ML20071L665
Text
. - -
Ue 3#N UNITED STATES
[
/
A.
NUCLEAR REGULATORY COMMISSION ffASHINSTON, D.C. 20885 g
,f March 2, 1900 OFFICE OF THE COMMISSIONER 6
MEMORANDUM FOR:
James M. Taylor Executive Direct r for Operations
-l James R. Curtiss k4gh.
FROM:
SUBJECT:
QUESTIONS CONCER)$1tG' DRAFT SECY PAPER --
" EVOLUTIONARY AND PASSIVE ADVANCED LIGHT WATER REACTOR RESOURCES AND SCHEDULES" I
e I have reviewed the staff's draft SECY paper, " Evolutionary and.
Passive Advanced Light Water Reactor Resources and' Schedules"J.in whicn the staff'has set forth its analysis of'the resource and schedular impacts associated with the review of the evolutionary The and passive advanced light water reactor standard plants.
very clear impression that one is left with after rpading this paper is that recent directives from the Commission have led to significant delays in the schedules for the individual design reviews, as well as for the evolutionary and passive _ requirements documents.
In order for me to evaluate this ~ matter in more detail, I have a number of questions (attached) that I would ask the staff to respond to.
I intend to pursue this matter at the Commission briefing on this subject, currently scheduled for April 3, 1990.
Accordingly, I would ask that the responses to the questions be submitted one week prior to that meeting, so that I might review the responses in preparation for the Commission briefing.
cc:
Chairman Carr Commissioner Roberts Commissioner Rogers Commissioner Remick SECY OGC See Staff Requirements Memoranda dated July 31, 1989, 1
August 24, 1989, September 12, 1989, and December 1S, 1989 (2).
9400030213 940629 PDR ColftS NRCC CDRRESPONDENCE..PDR
QUESTIONS FROM COMMISSIONER CURTISS
- EVOLUTIONARY AND PASSIVE ADVANCED LIGHT WATER REACTOR RESOURCES AND SCHEDULES Licensing Review Basis Schedule 1.
Please describe the process that the staff went through in preparing the Licensing Review Basis (LRB) for the GE Advanced Boiling Water Reactor.- When was the concept first discussed?
How long did it take from the time that discussions first began on the GE's submittal to formal submittal by GE of' a proposed LRB?. How much time was devoted by the staff to review of GE's proposed LRB?
Was the ACRS consulted prior to approval of the :LRB7 If so, what was the process and-how much time was involved?
Was the Commission consulted prior to_ approval of the LRB?
If so, what was the process and how much time was involved?
i 2.
Please identify the milestones and project the schedule that the staff would follow in reviewing an applicant's LRB, assuming that the directives contained in recent Commission Staff Requirements Memoranda on this subject did not apply.
3.
What recommendations, if eny, does the staff have for_how the Commission might streamline the process for reviewing i
and approving LRBs, in a manner consistent with the Commission objectives that are reflected in the various staff requirements memoranda?
Design Certification Schedule 4.
Please identify the milestones and project the schedule that the staff would follow in reviewing a. design certification application, assuming that the directives contained in recent Commission Staff Requirements Memoranda on this subject did not apply.
5.
What recommendations, if any, does the staff have for how the Commission might streamline the design certification process, in a manner consistent with the Commission objectives that are reflected in the various staff requirements _ memoranda?
General Electric Advanced Boiling Water Reactor Schedule 6.
The staff's proposed schedule calls for the preparation of modules two, three, and four sequentially, rather than concurrently, with one month for commission review allotted upon the completion of each module.
Are the issues that are addressed in these individual modules such that work on the
2 i
j modules must proceed sequentially or could the modules be prepared concurrently?
If there is nothing about these 4
j modules that requires them to be prepared sequentially, what i
~
is on the " critical path" -- is it resources or are we waiting for information from the applicant?
Please identify 1
those issues where we are waiting on the applicant for j
information.
In addition, if work on the modules can l
]
proceed concurrently, please identify the resources that would be necessary to proceed in this manner and the resulting schedule.
7.
Please identify the milestones and project the schedule that the staff would follow for the ABWR, assuming that the j
directives contained in recent Commission Staff Requirements Memoranda on this subject did not apply.
4 8.
What recommendations, if any, does the staff have for how j
the Commission might streamline the process for review and' j
approval of the GE ABWR, in a manner consistent with the j
Commission objectives that are reflected in the various staff requirements memoranda?
i b
l 1
Combustion Engineering System 80+ Schedule 5
9.
In projecting the schedule for the CE System 80+,
is the l
staff assuming the same " module-by-module" approach, with i
sequential consideration of modules, as that assumed for the j
GE ABWR7 If so, is there any reason why these modules could not be pursued concurrently, along the lines _ suggested in question #6, above?
i
\\
10.
What is currently on the " critical path" at this point for l
review of the CE System 80+ -- submittals from the j
applicant, staff review / resources, or the commission review i
process?
i 11.
Please identify the milestones and project the schedule that 4
the staff would follow for the CE System 80+, assuming that the directives contained in recent Commission Staff j
Requiraments Memoranda on this subject did not apply.
j 12.
What recommendations, if any, does the staff have for how tha Commission might streamline the process for review and approval of the CE System 80+, in a manner consistent with a
j the Commission objectives that are reflected in the various j
staff requirements memoranda?
For example, could the staff:
(a) Improve coordination with the ACRS, so that the time for ACRS review and comment is reduced to one j
month, along the lines of the schedule set forth for j
the EPRI requirements document?
l (b) Begin work on those portions of the design
.~ __
3
)
certification review (see Table III-2, step 1) that are i
not addressed in,,or are otherwise unaffected by, the LRB, prior to issuance of a final LRB7 (c) Conduct the activities identified under steps 2 and 3 of Table III-2 in parallel with step 1, so as to minimize the schedular impact of these activities?
In each case, clease identify the resources that would be necessary to achieve these efficiencies, if the matter is resource-sensitive.
EPRI Requirements Documents Schedule Evolutionary and Passive 13.
Please identify the milestones and project the schedule that the staff would follow for the EPRI Requirements Documents, assuming that the directives contained in recent commission Staff Requirements Memoranda on this subject did not apply.
14.
What recommendations, if any, does the staff have for how
.the commission might streamline the process for review and approval of the EPRI Requirements Documents, in a manner consistent with the Commission objectives that are reflected in the various staff requirements memoranda?
For example, could the staff begin review of EPRI's submittals on the Passive Requirements Document as individual chapters are submitted, along the lines of what was done for the Evolutionary Requirements Document, rather than waiting for a complete submittal from EPRI?
i j.
}
I i
i t
i i
February 26, 1990 i
For:
The Commissioners I
From:
James M. Taylor j
Executive Director for Operations
)
Subject:
EVOLUTIONARY AND PASSIVE ADVANCED LIGHT WATER REACTOR-RESOURCES AND SCHEDULES 4
]
Purpose:
To inform the Commission of the resource and. schedular impacts
)
i associated with the review of the evolutionary and passive 1
advanced light water reactor (ALWR) standard plants, and to j
identify the consistency of the staff review schedules for i
l the Westinghouse (W) AP-600 and General Electric (GE) SBWR i
j designs with the Department of Energy (D0E) program schedules.
i
Background:
In the staff requirements memorandum (SRM) pertaining to l
i SECY-89-334, dated December 15, 1989, the staff was directed to
]
submit to the Commission a projection of the resources necessary to adhere to the schedules proposed in SECY 89-334 as modified i
j in the subject SRM.. In addition, the Conslission instructed i
the staff to confirm with DOE that the proposed review schedules for the W AP-600 and GE SBWR designs are consistent with the i
program that DOE plans for these designs, and advise the Commission if the NRC and DOE schedules are incompatible.
]
Discussion:
In developing the schedules presented in SECY-89-334, the staff assumed that the approach it was utilizing in reviewing i
the evolutionary advanced light water reactors (ALWRs) and the EPRI Requirements Document would continue for the remaining i
evolutionary reviews and would also be applied to the passive light-waterreactor(LWR)plantreviews. The process was outlined in SECY-89-311.
I i
In two staff requirements memoranda (SRMs), dated December 15, j
1989, concerning SECY 89-311 and SECY 89-334, the Cosmiission provided guidance to the staff which detailed the process
,j that was to be followed in proceeding with the aforementioned j
reviews. To ensure that resource requirements and schedular impacts, if any, were appropriately assessed, and that the 1
Consiission guidance would be implemented properly, the staff i
i i
Contact:
j C.L. Miller, NRR/DRSP 2-1118 i
l i
i l
4 l
I' i
5 The Commissioners -
l i
i
]
l examined the relationship between the two SRMs. This was l
particularly necessary to ensure that the Comission's i
i detailed instructions would be followed in completing the j
i ongoing reviews of the EPRI Requirements Document and I
i evolutionary ALWR design certification applications, and would
}
be applied to future applications for standard plant design i
certifications. As directed by the Comission, the major.
i factors that have been added to the review process are:
4 (1) the Commission's formal review and approval of individual
}
Licensing Review Bases (LRB) documents, (2) the resolution of i
the policy issues and receipt of Comission guidance by the j
= staff before it prepares draft safety evaluation-reports i
i (SERs), (3) submission of all draft and final SERs to the Comission for information well ahead of issuance, and i
(4; completion of the EPRI Requirements Document Safety Evaluation for passive plants before submitting LRB documents to the Advisory Comittee on Reactor Safeguards (ACRS) for i
i review. The examination culminated in the development of two i
logic charts. The first is presented in Enclosure I and i
illustrates the path that must be followed in the review and j
approval of an application for design certification under 10
[
CFR Part 52. The second chart appears in Enclosure II and details the process that must be followed to complete the EPRI i
Requirements Document review for both evolutionary and passive i
ALWRs.
j Using these logic charts, the staff pursued the development of schedules and resources needed for the various reviews.
The staff concluded that because the processes are so complex, large uncertainties make it extremely difficult to develop '
i i
fixed schedules.
In order to develop a reasonable estimate l
of the schedules associated with these processes, the staff developed the following approach which utilizes two different assumptions:
j (1) Lower time estimates (designated as Case 1) were-developed assuming.that the whole process proceeded smoothly and that there would be no iterations needed to gain Comission approval at those points at which Comission involvement would be required.
1 (2) Recognizing that the approach identified in-assumption 1 (above) was extremely optimistic, the staff developed a second set of time estimates i
(designated as Case 2) by assuming that there is i
one iteration at each of the points in the process 1
at which Comi::sion approval is needed. This should l
not be construed as an upper bound on the time estimates, but is presented to illustrate the potential impact on schedules that could realistically t
j occur.
4 4
i e
i l
The Commissioners
~ l The schedule ranges are presented in a set of tables included as Enclosure-III, and have been prepared by tracking through the logic charts provided in Enclosures I and II. Table III-1 i
4 (of Enclosure III) details a timetable for the receipt, review,-
j and approval of an LRB document that would precede the formal
- view of the design certification application.. It shows that 19 months would be needed to complete this activity if the process proceeded smoothly (Case 1) and would 'need an additional 3 months to complete the scenario postulated in Case 2.
1 Table III-2 contains a similar timetable for the design i
certification review through the issuance of a Final Design.
j Approval (FDA) and' totals 28.5 and 34.5 months for Cases 1 i
and 2, respectively..By summing the total elapsed time in j
these tables, it can be seen that it would take 47.5 months j
for Case 1 and 56.5 months for, Case 2 from the time the i
discussions pertaining to the LRB document are initiated i
until an FDA is issued. The difference between the two cases i
is almost one additional year.
i i
This approach was then applied to the. ongoing reviews of the two evolutionary ALWR applications for design certification, the GE Advanced Boiling Water Reactor (A8WR) and the Combustion i
Engineering (CE) System 80+.
The results.for the ABWR are j
given in Table III-3 which indicates a schedule slip of 6.5 months for Case 1 and 11.5_ months for Case 2 from the proposed l
FDA date of December 1990 presented in SECY 89-334.
l It should be noted that Case 1 and Case 2 estimates given throughout this paper assume a relatively optimistic schedule i
for ACRS review activities identified in Tables III-1 and III-2.
For example, one month each is. assumed to be requireil for the conduct of ACRS meetings and issuance of subsequent j
ACRS letter reports. Since the procedures for approving an j
LRB document and an FDA contain several ACRS review milestones, i
any additional time required for these activities could be i
significant and would further impact the estimates presented i
in this paper.
l Table III-4 shows the results of applying the timetables 1
j presented in Tables III-1 and III-2 of Enclosure III to the CE System 80+ review. The results indicate a schedule slip i
of 20 months for Case 1 and 29 months for Case 2 to the
]
December 1991 date targeted by the Commission in the SRM j
pertaining to SECY 89-334.
j The projected schedule ranges for the completion of the EPRI Requirements Document for evolutionary and passive ALWRs are J
shown in Tables III-5 and III-6, respectively. These' tables were created using the logic that is shown in Enclosure II, 3
I l
.~
I i
j The Commissioners - !
l and indicate that the SER schedule for the evolutionary plant l
requirements will slip two months for Case 1 and eight months i
for Case 2 from the March 1991 date proposed in SECY 89-334.
i j
The passive plant requirements SER will meet the February 1992 projected date for Case 1 and will be 6 months late for Case 2.
As instructed by the Commission, the staff contacted DOE to confirm the dates for their pmgram for the AP-600 and SBWR j
and to assess the compatibility of those dates to the NRC i
1 review schedules.
It was determined that DOE plans call for l
the LRB documents to be submitted to NRC in June 1990 for the AP-600 and December 1990 for the SBWR. DOE desires NRC l
approval within six months of receipt of the LRB documents.
1 Given the Connission guidance that the staff should not
)
proceed to take the LRB documents for the passive plants to the ACRS before completing the EPRI Requirements Document j
review for passive plants, and using the timetable presented in Table III-1, it can be seen that it would be impossible to j
meet DOE's schedule.
i i
i Rather, the range of dates to complete this action for both i
the AP-600 and SBWR are projected to be December 1992 for Case 1, using February 1992 as the completion date for EPRI, j
and September 1993 for Case 2, using August 1992 as the completion date for EPRI. DOE projections indicate that the Standard Safety Analysis Reports for the AP-600 and SBWR will j
be submitted to NRC in July 1992 and October 1992, respectively.
J DOE projects FDA dates of January 1994 for the AP-600 and
?
October 1994 for the SBWR, Using the timetables illustrated i
in Table III-2, the projected dates for FDAs (both AP-600 and j
SBWR) for Case I would be May 1995 and for Case 2 the projected date would be July 1996.
i Table III-7 susmarizes the schedule range for all standard i
plant projects discussed above.
Final design certification
(
rulemaking dates are projected by adding 18 months to the date of the FDA.
It should be noted that the schedule estimates presented in Tables III-3 through III-6 and I
susmarized in Table III-7 for the various reviews of evolutionary and passive plants and for the review of the EPRI Requirements Document assume a relatively near-term Commission decision on the staff's recommendations for the j
issues presented in SECY 90-016.
Significant delay in the i
resolution of these issues would further impact these i
schedule estimates.
From the discussion presented above, it is evident that j
resource impact is not the primary factor in determining schedules for the standard plar.t reviews. Rather, the 4
process that has been identified herein will, to a large degree, be controlling. The resources projected for FY.1991 in the current NRC budget prcposal (29.3 FTE direct) appear j
to be adequate to allow the process that has been directed by i
_~
l A
The Commissioners the Commission to proceed for each of the standard plant reviews. Adding resources at this time would not result in a significantly shorter schedule.
lig /~
mes M. Ta or i
xecutive Director for Operations i
i l
)
i 1
l
Enclosure I i
DESIGN CERTIFlCATION (AND T A
Tx 6
v EPRI APPLICANT DSER s
ma REQ'TS DESIGN
-> oje c=-mgwrs '
c,*"h*= g ISSUED p
n l
FOR DC w/stArF POsmON pay y I
V V V
y ErErs T o "o ACRS
'$ak Ss neou DRAFT SER V V V
susM Trco To 0
O NN "M'8 'N V
V
[
POLICY NO > DRAFT SER APPLICANT LRB SUBMITTED SSUE goes oern V
s STAFF LRB REVIEW
^
> PREPARED 4
v v
o STAFF COMMENT. RECOMMENDATION V V s
COMMISSION SER TO
,l, l
COMMISSION v
FOR INFORMATION DRAFT RULE ACRS COMMISSION ISSUED BY V
lSER ISSUEDI COMMISSION ute I
V U
issuco O
A l
FDA l
-> sTw m er V
FINAL RULE
_y g
ISSUED BY
(
PUBUC COMMENT i
a V
I COMMISSION DC HEARINGS ACRS NO
Enclosure II EPRI R EQ U I R EM ENTS R EVI EW i
1 EPRI REQ UIREM ENTS FOR EVO LUTIO NARY AND PASSIVE PLANTS STAFF STAFF REVIEW POLICY REVIEW
> ISSUES EVOLUTIONARY PASSIVE AA i
Vl V
! ACRS k M
l onAPT sER PASSIVE Evot UTIONARY A
A D
T: _ _
> T: =L i
4 M ACRS k
v v
v DSER TO DSER DSER DSER TO COMMISSION -> ISSUED ISSU RESO M ON
(~ ISSUED
<- COMMISSIONu I
> ACRS b*
y I
FINAL SER NEW \\
SER I
PREPARATION POUCY E
" ' ' ' ~ ~ - -
COMMISSION BY STAFF SSUES INNR MDON
> ISSUED
\\
^
A no no 1
-s
~.. -...
i Enclosure III SCHEDULE RANGES i
l l
l
i Table III - 1 License _ Review Basis Review Schedule Ranges Step / Milestone Time (months)
Case 1 Case 2 1.
Discuss submittal with applicant /to LRB submittal 3}
3 2.
Review LRB submittal and prepare consnents and recommendations 6:
6 for ACRS/ Commission 3.
ACRS meeting 1,
1 4.
ACRS coments to Comission i
1 5.
Commission guidance to staff 2 --
2 6.
Final LRB prepared and provided to ACRS/ Commission 3-3 7.
'ACRS meeting 1
1 8.
ACRS comments to Commission 1
1 9.
Comission approval and LRB issued 1*
4**
Total =
19 )
22 s
- Assumes no iterations to gain Comission approval.
- Assumes one iteration to gain Comission approval.
4 Table III - 2 Staff Review of a Design Certification Application Step / Milestone Time (months)
Case _1 Case 2 1.
Staff review of Safety Analysis Report 15 15 2.
New policy issues *
- develop Commission paper 1
1
- staff meets with ACRS 1
1
- ACRS provides comments to Commission 1
1
- Commission provides guidance to staff 1
4**
3.
Prepare DSER and send to Commission 3
3 4.
DSER issued 0.5 0.5 5.
Open issue resolution / final SER prepared and sent to 3
3 ACRS/ Commission 5.
Staff meets with ACRS 1
1 7.
ACRS letter to Commission 1
3 8.
SER issued 1
2 Total =
28.5 34.5 j
- Assume two Commission papers will be written, but only one paper impacts overall schedules.
- Assumes one iteration to gain Commission approval of policy issues.
v
~
t' Table III - 3 Advanced Boiling Water Reactor Review Dates
, Step / Milestone Case 1 Case 2 1.
Start at staff review /DSER area of chart
/
\\
Cc
. re v-w 2.
Second module prepared and sent to Comission 4/90 7/90 g m'
}
3.
Second module issued
< 5/90 8/90 4
Cu. re J+
1/91 g
ro.
4.
Third module prepared and sent to Commission 10/90 2/91>
5.
Third module issued 11/90 6.
Fourth module prepared and sent to Cor.nission 12/90 3/91 7.
Fourth module issued 1/91.
4/91 8.
Integrate (final open issue resolution and ACRS comments 4/91-7/91 from earlier letters) and prepare final SER
~
9.
ACRS meeting 5/91 8/91
/91 11/9)#
6
- 10. ACRS letter
- 11. SER to Commission 7/91 -
12/91 Cm, RCw g
g,
- 12. SER/FDA issued 7/91 12/91 Total slip in schedule (months)=
6.5-11.5
- Assumes there will be-no new policy issues, staff recomendations in SECY-90-016 are endorsed by the Comission and three additional DSER modules will be issued similar to those specified in LRB.
- Assumes one additional iteration to gain Comission approval of policy issues.
..--_u 2.,.
2., _..
Table III - 4 Combustjon, Engineering System 80+ Review Step /Mllestone Dates Case 1 Case 2 1.
LRB review continues 3/90*
3/90*
2.
LRB 1ssued 4/91**
7/91**y
- J 3.
SER/FDA issued 8/93 5/94 Total slip in schedule (months)=
20 29 Pki Ob l
g3 C# ' '
g#^
v" s
9!
,eff (b
- Staff is three months into step two of Table III-1.
- Follows logic in Table III-1.
- Follows logic in Table III-2.
t i
i Table III - 5 EPRI Evolu_tionary Requirements Review Step / Milestone Dates Case 1 Case 2 1.
DSER on Chapter 5 issued 2/90 2/90 2.
Review Chapters 6-13, Appendices 6/90 6/90 3.
Remaining Policy issues identified for ACRS/Comission 7/90 7/90 4.
ACRS meeting 8/90 8/90 5.
Comission guidance 9/90 12/90 6.
DSER prepared and sent to ACRS/Comission 10/90 1/91 7.
DSER issued 10/90 1/91 8.
Open Issue Resolution 1/91 4/91.
9.
Prepare final SER and send to ACRS/Comission 2/91 5/91
- 10. ACRS meeting 3/91 6/91
- 11. Comission feedback 4/91 10/91 i
12.
Issue SER 5/91 11/91 Total slip in schedule (months)=
2 8
i Assumes one iteration to gain Comission approval.
.i L
i i
6 Table III - 6 EPRI Passive _ Requirements Document Review Step / Milestone Dates Case 1 Case 2 1.
Review begins upon receipt of complete submittal 8/90 8/90 2.
Policy issues identified for ACRS/ Commission 4/91*
4/91*
3.
ACRS meeting 5/91 5/91 4.
Cossnission guidance 6/91 9/91 5.
DSER prepared and sent to ACRS/ Commission 7/91 10/91 6.
DSER issued 7/91 10/91 7.
Open Issue Resolution 10/91 1/92 8.
Final SER prepared and sent to ACRS/Comunission 11/91 2/92 9.
ACRS meeting 12/91 3/92
- 10. Comunission feedback 1/92 7/92 11.
Issue SER 2/92 8/92 i
s Total slip in schedule (months)=
0 6
- Includes staff requests for additional information and EPRI responses.
I f Assumes one iteration to gain Commission approval.
i
i e
TABLE III-7 _- _ SCHEDULE RANGE
SUMMARY
PROJECT SER/FDA DESIGN CERTIFICATION RULEMAKING COMPLETE j
D PREVIOUS TARGET CASE 1 CASE 2 CASE 1 CASE 2 ABWR 12/90 7/91 12/91 3['It 1/93 6/93 SYSTEM 80+
12/91 8/93 5/94 3[13 2/95 11/95 EPRI EVOLUTIONARY 3/91 5/91*
11/91*
EPRI PASSIVE 2/92 2/92 8/92 AP-600 12/93 5/95 7/96 11/96 1/98 SBWR 9/94 5/95 7/96 11/96 1/98 i
t
- SER Only
i
~
e i
\\
i
...I believe that if the staff has fully explored the resource and schedules issues in preparing the subject proposed SECY paper, the staff should be able to answer the following questions with minimal l
effort and within the requested timeframe.
1.
What would staff's current projection be for issuance of the y FDA provided that the' Commission review of draft SER modules was eliminated?
2.
- What, if anything, constrains conducting the reviews and, /
i preparation of SERs for the second, third, and fourth modules V in parallel?
3.
Assuming that the Commission review of draft SERs was expedite the review and SER preparation such that the final' /
eliminated, what additional resources would be required to SER would be issued in September 1990?
l 4.
Has any direct knowledge of the staff concerning the amount of work left to be completed by the applicant for ensuring an i
" essentially complete design" and development of inspection, t
test and acceptance criteria, been factored into the staff's l
schedular projections?
If not, does the staff have an i
I adequate basis to believe that the applicant can support the previously projected schedule which called for issuance of an FDA in December 1990? If not, does the staff have an adequate basis to believe that the applicant can support either the i
case 1.
or case 2.
schedules provided in Table III-3?
5.
What guidance is currently available to the staff for l
Verifying the completeness of design and the adequacy of inspection, test and acceptance criteria?
If such guidance i
is not yet complete or does not yet exist, when does the staff expect it to be completed?
CE System 80+
1.
How long has staff been engaged in the activities covered by steps 1.
and 2.
of Table III-1 for the CE 80+?
Is this consistent with the projected timeframes for steps 1.
and 2.
in Table III-l?
If not, why not?
What would the staff's current projection be for issuance of y 2.
the final LRB provided that ACRS and Commission reviews and Commission approval were eliminated?
3.
What options exist to shorten the time necessary for staff 4
reviews of the LRB submittals and preparation of the final LRB Y following reciept of Commission and ACRS input?
l
i l
i 4.
What options are available to better coordinate with the ACRS such that the time for ACRS review and comment (steps 3.&4.
and 7.&8.
of Table III-1) is shortened to 1 month, as is V
l apparently the case for the EPRI Requirements Document Reviews j
(e.g. better coordinating with Acns meeting schedules, ongoing dialogue with the ACRS, and expedited review and report I
j preparation _by the ACRS)?
5.
What precludes the staff from embarking on portions of the i
design certification review identified as step 1.
in Table III-2 which are either not addressed in or are otherwise o unaffected by the LRB, prior to issuance of a final LRB?
Whatoptionsareavailableforshorteningthetimeframeforf a
6.
conducting step 1. of Table III-2?
7.
What options are available for conducting the activities identified under steps 2.
and 3. of Table III-2 in parallel V i
with step 1.
in order to minimize the schedular impact of i
these activities?
i f
I J
EPRI Reauirements Document - Passive Plants 1.
What constrains staff Dot to embark on the review until reciept of the complete sabmittal (step 1. of Table III-6) if EPRI should provide partial submittals earlier, similar to the 1
way the Evolutionary - Requirements Document submittals were
/, handled?
4 3
A.
What options are available to expedite the review and
)
identification of policy issues to the commission?
3.
In preparing the proposed SECY paper, has the staff solicited EPRI's position on the impact that finalizing the passive plant LRBs prior to completion of the passive plant Requirements Document would have on the value of the EPRI effort?
If so, what were EPRI's views?
If not, please find out.