ML20198F334

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Documents Directorate of Licensing Evaluation & Judgement of Nonrecoverable site-related Effort Expended on Unit 1 License Application Prior to Site Relocation & Addition of Duplicate Plant
ML20198F334
Person / Time
Site: Washington Public Power Supply System
Issue date: 12/17/1974
From: Anthony Giambusso
US ATOMIC ENERGY COMMISSION (AEC)
To: Donoghue D
US ATOMIC ENERGY COMMISSION (AEC)
References
CON-WNP-1025 NUDOCS 8605280478
Download: ML20198F334 (8)


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o sb Docket ::os. 50-46 i

and 50-513' 1

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j Daniel J. Donoghue, Director of Administration I

j EPPORT ON WASHINGTON PUBLIC POWER SUPPLY SYSTDi (WPPSS) PRIOR TO SITE RELOCATION AND PLANT DUPLICATION 6

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Summesry This memo is written to document the Directorate of Licensing ovaluation i

and judgment of the amount of non-recoverable and sito-related effort expended on the WNP-1 license application (Docket No. 50-460) prior to the WPPSS site relocation and addition of a duplicato plant, WNP-4.

This judgment will be considered by the Business Managencut Office in deciding whether to assess the Uashington Public Power Supply System (UPPSS, applicant) a second application fee for the license amendment submitted-on August 9, 1974.

Available manpower expenditure records show that about 526 man-hours were spent by review groups on PSAR material thst was subsequently modified or replaced due to the site relocation and plant duplication. Of these hours, over half are directly applicable to the review of the amended application.

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l Since the average application for a construction permit (CP) takes 8 to 10 thousand man-hours of Regulatory staff effort prior to completion of review, the approximately 260 msn-hours spent in review activity not applicable to the amended application is less than 3.5% of the normal CP review offort.

l Both plants have been under concurrent review at the new site since July i

1974. In our view, the msn-hours spent prior to the application amendnent are low enough so that assessment of a second full application fee is not justified.

l

Background

4 At a 10/24/74 meeting attended by W. Miller and J. Holloway, Business }!anaga-ment Branch, J. Ponner, OCC, and A. Schwencer and T. Cox of Reactor Projects (LUR 2-3), it was agreed that Mr. Schwencer's office would initiate docu-l mentation for the Directorate of LicensinC concerning the Regulatory staff effort on the UPPSS application. This effort in :ran-hours would be compared to the approxinately S to 10 thousand licensing man-hours nornally spent on r

a CP application. If the af fort on the application as ori;;inally docketed 1

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l Daniel J. Donoghue 2-is a relatively low fraction of the normal overall effort, then considerable justification exists for not levying an additional application fee for relocating UNP-1 and duplicating it with WNP-4.

The factors leading to the

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decision that this man-hour comparison is warranted are:

(1) There is precedent for waiving or not assessing an additional i

application fee for the addition of a reactor unit ue a site when the multiple units are reviewed concurrently.

(2) The WNP-1 &nd -4 plants are being reviewed concurrently since:

1 (a) PSAR plant-related material reviewed prior to the formal addition of WNP-4 is almost totally applicable to the WNP-4 plant because the two plants are duplicates.

(b) Three PSAR amendments between 5/31/74 and G/9/74 addressed the relocation and duplication of the original WMP-1.

An ER amendment dated 7/10/74 provided appropriate environmental information. These amendments have been reviewed on the schedule approved 4/29/74 for review of a relocated UNP-1, starting at the Q-2 stage of review.

(3) Very little site-related licensing work was done for the original (WNP-1) site.

(4) The site relocation was brought about by factors beyond the control of WPPSS management.

Discussion l

The UNP-1 application was docketed on October 18, 1973. On August 9, 1974, an amend:sent to the original application was received which formally committed to a site relocation of approximately 17 miles on the Hanford reservation, and to the duplication of the originally planned WNP-1 power plant with the WNP-4 plant to be located about 3000 feet north of the WNP-1 plant. Site relocation action was initiated following an inquiry by Senator Henry Jackson. who in November 1973, asked both the Bonneville Power Administration and the AEC to investigate the feasibility of continued operation of the N-reactor past the planned 1977 shutdown date.

Af ter docketing in October 1973, the Envirorunental Projects' review based on the original Hanford i site, was not pursued, first due to an unavoidable i

staff delay in engaging a national laboratory review team, and then due to l

the applicant's letter to D. Muller on February 21, 1974 formally suggesting j

rescheduling the environmental review after a site relocation decision.

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Daniel J. Donoghue '

Very little environmental review was conducted for the Hanford 1 site, but that work done is reflected in the attached manpower records. When i

the revised Xavironmental Report was submitted on 7/10/74 for environ-mental review at the new site, material covering the. addition of WNP-4 was in those documents, permitting a concurrent environmental review of the impact of both WNF-1 and WNP-4.

l Again starting in October 1973, the Reactor Projects' radiological safety j

review progressed through the Q-1 stage prior to site relocation, and included.a site visit to the new (WNP-1, 4) site, which eliminated the need for a site visit after the relocation was approved. When the safety review was rescheduled (approved by the Director of Regulation on 4/29/74) at the new site, the review through the Q-1 stage was not repeated, but the review of the non-site-related plant design was picked up at the point where it was terminated at the Hanford 1 site.

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Technical Review branch schedules were slipped six months or less to fit the development of new site-related information by the applictnt. The i

relatively inconsequential delay and planned review continuation without repeating the Q-1 phase of the process was the direct result of (a) a i

short move of 17 miles, still on the Hanford reservation, such that i

geology, meteorology, hydrology and seismology were similar, and (b)

WFPSS had recently been awarded a CP for a BWR at the Hanford 2 site one mile west of the new site area to be utilized. Information relating to I

the new site and the addition of a second, duplicate plant was presented on or before the scheduled dates, in PSAR amendments received 5/31/74, 7/1/74 and 8/9/74.

I Most of the non-site-related safety review done for UNP-1 is directly l

appifcable to the WNP-4.

This is because WNP-4 is a complete duplication i

of all of the UNP-1 project, as a separate plant, on the same site area.

The additional effort expended in the review of this application as now l

amended, is almost totally the result of the site relocation. This is i

the direct result of the WPPSS' timely duplication of the entire UNP-1 plant with another identical plant (WNP-4) on the same site with no shared syntmas except the off-site electrical system, and the cooling tower askoup and blowdown system.

I The attached data sheets are excerpts from manpower expenditure records of Regulation. They show a total of 391 regular working hours charged to the WNP-1 application review through June 1974 by the Site Analysis, Accident Analysis, Cost Benefit and Environmental Specialists Branches i

of the Site Safety Group. Less than half of the 391 man-hours could be j

attributed to work directly related to the original WNP-1 site.

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I Daniel J. Donoghue.

j One other Regulatory staff group, the Electrical. Inarrumentation and Control l

Systems Branch, reviewed PSAR material that was subsequently changed due to the relocation and plant duplication. This group spent 135 total regular hours prior to August 10, 1974, of which about 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> is the probable maxiansa time spent on material that was subsequently changed.

The total " lost" time, i.e., time not applicable to the concurrent review of the two duplicate plants at the new site, is less than 255 man-hours.

Compared to an 8000 man-hours " low average" time spent on a typical application for construction permit, the probable " lost" time is about 3.1% of the total review time required.

Originalsigned by Roger S.Boyd I

A. Ciambusso, Deputy Director for Reactor Projects Directorate of Licensing Attaciument:

Manpower Expenditure Record D TRIBUTION:

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09/26/14 TOTAL H4S FY 74 00000,48V = C ORG DOCKET ACT RCG NON. REG C00E NO CODE HRS PRS K320 05000460

'113 0,0 4.0 05000460 24,0 8.0 05000460 0,0 0

05000460 8.J 0

ACT.~00E TOTAL n32C 113 g,d 23,0,

00000482 212 6,0 2,0 ACT.CCDE. TOTAL K320 212 8,0 2.0

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g4 ORC. CODE TOTAL K320 10 3

d* T'(* M3 3 0 '

i

" IO' 000004e2 112 10,0 0

000004d2 c,0 0

00000482 7,0 1,5 00000482 2,0

.v ACT. CODE TOTAL K330 112 M

't.5 _

05000460 til 2,0 2.0 05000460 26,0 2.0 05000460 4.0 0

05000460 6,0 0

05000460 1.0 2,5 05000460 5,0 0

05000460 2.0 0

05000460 4.0 0

+

05000460

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-2.0 0

05000460 3.0 0

05000460 1.0 0

ACT.CCDE TOTAL K330 113 53 g5, 00000402 122 7,0 1,5 ACT. CODE TOTAL K330 122 3

JL...

00000482 212 5,0 9,5 Y

00000462 4,0 4.0 00000482 16,0 8,0 00000482 4,0 0

00000482 8,0 0

00000482 5,0 0

ACT.CCDE TOTAL K330 212 42 0 yd,

,3 05000460 213 2.0 0

05000460 10. 'J 0

05000460 3.0 0

ACT= CODE TOTAL K330 213 15.0 0

CPC.CCO: TOTAL K330 149,0 31,0

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TOTAL HRS FY 74 000004 h a '

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ORG OCCKET ACT REG NCs.8EG C00C No

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FRS HRS M.O 4.p.fl>

K310 00000482

'111 8.0 0

00000482 2.0 0

ACT= CODE TOTAL K310 1

111 10.0

f. _. 0 00000482 112-12.0 A 1.0 00000482 11.0

.'{ 2.0 00000482 12.0 00000482 0

12.0

.j 0

00000482 12.0 0

00000482 8,0 I

0 00000482 4.0 0

ACT.CODC TCT!.L K310 112-71.0

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05000460 113 16.0 0

05000660 39.0 0

07000460 3.0 0

00000482 4.0

.0 05000400 00000482 8.0 0

0.0 5

05000460 24.0 0

ACT.CC E TOTAL K310 113 100.0 l

5 00000482 212 3.0 0

ACT.CCDE TOTAt. K310 212 3.0 0

CRG.CC0C TOTAf. K310 180.0_

"3S f 4' V320 000004d2 til 2.0 4.0 00000482 2.0 0-5 00000482 12.0 0

ACT.CCDC TOTAL K320 til 16.0 4.0_

00000482 112 12.0 0

00000482 4.0 0

00000482 2.0 0

00000482 1.0 0

00000482 16.0 0

00000482 2,0 0

00000482 12.0 10.0 ACT.CCDE TOTAL M320 112 4.9.0 10.0 05000460 113 6.0 0

05000460 1.0 4

0 3 00 u'e 6 0 4.0 0

0$000400 6.0 0

05000400 0.0 0

G5000400 6.0 0

050004bJ 32.0 11.0 r; '..

D-09/26/7tl TOTAL HR5 FY 74 00000JSM '

ORG DOCKET ACT REG NON-AEG CODC No CODE HRS

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ACT-CCDE TOTAL K 3'l 0 212 6,0 0

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