ML20095F044

Requests Exemption to Revise 10CFR170 License Fee Schedule Re Gessar II Review.Exemption to Schedule Appropriate Since Review of Gessar II Design Committed Under Regulations & Policies in Existence in Early 1982

ML20095F044
Person / Time
Site:	05000447
Issue date:	08/10/1984
From:	Sherwood G GENERAL ELECTRIC CO.
To:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
MFN#115-84, NUDOCS 8408270155
Download: ML20095F044 (2)

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v GENERAL $ ELECTRIC NUCLEAR POWER SYSTEMS DMSON GENEPAL ELECTRIC COMPANY e 175 CURTNER AVENUE e SAN JOSE, CAUFORNIA 95125

, August 10, 1984

~Mr.7 William J.'Dircks MFN#115-84 Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

REQUEST FOR EXEMPTION TO REVISED LICENSE FEE SCHEDULE General Electric Company hereby requests an exemption to 10CFR170

, License Fee Schedule as revised effective June 18, 1984 with regard to l the GESSAR II review. The thrust ot this request is based on the fact that had the GESSAR II review been completed on the schedule planned by the NRC, the GESSAR 11 review'would have been completed before the new fee schedule was adopted.

The agreements made in March 1982 with the NRC staff for the review of CESSAR II were documented by the NRC in D. G. Eisenhut's letter to G. G.

Sherwood dated March 19, 1982, a copy of which is attached. For this review the staff developed two separate schedules, one for the 238 Nuclear Island and a second for the severe accident design. The delay of this review created the fee issue.

The 238 Nuclear Island review was scheduled for completion in May 1983,.

I and indeed the review was conducted as planned and the FDA was issued in July:1983.

The severe accident design review was scheduled for completion in May 1984. .However, this review is still underway.

This review was to be based on the " Proposed Commission Policy Statement on Severe Accidents..." SECY-82-1, dated January 4, 1982. At that time the Commission License Fee regulation 10CFR170 of March 23, 1978 was in effect. ,

! Given this agreement GE cotcplied with the Staff's requests for

' documentation prescribed in the Proposed Commissioners Policy Statement.

This included an extensive probabilistic risk assessment, cost benefit studies, etc. In fact the review was conducted almost on schedule until early 1983.

8408270155 40810 PDR ADOCK 05000447 p 8 PDR

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, GENERAL $ ELECTRIC l In April 1983 the Commission again published for comment a " Proposed Commission Policy Statement on Severe Accidents..." (48FR 16014). This revision to the Commissions Policy Statement required additional infor-mation for the severe accident review. Of course some schedule time was lost with the review of this additional info'rnation.

Subsequent to the April 1983 proposed Policy Statement, the NRC staff issued in January 1984, a' working draft tt the " Final Commission Policy Statement on' Severe Reactor'A gidents", mis working draft was even more extensive in describing specific eval::dtions' required for a severe accident review. These inciuded the use of new safety information, treatment of uncertainties, etc. Again GE complied with these requirements and again a delay in the severe accident review occurred.

As mentioned above the severe accident review of GESSAR II is still underway and as we are fully aware 10CFR170 License Fee Schedule was revised significantly, effective June 20, 1984.

General Electric believes that an exemption to the new license fee schedule is appropriate since the review of the GESSAR II design was committed under regulations and policies in existence in early 1982.

Further, the initial plan and agreement by both the NRC and GE was to complete the severe accident review in May 1984 which is before the June 20, 1984 effective date of the new fee schedule.

As an additional point, it is clear that the NRC staff during this review has gained significant knowledge in evaluating severe accidents.

GESSAR II is the first design reviewed for severe accidents. This is clearly in the public interest and supports GE's request for this exemption.

I would like to discuss this further with you at your convenience.

Very truly yours Glenn G. Sherwood, Manager Nuclear Safety and Licensing Operation cc: H.R. Denton, NRR D.G. Eisenhut, DL W.O. Miller LFMB

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E 3 NUCLEAR REGULATORY COMMISSION h ,$ WASHINGTON, D. C. 20555 e

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MAR 191982 Docket No. STN 50-447 -

General Electric Company ATTN: Glenn G. Sherwood, Manager -

Safety and Licensing '

Operation -

Nuclear Reactor Syst' ems Division --

175 Curtner Avenue, Mail Code 682 San Jose, California 95125:

Subject:

Review Schedule for GESSAR II-For the review of GESSAR'II, the staff has developed two separate schedules -

one for the 238 Nuclear Island and a second for the severe accident design.

• Copies of these two schedules, including key milestones, are enclosed.

. The review schedule for the 238 Nuclear Island calls for publication of the staff SER in March,1983, and issuance of an FDA in May,1983. To meet '

this schedule, we shall follow a revised procedure whereby, after docketing, only a single set of questions will be transmitted to GE for responses.

Subsequently, a series of meetings between the NRC staff and your represen-tatives will be held to res'olve open items and to finalize the SER.

The review schedule for the severe accident design provides approximately a two year review with issuance of an SER in March,1984 and issuance of an FDA in May, 1984. This schedule was developed assuming receipt by the staff of the supporting probabalistic risk assessment (PRA) in March and submission of the design details of the 238 Ndelear Island modifications in a reasonably, timely manner. ~

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S ncerely '

J Da e G. isen t. Director Division of Licensing

Enclosures:

Review Schedules cc w/ enclosures See next page

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. . . . j ENCLOSURE 1 . l I

lGESSAR 11. REVIEW SCHEDULE 1 l

' DOCKET SSAR' '

LATE 2/82 '

0-1 TO PM ,

7/16/82 '

Q-1 TO APPLICANT 8/13/82 APPLICANT RESPONSE TO 0-1 ,

11/26/82 SER INPUT TO PM -

2/1/83 ISSUE SER .

3/2/83 ACRS MEETING I4/83 ISSUE ~SSER kii8 FDA (NUCLEAR ISLAND) s, 5/83  ;

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(' ENCLOSURE 2; i ~.. SEVERE ACCIDENT DESIGN REVIEW SCHEDULE

• DOCKET PRA 3/19/82 BWR TECHNOLOGY UPDATE MEETINGS 5-7/82 0-1 TO PM 9/1/82 0-1 TO APPLICANT . 10/1/82 APPLICANT RESPONSE TO Q-1 2/1/83 ~  ;

Q-2 TO PM 6/1/83 0-2 TO. APPLICANT 7/1/83 APPLICANT RESPONSE TO Q-2 11/1/83 SER INPUT TO PM 2/1/84 ISSUE SER 3/1/84 -

ACRS f1EETING 4/84

. ISSUE SSER AND FDA (SEVERE ACCIDENT DESIGN) 5/84

• ASSUMES TIMELY RECEIPT OF C0f1 MISSION POLICY GUIDANCE AND l

DIRECTION ON SEVERE ACCIDENT ISSUE 9