in the acknowledgment of the enclosed report, the Steering Group's-task was made much easier by the well researched input material provided by the Working Group unoer Dr. Charles Hiller. The detailed-assessment requested and the underlying methodology and rationale are provided in Chapters I through VII and Appendices B and C.
Highlights of the report are presented in the Executive Summary and a direct response to each of the objectives outlined in your September 21.-1988 memo-is provided in Chapter VI!!.
After the effort was' begun, the Steering Group received an SRM (dated October 20,1988) related to the denial of a Petition for Rulemaking on 10 CFR Part 100.
In that SRM, it was noted that a comment would be inserted in the cover letter denying the petition and the Federal Register notice statirg "... that this issue will be considered in the NRt ' readiness to license' study...."
The Steering Group examined this matter and concluded that issue was not mature enough for resolution at this time. The staff planning to consider possible changes in Part 100 and implementing Regulatory Guides is currently focused on the staff review of and schedules for the evolutionary advanced light water reactors (ALWR) and the EPRI-ALWR Requirements Document. However, the staff should bring this issue to resolution before it would impact new plant proposals.
Dennis M. h.
rs+Af Crute field, ainnan Steering Group to Asses's Future Licensing Capability Encicsure:
Steering Group Report
e 6 y
l l
REPORT ON NRC READINESS TO PROCESS FUTURE APPLICATIONS FOR CONSTRUCTION PERMITS OR OPERATING LICENSES O
i 9
4 FEBRUARY 1989 l
l l
l
e i TABLE OF CONTENTS Page Acknowledgment E x e c u t i v e S unn.a ry..................................................
ES-1 I.
Introduction................................................
1-1 II.
Historical Current and Future Licensing Processes..........
Il-1 A.
Historical Licensing Process............................
11-1 B.
New Custom Plant Licensing Scenario.....................
II-I C.
Reactivated Plant Licensing Scenario....................
11-4 D.
Standard Plant on Pre-Approved Sites Licensing Scenario.
11-5 1.
E a r l y S i t e Pe nn i t s..................................
11-5 2.
Design Certification................................
II-6 3.
Combined Construction Permit / Conditional Operating License.............................................
II-6 E.
Licensing Process for Future Plants.....................
II-8 III.
NRC Resource Projections for Future Applications.............
III-1 A.
Base Case...............................................
111-1 1.
Licensing Resources.................................
III-1 2.
Inspa tion Resources................................
III-2 3.
Contractor Technical Assistance.....................
III-3 4.
Legal Resources.....................................
III-3 B.
New Custom Plant Licensing..............................
III-4 1.
Licensing and Inspection Resources..................
III-4 2.
Legal Resources.....................................
III-5 C.
Licensing of Reac tiva ted Plants.........................
I!!-6 1.
Licensing and Inspection Fasources..................
III-6 2.
Legal Resources.....................................
III-7 D.
Licensing of Standard Plants............................
III-8 1.
Early Site Permit Review............................
III-9 2.
Ccmbined License Review.............................
III-11 3.
Construction Inspection / Operating Authorization Review..............................................
III-12 IV.
NRC Guidance for New Applications...........................
IV-1 A.
Introduction............................................
IV-!
B.
Needed Additional Guidance Related to Rule Changes......
IV-1 C.
Needed Additional Guidance Related to Standard Review Plans and Regulatory Guides.............................
IV-2 1.
Environmental Standard Review Plan (ESRP)...........
IV-2 2.
Standard Review Plan................................
IV-3 l
3.
Regulatory Guides...................................
IV-3 i
4 Inspection Manual...................................
IV-3 D.
Resource Requirements...................................
IV-4 TC-1
t i
.Palg V. f NRC Resource Requirements for Satisfying DOE Nuclear........
V-1 Capacity Projections
. VI.
NRC Resource Impacts of-Processing Expected Future..........
Yl-1 Applicaticns VII.
Organizational Structure....................................
Yll-1 A.
Prior NRR Organization (late 1970's).................... Yll 1 1.
DivisionofProjectManagement(DPM)................
VII-1 2.
Division of Site Safety and Environmental Analysis (DSE)...............................................
VII-1 3.
Division of Systems Safety (055).................... Vi!-1 B. ' Organization Modifications for New Licensing Reviews....
Vil-2 1.
NRR Projects Organization...........................
VII-2 2.
NRR Technical Organization.........................
Y11-2 3.
NRR Antitrust and Financial Review Organization.....
VII-3 4.
NRR Inspection Oversight Organization...............
Vii-3 5.
Regional Organi z a t iois............................... VI ?.-3 Vill.
Conclusions and Recomr.endations.............................
VI!!-1 Appendix A......................................................... AA-1 Appendix B.........................................................
AB-1 Appendix C.........................................................
AC-1 9
4 TC-2
. _ _ _ _ _ _~_.__ _ __..___.-.-._-. __.. _..___~ _ _ _.. _ -._. _ _ _. _ _ _.. _ _ _
o ACKNOWLEDGMENT The Steering Group wishes to recognize the efforts of Dr. Charles Miller and-his Working Group in the preparation of this report.
They met routinely with the Steering Group to present the status of their work and they enthusiastically carried out their assignments. The detailed analyses, projections and findings of this report were prepared by them. The-Steering Group's task was made much easier as a result of their efforts.
The Working Group is composed of the following staff members:
Dr. Charles Miller. NRR, Chairman Charles Bartlett, RES Tim Collins, NRR Dick Dudley, NRR Geary Mizuno. OGC Lenny Olshan, NRR Ted Sullivan, NRR-Jim Wigginton, NRR e
EXECUTIVE SumARY This report assesses the readiness of the NRC to process possible future applications for construction permits and operating licenses for comercial nuclear power plants. The report provides year-by-year resource estimates for NRC review of several individual licensing scenarios believed to be resresentative of these future applications.
For these chosen licensing scenarios, tie report also discusses the licensing processes that should be used, the possible organizational structure that should be in place and regulatory guidance documents that should be updated. The report also provides a budgeting recomcendations for the 1991-1995 budget cycle related to the review of future applications.
NRC RESOURCE PROJECTIONS FOR PROCESSING FUTURE LICENSING APPLICATIONS By using historical data from the most recently licensed plants, a licensing base case was first developed.
The base case data was then adjusted to estimate the resources currently needed for the several licensing scenarios chosen for analysis.
These scenarios are (1) an application for construction and operation of a custom plant on a new site, (2) an application for reactivation and operation of a plant now in a deferred status but still having a valid con-struction permit, and (3) an application for a combined construction permit and conditional operating license which reitrences both a pre-approved site and a certified standard plant design. The report provides tables with year-by-year estimates of resource projections required for the review of each of these licensing scenarios.
The report also discusses the technical disciplines needed to process the license applications.
Table ES-1 provides a sumary of these NRC resource needs.
TABLE ES-1.
NRC RESOURCE NEEDS FOR INDIVIDUAL NEW APPLICATION REVIEWS Total NRC Staff Resources Needed Scenario PerApplication1/
Custom plant 155 FTE Reactivated plant with licensing review completed 70 FTE Reactivated without licensing review completed 94 FTE 2/
Standard plant 126 FTE M FTE estimates in this report do not include overhead factors.
U oes not include resources to certify the standard design ( 30 FTE's).
D ES-1
NRC RESOURCE PROJECTIONS FOR SATISFYING DOE NUCLEAR CAPACITY PROJECTIONS In September 1988, the Department of Energy (DOE) made projections of future nuclear capacity in the United States.
This report examines the combined NRC rescurces that w:uld be needed to meet DOE's most recently published upper and lower reference case projections.
The DOE 1cwer reference case is based on one additional plant of about 1200 MWe becoming operational in 2007. The DOE upper reference case assumes that three reactivated plants and eleven new plants will be operational by 2007. Tables showing the year-by-year NRC rescurces needed during the 1991-1995 budget cycle to process these applications are presented in the report for both DOE cases.
IMPACT OF FUTURE APPLICATIONS ON NRC FIVE YEAR PLAN The report recommends that the NRC assume for budgeting purposes that at least one reactivated plant application will be received in 1991. A reactivated plant would involve the most irrediate budget impact when compared to the other new application reviews.
In addition, the report recommends that NRC resources should be budgeted in 1993 and 1994 for preparation of guidance documentation (most of which are site related matters) for other future applications expected to be received by the mid-1990s.
NRC should also be prepared to request additional staffing in the mid 1990's as new plant application submittal dates become more definite. The hRR staff should periodically check with industry to see if any new applications are pending.
Table ES-2 presents the resources that would be needed to review a single reactivated plant application received in 1991, and to prepare guidance documentation for siting reviews of other future applications expected to be received in the 1994-1995 time frame.
It should be noted that none of the resources identified in Table ES-2 are currently included in the 1991-1995 NRC budget.
TABLE ES-2.
NRCFIVEYEARRESOURCENEEDS(FTE)M YEAR 1991 1992 1993 1994 1995 Reactivated Plant 12.7 15.0 23.5 27.5 14.4 Application Review Update Guidance 9.5 9.5 LICENSING PROCESS AND ORGANIZATIONAL STRUCTURE The report examines the historical two-step licensing process and changes and additions to previous practice to carry out the review of future plant appli-cations.
The changes result from recent rule changes and pending Comnission O FTE Values in this table do not include overhead factors.
l*.
decis'ons, such as the Severe Accident Policy Statement and the proposed ofproposed10CFRPart52gRPart26).
fitness-for-duty rule (10 The report also discusses the use and its three subparts:
early site permits, standard design certifications and combined construction permit / conditional operating licenses for the reviews of future applications.
The overall purpose of Part 52 is to improve reactor safety and streamline the licensing process by encouraging the use of standard reactor designs and by allowing the early resolution of site, environmental and reactor safety issues.
The report concludes-that while the historical two-step process remains a viable licensing vehicle for the future, the proposed Part 52 should also be promulgated and its use encouraged.
The report discusses the organizational structure that was successfully used by the NRC*in the past for conducting license application reviews, and addresses modifications to the current NRR organization that should be implemented if more than two future license applications are received.
The principal modifi-cation involves creating a new Project Directorate within NRR for the processing of future plant applications.
However, if only one or two future plant applica-tions are under NRC review, this organizational modification would not be-needed since the review could be successfully conducted within an existing NRR Project Directorate. However, we recomend that the project manager for the future plant application should, under these circumstances, report directly to the Assistant Director in order to assure adequate visibility and priority for the
. future licensing project.
l M The report discusses the proposed Part 52 as of January 1989.
CHAPTER I.
INTRODUCTION On August 18, 1988, the Chaiman requested the Executive Director for Operations (EDO) to create a small working group to assess the readiness of the NRC to process possible future applications for construction permits / operating licenses for nuclear power plants (COMLZ 88-27).
On September 21, 1988 in a memorandum from Victor Stello, Jr., Executive Director for Operations, to Chaiman Zech,
Subject:
Working Group to Assess Future Licensing Capability," the objectives of the assessment and the composition of the working group were detailed. This report provides the results of the assessment and the infomation needed to satisfy the ED0's objectives.
Chapter II of the report provides a discussion of the Part 50 historical licensing process that was successfully used by the NRC in the past to process applications, and necessary modifications to take into account changes to recent rules and Comission Policy.
The chapter also discusses the new licensing process described in the proposed Part 52 to Title 10 of the Code of Federal Regulations.
The individual NRC resource projections for several licensing scenarios are presented in Chapter Ill.
The scenarios that were analyzed were chosen because they are considered to be representative of the possible combinations of those new applications specified in the ED0's memorandum to the Chainnan (Appendix A).
These scenarios include construction and operation of a custom plant on a custom site, reactivation and operation of a plant with a valid construction pennit that is in a deferred status, and a standard plant application for construction and operation complying with the proposed Part 52.
The resource projections for these individual scenarios'were developed by starting with the resources needed to process the most recently licensed plants and making adjustments as necessary.
Chapter IV discusses guidance documents, such as regulatory guides and standard review plans, that should be revised to assist in the processing of future applications, and estimates the resource requirements for updating these documents.
Chapter V discusses the NRC resources needed to perform the combination of plant reviews needed to meet the energy needs projected by the Department of Energy (D0E).
The combined NRC resources needed to meet both the DOE upper and lower reference cases are presented.
Chapter VI presents the report recommendations that the NRC assume for budgeting
-purposes that at least one reactivated plant application will be received by 1991, and that site-related guidance documents applicable to other future applications should be available by 1995.
The basis for these recommendations and their impact on the 1991-1995 NRC budget is also presented in Chapter VI.
Chapter VII discusses a past NRR organizaticrial structure that was in place when many license applications were being successfully processed. This chapter also suggests minor changes to the current NRR organizational structure that would facilitate the review of future applications.
Conclusions and recommendations that address the objectives defined in the ED0's memorandum of September 21, 1988 are provided in Chapter VIII.
i I-1
Three-appendices'are also included and provide supplementary infonnation
-supporting that found in the main body of the report. Appendix A contains copies of the Chairman's request to perform the assessment and the ED0's September 21, 1988 response to the Chaiman. Appendix B provides a detailed discussion of the historical process used to license nuclear power plants.
Appendix C includes additional details on the resource projections, including technical expertise, needed to meet the licensing scenarios discussed in Chapter-Ill.
4 9
l I-2
1 CHAPTER !!. HISTORICAL, CURRENT AND FUTURE LICENSING PROCESSES A.
Historical Licensing Proces:
Recognizing that readers of this report are likely to be familiar with the historical licensing process, only the highlights of this orocess are sumarized below. Appendix B to this report contains a detailed description of this process and the timing of the various activities of the process.
The historical licensing process has been the 10 CFR Part 50 two step process which consists of a construction permit (CP) stage and an operating license (OL) stage. The basic review scope at each of the stages has been radiological safety, as determined by conformance to the regulations, environmental impact as required by the National Environmental Protet: tion Act, and antitrust.
The reviews, inspections, and hearings at the CP and OL stages generally have followed a similar pattern. Because the plant designs have not been finalized until the OL stage and because significant construction is underway at that time, considerably more resources have been ex sended by the staff during the OL review stage than at the CP stage.
However, tie staff review of the site characteristics, environmental impact, and antitrust have been carried out mainly at the CP stage.
The Reactor Inspection Program prior to full power operation has consisted of four phases. The pre-CP phase covered the period from notification of intent to construct up to issuance of one or more Limited Work Authorizations (LWAs) and/or the CP. Atthispointtheconstructioninspectionphase(CIP) began.
The CIP merged into the inspection of preoperational testing and operational readiness (PT0R). About six months prior to OL issuance, the startup testing phase I"D) inspection activities began.
The federal agencies with which the staff has had significant interaction during plant licensing are the Environmental Protection Agency and the Department cf Interior for the environmental review, the U.S. Geological Survey for the geo-logy / seismology safety review, the Federal Emergency Management Agency for the emergency planning review, the Department of Justice for the antitrust review, and the U.S. Army Corps of Engineers for hydrology review.
The factors that in the past have most significantly affected the staff resources expended for plant licensing have been:
fiearings with heavy intervention, resolution of siting problems, design and construction errors, resolution of allegations, and facility changes that have resulted from changes in or a better understanding of regulatory requirements. Many plants that the NRC has licensed have been relatively unaffected by these considerations.
- However, there has been a trend in the more recent cases toward increased resource expenditures attributable to one or more of these factors.
B.
New Custom Plant Licensing Scenario One licensing scenario examined by this study is an application for licensing of a custom plant design on a custom site.
The overview of the historical licensing process discussed above and the more detailed description in Appendix B of this report would be largely unchanged for an application for l
l 11-1
a new custom plant on a custom site. However, there are a number of recent and pending rule changes and Comission policy decisions which are expected to modify this and other potential new plant licensing scenarios.
These rule changes end pending decisions and their resource implications are described in the following paragraphs.
Prior to 1982, review of the financial qualifications to operate and decomission a nuclear power plant was performed at the OL stage.
The financial review was eliminated as a requirement at the OL stage by a rule change in September 1984.
Applicants for operating licenses are no longer required to submit information on their financial qualifications to operate the facility.
However, in June
/
1988,10 CFR 50.33(k) and 50.75 Reporting and Recordkeeping for Decomissioning 1
Planning, were added. These rules require applicants for operating licenses to submit detailed financial information to assure that the funds for decomissioning the facility will be provided. The net effect is that NRC staff resource requirements for financial reviews are expected to remain essentially the same as it was prior to 1982.
Two developments have a potential for greatly increasing the NRC workload involved with Federal reviews of emergency preparedness plans at nuclear power plants.
First, on December 3, 1987, new emergency planning regulations
[10 CFR 50.47(c)(1)] became effective, providing for NRC staff and Federal Emergency Management Agency (FEPA) review of utility prepared offsite emergency response plans where State or local governments decline to particisate in emergency planning.
Under the regulation, if the NRC determines t1at an applicants' inability to demonstrate compliance with emergency planning requirements results wholely or substantially from the nonparticipation of State and/or local governments, the NRC staff and FEMA will evaluate the utility prepared plans under the same 16 planning standards that are used to evaluate State and local utility plans, but will use the " realism" assumptions set forth in 10 CFR 50.47(c)(1).
Second, on November 18, 1988, the President issued Executive Order 12657
" Federal Emergency Management Agency Assistance in Emergency Preparedness Planning at Comercial Nuclear Power Plants." This Executive Order establishes a mechanism for Federal assistance to be provided to utilities in the prepara-tion and implementation of offsite emergency plans where State or local governments decline or fail to prepare adequately.
Upon certification by a utility that a " decline or fail" situation exists, the Federal government would help the utility prepare its offsite emergency plans.
Further, upon a specific determination that *.here has t,een maximum feasible use of utility and State and local resources, the Federal government will make available to the utility Federal facilities, equipment and personnel as part of the offsite response organization. The NRC staff and FEMA would evaluate the adequacy of these potentially. complicated utility prepared offsite emergency plans under NRCregulationsin.10CFR50.47(c)(1)mentionedabove.
The new NRC regulation has resulted in heavy demands upon the NRC staff and FEMA in the cases of the Seabrook and Shoreham nuclear power plants, which are the first to have utility prepared offsite emergency alans.
In the future, there may be facilities that may request the use of t e provisions of the Executive Order to obtain Federal assistance in offsite plan development or to gain the use of Federal facilities and resources in their offsite plans.
II-2
. =.
In September 1988, the Comission issued a new proposed 10 CFR Part 26 that, when promulgated, will require licensees authorized to operate nuclear power reactors to implement a fitness-for-duty program.
The general objective of the proposed rule is to provide reasonable assurance that nuclear power plant persormel are not under the influence of any substance, legal or illegal, that in any way adversely affects their ability to perform their duties. The coment period for this proposed rule recently expired. A final rule is currently scheduled to be promulgated by mid FY-1989. Additional NRC staff resources for review and inspection in this area will be needed for future plant licensing.
The Commission's Severe Accident Policy Statement was issued in final fom in August 1985 (50 FR 32138). This statement provided policy guidance on how to address severe accident issues for the licensing scenario discussed in this sections as well as the scenarios in Section II.C and II.D.
In addition to the traditional review governed by the regulations, new custom plant applicants will be expected to (1) demonstrate compliance with the Three Mile Island requirements for new plants as reflected in 10 CFR 50.34(f), (2) demonstrate resolution of all applicable Unresolved Safety Issues (USIs) and Generic Safety Issues (GSIs),
and (3) complete a PRA giving considar: tion to the severe accident vulnerabili-ties the PRA exposes along with the insights it may add to the assurance of no undue risk to public health and safety.
The Comission's Severe Accident Policy may lead to rulemaking Regulatory Guide and standard review plan additions and changes, or other decisions regarding procedures and criteria.
These actions are likely to be focused principally on operating reactors and standard plant licensing, since new custom plant applica-tions and reactivated plant licensing applications are expected to be relatively few in number.
Accordingly, staff guidance for severe accident reviews for custom plant licensing is not likely to be formalized in the regulations but will be developed on a case by case basis and based upon the related approaches taken by the Commission for standard plant licensing.
Since Severe Accident Policy for new custom plant licensing is not now codified in a rule, there is considerable uncertainty regardir.g the impact on NRC resources that this area could have in the hearing l
process.
In addition to any potential impact on hearings, severe accident reviews by the staff will require additional NRC resources not previously expended in the historical CP/0L licensing process.
C.
Reactivated-Plant Licensing Scenario The second licensing scenario examined by this study is the licensing of plants that hold a currently valid CP that are reactivated fron deferred status.
Currently there are 12 plants with valid construction permits.- Five of these plants (Comanche Peak 1, Limerick 2. Vogtle 2, and fl.atts,Bar 1 and 2) are currently under construction and actively proceeding 10 ward an operating
~
~
~
license and are noi E6nsidered to'be in a deferred status. ComancTeTeak 2,
~
although not formally in a defe'rred statusT ha'5~hal construction suspended.
Construction of Unit 2 will likely resume later this year. All of these six plants have NRC resources budgeted for the completion of the licensing reviews.
The remaining six plants are-in a deferred status with no budget allocation, II-3
c, and are candidates for reactivation.
These plants are Bellefonte 1 and 2*,
Grand Gulf 2. Perry 2, and WNP 1 and 3.
In accordance with the Commission Policy Statement on Deferred Plants published on October 14, 1987 (52 FR 38077), CP holders are expected to submit certain specific infomation when construction on a plant is deferred and when plant construction resumes. This information will be used by the staff to determine the status of the plant with respect to reactivated plant licensing. The acceptability of structures, systems, and components important to safety (upon reactivation will be determined by the staff based upon the following:
- 1) the staff review of the implementstion of the previously approved preservation and maintenance program, (2) the staff verification that design changes, modifications, and required corrective actions have been properly implemented, and (3) baseline inspections perfomed by the staff to verify that Final Safety /,aalysis Report (FSAR) quality and perfomance comitments have been met.
In addition to perfoming the above items specifically associated with reactivated plant licensing and completing the review, inspection, and hearings associated with historical plant licensing, certain recent rule changes and the Comission policy on severe accidents are expected to affect the reactivated plant licensing review. The major changes include the Fire Prote: tion Rule, Hydrogen Rule, Equipment Qualification Rule and the Decomissioning Funding Rule.
With regard to severe accidents, licensing applicants for reactivated plants will be expected to perfom an Independent Plant E amination (IPE), as outlined in Generic Letter 88-20, and address containment vuberabilities. As with currently operating reactors this will serve as the mechanism for addressing severe accidents for this licensing scenario.
Addi Monal resource requirements and potential hearing process impacts concerning setere accident considerations will be similar to those discussed in Section 31.B Tor new custom plant appli-cations.
The descriptions provided in Section II.B on financial qualifications and fitness for duty are equally valid for the reactivated plant licensing scenario being treated in this section.
L Of the six plants in a deferred status, three (Grand Gulf 2, Perry 2, and WNP 1) l are located on sites with previously approved emergency plans (EPt.
EP reviews I
would have to be perfomed for the remaining three plants (WNP-3 a nd Bellefonte l
1and2 sites).
D.
Standard Plant on Pre-Approved Sites Licensino Scenario The third licensing scenario examined by this study is an application for licensing of standard plants on pre-approved sites. A brief description of i
the proposed 10 CFR Part 52 process and a discussion of other differences between this scenario and the historical licensing process-discussed in Section II.A are presented below.
- Although construction is suspended at Bellefonte I and 2, these units are not fomally deferred.
However, since the NRC Five Year Plan does not allocate any resources to Bellefonte beyond FY-1989, for the purposes of this report Bellefonte is considered to be a deferred plant.
11-4
m,=
z, _
The Licensing Process-under Part 52 The p'roposed Part 52 has-three subparts.
These are:
(a) Early Site Pemits, L(b) Standard Design Certifications, and (c) Combined Construction Permit /-
Conditional Operating Licenses.
1.
Early Site Pemits Under Part 52, applications for an early site pemit would be required to include infomation on such things as the boundaries of the site; the number, type and themal power level of the facilities for which the site may be used; the type of cooling systems to be utilized; the anticipated maximum levels of radiological and themal effluents; existing and' future
. population profiles; the location and description of nearby industrial, military,'or transportation 1acilities and routes; emergency preparedness and a complete environmental report similar to-that required for a tradi-tional construction-permit application. Applicants need-not discuss-the need for power, but are required to perform an evaluation of alternative--
sites.
If the applicant wishes to perfom activities equivalent to those
_p3rmitted by an LWA-1 (see Appendix B),-then a plan for site redress must also be included.
- As'part of the NRC review of an early site permit application. the NRC wouldberequiredtoprepareanenvironmentalimpactstatement(EIS),and-make a finding with regard-to site emergency preparedness planning.
Part 52 provides.for two options for satisfying early_ site emergency preparedness (EP) requirements. - The first o > tion requires the applicant-to-provide infomation sufficient "...to sicw that the area surrounding the site is
^ amenable to emergency planning which would provide reasonable assurance that adequate protective measures could be taken in the event of-a radio-logical emergency at-the site; given the characteristics of the site and
- probable emergency planning zones' surrounding the site...."
After consultation with= FEMA, the Comminion makes a reasonable assurance.
finding.
Under the second option, the applicant may either-(a) propose emergency planning parameters'for review and approval by:the NRC and-the
, Federal Emergency Management Agency. The parameters may include such
- matters as the exact size-and shape of the emergency planning zones.
Confomance with these parameters by the emergency plans submitted-by an applicant for'a' combined license or an_ operating license will be sufficient to show the acceptability of the plans with respect to the emergency plannin
-option.g. requirements-reflected in the parameters. 1As part of the second
.the licensee mayl(b) propose complete emergency plans for-review and approval-.by the NRC and the Federal ~ Emergency Management Agency, in y
accord with theiapplicable provisions of 10 CFR 50.47..
In; addition, the application for site approval must be referred to the ACRS,
.and the-ACRS must report "on those parts of the application which concern reactor safety."
An early site permit is deemed to be a partial construction permit; there-N
- fore,'a mandatory public hearing must-be held on the permit application.
Publication-of notice of the hearing, the procedures-for intervention, and the conduct of the hearing would be the same as for a traditional II-5
e 3
construction pemit application.
However, depending upon which EP option is selected, the hearing complexity may vary, along with support staff resources.
2.
Desicn Certification Under Part 52, an application for design certification must contain the information necessary to receive design approval under Appendix 0 to Part 50.
In addition, the application must contain the non site specific technical infomation that is required of applicants for construction permits and operating licenses, includ Sg compliance with applicable TMI requirements. Also required are proposed resolutions of medium and high priority US!s and GSis, the submission of a PRA, and the proposed tests, analyses, inspections, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that a plant which references the design has been built and will be operated in accordance with the certification.
For nuclear sower plant designs with only evolutionary changes from current LWRs, tie proposed Part 52 requires presentation and certification of essentially complete designs.
Review of the application involves an ACRS report on reactor safety issues and, as a minimum, an " informal hearing' before an Atomic Safety and Licensing Board. A formal Maring is also possible.
Design certification would essentially constitute Commission pre-approval of the adequacy of the design for referencing in future applications.
3.
Combined Construction permit / Conditional Operating License kbpart C of part 52 authorizes the issuance of combined construction permitsandconditionaloperatinglicenses(combinedlicenses).
Applications for a combined license must not only include the information reqeired for e construction pemit, (including anti trust infomation),
but must also include the Final Safety Analysis Report (FSAR). Applications referencing an early site pemit must. demonstrate that the design of the facility, as well as environmental issues not considered in any previous proceeding on the site or design, fall within the parameters specified in the early site permit.
If an early site permit-is not referenced, then the same information required for an early site permit must be included.
If a design certification is referenced, the application must include those portions of the design specific to the site, as well as compliance with theinterfacerequirementsinproposedSection52.47(d).
In addition, emergency plans must be submitted, and if possible, certifications by applicable local and State government agencies that the plans are practicable and that they are committed to participating in developing and implementing the plans.
The review process for a combined license application would be similar in many respects to the review of a conventional construction permit. The safety review, however, would consider the final plant design rather than a preliminary design.- ACRS review of the application is required. An antitrust review by the Attorney General is also required. An environmental review of the application and hearing are required, including preparation of an EIS.
However, if the application references an early site permit.
Il-6
e 4
the environmental review would focus only on the suitabflity of the site for the particular design and any other significant environmental issues not previously considered in either the permit or certification proceeding.
i To srovide assurance that the pitnt can be built and operated in accordance wit 1 raquirements, proposed Part 52 wocid require that applicants to submit the sregosed tests, analyses, inspections, and acceptance criteria as part of tie application for a design certification.
These proposed tests, 1
analyses, inspections, and acceptance criteria will be reviewed and i
approved as part of the certification review.
Before the licensee may operate tto facility, a pre-operational antitrust review must be perfomed to deteranine if there have been any significant chdnges in the licensee's activities or proposed activities since the grant of the combined license.
If therc are, a review by the Attorney General is required.
The Attorney General may reco m end that an antitrust hearing be held by the Comission. Apart from necessary antitrust hearings, an interested member of the public also has the opportunity to request a hearing on the basis that either (1) there has been a material noncon-formance with the combined license, the licensee's written comitments, the 1954 Atomic Energy Act or the Comission's regulations which could adversely affect the safe operation of the facility; or (2) that some rnodification to the site or design is necessary to assure adequate public protection.
The approach inherent in the proposed Part $2 is based upon submission of com-plete infomation on the final design. As a result, the distribution of NRC 4
resources for licensing reviews will be expended over a shorter time frame, and earlier than in the traditional two-step licensing process. Similarly, NRC regional resources for the inspection of thi impimentation of the proposed tests, inspections, analyses, and acceptaNe criteria will have to be expended earlier in the licensing process than required by the historical licensing approach.
In addition to the above procedural changes for standard plants under the proposed Part 52, there are other differences from the historical licensing reviews that are discussed below.
Section !!.B of this report on New Custom Plant Licensing contains discussions of the effect on new licensing of the Decomissioning Funding Rule. Emergency Planning and fitness-For Duty.
The resource implications described in that section are equally applicable for this licensing scenario.
The Commission's Severe Accident Policy statement to, issued in final fom in '
August 1985. Through a series of interactions wi;t the Comission snd with industry, the staff has been developing specific M oposals for imriementing the severe accident policy.
The staff is considering developmer/c of a rule and accompanying regulatory guides that would require:
(1) ic'ertification of i
specific severe accident vulnerabilities that evolutionary designs must address (e.g.,containmentintegrity,containmentbypass,andcoredamage prevention), (2)(perfomance of a PRA and consideration of the vulnerabilities it exposes,.and 3) documentation of assumptions and incorporation into plant design, operation, and maintenance.
The staff resources for this licer.ng scenario will reflect the effort involved in reviewing the applicants' severe accident submittals, 11-7
- e o
i E.
Licensing Process for Future Applications The existing 10 CFR Part 50 two step licensing process should continue to be a viable licensing vehicle for future applications, at least for the near future.
NRC Comissioners and staff, the public, are the utilities (along with su) porting architect engineers and hSS$ vendors) have a vast body of experience and r,now-ledge of the existing Part 50 licensing process. All these particisants are familiar with their respective roles in this process, and history snows this process to be a werkable licensing vehicle.
Nevertheless, the proposed 10 CFR $? (after appropriate public connent resolution) should also be promulgated and used for future applications. Th.is proposed new rule is. intended to achieve the early resolution of licensing issues, to reduce the complexity and uncertainty of the licensing process, and enhance the safety and reliability of nuclear power plants.
Part 52's overall purpose is to improve reactor safety and streamline the licensing process by encouraging the use of standard reactor designs and by allowing the early resolution of site environ-mental and reactor safety issues. The public should be afforded an earlier.
entry into the licensing process as a result of design certification rulemaking process and subport C's combined CP/0L hearings.
process,, and they should be encouraged to do so. plants would use the Part 5 It is expected that most applications ta future However, the use of Part 50 for some future applications should not be outlawed.
G 11-8
~
.o CHAPTER !!!.
NRC RESOURCE PROJECTIONS FOR FUTURE APPLICATIONS In this chapter resource projections have been developed for the future plant licensing scenarios discussed in Chapter !!, Sections B, C, and D.
These projections include adjustinents to the NRC resources that were needed to complete the historical licensing reviews and inspection activities for the most recently licensed plants.
It should be noted that no resource estimates have been made for the Licensing Boards and Panels.
The resource projections of this report are characterized in terms of what is called a full time equivalent or FTE.
The FTE includes only the direct resources of the technical, regional or legal staff (OGC), and does not include resources needed for management, supervision or administrative support.
Due to the fact that overhead factors vary over time and from office to office, r.o attempt has been made to include these in the resource projections contained in this chapter and in the remainder of the report.
Any budget assumptions or actions that are based on this report should include the appropriate overhead factors.
A.
Base Case 1.
Licensino Resources To determine the resources needed for base case licensing,)historicalwere analyz data from the Regulatory Information Tracting System (RITS Since RITS data are available from June 1972 to the present, data from all theplantswhoseconstructionpermit(CP)applicationsweredocketedafter June 1972 were considered.
The licensing review resou:tas expended to issue cps have been plotted in Figure Ill-1 as a function of tirne of issuance of the CP.
Data points in Figure !!!-1 were plotted for an individual site when the construction permit review was applicable to identical units.
Braidwood data was not plotted since Braidwood was a duplicate of Byron and the data was not representative of an entire plant review.
A trend in CP licensing resources can be observed that indicates that the more recently the CP was issued, the higher were the resources expended for licensing.
Based on this trenc, a value of approximately 14 FTEs has been chosen to quantify the licensing resources that would be required for base case CP issuance.
This value is representative of the resources expended for the last few cps issued.
Figure III-2 contains a similar plot of licensing resources for issuance ofthelowpowerlicense(LPL).
Data points in Figure !!I-2 for multiple unit sites were plotted for the first unit since typical guidance was to charge all review hours to the first unit until it was licensed.
Hours actually charged to the subsequent units were a small percentage of those charged to the first unit.
This plot includes only those plants on Figure III-1 that have received an operating license. As can be seen, a value of 30 TTEs is a good approximation of the licensing resources needed to issue an lPL.
iurther analysis of historical RITS data for recently licensed )lants has shown that in addition to the resources expended to issue tie LPL, approximately two additional FTEs were required to issue the full power 111-1
e license (FPL). These additional resources were used primarily for closeout of issues that were unresolved at the time of LPL issuance.
Based on these considerations, a value of 32 FTEs has been chosen as the estimated licensing resources needed for base case operating license (OL) issuance.
An estinate has also been made of the time distribution of l'. censing resources needed during both the CP and OL stages.
For this purpose, one plant regarded as representative of licensing resource expenditures over time was chosen for detailed analysis.
The licensing resources expended were totaled for each year from application for the CP through issuance of the full power license (FPL).
These totals were then plotted to detennine the shape of the licensing resource expenditure curves for CP issuance and for OL issuance. The resulting curves were adjusted in magnitude to total 14 TTEs for CP issuance, and 32 FTEs for OL issuance.
Figure !!!-3 illustrates these results and depicts the base case time history for licensing resources.
Additional aspects of the analysis dealing with the distribution of base case licensing resource requirements by review discipline are contained in Appendix C.
These types of disciplines would also be needed to process the types of applications analyzed in Sections B, C, and D of this chapter.
2.
Inspection Resources Regional inspection resources for base case licensing have been calculated using an existing budget model.
This model has evolved over the last 10 years and was used by the fonner Office of Inspection and Enforcement to predict regional manpower for reactor construction inspections.
Since the model was reevaluated and adjusted annually to reflect average inspection resources utilized in the previous year, the model was regarded as appro-priate for use in predicting base case resource requirements. The model predicts inspection resources for a single unit for various phases of con-struction.
Table !!!-1 indicates a total base case regional inspection resource projection of 46 FTEs.
This value was determined using the annual resources for each phase of inspection from the budget model and the duration of each shase from past experience.
Additional details of the model dealing wit 1 the number, kind, and required timing of the various inspection types is contained-in Appendix C.
TABLE !!!-1 TOTAL REGIONAL INSPECTION RESOURCES Phase Phase FTE/YR Duration (Years)
Total PRE-CP 0.1 3
0.3 CIP 4.2 7
29.4 PT0R 5.6 2
11.2 STP 4.6 1
4.6 46 FTEs 111-2
'\\
e Resources for NRC Headquarters Construction Appraisal Team inspection efforts have been estimated to be 2 fiEs by examining actual RITS data for the plant considered to be representative of resource expenditures that was analyzed in Section II.A.1 above.
Since this plant, as well as many others, underwent a Construction Appraisal Team (CAT) inspection, these resources have been added to the total base case regional inspection resources predicted by the budget model.
Therefore, the total inspection resources that would be needed for base case licensing have been projected to be 48 FTEs.
Inspection resource requirements plotted as a function of time for the base case are shown on Figure !!!-4.
Figure III-5 is a com-posite plot of Figures III-3 and III-4, and illustrates the relationship of licensing and inspection requirements as a function of time.
Various features of Figure III-5 appear to be consistent with the histort-cal licensing process.
For example, the primary effort during the Cp stage was licensing, subsequent licensing efforts were minimal in the early years of construction, inspection was fairly constant from CP issuance through issuance of the FPL, and licensing efforts peaked during the preparation of the OL stage Safety Evaluation Report (SER) in year 9.
3.
Contractor Technical Assistance Historically, contractor technical assistance (TA) has been used to provide expertise not then available within the licensing staff or to supplement staff expertise.
Expertise that has been acquired through TA has included site environmental and geoscience specialists to assist in CP licensing reviews; fire protection, environmental qualification, and inservice testing support for OL licensing reviews; and various specialists to augment Construction Appraisal Team inspections.
Estimates of contractor technical assistance required for base case licensing have been ceveloped from historical data.
The costs for techni-cal assistance incurred prior to 1984 are only available as a total up to that time.
For 1984 and each year thereafter, the annual costs are avail-able for each plant. Technical assistance costs of $1,365,000 (or 11 FTEs at $125,000/FTE) were incurred for the representative plant analyzed in Section II.A.1 above.
These costs were compared with costs for several other plants and concluded to be representative of technical assistance needed for base case licensing.
Based upon discussions with staff employed by NRC since the early 1970s, it has been concluded that approximately 5 FTEs of technical assistance were typically expended for tie CP site safety and site environmental reviews.
The balance of the 11 FTEs of TA were expended during the OL stage.
4.
Leoal Resources Quantitative estimates of the Office of the General Counsel (OGC) resources required to support hearings were not made for base case licensing.
- Instead, this section describes the assumptions and methodology used for projecting OGC resource needs for the future licensing scenarios analyzed.
The estimates of OGC staffing requirements for the licensing scenarios discussed in this report are based on several factors.
First, the resource projection for each licensing alternative makes certain III-3
I o
assumptions regarding the nature of the intervention, the issues raised by the intervenors, and the timing of completion of necessary staff evaluations.
These assumptions are discussed in detail under the discussion of each licensing alternative.
However, a comon assumption has been that an application filed under any one of the licensing alternatives analyzed is expected to be very highly contested.* This neeans that for any such hearing there will be an unusually high workload related to procedural issues, including such aspects as:
a large number of contentions; substantial interlocutory appeals and motions for directed certification, some of which may be granted; some well-framed challenges to recent regulations which have not previously been involved in hearing; extensive post hearing appeals ano litigation. extensive discovery and many mo disputes
- Thus, alt of technical effort in the staff review may be similar to past experience, the level of legal effort is based more en recent experience in the Seabrook and Shoreham cases, but at a level below that currently required to support these cases.
In general, resources shown after issuance of a license are those needed to support appeals.
It is assumed that there are no major antitrust issues and no antitrust hearings.
B.
New Custom plant Licensing To estimate the NRC resources needed to license a new custom plant, it has been assumed that the plant would be very similar in design to the most recently licensed light water reactors, and that the traditional two step process would be used rather than the process discussed in the proposed 10 CFR Part 52.
Adjustments to the base case estimates have beer made to account for changes that have occurred in the licensing review that are likely to exist in future plant licensing.
These changes and the projected resource requirements are discussed below.
1.
Licensing and Inspection Resourcet Staff licensing resoi 'es necessary to review the prospective appli-cations for ccmpliance with the ATWS rule and station blackout rule have been estimated to add a total of approximately 0.2 FTE to those totals projected for the base case, divided between the CP and OL review stages.
The new rule, which requires that financial qualifica-tions for decomissioning be considered, essentially replaces the old financial review done at the DL stage.
Thus, no FTE adjustment has been made.
Implementation of the Comission's Severe Accident policy was assumed to require 0.5 FTE for staff licensing review and 1 FTE for contractor review, both during the OL stage, and are based upon historical experience from reviews of pRAs.
Resources to review the application for compliance with the fitness-fer-duty rule were estimated to add 0.3 FTE, divided between the Cp and OL stages ard between licensing and inspection.
Two project managers (pMs) have been assumed for years 1, 2, 3, 11, and 12 to manage staff support for the heavily contested hearings that are anticipated.
- If a number of licensing applications were submitted at about the same time, it might be more appropriate to use traditional assumptions, e.g., some hearings highly contested, some hearings moderately contested and some applications uncontested.
I 111-4
.~
4 h
As noted in Section II.B. the emergency planning (EP) rule pronmigated in j
November 1987 will allow the licensing process to proceed W1ere the applicant's failure to meet any of the planning standards is due to the non participation of State and/or local governments. Under this rule the potential also exists for highly complex hearings and correspondingly heavy resource requirements. This potential has not been specifically translated into an average resource requirement for the new custom plant 2
licensing case. -However, in the following paragraph an estimate of resources is included to account for protracted hearings on a variety of contested matters, including EP.
1 As noted in Section III.A on the base case, the resources needed for OL issuance have shown a steadily increasing trend.
Considering the OLs issued in recent years, resources well above those estimated for the base case were required for both licensing and inspection at some plants that encountered problems steming from design / construction errors, allegation resolution, and/or protracted hearings.
It should be expected that in the future, improvements will be made to avoid or minimize these problems, but it is likely that there will still be some plants that encounter these types of problems. The trend of increasingly organized intervention will likely continue and future issues, that in the past have not been controversial, may be litigated extensively.
It is projected that in the future substantial resources will be needed to handle these aspects of the licensing process.
To account for these added complications, con-tingency technical resources have been added.
These include 5 additional FTEs in the CP stage for siting issues including EP, and 15 additional FTEs in the OL stage for resolution of design / construction errors, allegations and EP issues.
These resources have been assumed to be needed toward the end of each stage, since the issues requiring these resource expenditures are resolved through hearings or examinations of the results of completed ccnstruction.
These resources have been divided equally between licensing and inspection. Of the 20 additional FTEs,10 have been assumed to be met by increases in contractor technical assistance.
Staff experience has shown that regional involvement has also been needed on matters related to construction errors, allegation resolution, EP exercises, and other litigated issues.
Experience has aise shown that substantial contractor TA has been needed to meet schedular requirements in these' areas.
2.
j.egalResources Estimates of OGC resources needed to support new custom plant licensing were based on the following specific assumptions.
A new custom plant is CP hearin likely to have hearings at both the CP and the OL stages.(a) environmental issue would be divided into two phases:
safety issues (adequacy of preliminary design and/or design criteria).
Siting issues would arise in both phases of the hearing (alternative sites in the environmental phase, and radiological impact related issues in the safety phase).
Although emergency planning issues may be litigated at the CP stage, it is assumed that they would tend to be minor and would not be litigated in a separate hearing phase.
For any necessary OL hearings, emergency planning would be a major area of contention, since it is assumed that intervenors would contest both the 111 5
l J
tmergency preparedness plan and the exercise with respect to whether it demonstrated a fatal flaw in the plan.
The exercise litigation would e
focus on that exercise which is conducted within 2 years of OL licensing, 4
sirce it is the exercise required to comply with 10 CFR Part 50, Appendix i
E.
Accordingly, this exercise should be conducted at about 2 years before the expected licensing date to assure sufficient time for the hearing (FEMA Report, new contentions, discovery, hearing preparation, hearing, proposed findings and ASLB decision) to be completed without affecting the expected OL licensing date.
The hearing on the plan should be conducted earlier, perhaps in conjunction with the hearing on environmental issues.
i or about 3-4 years before the OL date.
These assumptions concerning the timing of the safety and environmental hearings are intended to reduce crowding at the end of the hearing, in order to minimize the potential for deTay in the ultimate decision. Based upon the above, total OGC resources required for new custom plant licensing were projected to be 25 FTEs 4
(extendingover14 years).
Thus, for new custom plant licensing, the licensing resources needed have been projected to be about 56 FTEs, inspection resources have been projected to be approximately 52 FTEs, technical assistance resources have been projected to i
be in excess of 21 FTEs, and OGC resources have been projected to be slightly more than 25 FTEs.
A detailed year-by-year breakdown of resource needs for l
licensing and inspection is provided in Appendix C.
Figure !!!-6 is a plot of licensing and inspection resources by year needed for a new custom plant case.
This plot is similar in shape to base case licensing shown in Figure III-5, since the duration of new custom plant licensing has been assumed to be unchanged from tha base case.
The significant changes in resource projections are those discussed above, which occur primarily in years 3, 11, and 12.
I C.
Licensing of Reactivated Plants The six plants with cps in a deferred status can be separated into two groups.
Group one consists of Grand Gulf 2 and Perry 2, which on the average are about 401 complete.
Both plants in this group have an OL stage SER and an ASLB decision applicable te the second unit by-virtue of the licensing of the first unit at the site.
In group two are WNP 1 and 3 and Bellefonte 1 and 2 which have an average construction completion of about 701 but do not have OL stage SERs or ASLB decisions.
1.
Licensing and Inspection Resources Theresourcesneededforplants401completeandwithOLstageSERs(group one) have been determined as follows.
Inspection resources for each year from reactivation through full power licensing are based on the inspection resources for the corresponding years in the base case. Additions to the base case inspection resources have been made to account for the provisions of the Deferred Plant Policy Statement (DPPS) - 2 FTE staff and 1 FTE TA; updating the regional staff on the status of the design, the construction, and the inspection program - 1.5 FTE staff; and the resolution of design / construction errors, allegation resolution, and reopening of hearings - 3.5 FTE staff and 4 FTE TA.
Implementation of the DPPS has been assumed to occur principally through plant inspection, relying on regional, NRR, and TA resources.
It has been assumed that this Ill-6
effort would require a five person team for four months including resolution of issues and documentation. A portion of the the resources of the resident inspectors would be needed during the first year. Resources that would be expended by regional staff for updating on the status of plant design, construction, and inspectior, would be devoted to reviewing inspection reports written prior to deferral, status of construction as of the deferral, plant construction organization, quality assurance program and program controls, and the design criteria and any changes in ccanit.
ments. The estimate for contingencies is 3.5 FTE which is the inspection portion of the 15 FTEs assumed for contingencies in the new custom plant Case.
~
/ Licensing resources have beer, projected to be needed for project manage-
' ment - 1 FTE per year in years 1, 2, 3,(and 6 and 2 FTEs per year in years 4 and 5; review of plant-unique issues e.g., ISI, IST and fire protec-a tion) - 0.5 FTE staff per year in years 1, 4, 5, and 6 and 1 FTE in years
/
l2and3;andcontingenciesasdiscussedinthenewcustom31antcase-3.5 FTE staff and 4 FTE TA.
Issues such as ATWS, station blactout, emergency r
planning, fitness-for-duty, and performance of the Individual Plant Examination will all be..previously resolved on the first unit of these
- plants.
It has been assumed that the ccepletion of construction and,
~
~
i therefore, the licensing for this' case would require 6 years.
j g
2.
Legal Resources For a reactivated plant for which there is an existing ASLB decision (e.g.,
an ASLB decision authorizing operation of a two-unit plant with delayed second unit now reactivated), there remains the potential for reopening the proceeding on the grounc., of new information. OGC resource projections of 10 FTE assurre that a intervenor is able to raise a significant issue and is successful in getting the record reopened; the hearing is limited in scope to such issue. There is a potential for a motion to reopen in connection with the emergency planning exercise at about two years before the expected OL date.
If motions to reopen are filed but are not success-ful 0GC resources would be limited (from 0.5 to 1 FTE in connection with various appeals).
From this analysis the total licensing resources needed for reactivated plants with OL stage SERs and an ASLB decision have been projected to be almost 16 FTEs, inspection rescurces have been projected to be more than 35 FTEs, technical assistance resources have been projected te be 9 FTEs and OGC resources have been projected to be about 10 FTEs.
A detailed year-by-year breakdown of resource needs is provided in Appendix C.
~
/'
The resources needed for review of plants not located on a site with a
~'
currently licensed first unit; that is, plants without an OL stage SER, have been determined as follows.
Inspection resources for each year from reactivation through full power licensing are based on the inspection resources for the corresponding years in the base case.
Similar to plants with OL stage SERs additions to the base case inspection resources have been made to account for the DPFS - 2 FTEs staff and 1 FTE TA; updating the region 61 staff on the status of the design, the construction, and the inspection program - 2.5 FTEs (an increase over the estimate for plants withSERssincetheconstructionis70% complete);andcontingenciesas discussed in the new custom plant case - 3.5 FTEs staff and 4 FTEs TA.'
111-7
a Licensing resources have been projected based upon the resources for the OL stage of new custom plant licensing, which includes one edditional ' TE for project management for each of the two years associated with the htaring.
Hosever, it was assumed that reliance on the OL review documentation completed before deferral of the plant would save about 10% of the total staff licensing resources.
It has been assumed that construction completion and, therefore, the licensing for this case would require 5 years.
Technical assistance resources have been projected based upon the base case with certain adjustments. The assumption on OL stage TA resources in the base case was 6 FTEs. Additions to the base case TA were then made to, account for the DPPS and for contingencies.
2,Lt9$
For a reactivated plant without a prior ALSB decision, it is assumed thatl f
intervenors will raise a limited challenge on environmental matters and I
will actively contest the plants on safety and emergency planning issues, '
including the adequacy of the most recent emergency preparedess exercise.
The hearing would be on expedited schedule in view of the high degree of /
completion of the plant at the time of reactivation.
from this analysis, the total licensing resources for reactivation of plants not located on a site with a currently licensed first unit have been projected to be 34 FTEs, inspection resources have been projected to be 32 FTEs, technical assistance resources have been projected to be 15 FTEs and OGC resources have been projected to be 13 FTEs.
A year-by-year breakdown of resource needs is provided in Appendix C.
Figures III-7 and 111-6 are plots of the licensing and inspection resources for the reactivated plant cases discussed above.
These plots have been develosed for plants where the resumed construction activities have been assumed to ae carefully planned and full scale resumption takes place in a short time.
These figures also indicate that prior to OL issuatee, additional NRC review resources are needed soon after reactivation to resolve licensing issues on a schedule so that plant construction and operation will not be impacted.
D.
Licensino of Standard Plants The resource estimates for licensing new standard plants have been based upon compliance with the proposed new 10 CFR Part 52, resource estimates for base case licensing or new custom plant licensing, as appropriate, and the followNg assumptions:
1.
The applicant first requests an early site permit.
2.
The applicant then submits a combined construction permit and conditional operating license application that references a previously approved provides resources (approximately 80 FTE total)g NRC budget already
" certified standard design." Since the existin
-for review and approval III-8
s.
l t
byFY93ofthreecertifiedstandarddesigns(GE-ABWR,WestinghouseRESg SP 90, CE System 80+), these resources are not included in this study.-
3.
The previously approved " certified standard design" incorporates an essentially complete plant.
Resources needed for standard plant licensing have been estimated separately for each of the threr different phases of the review, that is (1) e6rly site pemit review (2) combined license review, and (3) the construction inspection / operating authorization review.
1.
Early Site Pemit Revig In accordance with the proposed new 10 CFR Part 52, an early site pemit review requires resources in the areas of emergency preparedness, site safety (including radiological review), site environmental review, site redress, project management, and inspection.
The earl has been assumed to require approximately three years.y site pemit review This assumption is based on the estimated duration of the CP stage in base case licensing.
Although the CP review is recognized to be more extensive than an early site review, the basic steps and the time to complete those steps should not be substantially different than those for an early site permit.
In some cases the early site review may be requested far in advance of actual plans for plant construction.
For the emergency preparedness portion of the site review, it is assumed that the licensee would submit general EP in'omation in accordance with option (1) of proposed 10 CFR Part 52.17(b).
Since this option only requires establisting that the site is "amenabit" to EP, review resources for the site pemit have been estimated to be one-third of the total EP review resources for base case licensing (1/3 x 0.5 = 0.17 FTE).
The site safety review (seismology, geology, hydrology, meteorology, and radiolo-gical engineering) has been estimated to include the total of the base case required site safety review and the offsite radiological review resources for both the construction permit and operating license phases.
The resulting total is 6.6 FTEs staff and 2 FTEs TA.
The site environ-mental review has been assumed to be similar to the environmental review at the construction permit phase of the base case review; hence the same resources (1.0 FTE staff and 3 FTEs TA) have been estimated to be required.
The site redress plan review required by the proposed Part 52 has been estimatedtorequireaboutIpersonmonth(0.1FTE).
project management is expected to require two FTEs per year resulting in a total of 6 FTEs for the 3 year period. A total of 2 FTEs has been estimated for con-tingencies, such as resolving difficult siting issues and supporting protracted hearings.
This effort has been assumed to consist of 1 FTE for NRC staff and 1 FTE for contractor TA.
Table 111-2 summarizes early site review licensing resource requirements whien total 15 FTEs.
M Although conceptual review of several smaller (600 MWe) advanced reactor designs (i.e., liquid metal reactor and modular high temperature gas cooled reactor)isunderwayintheOfficeofResearch,andpassivelightwater reactor oesigns are under development by industry, such designs are all excluded from this study since they are not expected to be certified during the current five-year budget planning cycle.
111-9
- i NRC inspection resources have been estimated to be 0.3 FTE. This is equal to the resources required for the pre-CP inspection phase for the base Case.
Hearings in an early site review proceeding will focus on environmental and siting safety issues. To estimate OGC resources, it is assumed that a completed emergency plan is not available at this stage, so than any emergency planning issues will be very limited, e.g., amenability of the surrounding area to emergency planning. The total OGC resources needed are estimated to be 5.5 FTEs.
Table !!!-2 sumarires the early site review licensing, inspection OGC resources and Technical Assistance requirerents of 15 FTE. 0.3 FTE 5.5 FTE and 6 FTE respectively, in tabular fom.
Fipne !!!-g is a plot of the i
licensing and inspection resources needed ove. time for an early site pemi t.
TABLE !!!-2 EARLY SITE REVIEW RESOURCES (EST!MATEDREVIEWDURATION=3 YEARS)
A.
LICENSING RESOURCES
);Vj, ' - ~,. 3
~
Emergency Preparedness 0.2 Site Safety Review 6.6(+2TA)
Site Environmental review 1
(+3TA)
Site Redress 0.1 Project management 6
1
(+1TA M+6 TA) )
Contingencies Average licensing resources:
15 FTE/3 yr. = 5 FTE/yr. (+2 TA)
B.
INSPECT 10H RESOURCES, FTE QA Inspection and Licensing Support 0.3
. Average inspection resources:
0.3 FTE/3 yr. = 0.1 FTE/yr.
C.
0GC RESOURCES FTE Hearing Support and Appealss 5.5 TOTAL 21(+6TA)
!!!-10
-o
)
1 2.
, Combined t.icense Review Jn accordance with the proposed 10 CFR Part 52, issuance of a combined license will require review efforts related to emergency preparedness, site / design interfaces, anti trust / financial qualifications, utility qualifications (including fitness-for-duty program), a hearing, and update of the site environmental review. The duration of the combined license review has been estimated to be two years.
Resource estimates have been made as described below.
The emergency preparedness review resources have been projected to be equal to the total base case EP requirements of 0.5 FTE, since the full formal emergency plan review and epproval will occur at this stage. The technical staff review of site and design interfaces has been projected to reouire about 15% of the 24.4 FTEs needed for the technical staff portion of the base case operating license review, resulting in 3.7 FTEs. The technical staff portion was determined by subtracting the project manage-ment resources of 5.6 FTEs from the 30 FTEs total for the base case operating license review.
Project management resources have then been added back at a rate of 2 FTE/ year and result in a total of 4 FTEs.
Antitrust and financial qualifications review resources have been assumed to be equal to the base case totals of 2.3 FTEs.
The staff review of the management qualifications of the applicant has been estimated to require about 0.4 FTE: the fitness for-duty review has been assumed to require 0.3 FTE, as in the new custom plant case.
Resources to update the Environ-mental Impact Statement already issued curing the early site review have been estimated to be the same as the OL base case resources for this reviewarea(1.5FTEs).
A total of 2 FTEs has been estimated for combined license review contin-gencies such as resolving difficult interface issues and protracted hearings.
This effort has been assumed to consist of 1 FTE for NRC staff and 1 FTE for contractor technical assistance. Two FTE for regional support have been projected for the combined license issuance including support for hearings principally on emergency preparedness and utility qualification issues.
The bulk of the regional resources woulo be needed during the design certification and construction inspection stages.
000 resource projections assume that the emergency plan is submitted with the combined license application and is vigorously contested.
Safety issues (e.g., plant-specific compliance with Part 50 requirements) are expected to be limited since it is assumed that the application will reference a certified design and will be limited to plant-specific compliance with the certified design.
OGC resources of 7 FTEs are projected.
In view of the two year schedule for the combined license, it is assumed that the hearing will proceed on an expedited brsis.
If the request for hearing raises a large number of significant issues, it may not be possible to meet the 2 year schedule.
Table III-3 displays the total combined license review resource require-ments of 14 FTEs for licensing, 2 FTEs for inspection, 7 FTEs for OGC, and 1 FTE of Technical Assistance.
III-11
~
TABLE 111-3 COMBINED LICENSE REVIEW RESOURCES (REVIEW DURATION = 2 YEARS)
A.
LICENSING RESOURCES E
Emergency Preparedness Technical Interfaces Review 0.5 3.7 ProjectManagement(2FTE/yr.x2yr.)
'4.0 Anti trust / financial qualifications Utility Management Qualifications 2.3 Fitness for-Duty 0.4 Environmental Update 0.3 Contingencies 1.5 1
(+1 TA T4T+1TA))
Average licensing resources:
14 FTE/2 yr. = 7 FTE/yr.
B.
INSPECTION RESOURCES FTE Regional Support for Licensing 2.0 Average Inspection resources: 2.0 FTE/2 yr. = 1.0 FTE/yr.
C.
OGC RESOURCES FTE Hearing Support and Appeals 7.0 TOTAL 23 FTE (+1 TA) 3.
Construction Inspection / Operating Authorization Review Construction inspection efforts have been assumed to begin immediately after the issuance of the combined license when licensee construction is expected to be initiated.
Licensee construction efforts are expected to take about seven years.
Standard plant construction duration is estimated to be about 2 years shorter than for the custom plant due to efficiencies resulting from having the total design completed and approved in advance.
Construc-tion inspection efforts and total resources needed are expected to be the same as those for the base case and custom plants.
Three inspection phases, construction ins pnasehasbeene)pectionprogram(CIP),preoperationaltesting/ oper readiness (PTOR, and startup testing (STP) would be utilized.
The CIP stimated to take 5 years, the PTOR phase has been estimated to take 2 years starting in the sixth year, and the startup phase has been assumed to occur during the year after oaeration is authorized, inspection described in Section !!!.A.2. resources are estimated by phase using tie budget model p team Resources for a construction appraisal model(predictions. CAT) inspection and for contingencies have been added to the bu A resource total of 50 FTEs for inspection results from summing each component as can be seen in Table 111-4.
!!!-12
g TABLE !!!-4 CONSTRUCTIONINSQCTION/0PERATINGAUTHOR!?1,TIONRESOURCES A.
INSPECTION RESOURCES Phase FTE Phase FTE/yr Duration Total CIP 5.9 5
29.5 PTOR 5.6 2
11.2 2
STP 4.6 1
4.6 CAT Inspection 2
contingencies 0.3 8
.2.4 (+2.4 TA) 50 (+2 TA)
B.
LICENSING RESOURCES FTE/YR Duration FTE Project Management 1
8 8
1 2
2 Technical Review 0.1 7
0.7 Contingencies 0.4 8
3.2(+3TA) 14 (+3 TA)
C.
OGC RESOURCES Hearing Support and Appeal-6 Total 70(+5TA)
NRR licensing review activities would also take place during facility cohotruction.
Early in the CIP phase, it has been assumed that NRR involvement would include a NRR project manager and selected technical support staff assistance to the regional office for resolution of new tec1nical issues that arise as construction proceeds.
It has been assumed that similar NRR support would also be provided during the PT0R phase.
NRR involvement would increase when the licensee submits a request for authorization to operate about six months before startup.
Thereafter.the facility review should require only the NRR resources needed for an operating reactor.
Therefore, NRR resources during the construction-inspection / operating authorization phase have been assumed to include a project manager and about 1 person-month / year for resolution of technical concerns during construction. -An additional 1 FTE/ year for project rnanagement has been added during the last two years to accomodate the issuance of the operating authorization. A total of 6 FTEs has been added for contingencies, with an assumed breakdown of 3 FTC: for NRC staff and 3 FTEs contractor technical assistance.
From Tabie III-4 it can be seen that the resulting total is 14 FTEs for licensing resources.
III-13
- _ _ _. _ ~
j i
i DGC resource projections assume that an intervenor is able to satisfy the j
threshold requirements to raise a significant issue at this stage; the hearing is limited in scope to such issue.
For timing purposts, the issue is assur,ed to be raised two year; prior to the espected date of the operating authorization.
OGC resources of about 6 FTE are projected to support the hearing and appeals.
If a hearing request is filed but the intervenor is unable to satisfy the Part $2 hearing threshold, OGC resources would be limited to between 0.5 and 1 TTE in connection with various appeals.
J Total NRC licensing and inspection resources needed over time for the combined license review through the issuance of the operating authorization and the comsletion of the startup test program are shown in Figure !!!-10.
4 Note that tais figure does not include resource estimates for the early I
site review phase which are shown separately in Figure 111-9.
In summary, resources required for review of a standardized plant (including early site review, combineo license review, construction inspection and issuance of an operating authorization) are predicted to be 43 FTEs for licensing 52 FTEs for inspection,19 FTEs for OGC and 12 FTES for technical assistance. A year by-year breakdown of these required resources is detailed in Appendix C.
2 i
1 e
111-14 2..- - - --. -. - -.-.-.
Figure ill-1. LICENSING RESOURCES EXPENDED VS. CP ISSUANCE 20 18-16-0 W RBLE Hlu.
O PERW 14-
.t) 2 0 JAMESPORT 12-4 0 PHIPPS BEND b
0 RN'ER BEND OYE1J.0W CREEK 0 SEABROOK d
T.10-o PALO VERDE E{
o SOUTH TDAS h
0 GRAND OU'I
]
6-CAU.AWAY o
YOOTLE o BYRON 0
WILLSTONE 3 4-2-
1 0
l l
l l
l 74 75 76 77 78 79 YEAR OF CP ISSUANCE III-15
i Figure ill 2. LICENSING RESOURCES EXPENDED VS. LPL ISSUANCE 1
50 4
45-O swmtoni i
a>
e>
~
0
,d voortt1
.L, A 50
--)
- - -,, o y, _ _ -
-o m,.
b 0
Pu voet t 0 uusix s b
0 'WUI IDO 1 0 WuND WJ 25-
.O i
Z l
M h20--
.O.
-]
o my 0
we' oex J
15-4 10-1 5-0 l
l
- 82
. 83-84 85 86 87 YEAR OF LPL ISSUANCE-III-16
. _ _ _, _ _ ~. _. _.. - - _ _. _. _ _...... _... -. -., _,. -. _. -. _.. _. _.
Fig u re Ili-3.
LICENSING RESOURCES (BASE CASE) g a
(
t E
L.
e s
s
'*;4--
E E
o 1
2 3
4 5
6 7
8 9
10 11 12 13 YEAR AFTER RECEIPT OF CP AFPLICATION
Fig u re 111 - 4.
INSPECTION RESOURCES (BASE CASE) 7
- g g g 3
- 2 i
e--
e 5--
m 84--
Z
' ' ^ " ^ " ' ' " " ' ' ' " '
" ^ " " ' '
^ ' '
l i
k 4
i Fig u re 111 - 5.
LICENSING AND INS P ECTIO N RESOURCES (BASE CASE) 2 LEGEND a
M LICENSING is--
a w
O
=
O INSPECTION u
M d
ia To rA'.
14--
I I
tr 12--
I d
f' f
t 7
i
)
$ to--
b
(
n_
r r
r La f
(
(
i l
b 8--
g g-I
(
f.
e__
?
p gT 3r f'
7
[
4 f
f r
f f l
)
i v'
f'
$ i s-3 I
h f f F'
3 f'
3 p
3 l
8 e
2 s
j r
.1 g
a f
i r
};
$j (
j-f 3-E l
?;
p2 c,>
,2 j
v 2
,m
_J o
7
>7 j
1 2
3 4
5 6
7 8
9 10 11 12 13 YEAR AFTER RECEIPT OF CP APPLICATION l
Y Fig u re lil-6.
LICENSING AND INSPECTION l
RESOURCES (NEW CUSTOM PLANT) i 2
,1 LEGEND ts--
/5 LICENSING
[
D
~
16--
y C
~
INSPECTION i
[
f E
y f
4-TO l'AL u
24--
f
(
i t
} '*
E
(
t 6 10--
-h r
Q-tJ f
f t
j
,Z a--
p-f c
F i4 f
y s
i e_. j [gf
[
f f' f e
7.
f'
('
G
(
f r
f
?
l
/
9
/
/
4__
6 f f (f-(
I
?
3
- ,g-3 j
j j
p p
h
(
h I
>g p
h I
3 r
2--
-j f
g.
3
?
?
?
?
y
?
c 4
l f
G
('
S
{
i 7,
L T'
0 1
2 3
4 5
6 7
8 9
10 11 12 13 YEAR AFTER RECEIPT OF CP APPLICATION
4 i
l Figure 111 - 7. LICENSING & INSPECTION RESOURCES l
REACTIVATED PLANT WITH ASLB DECISION L
CONSTRUCTION 40% COMPLETE i-l LEGEND a
O i
Ppy w
g;, M LICENSING is--
g w
INSPECTION l-r
.4 l'OTAL I'
j 14--
l l
i g 22--
1 10--
/
g a_
j w(
g..
e' s
i f.
I l
h i
(
I f
[j
[
e r
4 l
'?
,4~
f 1--
i fj
- j
(
l J_
a._._,'.',-
- . <_,,,,_k.
{
l 4
{
0-a 1
2 3
4 5
s l
j YEAR At-1 ER REACTIVATION
~
f
Figure 111-8. LICENSING & INSPECTION RESOURCES REACTIVATED PLANT WITHOUT ASLB DECISION CONSTRUCTION 70% COMPLETE 2o LEGEND O
b /$
LICENSING
[" < g
{
is--
c2 INSPECTION 1s--
h
(;
2 0
TOTA 1.
24--
(g p;
f<
g; 22--
/
~
id
'/
/
[/
p r,,
m,o--
p f4
/'
6 y
e 1
,;j's j;
r i
a--
?;
x l
r
<a 7
a--
/,f f
l f
f)
/
/-
f;
/,
e
/;
.c X
i e
{/
?,,
f I
i 2--
/
/
f,
'{
YJ
!/
/_.
e n
1 2
3 4
5 YEAR AFTER REACTIVATION
mm cwe.
NO G
T N
I I
C S
E N
P E
D S
C N
N I
S L
I E
E 3
4 G
C v.h E
3
,3 R
L g.j f
UO l
SE R
N N
O O
T )W I
I
. " + - y.~-
4.,,,
- c. !: ::y T
1 1
~..2 x.x.... i
,C;,,;;
- s ;.
,.t y, y., :
.,,,,;,i C E A
..X.
. A+ y.
++-
- v. p..X<vtEy+y.,s 9... s. '8,p..
- Xe*.. 54yC ".s s
EI
~-
C 3I PV g.
9-A+ 4.y,0.., y,/.
.X,'.y,+
s' 9 $.,y L
,y..y.y<.{,.c<, ;v,gbgc+pv,v,y'$,g" y p j ; -
3.;,;.
f.p
/
S E w c..,"O c,.
v 4O +Cul.
, p,,s,9c+i$.,,
P c.
9 N R gc,
'c ;
sl
,l r
P I
E A
&T F
IS O
GNY
,.h.a,.
-,, s,.
. a;,,- ' '- "',,2.... :
.7,-
t w I:..;
c T
.,. /, ' e. ' r ' s,.
s' :
L
. y. ::./v 2P
^
e -
9.. f...>y/, '.,. '*..,..
. '. <.' p....;y.4c.<. $ yf ;.
'y.<'
- ..7,s k n.y+ 5 I
[
S R
~
? :-
I NA
<X -;
s /.
E EE k.s.v4,s 9/.y;.
pc'.gCrKEK;.gv,,.,Egcp,c.h@,5 :." s,,,;cr,.
,r.
f., c
. g,..
^
C rH c;r C(
E IL R
R 9
E
,;.;.l 4,.
..;;,..;..,..^.>,p.;X"d.,>,'M:
.r 1
1
.9
- /7.
1
..s.+.. /.,.,. y"y,.'g. e
/c,.
y,.
1 l
..,, ~
/<-.
- 4..
1 A
f f
d o.r
..y. ~.
a..
E
,.9,4v ' ;,
,,f.
,.y./,
,. Cs4'
/ e,/..
X f k lm,r, R
i,.
R
,c, ;,.,f,, ', 9lRN, fv,c,,,-
c.
U
,c./s 3sgc %9cc A
G EY IF 5
4 3
1 g
w L Wq C
I f
I FIGURE 111-1 O. LICENSING & INSPECTION RESOURCES (COMBINED LICENSE APPLICATION i
REFERENCING A STANDARD PLANT AND A PRE-APPROVED SITE) 2 LEGEND
,u i
b E
l 20--
=
LICENSING
=
v t
i:
INSPECTION ic--
x j
E-s
?.
'; # J To FA!.
14--
5
?!
=
R H g i2--
m i
r y
y p
,e g
{
$ io--
/
/
l a-1 p
/
\\
tog o--
f^
('
i t
r, l
(
p i
e
^
~
{
h J
f i
j
(
\\
a--
h r
9 f
y 4
i f
i 7'
j 6
F s
r
/
l
/,
/
+
~
i 4--
- )
e a
i
,/
/, f
~
9
,1 4
J
/
/
e l
h Y.
Y I
2 g
g p
c, p
'h h
5 h
's h
i 1
s a
1
/,
p f
p
[
t j,
/,
f
/
e
/
1 7',.
e 2
s o
,2
,a
,2
.,2 t
1 2
3 4
5 6
7 8
9 10 I
YEAR AFTER RECEIPT OF APPLICATION i
i
o CHAPTER IV. NRC GUIDANCE FOR NEW APPLICATIONS A.
Introduction As part of this study, an assessment was made of the need for updating guidance documents for the licensing of new plants or sites for both the staff and applicants, and the staff rescurces required to accomplish any needed updates.
The primary purpose for issuing new guidance is to incorporate lessons learned from operating and other relevant experience, and provide greater stability in the licensing process by promoting unifomity and consistency in applications, staff reviews, and inspections.
Clear guidance to applicants also facilitates both the preparation of documents for staff review and the actual review itself.
Clear guidance to the staff promotes a consistent application of the governing criteria to each application, and constitutes management approval of the scope and depth of the reviews and inspections.
The following assumptions and discussion served to focus and fom the basis for detemining which guidance documents should be revised.
In general, only areas which cannot be included in the design certification reviews for standard plants were considered as candidates for updating. The vast majority of these are site related, although financial planning for decomissioning and physical security are discussed in this chapter because of recent or iminent rule changes.
Reactor and plant systems were excluded. This limitation in scope follows from the expectation that the majority of new plant applications will incorporate a standardized plant design.
Since three standard design certifi-cations are already scheduled for completion in the early 1990's by the NRC, revision of guidance for alant and reactor systems would not likely to be completed on a schedule w11ch would contribute substantially to these certification efforts.
in addition, since only a few custom plant licensing applications are expected, no general guidance updating appears to be justified.
There are three licensing guidance fomats used by the staff to assist both applicants and staff in the preparation and review of applications.
These aretheStandardReviewPlan(SRP).TheEnvironmentalStandardReviewPlan (ESRP), and the Regulatory Guides.
With regard to site related activities, the entire ESRP must be considered, about 30 sections of the SRP (mostly Chapter 2) must be addressed and about 20 Regulatory Guides (primarily guides in Division 1 - Power Reactors and Division 4 - Envir 'nent and Siting) need to be included.
The ESRP wds last updated in 1979.
Reg ry Guides have varied revision dates but most have not been updated sir.,
the 1970's.
Thelast(major) full scale revision of the SRP was 1981.
The NRC Inspection Manual provides inspection requirements, guidance, end policy for implementation of the inspection program during construction and operation of power reactors.
The construction inspection program implementing manual chapters and accompanying procedures require some FTE-intensive revisions.
The operations inspection program has recently undergone a major revision and is generally up to date with no major revisions needed.
B.
Needed Additional Guidance Related to Rule Changes Changes to several rules in the past few years have resulted in the need for additional staff guidance. These inc;ude 10 CFR Part 50.33(k) and Part 50.75 regarding Decomissioning Funding and 10 CFR Part 73 (Physical Security).
The specific infomation which a new applicant cust submit for a staff rey; with IV-1
l regard to decomissioning needs to be delineated in a new Regulatory Guide. A new Standard Review Plan Section is also needed.
Likewise two new guides need to be prepared, one to address Fitness for Duty, and the other to address Access Authorization. A revision to SRP 13.6 (physical security at pown plants)isalsonecessary.
For Emergency Planning, new guidance is required because of proposed rule r. wges to 10 CFR Part 52, and as a result of lessons learned and experience gained in the course of planning reviews and exercises and in adjudicatory proceedings.
Another consideration is the impact of aroposed Part 52 "Early Site Permits; Standard Design Certifications; and Com>ined License For Nuclear Power Plants."
With regard to emergency planning submittals, the proposed Part 52 allows options ranging from submittal of gentral infomation which indicates that a site is amenable to emergency planning, to submittal of a complete emergency plan.
Detailed guidance for each option need to be included in Regulatory Guide 1.101
- Emergency Planning and Preparedness for Nuclear Power Reactors" or a new guide needs to be issued.
In addition the proposed 10 CFR Part 52 (in both subpart B and C, contents of applications) requirei a part of the appli-cation the
- Proposed tests, inspections, analyses ed acceptance criteria which are necessary and sufficient to provide reasonable assurance that, if the tests, inspections and and analyses are perfomed and the acceptace criteria met, a plant which references the design is built and will operate it, accordance with the design certification." This requirement may involve submitta.1 and licensing review of system specific preoperational and startup tests procedures, among other things, in the past, detailed procedures wers nomally finalized 3 to 4 years prior to initial criticality and reviewed by regional inspectors during the nomal construction inspection program.
Reg. G"Me 1.68 " Initial Test Prograns for Water Cooled Reactor Power Plant;" needs t.x 3e revised or a new guide issued to reflect these requirements of 10 CFR 52.
One additional rule change related to siting is considered to be desirable for future plants, inis is in the area of seismic and geologic siting l
criteria (Appendix A to 10 CFR Part 100).
For exam >1e, guidance is needed t
to define standards and methods for determining suci parameters as the operating basis earthquake, and shutdown and restart criteria.
In addition to the rule change itself, a new regulatcry guide and revisions to Standard Review Plan Sections 2.5.1 through 2.5.5 are needed.
C.
Needed Additional Guidance Related to Standard Review Plans and Reglatory Guides
- f..
Environmentai,
irdReviewPlan(ESRP)
The ESRP was last updated in 1979. The document serve:; as the staff guide for the preparation of the Draft Environmental Statement (DES) and the Final Environmental Statement (FES).
This document in conjunction with Regulatory Guide 4.2 (Contents of Environmental Report) provide the basic guidance documents for the staff and applicants with regard to NEPA requirements.
In general these documents still provide valid guidance.
However, several sections of ESRP were never finalized.
These include the following sections: 8.1 " Description of the Power System"; 8.2.1 " Power and Energy Requirements"; 8.2.2 Factors Affecting Growth of Demand"; 8.3 "Pewer Supply"; 8.4 " Staff Assessment of Need"; and 9.2 " Alternative IV-?
Sites". These should all be finalized.
In particular, a ma or addition is necessary for Section 9.2 " Alternative Sites"jor revision This has been a much litigated issue in several previous applications. The ESRP also needs a general update with regerd to currently endangered species.
2.
St. Jard Review Plan The Standard Review Plan sections which address site suitability are pri-marily those in Chapter II. As discussed above, sections 2.5.1 through 2.5.5 will need te be revised assuming Appendix A to Part 100 is revised.
Other sections of the SRP related to siting need only mir.or revisions.
(
Aside from the siting sections, revisions to the SRP will be needed to address Financial Qualifications for Decomissioning and Physical Security.
3.
Regulatory Guides Staff effort will be needed to modify existing regulatory guides or to develop new guidas.
Since a number of these guides are needed for plany currently operating, the resources needed for revision of them are not incluoed here. In the area of Radiation Protection Standards, 7 new gold s arc required 3 other guides need major revisions, and about 22 rinor rwisions are necessary.
A new guide discussing the decomissioning aspects d the financial qualification requirements of 50.75 is likewise needed.
The mes. recent Physical Security Rule changes result in the need for two new gu w s, one dealing with Fitr.ess for Duty, the other addressing Access Authorization.
However, both of these areas are judged to be equally applicable to plants already licensed, and therefore the deve'op-1.
ment of outdance should nct be attributed solely to new plant licensing i;
needs.
If Part 52 is issued as currently proposed, then Regulatory Guides J:
1.68 and 1.101 will need to be revised or new guides prepared describing A
staff requirements regarding applicants testing and inspection programs and emergency planning options respectively.
With regard to plant siting, a number of Regulatory Guides (or assMiated NUREGs) need major revisions and others need minor changes to incorporate lessons learned from operating experience and to clarify the staff's current interpretatior, of the applicable regulations.
4.
Inspection Manual The construction inspection program is divided into four areas defir 1 activity-specific inspection phases.
They include (date last revi.
in parenthesis) the pre-construction permit (1977), construction (1950;,
preoperational testing and operational readiness (1984), and startup testingphases(1984).
Prior to the onset of significant new construction activities.-all phases of the construction inspection program need to be examined and modified /
uadated to ensure lessons learned from the recent past are factored into tie inspection process.
For example, in the past the NRC has not focused on the factors of managerent capability and prior nuclear experience during the Pre-CP construction phase licensing and review. The existing Pre-CP construction phase inspection procedure needs revision (1977 vintage) and should focus on the utility's management capabilities and prior nuclear experience to oversee a large construction project. Other potential IV-3
~.-..
3; y
-changes for management consideration include erpanded regionally based team inspections; continued shift in emphasis fram records review to direct rqrk observation; integration of a fem of the licensee readiness review process, as used in Vogtle 2 pilot program.
With the promulgation of Part 52, a companion inspection procedure is needed to implement the testing _and inspection Regulatory Guide previously Ldiscussed in this. Chapter.
- D.
)_RC Resource Requirements for Needed Additional Guidance
,The resources needed to complete the guidance documents discussed above are Rule Changes 2 FTE
-SeismicandGeologic_ Criteria (Part100AppendixA)-
Environmental SRP
- Finalize Sections 8.1; 8.2.1; 8.2.-2; 8.3; 8.4 2 FTE
- Methodology for Alternative Site (Section 9.2)
- Update.For_ Endangered Species Standard Review Plan 2 FTE Sections 2.5.1 through 2.5.5
- New Section on Decomissioning Regulatory Guides 8 FTE 1
i
- Geologic and' Seismic' Guide
- Siting Guides 7
- Testing and Inspection. Guide i
Inspection Manual 5 FTE
- Revise' Construction Inspection Manual Chapters and Associated Procedures
)
- Develop m.ng and_ Inspection Cuide Procedures TOTAL 19 FTE These resource esticates are based upon discussions with technical staff in NRR and RES, and estimates. prepared for a similar study _on guidance documentation needs for. license renewal reviews.
SRP and ESRP revisions were estimated as requiring 0.3 FTE per task.
One exception is ESRP Section 9.2, Methodology for Alternative-SiteEvaluationswhichisjudgedtobealargereffort(0.5FTE).
Regulatory Guide changes were estimated at 0.4 - 0.5 FTE and the' major revision to NUREG 0654 Emergency Planning Guidance (0.8 FTE).
Resources-are not included fort 2 Physical Security regulatory guides nor the Physical Security SRP changes-for.the' reasons discussed above. The 0.2 FTE to update the Inspection Manual's physical security procedures are also not included.--The above resource needs
'do not include resources which are alre.ady budgeted for the preparation of guidance to address severe accident considerations.
IV-4
- 3 The time at which these updated guidan:e documests should be available is, of course, dependent upon when the future apolications which could benefit from these 9uidance documents are filed with the H M.
45 will be discussed in the next Section, DOE has made projections of future nuclear casacity for the years 1990 through 2020.
Based on these projections, it seems licely that future applications that would benefit most from these updated hRC guidance documents will first be filed with the NRC in the 1994-1995 time frame. Accordingly, the resources of 19 FTE spread over two years to develop and complete these docurrents by that time should be provided in the 1993 and 1994 NRC budgets.
L I
l IV-5
~.
3 CHAPTER V.
NRC RESOURCE REQUIREMENTS FOR SATISFYING DOE NUCLEAR CAPA':ITY PROJECTIONS Projections for future nuclear capacity have been made in a study by the Department of Energy (DOE) entitled "Comercial Nuclear Power 1988:
Prospects for the United States and the World," 00E/EIA-0438(88), published September 1988.
The DOE report contains capacity projections for the years 1990 through 2020.
These projections are reproduced in Figure V-1.
DOE has assumed that no nuclear plants steming from new orders (as distinguished from reactivated plants) would be operable until at least 2006. DOE has made this assumption based on the limitations of nuclear utilities, reactor ano equipment vendors, designers, and constructors to complete any new nuclear orders in this time frame.
One factor, for example, is that large companies such as reactor vendors and architect-engineers, have shifted into the service business. Also many small venoors no longer manufacture nuclear grade components.
The difference between the DOE upper reference case and the DOE lower reference case up to 2005 results from different assumptions on the completion dates of those currently deferred plants having some construction completed.
For example, the upper reference case assumes that one such reactivated plant will be completed in 1995, one in 1996 and one in 2003, while the lower reference case assumes that none of these three plants will be reactivated in this time frame. Taking inc account previous estimates for leadtime, as explained in Chapter III, Section C, applications for reactivation would be received by the NRC in 1990,1991 and 1998, respectively if the DOE upper reference case is realized.
Beyond 2005, the upper reference case has been based on energy needs from projecting growth in nuclear capacity using an aggregated model that derives nucleargenerationrequirements(andinstalledcapacity)asashareof delivered er.ergy. Delivered energy has been projected using a demand function composed of economic growth and the growth rate for the price of aggregate energy. The lower reference case does not change between 2005 and 2010. The lower reference case after 2010 has been developed using a similar methodology as used in the upper reference case, but has been adjusted to reflect a lower rate of capacity growth.
The DOE lower reference case indicates no increase in nuclear capacity until 2011.
However, in 2007 a decrease of one gigawatt (GWe) of ca pacity has been assumed to occur by DOE as a result of decomissioning.
To ma(e up for this loss, one new 1200 MWe plant would have to become operable by 2007. Since the l
DOE lower reference case assumes no reactivated plants will be completed, the i
one new plant under these DOE assumptions would have to be either a custom or standard plant.
It is estimated that a custom plant would take 12 years from CP application to initial operation, and that a standard plant would take 12 years from application for early site review to initial operation. Accordingly, for this plant to be operable in 2007, the application for the custom or standard plant would have to be received in 1995.
The projected NRC staff m ources for satisfying the DOE lower reference case (that would first be needed in 1995) are listed in Table V-1.
These resources are those needed to l
process the future application only; resources for guidance development are not included in this table.
V-1
. s.
The upper reference case in the DOE report projects that 114 GWe of nuclear capacity will be needed in 2006. an increase of 6 GWe from 2005.: Thus, five new approximately 1200 MWe plants would be needed-by_2006 in addition to the three reactivated: plants-previously discussed.
To meet the goal of five new plants-by 2006, the five applications for these plants would have to'be received-in 1994. Applications for the three reactivated plants would be received in 1990, 1991 and 1998.
In 2007.-the upper reference case projects that six more plants would be needed.
Using the previous leadtime_ assumptions, six more applications would have to be received in 1995.- Including-the five plants needed to meet the 2006 projection, a total of eleven new plants would be needed by 2007.
~Most of the new plants will be standard plants. Thus -to meet DOE's upper reference case, it seems likely that the following-applicStions_ would be received:- three reactivated plants (one in 1990, one in 1991, one in 1998),
twi custom plants (one in 1994, one in 1995), and nine standard plants (fourin1994,fivein1995)4 Using these assumptions, the total NRC staff resources needed to process the future applications that would satisfy DOE's upper reference case are listed in Table Y-2 for 1990 and the subsequent five
~ year planning period.-
6 V-2
- s
'e TABLE V-1 NRC RESOURCE PROJECTIONS IN FTE FOR SATISFYING DOE LOWER REFERENCE CASE 1990 1991 1992 1993 1994 1995
-Custom Plant
. Inspection 0.1 7
Licensing 6.4 Legal.
1.6 Technical Assistance 1.7 Total TE Standard Plant Inspection 0.1 Licensing 5.0 Legal 1.1 Technical Assistance-2.0 Total ~
TY TABLE V-2 NRC RESOURCE PROJECTIONS IN FTE FOR SATISFYING DOE UPPER REFERENCE CASE
-1990 1991 1992 1993 1994 1995 Inspection 6.7 10.9 12.4-16.4 13.2 5.7 Licensing 3.5 9.5 15.0
.19.0 42,0 63.3 Legal-1.5 4.3 5.1 5.6 11.5 17.0 Technical Assistance 1.0 3.0 6.0 10.0 17.7 23.4 Total 12.7 27.7 38.5 51.0 84.4 109.4
- h'
(
l V-3
rIGURE y-1:
EXCERPTED rnor: DOE /EI A-0 4 3 8 (8 8 )
Figure 2.
Domestic Nuclear Capacity, 1982 2020 200
" " * " ?!
W
]$
tr Td O
'g
/
M
/
I$
175'-
4 st Upper w
,4 f,$
Reference f
_0 8
01 3
8
?fj e
150 -
/
~<
s O
f Z
~
u
~
e f
12 5 -
Il e
C
- n E
~
/
r....T 1
0 o
A inon' A inn s eie *++
= = e a. *,
v #" ',,, na - r: - :
o c
w 10 0 -
f.;
T, v
.m a
.C
~
Lower ij o
e Reference
+
d 75-
.e' S9 o
a L)
.1, rF
!?a
.f c.
m o
a.
g*
O No New Orders
?.
=
50-T 5!
E 8
z d
u<
I$
a 25-4; 1
tW m
0
~
1980 1985 1990 1995 2000 2005 2010 2d15-2020 Year of Activity Source See Table 8 and Energy Information Administration. Monthlv Enerry Review January 1988. DOE, EI A-0035(88 '01) (Washington DC April 1988)
V-4
~-
e CHAPTER VI.
NRC RESOURCE IMPACTS OF PROCESSING EXPECTED FUTURE APPLICATIONS The' impact of processing future applications on the NRC five year budget cycle from 1991 to 1995 will vary widely depending on the number and type of appli-cations projected to be received each year.
Comparison of the licensing scenarios presented in Chapter III shows that resource requirements for new custom or standard plant licensing reviews are significantly lower during the first three years tian those for reactivated plants. Thus, needed budget adjustments would be less severe for a new plant application and could possibly be made early in the current five year planning period if such a new plant application was scheduled to be received in 1994-1995.
In examining the DOE projections, it is noted that the lower reference case does not assume any plant reactivations during the planning period from 1991 through 1995.
Rather it assumes that one 1200 MWe new custom or standard plant will come on line about the year 2007.
To allow sufficient time for design and construction, an application for a construction permit for such a plant would have to be received about 1995.
To support an application received then, guidance documents would have to be updated during the previous two years.
The DOE upper reference case assumes that one reactivated plant will be completed in 1995, one in 1996 and one in 2003 in addition to five new plants that would need to be completed by 2006.
Therefore, reactivated plant applications would have to be received in 1990, 1991 and 1998 and the applications for the five new plants would have to be received in 1994.
During the current five year planning period, it seems logical to assume that new nuclecr generation is more likely to come from a reactivated plant rather than from a new custom or standard plant.
Such a partially completed plant could be on line more rapidly than a plant that has not yet been sited. Thus, areactivatedplantwouldprovideamorerapidresponsetoasignificantly increasing load growth or to heightened concern related to the greenhouse" effect.
Since'the DOE upper reference case projects two applications for reactivated plants will-M received early in the 1991-1995 five year planning period, it seems prudent for NRC to assume that at least one of these applications will be under active staff review beginning in 1991. We recommend that this approach be adopteo for budgeting purposes.
Listed below are the NRC resources needed to review one reactivated plant application received in 1991.
The table also includes the resources needed to i
upd6te needed regulatory guidance documents which are discussed in Chapter IV.
NRC FIVE YEAR PLAN RESOURCE NEEDS FOR PROCESSING FUTURE APPLICATIONS 1991 1992 1993 1994 1995 Reactivated Plant 12.7 15.0 23.5 27.5 14.4 Application Review 9.5 9.5 Update Guidance None of these resources are contained in the current NRC budget.
VI-I
'o CHAPTER VII. ORGANIZATIONAL STRUCTURE This chapter addresses modifications to the current NRR organization that would facilitate the safety and environmental reviews of a number of future license applications. Since the current NRR organization was formed primarily to emphasize the regulation of operating reactors, a brief description is first provided of the NRR organization which was successfully used in the late 1970's to review significant numbers of construction pennits and operating license applications.
A.
Prior NRR Organization (late 1970's)
The Office of Nuclear Reactor Regulation was divided into the Division of Project Management (DPM). Division of Systems Safety (DSS), Division of Site Safety and Environmental Analysis (DSE) and the Division of Operating Reactors (00R).
The Office also included the Antitrust and Indemnity Group and a Program Support Branch.
The major responsibilities and interfaces of DPM, DSS and DSE are discussed below.
1.
Division of project Management (DPM)
The Division of Project Management was responsible for overall management of all safety-related licensing activities on commercit.1 power reactor facilities, including the processing of applications.
In this context, overall management included both the technical and the administrative
[
coordination functions.
l The role of the license application project manager was to schedule and coordinate the technical specialist reviews and to perfonn an overall l
l review of the opplication in order to provide integration between review areas, to ascertain that the review was completed in all areas, and to assure that the evaluation of the application represented a balanced and well-considered effort.
l
.The individual licensing project managers for light water reactors were
. organized into branches which reported to an assistant director for LWRs; project managers working on other reactor types (i.e., LMFBR, HTGR)
L d
reported to a different assistant ofrector, l-2.
Division of Site Safety and Environmental Analysis (DSE)
This division was responsible-for all of the site safety and environmental aspects of application reviews.
It consisted of technical experts in these areas (such as geosciences and effluent treatment) as well as environmental-L project managers who managed the environmental portion of the review.
Some of the specialists participated only in the environmental review p
while some were involved in both the safety and environmental reviews, 3.
Division of Systems Safety (DSS _1 This division consisted of technical experts in all of the engineering and reactor systems disciplines.
The expertise within the branches was primarily available to the licensing project managers in carrying out their management respcnsibilities for review of new applications. While the project manager considered each project on an individual basis, the VII-1
1 DSS branches were able to assimilate operational experience in specialized areas of technology, and thereby achieve a more generic viewpoint.
B.
Organization Modifications for New Licensing Reviews An essential feature of the prior NRR matrix organization described above was that the aroject management function was separated from the technical review function )y the creation of separate divisions.
In this arrangement a single projects division was responsible for planning, scheduling and overall management of the licensing reviews.
The technical divisions were composed of individual branches of highly expert technical specialists who looked at all issues within their area of special expertise.
The existing NRR organization is composed of two projects and five technical divisions.
The projects divisions are divided into assistant directorships which are made up of individual project directorates. The technical divisions are composed of technical branches of specialized expertise.
This existing organizational structure can be easily modified to accommodate any number of new license applications and still maintain the advantages of a centralized project management staff and a centralized technical staff.
The specific details of the organization would depend upon the number of applications received; however, the structure of the NRR organization need not depend upon the type of licensing review process utilized for new applications.
This is I
because similar types of technical review and project management expertise are needed for both the Part 50, two-step licensing process and for the proposed new Part 52 licensing process.
1.
NRR Projects Orgenization For a single new or reactivated plant application, the project could be assigned to a project manager within an appropriate existing project directorate, along with the necessary project management and/or project engineer resources.
The project directorate (PD) would be responsible for management of both the safety and environmental review areas.
In order to assure adequate visibility and priority for the new application review, the project manager should report directly to the Assistant Director.
After a sufficient number of new applications have been received, a new project directorate dedicated to new application reviews should be established.
If more applications are received, additional licensing project directoratos could be created.
2.
NRR Technical Organization Needed additions to the NRR technical staff for the review of applications for new or reactivated plants should be placed in the existing NRR techni-cal review branches, with the exception of the site environmental specialists and certain types of site safety specialists.
The current NRR organization does not include these two types of disciplines.
Previous NRR reviewers in these fields have either left NRR or are working in different areas.
New NRR staff members trained in these areas would need to be obtained and probably located in a new technical section or branch in the appropriate technical division. Additional environmental review expertise could be obtained from technical assistance contractors whose work would be managed and reviewed by the NRC environmental and site specialists.
VII-2
a,,
These contractors could be used to supplement the NRR staff without modifying the NRR organization as the number of new applications grew.
3.
NRR Antitrust and Financial Review Organization The additional resources needed to perform these reviews should be assigned to the branch in NRR that is currently assigned the responsibility for such reviews under the existing NRR organization.
4.
NRR Inspection Oversight Organization Headquarters programmatic oversight and guidance for inspection would continue to be provided within the current organizational structure. The NRR Inspection and Licensing Program Branch would be responsible for providing oversight and guidance for new or reactivated construction inspection program.
Inthepast,aheadquartersbasedConstructionAppraisalTeam(CAT) inspection was performed during the pTOR phase.
NRR staff expertise capable of leading and conducting the CATS for the reactivated plants resides in the NRR organization but would have to be augmented. As previously, the hRR resources could be supplemented by contractors.
S.
Regional Organization When construction commences for any one of the new or reactivated plants, construction resident inspectors should be assigned to the projects organization of the appropriate region.
Also additional construction
' inspection specialists should be assigned to the region's technical organization.
As construction of additional plants is approved by NRC, additional resident inspectors and construction specialists could be assigned to the Regions without significantly impacting the existing regional organizational structure.
e -
VII-3
'o CHAPTER VIII. CONCLUS10NS AND REC 0W.ENDATIONS The enclosure to the ED0's September 21, 1988 memorandum to the Chaiman provided six objectives to be accomplished by the Licensing Readiness Assessment Group.
Lech of these objectives is presented below along with the groups' related conclusions and recomendations.
Objective (1):
project and analyze the licensing process that should be in place for submission, review and decision-making on future applications for construction and o>eration of civilian nuclear power plants.
For the purpose of this study, suc1 applications are:
(a) thosa that reference a Certified Standard Design, use a pre-approved site. and apply for a combined construction pennit and conditional operating license; (b) those that contain some combination of the features in (a) above; (c) those seeking construction of a custom plant on a new site; and (d) those seeking authorization to resume construction of a partially completed unit.
Conclusi>n Future applications which reference a Certified Standard Design, use a pre-Lpproved site, and request a combined construction permit and conditional operating license should be submitted and reviewed under the framework to be estcblished by 10 CFR Part 52.
For future applications that involve a custom plant design, either the histori-cal two step process (10 CFR Part 50) or the combined CP/0L (proposed Part 52) process should be used.
However, use of the Part 52 process should be encouraged.
Future applications seeking authorization to resume construction of and operate a partially completed plant should be reviewed under the 10 CFR Part 50 two-step licensing process.
Recomendation Both the historical two-step licensing process established by 10 CFR Part 50 and the proposed Part 52 process should be in place for the processing of new applications. However, applicants should be encouraged to use the new Part 52 approach.
Objective (2):
identify,foreachtypeofapplication/requestin(1)above, tTie practices, procedures, guides, standard review plans, rules and regulations that will have to be revised or developed and be in place before an application is received.
VIII-1
.e 1
Discussion For all new applications, an_ individual site safety and environmental review will be necessary either as part of an Early Site Review, a CP application, or a Canbined CP/0L aaplication.- Thus, revision and updating of-staff guidance in the site area siould be accomplished.
Plant system and other plant design reviews are expected to be minimized by a Comission emphasis on standardization.
Since completion of several standard design certifications is expected in the mid-1990's, revision of guidance documentation in the systems and design areas cannot be completed en a schedule which would contribute significantly to the completion of the standard design certifications.
Recomendation The specific documentation, principally site and environment guidance, discussed in Chapter IV should be updated or revised.
This task needs to be completed before 1995 in order for the guidance to be available to applicants on a time scaleconsistentwithDOEnuclearcapacityprojections(discussedinChapterV).
Objective (3):
identify the resources needed to develop / revise procedures, regulatory guides, standard review plans, rules and regulations.
Recomendation The details of the resource needs for guidance documentation updating and revision are provided in Chapter IV.
In order to complete this effort by 1995, approximately 9-10 FTE per year are needed in 1993 and 1994.
Objective (4):
identify the organization and structure needed to review, process and manage work activities associated with each type of application /
request-in(1)above.
Include the organization and structure needed for NEPA reviews and for coordination with other Federal agencies such as USGS.
Conclusion The current NRR organization is structured'in a fashion which is generally similar to that successfully used in the past for processing of applications, and is amenable to the processing of future license applications for any of the cases discussed above.
The existing matrix structure of project management L
and technical divisions would need to be slightly modified to provide for a new Licensing Project Directorate (LPD) for processing of future plant applications, and when the number of applications increases, the reassembling of the site l
review specialists into an organizational entity within one of the existing technical divisions.. A project manager for each of the first one or two new L
applications should report directly to the Assistant Director in order to l
assure adequate visibility and priority for the future licensing projects.
As more new future applications are received, the LPD should be formed. The regional offices would not need to be reorganized, but would need to add expertise in the construction inspection areas in proportion to the number of applications received.
NEPA reviews and USGS and other Federal agency coordination can be accomodated by the modified NRR organization, specifically by the project manager in coordination with the NRR site review specialists.
Objective (5): -identify the resources, including technical expertise, needed to review, process and manage work activities, including construction I
VIII-2
o inspections, associated with each type of a> plication / request in (1) above.
Such technical expertise could be obtained >y direct hire and/or by contract.
Conclusion Total NRC resources (in FTE) to issue an license for initial operations for new or reactivated plants were estimated for the licensing scenarios shown below.
Tech Licensing inspection Legal Assis_t TOTAL 1/
Standard plant (with certified
- design, Early Site Review 15 0.3 5.5 6
27 Combined License /
Operating Auth.
28 52 13 6
99 Standard Plant Total U
52 B
H 126 12 year period)
Custom plant (two-stepCP/0L process - 12 year period) 56 52 25 21 155 Reactivated plant (second unit with ASLB decision - 5 'caar period) 16 35 10 9
70 Reactivated plant (withoutASLB decision - 4 year period) 34 32 13 15 94 The technical review disciplines needed for these scenarios would be similar to the disciplines used in historical licensing reviews, as detailed in Chapter III and Appendix C.
The NRR organization no longer contains a center of excellence of site safety and site environmental specialists which would be needed for both reactivated and new plant applications.
Although some of the technical expertise still resides in the staff, it would have to be reassigned from other budgeted agency work to review new applications.
Objective (6):
address the im?act of resource needs on the 5-Year Plan and whether and to what extent suca resources could or should be accommodated in the Plan.
1# Rounded to nearest FTE Vill-3
Discussion There are currently no resources budgeted for new license application reviews in the early 1990's and beyond. An increase in staffing will be necessary-if any new applications or reactivations are received during this period.
For the five year budget cycle from 1991 to 1995, the resource implications vary widely depending upon the projected number of applications received each year.
Based upon DOE projections for nuclear capacity discussed in Chapter V, serious delays in new plant licensing would occur unless significant additional resources for application reviews are made available in the 1991-1995 time period. Of all new application types considered, the reactivation of a partially completed unit for
- which an SER has not yet been issued would have the largest resource impact.
Recomendation As discussed in Chapter VI, the Coariission should assume for budgeting purposes that one application for the reactivation and operation of a deferred plant will be received in 1991. Also, in order to forestall licensing delay in the review of other future applications, the NRC should be prepared to request additional staffing for the mid-1990's and beyond as new plant application submittal dates become more definite.
NRR should periodically survey the industry to determine when these future applications may be received.
In addition NRC resources should be budgeted in 1993 and 1994 for preparation of guidance documents, principally site-related, applicable to new applications.
The resources needed to support the review of one reactivated plant application and to prepare guidance documentation for new applications, expected to be received by 1995 are as follows:
FIVE YEAP; PLAN RESOURCE NEEDS 1991 1992 1993 1994 L93 Reactivated Plant 12.7 15.0 23.5 27.5 14.4 Application Review 9.5 9.5 Update Guidance Total 12.7 15.0 33.0 37.0 14.4 4
VIII-4
m..
4 w.
.A..
.,us A
.m-4.
4._, _ - _
.w2 4.
_itv-wa.,a A-2-.4 a
m a
,m.
A..
O -
4 APPENDIX A I
A
- ~ -
.--~.
9erT.eq\\
- g
' N STATas NUCLE AR REGULATORY COMMIS$10N l
[
o 3
cmaeoto=,o c. pones O
SEP 21 iggs MEMORANDUM FOR: Chairman Zech FROM:
Victor Stello, Jr.
Executive Director for Operations
$UBJECT:
WORKING GROUP TO ASSES $ FUTURE LICEh$!NG CAPABILITY In response to your memorandum of August 18, 1988 I have established a small working group to assess the readiness of the NRC to process an application for a construction pemit/ operating license for a nuclear power plant that could be submitted in the future. The membership of the group and its charter are enclosed
! plan to-have the group begin work imediately and provide its conclus-and recomendations to me by December 23, 1988. We wouV then be prepared to deal with any necessary adjustments to the Five Year F1.n in early 1989.
I will separately. task the Office of Nuclear Materials Safety and Safeguards to perforin a similar study of the licensing process and resources needed to handle an application for the construction and operation of a uranium enrich-ment facility. The conclusions and recomendations of this study will also be due by December 23, 1988.
I expect to forward recomendations on this matter
.to the Comission about 30 days after I receive the study results.
/
ctor ello Executive Direktor for Operations
Enclosure:
Charter cc:- Comissioner Roberts Comissioner Carr Comissioner Rogers SECY OGC e
se 1
.AA-1 1
~ -. - -
e CHARTER WORKING GROUP TO ASSESS READINESS TO PROCESS LICENSE APPLICATIONS At the request of the Comission, the Staff has been tasked to assess the readiness of the NRC to process an application for a construction permit /
operating-license that could be submitted in the future.
(Seeattachedmemo fmZechtoStello,8/18/88.) A Steering Group and a Working Group have been established for this purpose.
The Steering Group will be composed of:
D. Crutchfield, Chainnan Acting Associate Director for Projects, NRR J. Scinto First Deputy Assistant General Counsel Office of General Counsel W. Houston, Deputy Director Division of Reactor Accident Analysis Office of Nuclear Regulatory Research W. Kane, Director -
Division of Reactor Projects E. Case, Consultant Mr. D. Crutchfield is the Chairman of this Steering Group.
This Steering Group will provide the general policy oversight and guidance to
'the Working Group. The Steering Group will meet as necessary with tb Working Group to review the status and provide further policy direction as neede0 The AA-2 l
2 Working Group will be composed of the individuals providing the following technical expertise under the direction of Dr. Charles Miller, Standardization and Non-Power Reactor Project Directorate:
Severe Accidents (1)I
$ystems(1)
Engineering (1)
RadiationProtection(1)
Projects, Siting, Environmental (2)
~
Legal (1)
The objectives of this Working Group are to:
(1) project and analyze the licensing process that should be in place for submission, review and decision making on future applications for construction and operation of civilian nuclear power plants.
For the purpose of this study, such applications are:
(a) those that reference a Certified Standard Design, use a pre approved site, and apply for a combined construction pemit and conditional operating license; (b) thosethatcontainsomecombinationofthefeaturesin(a) above; (c) those seeking construction of a custom plant on a new site; and INumber of individuals needed.
AA-3
.*o 3
(d) those seeking authorization to resume construction of a partially completed unit.
(2) identify, for each type of application / request in (1) above, the practices, procedures, guides, staniard review plans, rules and regulations that will have to be rtvised or developed and be in place before an application is received; (3) ' identify the resources nee 6ed to develop / revise procedures, regulatory guides. standard review plans, rules and regulations.
(4) identify the organization and structure needed to review, process, and r.anage work activities associated with each type of application /
request in (1) above.
Include the organization and structure needed for NEPA reviews and for coordination with other agencies, such as USGS.
(5) identify the resources, including technical expertise, needed to review, process and manage work activities, including construction inspections, associated with each type of application / request in (1)-above. Such technical expertise could be obtained by direct hire and/or by contract.
.(6) address the impact of resource needs on the 5 year Plan and whether and to what extend such resources could or should be accommodated in the Plan.
The Working Group will submit its conclusions and recommendations to the Executive Director for Operations by December 23, 1988.
Attachment:
Memo fm Zech to Stello 8/18/88 J
AA.4
~.
e
- a omseek UNITED $TATil
/
t, NUCLE AR REGULATORY COMMIS$10N g
1 m As m oTow.o.c.sotas OT August 18, 1988 sow nurw CQMT_.?-ea-27 NEHoRANDUM FOR:
Victor Stello, Jr., Executive Director for operations FROM:
Iando W. Esch, Jr.
(v.
k SUILTECT:
READINESS To PROCESS A NEW APPLICATION F R A CONSTRUCTION PERMIT OR OPERATING LICENSE The commission wants to ensure that this agency possesses the capability to review and act upon any new application for a construction permit / operating license for a nuclear power plant or an enrichment facility that may come before it.
Accordingly, the commission requests that you establish a small working group to assess the readiness of the NRC to process an
- application for a construction permit / operating license that could be received in the future.
The assessment should identify any significant revision to the regulations, regulatory guides, or the standard review plan, or other regulatory documents that would be needed based on new knowledge or recent construction or operating experience (e.g., quality assurance requirements, siting requirements, source term, etc.).
This group should also address the availability of technical expertise in disciplines necessary to process the application and the breadth and depth of resource availability should an application be received.
The group should report its conclusions and recommendations through you to the commission.
The study should estimate the necessary agency resources for an application that references a certified standard Design, uses a pre-approved site, applies for a combined construction permit and conditional operating license, or for an application for a custon plant on a new site, or any reasonable combination of these possibilities.
Additionally, the study should address what would be required if a utility wanted to resume construction of a partially comp 3 sted unit.
I believe this review represents an important and prudent first step toward assuring that this agency will be prepared to process any applications it may receive.
I would appreciate your prompt response indicating your plan and schedule to complete this assessment by september 9, 1988.
Copies:
Commissioner Roberts commissioner Carr commissioner Rogers SECY GPA ocC Wd Off. DQ hte fr' /d ff jj,' g
. ' C.C AA-5
m a
i t
e APPENDIX D b
4 4
\\
l w-
APPENDIX B:
BACKGROUND ON THE HISTORICAL LICENSING PROCESS The historical licensing process consisted of two stages.
First, a construction permit was issued by the Comission authorizing construction of the proposed facility.
The focus of this stage of review was on the preliminary design of the facility and the suitability of the proposed site. The second stage concerning the operating license focused on the plant's final design and construction, and on testing, operations, and emergency preparedness.
An applicant for a construction pemit for a nuclear power plant could tender the required infomation in three parts.
The first part, consisting of anti-trust information, was tendered 9-36 months prior to the submission of the other required infomation in order for the Justice Department and the NRC staff to begin the antitrust review.
The second part was the Environ-mental Report * (ER) and site suitability infomation and the third part was the Preliminary Safety Analysis Report (PSAR).
Tendering of the ER tradi-tionally preceded the tendering of the PSAR by no longer than six months.
From the time the NRC had receiveo notification of the utility's intentions to build a nuclear power plant up to the issuance of the construction permit, the Pre-CP inspection program was instituted. The pre-CP phase inspection effort focused on the applicant's quality assurance (QA) program relative to implementation of ongoing activities of design and procurement.
Substantial emphasis was placed on verifying that, through the QA process, all quality technical and administrative activities and requirements important to safety had been effectively implemented prior to the issuance of the O nstruction permit (CP).
The regional inspection program during this phase as well as the later stages of construction inspection included the implementation of the Vendor Inspection Program which covered the Architect Engineer, NSSS vendor, and organizations contracted by the applicant to perfom design, manufacturing or other site-related activities.
The regior ascertained whether the applicant had been instituting effective control and overs'ght over such contractor activities. After a limited work authorization (LWA) has been issued, the pre-CP inspection activities included the initial environmental protection inspection.
Some time during the period that the applicant prepared its application for a construction permit, usually about 6-12 months prior to tendering, the NRC staff held a general introductory meeting in the area of the proposed site.
These meetings were held to familiarize the public with the safety and environmental aspects of the proposed application, including the planned location and type of plant, the regulatory process, and the provisions for public participation in the licensing process. Additional public meetings of this kind to exchange information and ideas were frequently held during the course of the reactor licensing process.
- The ER and corresponding NRC staff Final Environmental Statement (FES) were necessitated by the passage of the National Environmental Policy Act (NEPA) in 1959 and the court's interpretation of this legislation in the 1971 Calvert Cliffs decision.
l i
AB-1
When a construction permit application was been submitted, it was first subjected to an acceptance review by the NRC staff to detemine whether it contained sufficient information for conducting a detailed review. The results of the pre-CP phase inspections up until that point were fed into the acceptance review process.
The Atomic Energy Act of 1954, as amended, requires the NRC, in conjunction with the Department of Justice, to conduct a pre-licensing antitrust review of construction pemit applications. The Act requires the Attorney General to advise the Comission whether the activities under the license would create or maintain a situation inconsistent with the antitrust laws. After the Attorney General has completed its investigation, the Connission has been advised whether a hearing was needed or that no hearing was desired if certain actions were taken or if certain conditions were attached to the license.
The public has been offered the opportunity to request an antitrust hearing. Hearings have been held by a panel of the Atomic Safety and Licensing Board.
Only three CP stage antitrust hearings have been held.
The Construction Inspection Phase (CIP) was implemented upon issuance of the construction permit. The primary objective of the CIP was to ensure public health and safety through the staff evaluation of the licensee performance during construction and major plant modifications.
This was accomplished by determining the CP holder's effectiveness in identifying and correcting conditions that might adversely affect operational safety, in achieving compliance with NRC requirements, and in meeting comitments.
The intent of the inspection process was ultimately to determine whether safety-related materials, components, structures, systems, and construction activities were technically adequate.
Each CP application was reviewed to determine whether the plant design was consistent with NRC requirements. During the staff's review, the applicant was required to provide additional information as needed to complete the evaluation. The principal areas of the staff's safety review were:
Financial Qualifications of the applicant to design and construct the proposed facility.
Characteristics of the site environs including population and land use.
Physical charactcristics of the site including seismology, teology, hydrology, and meteorology.
Proposed programs for design, fabrication, construction and testing of structures systems and components important to safety.
Anticipated response of the reactor to various postulated operating transients and hypothetical accidents.
Plans, organization, and qualifications for conducting plant operations.
Physical security and safeguards.
Proposed program for quality assurance.
AB-2
o Design of proposed systems for control of radiological effluents.
The staff traditionally called upon the U.S. Geological Survey (USGS) for expertise in the areas of geology and seismology.
This relationship was initially established to help the small NRC geosciences staff with its heavy workload.
In later years the USGS role was more oriented to supplementing the geosciences staff with specialized expertise.
When the safety review of the application had progressed to the point that the staff concluded that acceptable design criteria, preliminary design infomation, i
and financial information have been adequately documented in the application, a j
SMity Evaluation Report (SER) was prepared.
The Advisory Comittee on Reactor Safeguards (ACRS) reviewed each application for a construction pemit for a nuclear power plant.
Each application was assigned to an ACRS subcommittee, usually made up of four to five ACRS members.
In thvse cases where the plant design was essentially the same as a previously l
reviwed plant (e.g., a second unit), the subcomittee review was not begun until the staff had nearly completed its detailed review of all the safety-reliied features of the plant. Where new or modified concepts or special site conf iderations were involved, the ACRS began its fomal teview earlier in the prowss.
Noir. ally, before the full ACRS has considered a project, use staff had completed its SER.
The SER and the report of the ACRS subetmittee have formed the basis for Comittee consideration of a project. Wcen tk Comittee com-pleted its review, its report was submitted to the NRC in the form of a letter to the Chaiman.
The staff typically prepared one or more supplements to the SER to address the safety issues raised by the ACRS report and to include any additional information made available since issuance of the SER.
Concurrently, a review of the applicant's Environmental Report had been perfomed by the staff to evaluate the potential environmental impact of the proposed plant.
This review was also performed to prov!de comparisons between the benefits to be derived and the possible risk tc the environment.
The NRC review required considerable interaction with the Environmental Protection Agency (EPA) on the impact of the proposed facility on the aquatic environment.
This interaction has been a result of the Clean Water Act which gave EPA the responsibility for issuing discharge pemits. To a lesser extent NRC has interacted with the Department of Interior.
This interaction has peeained to the impact of siting decisions on endangered species and unique fn,,; and wildlife ecosystems. The environmental review has frequently resulted in the imposition of specific conditions on the siting design in order to atisfy the NEPA. Af ter completion of this review, a Draf t Environmental statement (DES), containing conclusions on environmental matters, has been issued.
Each DES was circulated fer review and comments by the appropriate Federal State and local agencies as well as by private individuals and organizations. After receipt of all coments and resolution of any outstanding issues, a Final Environmental Statement (FES) was issued.
The Atomic Energy Act requires that a public hearing be held before a construction permit is issued for a nuclear power plant.
Soon after an appli-cation has been docketed, the NRC issued a notice of the hearing. The hearing AB-3
o for each case was held after completion of the NRC staff review. Opportunity was afforded for members of the public to participate in the hearing.
The public hearing was conducted by c three-member Atomic Safety and Licensing Board.
The SER and its supplements, the FES, and staf f testimony to address contentions constituted the-staff's primary evidence at the hearing. Depending upon the case, either a combined or separate safety and environmental hearings were held. The Board's initial decision was subject to a mandatory review by an Atomic Safety and Licensing Appeal Board and a discretionary review by the Comission.
NRC regulations provide that the Director of Nuclear Reactor Regulation may authorize limited construction work to be carried out prior to the issuance of a construction pemit. This authorization is known as a Limited Work Author-ization (LWA). The regulations provide for the authorization of two types of LWAs. The first type (LWA-1) may authorize site preparation work, installation
- of temporary construction support facilities, excavation, construction of service facilities, and certain other construction not subject to the quality assurance requirements.
Thesecondtype(LWA-2)mayauthorizetheinstallation.
of structural foundations.
The first type of LWA may be granted only after the licensing board M s made all of the NEPA findings required by the Comission's regulations for the issuance of a construction permit and has determined that there is reasonable assurance that the proposed site is a suitable location for a nuclear power reactor of the general size and type proposed from a radiological health and safety standpoint. The second type may be granted if, in addition to the findings described above, the hearing board determines that there are no unresolved safety issues relating to the installation of structural foundations.
Upon completion of the hearing and receipt of favorable findings from the Hearing Boards, completion of the staff's safety, environmental, and antitrust reviews, and receipt of satisfactory input from the Region on the inspection program, a construction permit has been issued by the Director of NRR.
t When the construction of the nuclear plant progru sed to the point where final decign information and plans for operation were ready, the applicant submitted the Final Safety Analysis Reoort and an updated Environmental Report in support
-of an application for an operating license (OL). The FSAR set forth the pertinent safety aspects of the final design of the facility.
The FSAR also provided plans far operation.ind procedures for ccpin; with emergencies.
The staff's conclusior.s on the utility's offsite emergency plans have been based upon the findings of the federal Emergency Management Agency (FEMA).
FEMA reviews the utility's plans'to determine whether State and local emergency plans are adequate and whether there is reasonable assuaince that they can be implemented.
Considerably more NRC resources have been expended at the OL stage than at the
-CP stage. This is due to the fact that the review of the final design and the majority of the construction inspection takes' place during the OL stage.
Unless there has been significant new information, however, most-of the review effort for the site characteristics, environmental impact, and antitrust areas have been expended during the CP stage since thesrs matters must be agreed upon AB-4
g for licensing to proceed. At the conclusion of the reviews the staff again prepered a SER and a FES and, as during the construction pemit stage, the ACRS made an independent evaluation and presented its advice to the Comission.
The Construction Inspection Phase continued through the OL review process and was not teminated until the OL was issued.
These inspection activities were accomplished chiefly by examining and observing infield work perimance and implementation of the QA program.
A construction site' typically had two resident inspectors (after 1980) that ideally were construction generalists.
Region-based technical experts in concrete, electrical /I&C, civil, structural, and welding provided the needed expertise to complete the specialized, technical inspection requirements.
The Construction Assessment Team (CAT) inspections used integrated multi-discipline inspections and were norually conducted about 18 months prior to projected OL issuance.
Fourteen CATS have been completed and primarily focused on hardware installation and quality of construction, At selected construction sites, additional team ~ inspections / evaluations were perfomed, as needed.
These included the Integrated Design Inspection (IDI).
andtheIndependentDesignVerificationProgram(IDVP).
Like the CAT, the IDI program was conducted by NRC headquarters (old OIE).
101s were conducted to provide an independent assessment of the quality of design activities for a specific plant system.
IDI's were nomally done at selected plants nearing completion of construction (and for which the design was complete).
IDVP's took a broader perspective on the design process and were normally independent, third-party audits that helped ensure that the plant had fuliy complied with applicable regulations and licensee commitments.
The latter stages of construction, and completion of primary piping, electrical cabling, and instrumentation have marked the winding down of the construction process and the start of the preoperational testing and startup phases.
The preoperational testing and operational readiness phase (PTOR) inspection program typically began 18 to 24 months prior to issuance of the OL. The two primary objectives of the PT0R inspection prograr were to (1) verify that systems and components important to the safety of the plant have been fully tested to demonstrate that they satisfy their design requirements and (2) verify that management controls and procedures, including QA programs, have been documented and implemented.
These objectives were accomplished chiefly by providing direct observation and technical procedural review of the two components of the licensee's preoperational testing program -- construction verification and preoperational tests.
Coestruction tests of a system or component are perfomed under the direction ci construction management for turnover to the operations staff for preoperationti testing.
Preoperational tests demonstrate proper functioning and conforman o of components, systems and structures to the design requirements.
Theprimaryobjectiveofthestartuptestingphase(STP)inspectionactivity was to verify that the licensee has been meeting the requirements and conditions of the facility license for precritical tests, initial fuel loading, initial criticality, low-power testing, and power ascension tests.
Other inspection activities included security and safeguards, the radiation protection program, AB-5
.o
+
v the radwaste systems startup, and the events reporting system. This verifica-tion was achieved through direct observation, witnessing tests, reviewing procedures and records, reviewing test data, and evaluating tests resultt.
The Region has accomplished the STP inspection obactive by ensuring that the licensee had developed tests fo* systems and components important to safety and that tests conducted under trer m4 and operati;1g conditions demonstrate satf
- faction of t' design req m
- nts as specified in the FSAR.
This phase of the inspection pit...ar became effect'"e approximately 6 months before issuance of the operating license and continw d approximately 1 month after the facility completed the full-power testing program.
A public hearing is not mandatory vith res)ect to an operating license applica-tion, but any person whote interest might se affected ay the proceeding way petition tne NRC for a hee ing.
If a public hearing was held, the decision
)rocess was generally the Same as that described for the construction permit leering.
Findings made by a licensing board are subject to discretionary Comission review.
In the past if no nearing was recuested, findings could be made by the Director of Nuclear Reactor Pcgulation anc en operating license could be issued.
In recent years the practice has been that the Director, NRR, would issue an o>erating license restricted to 5% power.
However, regardless of whether a learing has been held, the Comission reviewed the license and gave its approval befcre the full power licona was issued.
Each license for operation of a nuclear reactor has contained Technical Speci-fications and an Environmental Protection Plan. The Technical Specifications contain surveillance requirements and limiting conditiens for plant operation.
The Environmental Protection Plan sets forth the particular measures imposed on the plant to assure protection of the surrounding environnent.
l AB-6
t p.,
I i
t J
I I
j 2
1-4 h.
I APPENDIX C I
I I
'l E
-4
[
I i
l l
l 1-I e
4 k
i i
l l
4 r
i l
,,.i._,.
3
.4,y..,,_
, ~...m.,--
. -. ~.,,~~.-~~.e--.,
~ - - - -
.r.----
--,---+wwwa--n--=w-~--ee-
~~-w~*-a*+"*"We*'r+w-'-*
e APPEhDIX C:
BREAKDOWN OF RESOURCE NEEDS l
Included herein is additional information supporting the resource projections presented in Chapter !!!. Details are previoed on:
(1) annual resource projection for each case analyzed; (2) the distribution of base case licensing resourceneedsbymajortechnicalarea;(3)thelicensingreviewdisciplines; and (4) the distribution of base case inspection resources by major inspection area. Although the specific values depend on a nurber of detailed assumptions, the overall estimates and the general distribution reasonably encompass a wide range of assumptions concerning details of the review process.
Annual Resource Projectiens The following tables summarize the FIEs projected by year for each licensing case analyzed in the report.
Table C.1 Base Cese*
Technical Year Licensing 1nspection Assistance 1
5.3 0.1 1.7 2
5.2 0.1 1.7 3
3.1 0.1 1.7 4
0.2 4.2 0.0 5
0.0 4.2 0.0 6
0.7 4.2 0.1 7
1.9 4.2 0.4 8
0.7 4.2 0.1 9
8.4 4.2 1.6 10 7.7 4.2 1.5 11 5.2 6.4 1.0 12 5.5 6.4 1.1 13 1.5 4.6 0.3 Total 45.4 47.1 11.2
- 0GC estimates not made AC-1
l*,
1 Table C.2 Custom Plant j
Total Technical Resources Year Licensing Inspection OGC Assistance Required 1
1 6.4 0.1 1.6 1.7 9.8 2
6.3 0.1 2.1 1.7 10.2 3
5.6 1.6 2.5
- 3. '/
13.4 4
0.2 4.2 2.5 0.0 6.9 5.
0.0 4.2 1.5 0.0 5.7 6
0.7 4.2 0.8 0.1 5.8 7
2.0 4.2 1.1 0.4 7.7 8
0.7 4.2 2.5 0.1 7.5 9
8.5 4.2 2.0 1.6 16.3 10 8.2 4.2 2.8 1.5 16.7 11 7.9 C.2 2.8 5.0 23.9 12 8.3 6.?
2.3 5.1 23.9
-13 1.5' 4.6 M
M M
Total 56.3 52.2 25.3 21.2 155.0 2
Table C.3 Reactivated Plan ~ts With an ASLB Decision
& b Mh' Total Technical Resources l
Year Licensing Inspection OGC Assistance Required I-1 11.5
-5.7 1.3 1.0 9.5 2
2.0 4.2-1.5 0.0 7.7 3
2.0 4.2 1.5 0.0 7.7 4
4.3 8.2 1.3 4.0
'17.0 5
4.3 8.2 1.8 4.0 18.3 6
1.5 4.6 1.3 0.0 M
Total 15.6 35.1 9.5*
9.0 69.2*
- Includes 0.8 FTE in year 7 for appeal process.
l AC-2
. ~ ~, _. _ _. _, - _, _. _
~
Table C.4 i
Reactivated PlantTkithout an ASLB Decision j
[rqs786h Total V
Technical Resources Year Licensino Inspection OGC Assistance Required 1
3.5 6.7 1.5 1.0 12,7 2
6.0 4.2 2.8 2.0 15.0 3
9.0 8.2 2.3 4.0 23.5 4
10.0 8.2 3.3 6.0 27.5 5
5.6 4.6 2.2 2.0 14.4 Total 34.1 31.9 13.3*
15.0 94.3*
i
- Includes 1.2 FTE in year 6 for appeal process.
Table C.5 Standard Plant Total Technical Resources Year Licensing Inspection OGC Assistan e Required 1
5.0 0.1 1.1 2.0 8.2 2-5.0 0.1 1.1 0.0 8.2 3
5.0 0.1 1.8 2.0 8.9 4
7.0 1.0 2.8 0.5 11.3-5 7.0 1.0 2.8 0.5 11.3 6
1.5-5.9 1.5 0.7 9.6 7
1.5 5.9 1.5 0.7 9.6 8
1.5 5.9 0.0 0.7 8.1 9
1.5 5.9 0.0 0.7 8.1 10 1.5 5.9 0.0 0.7 8.1 11 2.5 6.8 2.0 0.7 12.0 12 2.5 8.4 2.0 0.7 13.6 13 1.5 4.6 1.8 0.7 8.6 Total 43.0 51.6-18.4 12.6 125.6 AC-3
= - - - _.
- n
~
Distribution by Major Technical Area and Complete Listino of Disciplines An estimate has been made of the base case distribution of resources expended by review discipline during the CP and OL stages. One plant regarded as representative of licensing resource expenditure was chosen for detailed analysis.
RITS hourly data was tabulated by reviewer from the CP acceptanct-review through the issuance of the LPL. Based upon branch roster and corporate memory of the time period of interest, a technical discipline was assigned to each reviewer.
The review team analyzed over 600 individual time charges by different reviewers at each stage of the licensing review.
The data was origina11) diviced into 43 review disciplines, but was subsequently grouped into ten technical areas.
The distribution cf resources is shown in Table C.6 The complete listing of disciplines is shown in Table C.7.
Table C.6 Base Cac: L; ensing Resource Distribution by MaTo~f Technical Area CP Phase OL Phase 1
NE I
DE Site Safety 14 1.9 11.6 3.5 Site Envir.
- .3 1.0 5
1.5 Radiolog. Eng.
11.8 1.6 10 3.0 System Eng.
14 1.9 33.7 10.2 financial Anal.
11 1.5 2.6 0.8 Safeguards 0
0 1.7 0.5 Emerg. Prep.
0 0
1.7 0,. 5 Proj. Mgmt.
33.8 4.6 19.2 5.8 Hunan Factors 0.7 0.1 2.3 0.7 Engrg. & QA 7.4 1.0 12.2 3.7
~
100.0 13.6 10 D 30.2 AC-4
o.
Table C.7 Licensing Review Disciplines SITE SAFET_Y
$1TE ENVIRONMENTAL Meteorology Aquatic Science Hydrology Land Use Analysis Geology Terrestrial Biology Seismology Marine Biology Geotechnical Engineering Oceanography Site Analysis Limnology Environmental Engineering RADIOLOGICAL ENGINEERING Occupational Health Physics ENGINEERING & QUALITY ASSURANCE Environmental Health Physics Mechanical Engineering Nuclear Waste Fire Protection Accident Evaluation Chemical Engineering Structural Engineering SYSTEMS ENGINEERING Materials Engineering Reactor Systems Metallurgy Auxiliary Systems Non-Destructive Examination Containment Systems Quality Assurance Probabilistic Risk Assessment Nuclear Engineering HUMAN FACTORS Nuclear Physics Human Factors Engineering Technical Specifications Power Systems EMERGENCY PREPAREDNESS Instrumentation Emergency Freparedness Analysis Environmental Qualification PROJECT MANAGEMENT (PM_1 FINANCIAL ANALYSIS Licensing PM Antitrust Environmental PM Financial Oualification Regional & Environmental Economics SAFEGUARDS / SECURITY Safeguards ana Security Analysis e
AC-5
n Distribution of Base case Inspection Resources i
The following table sumarizes FTEs projected by the budget model of the fonner Office of Inspection and Enforcement, it contains a breakdown of base case inspection resources by major inspection area and by inspection phase.
Table C.8 l
I Base Case Inspection Resources Distribution by Major Inspection Area PRE.CP CIP PTOR STARTUP PHASE
_ PHASE PHASE PHASE FTE FTE FTE FTE Engineering 100
.5 47 2.00 42 2.35 32 1.45 Sr. Resident 0
0 24 1.00 18 1.00 22 1.00 Resident 0
0 24 1.00 18 1.00 22 1.00 Project Ngmt.-
0 0
5 0.21 6
0.34 7
0.32 Rad. Safet/
0 0
0 0
8 0.47 8
0.36 Safeguards 0
0 0
0 5
0.27 5
0.23 Emer. Prep.
0 0
0 0
3 0.18 4
0.20 Total 100
.5 100 4.2 100 5.6 100 4.6 t
Y AC-6
m.____.._._______._____.______.
<> 6 i
0 RAFT 1
i f
The Honorable B. J. Habibie State Minister for Research i
and Technology.
Jakarta, Indonesia
Dear Dr. Habible:
I was pleasedEto have the opportunity to meet with you during your October 5th visit to the U.S. Nuclear Regulatory Commission (NRC).
p believe the dialogue we initiated was mutually beneficial and encourage you and other Indonesian personnel concerned with nuclear safety to renew contacts with us during any future trips to the Washington area.
You asked me_to relay'to the Comminston your request that the NRC t
agree to oversee and certify the entire reactor project, not just the design, if Indonesia commits to an advanced. reactor of U.S. origin.
!As;1'had cautioned you to expect, the Commission's position on such i
requests remains unchanged: Neither our resources nor our policy allow us to undertake such a project, which would involve liability
_ questions and exceeds our authority and readily available resources.
It has been our position that'a country about to embark on a nuclear power program should plan to carry out 'its own regulatory responsibilities.
l -
i n
l L
+n 2
The IAEA can be an excellent source of guidance and support for countries initia ing a nuclear power program, in addition, NRC can, subject to resource availability, offer countries just entering the nuclear power arena assistance in such areas as acquiring basic NRC safety documents, providing on the job training assignments within the NRC staff, giving technical advice on specific questions, supplying technical experts to support IAEA sponsored in country safety missions, and arranging for participation in regulatory / safety classes taught by the NRC Technical Training Center in Chattanooga, Tennessee. We provide our expertise to other countries whenever possible, but always in a supporting rather than a 1 cad role.
You had also asked for some information on the type of team NRC needs to license and inspect a nuclear power plant in the U.S.
I am enclosing an internal memo, with attached steering group report, which contains analyses of past and projected NRC manpower requirements during each year of construction for several U.S.
reactor scenarios. Please understand that this material reflects the situation and the program in the U.S.
These can be expected to differ significantly from Indonesian circumstances.
Please let me know if I can do anything further.
NRC will be glad to work with you as you move toward a commitment to safe nuclear power.
We have made similar offers to Drs. Ahimsa and Subki nf the
<3 )
3 Indonesian National Atomic Energy Agency during the annual meetings of the U.S. Indonesian Nuclear Joint Steering Connittee and stand prepared to activate them as you identify your needs.
Sincerely, Harold R. Denton, Director Of fice of Governmental and Public Af fairs
Enclosure:
Homo dtd 2/24/89, Crutchfield to Stello, w/ accompanying Steering Group Report cc y/ enclosure:
Dr. D. Ahimsa, BATAN Hr. E. Yamin, State Electricity Company bec w/o enclosure:
J. Taylor, EDO S. J. Chilk, SECY H. Denton, GPA J. Shea, IP R. Hauber, IP S. Bosken, DOS S. Rosen, DOE A. Giarratana, NMSS D. Chaney, IP Indoner,ia file IP r/f l
- _.