ML20039F109

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Counsels Against Limiting B-SAR-205 Preliminary Design Approval to 3 Yrs
ML20039F109
Person / Time
Site: 05000561
Issue date: 05/19/1978
From: Deyoung R
NRC
To: Case E P, Mattson R
NRC
Shared Package
ML111090060 List: ... further results
References
FOIA-80-515, FOIA-80-555 NUDOCS 8201110871
Download: ML20039F109 (1)


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g May 19, 1978 Note To:

E. G. Case R. J. Mattson BSAR-205 PDA We have been informing the Comission over and over during the past year that all future PDAs will issue for a term of five years.

You recently indicated your intent to limit the PDA for BSAR-205 to a tenn of three years beca'use B&W has yet to acquiesce to one part of a new requirement on cold shutdown requirements recently sanctioned by the RRRC.

I strongly suggest that you reconsider your proposed action.

I think it would contradict what we have told the Comission we would do, and is totally unnecessary unless we believe we lack the capability to resolve a matter of this type without the leverage of a reduced term of approval.

We are now engrossed in a problem of fees for PDA-extensions.

I think we will find a way to exempt current PDAs from fees for such extensions.

But a prime basis for such exemption will be the pre-March 23, 1978 application for extension. This will not hold for BSAR-205.

Again, I think we will create unnecessary problems if we limit the BSAR-205 PDA.

I don't believe the limited term is needed because of safety considerations; I believe the staff is fully capable of resolving the matter promptly whether the term of the PDA is three or five years.

We are prepared to accept a five-year tenn with final resolution of ATWS and numerous other safety matters pending. Why not this matter also? This last minute " persuasion" with the applicant "over the barrel" may appear to be the easy way out, but I doubt it.

Again, I request your reconsideration.

R.C.heYoung 8201110971 810403 FDR FOIA

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MADDEN 00-515 PDR

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