ML20150E221
| ML20150E221 | |
| Person / Time | |
|---|---|
| Issue date: | 11/06/1978 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20150E218 | List: |
| References | |
| RTR-NUREG-75-087, RTR-NUREG-75-87 NUDOCS 7812110201 | |
| Download: ML20150E221 (3) | |
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O VALUE li1 PACT STATEMENT SRP Section 13.1
- 1. PROPOSED ACTION that, A. The scope of Section 13.1 of the SRP is being revised to requira in addition to an applicant submitting specific information relative to its technical capability, it must also submit similar information
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for its principal contractors (NSSS vendor and architect-engineer fortheproject). Note: This would apply only at the construction standard design and permit review and include applicants for aThis information may be f those for a manufacturing license.
j provided by a description of their past experience in similar projects or by a description of their technical staffs.
? B. The need for this stems from two sources:
to Part F0, Appendices M, N, and 0,
- 1. Recent changes (1973-1975) that require the Commission to make a finding of technical qualifications. The current SRP does not provide for the submittal and review of the pertinent information to support this finding.
- 2. A weakness in information submitted upon which to base the finding of technical qualifications pursuant to 10 CFR The regulatory base is not 50.34(a)(9) & (b)(7). Note: The changed by this revision to the SRP Section 13.1.
change is to assure that sufficient information is in the docket and reviewed by the NRC staff to adequately support this finding.
C. We estimate that the negative impact on NRC operation would be negligible ,(perh_aps ay2 man-dy per application) to evaluate the additional information. The positive impact is not readily determinable since the information submitted is of a non-technical nature and it is difficult to quantify the value of information used to provide a basis for a conclusion of technical qualifications.
However, the subject of adequacy of technical qualifications has been raised in public hearings and the expanded scope shoulo minimize a similar contention being raised in future hearings.
C2. We estimate that the negative impact on industry would consist only of the effort tc, initially prepare and submit the necessary supporting infonnaiion (a rough estimate Th5 oidy is on positiye the orderindustry impactTn of 4 Ean-d AyLP9C..appjication. )would be the decrease There is no probability that this sub raised as a contention in future public hearings. However, real impact on other government agencies and the. public.
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2 there is a beneficial effect in that they will be better informed relative to the technical qualifications of the firms principally responsible for the safe design and construction of the facility and, accordingly, will better understand the basis for our con-clusion regarding the adequm' of technical qualifications. .The NRC will be _better informed and have better documentation to lup2 ort concliisions relative to the technical qualTfications of appl __icants.
C4. The item at issue is a revision to Section 13.1 of the SRP. No other scatement on the form of promulgation of this item is needed.
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- 11. TECHNICAL APPROACH l
I This section of the value-impact statement is not applicable to this change.
III. PLAN FOR IMP _LEMENTATI0ti This revision to the SRP would apply only to new applications. .Lt.
will be imp,lemented for all new applications received 4 months after the_Au.b.lication__ of the revi_ sed section 67 the SRP.
IV. PROCEDURAL APPROACH Since a determination has been that the SRP's will be updated, we find no basis for suggesting an approach other than the SRP. Al ter-natives include Regulatory Guide and revised regulations. However, the revision of the SRP and incorporation of the provision in the Standard Format seems the most practicci and direct approach.
V. STATUTORY C0_NSIDERATIONS - NRC AUTHORITY This section of the SRP derives from the following Federal Regulations:
- 1) 50.34(a)(9) for Preliminary Safety Analysis Reports, 2) 50.34(b)(7) for Final Safety Analysis Reports, Section 5.(e) of Appendix M of Part 50 for applicant for a manufacturing license, Section 2. of Appendix N of Part 50 for applicants for licenses to construct power reactors of the same design to be located at different sites, and Section 3. of Appendix 0 to Part 50 for persons submitting a preliminary or final standard design. Based on these statements of required infonnation, and the considerations of Part 50.40, 50.45 and Appendix M for findings stated therein with regard to the adequacy of technical qualification, we have proposed the SRP revisions to provide a better basis for our findings.
Note: There is no need for a NEPA statement for this change to the SRP.
VI. Surnary_ and Concl usions The proposed action is to add to the Standard Review Plan the area of review of the technical capability of the principal contractors of l applicants for a construction permit; for applicants for a manufacturing l license, and for persons applying for the review of standard plant l designs. This need for revision to the SRP has been emphasized by the addition of Appendices M, N, & 0 to Part 50 of the Code of Federal Regulations and to provide docketed additional information over that currently supplied from which to draw a conclusion of technical qual-ifications as required by Part 50.
We consider the impact on applicants to be inconsequently negative, in that they will have to prepare and submit up to approximately 3 rrore pages in their application. On the positive side, the applications will provide to the public greater information on which to share the NRC's concli.sion of technical qualifications.