ML20008F163
| ML20008F163 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/27/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML20008F164 | List: |
| References | |
| NUDOCS 8103120422 | |
| Download: ML20008F163 (6) | |
Text
T, f/f C PBR 53 KtQ s,I t
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Mr. R. J. Gary C-
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2001 Bryan Tower U
Dallas, Texas 75201 N
Dear Mr. Gary:
SUBJECT:
LICENSING REVIEW FOR COMANCHE PEAK BY THE MECHAtlICAL EfiGINEERIflG BRANCH The Mechanical Engineering Branch (MEB) has chosen not to develop the usual Q2/ Staff Positions round of questions, btit to proceed directly to a draft Safety Evaluation Report (SER) input for the Comanche Peak Steam Electric Station review. This letter transmits the draft SER input (Enclosure 4).
We request that your staff (1) review the enclosed draft SER input, (2) prepare responses to resolve each of the open items and (3) meet with the NRC staff at a mutually agreeable time and place where your staff will present and discuss your responses and proposed solutions for each open item.
The objective of this meeting is to resolve each open item during the meeting without resorting to further written questions and answers.
In addition to our consultant, Energy Technology and Engineering Center, we intend to have appropriate flRC technical personnel attend the meeting, thrcugh and including those at the Assistant Director level. We request that you be represented by equivalent level of management and by represen-tatives of your NSSS vendor and architect-engineer so that decisions can be approved. Any necessary appeals would subsequently be handled at the NRC Division Director level.
This innovative process for the licensing review has been used by the MEB for the Grand Gulf 1 & 2, Susquehanna 1 & 2, and Waterford 3 plants and has proven to be successful for all the participants involved. We believe it accelerates the review and conserves valuable man-hours otherwise spent on extended efforts to communicate our concerns and needs for additional information. Three additional enclosures (Enclosures 1, 2 and 3) provide guidance on preparing for the meeting, logistics for the meeting, and observations on our experiences with two earlier meetings.
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Mr. R. J. Gary 2 7 1931 When your staff has had sufficient time to review the draft SER input and has prepared responses to resolve each open item, you snould develop an agenda for a meeting to close out the open items and propose to us a time and location for that meeting.
We suggest that the meeting be held at the Gibbs & Hill officies in New York during the week of April 5,1981. However, we are open to other suggestions. When the site and time have been selected, we will then issue a meeting notice. As interested members of the public may wish to attend the meeting, notice must be issued a, minimum of two wens before the meeting is held.
Please select a site wnich will not preclude members of the public from attending.
If you have any questions regarding this procedure for completing the ME3 review or the information included in the draft SER input, please call us.
Sincerely, Pf't.w a
Robert L. Tedesco Assistant Director for Licensing Division of Licensing
Enclosures:
1 Guidelines for SER Meeting Preparation 2.
Guidelines for SER Meeting Logistics 3.
Observations Based on Grand Gulf & Susquehanna SER Meetings 4.
Comanche Peak Draf t SER w/ Attachment I cc w/ enclosures:
See next page a
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Mr. R. J. Gary Executive Vice President and General Manager Texas Utilities Generating Company 2001 Br Dallas,yan Tower Texas 75201 Nicholas S. Reynolds, Esq.
cc:
Debevoise & Liberun Mr. Richard L. Fouke 1200 Seventeenth Street Citizens for Fair Utility Regulation 1663-B Carter Drive Washington, D. C.
20036 Arlidgten, Texas 76010 i...
Spencer C. Relyea, Esq.
8 Worsham, Forsythe & Sampels Resident Inspector / Comanche Peak 2001 Br Nuclear' Power Station Dallas,yan Tower c/o U. S. Nuclear Regulatory Cc=ission Texas 75201 P. O. Box 38 Mr. Homer C. Schmidt Glen Rose, Texas 76043 Manager - Nuclear Services Texas Utilities Senvices, Inc.
2001 Br Dallas,yan Tower Texas 75201
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Mr. H. R. Rock Gibbs and Hill, Inc.
393 Seventh Avenue New York, New York 10001 Mr. A. T. Parker Westinghouse Electric Corporation P. O. Box 355
,4 Pittsburgh, Pennsylvania 15230
. David J. Preister
. Assistant Attorney General Environmental Protection Division
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P. 0. Box 12548, Caoitol Station Austin, Texas 73711 h'
- 't Mrs. Juanita Ellis, President 1
Citizens Association for Sound
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'.;@d 1426 South Polk Dallas, Texas 75224
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.s Geoffrey M. Gay, Esq.
West Texas. Legal Services l-l Fort Worth..T_exas100MainStreet(LawyersBldg.),~e'.D
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ENCLOSURE 1 Guidelines for SER Meeting preparation 1.
The review branch should prepare a draft SER which describes the open issues in its review. The review branch must consult other branches as necessary if the issue crosses jurisdictional lines.
It may be necessary for these interfacing branches to appear at the SER meet.ing or to be available via conference call.
2 2.
The open issues in the draft SER should be described in sufficient detail to allow the applicant to prepare an appropriate response. The applicant should be encouraged to request any necessary clarificaticn by phone.
3.
The draft SER should be sent to the applicant by the project manager with explicit instructions that the applicant be pr,epared to meet until all the open issues are resolved.
In isolated cases resolution includes an agree-ment to disagree. This ground rule has been f'ound to be a key in setting the tone of the meetings.
4.
The applicant should prepare a detailed agenda, issue by issue, so that one may ascertain on which day a particular l'ssue will be discussed.
3 5.
The applicant should prepare draft responses to each open issue, and if t
possible, provide these to the NRC a few days before the SER meeting.
6.
It is essential that both sides enter this meeting with an open mind, ready to pursue a variety of alternative approaches for achieving the necessary level of safety.
This may be more difficult for the NRC than the applicant if we lose sight of the fact that SRp's and Regulatory Guides present one acceptable approach. There may be others equally as acceptable.
7.
The period from receipt of the draft SER by the applicant until the SER resolution meeting i; expected to average about 2 to 3 months.
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r ENCLOSURE 2 Guidelines for SER Meetin; Legistics 1.
The meeting ree shculd be as small as practical to ccafortaoly hold the participants.
It is important that the accustics be adequate to allcw a conversation across the rece.
found to be inhibiting and should not be used.A podiu: and micrcphone was 2.
We have found that the meeting runs most snoothly when chaired by the applicant.
Idaally, the applicant shculd lead off the discussion of l
each open issue by providing an oral presentatien of its pecpesed Slides and handcuts are also helpful,in this regard.
response.
3.
The meeting room shculd be 1ccated as near as pcssible to files, calcu-lations, or other supplerentary information.
performed the work in question should also be readily available.The engineers h 4
A working lunch is quite useful as'it saves tire and dcas not disrupt the ficw of thought. Box lunches seem to be adequate. NRC staff shculd reimburse the applicant for these.
5.
Phones and telecopiers shculd be readily available for contunications with the home offices. Provisions for conference calls would also be useful.
6.
Evenings should be used to caucus and werk out revisiens to positiens en both sides.
7.
At the meeting's end, the applicant and NRC should review each issue and agree upon the required follew-up actions by both sides.
il.
Typically, the issues can be closed out when the applicant ferrally makes the agreed upcn FSAR changes.
submitted by the applicant on his docket may also be adequate.Other The NRC project manager shculd be consulted.
G
ENCLOSUPI 3 Observations _ Essed On Grand Gulf & Suscuehanna SER Meetin;s 1.
The use of draft SER meetings to resolve open licesf rg issues should cut the current 18 month review schedule significantly.
Such reetings are very successful because the ground rules are quite clear; the partici-pants (including the NRC) are comitted to extend the meeting until the issues are resolved.
In practice, of the 50-60 issues discussed during tw:
SER reetings, all but two were resolved during the course of the reeting.
These two required additional inferration frcm GE, not available at the -
i caeting site.
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2.
Extended face-t:-face discussiens pemit the NRC and applicant to better
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understand each other's real cencerns and problen. We fcund the discussiens with the applicant were among the most frar.k and open we have experienced in quite sore time. Quite often we were able lo find a middle ground frca which a solution agreeable to both sides could be fashicned.
3.
Hopefully, the applicant will leave the meeting not feeling as if it had been bullied by the regulators. We believe that the applicant will better and mere carefully carry out its comitrents when the required actions are mutually agreed'upen.
4.
Such an SER meeting requires all participants to do their he owcrk.
We were told by the applicants that even its pre-meeting preparatica was valuable because the intense interaction and discussicn with its contracters gave it a better handle on its plant design.
5.
Similarly, we in the staff were forced to specifically state cur safety concerns and get to the heart of the matter. Once we did so, both we and the applicant rather quickly agreed upcn a resolution.
6.
Because we covered so ruch of the plant review during a three day period, both we and the applicant were better able to place the various issues into context.
It quickly became clear that sore issues really affected plant design while others would have negligible ircact. These lesser issues could be quickly resolved.
7.
Especially during the Grand Gulf teeting held at the Sechtel Offices in Gaithersburg, we were able to audit a wide variety of calculations and verify on the spot whether the applicant was actually meeting its coccit-This was useful and efferded the staM the opportur.ity to verify ments.
procedural details and assumptiens.
8.
We found that the applicant, AE, and NSSS supplier were generally represented by high quality persennel, both working level and supervisory. A vice-president of Pennsylvania Power & Light attended the Susquehanna meeting.
What this means is that the applicants and their contractors are willing to comit their resources if they feel that these SER ceetings will really further their review.
We believe that the staff should take advantage of this attitude and spend the relatively srall ancunt of staff resources necessary to achieve a large return in licensing progress.
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