Review on first COL application shows learning curve just beginning


Jenny Weil, Washington
15 October 2007
Inside NRC
Volume 29, Issue 21 English
(c) 2007 McGraw-Hill, Inc.

NRC staffers said last week they were hitting some bumps in the initial review of the South Texas Project Nuclear Operating Co.'s application for a combined construction permit-operating license, or COL.

But STP officials said they expected snags in this trailblazing effort and that they would work with the staff to deliver whatever documentation was needed to get the technical review rolling.

The application, a 200,000-page document submitted on a single DVD, was filed on September 24. But the staff did not start its "acceptance" assessment to determine whether there is all the information it needs for a full-blown review until the start of the new federal fiscal year, on October 1.

The staff and STP officials met October 11 for the first public meeting since the application was filed - the beginning of more than a dozen others expected by the end of 2008. NRC staffers outlined several issues during the meeting, including a lack of supporting documents for at least two sections, outdated data for one section, missing figures for another and, in one instance, the absence of state emergency preparedness plans that were cross-referenced in the application.

STP officials took the staff's feedback in stride. Greg Gibson, STP Nuclear Operating Co.'s manager of regulatory affairs, emphasized the sheer volume of the application, which includes 375 sections. "If we need to supplement the application, we will," he told the staff. But he said STP believes the application is sufficient for docketing. Meantime, he said, the company is working on a revision and expects to submit it in early January. "We are the first [applicant], and there are going to be a lot of lessons learned," he said. "There are areas where we thought we hit the target, but we didn't. We're happy to augment our application however we can."

One lesson the staff already discovered is that the DVD was too large to upload to its electronic library Adams. The information had to be broken up into files of about 50 megabytes. The agency released the document October 11.

In a description of its plans, STP projects it will take 108 months to complete the COL application review and build the two proposed General Electric ABWRs. The schedule estimate is per unit.

It said it expects to cover the operating costs of the proposed STP-3 and -4 for the first five years largely through the sale of electricity from power purchase agreements. It expects 70% of the units' generating capacity to be under contract and the remaining 30% to be sold on the open market. It said that NRG Energy, the majority stakeholder in STP Nuclear Operating Co., already has "negotiated three term letter agreements with purchasers."

The two units would be built on the site of the existing two-unit station, in Matagorda County, Texas, about 100 miles south of Houston.

The project has been driven by NRG, which owns 44% of the twin 1,333-MW PWRs and, as NRG President/CEO David Crane has said, also provides the "strategic [direction], funding and business acumen" for the operations. It is still seeking partners for the two new units but expects the city of San Antonio, a 40% owner of units 1 and 2, to sign on with STP endeavor, and has said others have expressed an interest. Crane said it is using the same operating company model for building the new units because the company has the proven "technical horsepower" for the project.

NRG has made clear that it does not intend for the COL application review to be a licensing exercise, unlike NuStart Energy's soon-to-be filed Bellefonte COL request. NuStart, a consortium of 10 electric companies and two vendors, chose the Tennessee Valley Authority site in Scottsboro, Alabama, where two partially finished PWRs were mothballed in 1988, as the lead application for the Westinghouse AP1000. But TVA has indicated it has no near-term plans to move beyond licensing, which had been a source of frustration to the late NRC Commissioner Edward McGaffigan, who wanted the industry to put forward a lead application for a project that was intended to be more than theoretical.

NRG chose the ABWR, rather than a newer design, because four of the reactors have been built in Japan, and two units are under construction in Taiwan. Although the design was certified by NRC a decade ago, NRG wants to update the control room to a digital system. Trying to adhere as closely to the original ABWR design control document while modernizing the technology has been a challenge for STP. It expects the digital instrumentation and control room to be modeled after the Lungmen design in Taiwan.

"We are not starting from scratch," Tim Hurst, principal I&C engineer with STP, told NRC staff at last week's meeting. "We want to make this an evolution from what's already been built."

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