ML20055C237

Requests Commission Review NRC Assessment of NRC Readiness to Process Applications for CPs or OLs

ML20055C237
Person / Time
Issue date:	04/03/1989
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
TASK-PINC, TASK-SE SECY-89-104, NUDOCS 8904070117
Download: ML20055C237 (80)

Text

{{#Wiki_filter:. ) eeeeeeeeeeeeeeeeeeeeeee. RELEASED TO THE PDR / A r e i-t fo/$9/llo i (,.,,,,,/ 6e inip.ii-l ....e POLICY ISSUE (NEGATIVE CONSENTI l O " ' ", '. !- ! i SECY-89-104 [1* : The Commissioriers tror: Victor Stello, Jr. Executive Director for Operations a h r ' t : *.

• ASSE! SPENT OF FUTURE LICENSING CAPABILITIES i

Pu-: n : 70 reouest Corrission review of the staff's assessment s cf it.e NRC resciness to process future applications for i construction permits or operating licenses. l i s tt.! s i c ' ; in response to the memorandum froisi the Chairman dated Augt:st 18, 1986, a small group was established to assess the readiness of the NRC to process an application for a construction permit / operating license for a nuclear power i plant that coulo be submitted in the future. The member-l ship of the group and its charter was enclosed in the ED0's l response to the Chairman datec September 21, 1988. t After the effort was begun, the M eeting Group received an SR!i (dated October 20,1988) reined to the denial of a Petitior for Rulemaking on 10 CTR Part 100. In that SRM, it was noted that a comment would be inserted in the cover l letter cenying the petition and the Federal Register notice l l stating *...that this issue will be cons 16ered in the NRC ' readiness to license' study..." The Steering Group examined this matter and concluded that 15 sue was not mature enough for resolution at this time. i The staff who will consider possible changes in Part 100' and implementing Regulatory Guides is currently focused on the review of and schedules for the evolutionary advanced light water reactors (ALWR) and the EPRI-ALWR Requirements Document. However, the staff will bring this issue to resolution before it woule impact new plant proposals. Recomeret tion: The staff intends to develop plans to implement the recomendations of the enclosed Steering Group report f O 'f d 7 o tty (gs yg Cert 6ct: \\ Dennis Crutchfieic, NRP ) p 4 - 12EA k nnwg;

n , ^> Gb.i %,,. 'b. / ( ~ ( i_ i '. ; ? A, -_- ' ^l j " sn g' . 2.. ^4 y ml.. ( ~ unlest etherwise instructed ty the, Comission.- These, 'resourer. and planning: assumptions will be reflected in-the t. ext updato cf the Five Year. Plan.' f;X 'j7.. m. iM w; 171ctor Stello, Jr j., - ' Executive Director for Operations -Ent im tet. ,? ? ' l AO 5'Ji f ( y.., l -- - e,. 0 -a. SECY *nTE: n the absence of instructions to the contrary,- SECY~will notify the staff on Tuesday,JApril 18, 9' 1950, the,t the Ccmission, by. negative consent,1 asser.ts to.the action proposed <in this paper. eg h;

==., *e s= es = ap g,... = e. ! ' .M w.. w. s '( 6 Cc:=iscior.ere oGC i ' C I;- G7Di + TsE3:0 :At-Grr:CES ELL h -n wr :- -: AC::17 a.TSLEP/ .;g;;p= ? 'SECY 1 y.: f b -0 t r, d -i t, ..j.i i 9 l bya k f '\\ } e s-w- - " ~ ' - ' * * ' " ' ' ^-

c: + l: i i r t L li i REP 0F.T CN fiRC READINESS TO PROCESS FUTURE APPLICATIONS F0k C01:5TRUCTION PERMITS OR OPERATING LICENSES l l-i FEBRUARY 1989 l l

c ' n. 5 i TABLE OF CONTENTS Page AcAncwledgment [ x e c u t i v e ' S u nAa r y.................................................. ES-1 Introduction........................................'........ I-l I'. Historical. Current anc Future Licensing Processes.......... II-1 A. Histcrical. Licensing Process............................ II-1 E. New Custom Plant Licensing Scenario..................... 11-1 C. Reactivated Flar.t Licensing Scenario.................... II-A C. Stancare Plert cr. Fre-Approved Sites Licensing Scenario. II-5 2. E a r l y S i t e F e rm i t s.................................. 11-5 2. De s i gn Ce r ti fi c e t i c n................................ II-6 3. Corbirec Constructicn Perrit/ Conditional Operating License............................................. II-6 E. Licensing Process for Future Plants..................... II-8 I!?. NRC Resource Prefections for Future Applications............. III-1 A. Base Case............................................... 111-1 1. Licensing Rescurces................................. !!!-1 2. Inspection Resources................................ III-2 3. Contractor Tectrical Assistance..................... III-3 4. Legal Resources..................................... III-3 B. New Custom Plant Licensing.............................. III-4 1. Licensing ard Inspection Resources.................. III-A 2. Legal Resources..................................... III-5 C. Licensing of Reactivated Plants......................... III-6 1. Licensing ana Inspection Resources.................. III-6 E. Legal Resources..................................... III-7 D. Licensing of Standarc Plants............................ III-8 1. Early Site Fermit Review............................ III-9 2. Combined License Review............................. III-11 3. Construction Inspection / Operating Authorization Review.............................................. III-12 IV. NRC Guidance for New Applications........................... IV-1 A. Introduction............................................ IV-1 B. Needed Additional Guidance Related to Rule Changes...... IV-1 C. Needed Additional Guidance Related to Standard Review Plans anc Regulatory Guides............................. IY-2 1. Environmental Standard Review Plan (ESRP)........... I 'l-E 2. Standard Review Plan................................ IV-3 3. Regulatory Guides................................... IV-3 a. Inspection Manual................................... IV-3 D. Resource Requirements................................... IV a

n. x i-(' ..c- . t y ;;, *l +. [o Page i b 'f:- Eescurce. Requirements fer Satisfying DOE Nuclear........ V-1 . acacity Prcjections' h )f. ';C~Pesource Impsets of Precessing Expecteo. Future.......... VI.I

plicatiens c

a pc VII. Crgani:aticral Structure.................................... VII-1 t L 'A., Prier. NRF Crgani:e tien (late 1970's ).................... VII-1 J 1. Civision of Preject Management (DPM)................ VII-1 i 2.' Division of Site Safety and Environmental Analysis (DSE)............................................... VII-1 E n .3. Civision of Sys tems Sa fety (DSS).................... VII-1 E. Organi:ation1Vcdifications for New Licensing Reviews.... VII-2 1. NRF_Frejects Organization........................... VII-2 E. NRR Technical Organi:aticn.......................... VII-2 '3. -NPP Antitrust anc Financial Peview Organi:ation...., VII-3 4 hRR Inspection.0versight.0rgani:aticn............... VII ' E. Regicnol Crgani:ation............................... VII-3 [ 1

VII:.

enclus ions and Pecemrenca tichs............................. VI!!-1 A;penob A......................................................... AA-1 Appencu C......................................................... AB 1 ApDhno17'C.........................................................- AC-1 f t -r 1 N L l - e i ? Y s

---

..-l-a

V 4 ACKNOWLEDGMENT 6 1 The Steering. Group wishes to recogni:e 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 ;d11er, NRR, Chairman i Charles Bartlett, RES Tim Collins, NRR Dick Dudley, NRR Geary Hi:uno 0GC Lenny Olshan, NRR Ted Sullivan, hRR Jim Wigginton, NRR 1 i l

j i EXECUTIVE

SUMMARY

Thir report assesses the readiness of the NRC to process possible future applications for construction permits and operating licenses for comrMrcial nuclear power plants. The report provides year-by-year resource estimates for NRC review of several inoividual licensing scenarios believed to be representative of these future applications. For these chosen licensing scenarios, the report also ciscusses the licensing processes that should be used, the possible organize:ional structure that should be in place and regulatory guidance documents that should be updated. The report also provides a budgeting recomrrendations for the 1991-1995 budget cycle related to the review of future applications. NRC RESOL'RCE PROJECT:0NS FOR PROCESSING FUTURE LICENSING APPLICATIONS a By usir.g 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 needea 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 ar.d operation of a plant now in a deferred status but still having a valid con-struction pemit, anc (3) an application for a combined construction pemit and conditional operating license which references 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 licer.se applications. Table ES-1 provides a sumary of these NRC resource neeas. l TABLE ES-1. NRC RESOURCE NEEDS FOR INDIVIDUAL NEW APPLICATION REVIEWS H Total NRC Staff Resources Needed Scenarie Per Application 1/ Custom plant 155 FTE Reactivated plant with licensing review completed 70 FTE Reactivated without licensing review completed 94 FTE S/ Standard plant 126 FTE E FTE estimates in this report do not include overhead factors. S/ oes not incluce resources to certify the standard design ( 30 FTE's). D

4

-NR RESOURCE PROJECTIONS FOR SATISFYING DOE NUCLEAR CAPACITY PROJECTIONS In September 1988, the Department of Energy (DOE) made projections of future nuciear capscity in the United States. This report examines the combined NRC resources that woulc be needec to meet DOE's most recently published upper and 'ower reference case projections. 1he DOE lower reference case is based on one additional plant of about 1200 MWe becoming operational in 2007. The DOE upper reference case assumes that three reactivateo plants and eleven new plants will be operational by 2007. Tables showing the year-by-year NRC resources needed during the 1991-1995 budget cycle to process these applications are presentec 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 imeciate budget impact when compared to the other new application reviews. In additien, the report recommends that NRC resources should be budgeted in 1993 ano 1994 for preparation of guidance documentation (most of which are site related matters) for other future applications expected to be received by tne 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 sheuld 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 cocumentation 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 identifico in Table ES-2 are currently included in the 1991-1995 HEC budget. TABLE ES-NRC FIVE YEAR RESOURCE NEEDS (FTE)M YEAR 1991 1992 1993 1994 1995 Reactivated Plant 12.7 15." 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 accitions to previous practice to carry out the review of future plant appli-cations. The changes result-from recent rule changes and pending Commission N FTE Values in this table do not include overhead factors.

i l ae:trions, such as the Severe Accident Policy Statement and the proposed

1. itness-for-cuty rule (10 of prooosea 10 CFR Part 52gR Part 26).

The report also discusses the use l and its three suoparts: early site permits, standard design certifications and combined construction permit / conditional operating licenses for the reviews cf future applications. The overall purpose cf 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 resolutien 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 encourared. The report discusses the organizational structure that was successfully used by the NRC in the past for ccnducting license application reviews, and adoresses mootficctions to the current NRR crganization that should be implemented if more than two future license applications are received. The principal modifi-catien involves creating a new Project Directorate within NRR for the processing of future piant applications. However, if only one or two future plant applica-tions are under NRC review, this orcanizational modification would not be needed since the review could be successfully conducted within an existing NRR Project Directora te. However, we recommend that the project manager for the future plant applicatien should, under these circumstances, report directly to the Assistant Director in order to assure adequate visibility and priority for the future licensing project, i 1 l l 1 1 l l i The report discusses the proposed Part 52 as of January 1989.

? b CK'FTEE !. NTRODUCTION i Cr August IS.1988, the Chairman requested le Executive Director for Operations ti;G, to create a small working group to assess the readiness of the NRC to prccess possible future applications for ccnstruction permits / operating licenses for nuclear power plants (COMLZ 88-27). On September 21, 1988 in a memorandum frot Victor Stello, Jr., Executive Director for Operations, to Chairman Zech.

Subject:

Werking 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 information 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 mooifications to take into account changes to recent rules and Commission Policy. The chapter also discusses the new licensing process oescribed in the proposed Part 52 to Title 10 of the Code of Federal Re gu l a ticr.:. + The indivicual NRC resource projections for several licensing scenarios are presented in Chapter III. 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 Chairman (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 permit that is in a aeferred status, and a standard plant application for construction anc 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, l Chaoter IV discusses guidance documents, such as regulatory guides and stenaarc review plans, that should be revised to assist in the processing of future applications, and estimates the resource requirements for updating these docuaents. l l Chapter V discusses the NRC resources needed to perform the combination of l~ plant reviews needed to meet the energy needs projected by the Department of l Energy (D0?). The combined NRC resources needed to meet both the DOE upper and icwer 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 l applications should be available by 1995. The basis for these recommendations ano.their impact on the 1991-1995 NRC budget is also presented in Chapter VI. Chapter VII discusses a past NRR organizational structure that was in place when.many license applications were being successfullv neocessed. This chapter I also suggests ninor changes to the current NRR organizational structure that. would facilitate the review of future applications. Conclusions and recommendation: that address the objectives defined in the ED0's meteranoum of September 21, 1988 are provided in Chapter VIII.

Y I c' Three arrendices are also included and prov w tupplementary information supporting that found in the main body of the report. Appendix A contains copies of the Chaiman's request to perform the assessment and the E00's i September 21, 1988 response to the Chaiman. Appendix B provides a detailed i ciscussion of the historical process used to license nuclear power plants. l Appencix C includes additional details on the resource projections, including technical expertise, needed to rneet the licensing scenarios discussed in Chapter III. t 6 1 [ t .g g

E 4 CHAPTER II. HISTCRICAL, CURRENT AND FUTURE LICENSING PROCESSES l A. historical Licensino Precess Recognizing that readers of this report are likely to be familiar with the historic 61 licensing process, only the highlights of this process are sumarized below. Appendix B to this report contains a detailed cescription of this l process anc the timing of the various activities of the process. -I 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 detemined by confomance to the regulations, environmental impact r as requireo by the National Environmental Protection 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, consioerably more resources have been expended by the staff during the OL review stage than at the CP stage. However, the staff review of the site characteristics, environmental impact, and antitrust have been carried out i 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 Authorizatiens (LWAs) anc/or the CP. At this point the construction inspection phase (CIP) began. The CIP merged into the inspection of preoperational testing and operational readiness (PTOR). About six conths prior to OL issuance, the startup testing phase (STP) inspection activities began. The federal agencies with which the staff has had significant interaction during l, plant licensing are the Environmental Protection Agency and the Department of 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 revier, 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 11 ave been: hearings with heavy intervention, resolution of siting problens, 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 exasined by this study is an application for licensing of a custom plant design era custom site. The overview of the historical licensing process ciscussenbabove and the more detailed description in Appencix B cf this report amuld be largely unchanged for an application for

a rew custom plant en a custom site. However, there are a number of recent 1 cr.c :encing rule changes and Commission policy decisions which are expected to moc1f/ this and other potential new plant licensing scenarios. These rule charges and pending decisicns and their.esource implications are described in i the feilcwing paragraphs. Prior to 1982, review of the financial qualifications to operate and decommission a nuclear power plant was performed at the OL stage. The financial review was j eliminated as a requirement at the CL stage by a rule change in September 1984. 1 Applicants for operating-licenses are no longer required to submit information on their financial qualifications to operate the facility. However, in June 1 1988,10 CFR 50.33(k) and 50.75. Reporting and Recordkeeping for Decomissioning Planning, were added. These rules require applicants for operating licenses to J submit detailed financial information to assure that the-funds for cecomissioning the f acility will be provided. The net effect is that NRC staff resource i 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 involvec with Federal reviews of emergency preparedness plans at nuclear power i plants. First, on December 3,1987, new emergency planning regulations [10 CFR 50.47(c)(1)] became effective, pro *iding for NRC staff and Federal Emergency Management Agency (FEPA) review o.' utility prepared offsite emergency response plans where State or local governments decline to participate in emergency planning. Under the regulation, if the NRC determines that 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 preparea plans under the same 16 planning standards that are used to evaluate State ano local utility plans, but will use the " realism" assumptions set forth in 10 CFR 50.47(c)(1). Seconc, on November 18, 1988, the President issued Executive Order 12657 "Feceral 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 there has been maximum feasible use of utility and State and local resources, the Federt.1 government will make available to the utility Federal facilities, eouipment and personnel as part of the offsite response organization. The NRC staff and FEPA would evaluate the adequacy of these potentially complicated utility prepared offsite emergency plans under l NRC regulations in 10 CFR 50.47(c)(1) mentioned above. .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 plans. In the future, there may be facilities that may request the use of the 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.

3 feotetter 1988, the Commission 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-cuty program. The general objective of the preposed rule is to provide reasonable assurance that nuclear power plant perscr.nel are not under the influence of any substance, legal or illegal, that in any way adversely affects-their ability to perfom their duties. The conenent 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 section, 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 plents as reflectec in 10 CFR 50.34(f), (2) demonstrate resolution of all applicable Unresolved Safety !ssues (USIs) and Generic Safety issues (GSIs), anc (3) complete a PRA giving consideration to the severe accident vulnerabili-1 ties the PRA exposes along with the insights it may add to the assurance of.no undue risk to public health and safety. The Commission's Severe Accicert 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 standare 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 formali:ed 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 regarding the impact on NRC resources that this area could have in the hearing 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 from deferred status. Currently there are 12 plants with valid construction permits. Five of these plants (Comanche Peak 1. Limerick 2, Vogtle 2, and Watts Bar 1 and 2) are currently under construction and actively proceed %g toward an operating license and are not considered to be in a deferred status. Comanche Peak 2, although not formally in a deferred status, has had construction suspended. Construction of Unit 2 will likely resume later this year. All of these six l plants have NRC resources budgeted for the completion of the licensing reviews. L The remaining six plants are in a deferred status with no budget allocation, Ll. J

1 ] ) 6r.c are candidates for reactivation. These plants are Bellefonte 1 and 2*, Granc Gulf 2, Perry 2, and WNP 1 and S In acccreance with the Commission Policy Statement on Deferred Plants published cr. cctcber 14,1987 (52 FR 38077), CP holders are expected to subit certain specific infomation when construction on a plant is deferred and when plant -construction resumes. This information will be used by the staff to detemine the status of the plant with respect to reactivated plant licensing. The acceptability of structures, systems, and components important to safety (upon l reactivation will be determined by the staff based upon the following: 1)the staff review of the im maintenanceprogram,(plementationofthepreviouslyapprovedpreservationand2) the s and required corrective actions have been properly implemented, and (3) baseline inspections perfomed by the staff to verify that Final Safety Analysis Report (FSAR) cuality and perfomance commitments have been met. In accition te perfoming the above items specifically associated with reactivated plant licensing ano completing the review, inspection, and hearings associated with historical plant licensing, certain recent rule changes and'the Commission policy on severe accidents are expected to affect the reactivated plant licensing review. The major changes include the Fire Protection Rule, Hydrogen Rule. l Ecuipment Qualificatier. Rule and the Decomissioning Funding Rule. With regard to severe accidents, licensing applicants for reactivated plants will be expected to perform an Independent Plant Examination (IPE), as outlined in Generic Letter 88-20, ano address containment vulnerabilities. As with _ currenti; operating reactors this will serve as the mechanism for addressing severe accidents for this licensing scenario. Additional resource requirements. ano potential hearing process impacts concerning severe accident considerations will be similar to those discussed in Section II.B for new custom plant appli-l Cations. I The descriptions provided in Section II.B on financial qualifications and fitness I for duty are equally valid for the reactivated plant licensing scenario being treated in this section. Of the six plants in a deferred status, three (Grand Gulf 2. Perry 2, and WNP 1) are locatec on sites with previously approved emergency plans (EP). EP reviews would have to be performed for the remaining three plants (WNP-3 and Bellefonte 1and2 sites). D. Standard Plant on Pre-Approved Sites Licensino Scenario l The third licensing scenario examined by this study is an application for i licensing of standard plants on pre-approved sites. A brief description of l the proposed 10 CFR Part 52 process and a discussion of other differences l between this scenario and the historical licensing process discussed in Section II.A are presented below. l l t

• Althougn construction is suspended at Bellefonte 1 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.

N Licensinc Process under Part b2 The ;roposed Part 52 has three subparts. These are: (a) Early Site Pemits, it, handard Design Certifications, ano (c) Combined Construction Permit / Concitional Operating Licenses. Early Site Permits Under Part 52, applications for an early site permit would be required to. include infomation on such things as the boundaries of the site; the number, type anc 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 cescription of nearby industrial, military, or transportation f acilities 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 .neeo for power, but are requireo to perform an evaluation of alternative sites. If the applicant wishes to perfom activities equivalent to those permitted 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 would be requireo to prepare an environmental impact statement (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 option requires the applicant to provide i information sufficient "...to show that the area surrounding the site is [ amenable to emergency planning which would provide reasonable assurance. th&t adeounte protective measures could be taken in the event of a radio-lop cal emergency at the site; given the characteristics of the site and l r m ble emergency planning zones surrounding the site...." After L m sultation with FEMA, the Commission makes a reasonable sissurance finding. Under the second option, the applicant may either (a) propose emergency planning parameters for review and approval by the NRC and the l Federal Emergency Management Agency. The parameters may include such matters as the exact size ano shape of the emergency planning zones. Conformance 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 planning requirements reflected in the parameters. As part of the second-i l option, the licensee may (b) propose complete emergency plans for review and approval by the NRC and the Federal Emergency Management Agency, in accord with the applicable provisions of 10 CFR 50.47. In addition, the application for site approval must be aeferred 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-fore, a mancatory public hearing must be held on the pemit 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 - ~ -. r

l i I h construction pemit applicatier. However, depending upon which EP option is selectcd, the hearing complexity may vary, along with support staff resources. t 2. Desier 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 reouired of applicants for construction pemits and cperating licenses, including compliance with applicable TMI requirements. Also requireo are proposed resolutions of medium and high priority USIs 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 certi fica ti c r.. For nuclear power plant designs with only evolutionary changes from current LWRs, the 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 Boarc. A formal hearing is also possible. Design certification woule essentially constitute Comission pre-approval of the adequacy of the design for referencing in future applications. 3. Combined Construction Pemit/ Conditional Operatino License Subpart C of Part 52 authorizes the issuance of combined construction permits and conditional operating licenses (combined licenses). Applications for a combined license must not only include the information required for a construction permit, (including anti-trust infomation), but must also incloce the Final Safety Analysis Report (FSAR). Applications referencing an early site pennit must demonstrate that the design of the facility, as well as environmental issues not considered in any previous preceeding en 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 the interface requirements in proposed Section 52.47(d). In addition, emergency plans must be submitted, and if possible, certifications by applicable lccal and State government agencies that the plans are practicable and that they are comitted 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 ano hearing are required, including preparation of an EIS. However, if the application references an early site permit,

q the environmental review would focus only on the suitability of the site fer the particular design and any other significant environmental issues ~ not previously considered in either the permit or certification proceeding. To provide assurance that the plant can be built and operated in accordance with recuirements, proposed Part 52 would require that applicants to submit the preposed tests, analyses, inspections, and acceptance criteria as part of the application for a design certification. These proposed tests. analyses, inspections, and acceptance criteria will be reviewed and r approved as part of the certification review. Before the licensee may operate the facility, a pre-operational antitrust l review must be performed to determine if there have been any significant charges 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 recomend 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 bt sis that either (1) there has been a material noncon-formance with the e ombined license, the licensee's written comitments, the 1954 Atomic Ent:rgy Act or the Comission's regulations which could 6dversely affect t'te safe operation of the facility; or (2) that some mocification to the site or design is necessary to assure adequate public protection. The approach inherent in the proposed Part 52 is based upon submission of com-plete information on the final desien. As a result, the distribution of NRC resources for licensing reviews will be expended over a shorter time frame, and earlier than in the tradi'tional two-step licensing process. Similarly NRC regional resources for the inspection of the implementation of the proposed tests, inspections, analyses, and acceptance criteria will have to be expentied earlier in the licensing process than required by the historical licensing

approach,

';n addition to the above procedural changes for standard plants under the l proposed Part 52, there are other differences from the historical licensing reviews that are oiscussed below. Section-!!.B of this report on New Custom Plant Licensing contains discussions of the effect on new licensing of the Decommissioning 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 was issued in final fom in Au;ust-1985. Through a series of interactions with the Comission and with industry, the staff has been developing specific proposals for implementing the severe accident policy. The staff is considering development of a rule and accompanying regulatory guides that would require: (1)identificationof specific severe accident vulnerabilities that evolutionary designs must address (e.g., containment integrity, containment bypass, and core damage preventien), (2) performance of a PRA and consideration of the vulnerabilities it exposes, and (3) documentation of assumptions and incorporation into plant design, cperation, and maintenance. The staff resources P this licensing scenario will reflect the effort involved in reviewing the applicants' severe accident submittals. I

E. Licensine Process for Fatore 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 Corr.issioners anc staff, the public, ano the utilities (along with supporting archits:t encie.eers and NSSS vendors) have a vast body of experience and know-leoge of the existing Part 50 licensing process. All these participants are familiar with their respective roles in this process, and history shows this - precess to be a workable licensing vehicle. Nevertheless, the preposed 10 CFR 52 (after appropriate public connent resolution) shoulo also be promulgated and used for future applications. This proposed new rule is intended to achieve the early resolution of licensir; 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 anc streamline the licensing process by encouraging the use of stancaro reactor cesigns and by allowing the early resolution of site environ-nientai anc reactor safety issues. The public should be afforded an earlier entry into the licensing process as a result of design certification rulemaking process ano subpart C's combined CP/0L hearings. It is expectea that mcst applications for future plants would use the Part 52 process, anc they should be encouraged to do so. However, the use of Part 50 for some future applications should not be outlawed. t 9 e r

4 CHAPTER ::I. NRC RESOURCE PROJECTIONS FOR FUTURE APPLICATIONS Ir. this chapter resource projections have been developed for the future plant licensing scenarios discussec in Chapter II, Sections B C, and D. These projections include adjustments 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 i 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, no attempt has r been made to include these in the resource projections contained in this chapter and in the remaincer of the report. ?,ny budget assumptions or actions that are based on this repor: snould include the appropriate overhead factors. A. Base Case 1. Licensing Resources To determine the resources needed for base case licensing, historical data f rom the Regulatory Infonnation Tracking System (RITS) were analyzed. Since RITS data are available from June 1972 to the present, data from all the plants whose construction permit (CP) applications were docketed after June 1972 were considered. The licensing review resources expended to issue cps have been plotted in Figure III-1 as a function of time of issuance of the CP. Data poin',s in Figure III-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 cuplicate 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 trend, a value of approximately 14 FTEs has been chosen to quantify the licensing resources that would be required for base i 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 recources for issuance ofthelowpowerlicense(LPL). Data points in :igure III-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, e value of ~ 30 FTEs is a good approximation of the licensing resources needed to issue an LPL. Further analysis of historical RITS data for recently licensed plants has shown that in addition to the resources expended to issue the LPL, approximately two additional FTEs were required to issue the full power'

iicense (FPL). These additional resources were used primarily for closecut 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 estimate has also been made of the time distribution of licensing 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 detaileo anal,vsis. The licensing resources expended were totaled for each year from a p ication for the CP through issuance of the full power license (FPL). These totals were then plotted to determine 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 FTEs for CP issuance, and 32 FTEs for OL issuance. Figure III-3 illustrates these results ano 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. E. Inspection Resources Regional inspection resources for base case licensing have been calculated using an existing budget model. This rodel has evolved over the last 10 years and was used by the fomer 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 III-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 phase from past experience. Additional details of the model dealing with the number, kind, and required timing of the various inspection types is contained in Appendix C. 4 TABLE III-1 TOTAL REGIONAL INSPECTION RESOURCES i. l Phase j 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

i Resources for NRC Headouarters Construction Appraisal Team inspection i efforts have been estimated to be 2 FTEs by examining actual RITS data for the plant considered to be representative of resource expenditures that was analyzed in Section !!.A.1 above. Since this plant, as well as many others, undenvent a Construction Appraisal Team (CAT) inspection, these resources have been added to the total base case regional inspection i 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 erd 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 histori-cal licensing process. For example, the primary effort during the CP a stage was licensing, subsequent licensing efforts were minimal in the early years of constructien, 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 oeveloped 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 t1e CP site safety and site environmental reviews. The balance of the 11 FTEs of TA were expended during the OL stage. 4. Legal 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 resourceprojectionforeachlicensingalternatiyemakescertain m 1

assumptions regarding the nature of the intervention, the issues raised by the latervenors, and the timing of completion of necessary staff evaluations. These assumptions are discussed in detail under the discussion of each licensing alternative. However, a common assumption has been that an application filed under any one of the licensing alternatives analyzed is expected to be very highly contested.* This nieans 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 cartification, some of which may be granted; some well-framed challenges to recent regulations which have not previously been involved in hearing; extensive discovery and many motions relating to discovery disputes; extensive post hearing appeals sno litigation. Thus, although the level of techtical effort in the staff review may be similar to past experience, the level of legal effort is based more on recent experience in the Seabrook ind Shoreham cases, but at a level below that currently required to suppcrt these cases. In general, resources shown after issuance of a license are these 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 ke 9std rather than the process discussed in the proposed 10 CFR Part 52. Adjustments to the base case estimates have been made to account fr changes that %ve occurred in the licensing review that are likely to exist in future plant licensing. These changes ano the projected resource requirements are discussed bel w. 1. Licensing and Inspection Resources Staff licensing resources necessary to review the prospective appli-cations for compliance with the ATWS rule and station blackout rule have been estimated to add a total of ~6pproximately 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 decommissioning be considered, essentially replaces the old financial review done at the OL stage. Thus, no FTE adjustment has been made. Implementation of the Connission'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-for-duty rule were estimated to add 0.3 FTE, divided between the CP and OL stages and 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. ~

• 1f a number of licensing applications were submitted at about the same time, it r.ight be more appropriate to use traditional assumptions, e.g., some-hearings highly contested, some hearings moderately contested and some

~ applications uncontested.

~ As noted in Section 11.B. the emergency planning (EP) rule promulgated in November 1987 will allow the licensing process to proce6d where 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 licensing case. However, in the following paragraph an estimate of-resources is included t3 account for protracted hearings on a variety of contested matters, including EP. As noted in Section III.A on the bes: case, the resourc2s needed for OL issuance have shown a steadily increasiny + rend. 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 stensning 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. Ine trand of increasingly organized intervention will likely continue and future isms, 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 fer siting 1:::cs 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 construction. 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 also shown that substantial contractor TA has been needed to meet schedular requirements in these areas. 2. Legal Resources Estimates of OGC resources needed to support new custom plant licensing were based on the following specific assumptions. A new custom plant is likely to have hearitigs at both the CP and the OL stages. CP hearin would be divided into two phases: (a) environmental issues, and (b)gs safety issues (adequacy of preliminary design and/or design criteria). Siting issues wouldarise in both phases of the hearing (alternative sites in the environmentalphase, and radiological impact related issues in the safety phase). Although emergency planning issues may be litigated at the CD stage, it is assumed that they,would tend to be minor and would not be litigated in a separate hearing phase. For any necessary QL2 earings, emergency planning would be a major area of contention, since ftds assumed that intervenors would contest both the i l

z. ' s, f k e q r emergency preparedness plan and the exercise with respect to whether it cemonstrated a fatal flaw in the' plan. The exarcise litigation would i focus on that exercise which is conducted within 2 years of OL~ licensing, since it is the exercise required to comply with 10 CFR Part 50, Appendix 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 i expected OL licensing date. The hearing on the plan should be conducted' earlier, perhaps in conjunction with the hearing on environmental issues, or-about 3-4 years before the OL date. These assumptions concerning the 1 timing of the safety and environmental hearings;are intended to reduce-crowding at the and of the hearing, in order to minimize the potential ~ for-delay in the ultimate decision. Based upon the above, total OGC resources required for new custom olant licensing were projected to be'25 FTEs Wxtendingover14 years).

Thus, for new custom plant licensing, the licensing resources needed have been 4

projected to be about 56 FTEs, inspection resources have been projected to be approximately 52 FTEs, technical assistance resources have been projected to - be in excess of 21 FTEs, and 0GC resources have been projected to be slightly more-than 25 FTEs. ' A detailed year-by-year breakdown of resource needs for licensing and inspection is provided in Appendix C. Figure III-6 is' a plot 'of licensing and inspection resources by year needed for a new cus om p ant case. This plot is similar in shape to base case: licensing t l L shown in Figure III-5, since the duration of new custom pirt licensing has been assumed to be unchanged from the base case. The significan, changes in resource ' projections are those discussed-abovt, which occur primarily in-years 3.11, and 12. L. Licensine 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 40% complete. Both plants in this-group have an OL stage SER and an ASLB' decision applicabb to 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 70% but do not have OL stage J SERs or ASLB decisions. 1 -'1

Licensino and Inspection Resources n

The resources-needed for plants 40% complete and with OL stage SERs (group one)havebeendeterminedas-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 tesources have been made to account for the irovi~, s of the Deferred Plant Policy Statement (DPPS) - 2 FTE staff and ~ ~ i F-" '3, updating the egional staff on the status of the design, the con druction, and the inspection program - 1.5'FTE staff; and the resolution of design /constructim crrers, allegation resolution, and r eopening of hearings - 3.5. FTE staff and 4 FTE TA. Implementation of the .DPPS has been assumed to occur principally through plant-inspection,. reb mg on' regional,' NRR, and TA >esoerces. It'has-been: assumed that-this .i +L- .+

Ek. V effort would require a five person team for four months including resolution of issues and documentation. A portion-of the the resources of the. k resident inspectors would be needed during the first year. Resources that L would be expended by regional staff for updating on the. status of plant L design, construction, and-inspection would be devoted to reviewing: L inspection reports written prior to deferral, status of construction as. .of the deferral, plant construction organization, quality assurance'pagram and program controls, and the design criteria and any changes in consit- ~ments. The estimate for contingencies is 3.5 FTE which is the inspection ~ D portion of the 15 FTEu assuned for contingencies in the new custom plant .cas e. Licensing resources have been projected tobe 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 St review of. plant-unique issues (e.g., ISI, IST and fire protec-i r,iod 4 3 FTE staff per year in years 1, 4, 5, and 6 and 1 FTE in years t and 3,; and contingencies as discussed in the new custom plant case - 3.5 L FTE staff and 4 FTE TA. Issues such as ATWS, station blac cout, emergency l planning, fitness-for-duty, and perfomance of the Individual Plant Examination will all be previously resolved on the first unit of these plants. It has been assumed that the completion of construction and, J therefore, the licensing for this case would require 6 years. L m lj t. 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-i second unit now reactivated), there remains the potential for reopening the proceeding on the grounds of new information. OGC resource projections of 10 FTE assume that a intervenor is able to raise.a significant issue, E and is successful in petting the record reopened; the hearing is limited. in scope to such' issue, There is a potential for a motion to reopen in 4 connection with the emergency planning exercise at about two years before L the expected OL date. If motions to reopen are filed but are not success-l- ful,'0GC resources would be limited (from 0.5 to 1 FTE in connection with L various ap, wis). From this analysis the total licensing resources needed for reactivated H plants with OL. stage SERs ano an_ASLB decision have been projected to,be. L almost 16 FTEs, inspection resources have been projected to be more-than L 35 FTEs, technical assistance resources have been projected to be 9-FTEs and OGO resources have been projected to be about 10 FTEs. A detailed year-by-year breakdown of resourceLneeds;isfprovided in Appendix C. d g C f6 %, 1The resources needed for review of plants.not located on a site with a-t currently licensed first unit;.that"Is plants without an OLL stage SERL 1 ~ a n._., have been detemined 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 J ~ a with OL stage SERs., additions to the base case inspection resources-hue been made' to account for the DPPS 2 FTEs staff and 1 FTE TA; updating . the regio'1al staff on the stt :tr of the design, the construction, and the inspe-tion' program - 2.5 FTEs (an increase over the estimate for plants' a , with 5ERs since the conttruction is 700 complete);.and contingenciesias discussed'[in the new custom planticase 9 3j5fF.TEs staff andi4f TEs CA % y M ih 4 D

m ' ? I Licensing resources have been projected based upon the resources for the OL stage of new custom plant licensing, which includes one additional ^FTE for project management for each of the two years associated with the. hearing. However, 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.= .3 i Technical assistance resources have been projected based upon the base l case with certain adjustments. The assumption on OL stage TA resources l in the base' case was 6 FTEs. Additions to the base case IA were then made to account for the DPPS and for contingencies. I For a reactivated plant without a prior ALSB decision, it is assumed that intervenors will raise a limited challenge on environmental matters and will actively contest the plants an safety and emergency planning issues, l including the adequacy of the most recent emergency preparedess exercise. The hearing would be on expedited schedule in view of the high degree of I completion of the plant at the time of reactivation. From this analysis, the total licensing resources for reactivation of .pitnts not locateo on a site with a currently licensed first unitL have been i projected to be 34 FTEs, inspection resources: have been projected to be. 32 FIEs,-technical assistance resources have been projected to be 15 FTEs and CSC 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 III-8 are plots of the licensing and' inspection resources for tha-reactivated plant cases discussed above. These plots have been developed for -plants where the-resumed construction activities have been assumed to be i carefully planned and full scale resumption takes place in a short time. These figures also indicate that prior to OL issuance, 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 t compliance' with the proposed new 10 CFR Part 52, resource estimates for base case licensing or new custom plant licensing, as appropriate, and the following

assumptions

w, _. w ~ . CWp My2"* ' g" gd - 1.. The applicant first' requests an early site permit.

2.

The applicantihen submits a combineh ebristruction permit and conditional operating license application that references a previously approved " certified standard design." Since the existing NRC budget already provides resources (approximately 80 FTE total) for review and approva.;l, - ~ n m y 1 Q ^ N$ Q

0 r

L .m.

v?: 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 eacn of the three different phases of the review, that is, (1) early sitr mit review, (2) combined license review, and (3) the construction inspectic s.. ting authorization review. 1. Early Site Permit Review In accordance with the proposed new 10 CFR Part 52, an early site permit review requires resources in the areas of emergency preparedness, site safety (including-raciological review), site environmental review,-site redress, project management, and inspection. The early site pennit review has been assumed to require approximately three years. This assumption is based on the estimatec curation 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 pemit. 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 infonnation in accordance with option (1) of proposed 10 CFR Part 52.17(b). Since this option only requires establishing that the site is " amenable" to EP, review resources for the site permit 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 anC 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 requireo by the proposed Part 52 has.been estimated to require about 1 person-month (0.1 FTE), 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 ccusist of 1 FTE for NRC staff and 1 FTE for contractor TA. Table III-2 summarizes early. site - review licensing resource requirements which total 15 FTEs. E Although conceptual review of several smaller (600 MWe) advanced reactor designs (i.e., liquid metal reactor and modular high temperature gas-cooled reactor) is unde may in the Office of Research, and passive light water reactor cesignr are uncer development by industry, such designs are all - excluded'from Als study.since they are not. expected to be certifiedtduring. the current' f asyear budget planning cycle.

NRC inspection resour;.es have been estimated to be 0.3 FTE. This is equal to the resources required for the pre-CP inspet: tion phase for the base Case. Hearings in an early site review proceeding will focus on environmental-ano siting safety issues. To estimate OGC resources, it is assumed 1 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 III-2 sumarizes the early site review licensini, inspection, OGC l resources and Technical Assistance requirements of 15 FTE. 0.3 FTE, 5.5~ FTE-and 6 FTE respectively, in tabular form. Figure III-9 is a plot of the-licensing and inspection rescurces needed over time for an early site permit. TABLE III-2 EARLY SITE REVIEW RESOURCES (ESTIMATED REVIEW DURATION = 3 YEARS) A. LICENSING RESOURCES FTE Emergency Preparedness 0.2 Site. Safety Review 6.6(+2TA) Zite Environmental review 1 (+3TA) Site Redress 0.1 Project management 6 Contingencies 1 (+1 TA) 15'I+6TA) Average licensing resources: 15 FTE/3 yr. = 5 FTE/yr. (+2 TA)' .B. INSPECTION RESOURCES FTE QA Inspection and Licensing Support 0.3

Average inspection resources:

0.3 FTE/3 yr. = 0.1 FTE/yr. L C. OGC RESOURCES FTE Hearing Support and Appeals S.5 TOTAL 21 (+6 TA) ' s 8/,, ' y rN - l/pp g.- y

M y 4 = 2. Combined License Review In accordance with the proposed 10 CFR Part 52, issuance of a combined license will require review efforts related to emergency preparedness,. a 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 eoual to the total base case EP requirements of 0.5 FTE, since the full fonnal emergency plan review ano approval will occur at this stage. The technical staff review of site and design interfaces has been projected to require 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 TTEs from the 30 FTEs total for the base case operating license review. Project management resources have then been addeo 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= review arec (1.5 FTEs). A total of 2 FTEs has been estimated for combined license review contin-m gencies such as resolving difficult interface issues and protracted hearings. This effort has been assumed to consist of 1 FTE for NRC staff ano 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. OGC 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. '0GC 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 basis. LIf 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. .? 4[ gy ~, 3, + 3 yGf ni ~

+ , 2. : V.. F*.[ TABLE III-3. i COMBINED LICENSE REVIEW RESOURCES i (REVIEW DURATION = 2 YEARS) A. . LICENSING' RESOURCES i g Emergency Preparedness 0.5 Technical Interfaces Review 3.7 + Project Management (2 FTE/yr. x 2 yr.) '4.0 l Anti-trust / financial qualifications 2.3 o Utility Management Qualifications 0.4 Fitness-for-Duty 0.3 Environmental Update 1.5 Cor.tingencies 1 (+1 TA) ITT+1 TA) Average licensing resources: 14 FTE/2 yr. = 7 FTE/yr. B. INSFECTION-RESOURCES FTE- . Regional Support for Licensing 2.0 Average Inspection resources: 2.0 FTE/2 yr. = 1.0 FTE/yr. 1 C. OGC RESOURCES FTE l Hearing Support and Appeals 7.0 TOTAL 23FTE(+1.TA) .i 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 ~be7the e 'same.as those for the base case and custom plants. Three inspection phases, readiness (PTOR)pection program (CIP), preoperational testing / operational' construction ins ,~and startup testing (STP) would be utilized. The CIP. phase has been estimated to take 5 years, the PTOR phase has been estimated to take 2 years starting in the sixth year, and the startup phase has7 een b io assumed to occur during the year after operation is authorized. Inspection . resources are estimated by phase using the budget model previously described in Section III.A.2. Resources for a construction appraisal team-(CAT) inspection and for contirgencies have been added to the budget model-predictions. A_ resource total of 50 FTEs for inspection results - from summing;each component as gan bejseen in Table III-4.~ gggg,g %,w

3:..

• J

2. :

i . TABLE III-4 CONSTRUCTION INSPECTION /0PERATING AUTHORIZATION RESOURCES A.. INSPECTION RESOURCES Phase FTE Phase FTE/yr Duration Total CIP. 5.9 5 29.5 PTOR 5.6

2 11.2 STP 4.6 1

4.6 CAT Inspection 2 Contingencies 0.3 8 2.4 (+2.4 TA) 50 (+2 TA) 6.- 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 (+3 TA) 14.(+3 TA) C. OGC RESOURCES EE Hearing Support and Appeal 6 Total 70(+5TA) NRR licensing review activities would also'take place during facility construction. 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-technical ~ issues that arise as construction proceeds. 'It has been assumed that similar NRR support would also be provi M during-the PTOR phase. NRR involvement would increase when the lice: - lubmits a request for authorization to operate about six months before.,ortup.. . Thereaf ter, 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-renth/ year for resolution of_ technical concerns during construction. An additionai 1 FTE/ year for project management has been added during the last two years to accomodate, w the issuance of the operating authorization. A total of 6 FTEs has been added for contingencies. with an assumed breakdown of 3 FTEs for NRC staff and 3 FTEs contractor technical assistance. From Table III-4 it can be i seen that the resulting total is 14 FTEs for licensing resources. i b; 4 x Mogy O y

t. T,1,

,tA

._f I j.L'I OGC resource projections assume that an intervenor is able to satisfy the threshold requirements to raise a significant issue at this staget.the hearing is limited in scope to such issue. For timing purposes, the issue is assun.ed to be raised two years prior to the expected date of the operating authorization. OGC resources of about 6 FTE are projected to s' 3rt the hearing and appeals. If a hearing request is filed but the in'tt, unor is unable to satisfy the Part 52 hearing threshold, OGC resources would be limited to between 0.5 and 1 FTE in connection with various appeals. Total NRC licensing and inspection resources needed over' time for the-combined license review through the issuance of the operating authorization -and the' completion of the startup test program are shown in Figure 111-10. flote that this figure does not include resource estimates for the early site review phase which are shown separately in Figure III-9. In summary, resources required for review of a standardized plant (including early site review, combinea 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 cf these required resources is detailed in Appendix C. e -Mhg 9 m p .1 g { t

f'4f

/ c.<* '

.w. ? !. :: b 7 f'. g cyg ":. #.1! CENSING RESOURCES EXPENDED VS. CPLISSUANCE 3 c 9-7 p .) .l >.18 - .16 ~ 7 OMARBLE HILL' 1 O P8W 14T l, y-

• o WOLF CREEK

-- 0 JAMESPORT [ l-12 - 3 o PHIPPS BEND' .W 0 RIVER BEND 0 YELLOW CREEK g 0 SEABROOK l 10-o -PALO VERDE 'O ? Z 9 jj o SOUTH TEXAS c. g4 h o GRAND GU'I 3 6-- ( o. V0GTLE - o BYRON O M!LLSTONE 3 4 ~ 2 ,<0 I 74 75 76 77 78 79 -YEAR OF CP ISSUANCE. - c m x

+ e: f ' \\ v = cure "f 2 LL! CENSING RESOURCESLEXPENDED VS LPL lSSUANCE!

5:-

i.3 I pe 0- se taAs i y o ,i.' ,l {' 40T i -i-Iy 7 33 u 0 -W. vocitE1 Q 30 -' O gynow i 0m1 g M 0 PALD WRDE 1 0 RLEONE 3 r.! o es e i 25 e ouv 10: 11 l ra 520-mo l J'- 0 CAl.LAWAY .I~ 15 0 - wCJ CRS i-i o .10-7 s 5-- Ti 0 v t: 82 83 84 85 86 87 . y YEAR:0F LPL ISSUANCE

o e

L Fig u re 111 - 3. LICENSING RESOURCES (BAS E CAS E) l l = e-- = 9 i 1 2 3 4 5 6 7 8 9 10 11 12 13 '(EAR AF~l ER RECEIPT OF CP APPLICATION e k&

Fig u re 111 - 4. INSPECTION RESOURCES (BASE CAS E) 7 ISSUE OL e-- V 5-- 1 2 3 4 5 6 7 8 9 10 11 12 13 o _ ___. _. _ _.._.

[ Fig u re 111 - 5. LICENSING AND. INSPECTIDN [ RESOURCES (BASE-CASE) l LEGEND u kjh LICENSING. 'l L ta-g a D U m y O INSPECTION M b ~ m Tri rm. ] 14-- g 12-- M h 10-- ~ .n_ idb 8-- j I s. F .o [ S 1 2' 3 4: 5 6 7 8 19 10 '~1 1 ~ 112 i 13 YEAR JAFTER' RECEIPT :OFbCP.: APPLICATION ~ 1 ~ = =x_.-~~,_.. 3t ~. x. i+ " ' ~ ^

( Fig u re 111.- 6. LICENSIN.G AN D IN S P ECTIO N RESOURCES (NEW CUSTOM P LANT) 8 LEGEND N @M LICENSING is-- 8 l a 16-- O f so-TOl'AI. 9 y 14-~ "8 ~ i2-- .~ ~ 10-- Q x .a- ~ 6-- [ G .o 5' 6 E7-8 .9 ' 1.0

11. :12: 13 1

2 3 4 YEAR :.AFTER :.RECEIP F OF?CEAPPLICATION: [ 2 ,7 7 u

. ; =;

=.;

l

Figure 111-7. LICENSING oc INSPECTION -RESOURCES REACTIVATED PLANT WITH E ASLB-DECISION. CONSTRUCTION 40% : COMPLETE 3 LEGEND o .is- - b I LICENSING S 16-INSPECTION r . 3o l'O TAI. 34 l 12 --- ( ' 10 --- a. w( g. 6- -- 4' [ 1 2 ) g _ a s_ s_ ~ ~1 '2. 3 4-5.. ~6 -YEAR AFTER REACTIVATIO' ~ ,-~- -N; 1 - 7* - - - - - - -. = -. . n. u.. y-6;L =: +- ~

ll, su lb.,..... o Figure 111 - 8.. LICENSING & INSPECTION RESOURCES-REACTIVATED PLANT WITHOUT ASLB DECISION CONSTRUCTION -70% COMPLETE 2 LEGEND ax. sd LICENSING E! . is-- -y ~ t. INSPECTION oe. IrilAI. 34 ) 12-- ~ t o --- y,._ l7 ~' 6-p n 5:N 4 r e /. 2-3_ 9 g e h-l' ~ S S'-- 'Y A '~' o. 1 2 3 .4' .5 ~ n u' YEAR AFTER REACTIVATION: i i ~ ~ = .v - -'..gj 3 s =..:- y. = -. ^ ^ u- - ;W.. _; ;;-b. -

FIGURE 111-9. LICENSING & INSPECTION RESOURCES. (EARLY SITE REVIEW) g LEGEND If 15PECTION LICENSING s 1 ... ~. 4 i.<.-. ....,y. s

.;s.g M..; -

,, e.c.. < R*gNN'S,.y $w/;^ t4.,. V.... .p.i 4 ./,.,. e RS.4;+- e,>.$:. *:. '.-y' .s.., e.s. 7. - e.va n., $"+~2 R..~ v,, y :v..x.j s:.y..x.,-;,- .-ep, .s v.s b 6,b+/ ".s, X-X-X<* /.- % q,s.?Q.$.' cp s.. .y -

v..v. g. v<

'.*>,.y.s.,y

i. A.- O..s

..v., c p v.-.-<.. i r.,c,... 6 - v v. ....v.v y ;. z,q/>. r>.v.. f... vs.. - -.. 2 f. v.v.v.v. d y-y-i>v.v - ,..y. v. 2

v... -

.s.. i-s.. .y, y, Ld 6 -------#< , y~s. < yo.. s..- / y,.s 4 C479v.qy' ,y-7.;re.: - y.*+ *4 N ^s '4.- i 2 2/v.s.y s... s y. c' ',y. >...,,.-/.- y 'q,. fqv. y ta n: . ?.>,. -.y f-g /,9.s.y. .. ~..... y 2 4. ...v - ?.,e s. .v.- A. sy.v5"... i s L2

s. y. ' y " y Sj:

'v.,..y,y y: s'v:.v.v.f... v. x.y -.y v.-.., 2-- v/y. S ".[.6. '..y,y-a :; 's,- .s..

v..-s.-/...c sv3.;. ".s.y N.

su.y. cy:., Os..yAv.s : vf ...-v-. vf v.. .s . y.s .....-7-/. .y.u : s.y...6.y- '...v .y sv/. 7.. X- .. v. v..-

v. s.- --

,s..s.~...4 v.v. e..9. '

.v. ~,

r.v v.- s.. in,-e.v..y

s.../.f...,.,,

..ve.

v....... y,

......y..y v q.. ',.-<...-<.b.- '. v..-.,.A,' v...v..,....v .-s ,..v...,...

v.. f..... o<

s,v. ;.- '?./y,~...y: i ..v... v. ,y. - O .-/..y ...v.-/.s s y.v.y./y s'... -/. ..v.. 4 s..y y.y s. ' y...s,.. 3 s..v. g Ay: ,..v: ,'.yc. v.,y., ...y .-: ?. 2.. .v s.y.....v. . v....... .........y, ......,...~ >..,.........s. '.:.v.~.- .. ~.. -.... -. ,......,.-:.~.,, q.,......, .p,, .y ..y..- ... ~. ....v. >,s.y. s.. y..,..y. .~.- v.v-: :~ n.__ v.v.., n.~ v>:..,.,:m 1 1 2 3 j 1 YEAR AFTER RECEIPT OF APPLICATION i ...-~...__ -. e.

l FIGURE 111-10. LICENSING & -lNSPECTION RESOURCES (COMBINED LICENSE APPL.lCATION REFERENCING A STANDARD PLANT l AND A PRE-APPROVED: SITE) 2 r LEGEND 1.=. bN LICENSING is--

p n

n .j .}.. INSPECTION !b /4> TOl'Al. i4-lI! ~

l p

. ' *~ ~ b -Qjio-( a ~ k-.. a-e. ? k /,. ~4 s h' f 3 ~ + f 4 e 2. 3 ~ i l '? 3 7 3 3 I, L'd 3 s f/ 6 O 1- -2 J '4. 15-6- '7 8 9 ~101 YEAR 'AFTER

3.,

- RECEIPT - OFL APPLICATION. j. ^

1. .c__

- J

.;.A m k CHADTER 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 resources 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 uniformity and consistency in applications, staff reviews, ard inspections. Clear guidance to applicants also facilitates both the preparation of documents for staff review and tne 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 form the basis for determining which guidance documents should be revised. In general, only dreaS Which Cannot be included in the design Certification reviews for standard plants were considered as candidates for updating. The vast majority of these '7 are site relateo, although financial planning for deconsnissioning and physical security are discussed in this chapter because of recent or insninent 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 aro already scheduled for completion in the early-1990's by the NRC, J revision of guidance for plant and reactor systems would not lilrtly to be completed on a schedule which would contribute substantially to these i L 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 fonnats used by the staff to assist both applicants and staff in the preparation and review of applications. These-are the Standard Review Plan (SRP), The Environmental Standard Review Plan (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 0) must be addressed and about 20 Regulatory Guides (primarily guides in Division 1 -~ Power Reactors and Division 4 - Environment and Siting) need to be included. The ESRP wds last updated in 1979. Regulatory Guides have varied revision-dates but most have not been updated since the 1970's. The last (major) full I ' scale revision of the SRP was 1981. The NRC Inspection Manual provides inspection requirements, guidance, and policy .for implementation of the inspection program during construction and operation of power reactors. The construction inspection program implementing manual i 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. 1~ B. Needed Additional Guidance Related to Rule Changes Changes to several rules in the past few years hr.ve resulted in the need for additional staff guidance. These include !? C R Pr.rt 50.33(k) and Part 50.75 regarding-Decommissioning Funding and 10 CFR Part 73 (Physical Security).: The i specific information which a new applicant must submit for a staff review with

.l j 1 regarc te decomissioning needs to be delineated in a new Regulatory Guide. A new Stanoaro Review Plan Section is also needed. Likewise two new guides need to Oe prepared, one to address Fitness for Duty, and the other to address Access Authorization. A revision to SRP 13.6 (physical security at power plants)isalsonecessary. For Emergency Planning, new guidance is requireo because of proposed rule changes l tt 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; 'i S'tanoard Design Certifications; and Com)1ned License For Nuclear Power Plants." With regard to emergency planning submittals, the proposed Part 52 allows options ranging from submittal of general information 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 l a new guide needs to be issued. In addition the proposed 10 CFR Part 52 (in both subpart B and C, contents of applications) requires as part of the appli-cation the " Proposed tests, inspections, analyses and acceptance criteria which are necessary and sufficient to provide reasonable assurance that, if the tests, inspections and and analyses are performed and the acceptance criteria; met, a plant which references the design is built and will operate in accordance with the design certification." This requirement may involve submittal and licensing review of system specific preoperational and st:.. tup tests procedures, among other things. In the past, detailed procedures were normally finalized 3 to 4 years prior to initial criticality ano reviewed by regional inspectors during the nomal construction inspection program. Reg. Guide 1.68 " Initial Test Prograns for Water Cooleo Reactor Power Plants" needs to be revised or a new guide issued to reflect these requirements of 10 CFR S2. One additional rule change related to siting is considered to be desirable for future plants. This is in the area of seismic and geologic siting cr_iteria (Appendix A to 10 CFR Part 100). For example, guidance is needed to define standards and methods for detemining such parameters as the operating basis earthquake, and shutdown and restart criteria. In addition to the rule change itself, a new regulatory 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 Reguiatory Guides 1. Environmental Standard Review Plan (ESRP) The ESRP.was last updated in 1979. The document serves 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 ana 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 " Power Supply"; 8.4 " Staff Assessment of Need"; and 9.2 " Alternative m

T.. \\ b.=' Sites". These'shouldlall.be finalized.- In particular, a major revision. cr accition is necessary for Section 9.2 " Alternative Sites". This has been a much litigated issue in several previous applications.' The ESRP also needs a general update with regard to currently endangered species. Standarc Review' Plan The Standaro 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 to' be revised assuming Appendix A to Part 100 is revised. Other sections of the SRP related to siting need only minor rwisions. Aside from the siting sections, revisions to the SRP will se needed to address Financial Qualifications for Decomissioning and Physical Security. l -3. Regulatory Guides Staff effort will be needed to modify existing regulatory guides or to oevelop new guides. Since a number of~these guides are needed for plants currently operating, the resources needed for revision of them are

not incluced here. In the area of Raciation Protection Standards, 7 new guides are requireo, 3 other guides need major revisions. and about 22, miner revisions are necessary. A new guide discussing the decommissioning aspects-of the financial qualification requirements of 50.75 is likewise needed.

The most recent Physical Security Rule changes result in the need for two new guides, one dealing with Fitness for Duty, the other addressing c . Access Authorization. -However, both of these areas are judged to be 4 equally applica: e to plants already licensed. and therefore the develop-l ment of guidance should nct be attributed solely to new plant licensing needs._ If Part 52 is issued as currently proposed, then Regulatory Guides 1.68~and 1.101 will need to be revised or new guides prepared describing staff requirements regarding applicants-testing and inspection programs and emergency-planning options respectively. With regard to plant siting, a number of Regulatory Guides (or associated-i NUREGs) neea major revisions and others need minor changes to incorporate lessons learned from operating experience and to clarify the staff's current interpretation of the applicable regulations. 4. Inspection' Manual The construction inspection program is divided into four areas defining activity-specific inspection phases. They include (date last revised in parenthesis) the pre-construction permit (1977), construction (1986), preoperational testing and~ operational readiness'(1984), and startup testing phases (1984). Prior to the onset of significant new construction activities, all phases of the construction inspection program need to be examined and modified / updated to ensure lessons learned from the-recent past are factored into the inspection process. For example, in the past the NRC has not focused' on the factors of management capability and prior nuclear experience curing the Pre-CP construction phase licensing and review. The existing Pre-CP construction phase' inspection procedure needs revision (1977 vintage) ano should focus on the utility's management capabilities;and prior nuclear experience' to oversee a large construction project. Other potential =

i \\t, (_ a, L r cnanges:for management consideration include' expanded regionally based team inspections; continued shift in emphasis from records review tc- . direct work observation; integration of a fom of the licensee readiness review process, as used in Yoptie 2 pilot program. With the promulgation of Part 52, a companion inspection-procedure.is. needed to implement the testing mi inspection Regulatory Guide previously discusseo in this Chapter. D. hRC Resource Reouirements for Needed Additional Guidance The resources needed to complete the guidance documents-discussed above are:- Rule Changes 2 FTE -SeismicanoGeologicCriteria(Part100AppendixA) Environmental SLP - Finalize Sections 8.1; 8.2.1;-8.2.2; 8.3; 8.4 2 FTE - Mettedology for Alternative Site (Section 9.2)- - Update For Endangered. Species Star.dard Review Plan 2 FTE - - Sections 2.5.1 through 2.5.5 - New Section on Decomissioning ' Regulatory Guides 8 FTE a - Geologic and Seismic Guide - Siting Guides - Testing and Inspection Guide Inspection Manual 5'FTE Revise Construction Inspection Manual i Chapters and Associated Procedures 1 (MC2511-25'14) - Develop. Testing and Inspection Guide Procedures TOTAL 19 FTE These resource estimates 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 a. requiring 0.3 FTE per task.- One exception is ESRP Section 9.2, Methodology for Alternative Site Evaluations which is judged to be a larger effort (0.5 FTE). H 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 for 2 Physical Security regulatory guides nor the Physical Security SRP changes v 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 already budgeted for the preparation of guidance to address severe accident considerations.

e' e i The tir.e at which these updated guidance documents should be available is, of course, dependent ~upon when the future applications which could benefit from' these guidance documents are-filed with the NRC. As will be discussed in the next Section, DOE has made,)rojections of future nuclear ca sacity for the years '1990 through 2020. Based on these projections, it seems li cely that future applications that would benefit most from these updated NRC 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 documents by that time should be provided in the 1993 and 1994 NRC budgets. 1 i l t l' i'. r.- 9 M p h

CHA:TER V. NRC RESOURCE REQUIREMENTS FOR SATISFYING DOE NUCLEAR CAPACITY PROJECT 10NS Projections for future nuclear capacity have been made in a study by the Department ^ of Energy (00E) entitled " Commercial Nuclear Power 1988: Prospects for the United States and the World," 00E/EIA-0438(88), published September 1988. The DCE report contains capacity projections for the years 1990 through 2020. j These projections are reproduced in Figure V-1. DOE has assumed that no nuclear plants stemming 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, ar.d 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 vendors 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 sssumes that one such reactivated plant will be completec in 1995, one in 1996 and one in 2003, while the lower reference i case assumes that none of these three plants will be reactivated in this time frame. Taking into account previous estimates for leadtime, as explained in i 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 i realized. Beyono 2005, the upper reference case has been based on energy needs from projecting growth in nuclear capacity using an aggregated model that derives nuclear generation requirements (and installed capacity) as a share of celivered energy. Delivereo energy has-been projected using a demand function composeo 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 i 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 capacity has been f assumed to occur by DOE as a result of decommissioning. To make up for this P loss, one new 1200 MWe plant would have to become operable by 2007. Since the DOE lower reference case assumes no reactivated plants will be completed, the 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 m standard plant would have to be received in 1995. The projected NRC staff resources-for satisfying the DOE lower reference case (that would first be a needed in 1995) are listed in Table V-1. These resources are those neefed to p:ocess the futurr application only; resources for guidance development are not included in this table. f "' -.... _ _ _ _. _ _ _ _ _ _ _ _ _ __

t The upper reference case in the ' DOE report projects that 114 GWe of nuclear ccpacity 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 piar.ts 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 l 1990, 1991 and 1998, i In 2007, the upper reference case projects that six more plants would be needed. Using the previous 'leadtime assumptions, six mo.e 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 applications would be t received: three reactivated plants (one in 1990, one in 1991, one in 1998), two custom plants (one in 1994, one in 1995), and nine standard plants (four in 1994, five in 1995). Using these assumptions, the total NRC staff resources needed to process the future applications that would satisfy DOE's upper referer.ce case aro listed in Table V-2 for 1990 and the subsequent five year planning perioo, f i l '1 h 1. l ~. 1 t

t [* .j/ TABLE V-1 n !!RC RESOURCE PROJECTIONS IN FTE FOR SATISFYING DOE LOWER REFERENCE CASE 1 1990 1991 1992 1993-1994-1995 Custom Plant i Inspection 0.1 Licensing. -6.4 Legal 1.6 Technical Assistance 1.7 Total "Ei t. 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 UPPEk REFERENCE CASE 1990 1991 1992 1993 1994 1995 Inspectior. 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 1 Total 12.7 27.7 38.5 51.0 84.4 109.4 .m., c

~ . n '. ' ~ e e + 4.- i c ~ ! TJ P.E '.'- 1 : - EXCEF.PT D FRO:: DOE /2! A-0 4 3 8 (8 8 ). 4 Figure 2. Domestic Nuclear Capacity, 1982 2020 t-:p pmvww myw.w _., m -gy,,,, gy,. .y. y h

p!

1 y, pp s$ 17 5 - / Upper : 0, ' _2 e Reference-ng-e e ex e f i@ 0 150-5 H ,5 f$. $. 'i ~ Z l-T ....+ ; m o e ? O r.s 125-f 'y 0 0 ss .i ,/ T....i i a .. l -O 0 . tilltin + n u n n :- essa'g.., T.) j J.. - ..w i w atgg"'gg4

• c ammmmmm

--. l H ama Ti- .c w 10 0 - -i p!! i o z a t. 9: .f1 E. e' 'd / Lower n ~~- Reference 75- ?6 c -.i n c sy C. C 9 c T C a .,c No New Ordars = 50-a i o 4 1 =. dj ~1 Z .e?: li @) s m... b3 SN a a . y. c:s o a %} 1980 1985 1990- 1995 2000 2005 ~2010 2015 2020 1. ,r Year of Activity See Table 5, snc Energy Information Administration. \\f onthlv Enerev Review

.;r:e January 198B. DDE EIA-0035(88 01)(Washington DC April 1988) 1

,x CHADTER VI. NRC RESOURCE IMPACTS OF PROCESSING EXPECTED FUTURE ~ APPLICATIONS The impact of processing future applications on the NRC five year budget cycle fror.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 than 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 nuclear 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, a reactivated plant would provide a more rapid response to a significantly . 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 be received early in the 1991-1995 five year planning period, it 3 seems prudent for NRC to assume that at least one of these applications will 1 be under active staff review beginning in 1991. We recomend that this approach be adopted for budgeting purposes, l Listed below are the NRC resources needed to review'one reactivated plant application received in 1991. The table also includes the resources needed to update needed regulatory guidance documents which are discussed in Chapter IV. NRC FIVE YEAR PLAN RESOURCE NEEDS FOR DR0 CESSING FUTURE APPLICATIONS 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 L None of these resources are contained in the current NRC budget.

) 1 l j CHAPTER VII. ORGANIZATIONAL STRUCTURE l This chapter addresses modificatior.s 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 permits: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 S Safety and Environmental Analysis (DSE)ystems Safety (DSS). Division of Site 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 Managerent was responsible for overall management cf all safety-related licensing activities on commercial power reactor facilities, including the processing of applications. In this context, overall management included both the technical and the administrative coordination functions. The role of the license application project manager was to schedule and coordinate the technical specialist reviews and to perfonn an overall review of the application in orcer to provide integration between review t 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. 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) reported to a different assistant director. 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 project managers who managed the environmental' portion of the review. Some of the specialists participated only in the environmental review while some were involved in both the safety and environmental reviews. 3. Division of Systems Safety (DSS) ~ 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 responsibilities for review of new applications. While the project manager considered each project on an inoividual basis, the

.o i DSS branches were able to assimilate operational experience in specialized-areas of technology, and thereby achieve a more generic viewpoint. E. Oreanization Modifications' for New Licensing Reviews An essentiel feature of the prior NRP, matrix organization described above was that the project management function was separated from the technical review function by 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 w projects and five technical divisiens. The projects divisions are dividN '.nto assistant directorships which are made up of indivicual. project directorates. The technical divisions are composed of technical branches of specialized expertise. This existing organizaticnal structure can be easily modified to accomodate any number of new license applications and still maintain the advantages of a centralized project manecement staff and a centralized technical staff. The specific details of the organization would depend upon the number of applications receivec; however, the structure of the NRR organization need not depend upon tne type of licensing review process utilized for new applications. This is 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 Organization l For a single new or reactivated plant application, the project could be assigned to a project manager within an appropriate existing project airectorate, 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 orcer.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 directorates could be created. l 2. NRR Technical Organization Neecea 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 i appropriate technical division. Additional environmental review expertise L could be obtained from technical assistance contractors whose work would be n.anaged and reviewed by the NRC environmental and site specialists.

l i i These contractors.could be used to supplement the NRR staff without mocifying the NRR organization as the number of raw applications grew.- 3. NPR Antitrust and Financial Review Organization The adcitiona 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 1 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. In the past, a headouarters based Construction Appraisal Team (CAT) inspection w6s performed during the PTOR phase.: NRR staff ~ expertise capable of leading and conducting the CATS for-the reactivated plants resioes in the NRR organization but would have to be augmented. As previously, the NRR resources could be supplemented by contractors. 5. 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 shoulo 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. 'V' g w

.c + 5 CHAPTER V:::. CONCLUSIONS AND RECOMMENDATIONS [ The enclosure to the ED0's September 21, 1988 memorandum to the Chairman providec six objectives to be acccmplished by the Licensing Readiness i Assessment Group. Each of these objectives is presented below along with the groupsrelated conclusions and reconenendations. Objective (1): -project ano analyze 9e 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 p"rpose 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 per1 nit and conditional operating license; (b; those that contain scee comoination of the features in (a) above; (c) those seeking construction of a custom plant on a new site; and (d) those seeking authori:ation to resume construction of a partially completed unit. Conclusion Future applications which reference a Certified Standard Design, use a pre-approved 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, for each type of application / request in (1) above, the practices, procedures, guides, standard review plans, rules and regulations ^ that will have to be revised or developed and be in place before an applicati,on is received.

,.O Ciscussion 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 _6 Cocineo CP/0L application. Thus, revision and updating of staff guidance in the site area should be accomplished. Plant system and other plant design reviews are expected to be minimized by a Commission emphasis on standardization. Since-completion of several standard design certifications is expected in the mia-1990's, revision of guidance documentation in the systems and design areas cannot be completed on a schedule which would contribute significantly to the completion of the standaro design certifications. ReconMndation The specific documentation, principally site and environment guidance, discussed ~ in Chapter IV should be updated or revised. This task needs to be completed befera 1995 in order for the guidance to be available to applicants on a time scale consistent with DOE nuclear capacity projections (discussed in Chapter V). Cbjective (3): identify the resources needed to develop / revise procedures, reguiatory guices, standard review plans, rules and regulations. Recommendation 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, approximate h 9-10 FTE per year are needed in 1993 and 1994. Objective (4): Hentify the organization and structure needed to review, process ano manage work activities associated with each type of application / requestin(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, arc is amenable to the processing of future license applications for any of ~ the cases discussed above. The existing matrix structure of projc t management and technical divisions would need to be slightly modified to provMe 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 C 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 applications -should report directly to the Assistant Director in ordor to assure adequate visibility and-priority for the future licensing projects. A 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 I 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

c ' nspections, associated with each type of application / request in (1) above. i Such technical expertise.could be obtained by direct hire and/or by contract. Conclusion Total NRC resources (in FTE) to issue an license for initial opmtions for new or reactivated plants were estimatea for the licensing scenarios shown below. Tech Licensing Inspection Legal Assist TOTAL 1/- Standard plant (with certified

design, Early Site Review 15 0.3 5.5 6

27 Combined License /- Operatine Auth. 28 52 13 6 99 Stancaro Plant Total 42 52 19 Tf T2T 12 year perioo) Custom plant -(twc-stepCP/0L process - 12 year period) 56 52 25 21-155 Reactivated plant (second unit with ASLB cecision - 5 year 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 u' sed-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): adoress the impact of resource needs on the 5-Year Plan and. _.~ whether ano to what extent such resources could or should be accomodated in ~ the Plan. l 1I Rounded to nearest FTE

o-e 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 i depending upon the projected number of applications received each year. Based i 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. Recommendation As discussed in Chapter VI, the Commission 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 needeo to support the review of one reactivated plant application and to prepare guidance documentation for new applications, expected to be receiveo by 1995 are as follows: FIVE YEAR plan RESOURCE NEEDS 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 Total 12.7 15.0 33.0 37.0 14.4 mMe W" b

y,, t ,qgwy engf;

~gz-.

,s. A ., -),i 1 [, p a- .g 4 1 l ..tr Ik r k' ~ k Q:s . \\, S . j-1 .i!- t g [ ' j. e k e5. e f-y [ t b '.g .1y P 1. -.e t* k 3 m F 2 f APPENDIX A. e bh b t i n J ' - t + f. 4-f a 4 k: ,L. e. Ety r e t hh+-eemmw,c.y w ,%, a .m

1 i. -f. '* g veinTDSTATas - f %, g e-NUCLE AR REGULATORY COMMISSION j gl wAemie.oton, o, c. senes Q ef } SEP 211963 1 MEMORANDUM FOR: Chaiman Zech FROM: Victor Stello, Jr. Executive Director for Operations

SUBJECT:

WORKING GROUP TO ASSESS' FUTURE LICENSING 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 s' 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. I plan to have the group begin work issnedtately and provide its conclusions and recomendations to me by December 23, 1988. We would then be prepared to deal with any necessary adjustments to the Five Year Plan in early i 1989. 'I will separately task the Office of Nuclear Materials $4fety and Safeguards j to perform a similar study of the licensing process and resources needed to handle an application for the construction and operation of e uranium enrich-ment facility.- The conclusions and recomunendations of this study will also be due by December 23, 1988. I expect to forward reconsnandations on this matter 1 to the Commission about 30 days after I receive the study results. / d0 ctor Stello. Executive Dire'etor for Operations

Enclosure:

Charter cc: Comissioner Roberts Comissioner Carr Comissioner Rogers SECY OGC th Nk g l lI 1

4. CHARTER WORKING GROUP TO ASSESS READINESS TO PROCESS LICENSE APPLICATIONS At the recuest 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 fm Zech to Stello. 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, Chairman 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 Chaiman of this Steering Group. l. This Steering Group will provide the general policy oversight and guidance to l.~ the Working Group. The Steering Group will seet as necessary with the Working Group to review the status and provide further policy direction as needed. The l L l AA-2

9 5- ,-a' 1 i_ q: 't I 2.- f Werking Group will'be composed of the individuals providing the following' l technical expertise under the direction of Dr. Charles Miller, Standardization ~ and Non-Power Reactor Project Directorate: i Severe Accidents (1)I j Systems (1) Engineering (1) Radiation Protection (1) Projects. Siting, Environmental (2) Legal (1) ~ The objectives of this Working Group are to: l (1) project and analyze the-licensing process that should be in p' lace Ll for submission, review and decision-making on future applications l. !'L for construction and operation of civilian nuclear power plants. L For the purpose of this study, such applications are: l (a)- those that reference a Certified Standard Design, use a. i I pre-approved site, and apply for a combined construction permit L and conditional operating license; -(b) those that contain some-combination of the features in (a). above; 1 .(c) those seeking construction of a custom plant on a new site; and 4 'I Number of' individuals needed. z

.,c k + 3 (d) those seeking authorization to resume construction of a _j partially completed unit. 1 (2) identify, for each type of application / request in (1) above, the 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; (3) identify the resources needed to develop / revise procedures, regulatory guides, standard review plans, rules and_ regulations. (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 agencies such as USGS. -(5) identify the resources, including technical expertise, needed to review, process and manage work-activities, including construction 1 inspections associated with each type'of application / request in I (1)_above. Such technical expertise could'be obtained by direct i hire and/or by contract. l l (6) address the impact of resource needs on the 5 year Plan and whether L" 1 and to what extend such resources could or should be accomodated in the Plan. The Working Group will submit its conclusions and recommendations to the Executise Director for Operations by December 23, 1988.

Attachment:

Memo fm Zech to Stello 8/18/88

l w.: lI [s.s ess 'e, UNitt0StaTtt e ./ NUCLEAR REGULATORY COMMISSION CrT/j Q aan.u=otos.s.c.sosas j L August 18, 1988 amanwv COMLZ-AB-27 7 MEMORANDUM FOR: Victor Stallo, Jr., Executive Director for Operations FROM: Iando W. Each, Jr. (V. k SUS 7ECT: READINESS TO Process A NEW APPLICATION RA 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 nn 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 idensity 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 ters, etc.). This group-should elso 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 now 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 completed 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 say 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 CEcY GPA OGc Revd 01f. IDQ Date fr'. /B h'. :;.c w

w m.,.mc 1 i g .,.,,m. 9 w o 9, N 4 t i s 4p; t s )?.- ?!' t w. d, i ]

k. 7,

[ =? p a= t 4: . [ . s, t f

,A' j

g:, b ,:n i

A

.1; .4 L s s .s vv.- ..r .y 3 v, '{ (c - t e .f.t ,- i<. i .h

APPE:: DIX B 3

t o L 'C s - f? 2 .s+ T e a s 9 ,9. p W 4 'l k L f ' ^, -{ a

• y

[$ ^ e. t ^ -- 'i i U -[ W(4'-- 'Mr Da s'a- + csh. K.cr7 +.ga. -M s,4y y .sm.,e.,. m,..-n.

7 g i APPENDIX B: BACKGROUND ON THE HISTORICAL LICENSING PROCESS. The historical licensing process consisted of two stages. First, a construction permit was issued by the Connission authorizing construction of the proposed facility. The fccus 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 [ construct 1)n, and on testing, operations, and emergency preparedness. An applici.nt for a construction permit for a nuclear power plant could tender l the required information in three parts. The first part, consisting of anti-trust in'ormation, was tendered 0-36 months prior to the submission of the other reluired information in order for the Justice Department and the-NRC staft' to begin the antitrust review. The second part was the Environ-rrental Report * (ER) and site suitability infomation and the. third part was the Prelim 1riary Safety Analysis Report (PSAR). Tendering of the ER tradi-tionally prececed the tendering of the PSAR by no longer than six months. From the time the faC had receiveo notifict. tion of the utility's intentions to-build a nuclear power plant up to the issuance of. the. construction perinit, the Pre-CP inspectier. 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 err.phasis was placed on verifying that, through the QA process,- all quality technical and administrative activities ano requirements important to safety had been effectively implemented-prior to the issuance of the construction permit (CP). The regional inspection program during this phase as well as the later stages of construction inspection includeo the implementation of the Vendor Inspection-Program which covered the Architect Engineer, NSSS vendor, and organizations contracted by the applicant to perform design, manufacturino i or other site-related activities. The regior ascertained whether the applicant 3 had been instituting effective control and oversight over such contractor activities. After a limited work authorization (LWA) has been issued, the l 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 anti 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 corresponcing NRC staff Final Environmental Statement (FES) were necessitated by the passage of the National Environmental Policy Act (NEPA) in 1969 and the court's interpretation of this legislation in the 1971 Calvert Cliffs decision.

.c. i Khen a construction permit application was been submitted, it was first sut,jected to an acceptance review by the NRC staff to determine whether it contained sufficient infomation for conducting a detailed review. The results cf 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 1 construction permit applications. The Act requires the Attorney General to advise the Commission 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 uttached to the license. The puolic has been offered the opportunity to request an antitrust hearing. Hearings have beer. 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 connitments. 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 esaluation. 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 characteristics of the site including seismology, geology, hydrology, and meteorology. Pr: posed 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.

.. + f. Design of proposeo systems for control of radiological effluents. 1 .The staff traditionally called upon the U.S. Geological Survey (USGS) for excertise in the areas of geology and seismology. This relationship was initially established to help the small NRC geosciences staff with its heavy -l workloco. 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, and financial information have been adequately documented in the application, a Safety Evaluation Report (SER) was prepared. The Aavisory 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 these cases where the plant design was essentially the same as a previously reviewed plant (e.g., a seccnd unit), the subcomittee review was not begun. until the staff had nearly completed its detailed review of all the safety-i .relatea features of the plant. Where new or modified concepts or special site considerations were involved, the ACRS began its formal review earlier in the process. hortally, before the full ACRS has considered a project, the staff had completed its SER. The SER and the report of the ACRS subcomittee have formed- ^ the basis for Comittee consideration of a project. When the 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 th'e 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 y proposed plant. This review was also perfomed to provide comparisons between the benefits to be derived and the possible risk to 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 pertained to the impact of siting decisions on endangered species and unique fish and wildlife ecosystems. The environmental review has frequently resulted in the-imposition of specific conditions on the siting design in order to satisfy the NEPA. After completion of this review, a Draft Environmental Statement (DES), containing conclusions on environmental matters, has been issued. Each DES was circulated for review and coments 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 reouires that a public hearing be held before a construction pemit is issueo for a nuclear power plant. Soon after an appli-cation has been docketed, the NRC issued a notice of the hearing. The hearing

for each case was held after completion of.the'NF.C staff. review. Opportunity was afferced for members of the public to participate in the hearing. The public hearing was :onducted by a three-metroer Atomic' Safety and Licensing Board. The SER and its supplements, the FES, and staff testimony to-address contentions constituted the staff's primary evidence at the hearing. Depending upon the case, either a combined or separate tafety 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-Cornission. 1 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 permit. This authorization is known as a Limited Work Author-- ization(LWA). The resulations provide for the authorization of two types of LWAs. The first type (LWA-1) may author'.ze site preparation work, installation of temporary construction support facilities, excavation, construction of service facilities, anc! certain other construction not subject to the quality assurance requirements. The secona tyre (LWA-2) may authorize the installation of structural foundations. The first type of LWA ruay be granted only after the licensing board has made all of the NEPA findings required by the Connission'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-i reactor of the general size and type proposed from a radiological health and safety standpoint. Thc.second type may be granted if, in addition to the findings described abose, the hearing board determines that there are no unresolved safety issues relating to the installation of structural founcations. Upon completion of the hearing 1.nd receipt of favorable findings from the Hearing Boards, complet' ion of tae staff's safety, environmental, and antitrust l reviews, and receipt of satisfactory input from the Region on the inspection program, a construction permit has been issued by.the Skutor of NRR. When.the construction o the nuclear plant progressed to the point where final d design information and plans for operation were ready, the applicant submitted the Final. Safety Analysis Report and an updated Environmental Report in support of an application for an operating license (OL). The FSAR set forth the pertinent safety aspect 3 of the final design of the facility. The FSAR also provided plans for operatinn and procedures for coping with emergencies. The staff's conclusions on tae utility's offsite emergency plans have been based upon the findings of thc. c deral Emergency Management Agency (FEMA). FEMA e reviews the utility's pb as to determine whether State and local emergency-l plans are adequate and wtether there is reasonable assurance that they can be implementeo. j Considerably more NRC res wrces have been expended at the OL stage than at the majorityoftheconstructi{thefactthatthereviewofthefinaldesignandthe CP stage. This is due tc on inspection takes place during the OL stage. Unless there has been significant new information, however, most of the review effort for the site charac; eristics, environmental impact, and antitrust areas i have been expended during ghe CP stage since these matters must be agreed upon l

s* ,+ for licensing to proceed. At the conclusion of the reviews the staff again-prepared a SER.anc a FES and, as during the construction permit stage, the ACRS made an independent evaluation and presented its advice to the Comission. The Construction Inspection Phase continued through the OL review process cnd was not terminated until the OL was issued. These inspection activities were accomplisSec cniefly by examining and observing infield work perfomance 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 j inspe:tions and were normally conducted about 18 months prior to projected OL i s s ut.nce. Fourteen CATS have been completed and primarily focused on hardware installation and cuality of construction. At selectec construction sites, aoaitional team inspections / evaluations were performec, as needed. These included the Integratea Design Inspection (IDI) and the Indepencent Design Verification Program (IDVP). Like the CAT, the IDI program was conducted by NRC headquarters (old OIE). IDIs 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 nomally compliedwithapplicableregulationsandlicense[rethattheplanthadfully independent, thirc-party audits that helped ensu consnitments. 1 The latter stages of constru: tion, and completion of primary piping, electrical cabling, and instrumentatica have marked the winding down of the construction process and the start of tne 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 program 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, t 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. Construction tests of a system or component are performed under the direction of construction management for turnover to the operations staff for preoperation61 testing. Preoperational tests demonstrate proper functioning ^ and confomance of components, systems and structures to the design requirements. The primary objective of the startup testing phase (STP) inspection activity 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,

q l 1 the radwaste systems startup, and the events reporting system.. This verifica-tion was achieveo through direct observation, witnessing tests, reviewing i prececures and records, reviewing test data, and evaluating tests results. ] The Region has. accomplished the STP inspection objective by ensuring that the licensee had developed tests for systems and' components important1to safety n d. that tests cenducted under transient and operating conditions demonstrate 1 satisf6ction of the design requirements as specified in the FSAR. This phase of the inspection program became effective approximately 6 months before issuance of the operating license and continued approximately 1 month after the facility completed the full-power testing program. A public hearing is 'not mandatory with respect to an operating license applica-tion, but any person whose interest might be-affected by the proceeding may petition the NRC for a hearing. If a public hearing was held. the decision. process was generally the same as that described for the construction pemit henring. Findings made by a licensing board are subject to discretionary Comission review. In the past'if no hearing was requested, findings could be made-by the Director of Nuclear Reactor Regulation and an operating license could be issued. In recent years the practice has been that the Director, NRR, would issue an operating license restricted to 5% power. However, regardless of whether a hearing has been held, the Comission reviewed-the license and gave its approval before the full-power licence 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 environment. L l L I l ^v L 1. L L13 l!

m y 4 p, =_y-a f. 1 n. o ( ,) i1 r :.,. : t t.- J

en

- 1,

=- g; u a f., ) 3 n. yn E '. e e (- 4 m n> 8 ? f).

)

4 ..t Er. g j. 3 ,7.. t x j 1 I i-

1

.!'2i g t -l ). APPENDIX C y .I r f l, R h -l 1 4 E-

i l

L) i a .cs Q a b r ,k J t J ~! i 1 ~i e i 4 +,. t \\1 1 I I t1 'I t I w u uw % 4 a a -,~ - x

APPENDIX C: BREAKC)WN OF RESOURCE NEEDS Inclucec herein is additional information supporting the resource projections-- presented in Chapter III.projectlon for each case analyzed; (2) provided on: (1) annual resource Details are e the distribution of base case licensing resource needs by major technicai area; (3).the licensing review disciplines;- and (4) the distribution of base case it,spection resources by major inspection area.- Although the specific values depend on a number.of detailed assumptions, the overall estimates and the general distribution reasonably encompass a wice range of assumptions concerning-details of the review process. Annual Resource Projections The following tables summarize the FTEs projected by year for each licensing case analp ea in the_ report. Table C.1-Base Case

• Technical Year Licensinc Inspection Assistance 1

5.3 0.1 1.7 2 5.2 0.1 1.7 3 3.1 0.1 1.7 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 S: 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 Mye 65

/

,J.

.,r. ,'o

, g i

Table C.2 Custom Plant Total Technical-Resources Yeas Licensing Inspection OGC Assistance-Required i E.4 0.1 1.6 1.7 9.8 2 'C.3 0.1 2.1-1.7 10.2 3 5.6 1.6 2.5 3.7 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 i 7 2.0 4.2 1.1 0.4 7.7 8 0.7 4.2 2.5 0.1 7.5. 9 E.5 4.2 2.0 1.6 16.3 10 E.: 4.2 2.8-1.5 16.7 11 7. 5-C.2 2.8 5.0 23.9 12 E.3 8.2 2.3 5.1 23.9 12' 1.5 < 4.6 0.8 0.3 7.2 Total SE.: 52.2 25.3 21.2 155.0 Table C.3 Reactivated Plants With an ASLB Decision 1 Total Technical Resources 3 Year Licensing Inspection OGC Assistance Required-i 1-1,5 5.7 1,3 -1.0 9.5 l 2 2.0 4.2 1.5 0.0 7.7 3 2.0 4.2 1.5 0.0 7.7 i 4 4.3 8.2 1.3 4.0 17.0 t 5 4.3 8.2 1.8 4.0 18.3 6 1.5 4.6 1.3 0.0 7.4 Total 15.6 35.1 9.5* 9.0 69.2*

• Includes 0.8 FTE in year 7 for appeal process.

W-t~ \\

fe Table C.4 Reactivated Plants Without an ASLB Decision Total Technical Resources Year Licensing Inspection OG.C, Assistance Reevired 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*

• !ncluces 1.2 FTE in year 6 for appeal process.

Table C.5 Standaro Plant Total Technical Resources Year Licensing 'nspection OGC Assistance Reovired 1 5.0 0.1 1.1 2.0 8.2 2 5.0 0.1 1.1 2.0 8.2 3 5.0 0.1 1.8 2.0 8.9 4 7.0 1.0 2.8 0.5 11.3 E 7.0 1.0 2.8 0.5 11.3 6 1.5 5.9 1.5 0.7 9.6 I 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.n 51.6 18.4 12.6 125.6 i 849 59 4 g e-4 h ( [ I )i ) t i

i Musumu C

• ?

L'istributien by Major Technical Area and Complete Listino of Disciplines An e:::, mate has been made of the base case distribution of resources expended by review discipiine during the CP and OL stages. One plant regarded as representative cf licensing resource expenditure was chosen for cetailed analysis. RITS hourly data was tabulated by reviewer from the CP acceptance 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 originally divioed into 43 review disciplines, but was subsequently grouped into ten technical areas. The distribution of resources is shown in Table C.6 The complete listing of disciplines is shown in Table C.7. Table C.6 Base Case Licensing Resource Distribution by Major Technical Area CP Phare OL Phase i NE NE Site Safety 14 1.9 11.6 3.5 Site Envir. 7.3 1.0 5 1.5 Radiolog. Eng. 11.8 1.6 10 3.0 System Eng. 14 1.9 33.7 10.2 Financial A.nal. 11 1.5 2.6 0.8 Safeguards 0 0 1.7 0.5 Emerg. Prep. 0 0 1.! 0.5 Proj. Mget. 33.8 4.6 19.2 5.8 Human Factors 0.7 0.1 2.3 0.7 Engrg. & QA 7.4 1.0 12.2 3.7 100.0 13.6 100.0 30.2 p,_ I 4 g .?.a'k[ h 64 j

a' (~ Table C.7 ) l L Licensino Review Disciplines SITE SAFETY SITE ENVIRONMENTAL Meteorciogy Aquat'c Science ~ Hydrology Land Use Analysis i Geology Terrestrial Biology Seismology Marine Biology l Geotechnical Engineering Oceanography Site Analysis Limnology l Environmental Engineering RADIOLOGICAL ENGINEERING Occupational health Phyiics ENGINEERING & QUALITY ASSURANCE Environnental Health Physics Mechanical Engineering Nuclear Waste Fire Protection Accicent Ev61uation Chemical Engineering Structural Engineeri,ig SYSTEMS ENGINEERING Materials Engineering Reactor Systen.s Metallurgy Auxiliary Systert.s Non-Destructive Examination Containment Systems Quality Assurance Probatilistic Risk Assessment 1 Nuclear Engineering HUMAN FACTORS Nuclear Physics Human Factors Engineering ~ Technical Specifications Power Systems EMERGENCY PREPAREDNESS Instrurrentation Emergency Preparedness Analysis Environmental. Qualification i PROJECT MANAGEMENT (PM) 1 FINAhC:AL ANALYSIS Licensing PM Antitrust Environmental PM l Financial Ocalification ~ Regional & Environmental Economics l SAFEGUAkDS/ SECURITY Safeguards crio Security Analysis l' e 7 2 cg 1 3: j

v M stribution of Base Case Inspection Resources lhe following table sumarizes FTEs projected by the budget ecdel of the fo r 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 Base Case Ins wetion Resources Distribution by.4a.1or Inspection Area PRE-CP CIP PTOR STARTUP-PHASE PHASE PHASE PHASE FTE FTE I FTE Engineering 100 .5 47 2.00 42 2.35 . 32 1.45 Sr. Reticent 0 0 24 1.00 18 1.00 22 1.00 Resident 0 0 24 1.00 18 1.00 22 1.00 Project Mgmt. 0 0 5 0.21 6 0.34 7 _0.32 Rad. Safety 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 i it ' i 1 s p. I Q.. l ) I w;..a;# y 3 gig.s 4 q,, gjj,g.j@ 4;, l 3 ,c,

a

[_}}