ML20102A467

Requests That NRC Reconsider Position Re Future Role of Preliminary Design Approval (Pda) Application Requirements. Pda Considered Incentive for New Programs in Industry & Accreditation Important to Marketing Aspect

ML20102A467
Person / Time
Site:	05000601
Issue date:	02/09/1984
From:	Rahe E WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19277F284	List: ML20102A467
References
FOIA-84-335 NS-EPR-2886, NUDOCS 8502080392
Download: ML20102A467 (2)

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NS-EPR-2886 Harold R.-Denton, Director .

Office of Nuclear Reactor Regulatiqn U.S.- Nuclear Regulatory Commission 7920 Norfolk Avenue l Phillips Building Bethesda, Maryland 20814

Subject:

.RESAR SP/90 Preliminary Design Approval Application

Dear Mr. Denton:

i Your letter.of January 25, 1984 asked for Westinghouse's 1

acknowledgement and understanding that the RESAR SP/90 PDA and FDA~ design reviers are subject to final Commission policy now evolving relative to standardi:ation and severe accident con-siderations.

We' appreciate-the NRC's position that changing regulatory policy

. attache's some uncertainty to reference standard plant reviews at this time. We, nevertheless, remain willing to proceed with our application despite that uncertainty and, in fact, with full

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expectation that we may need to satisfy certain regulatory-requirements not now in place. This willingness stems from the

- high confidence we place in-our design and,-in particular, its

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advanced safety features and' integrated-total plant design assessment and specification.

.However, your-letter indicates an even more fundamental issue "

-than that regarding changing requirements. In particular, you- ,

. indicate'that the-very role of PDAs in a future licensing process

.is open.to question. . Our previous letter. to - you (NS-EPR- 2855) of-November 16, 1983. stated that the PDA concept remains an important incentive for industry initiatives involving major new design

' development programs and that.such initiatives are key to the future._ health of this industry. As.you are well aware, regulatory 8502080392 840816

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,Page Z l accreditation has become an important consideration in market receptivity of new design offerings, both domestically and internationally. Major development programs require major investments and involve significant lead times. Marketing activities cannot: wait until final completion of such lengthy development effort and yet are seriously compromised if regu-latory accreditation is absent.

Westinghou'se began the development program of the RESAR SP/90 in 1978 and is now at a stage where serious commercial activity is appropriate. We must have a progr,am in place with expecta-tion of near term regulatory accredita* ion. A PDA without utility (referencability for a facilit/ license application) would be of limited value to us. We request that you reconsider your position and reaffirm a continuing role for PDAs La the

. future licensing' process.

Very truly yours, O

E. Preston Rahe, JW., Manager Nuclear Safety Department-I cc:- D. G. Eisenhut R. J. Mattson 9

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