ML20125D451

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Comments on Proposed Branch Technical Position Re Overpressure Protection.Implementation Section Needs Mod to Include All Classes of Applications & to Provide Guidance Re Imposition on Applicants W/Pending Licensing Decisions
ML20125D451
Person / Time
Issue date: 11/17/1977
From: Boyd R
Office of Nuclear Reactor Regulation
To: Mattson R
Office of Nuclear Reactor Regulation
Shared Package
ML20125D401 List:
References
REF-GTECI-A-26, REF-GTECI-RV, TASK-A-26, TASK-OR NUDOCS 8001140309
Download: ML20125D451 (3)


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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20666

' ra -j h,*..../ Nov 17 m MEMORANDUM FOR: Roger J. Mattson, Director Division of Systems Safety FROM: Roger S. Boyd, Director Division of Project Management

SUBJECT:

WORKING PAPER ON RCS OVERPRESSURE PROTECTION DURING STARTUP AND SHUTDOWN FOR PWRS In general, DPM concurs with the proposed Branch Technical Position. We do feel, however, that the implementation section needs to be modified to include all classes of applications,to specifically address how the position will impact applications using the replication and reference design options of the standardization prograrr, and to provide guidance on how the position can be imposed on applicants with pending near term license decisions.

It cover these points, we recommend the following implementation section:

The Branch Technical Position, as specified in Section B, will be used in the review of all Preliminary Design Approval (PDA),

Final Design Approval (FDA), Manufacturing License (ML), Operat-ing License (0L), and Construction Permit (CP) applications involving plant designs incorporating pressurized water reactors.

All aspects of the position will be applicable to all applications, including CP applications utilizing the replication option of the Commission's standardization program, that are docketed after (date of promulgation). All aspects of the position, with the exception of reasonable and justified deviations from IEEE-279 requirements, will be applicable to 0L applications docketed prior to (date of promulgation) but for which the licensing action has not been completed as of (date of promul-gation). All aspects of the position will be applicable to all CP, ML, PDA and FDA applications docketed prior to (date of j promulgation) but for which the licensing action has not been completed as of (date of promulgation). Holders of appropriate PDA's will be informed by letter that all aspects of the posi-tion will be applicable to their approved standard designs and i I

that such designs should be modified, as necessary, to conform to the position. Staff approval of proposed modifications can 90017175

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' Roger J. Mattson EV27m be applied for either by application by the PDA-holder on the PDA-docket or by each CP applicant referencing the standard design on its docket.

The following guidelines may be used, if necessary, to alleviate impacts on licensing schedules for plants involved in licensing proceedings nearing completion on (date of promulgation):

1. Those applicants issued an OL during the period between (date of promulgation) and a date twelve months there-after, may merely commit to meeting the position prior to OL issuance but shall, by license condition, be required to install all required staff-approved modifi-cations prior to plant startup following the first scheduled refueling outage.
2. Those applicants issued an OL beyond (date twelve months after the date of promulgation) shall install all required staff-approved modifications prior to initial plant startup.
3. Those applicants issued a CP, PDA or ML during the period between (date of promulgation) and a date six months thereafter may merely commit to meeting the position but shall, by license condition, be required to amend the application, within six months of the date of issuance of the CP, PDA or ML, to include a description of the proposed modifications and the bases for their design, and a request for staff approval.

4 Those applicants issued a CP, PDA or ML after (date six months after date of promulgation) shall have staff approval of proposed modifications prior to issuance of the CP, PDA or ML.

e also offer the following specific coments:

1. In the working paper, page 2, third line from the ,

bottom - insert the word " pressure" after "over ".

2. In the working paper, page 4, second line - insert the word "can, such that the sentence reads ". .. . . unless it can be shown that .....".

90017176 l

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Roger J. Mattson hov i 7 377

3. In the working paper, page 5, third paragraph - We cannot logically arrive at the conclusion stated in this paragraph without knowing the dollar cost of the modifications.

4 In the working paper, page 5,Section VI (1), first line -

insert the word " Position" after " Technical".

'hogerS.Boyd, Director Division of Project Management cc: R. Boyd R. DeYoung D. Vassallo F. Williams L. Crocker 90017177 I