ML20138H397
| ML20138H397 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 04/30/1997 |
| From: | Bruschi H WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Collins S NRC (Affiliation Not Assigned) |
| References | |
| RTR-NUREG-0800, RTR-NUREG-800 NUDOCS 9705070163 | |
| Download: ML20138H397 (3) | |
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Westinghouse Energy Systems Wesunghouse Energy Center Electric Corporation Business Unit QBgfgh PennsyNania WS0355 Howard J Bruschi sfe'a'$r'o!eTs'Dwision April 30, 1997 Mr. Sam Collins Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Collins:
This letter is in response to your March 6, 1997 letter to me transmitting SECY-97-051, " Schedule for the Staff's Review of the AP600 Design Certification Application."
This schedule is the result of considerable planning on the part of both the NRC and Westinghouse in late 1996.
We acknowledge, and are working in accordance with, the NRC's conclusions that it can issue an Advanced Final Safety Evaluation Report (FSER) to the Commission and ACRS in November, 1997, and can issue the Final Design Approval in March, 1998.
Your letter discusses the documentation supporting the NRC review of the NOTRUMP and WGOTHIC codes.
We recognize the importtace of timely submittal of quality documentation of these codes.
It is for this reason that we have worked closely with your reviewers to ensure that there was sufficient information to maintain progress of the review on schedule.
For example, in December 1996, we submitted nine of ten chapters of the NOTRUMP final validation and verification report rather than hold the entire report for the last chapter to be completed.
That single, last chapter has, of course, since been submitted.
The documentation for the WGOTHIC code consists of three separate reports that have been submitted over a period of time.
As each report was submitted, we incorporated what had been learned from the review of the previous report submitted.
This process understandably created inconsistencies among the three reports.
We recognized j
that these inconsistencies must be eliminated before the FSER is 1
issued.
We have met with key members of your staff on this issue and we are updating the WGOTHIC documentation to achieve the necessary consistency and quality.
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' situation, we submitted 12 of 13 chapters of the WGOTHIC Code Applicability Document to ensure that the review continued to move forward.
The final chapter has been submitted.
Your reviewers have acknowledged the interim submittals as a means to keep the NOTRUMP and WGOTHIC code documentation off the critical path for the FSER.
In Revision 6 of the SSAR, the level of detail was reduced from what was contained in the original submittal to what we believe is required under NUREG-0800, the Standard Rev. jew Plan.
We have 1
been informed that the problem was that the NRC had relied on the original submitted level of information as part of their review.
As discussed in several management meetings since that time, Westinghouse will continue to reinsert, where appropriate, SSAR information required by the staff to reach its safety conclusion.
At a meeting with the staff on April 15, we agreed to reissue certain figures to enhance legibility and to include cross-reference information for inter-systems connections.
This action should close this issue.
As you noted, in the NRC's December 6, 1996 letter to Westinghouse, the NRC staff identified 27 key issues that they 4
believed had the potential to become critical path items and that a rapid resolution was necessary to support the proposed review schedule.
Your March 6, 1997 letter indicated the staff was meeting with NRC senior management to establish positions on these issues and Westinghouse would be informed on these positions when they were finalized.
To date, we have received position letters on seven issues.
With four and one-half weeks remaining until the SECY-97-051 milestone of " Applicant (W) submits final SSAR revisions and documentation," it is imperative that the NRC staff provide us with any positions where there is a potential conflict with positions we have taken in the design of the AP600.
Examples of this includes post-72 hours actions, the soil / structural / seismic interaction SSAR revision and ex-vessel phenomena studies.
I am concerned about several aspects of the review that require additional NRC resources and management involvement.
As we discussed with you on April 8, 1997, we are lacking responses from the NRC in such areas as the regulatory oversight proposed 064 97.hjb
, for those systems that were determined to be Regulatory Treatment Nonsafety Related Systems (RTNSS) important, and the responses from the containment systems area on certain submittals.
In the latter area, we have since received their comments on our ITAAC and we understand that their comments on Technical Specifications will be forthcoming shortly.
We still have no improvement in the expected timing for comments on the initial test program.
We need the NRC comments in a time frame consistent with a reasonable turn-around time for us to respond in accordance with the SECY-97-051 schedule.
Lastly, we request that additional management screening of RAI's be made prior to transmittal to Westinghouse to enaure that they are focused on the safety of the plant design.
Examples are the recent RAI where we were asked to explain the difference between 11 minutes and "about 10 minutes" in the time to fill the PCS water distribution system for a transient that lasts for seven days or the RAI that asked about the " Data for the Locker Room Exhaust Fans" which are not in a safety-related or a defense-in-depth portion of a system.
1 I am comm!.ted to ensuring that we provide the NRC with timely, quality submittals required to complete the AP600 design certification review.
I appreciate your personal involvement in this effort and your approach to resolving issues rather than simply exchanging anecdotes.
I am convinced that you and I can make the difference in directing our respective resources to focus on issue closure to ensure that the AP600 review makes the progress necessary to achieve the dates in SECY-97-051.
Sincerely,
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