When the U.S. Nuclear Regulatory Commission (NRC) first published regulations to combine the construction license and operating license of nuclear new-build plants into a single permit, the process of preparing a submittal represented a moving target, to say the least.
For utilities, the COLA process (combined construction and operating license application) blended two separate regulatory thresholds — construction and operation — into one. The combination improves predictability. This way, utilities can avoid the costly problem of being in the midst of construction should the NRC determine a problem when evaluating the operating application, a common occurrence in the previous application method.
Black & Veatch assisted Detroit Edison (DTE) with its COLA for the utility’s proposed new advanced-design nuclear unit, Fermi 3 at the existing Fermi 2 nuclear site in Michigan. It was a two-year process.
Black & Veatch’s COLA submission on behalf of DTE consisted of more than 10,000 pages of documents. Black & Veatch stayed in constant contact with the NRC during this time. The main reason for this close working relationship was that the COLA environment was only partially defined at its start. As Black & Veatch was compiling massive amounts of site-specific data, the NRC was refining its own processes to accept applications.
“It was clear that the Black & Veatch team had to be highly adaptive if we were going to start a project, execute it for a year, receive new criteria on how success was going to be measured and still meet our performance metrics with DTE at the end of the two-year execution,” said Rob Crandall, Black & Veatch Project Manager – Nuclear Services.
In the months leading to the COLA submission, Black & Veatch worked closely with experts on electronic information deliveries, software experts – including the software author – the client and, of course, the NRC.
There are 11 parts to a COLA submittal, and an element of Black & Veatch’s role was to put together all parts into a cohesive application. The scope of the work included a detailed Environmental Report (ER) that assessed the environmental impacts from plant construction and operation; the Final Safety Analysis Report (FSAR) that addressed the site and plant development for site-specific systems and analyses; and the Emergency Plan.
Black & Veatch and its subcontractors provided site development, hydrological, geotechnical and seismic investigations and analyses associated with the proposed technology design for input into the FSAR and ER. Field reconnaissance, wildlife and aquatic surveys, cultural resource evaluations and land use planning were also undertaken for ER input.
The FSAR and ER also included historical meteorological data for the region, considering severe weather patterns, average precipitation patterns, average temperatures and an assessment of how the weather patterns would affect the facilities.
The Emergency Plan covered the onsite and offsite response to assess a potential radiological incident/accident for the protection of plant employees, the general public and surrounding environment
It's All About Relationships
When Crandall reflects on the project, one of his key takeaways is strikingly non-technical.
“One thing that I learned was that for all of the engineering, all of the environmental work, all of the evaluation of it, and all of the regulation of it – it all comes down to people and relationships,” Crandall said. “It demonstrated to me that the real value of project execution was the way that Black & Veatch organized the contribution of a variety of participants inside the company and outside, to a successful conclusion years from when we started.”
The NRC has granted DTE its COLA, but with that comes a laundry list of checks and balances that the NRC will need to see closed out before the plant construction begins, Crandall said. The NRC continues to monitor these follow-on actions so as to permit the safe operation of the plant upon its completion.
“Detroit Edison is still proceeding, and we remain involved with various ancillary studies, the addressing of NRC questions and its requests for supporting documents,” Crandall noted. “The review process goes on for a few years, and Black & Veatch continues to support those responses.”
COLA Submittal Passes NRC Scrutiny on First Attempt
The U.S. Nuclear Regulatory Commission has an ambitious electronic submittal process for the combined construction and operating license application (COLA) – one so rigorous that the smallest of missed details can kick the whole proposal back. Black & Veatch became the first company to have its COLA, submitted on behalf of Detroit Edison, pass the electronic system’s scrutiny on the first attempt.
The NRC’s meticulous COLA standards not only governed what information is included in the application, but how it is included. For example, figures and tables in the document must appear at a resolution that would electronically reproduce to the level required by the NRC submittal requirements. Thus, when the NRC scanned the massive document for figure resolution, if any one figure did not meet the dots-per-inch threshold by the NRC library requirements, evaluation of the submittal for the docket would be delayed. Client expectations were tied to timely docketing of the submittal.
“We had numerous discussions with the NRC – not merely at the supervisory level, but at the technician level with those who were responsible for accepting the submittals,” said Rob Crandall, Black & Veatch Project Manager – Nuclear Services. “We vetted the process before we submitted the COLA rather than let the process vet our document as it was submitted.”
Subject Matter Expert
Rob Crandall: CrandallRA@bv.com