ML20199B440
| ML20199B440 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 11/04/1997 |
| From: | Roe J NRC (Affiliation Not Assigned) |
| To: | Mcintyre B WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| NUDOCS 9711180321 | |
| Download: ML20199B440 (6) | |
Text
_ __
9 083
- f* **%g**,
.i iaNITED STATES
[
?>
NUCLEAR REG 9LATORY COMMISSION g
j wAssiwopq, a.c sones.cooi yg*
November 4, 1997 Me, Brian A. McIntyre, Manager Advanced Plant Safety & Licensing Westinghouse Electric Corporation Energy Systems Busiress Unit l
P.O. Box 355 Pittsburgh, PA 15230
SUBJECT:
AP600 REVIEW SCHEDULE
Dear Mr. McIntyre:
Your letter dated September 26, 1997, provided comments on the draft AP600 schedule dated September 18, 1997. As you noted in your letter, the schedule represented a six-week improvement over that which was provided during the September 10, 1997, meetiig. The improvement was accomplished by incorporat-ing the time allocated for the Office of the General Counsel the final safety evaluation report (FSER) revisions necessary(0GC) review and to address OGC comments into the three month period PDST allocated for preparation of the FSER.
The staff remains committed to completing the AP600 review with the resources currently available.
However, as sthted in the work may result in delays in a particular area. past, emerging higher priority The Office of Nuclear Reactor Regulation will attempt, to the extent possible, to minirnize these delays.
However, your cooperation is needed to quickly respond to the remaining requests for information from the staff and to ensure that the outstanding issues are resolved at the latest by the end of January 1998. This is the best way to ensure the schedule is met.
Schedular improvement can only be achieved with earlier resolution of the open issues.
Responses to your specific comments on the proposed schedule are given below:
Westinahouse Comment Number 1:
"The duration from " Issue FSER to Commis-sion/ Advisory Committee for Reactor Safeguards (ACRS)" to " Issue FSER" and Issue FDA" has increased nearly 2 months relative to that in SECY-97-051. The associated activities need to be reexamined with the objective of shortening their durations.
The activities are on the critical path."
The Office of Nuclear seculatory Commission (NRC) Response:
Your observation is correct. As discussed during the October 9, 1997 meeting, the ACRS is not scheduled to meet in August 1998.
However, the ACRS has examined tlys to optimize its schedule, and has indicated that it can optimize its review provid 4 the Advanced FSER is provided to them by May 1, 1998. The staff has inforV the Committec that it is the staff's intention to close all of the f
open items before it issues the Advanced FSER.
Issuance of the Advanc.ed FSER l
with open items could jeopardize the improvements to the review schedule that o
o w E IFRE CErgsg s{ y
- gq=g gga l
A em j
-"an
\\
1.11.11 I.ll.Il.li.I1.0.1
l Mr. Brian A. McIntyre November 4, 1997 this approach yould provide. The staff recognizes that these activities are on the critical path and plans to take steps (modify the FSER in anticipation of ACRS comments during the ACRS review phase) to minimize the schedule impact.
Westinahouse Comment Number 2:
"The logic tie between " Westinghouse submits standard safety analysis report (SSAR) revisions" and " Westinghouse resolves open issutes" and follow-on activities needs to be changed.
Resolution of open issues is likely to result in some SSAR revisions, preceded by SSAR markups and acceptance by the NRC. All that would remain after this step is for NRC to confirm that the revised SSAR complies with the agreed upon markups. This could be completed anytime up to the point of PDST completing its preparation of the FSER."
NRC Resoonse: The staff cannot enmplete its review until all documentation is received by Westinghouse. Westinghouse and the staff have used markups to expedite the agreement on technical resolutions; however, final documentaticn is necessary for full closure. The three morths associated with PDST process-ing of the FSER involves review of the FSER sections for completeness and appropriate references, technical editing, technical staff and senior manage-ment review of the final assembled product, and, finally, review by the Office of the General Counsel.
The addition of the verification of SSAR changes during this time period cannot be se,) ported because the activities identified above will be occurring during that pericd.
Westinahouse Comment Number 3:
"It is not clear why the activity " Staff technical review complete w/open issues" was extended to January 31, 1998 In the draft schedule of September 10, 1997, this activity ended on November 28, 1997. The only outlier that we are aware of is the inspection, test analysis, and acceptance criteria (ITAAC) revier, which does extent through January, 1998.
It would be preferable to handle the outlier separately.
The other review areas should still be scheduled for completion by November 28, 1997, to avoid adding items to the critical path."
tlRC Response: The November 28, 1997, date was established as the end date for the staff to provide FSER inputs.
In order to maintain this date, the technical staff was instructed to complete the input regardless of whether all issues were resolved.
Items where the review had not been completed because of lack of information from Westinghouse or where there was a disagreement between Westinghouse and the staff will be written as open items. Conse-quently, the November 28, 1997, date is not the review completion date. This milestone is intended to identify information for Westinghouse that the staff believes is absolutely necessary to finish the AP600 review.
ITAAC is not the only outlier. There will be a number of open items to h resolved during the December 1997 through January 1998, period because of.ae staff's resolution approach.
Furthermore, the ITAAC are an integral part of the design certifi-cation review and issues that arise in the ITAAC review may impact the conclusions reached by the staff in other parts of the safety review as well as require modifications to the SSAR. As a consequence, the ITAAC cannot be handled separately.
rg
.i Mr. Brian A. McIntyre November 6, 1997 Westinchouse CommfaL8 umber 4:
"We fully support scheduling the " Westinghouse resolves open issues" as starting on September 1, 1997. As agreed previously, the open issues will be identified and tracked separately to permit management of issue closure.
Early identification of open issues and management focus en resolution of these issues may permit some improvement on the January 30, 1998, activity end date."
NRC Response:
NRC agrees. The senedule will be changed to reflect this comment. However, it should be noted that NRC did not show open item resolu-tion starting before the end of November because it was felt that it could be misinterpreted.
Showing open issue resolution starting earlier could create the false impressica that Westinghouse had far greater time to resolve those open issues that are identified by the NRC and sent to Westinghouse between September 1, 1997, and the end of November 1997.
Westinahouse Comment Number 5:
"The Activity "PDST FSER preparation" can also be scheduled to start in September 1997.
Some FSER inputs are complete already and most should be completed by November 28, 1997. This could potentially shorten the duration from the end of ' Westinghouse resolved open
. issues" to the end of "PDST FSER preparation" frcm three months to six or seven weeks.
The critical path would be shortened by the same amount."
NRC Resoonse:
It is NRC's intention to start tha preparation of those sections of the FSER that are complete as time permits. However, the projects staff is currently involved in facilitating discussions necessary to resolve all the open issues with the goal to produce an FSER with few open items.
Given the choice of early work on FSER preparation or resolution of open issues, NRC chose the latter for two reasons. First, it is far more benefi-cial to the AP600 review to close out all the open issues before the FSER inputs are written.
Second, while FSER preparation could start on a number of sections, there are enough open issues in others to render efforts toward the early production of the FSER inefficient. Given lihiited staff resources, it is more efficient to resolve open issues.
Westinahouse Comment Number 6:
"The net effect of these suggested changes can be an improvement of as much as three and one-half months on the " Issue Final FSER" and " Issue FDA" dates.
Important intermediate dates would also be improved with the " Issue FSER to Commission /ACRS" occurring as much as one and one half months earlier."
NRC Resoonse:
The SECY-97-051 gave the following dates:
Applicant Submits Final SSAR Revisions & Documentation 5/97
- FDA 3/98 The current schedule projects issuance of the FDA in September 1998. This represents a slip in the schedule of approximately 6 months. Westinghouse has indicated that most of the information necessary to complete the AP600 review was submitted by mid-September 1997, so it believes that a more appropriate schedule slip shotid be about 3-1/2 months (May 1997 to mid-September 1997).
The May 1997, date in SECY-97-051 was the cutoff for the last and final SSAR
t Mr. Brian A. McIntyre November 4, 1997 revision. This last and final revision was to include changes to reflect the final resolution of all open issues. At that point, the staff was to start the final process of FSER development.
It should be noted that in the current schedule, there are at least two SSAR submittals that have not been received.
One of these the NRC expects to receive in the next month.
In addition, staff identification of all of the open issues will not be complete until the staff completes its initial draft of the FSER (end of November 1997). The current schedule recognizes that the FSER inputs received by the end of November will include a larger number of open issues than allowed to initiate ACRS review.
Two months, December 1997, and January 1998, were set aside to resolve the remaining open issues.
These resolutions will require appropriate SSAR revisions and consequently, the final AP600 SSAR revision is scheduled to be submitted at the end of January 1998. The elapsed time from the end of January 1998, to the projected FDA in September 1998, is approximately 8 months. The comparable elapsed time identified in SECY-97-051 is 10 months.
Therefore, the NRC has cut 2 months from the schedule. The staff does not believe that further schedule improvement can occur even assuming additional staff resources were available.
Finally, in establishing the schedule, the staff has made assumptions regard-ing the actions of external organizations outside its control, such as the ACRS and Westinghouse. These organizations could have a substantial impact on the schedule if the staff's assumptions are not met.
Sincerely, original signed by:
Jack W. Roe, Acting Director Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No.52-003 cc:
See next page DISTRIBUTION:
See next page DOCUMENT NAME: A:SCHEDLTR To rsceive a copy et this vocument, indicate leathe boa:
- C" = Copy without ettschment/ enclosure "t* = Copy with attactanent/ enclosure
- N* = No copy IOFFICE PM:PDST:DRPM
' V (A)DiPDR:DRPM l
l l
NAME TRQuay -17N JWRoei 11/tt/97 11/lC/97 DATE
~
~
~
OFFICIAL RECORD COPY l
I
4 Mr. Brian A. McIntyre Docket No.52-003 Westinghouse Electric Corporation AP600 M
cc: Mr. Nicholas J. Liparulo, Manager Mr. Russ Bell Nuclear Safety and Regulatory Analysis Senior Project Manager, Programs Nuclear and Advanced Technology Division Nuclear Energy Institute Westinghouse Electric Corporation 1776 I Street, NW P.O. Box 355 Suite 300 Pittsburgh, PA 15230 Washington, DC 20006-3706 Ms. Cindy L. Haag Ms. Lynn Connor Advanced Plant Safety & Licensing Doc-Search Associates Westinghouse Electric Corporation Post Office Box 34 Energy Systems Business Unit Cabin John, MD 20818 Box 355 Pittsburgh, PA 15230 Dr. Craig D. Sawyer, Manager Advanced Reactor Programs Mr. Sterling Franks GE Nuclear Energy U.S. Department of Energy 175 Curtner Avenue, MC-754 NE-50 San Jose, CA 95125 19901 Germantown Road Idaho Falls, ID 83415 Germantown, MD 20874 Mr. Robert H. Buchholz Mr. Frank A. Ross GE Nuclear Energy U.S. Department of Energy, NE-42 175 Curtner Avenue, MC-781 Office of LWR Safety and Technology Sar, Jose, CA 95125 19901 Germantown Road Germantown, MD 20874 Barton Z. Cowan, Esq.
Eckert Seamans Cherin & Mellott Mr. Charles Thompson, Nuclear Engineer 600 Grant Street 42nd Floor AP600 Certification Pittsburgh, PA 15219 NE-50 19901 Germantown Road Mr. Ed Rodwell, Manager Germantown, MD 20874 PWR Design Certification Electric Power Research Institute 3412 Hillview Avenue Palo Alto, CA 94303
Mr. Brian A. McIntyre DISTRIBUTION:
Letter to Brian A. McIntyre. Dateds November 4.1997 Docket File PUBLIC PDST R/F JWRee DMatthews TRQuay TKenyon WHuffman JSebrosky DScaletti JNWilson JMoore, 0-15 B18 WDean, 0-5 E23 ACRS (11) ia