ML22230A196
| ML22230A196 | |
| Person / Time | |
|---|---|
| Issue date: | 05/10/1978 |
| From: | NRC/OCM |
| To: | |
| References | |
| Tran-M780510 | |
| Download: ML22230A196 (1) | |
Text
ECR:TARIAT RECORDS NUCLEAR REGULATORY COMh\\lSSION IN THE MATTER OF:
STANDARDIZATION OF NUCLEAR POWER PLANTS Place - Washington, D. C.
Date -
10 May 1978 Pages l 58 ACE -FEDERAL REPORTERS, INC.
Official Reporter.;
4.44 North Capitol Street Washington, D.C. 20001 NAT!ONWIDE COVERAGE* DAlLY Telephone:
(202 ) 347-3700
DISCLAIMER This is an unofficial transcript fa meeting of the United States Nuclear Regulatory Commission held on
/{)
- I 1f' in the Commission's offices at 1717 H Street, N. W, Washington, D. C:
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determinations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statement or arg~ment contained herein, except as the Commission may authorize.
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9 10 11 12 13 14 15 16 17 18 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DISCUSSION OF STANDARDIZATION OF NUCLEAR POWER PLANTS a.-m.
BEFORE:
Room 1130 1717 H Street, N.W.
Washington, D. C.
Wednesday, 10 May 1978 The Commission met, pursuant to notice, at 10:55 DR. JOSEPH M. HENDRIE, Chairman PETER A. BRADFORD, Commissioner RICHARDT. KENNEDY, Commissioner VICTOR GILINSKY, Commissioner ALSO PRESENT:
Messrs. E. Case, W. Kane, R. Mattson, R. DeYoun_g, 19
,:_A. KenneMe,__-~-. Miller, R. Boyd, R. Fonner, 20 21 22 23 24 Ace-Federal Reporters, Inc.
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P R O C E E D I N G S CHAifil'iAN HENDRIE:
If we could come to order.
We turn now to standardization.
- welcome to all the standardizers or nonstandardizers, as the case may be.
We will soon sort out who the good guys and bad guys are here.
MR. CASE:
And we have our number one standardizer.
Yes, may I have the first chart?
(.Slide.)
We have some charts to lead us through hopefully a short presentation.
Just briefly to review where we are on this, we star 12 on this revision of our program in January of 1977.
A year and 13 a half later we still haven't gotten it approved, and we are 14 15 16 17 18 19 20 21 22 still pursuing it. We think we are at the end.
We think it should be approved.,1 And we will go through it very briefly.
The next chart.
(.Slide.)
This introduces a brief resume of what we do currentl and what the proposed policy recommends.
C(l.lM[SSIONER GILINSKY:
Could we go back to the previous slide?
(Slide.)
COMMISSIONER GILINSKY: What is it that you are at 23 the end of?
I think we are at the end of the Staf Ace-Federal Reporters, Inc.
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review to the extent we can do it.
And we are here requesting your concurrence with the staff proposals.
MR.. CASE:
We've.gone,as far-a,s-we.can go.
~E~.. DE YOUNG:
Unless we start again.
What I said was that it took a year and a half to get here.
CHAIRMAN HENDRIE:
Like Kansas City, everything is up to date and they've gone about as fer as they can go.
- MR. DE YOONG:
'!'he current practice in what we call the reference system concept with the PDA and FDA concept is the PDA term for the NSSS is three years, the PDA term for a balance of plant that mates with that is less than three years; it's tied to the expiration date of the NSSS.
The FDA concept is applicable only to plants that use the PDA.
(Slide.)
There's no forward referenceability of the FDA in any new CPs.
That is our current policy.
(Slide.)
The next slide shows the recommendations.
The term for all the future PDAs is five years.
We would extend the current balance of plant PDA's to three years without any re-review.
We would extend any three-year PDA to five years upon completion of a defined extension review.
And the FDA-1 we would make referenceable in CP and combined applications 1
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for a few years.
CHAIRMAN HENDRIE:
Now let me catch up.
(Making notes. )
CHAIRMAN HENDRIE:
Five year terms you are proposing what is a TI PDA?
MR. DEYOUNG:-:-* Terini t. Island. -.. It ties" *iirto. the.-nuclear.
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0 island.
It is a minor one; we only have one.
CHAIRMAN HENDRIE:
MR. CASE:
Right.
CHAIRMAN HENDRIE:
Match-up to GESSAR.
Nuclear Island.
And you would do these without need for a review stage in the update?
MR. CASE:
That's right.
We think we should have grante:i the three years initially.
Now we would like to go back and just extend them without any re-review.
CHAIRMAN HENDRIE:
How old is the oldest one of those things?
.M.R.. DE YOUNG:
The oldest balance of plant?
I think it was put out in May of 1976.
SWESSAR.
The PDA was put out in May of 1976.
CHAIRMAN HENDRIE:
When you say "extend to three years," what do you mean?
Well, the PDA for the first SWESSAR was
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tied to a RESAR-41.
RESAR-41 was put out in December of '75; therefore, we made the PDA for SWESSAR that tied into RESAR two years and seven months.
This is the difference from the time of the PDA for the NSSS and the PDA for the BOP that tied into it.
- we made that to expire at the same time RESAR expired.
The worst one that we have now is -BOPSSAR or the pioneer that tied into RESAR-41.
That PDA is only good for one year and four months.
We have one in-house now that's tied to the *cESSAR.
That PDA, if we follow our current practice, might be good for a day or two.
CHAIRMAN HENDRIE:
So the proposal here would be to extend the CESSAR Westinghouse BOP by about five months.
Right.-
CHAIRMAN HENDRIE:
The BOPSSA..'R.. by 1. 6 years.
That's right.
CHAIRMAN HENDRIE:
No, a year and eight months.
MR. __ DE YO~G: -~ght. _____ _
So the SWESSARS would be extended by about five months. BOPSS.AR.:Z by about one year, eight months.
CHAIRMAN HENDRIE:
Then you would extend these three years jobs to five, i.e., add two more years to them.
After the perfonnance of an extension review.
And we will be talking about that at some length later on.
What that is, how much manpower it is going to take.
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6 Next slide.
(Slide.)
Duplication concept.
The current practice is to 4
approve a design for a group of utilities that come in at the 5
same time and then that's done.
6 The recommended policy is to treat it as a reference 7
system concept.
Once we approve it, we would permit other s
utilities to come in for a five-year period and reference that 9
design.
So we would have the FDDA-1 and the FDDA-2, which would 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
,\\c::,.-Feciernl Reporters, Inc.
25 parallel the FDA-1 and the FDA-2.
We would just follow the same concept.
It is a complete plant; the NSSS plus the BOP.
It is as complete a standard plan as I think we can get and everyone has been very happy with the concept.
The Staff COMMISSIONER GILINSKY:
You don't allow others to reference it now.
No, we do not.
And we will talk about why not later, when we get into why we don't want to take some of the comments we have received on some of these proposals.
COMMISSIONER GILINSKY:
Can you give me a hint?
(.Laughter.)
DE. YOUNG:
It is, for example, two of the designs are RESAR-3 plants.
The Staff concluded its review of the RESAR-3/NSSS back in December of 1973.
It's they are not Standard Review Plan plants.
We did not review it to that
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Standard Review Plan concept that we have now.
We don't think we would like to go and permit those plants to be referenced at this time.
We think an.update should be required.
I don't think it is a big thing.
The next slide.
(Slide.)
CHAIRMAN HENDRIE:
The recommendation then applies
~'.lR. DE YOUNG:
New.
CHAIRMAN HENDRIE:
Duplication applications that would come --
In the future.
CHAIRMAN HENDRIE:
New ones.
But would not apply to --
- MR. DE YOUNG:
To the old ones that have been app~oved.
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CHAIRMAN HENDRIE:
Now when you talk about duplica-tion this way, you certainly mean SNUPPS and where else?
19 only three we have.
20 CHAIRMAN HENDRIE: What's an FDA-1 and an FDA-2 mean 22 MR. DE YOUNG:
It has the same context as we do for the 23 reference system design.
For example, the FDA-1 would be tied 24 to the PDA-1.
That regulatory requirement's cutoff date.
We Monick Reporting Company 25 haven't updated that at all.
That's the FDA-1 that applies to
8 the plants that use the PDA.
It applies to those at the OL 2
stage.
We will also permit the FDA-1 to be referenced in new 3
CP applications for a few years.
4 The FDA-2 is a design that has been updated to 5
today's regulatory requirements.
And that would be permitted 6
to be referenced in new applications, forward-referenceable 7
for a period of five years.
And that holds good for the OL's 8
too.
9 CHAIRMAN HENDRIE:
Let's say where you have somebody 10 like an architect/engineer or a vendor who is supporting design 11 and hopes to do some business selling it, if anybody ever buys 12 any*. plants again, I can see where you have.got somebody's 13 who is interested in updating and getting an.FDA-2 that becomes 14 a final, forward-referenceable, final design.
That's fine.
15 In the case of a duplicate plant, so~t of the 16 original, the authors of the concept presumably have got their 17 plants designed and they -- you do a CP review and then give 18 them a PDA -- PDD, I guess it has got to be and as far as 19 they are concerned, why that's sort of,. you know, gravy.
20 Why, then they come to operation time and they file 21 their final Safety Analysis report, you do the OL reviews, 22 those documents then become the base documents for an FDA-1.
23 Now, who comes along and is going to perfect that 24 design and update it to make an FDA-2 out of it?
Do you see Monick Reporting Company 25 that the vendor and architect/engineer concerned might go ahead
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and use -- pick that up and do that as a commercial enterprise?
The SNUPPS crew has indicated they might
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4 CHAIRMAN HENDRIE:
I see.
And they "WOuld like to have the capability 6
to do so.
They don't know whether they would, but they would 7
like to have the capability to have the same advantages as the 8
PDA.
9 10 CHAIRMAN HENDRIE:
I see.
COMMISSIONER GILINSKY:
Could you run over the ll FDA-1 and FDA-2 for me?
We put out a PDA-1.
That' s a preliminary
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13 design.
Utility comes along and references that and we grant 14 the CP.
They are building that plant.. At the OL stage, they 15 need to have a final design.
The.vendor may chose to get a 16 Final Design Approval, but that same utility can reference in 17 the OL application.
That's an FDA-1.
18 The vendor will say, it doesn't pay me to develop 19 that because you ask me 800 questions and ybu.-charge me a big 20 fee to do so.
I might as well just let the utility do it and 21 he will pay the fee.
I will not provide an FDA-1 unless you 22 give me the chance to have that reference in new applications 23 as well.
24 M_R. CASE: _ New CP appllications.
Monick Reporting Company 25
~- DE YOlJNG:
In a new CP.
10 And our proposed policy is that we will grant that 211 for a few years, and we will be talking about that a little 3
4 later on.
That's the PDA-and the FDA-1.
COMMISSIONER GILINSKY:
When you say "new CP" but 5
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MR. CASE:
But he can use it.
But he can use it. It is a final design.
COMMISSIONER GILINSKY:
Are you saying he can 9JJuse that one for the OL?
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15 MR. DEYOUNG:
He could use it*~n a reactor.
MR. CA.SE:
.Not the CP really, the reactor.
That's right. Not the CP, it's the next COMMISSIONER GILINSKY:
In other words he can 1611 complete a design of a reactor on the basis of that approval?
17 18 IV1R. DE YOUNG:
Righ.:t.
CHAIRMAN HENDRIE:
It has to the utility the desir-1911 able feature that he knows much better what all those areas 20 II may require.
21 COMMISSIONER GILINSKY:
He ought, I suppose, be able 22 II to get a combined CP /OL with that thing.
23 CHAIRMAN HENDRIE:
Well, if we had authorization to 24 II issue one, why that would be the basis of such issuance.
We Monick Reporting Company 2s II need the authority.
That authority is for a few years, as we 2 will talk about somewhat a little later.
The FDA-2 is a longer 3
period of time.
Because they update that design, they modify 4
the FDA-1 by bringing it up to today's requirements when they 5
come in with an application for an FDA-2.
If we grant that, 6
that can be used for combined licenses for a period of five 7 years.
8 COMMISSIONER GILINSKY:
So the difference is between 9
five and a few.
And a few.
COMMISSIONER GILINSKY:
And a few is not five.
- MR. DE YOUNG:
A few is not five.
Jl._ few is on the order 13 of two to three.
14 15 16 17 a few.
18 COMMISSIONER GILINSKY:
Two is a few?
Two is a few.
CHAIRMAN HENDRIE:
Three may also turn out to be MR. DE YOUNG: Three, we will be talking about tv.O 19 three later on.
20 CHAIRMAN HENDRIE:
Some people would say if you 21 meant two, you should use a couple here.
22 COMMISSIONER GILINSKY: Wouldn't it be simpler just 23 to have one system?
24 Monick Reporting Company 25 CO~..MISSIONER KENNEDY:
Or say two and three.
COMMISSIONER GILINSKY: If we are arguing -- if the
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difference is between three and five.
Just that one track.
I think we will.
I think it's going to 3 eventually be in track.
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The FDA-1 is needed more than FDA-2.
It is the policy tra.t started.
CHAIRMAN HENDRIE:
Once we come to a time where 7
in time for a construction permit you take these and reference 8
a final design, rather than a preliminary design, then from 9
that point on, why presumably they will be referencing 10 well, after a couple of years transition period -- they will 11 be referencing these five year --
FDA-2' s.
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CHAIRMAN HENDRIE: -- final designs.
And every five 14 years they will get updated and suitably modified to sooth 15 everybody's druthers.
16 At the present time, plants continue to come for 17 construction permits with preliminary designs, either custom 18 preliminary designs or the generic Staff-approved preliminary 19 designs.
20 Now when they get to the OL stage, now there is a 21 hassle over how far back you carry the Reg Guide cutoff date 22 23 24 Monick Reporting Company was
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That Is all the way before the PDA submitted.
CHAIRMAN HENDRIE:
And the FDA-1 concept is a sort 25 of -- is an artifice which will be transient, presumably in the
13 long scheme of things, to provide a reasonable accommodation 2
to the vendor needs and imperatives and utility needs and 3
imperatives and our needs and imperatives, by no means least.
4 But presumably one eventually works out of this 5
system as one comes to a point where there are final designs 6
available for referencing and utilities will hopefully find 7 that it is much more efficient from their standpoint to use 8
those when they first begin to they presumably to a much 9
greater degree then know what the plant is going to look like; 10 material list, the instrument list, and so on.
The manufacturing license, the current 12 practice requires by regulation that we specify the number of 13 units in the manufacturing license.
We ha~e provided some 14 additional guidance to determine how that number shall be 15 specified.
16 We also have specified that there will be a five-yea 17 design update of that manufacturing license design.
18 We will be talking later about why this is accept-19 able and so on.
20 CHAIRMAN HENDRIE:
How does the recommendation 21 accommodate -- I believe we have had communication from your 22 friends in OPS saying, wait a minute 23 24 Mo;.,ick Reporting Company MR. DE YOUNG:
They are happy with what we have done.
What this proposal is.
They are satisfied with what we have 25 done.
j eri 14 14 Next slide.
(Slide.)
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Replication.
The current practice is to allow a 4
period for replication of about 2-1/2 years after the base 5
plant SER is put out, the Safety Evaluation Report by the 6
Staff.
7 The recommendation is to define that as three years.
8 And we have defined the qualification review required. for 9
replication.
10 Next slide.
11 (Slide. )
12 13 14 CHAIRMAN HENDRIE:
What do you mean "may be less if standard design is referenced"?
It means we have a standard design, as this 15 slide shows.
That there is a consistent five-year approval 16 towards the standard design.
17 CHAIRMAN HENDRIE:
Okay.
18 If Roger wants to replicate your plant, which 19 referenced the standard design, you don't get a free extra 20 year ride because of the replication provision over the standar 21 plan approval terms.
22 23 24 MR~ DEYOUNG~
Right.
MR. -MATTSON: _ --:- no back-door extensibn of the* PDA.
or FDA _thr9~gh replication.
Monick Reporting Company 25 MR. DE YOUNG:
Or any other means.
15 COMMISSIONER GILINSKY:
Is there a difference in 2 the review that you get -- what I have been harping on?
As I said at the last rreeting we had, I think
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4 at the beginning of the standardization policy it was true that 5
when we got the first few standard plants, they received a 6
more in-depth review, much more.
We said we were going to do 7 it, we assigned our senior people, our best people to it, and 8
they did it.
9 As time went by, as our re.cords have indicated, 10 it is rare that we get a non-standard application any more.
11 They all either are PDA's or they refer to one of the PDA's or 12 standard designs.
So it is becoming the norm for an in-depth 13 better review than we did when standardization started.
I 14 don't think we are there completely, but we are heading very 15 rapidly in that direction.
16 The reviewer it is hard to tell when this is a 17 custom plant and this a standard plant.
It's getting so routin, 18 we are beginning to use the standard review plan to the same 19 depth that we use it for any review now.
20 So I think that the thing we started with about 21 three years or four years ago when we did these reviews, it 22 was a distinct difference, but that difference is eroding, 23 24 and they are coming closer and closer together.
We are not there yet.
But we are getting close.
Monick Reporting Company 25 We have a consistent five-year approval term
16 for all the standard designs.
And the policy would prohibit 2 unintended extension of approval terms.
And we have defined 3 the review matters for the qualification to replicate, qualifi-4 cation to duplicate, and for the PDAs.
We will be talking about 5
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those later.
It's just a brief description of current policy and what we are recommending.
(Slide.)
The next slide shows the current questions.
It was 10 an anti-trust matter that we had to look into.
There was a 11 matter of the fees.
Even though the fee matter is not tied 12 into this statement that we wish to get extended, they are 13 related.
And we have been asked to address that at the end of 14 this policy discussion.
So we will be talking about these 15 after we get through with the statement talk.
16 The current questions.
Also there is one about the 17 FDA period, whether it is two or three years.
Then we have a 18 set of comments on the Office of Policy Evaluation.
We'll go 19 through these one by one.
20 (Slide.)
21 The next slide is anti-trust.
We contacted the 22 Department of Justice in January of this year.
Early in 23 February we provided them with copies of our Staff report, that 24 large report that we had, and copies of the proposed statement Monick Reporting Company 25 that we provided to the Commission.
We met with them after the
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had a chance to read.it, we talked to them about them, we 2
answered many questions.
After that, there were periodic phone 3
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8 conversations with our anti-trust group, and then on the 20th of April, we received a Department of Justice letter.
(Slide.)
The next slide indicates that that letter that we received, there were no new concerns that the Department of Justice people were able to detect beyond those indicated by 9
the Staff.
They also commented that the Standard Design 10 Approval concept that we proposed to look into further, it is 11 not part of this policy package that we have before you now.
12 But they said that this Standard Design Approval 13 concept would essentially eliminate the anti-trust concerns.
14 We agree with that.
15 We have modified the statement on pages 2 and 9.
16 We provided you with copies.
It is indicated in purple_ink 17 or blue ink or something.
A few modifications to the proposed 18 policy statement.
that indicate the Department of Justice 19 help to us.
This has been reviewed by the anti-trust people 20 on the Staff and they agree with it.
21 (Slide.)
22 The next problem we had was the FDA-1 forward 23 24 Monick Reporting Company 25 referenceability.
This two to three year problem.
The Combustion Engineering wrote a lette~ one time to the office director and the next time to the Chairman of the Commission,
18 with concerns they had that the period proposed by the Staff 2 of what they termed two years -- it is not two years -- was too 3 short.
It is inadequate.
They said five years forward 4 referenceability was justified and three years would be accept-5 able to them.
6 After reviewing it and talking to other various 7 people involved in the standardization program, we have agreed 8
to extend our period by one year.
That doesn't mean_it is a 9
two to three period extension.
And the next slide will indi-10 cate that.
ll (Slide.)
12 The seven-year term was our initial position.
And 13 on the top of one of those lines, it shows the PDA goes out, 14 the PDA is extended, the PDA expires, and at the end of seven 15 years, we would terminate any FDA-1 that might go out.
16 Combustion Engineering assumed that the FDA-1 would 17 go out the day the PDA expired, and if it did, in that unlikely 18 event, there would be a two-year period of forward reference-19 ability.
We expect, if we do the review as promptly as we have 20 21 done the standardization reviews, that it might go out sooner.
And we have always said two years for that review.
22 Combustion Engineering is concerned that we may not 23 get that done for a long time, and they are worried about the 24 Staff extending its review period.
But we think, from what we Monick Reporting Company 25
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19 have, the records we have, that we can do it.
And if we do get it out before the PDA, the FDA would be good, according to our chart, for 2~1/2 years with out current position.
We have 4 modified it to' include another year.
So FDA-1 would expire 5
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eight years after the PDA issues.
And we also permit the FDA-1 to be referen~ed in any application from the day it is docketed to the day it expires.
According to this chart, that would be a period of 5-1/2 years.. Combustion Engineering has indicated to us they would still p:r:-efer if they had a firm three-year period at the end of the thing because they are concerned that we may* not get the review done.
The Staff is concerned,*as-it has happened in a few cases, that the vendor may not want us to get the review done for one reason or another.
They are dragging on one specific technical matter.
Rather than r~solving it, they hang up the review and we just don't get it done.
So I think what we have done is a good compromise*. between the Staff's concerns and the Combustion Engineering concerns.
There is not a full three-year period at the e~d of it.
There might be more, there might be somewhat less; but we have extended it by one year beyond what we had previously.
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would have three years from the time you actually the FDA, in
20 the sense that the applicants, the utilities, may not buy the 2 design if the thing is still under review?
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 MB.. DE YOUNG:
They want a firm three years after we put it out.
See, our predictions say with this new policy, they will have three and a half years, if they get that review done.
If the Staff and the vendor get it done, they will have more than three years.
If because for some reason the Staff and the vendor can't get the review done, there must be reasons and that period may be less than three years.
MR. KENNEKE:
When would-the first *onE/have to be q.ocketed to meet the schedule, on real time?
Well, the first one is supposed to be docketed --
we only know of one FDA-1 that we are going to get and that's from Combustion Engineering.
That is why they are writing the letters.
That's expected to come in this summer.
The PDA was put out less than 2-1/2 years ago, so it should be roughly about 2-1/2 ye~rs after the PDA was put out they will be in with the FDA-1 application; maybe a few months later.
They always have problems getting the final product book put togethe.
But it's not too far from this schedule that we have put down.
___ -~- _:__~--_~-=--::_Would J;:J:i.~e_];)e an_a,Qcep__tance_r:eview,- _too?* _
There i_s an acce:i;~_-)::ance_ review.
We have never had* any problems with the acceptance reviews for the Ace-Federal Reporters, Inc.
25 Combustion plants.or Westinghouse plants, not too many problem.
21 We have changed the statement to modify one 2
word on page 10, from "two" to "three." It's another change we 3
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6 have made in the statement.
Continue.
(_Slide.)
The next slide indicates a set of comments that we 7
received from the Office of Policy Evaluation.
One, they would 8
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25 propose that we extend PDAs to five years without any re-review.
Secondly, they would propose that we put out preliminary duplicate design approvals for the currently approval dupli-cate plant designs.
They have some concern,,about the manu-facturing license design update period.
On replication, they think it should be a five-year term versus the proposed three-year term by the Staff.
They are very concerned about our capability to discipline our requirements at the OL stage.
And finally, they had a comment on anti-trust that I think has been resolved. We will talk about each of these OPE comments following.
CHAIRMAN HENDRIE:
Let's see, the manufacturing license design update period was the problem.
CHAIRMAN HENDRIE:
The number of units and the time to start these and so on.
Now, do you think you have covered that --
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comment.
v7e will be talking a little bit about each Next slide.
(Slide.)
To extend the PDAs without a proposed review.
This 6
was considered by the Staff in its study and we have contacted 7
various segments of the Staff when we developed the policy.
8 It was considered and was rejected.
9 If we can slip to the next slide.
10 (Slide.)
11 Basically, the problem was that the standard designs 12 that we have were done prior to the standard review plan being 13 14 15 16 17 18 19 20 21 22 23 24 Ace-Federal Reporters, Inc.
25 effective within the Staff.
These are the dates for the standard designs and SWESSAR there stands for three PDA designs They all have the same date.
The Staff SER input, that's when the Staff review was done, this is very much concerned in the thing, this is three months to the favorable ACRS letter.
Much of the review has been completed well before this statement.
So these con-servative dates show that the top five would be done well before the Standard Review Plan was issued.
That line indicate the. Standard Review Plan was put out in late November of 1975.
Even after that the remaining plants, much of the review of Q-ls and Q-2s were done to almost standard review plan, but not quite; they aren't quite -- we can't quite say
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For this reason we believe we should hold to, require some updating review that we will be talking later to bring these up.
Not all the way, but bring them up.
If we can go back to the prior slide?
(Slide.)
We believe that it would be bµrden to do so; but is not excessive from the industry people.
We will be talking about this when we talk about fees and resource requirements later on.
And finally, CHAIRMAN HENDRIE:
When are you going to talk about the proposed scope of review?
later. At the end.
It will come into it at the end.
I think its place is more suited.to the fees.
CHAIRMAN HENDRIE:
Also affects us to see --
Oh, yes.
MR.- KENNEKE:
Dick; can we*goback -- actu?-lly to ~e next chart where you had the timing of the standard designs.
Yes, go ahead.
Next chart, Brenda.
(Slide.}
- . MR. KENNEKE:
The SRP was issued effective late '}S, right?
1**-.*~. DE YOUNG:* November, 75._
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25 24
. MR. KENNEKE:
When was work fir9t beguh:on*the.Standard Review Plan?
tffi.. DE YOUNG:
Oh, I -w:,uld say about two years before that, roughly.
MR. KENNEKE:
1972?
No, 1973.
~-
CHAIRMAN HENDRIE:
About the beginning of '73.
JYIR. DE YOUNG:
At a. low-effort :p3.ce.
MR. KENNEKE:
And the first.GESSAR/SER, was December '.74, so that would be roughly two years, not quite two years after the beginning of that effort.
Now the effort was not to really guide the reviews that were going on.
The effort was to develop a standard review plan that people could agree on within the*
Staff that would be the standard review for all the plants.
It wasn 1 t utilized instantly.
Many of the people that develope parts of Ehe Standard Review Plan, for example, thought that this was their last chance to get dreams into it.
We have been in the process lately of eliminating some of the dreams.
It was impossible some of the requirements couldn't be met.
It was beyond the capability of the technology.
So it wasn't totally consistent with the practice that we were using.
People as late as a year ago have told us that, gee~
they didn't know they were supposed to follow the Standard Review Plan.
Actual reviewers.
So it has only been about a
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25 25 year after the Standard Review Plan was put into effect by putting it out and then routinely beginning to make sure that the Staff was placing it into routine use.
COMMISSIONER BRADFORD:
Dick, what do you mean when you say some of the requirements were beyond the capabilities of technology?
Nell, the Standard Review Plan, some of the reviewers thought, now, we have to put it down on paper.
This is all we are going to be required to be able to look at.
This is going to define our review.
So they said, it's the last chance to get some of the things that we might want to look at, that once we put it down on paper, we are not going to be able to deviate from this, so let's put some things that we think should be looked at, we don't know quite how to do it, but
-things that we think we should look at.
Some of that got into the Standard Review Plan
- It has been in the process of being eliminated because we recognize that the technology is not there and we can't do it.
It is impossible.
COMMISSIONER BRADFORD:
Can you give me an example?
J\\1R.. DE YOUNG:
The one I knew about best was in the hydrology area and I can't quite do it, I can't recall it now, the details.
And we don't have the personnel here.
We have been in the process of revising the Standard Review Plan and these are being eliminated.
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25 26 Office letter No. 9, for example, that we talked about sometimes, was recognized in that it states that we will eliminate unnecessary things that are not possibLe to do, things like this.
It began to be recognized that there were things in the Standard Review Plan that should not have been there.
It was a tremendous step, but it wasn't a complete step and it wasn't perfect.
COMMISSIONER BRADFORD:
What is the status of the Standard Review Plan?
Is it the equivalent of one of -- is it Commission-approved?
No, it is staff-approved.
The Staff states that a plant that conforms to the Standard Review Plan is safe enough to equal license status.
It does not necessarily mean that a plant that does not conform to the Standard Review Plan in every respect is not acceptable to license.
It just means that we have to look at that and determine the justification for that deviation from the Standard Review Plan.
COMMISSIONER BRADFORD:
How does it relate to a Reg Guide?
- ---~------------------
_MR. DE YOUNG:
It includes many of the Reg Guides as criteria for acceptance.
Branch Technical Positions, the same way.
It includes those.
It references them as part of the Standard Review Plan.
CHAIRMAN HENDRIE:
In principle, it is a cup lower
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25 27 of document in terms of hierarchy of standing coming down from the laws, the Commission's regulations; Reg Guides have a wider circulation in the agency, and more particularly, outside the agency, before they are adopted.
And they are *scrubbed exten-sively through the ACRS and outside comments and so on.
The Standard Review Plan is more --. (inaudible) associated Branch Technical Position stated in the more nearly representative sort of, in a sense, the eternal views of the reviewing staff as to what the standards are.
I don't know what their practice is, :there.are, of course, public comments taken on those things, but not nearly the degree of circulation that a Reg Guide has.
They are more nearly a Staff -- strictly a Staff document.
- :MR. DE YOUNG:
Yes.
MR. KENNEKE:
Were ther~ any aspects -:=
0 when' therevJew plan-was built -- that would be essential to licensing added in the course of the Standard Review Plan?
Compared to those that were reviewed under the old system?
- -MR. DE YOUNG:
Roger1 _are yoU:~,::---:--*
MR. MATTSON:
I can't hear the question.
can you restate it?
MR. KENNEKE:
Is' there anything ~~,: when the Standard-'-
Review Plan did come into being, was there anything added in the way that was essential to safety that was not included
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25 28 in the reviews of the old plants under the less --
MR. MA'ITSON:
How do you want me to answer that question;
~----------
yes and no.
Answer is yes c!Dd no.
.MR. :MATI'SON:
Some in the sense of just writing it down for the first time; some in the sense of changes to the review process.
MR *. CASE:. For instance; s~?-a,rd Review P_lari requires Reg Guide 1.6, which is the spectrum to be used in designing against earthquakes.
Before that we didn't use that.
We require it now.
So the answer is that doesn't necessarily mean that plants that don't have that Reg Guide are unsafe, because there might have been compensating measures in damping factors.
CHAIRMAN HENDRIE:
There were also plants where we cranked up the equivalent of that spectrum before the Reg Guide was adopted.
That's right.
~
CHAIRMAN HENDRIE:
It was around for a long time._
before there.was a Reg Guide.
It's, in fact, a complex question.
MR.- MATI'SON:
This is -an attempt *to get some of that complexity out.
By saying here, at least, all standard review plans approved, even though changes continue tq occur, they are at least all starting from the base.
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25 II 29 CHAIRMAN HENDRIE: But it is also true that even for the earliest of those things, and we started in on GESSAR back in '73 or something like that, people knew they were taking a pretty hard cut at something that was going to stand for a number of plants.
There wasn't any doubt in anybody's mind on the Staff along the lines, well, this is just a little exer-cise that doesn't matter much.
Some of which sentiment seems to have been the difficulty with the earlier reviews and things like RESAR-3 that dated back to two to five years before that.
- MR. DE YOUNG:
-Pre-standa:):'."dization..
CHAIRMAN HENDRIE:
So, in fact, those reviews were pretty hard fought enterprises.
And I think there is -- I think you really have to look very carefully at the update review requirements.
-We agree.
CHAIRMAN HENDRIE:
Everybody likes to think, well, we will just run down these things and touch them up and so on.
Jv,!R.. MATTSON:
That's not what we. are posing, iJir.>Chair~
- --~~ -
man; he's going to have a slide later.
It says,"Category II and Category III Reg Guides pursuant to the regulatory require-ments review committee's mark on those categories of guides,"
and list the Category I's and tell us where you stand.on those today.
There is no requirement to meet them; just where ~o you stand.
CHAIRMAN HENDRIE:
Well, I think it might be useful
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25 30 to bring that portion of the discussion forward and search it out.
All right.
CHAIRMAN HENDRIE:
OPE's concern, and I share it, in part has to do with how precisely one can define a reason-able level of update review.
And then hang to it.
And the_:r concern always is that once you start, why you are in for a full review from soup to nuts, and to the extent that there is some confidence that what is contemplated is, you know, a reasonable minimum, essential update, with good-understanding:~
of':what :ought to be *done and what is not to be included, why that helps considerably.
Brenda, we WJuld like to proceed to the last seven slide*s.
It begins with "PDA extension review."
The slide that she is going to put up, that you have in your sets of slides near the end, seven from the end, the PDA extension review matter.
Why don't we go into review?
There are four things we are going to review to some extent.
The RRRC, I think you know what they are, and as they review any new matter proposed by the Staff, they categorize it.
The Category 1 matter, the RRRC said, we will place this requirement on all future plants.
It is forward-fitting; no backfitting requirements whatsoever.
The Category 3 matter is we are going to place this on all future plants and, in addition, we are going to require
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25 31 it to be backfitted in its entirety on all older plants, in its entirety.
Category 2 matter that isn't between the two says it will be placed on all new plants and it will be placed on all previous plants to the extent that it is necessary and practical to do so.
Then there is another category that we call an NRR Category 4 matters.
These are matters that we have become informed about.
COMMISSIONER BRADFORD:
Let me just ask you about the interplay between the words "necessary" and "practical" in that.
Does that mean that if it is necessary, but it isn't practical, we don't do it?
COMMISSIONER BRADFORD:
It's "necessary or practical'!
v-fuere it is necessary.
There is some hope that the parts may not be necessary because the design of that specific plant, while it doesn't exactly adhere to the require-ment that we have approved, it is an alternative design that
(
is equally acceptabl.e.
And it may be partially acceptable.'
CHAIRMAN HENDRIE:
I think a better answer is that if a feature were considered absolutely essential for a plant for the public safety, it would be in Category 1.
If it is Category 1, it ain't that way.
Three, by their definition.
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25 MR. MATTSON:* Absolutely necessary is Category 3.
-~_MR.. DE YOUNG:
Category l says forward effect.
CHAIID'JAN HENDRIE:
I've got it backwards.
MR.* ivlATTSON: - The scale has been changed. - -
32 COM.MISSIONER BRADFORD:
So the words ".necessary" in Category 2 means, sort of necessary, plant by plant.
- MR. DE YOUNG: It means that certain things will be required but they may be there.
It doesn't exactly have to adhere to the regulatory guide, which defines a way to meet a requirement MR. CASE:
And it takes i~to*-accourit how-far.. th~y-are*
in the design or in the construction.
You take the practical factors involved into account.
In a sense, you do a value imp:lct judgment on the requirements taking into account where they are, how much it would cost, how much you gain for safety.
The Ratchet committee can't do that because it depends on the plant's specific features; it is just too much for them to do.
They have done some-of it on Category *3s.
They have got enough to know that on this, they have got enough information to make the decision for the Staff, backfit in its entirety.
But on most of it, there is so much informa-tion to get and so many evaluations to make that they can't possibly do it and they refer to the Staff.
They will review what the Staff does with that information later.
MR. KENNEKE:
Wheh the _oomrtri:ttee decides an :i:tern is:**'
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25 33 Category 3, when is that implemented?
And how is it imple-mented'?
Well, we will be talking about that shortly.
Whenever the committee acts, we are -,.,.c.th:1=.sponsoring group for that position,.. that proposal, once the committee approves*it generally begins to implement that approved posi~
tion.
They got theirs approved by the RRRC and they begin to implement that. position in all ongoing reviews they have.
Now the backfitting requirements that they leave to a program, develop for backfitting considerations, the Category II is the same way.
As soon it is approved, the sponsoring group says, I got it through, I got it approved, I got to implement it.
MR. CASE:
The point that *Al is~ bringJ,.ng.up, we do ---
we start implementing for the reactors that are under review.
But for those that have.already been reviewed, we are in the process of developing a program for doing that, but we haven't done it yet.
So we have this backlog of Category 2's and 3's that should be applied to applications or operating plants that are not in the review process.
But we haven't had the manpower or the procedures to develop a system to do that.
MR. KENNEKE:
But they have been* publicly known for some tim~, right?
They have published in positions, or at least as far as the Guides are concerned?
- MR. bE YOUNG: ** They ha.ye_ bee~_ J?Ublicly *known~
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25 34 MR. KENNEKE:
In. :the s_pecific. caie of the PDA extensions, why couldn't they be picked up in the course of your review of the FDA-1 application, to the extent it was an essential then?
MR. CASE:
You have to ptck.. it Uf) as part.of* the-PDA.~
extension MR. KENNEKE:
No, you-are defining that situation.* Why couldn't you pick up any things having to do,*that affected the design and as Category 3, in the course of your FDA-1 MR. DE YOUNG:_,I,t*will be.
- Sut not.everyone who. has a PDA is going to submit an FDA-1.
Only one of the 11 PDA holders has indicated a strong intent to submit an FDA-1; only one.
context of a formal extension review process?
Why not a direct tie-in to these --
I had wanted to go back to the previ-ous slide.
We talked about there is not an excess burden on the vendors to do the review.
And then the other point that we wanted to make, the strong point, was that in developing this proposed policy, we had involved the Staff to a larger extent than we had before.
We had to talk to them about it, what we were going to do.
We also talked to the ACRS on several occasions, kept them up to date; we have general accord with what we are going -- agreement as to what has been
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25 35 proposed.
Now if we change that and say instead of doing a review to extend the PDA, 's, we are just going to do it, I think it would delay the policy -- I think ma:hagement*would feel obligated to go back and to explain why we are doing this and the basis for it to the Staff and to the ACRS.
And that's the problem we see, that if we automatically come out with a new policy that says, "Exten them, put out PDDA's for the old duplicate plants," :r think we would have adverse reactions within the Staff.
And I think some of the ACRS might feel bad and tell us that, you know, that's a big change, we might not agree with that.
We would have to go back.
And that was the other point I wanted to make about why we don't believe that we can change the policy now.
I think it is important to get the statement, after a year and a hal.f.
I think we have general agreement with all bodies that we have talked tb about the adequacy and accept-ability of what we propose.
And I think it is time to go --
-~-. CASE*: _ ~ 'can answer your ~estion now. _ You* could.
do it outside of the PDA review, but if you haven't done it, you have to do it during the PDA extension review.
If you have an PDA extension review.
Okay, let me go on to the NRR Category 4 for just a second.
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-1vffi.. DE YOUNG:
I haven't explain~ _....:_.
- MR. MA'ITSON:*
I think *there is a point here -about the -
practicality.
Let's assume we extend the PDA's without review, with the Category 2 and 3 reviews.
We have already said they are going to have pay the Category 2 and 3 penalty sometimes.
So.when does that mean they pay it?
Those people who would purchase that PDA in its extended period?
It means they would pay it 7 or 8 years from now, after they have::poured concrete, after the steel is erected, and you have got a severe backfit problem.
It's better to pay the penalty now in the design stage of that PDA, that is update it so that you don't have to pay it eventually after the thing is set in concrete.
You have already made the decision they got to pay the penalty.
It is whether you do it on paper or whether you do it in concrete.
It is much cheaper to do it now.
lYIR *. KENNEKE:
These 2 's and 3-' s--have been around for sometime.
We'-11 be-going into this in th_e next set -of -
slides.
MR. MA'ITSON:
-- maybe new ~cons~~liorj p~ts, appJi:-:-
cations since those 2's and 3's have come out.
We have not portended an enormous backfit problem that didn't exist already.
'- IvIR. KENNEKR:
Are* you tal)<µig about these who "are -afcfected -
by the existing PDA's, right, those having to pay the bill to
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25 37 fix them, to upgrade them?
_MR. CASE:
They hav~ tp pay l'.'etrQ, right?
- MR~ - KENNEKE:
And those Categories 2-'s and 3' s have been there, you have outlined them in your statement?
MR. MA'ITSON:
A number of them have been picked up in the course of routine licensing of the plants in-house at the CP stage.
We are going to find that some of them have already picked up.
The point is that there is no systematic docu-mented program to check them off one after another for every plant out there.
That's the program that Case has described.
CHAIRMAN HENDRIE:
I wish you would work on through these slides quickly.
MR. KENNEKE:
Can I ask one 5{Uestion on ca,t~gory -4 _; tli.ose -
are the review items, correct?
Category 4 are those matters that have*
come to attention rather recently.
The Staff has not had the time to prepare the package for the review of the RRRC, and the Staff is doing so.
But in the interim, they get the division director approval and the office director approval to '
use these in ongoing reviews.
Any ongoing review, we will trea these measures.
Category 4 measures are such things as grid stabilit, overpressurization protection; things that have come up because of operation or people leaving the Staff or comments or any-thing that we are addressing, it takes time to get the package
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25 38 prepared for RRRC consideration.
In the interim, we have said on every ongoing review, we will consider them.
So that's a Category 4, NRR_Category 4.
It has not been reviewed by the RRRC; it will be.
_:-MR~ -*KENNEKE=----ThB--*end *-result'"of,-using mem~in-reviews-:- would --- -
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be in effect a Category 1, 2 or 3 requirement on particular applications; is that right?
~MR: -nE'-YOUNG:*---y~s.
- -*~~-.
I*ffi.-~*-KENNEKE :---so-they-*rea-J.ly ~are* subclividable--at-<tne--en-a.-**---._ -~* --*
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into one of the other three.
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Category 2 or 3, or the division director or the office directo wouldn't think they were important enough to implement.
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forward fitting type, we '11Duld
_. just go through the Ratchet, it may take several months but just wait.
CHAIRMAN HENDRIE:
Have you got a slide, I want to look --
M."t:U
- DE YOUNG:
. Next slide.
(Slide.)
Last time we were down, we talked, we tried,to take a look at needed resources for manyears, and the top one was m
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25 39 guess after talking to a few people on Staff as to what in man-years would be required to extend these PDAs.
CHAIRMAN HENDRIE: Futu:r-e decisions.
!1.R. DE YOUNG:
The one before that.
Neede.1 resources and manyears.
MR. CASE:-
The slide - -before that;.Bill.
(Slide~)
MR.
- DE YOUNG:
We sriowed the -1: in : for: a total on the top line there, the manyears that I, after talking to a few people, had expected might be required to do these PDA extension reviews.
We took a look after we met with the Commission a few months ago and said, what would be kind of the upper limit to that?
Maybe we are wrong, maybe something will take longer than we think.
And,the next slide shows that it could go --
(Slide.)
- . MR. CASE: _ I guess. it is fair-to i:;;ay __ that IT¥ idea of how to budget has changed over that period of time.
I think I budgeted in the past too much on target schedules and hopeful expectations.
And it hasn't worked out.
So I have become much more pessimistic.
". COMMISSIONER -BRAJ?FORD:. _Realistic.
~- DE YOUNG:
As a rough upper limit we took the number of PDA's, we multiplied it by the requirements that we thought each division might have to put in, multiplied by an overhead factor of.4. and came up with 27 manyears to do the PDA
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25 40 extensions.
I think that is a real upper limit.
(Slide.}
The next slide shows the accumulated RRRC decisions as a function of the month in which they were made.
In Categor 3, as you can see, they add up --
CHAIRMAN HENDRIE:
Cumulative now?
These are cumulative for category 3, 2 's and l's.
So it shows that not all of them will be applied to all of the PDA's.
(Slide.)
The next slide we took a look to see which Category 3's and which Category 2's might apply to which PDA.
And the only number wrong in there is the number 4 under Category 2 for GESSAR Nuclear Island, that should be 11.
CHAIRMAN HENDRIE:
The top one.
And you can see that the RRRC decision, Category 3's are for balance of plant requirements, NSSS requirements, utility requirements; and they are not all applicable to every PDA.
(Slide.)
The next slide, we tried to do an assessment weightin1 them to see what kind of equivalent r_eviews might be required. I We weighted them for the extent that the design, and we weighte them for the PDA age, which would mean not all of these
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25 41 considerations would have to go into it.
And then we found a total weighted value.
And we thought the equivalent of the worst review we would have to do is about 5.4 of those equivalent reviews.
(Slide.)
We took a look, on the next slide, at what that might mean.
DPM, we think we can do at one review with a quarter of a manyear on the average.
DSS thinks they may need _one manyear, one technical manyear.
DSE, for their part of it they think they may need a quarter of a manyear.
That's a total of 1.5.
We multiplied by the overhead factor and get 2.1 resultin~ instead of the 5 manyears that I had shown you last briefing,.. about 11 man years.
I think this is probably more realistic than the 5 and much more realistic than perhaps the 27 upper limit.
That's the_.-_
RESAR system.
That's the type of review, the type of matters that we would be reviewing on these PDA extensions.
We would also like to say that we had a comment from OPE that we did not put on that we could swallow the resources within present manpower.
I think it is difficult.
I just -- you know, the resources that we are talking about, I think it is impossible.
We just are not there.
We haven't done any wor~ since we met with you on the last two occasions,
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42 with respect to the Standard Design approval route that everybody further.
a lot of people are indicating we should pursue There are some things.we have to do that we haven't been doing.
And manpower, we can eat just so much manpower requirement.
CHAIRMAN HENDRIE:
Art, for the resource questions, I think I'd rather deal with in connection with the discussion that we will have to have about that subject.
I'm more interes -
ed right now in the policy statement on standardization.and getting on with that.
You figure a manyear and MR DE YOUNG:
DSS.
CHAIRMAN HENDRIE:
A direct manyear and a half.
It is not a trivial review.
How long do you think it will take in months?
Ne did that study, too, previously and we came up with about eight months.
Because of the delay in getting the policy out and getting the applications in for the PDA extension, we have made one more change to the proposed statement, on page 7, to reflect that the review may extend beyond the PDA extension date.
We just had to put a few words in there to recognize that if we don't get to these extension reviews, we may have to extend them, why we are doing it for 25 good cause, by the director of NRR.
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I 25 43 CHAIRMAN HENDRIE:
Are the PDA holders going to have to file applications?
The PDA holders have all filed applications for PDA extensions.
They did so prior to the date when the new fees CHAIRMAN HENDRIE:
Is that all they have to do until you begin to look at them?
They don't know what to do.
We have not informed them specifically of the review matters.
They know they are going to have to do something. They are kind of aware of some of the things on the Category 3's and 2's.
But they are not specifically advised that they will have to treat all of these matters.
MR. CASE:
Well, obviously.t!:1eCornrnission h_asnit made a decision yet so they don't know exactly what.they would have to send in for such a review.
CHAIRMAN HENDRIE:
Let's go back to the place we were.
If we can go back to the charts, to "Extend the PDAs without proposed review."
(Slide.)
I think we are done with that.
The next one.
(Slide. )
Issue PDDA's for the current duplicate designs.
The Staff proposal, as I said before, is a major change that was
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25 44 not indicated to be needed by anybody that commented on it.
It was a Staff-initiated change.
It's a significant change to change over from what we had been doing on the SNUPPS-type of thing, considering them once then that design was done, to the present proposed policy to take that approved design and extend the period to which it might be used for f+/-ve ¥ears, treat it as a PDA-type of design.
We think we have gone quite some length --
CHAIRMAN HENDRIE:
Well, not really.
Because you have proposed that this apply only to hypothetical new dupli-cate designs.
That is what we are going to get --
CHAIRMAN HENDRIE:
-- if your policy is adopted, when they come into the house, so the Staff reviews them know-ing that they will in fact have a five-year PDDA credential attached to them and from the Staff's standpoint, they will be indistinguishable from newly-submitted standard desjgns in for first PDDA's.
So I must I don't find that -- I find it difficult to discern concession here.
- MR. DE YOUNG:
As I said before I the review -
.:.MR. -CASE:*.:.._ C(?~cession, it was in.itiativ~_.__that_ came from the Staff.
It wasn't industry initiative.
We think we have shown some imaginative thinking here.
I w:iuld also like to say that I think as I said before, that any application coming in is getting
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25 45 about the same review now, whether or not it is a duplicate plant design or a custom design.
It is getting the Standard Review Plan review.
CHAIRMAN HENDRIE:
Look,-:there are three -- there are these three things that are working in the shop and have been for some time.
That's the next slide, please.
(Slide.)
CHP..IRMAN HENDRIE:
What would it take to get those to a position where we are willing to issue a five-year PDDA?
MR. DE YOUNG: I think bring it up to the current new typ::
requirements.
MR. KENNE.KE:
They wi3:1 come in for an-FDDA~ a __ final approval, right?
They will be in for a final approval based
--*-----------~----
on the old regulatory requirements cutoff date.
Quite some tim ago.
_MR.--KENNEKE:
So by the same_ logic, -you couldn't extend--
the FDDA concept to them when you got through the OL reviews?
No, we could not.
- , MR. KENNEKE:
By your logic?
-_ MR. CASE:
That's right.
I think the situation is "worst" because tw::,
of the three plants, approved plants, are RESAR-3 plants.
And there has been quite some concern about extending the period of
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25 46 approval of a RESAR-3 plant from December of 1973 on.
They should be updated.
I think the Staff is ready to do it and knows what has to be done.
Westinghouse is.
And from our discussions with SNUPPS, for example, when we first told them we were considering this, they said that's excellent.
- MR. KENNEKE:.. How.about* the Cherokee-Perkins?
how about?
MR. KENNEKE:
Ts i;t possible todistinguish-among*thern?
,;,Jell, Cherokee-Perkins, of course, is the most recent but it is tied to the CESSAR.
If we require CESSAR to update, how do you not require the mating portion of the plant to update, too?
I think it is the same problem.
I think.we should -- what's past is past.
We did something witb it.
To bring it up in today's requirements, *r )l:!.hink would satisfy the Staff, *the ACRS, and them.
It would make a more viable, salable plant.
It's a current plant.
It's a Standard Review Plan plant.
I think it's good policy to let what has been done stay.
And go forward with the new policy.
CHAIRMAN HENDRIE:
Would a review, an updating review of the genera'l t_hrust of the one proposed for PDA extensions serve to make these duplicate designs acceptable?
I don't think so, because of the two RESA..~-3 plants.
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25 47
- MR. KENNEKE:
vvhat's with the RES.AR::-3?
~- DE YOUNG:
RESl>..R-3 hurt us. It hurt the Staff. It got dissension within the Staff.
It took quite a bit of resolving And I don't think. we should extend the RESAR-3 plants beyond what we have now.
It's just something that we should put behin us.
MR. MATrSON:
It might make sense to think along these lines for CESSA~where the design is currently active in the vendor's shop.
The RESAR-3 design is active only in the sense of pneparing in for OL's for those RESAR-3 plants.
Westinghous in fact, has moved on through several iterations of their standard plant.
RESAR-414, of course, being the more recent, at the CP stage.
Given~the CHAIRMAN HENDRIE:
Well, the 414 is a larger --
RESA.R. -3S is the standard plant for RESAR-3.
The RESAR-41 was the first Westinghouse plant that wasn't salable because they made, in my opinion, too many design changes that did not sell.
They changed that 41 --
CHAIRMAN HENDRIE:
They backed down to what, -the41? - Or *whatever?
The 414.
But the second RESAR standard plant was the RESAR-3S, to which the RESAR-3 design standardized.
CHAIRMAN HENDRIE:
Yes.
Now how much different would the SNUPPS plants look if you put a 3S nuclear steam supply in them?
Enough so that
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25 48 much of the architect/engineer's safety-related work changes?
, MR. MA'ITSON:
Tli.ere are* significant difference?, yes_, :::sir.
--- ----~-----------"':-- ----------
In steam generators, elsewhere in the design.
It may not require as much hardware changes as we think. But we would have to do the evaluations to show that they are acceptable.
I don't know.
I would not guess it would be a simple task.
CHAIRMAN HENDRIE:
Is there any inclination to do such an updating and then carry that as a standard RESAR?
- MR.* MATTSON:
That's what we said from the start;- that * -
this was an idea and it was, nob, ~uggested by the industry.
We thought it looked like a good idea for the future, if someone would care to use it in the future.
The suggestion that~.
we update old duplicate plant design was one I think came from OPE~
. Within the last month or so~ -
MR. DE YOUNG: Ne never really considered it. They were too old, two plants with RESAR-3 plants in them.
We didn't give it a thought.
We just thought it was wrong to perpetuate a problem that had developed.
- . ME. KENNEKE:
'lliey all meet ~the basic_ regulatio~?.
- -------------------- -~- ------
.Absolutely.
MR. -KENNEKE:
What*is the essential qifference then-be1=,w~~!'l_,.,c:;;.cc "_
them as referenceable for standard designs in something that
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25 49 would not be in terms of safety benefit?
- MP.. DE YOUNG:
- I think v-B have made changes.
In the interim
,l I I had the standard review plan get issued.
They are doing things now routinely that MR. CASE:
Do you want to say. s6fflething? -
MR. MATTSON::~ Yes, I got to say something.
I get a lot of direction about discipline of the review process, standardization of the process, and adherence to the.Standard Review Plan.
And I think we do a pretty good job using that Standard Review Plan and exercising reasonable management discipline in the face of an enomous anount of standardiza-tion options.
And we either mean standardization or we don't mean standardization.
If we keep reinventing review processes, and to go back and say to reviewers who have never used the Standard Review Plan on RESAR-3, I'm going to somehow invent this yet another option under the standardization program, and forget all that stuff I told you about the Standard Review Plan, we are going to use this special procedure which, oh, by the way, I haven't defined yet, but it is something differ-ent in Category 2's and 3's, I simply can't exercise management discipline in the faces of those kinds of options.
No one has proposed that option.
No one thinks it is economically reasonable for them to propose that option.
It ought not to be considered.further.
I can't in the face of all of those options exercise discipline.
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25 50 MR..
- BOYD:. One. further point on that~-
For those older* * --
plants, by now, almost, the statute of limitations has run out.
If someone came in today and wanted to replicate Byron-Braidwoo,
as Marble Hill wanted to replicate them two years ago and successfully did, we would say, no, the statute of limitations has run out.
You are 2-1/2 years since the SER is over.
And replication is just another concept of duplica-tion, standardization.
Whatever logic drives us that way in the standardization policy should drive us the same way in this consideration.
It's just an argument.
CHAIRMAN HENDRIE:
Let's progress down the slides.
Next slide.
(Slide.)
The next slide talks about replication. _ And),.the proposal from OPE is to extend the period from three years that the Staff proposes to a period of five years.
Initially replication was considered by the Commis-sion to be an interim concept between what we had and the standardization program.
The initial experience was extremely poor, very poor.
The experience has been improving.
On the basis of that improving experience, we thought we should keep the concept as part of the standardization package.
We didn't see the need to have a major term increase at this time.
We did say in a report that on the basis of the accumulating experience, we would consider a term change at a
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25 51 later date.
Again, we have the problem that we have discussed this matter, that general agreement with the ACRS and the Staff and if we change now, we will have to -- we are almost obligated to go back.
(Slide.)
CHAIRMAN HENDRIE:
Move very rapidly.
1>1a.nufacturing license.
N.hy we took the :p:isi-tion we did, we haven't -- we have no experience with it now.
We thought we should have a design update period of five years, consistent with the other standard designs.
We talked to OPS -
we are not the only ones that are concerned with keeping a standard design inviolate.
They are, too.
They say, we think five years is.about as much as we can swallow.
We'll probably have changes to that floating nuclear plan~ and five years is acceptable to us, too. They want to have the chance to come in with changes.
So it is not only the Staff being held to its rigid discipline, the utility is also being held and they will pile up changes that they would like to make.
And a five-
/
year period is consistent with what they think is right for the floating nuclear plant.
MR._ KENNEKE: - Dick, _o~e guest1on-:dn that.
There* is a difference in the MLK's from the other designs.
The other designs can be built in parallel.
But in the case of ML, it is on an assembly, you go one at a time.
You only have so many underway as of five years.
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It's not totally ass$Tlbly line. _ They als_o have, I forget what they call them, but component packages that go --
MR. -KENNEKE: _ But it- -is moving basically on an-assembly-*-_ --
line situation.
The main platform is moving on the assembly line.
__ MR. KENNEKE: - -The point:* is they are -built. in series, -not in parallels.
That's right.
1'-1:R. KENNEKE:
Not only :that,* but they are final designs_~
No, they are not.
MR-KENNEKE:
As being built._
They are the final design, but it is not that final design that we approved.
-_/'."]R. -KENNEKE:
Yqu_~an they" don't begin to build-~tiiyou
- -~ -
issue the ML, in which case MR. DE YOUNG:
Just like a CP.
We have not approved the final design for a CP; we havenot approved the final design for an ML.
We approved a preliminary design for that manu-facturing license.
MR. KENNEKE:
But when you issue the ML Is so that they could begin to build
, MR~ ~DE YOUNG:
That is not the final design~
an approved final design.
It-is not
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- MR. KENNEKE:
They will actually -begin to bU:ild ~ith--a -preliminary--
It's just like a CP.
They will actually begin to build the plant, to construct the plant prior i::o our approval of that final design.
-,.MR. KENNEKE:
- When do they have to come back for the final design approval?
Prior to the operation of the plant.
The next slide.
(Slide.)
The other comment was they voiced strong concern abo our capability of controlling the matters that we would re-revie at the final design stage., The Staff throughout ourreport and 13 prior presentations have stated our reqognition that this is 14 15 16 going to be a problem.
We know it.
We recognize it.
It's also an industry problem.
We don't know what changes industry is making to their standard designs.
We have 17 talked to a few of them.
We think they are controlling it.
18 19 20 We don't know, and we won't know until we see the final design package.
We have been successful at the CP stage.
It hasn't 21 been easy with the Staff.
The discipline has been there.
We 22 think we can be successful at the OL stage.
We intend to give 23 24 Ace-Federal Reporters, Inc.
25 it the best management shot to control this.
And the control, again, is by the Standard Review Plan and the RRRC.
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25 54 (Slide.)
The next slide is a general summary.
The Staff-recommended policy has been developed with care and due regard for the Commission, the Staff, the ACRS and industry needs and practices. The OPE suggestions, if accepted at this time, could lead to strong adverse reactions.
It would lead to further delay in implementation of any changed parts.
(Slide.)
The next slide indicates that we would recommend approve the proposed policy with the simple changes in the statement that we have indicated in the colored boxes.
And lastly, if we can proceed to the next slide, we can talk about the fees, if you wish, Mr. Chairman.
(Slide.)
CHAIID'l'..AN HENDRIE:
I propose to not deal with the fee question at this time.
And whatever is said about it, it will have to be some comment on the policy statement, draft policy statement, that the fee question will be considered at the Commission at a later time.
I must say Staff worked hard on this and it~rated it a number of times.
I share some of the sentiments OPE has suggested about concern about being able to define and stick to a limited review and so on.
I also recognize the Staff side, the review staff side of the picture and the concern about extensions without looking at things that get to be several
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25 55 years old.
On balance, I come down in favor of the proposed policy statement of the Staff on standardization.
I had.hoped, do you remember originally, that there would be a lock on this about the first of the year and we are very considerably past that now for several reasons, not the least of them was my plunge down. a hill in Canada.
distractions as well.
But there were a number of other I
If. yo'l;l feel you have the matter well enough in hand,------
why not take** a vote of the quorum present in approval of the proposed standardization statement?
Peter, do you feel able to vote on this matter or would you prefer not to at this time?
COMMISSIONER BRADFORD:
I would be prepared to say I am inclined to a degre*e you have already expressed, but I prefer.,: not to cast a formal vote.quite yet.
CHAIID-'T.AN HENDRIE:
All right.
I will propose to run the thing on the current sheet, Stan,.. *.. and see, __ if we can do it that way.
Now the question of fees associated with these things gets to be a complex one of, in part, balancing with the new fee schedule with the Commission and, in part, making a transition from a time when we have not charged fees for t:h.ese reviews to a time in t~e future when we will charge fees for these reviews.
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25 56 MR. CASE:. Cornpli9ated by the fact that when we put together the fee paper, we didn't have PDA extensions in mind.
It was developed later.
So that it really was not focused on in the fielding at all.
r'lR. DE YOUNG:
I might say~ had received the extension request from every PDA holder prior to the time when the fee rule went into effect.
Admittedly, that one of the purposes of that was to avoid a fee.
Which shouldn't be a surprise to any one of us.
CHAIRMAN HENDRIE:
Well, I have some concern about whether or not we are going to have any continued requests for extensions or support from people in answering questions and so on, if they discover there is a $50,000 tag for these reviews, which is the price you would have charged for a PDA in the beginning.
The fee under the current rule requires a pay-ment for one of these equivalent reviews is' something like
$150,000.
If it's two manyears, it's well beyond what they paid for the fee for the PDA itself.
CHAIRMAN HENDRIE:
Really, you are treating it as a special MR. DE. YOUNG:
Special project... It's well d~fined as a
- special project in the rule, and that says, you pay what it costs to do the review.
CHAIRMAN HENDRIE:
It seems to me that that ought to
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4 57 be -- Staff ought to take another look at that.
The last time we came around recommending fees,_ it was a recommendation to consider it a special project.
I will regard a special project fee on these things.
If we expect it to run in the neighbor-5 hood of $150,000, the Commission may as well now vote that ther 6
will be no standardization policy of this Commission because 7
such a fee -- establishment of such a fee is totally equivalent 8
to that sort of a decision.
9 So I think some way to make that transition in a 10 different way is essential.
11 I can't conceive that what purports to be an upgradin 12 review for PDA, in which the manpower investment with the 13 14 15 16 17 18 19 20 21 22 23 24 Ace-Federal Reporters, Inc.,
25 whole thrust is very considerably less than the,original scope of the PDA review, can in any justice, you can go and charge the guy three times what the damned PDA itself cost.
Okay.
J'.v'.IR. MILLER:
Mr. Chairman, actually the* *PDA, I think you -
are misunderstanding.
PDA itself costs an average of $500,000.
CHAIRMAN HENDRIE:. What do we c~ge- __ the Applicant?.We-charged him zero, right?
MR. MILLER:
In the-past,--that's right.
There.werc-e n9 0 __ _
fees up to the time CHAIRMAN HENDRIE:
The policy that is set down here in the Commission's fee schedule is to charge $50,000 on
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25 58 application.
- MR. MII.JER: - __ Rj.ght.
CHAIRMAN HENDRIE:
The balance of the total fee then gets worked out over sales of that design and is paid by utilities down the line.
So in the future people who get the full scope PDA review, the vendors, will pay $50,000 for it; okay?
'<*. :MR. MILLER:
~And then 20 perq:mt*on each sale.
CHAIRMA.'N" HENDRIE:
On down the line if there are sales.
. MR. MILLER:
Right.
CHAIRMAN HENDRIE:
What I.am saying now is that vendors are being asked for an update review of considerably less magnitude to pay something which is estimated in the
$100- to $200,000 class.
I'm saying that's just simply unreasonable.
- MR. MILLER:*
If, in fact.,. the nl=1ffib_ers_jJ1at_ Dick just gave -:.
- you -were ':"'.-roughly a..rnan-year would be $60- to $70,000.
If thP.ir manpower estimates are correct.
$140,000.
saying.
MR~* C.~SE:
Two man. years.
CHAIRMAN HENDRIE:
Two manyears is how much?
,.MR. MILLER:
Two rtlari: years -:Wh_<?uld be about =$150, 000 CHAIRMAN HENDRIE:
Well, that is what I have been
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25 59 MR. FONNER:
Mr.- Chafrman, under the license fee -rule as it is currently written, the Commission does have the authority to exempt people from the payment of fees.
And it is clearly within the Commission's discretion to do so.
There is one other way we might find them acceptable and that is define those app~ications that were provided to us complete enough to start our extension reviews.
As far as the vendors knew, there was nothing they had to add.
They knew there was something coming down the line called Category 2's and 3's or 4's.
But *they weren't specifically aware of it.
They thought that that application -
MR. CASE:
Right.
And, of course, that was.just the -
Staff's view.
There were other views, including one expressed by OPE, and._itmight have turned out to be just a simple piece of paper was enough.
i-iR. ~E-YOUNG:
Right.
_Well, we will investigate. that* again.-
CHAIRMAN HENDRIE:
The Commission has to go_away, but I really think a revision of that recommendation on the fees for this thing would be helpful to the Commission.
These two items on the morning's agenda which we will not hear at this time will go down in the afternoon.
(Whereupon, the hearing was adjourned.)
J