ML20128F727
| ML20128F727 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/05/1993 |
| From: | Barth C NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#193-13612 96-671-01-OLA-3, 96-671-1-OLA-3, OLA-3, NUDOCS 9302120008 | |
| Download: ML20128F727 (16) | |
Text
J36/z' February 5,1993 q
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UNITED STATES OF AMERICA "A
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
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Docket Nos. 50424 OLA-3 GEORGIA POWER COMPANY, et al.
)
50425-OLA-3
)
(Vogtle Electric Generating Plant
)
Re: Licensee Amendment (Transfer Units 1 and 2)
)
to Southern Nuclear)
)
)
ASLBP No. 96-671-01-OLA-3 dllC STAFF RESEONSE TO LICENSING BOARD OUESTIONS INTRODUCTION The Licensing Board's Memorandum and Order (Request For Information, Briefs) dated January 15,1993, propounded questions regarding the structure and management of the present and proposed licensees of the Vogtle facilities, and requested that the participants address them. The Staff response follows.
DISCUSSION A.
The Board requested a copy of the Vogtle licenses showing the language of the changes sought by Georgia Power Company. By letter dated January 21,1993, counsel for Georgia Power Company provided to the Licensing Board a copy of Georgia Power's September 18,1992 license amendment requests to the NRC. Those amendment requests contain copies of the present operating licenses for the Vogtle facilities, marked in handwriting to indicate the changes to be made.
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B.
The Board also requested information "concerning the legal effect of the change that is being sought" (Order 2) Georgia Power Company is currently authorized by the Vogtle licensees to operate the Vogtle facilities.
By the pending license amendment applications, it is requesting that the operating licenses be amended to authorize the Southern Nuclear Operating Company, Inc. (Southern Nuclear) to operate the Vogtle facihties pursuant to section 103 of the Atomic Energy Act,42 USC i 2133.
The legal effect of the proposed action will be the authorization of Southern Nuclear as -
the sole operator of the Vogtle facilities. It is further proposed that the Georgia Power Co. remain on the licenses as being authorized to possess the facilities.
C.
The Board then propounded three specific questions.
1.
The first asked: "What is authorized by the current license or included in the updated safety analysis report, with respect to whether the organizational structure for the operation of Vogtle may include, directly or indirectly, SONOPCO or Southern Nuclear?" [ Footnote omitted].
Southern Nuclear is not mentioned in the current operating licenses for the Vogtle facilities, and it is not currently licensed te operate the Vogtle units. Southern Nuclear has been identified, since (farch-1991, in chapter 13 of the Final Safety Analysis Report (FSAR), as providing support services for the Vogtle facilities.8 See Revision 1, dated 10 C.F.R. i 50.34(b)(6) requires that the FSAR submitted on application for an operating license shall provide, among other matters:
"The following information concerning facility operation: (i) The applicant's organizational structure, allocations or responsibilities and authorities, and personnel qualifications requirements." Although that regulation does not require revisions to an FSAR be after a plant is licensed,10 C.F.R.'
{ $0.71(e) provides that a licensee shall periodically update its FSAR to keep it' current, and submit those revisions to the Commission.
t i March 1991; Revision 3, dated December 1992.8 The Vogtle Electric Generating Plant l
FSAR I 13.1.1.2, Rev.13/91, sets forth the organizational arrangement regarding Vogtle in terms of the corporate affiliation of various management officials. The executive vice president for nuclear operations is an officer of Georgia Power Company, Alabama Power Company, and Southem Nuclear Operating Company, Inc. FSAR i 13.1.1.2.1.1. The senior vlee president for nuclear operations is an officer of all three supra named corprations FSAR 513.1.1.2.1.2. The vice president for nuclear for the Vogtle facilities is an officer of Georgia Power Company and Southern Nuclear Operating Company, Inc. FSAR 6 13.1.1.2.1.5. Since March 1991, the FSAR has shown that a number of officers of Georgia Power Cempany are also officers of Alabama Power Company and Southern Nuclear Operating Company, Inc. See also Figure 13.1.1-1.8 2.
The Licensing Board next asked how NRC regulations and practices affect the interpretation of the license and FSAR. De Commission's regulations, of course, have the force and effect of law. In any situation where a provision of an A copy of Revision 3 was sent to the Licensing Board by Licensee's counsel on 2
January 21,1993.
8 Further, Southern Nuclear's provision of t:rhnical support sen>lces for the Vogtle facility has been discussed among Georgia Power Company and NRC's Office of Nuclear Reactor Regddon and NRC's Regional Office in Atlanta, Georgia since 1988. See NRC Meeting Summary, dated March 25,1988, attached hereto. The NRC conducted an inspection of the Vogtle facilities in the summer of 1991. As a part of that inspection, NRC inspectors visited the Southern Nuclear Operating Company offices in Birmh,gham, Abbama. The primary purpose was to gain a more detailed working knowledge of the-vs.ous Vogtle suppon activities and groups. The inspection report concluded: "No violations or deviations were identified." NRC Inspection Report Nos.: 50-424/92-22 and 50-425/92-22 at pages 13 and 15, dated October 28, 1991, pertinent pages are attached hereto.
4 operating license conflicts, or apparently conflicts, with the Commission's regulttions, the regulations prevail.
I 3.
The Licensing Board concluded !?* houiry by asking:
'To what extent, if any, is the character or competence of Individuals already jointly employed by Georgia Power and Southern Nuclear in the management of Vogtle relevant'to the approwl of the requested license amendmenM**
8 Staff tells us that character is relevant in connection with the licensee, but it does not cite regulations or precedent. Tr. 90,94 (character of people already managing the plant is important),98. Licensee, on the other hand, tells us that the character and competence ofindividuals who already have management duties, and will continue to have management duties, is not relevant to the issuance of the license amendment. Tr. 97.
Section 182 of the Atomic Energy Act, 42 USC 6 2231, provides that the Commission, by rule or regulation, may require such information as it determines to be necessary to decide the " character of the applicant." The Commission has enacted no regulations in regard to the " character" of an applicant. However, the Commission addressed the character of licensees and applicants in Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No.1), CLl 85 9, 21 NRC 1118,1136 37 (1985); Ilouston Lighting and Power (South Texas Project, Units 1 and 2), CLI-80 32,.
12 NRC 281,291 (1980); see also Metropolitan Edison Co. (Three Mile Island Nuetear Station, Unit 1), ;. LAB-772,19 NRC 1193, '.206-08 (1984), and Ilouston Lighting &
Power Co. (South Texas Project, Units 1 & 2), LBP 84-13,19 NRC 659, 673 679 (1984), Each of the cited decisions indicate that the character of an applicant may be
5 considered in appropriate lleensing actions. In 'Ihree Mlle Island,21 NRC 1136 37, the Commission stated:
A generally applicable standard for integrity is whether there is reasonable assurance that the Licensee has sufficient character to operate the plant in a manner consistent with public health and safety and applicable NRC requirements. The Commission in making this determination may consider evidence regarding licensee behavior having a rational connection to the safe operation of a nuclear power plant. This does not mean, however, that every act of licensee is relevant. Actions must have some reasonable relationship to licensee's character, i.e.,
its candor, truthfulness, willingness to abide by regulatory requirements, and acceptance of responsibility to protect public health and safety. In addition, acts bearing on character generally should not be considered in isolation. The pattern of licensee's relevant behavior, including corrective actions, should be considered [ Footnote omitted].
In South Tc. ras 12 NRC at 291, the Commission stated:
in large part, decisions about licenses are predictive in nature, and the Comrnission cannot ignore abdication of knowledge by a license applicant when it is called upon to decide if a license for a nuclear facility should be granted.'
We believe that the above issues relating to technical competence and to character permeate the pleadings filed by Citizens. They do deserve a full adjudicatory hearing, as they will no doubt get in the operating license proceeding, and they do deserve expeditious treatment because they could prove disqualifying 5
' Equally, and perhaps of more concern, the Commission cannot ignore false statements in documents submitted to it.
Congress has specifically provided that licenses may be revoked for material false statements," see section 186a of the Atomic Energy Act, and we have no doubt that initial license applications or renewal applications may also be denied en this ground, certainly if the falsehoods were intentional, FCC~
- v. WOKO,329 U.S. 223 (1946), and perhaps even if they were made only with distegard for the truth. lxflore Broadcasting Company v. FCC,
,_ F.2d,_ (D.C. Cir. No. 781677, June 5,1980); Virginia Electric and Power Company v. NRC,571 F.2d 1289 (4th Cir.1978).
We include, of course, the false statements charge in this category.
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6-He licensee has requested that amendments be issued to the Vogtle licensees to grant permission for Southern Nuclear instead of Georgia Power to operate the Vogtle faellities. The issuance of an operating license or amendment requires an affirmative finding of compliance with the Atomic Energy Act, the Commission's regulations and reasonable assurance of health and safety of the public 10 C.F.R. I 50.57. If personnel who will be involved in the operation of the facility lack character to operate the facility, then the requested operating license or amendment may not be issued. South Te. ras, supra,19 NRC at 669 and 831 and 7hree Mlle bland, supra,21 NRC at 1137, N.37.d Here, a few individuals who are currently emplayed by the licensee, Georgia Power, are also employed by the prospective licensee, Southern Nuclear. The character of these individuals is thus relevant to approval of the requested amendment.
- Tr. 98; see also Tr. 94 lines 14 and 15. The Staff emphasizes that Petitioner cannot show that he will be harmed by the proposed amendments as Petitioner does not show that the character of the licensee will be changed whether or not the amendments are issued. The same people will manage Vogtle whether or not the amendment is granted. As the Licensing Board stated: "The character is not any more relevant to the new form than the old one." Tr. 99; see also Tr. 104 105. The Board went on to conjuncture that on this basis it should, perhaps, authorize the issuance of the subject amendments. The Staff disagrees. While the statement shows that petitioner lacks standing since he could not be harmed by the issuance of the amendment (as the same people would be in charge), it does not show that the amendment should be approved.
As the Board is aware, the issue of whether licensee has the character to be licensed is also before the NRC by virtue of a petition submitted under 10 C.F.R.
f 2.206 by Mr. Mosbaugh. Further, although, intervention may not be granted unless.
a petitioner shows palpable harm, the Staff has an independent obligation - regardless of whether a petitioner can show harm and regardless of whether he is admitted as a party -
to determine whether an amendment may be approved under the Act and regulations. See generally Vermont Yankee Nuclear Pour corp. v. Natural Resources Defense Counsel, Inc. 435 US 519,526-527 (1978).
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CONCLUSION At the present time, the matter before the Licensing Board is whether l
Mr. Mosbaugh has standing to intervene, l.c., would approval of the amendment increase the risk of harrn to him. The merits of Mr. Mosbaugh's contentions, which concern the prospective lleensee's, Southern Nuclear, character, are not yet before the Licensing -
Board for determination. The Staff reiterates its position that Mr. Mosbaugh should be denied standing as he cannot show that the grant or failure to grant the amendment would i
adversely affect his health and safety.
Respectfully submitted,
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Charles A. Barth Counsel for NRC Staff l
Dated at Rockville, Maryland this 5th day of February 1993 l
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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- 3!$[
BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD
.py g In the Matter of
)
)
Docket Nos. 50-424 OLA-3' GEORGIA POWER COMPANY, et al.
)
50-425 OLA-3
)
(Vogtle Electric Generating Plant
) 'Re: License Amendment (Transfer Units 1 and 2)
)
to Souther Nuclear)
)
)
ASLBP No. 96 67101 Ols.-3 CERTIFICATE Of SERVICE I hereby certify that copies of 'NRC STAFF RESPONSE TO LICENSING BOARD QUESTION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system this 3rd day of February,1993.
Peter B. Bloch, Chairman
- John Lamberski, Esq.
Administrative Judge Arthur II. Domby, Esq.
Atomic Safety and Licensing Board Trautman Sanders U.S. Nuclear Regulatory Commission Nationsbank Building, Ste. 5200 Washington, D.C. 20555 600 Peachtree Street, N.E.
(301) 492 7285 Atlanta, Georgia 30308 (404) 885 3949 James H. Carpenter
- Administrative Judge David R. Lewis, Esq.
Atomic Safety and Licensing Board Shaw, Pittman, Potts and Trowbridge -
U.S. Nuclear Regulatory Commission 2300 N Street, N.W.
Washington, D.C. 20555
' Washington, D.C. 20037 (301) 492-7285 (202) 663 8007 Thomas D. Murphy
- Director, Envirotmental Protection Administrative Judge Division Atomic Safety and Licensing Board Department of Natural Resources U.S. Nuclear Regulatory Commission 205 Butler Street, S.E.
Washingtor,, D.C. 20555 Suite 1252 (301) 492-7285 Atlanta, Georgia 30334
2-Mir.hael D. Kohn, Esq.
Adjudicatory File' (2) l Stephen M. Kohn, Esq.-
Atomic Safety and Licensing Board Kohn, Kohn and Calapinto, P.C.
Panel 517 Florida Ave., NW Mall Stop: EW-439 Washington, DC 20001 U.S. Nuclear Regulatory Commission (202) 462-4145-Washington, DC 20555 Stewart D. Ebneter Atomic Safety and Licensing Board Regional Administrator Panel
- i USNRC, Region 11 Mall Stop: EW-439 101 Marietta St., N.W.
U.S. Nuclear Regulatory Commission Suite 2900 Washington, DC 20555 Atlanta, GA 30303 Office of the Secretary * (2)
Office of Commission Appellate Attn: Docketing and Service Adjudication
- Mall Stop: 16-G 15 OWFN Mail Stop: 16-G 15 OWFN U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Edwin J.
s Deputy neral Counsel' forR clor Licensing e
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g Docket Mos.: 50 424, 50-425 License Hos.: NPF.68, NPF 81 Georgia Power Company ATTN Mr. W. G. Hairston, !!!
Senior Vice President -
Nuclear Operations P.O. Box 1295 Bireingham, AL 35201 Gentlemen
SUBJECT:
NRC INSPECTION REPORT N05.150-424/91-22 AND 50 425/
This refers to the inspection conducted by Brian Sonser of thi. office on August 25 - September 28, 1991.
This inspection included a review of activities authorized for your Vogtle facility.
At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.
WitMn Areas examined during the inspection are identified in the report.
these areas, the inspection consisted of selective examinations of proceduros and representative records, interviews with personnel, and observation of activities in progress.
The enclosed Inspection Report identifies activities that appeared to violate NRC requirements that are not citedt therefore, a response is not required.
In accordance with Section 2.790 of the NRC's " Rules of Practice,' a copy of this letter and the enclosure will be placed in the NRC Public Document Roce.
Should you have any questions concerning this letter, please contact us.
4 Sincerely, dM k 1
Alan-R. Hardt, Chief Reactor Projects. Branch 3-Division of Reactor Projects Enclosuret NRC Inspectinn Raport
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Report Hos.: 50 424/91-22 and 50-425/91-22 t.icensee: Georgia Power Company 7
P.O. Box 1295 Strfningham, AL 35201 Docket Hos.: 50 424 and 50-425 t.icense Nos.: HPF 68 and NPF-81 facility Names Vogtle Units 1 and 1 Inspection Conducted: August 25. September 28,1991 5 b.
1.M 3 0 A Y8'8 Inspectors:
B. R. Eonstr Seniorkesicent inspector Date 55gnet
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R. D. Starkey Res Went inspector Da'te Signed g
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}:.n/sl ate'5tgnes P. A. Balrpin, Reddent inspector ud.b [.
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Approved By: P. Skinner, Chief
~Date Signed Reactor Projects Section 38 DivisionofReactorProjects SUt9%RY Scope:
This routine inspection entailed inspection in the following arenst plant operations, surveillance, an ESF system walkdown, review of licensee event reports, followup, and review of off-sitt engineering.
and technical support resources during a visit to the Itcenset's corporate offices.
Results: Two non cited violations were identified and reviewed during the inspection:
Failure to perfons a TS regaired er.orgency diesel fuel oil analysis for i,sh content resulted in a missed surveillance (paragraph 4b).
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1he cause of this event was a failure to follow procedure. Proce 93240 C, Reacter Vessel Assembly Disassembly Instructions, step 4.12.2.3, which requires proper installation of the cover bolts wasl not followed.
The licenses took prompt corrective action 6y i
infoming contract maintenance of their responsibilities regardine i procedural compliance. This is identified as a second example of 2;:
414/g1 !! 04 1
One non cited violation was ideatitled.
1 Corporate Engineering And Technical Support Visit (40703, 31100, 40$00).
6.
Dur!q this reporting period, the inspectors visited the Southern Nuclest!
Ne primary: purpose ey Operasinfl Company of" ices in limin ham, Alabama.this vis<
t was to gain a more detai ed working knowledge of the numerc Yogtle support activities and to learn more about how the support groupsi are organised, function, and interact.
The. inspectors held detailed discussions with the Vogtle Vice President :the Vogtle-Manager of a
and the Vogtle Manager of Engineering as<well-es otheri l Licensing, in the Nuclear [ngineering and Licensing group. ' Nuclear personnel Maintenance and support group and the Nuclear Administration group. _ Th0 discussions included day to. day operations as well as several on going '
projects.
The inspectors also met with the Southern Company. Services Vogtle - '
Engineering Manager and other 5C$ personnel that support 'the Vogtle 1 project.
Southern Company and 5echtel are used by $NC for most of thel engineering work that supports the Vogtle project. The inspectors tours; the SCS facilities and discussed several current projects.
Particulut,l noteworthy was' the on going conversion of Vogtle drawings to a CAD systei' This will make ; drawings revisions more affic' erit.
2 The inspectors also met with $NC Technical Services personnel. -Thisl support group provides ass! stance with licensing, engineering and environmental-issues, nuclear fuel.-and inspection and testing _ services; Two particult.rly strong areas noted were the nucleer fuelscgroup which!
provqdes core analysis and comercial services for fuel procurement, ant the inspection and testing grou1 which provides-on site expertise in ll!
and 15T.
The inspectors also Learned that Bechtel and to some-degree Westinghouse, have groups dedicated to Vogtle support.
The inspectors noted throughout their discussions that-virtually:e'veryl individual placed emphasis on their role as pris.arily"being a support!
function-to the-site.
$NC'provides' dedicated support to'ench of the.
The SNC Yogtle project office 7 tasks the Vett1(
nuclear power stations.
dedicated SCS office -and the Vogtle dedicated Bechtel orgsnization witi:
SNC to be.a client for their engineering services.; T s pecific--support - assignments.
Both the $ch and'8echtel; offices -conside 4
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54 that 5NC sets priorities and holds SCO and Bechtel responsible for meeting!
assignments. The inspectors also toured the SC5 Power Coordination Centesi and discussed operation of_ the facility.
particular emphasis was placed,
on Vogtle switchyard configuration and the effects on the electrical grid.;
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The inspectors also while at the SNC offices discussed the functioning of!
the Vogtle $AER group and 15EG with the 5AER manager.
50th of these groups had been previously r6 viewed and observed to be functioning i
effectively.
The inspectors also reviewed Safety Review Board member i
qualifications and reviewed preparation of agenda items for the neat IRB !
meeting. Both the SM member qualifications and the agenda items meet ths:
4 T5 and AW5! requirements.
No violations or deviations were identified.
7.
Mid loop / Reduced Inventory Activities (GL 88-17) j The inspector reviewed the licensee's preparation for midtoop/ activities for the Unit I refueling outage-(IR3).
The. inspector verified that.,
appropriate procedures are in place which address the concerns of Generls!
Letter 8817(LessofDecayHeatRemoval)datedOctober 17,1988. During; 1R3. the Ifcensee, as part _of their Shutdown Risk Management : plans to '
maintain 3 out of 4 onsite and offsite power sources available when fuel.
is in the vessel.
One exception to this strategy occurs during fool 1
- offload when the 'l' RAT will be taken out of service for appl'-DG is out hours to perform 4 tap setting change at the.same time the of service.
Both DGs will remain operable until Mode.5 entry.. Also, betti RHR pumps will be available while fuel is in the reactor. vessel:and-although the RC5 will be at reduced inventory it will not be drained teL' midloop while fuel is the: vessel.
5G eddy current testing is not scheduled until the vessel-is defueled.
Procedures are active and in use for Ltha'followir,g requirements..
l CONTAINMENT CLOSURE CAPABILITY FOR MITIGATION OF RA010ACT!VE RELEAlt!
- Procedure 14210 1 Containment Building Fenetration Verification Refueling. Rev. 7. is used to verify containment butiding penetrettes status prior to and during= the refueling or' core alteration or movement of > {rradiated fuel within the containment.'
Procedure 18013 C. Loss of Residual Heat Removal, Rev.10. step AS. states that when RHR cooling can not be restored 1n a timely manner. and when RC1 level is less tien the--1gl foot elevation.1then initiate containment; closure procedure 14210 1.' Additionally, procedure 12008.C. Mid-Leos.
Operations, feet elevation the" containment equipment' hatc below-191 closed with-a minimum of 4 - bolts.
This limitation may_bs waivede provided that a method is1provided? for closing the containment z. !
equipment: hatch without the use of electrically, operated equipment i
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Review of Corporate Engineering and Design Change Support (40703, 37828)
B.
During this reporting period, the inspectors visited the Southern Nuclur Operating Co'rpany offices in Birmingham, Alaba r.a.
The primary focus of visst was to review and evaluate the off-site support organization's t 11:
responsibilities, authorities, and lines of comunication in the design change process, and to review selected design changes.
The SNC organization is responsible for oversight of the design process in support of the Vogtle site,
$NC oversees the processing and. tracking of des'gn development, reviews work authorizations to ensure work is od an approved work list, and ensures the appropriate design organization has been designated 17 perform the work.
Southern Company Services and SNC sets the Bechtel perform most of the engineering work for SNC.
priorities and holds the support organizations responsible for meeting Both Bechtel and SCS maintain a dedicated Vogtle support assignnents.
organization.
The SNC Vogtle project is progressing toward 6 goal of six month design windows in which all design resources will be comitted to preparation of This will 411cw more time to procure DCPs six months prior to an outage.
The raterials, walkdown the DCP, handle exceptions and budget time.
present design process has resulted in a less efficient use of time and i
resources and some DCPs being completed and sent to the site at the time 1
they were to be inplemented.
The inspectors also ret with SCS Yogtle project management, reviewed their The design change process and organization and toured their factilties.
SCS support organization supports the site by preparing design changes, responding to requests for engince-ing assistance, and reviewsng M00s and The inspectors found that administrative cuntrols were clear, the FCRs.
process was well understood and lines of comunication were well established.
The inspectors found particularly noteworthy the degree to This was which SCS is striving to enhance productivity and efficiency.
particularly evident in the on going conversion of Yogtle drawings to a CAD system, the cable conf t!)uration data system, and the storage and control of Vogtle documentation.
The inspectors also reviewed a sample of DCP and HDD documentation to verify these changes were processed in accordance with the established controls.
This review included safety evaluations and other checklists prepared to support the CCP. The items reviewed are listed belowl DCP 92-V2N0052, Revise OPDT and 0 TDT Setpoints to Support the Yantage 5 Fuel Upgrade DCP gl-V2N0112, Provide Separation for Power Fall, Alarm Fail and the Steam Generator Level Control Circuits
o Wenfto sTATas NO:: LEAR REGULATSRY COMMIS$l0N J
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g g gg Jocket Nos. 50 348/364 - 50 321/366 50 424/425 LICENSEE 5:
Alabama Power Company sad Georgia Power Company Unita 1 and 2 FACILITIES:
Farley Nuclear Plant. Units 1 and i Hatch Nuclear Plant.
Vogtle Nuclear Plant.-Units 1 and 2
$UBJECT:
MEETING $ UMP %RY FOR MEETING 0F MARCH 18. 1988 WITH SOUTHER i
QMPANY REPRESENTAT!YES REGARMNG THE ESTABL15HMENT OF AN-OPERATING COMPANY FOR THE FARLLI. HATCH AND V0G1LE PLANTS.;
the NRC staff met with representatives of South.rn Company Cn March 18. 1988, Services (5C5), land to discuss.the inferi.ation that would be r Rockville, Mary submittal for amendments to the licenses and construction.pemit held by APC and GPC for the Farley. Hatch and Yogtle Nuclear Piants. Attendees >are listed '
i in Enclosure 1.
The viewgraphs used by the SC5 representative in his presentation are in Enclosure 2.
Mr. L. Long of SCS made the presentation. He emphasized that the companies were still evaluating the idea and concept of an operating company.c His presentation was to describe generally what the licensees propose to taclude in' ;
I their applications. He covend previous actions that the agency has taken.
regarding changes in plant operators. The changes in 7echnical 5)ecifications were also discussed, including the deletion-of the organization ciarts from the specifications as was done for the shearon Harris Station. The-' staff advised hin that we anticipate the issuance of the generic letter on this issue in the near future.
There was scoe discussion regarding the need to file the OL application-men 6ent and the FSAR amendetent concurrent with the'CP amendment for Vogtle.
Unit 2.
The licensees did not believe-that the amendnents needed to be sub.
sitted concurrently and, in fact.. should be done sequentially.
The itcensees requested that-the staff advise.them on the level sf detail that would be needed-in the applications._ The staff suggested to the licensees that' they address-the following pointss
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The responsibilities and authorities of the.elemints of the new organization.-
.2.. ~ !dentify where tasks were in the old organization'and'where they will be'-
in the new organization.
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Address the corporate aspects of prograrmatic areas, such as securit fire protection, in the transfer from the old offsite to the new offsite 3,
organization.
The licensees expressed concerns that we were asking more o The staff offered to investigate done for other licensees like GPU Nuclear.the level of d back to the Itcensee.
The licensee indicated that their start date was inde 4,
factors, but that following a decision tc proceed, they would plan There would be amendment amenacent applications filed within two weeks.
The applications for the five operating licenses and the construction OL application amendment and the fiAR amendment fo t
flied at a later date.
as expeditiously as possible, preferably within three months.
, DAY O '?"
linor G. Adansas, Otractor Project Otractorate !!-1 OlvisionofReactorProjects!/!!
Enclosures:
As stated cc w/encls: See next page i
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