ML062640042
| ML062640042 | |
| Person / Time | |
|---|---|
| Issue date: | 09/15/2006 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| References | |
| DG-1145 | |
| Download: ML062640042 (11) | |
Text
DG-1 145 PRE-WORKSHOP 7 COMMENTS COMBINED LICENSE APPLICATION INFORMATION REQUIREMENTS During the first 6 workshops on Draft DG-1 145, the timing and applicability of information requirements were discussed in several technical areas. Industry addressed these requirements in several pre-workshop and "Blue Card" comments. During Workshop 5, the Staff commented that COLA guidance should identify the information required for a reasonable assurance finding vs.
what information would be available at the time of application. Industry presented tables at Workshop 6 that identified several instances where the information required is either 1) not appropriate for a COL application or 2) not available at the time of application submittal but would be available later.
The following revised table identifies examples of information requirements in these categories identified in the draft-for-comment version of DG-1 145 published September 6, 2006. Revisions to the earlier table are shown in red and italics. It should be noted that the examples are typical and the availability of information may vary for different applications. Further review of DG-1 145 may result in additions to the table. The table is draft but it provides a basis for further discussion of these issues.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID 1.02-1 C.1.2.3.3 C.L.2.3.3-1 B (4) Submit 2 consecutive years of met data. 1 year prior to Submit 1st yr with application, NRC states approachacceptable but text submittal, 2nd 2nd year as COLA still requires2 years data prior to complete after supplement docketing. submittal 1.03-1 C.1.3.6.3(1)(a) C.L.3.6.3-1 P (3) Submit types of materials and material Types of materials Submit material types DELETE specifications (including heat numbers), and specifications for w/application, heat numbers for base metals, weldments, fittings and most components available on site before fuel safe ends. available by load for inspection Removed Heat numbers. application, heat numbers available during construction 1.03-2 C.1.3.6(3)(b) C.1.3.6.3-3 P(3) Requires application include material Representative Submit representative properties including toughness (J-R properties available properties with application; curves), tensile (stress-strain curves) data at application; as-built as-built material properties at temperatures near the upper range of properties available available on-site before fuel normal operating temperatures. during construction. load for inspection.
Accepted per App. I but text not modified.
1.03-3 C.1.3.6.3(2)(a) C.I.3.6.3-5,-6 P(4) This section requires that the application As-built drawings will As-built drawings would be include as-built drawings of pipe be completed during made available as they are geometry, etc. construction. Design completed on site for Accepted per App. I but text not modified. piping isometrics inspection.
available in application.
1.03-4 C.1. 3.9.2.4 C.L.3.9.2.4-1 P(5) This section implies that the pre Applicable to follow Provide results in COLA.
operational flow-induced testing of reactor on plants. Provide internals would be complete at the time of results of operating COLA. Based on the workshop plant testing.
discussion, we understand this applies to later plants referencing results from an operating plant.
Clarified in App. I but text not changed.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WSI Summary Description Availability Proposed Review Approach No. Blue Card ID 1.03-5 C.1.3.13.1.4 C.1.3.13.1.4-1 P(5) Requires preservice inspection test Test requirements, Provide requirements in results. criteria available at COLA, test results available Accepted per App. 1 but text not changed. COLA. Results onsite during construction.
available during construction.
1.04- C.I.4 C.I.4-2 B(2) First bullet, first slide. This bullet For COLAs Reference the DCD for the 1DELETE (presentation) identified the COL Information item that referencing a certified application. Submit License any changes to the referenced design be design, the fuel Amendment Request when identified to the Staff. As discussed in the design in the generic the final design is complete.
workshop, the final fuel design and DCD is the COLA loading pattern may not be available until design. During after the application and possibly after the construction, the final COL is issued. In this case, the final design and loading design would be submitted as a license pattern will be amendment request under the Tier 2* developed.
change process after the COL is issued.
Does the staff agree that the design in the generic DCD is the required design until the license amendment request is approved, and the COL may be issued based on the approved fuel design described in the generic DCD?Accepted 1.05-2 C.1.5.2.4.1 C.I.5.2.4.1-2 P(5) This section provides a list of information Some of the items Provide available information, DELETE required to be included in the application. are available at remainder will be available on Four of the 9 items would not be available COLA, others will site during construction.
at COLA. become available Accepted during construction 1.05-3 C.1. 5.3.2.2 C.L.5.3.2.2-1 P(5) Section requires a comparison to Operating procedures Provide requirement in COLA DELETE operating procedures. will not be available that procedures will address Accepted at COLA. limits.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID 1.06-1 C.1.6.2.3.4 P(5) Section requires test results and periodic Testing will not be Provide test requirements in DELETE C.l.6.2.4.4 updates for containment tests complete at COLA or COLA.
C.1.6.2.5.4 Accepted before the COL is issued.
1.06-2 C.1.6.4.5 P(5) Section requires test results for Testing will not be Test requirements provided in DELETE habitability systems. performed until after the COLA. Test results Accepted the COL is issued. available onsite as tests are completed.
1.08-2 C.1.8.3.2.1 C.I.8.3.2.1-1 P(5) This section requires battery Design requirements Application to include the characteristic curves to be included in the for safety-related design requirements, battery application. batteries would be characteristics to be available REJECTED. NRC wants before license is available at COLA. on site as they become issued. available.
1.08-3 C.1.8.4.1 C.18.4.1-1 P(5) Section requires description of Functional General description in COLA, DELETE procedures and training. requirements for remainder available for Accepted operator actions inspection during available at COLA construction.
1.08-4 C.1.8.4.1 C.I.8.4.1-2 P(5) Requirement to identify local power Requirements for Describe requirements in sources and transmission paths that could AAC sources can be COLA, contracts for AAC be made available to resupply power described but supply to be developed plant following a SBO.REJECTED. NRC transmission and during construction and wants info before COL issued. power sources may available on site.
be under the control of a TSO and not available at the time of COLA.
1.10-1 C.1.10.2.3.3 C.1.10.2.3.3-1 P(3) This section requires pre-service General requirements General requirements to be DELETE C.111.1.10.2.3 B(5) inspection procedures and acceptance for the procedures, included in the application.
criteria for turbine rotors. including acceptance Procedures and acceptance Accepted criteria, would be criteria made available during known at the time the construction.
application is filed.
Procedures and criteria would be developed during
COL INFORMATION TIMING DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID construction.
1.13-1 C.1.13.1.2.1 C.1.13.1.2.1-1 P(3) This section requires an applicant to General organization Provide general organization DELETE provide an organization chart for the description available in the application, make operating organization. The detailed for application, detailed org chart available organization won't be known at the time detailed description for inspection during the application is filed. A high level available during construction.
organization chart would be available then construction.
and more details filled in during construction. This position is consistent with SRP 13.1-13.2, Rev. 5 dtd 7/05 Accepted 1.13-2 C.1.1 3.5 C.I.13.5-1 B(3) The introduction to this section requires General description General description in COLA, DELETE identification of persons (by position) who of the position and remainder available for are responsible for writing and approving experience inspection during procedures. This level of detail would not requirements for construction.
be known at the time the application is procedure writers and submitted. approvers available Accepted at time of application.
Specific responsibilities would become available during construction
COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability ProDosed Review ADDroach No. Blue Card ID 1.13-3 C.1.1 3.5.2.1 C.1.13.5.2.1-2 B(3) Guidance requires that each procedure Procedure types Classification of types of DELETE performed by licensed operators be could be classified. procedures could be included identified by title and included in a in the application and the described classification system. This details developed during level of detail will not be known at the time construction and available for of application. inspection.
Accepted 1.13-4 C.1.13.5.2.1A C.1.13.5.2.1-3 B(3) Requires identification of the groups The part of the Part of the organization responsible for procedure development, organization responsible identified from maintenance and format. This level of responsible would be the high level organization detail would not be known at the time of available and the chart in the application.
application.Accepted per App. 1 - text not details would become Detailed assignments made changed. available during available on site as they are construction. defined.
1.13-5 C.1. 13.5.2.1 C.1.13.5.2.1-2 B(3) Section 13.5.2.1, third sentence: The The general content COLA would include a general format and content of each class will be available at description of the general of procedures should be described. the time the COLA is content of each class of Accepted per App. 1 - text not changed filed. Format would procedure. Writer's guide be developed as part avail;able during construction.
of a writer's guide after the COL is issued 1.14-1 C.1. 14.2.2 C.1.14.2.2-3 P(3) SAR should describe how and to what General requirements Submit general requirements extent the applicant's plant operating and for plant staff in COLA, detailed procedures technical staff will participate in each participation defined available for inspection on major test phase. prior to application; site prior to to Accepted per App. 1 but text not changed. detailed requirements commencement of preop defined in procedures testing.
prior to commencement of
.preop testing
COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID 1.14-2 C.1.14.2.4 C.!.14.2.4-1 P(4) The wording in the section implies that the Admin Control The COLA could contain a DELETE details of administrative control procedures will be description of the procedures will be known at the time the developed during requirements for development COLA is submitted. construction. of these procedures and the Accepted procedures would be available on site as they are completed.
1.14-3 C.1.14.2.8 C.1. 14.2.8-1 P(4) This section requests a description of how Recent operating and The COLA could include a operating and test experience is test experience would comitment to review incorporated into the development of test be reviewed just prior operating experience and the procedures. to writing the test test procedures would be Accepted per App. I - text not changed. procedures during available on site as they are construction. completed.
1.14-4 C.1.14.2.11 C.1.14.2,11-1 P(4) This section requires that each "test" The test procedures These test procedures would required to be completed before fuel load and even a detailed be available on site as they or designed to satisfy ITAAC should be listing of the tests are completed.
cross referenced and provided with the would not typically be application. available prior to Accepted per App. I - text not changed. COLA 1.14-5 C.1.14.2.11 C./. 14.2.11-3 P(4) This section requires the sequential test The detailed test Test schedules will be DELETE schedule for each SSC be provided with schedule would not available on site as they are the application typically be available completed.
Accepted prior to COLA.
1.17-1 C.1.17.5.1 C.L 17.5.1-3 B(3) This section requires that the planned Decisions related to General QA program sharing of personnel between units be sharing personnel requirements described in the addressed in the COLA. REJECTED would not be finalized COLA. If a decision is made at the time of COLA. to share personnel, it would This level of detail be documented in should not be administrative procedures required in the COLA prior to fuel load.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WSI Summary Description Availability Proposed Review Approach No. Blue Card ID 1.17-2 C.1.17.6 ???? P(3) This item requires a listing of SSCs A general description Provide a general description (1.1.5) explicitly mentioned in the EOPs. EOPs of how the EOPs will in the COLA. EOPs and the will not be available at time of COLA. be addressed in the requested listing would be NOT ADDRESSED Maintenance Rule available on site for program available at inspection during the time of construction.
application.
1.17-3 C.1.17.6 C.1.17.6-4 B(3) General content issues for the COLA. General description General description in COLA, DELETE Guidance included requirements for of the program remainder available for information on several aspects of the MR including inspection during program that would not exist at the time of requirements construction.
application. available at the time Accepted of application. Other aspects would be developed after the license is issued.
1.17-4 C.1.17.6 C.1.17.6-7 B(5) The site personnel qualification and General position Provide general requirements DELETE functional descriptions level of detail is descriptions would be for positions in the application much greater than that specified in available in the and detailed procedures C.13.1. For example, the listing includes application. Detailed would be available on site as titles like Shift Supervisors, Shift position descriptions they become available.
Technical Advisors, Reactor Operators, would become etc. instead of licensed operators and available during non-licensed operators. construction.
Accepted 1.17-5 C.1.17.6 C.1.17.6-8 B(5) This section requires detailed training General training General requirements DELETE procedures for Maintenance Rule requireents would be discussed in the application, personnel. available at the time detailed procedures available Accepted of COLA. on site as they become available.
1.17-6 C.1.17.6 C.1.17.6-9 B(5) This section requires detailed descriptions Program Program requirements DELETE of site procedures and database requirements provided in COLA, detailed descriptions for Maintenance Rule consistent with the descriptions available on site implementation description in C.IV.4 as they become available.
Accepted available in the
COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID application.
1.18-1 C.1.18 C.I. 18-1 B(5) This section states that by the time of Fewer than 11 Application will describe DELETE application, the first 11 elements should elements will be completed elements. Others be complete. complete. Those not will be available as completed Accepted completed in DCD during construction.
are covered by DAC.
11.01 C.I1.1.4 C.l. 1.4-1 B(4) This section requires that the PRA The plant design will The PRA should reasonably 1DELETE realistically reflect the actual plant design not be complete at reflect the plant design as it at the time the COLA is the time the COLA is exists at the time the COLA is subm itted.Accepted submitted. submitted.
N/A N/A This section requires manuals, reports, Tech Spec Provide the Admin Controls Submitted etc., identified in the Tech Spec Admin requirements to section in the application and after WIS 6 Controls Sections to be submitted with the develop these develop the programs during application. documents will be construction. This is Not addressed - guidance still requires included in the consistent with the approach submittal of these documents. application but the taken for regulatory required details needed to programs.
complete the documents won't be known.
111.03-1 C.111.3 C.111.3-5 P(2) Some required environmental information Preliminary Submit preliminary will not be available at the time the COLA information available information with COLA.
is submitted. An example is the final at time of application. Updated information available routing of transmission lines Final information during construction for NRC REJECTED would be developed inspection.
during construction.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WSI Summary Description Availability Proposed Review Approach No. Blue Card ID 111.04-1 C.111.4.3 C.1114-2 P(2) In Section C.II.4.3, the staff says it COL Action and Identify required information intends to include license conditions for Information items in COLA with a commitment COL action or information items that a identified in generic to complete the actions.
COL applicant "cannot address" before DCD and ESP and Documentation of completion the license is issued. COL applications required information available during review or must, and therefore will, address all to be developed construction.
required COL items. For items that refer available for the to actions that will take place after the COLA. Information license is issued, COLAs will contain required to document commitments to complete those activities completion would be at the appropriate point in the construction available at various or operation of the plant. These times during COLA commitments are expected to be review and inspected as part of the NRC construction construction.
inspection program and typically do not rise to the level of significance that would call for creation of a license condition.
Why does the staff intend to create a suite of license conditions, rather than rely on its CIP, for COL Items that refer to actions that will take place after the license is issued?
Not completely addressed.
111.05 C.I1.5.1 C.I11.5.1-3 B(5) This section states that "detailed design As discussed with the Identify the information that is 1DELETE information should be submitted early in Staff, the available in the COLA and the COL application phase". Specifically development process supplement the application for I and C systems, at the time of for I and C designs information after submittal as application or shortly thereafter, sufficient will proceed beyond design details are completed.
as-built and procurement information is the COL application available for NRC review to assure that date and even DAC are satisfied.Accepted beyond COL issuance
COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID 111.05-2 C.111.5.1 C.111.5.1-4 P(5) The first paragraph states that sufficient Some DAC Describe DAC completion DELETE as-built and as-procured information to completion information available at the address DAC should be available at the information will be time of application.
time of the COL application submittal, or available. Remainder Remainder available on site shortly after and that this detailed design will be completed as it is completed.
information should be submitted during during construction.
the COL application phase. This implies an unrealistic expectation of the level of detail of information available at the time of submitting the application. Further, in some design areas, as-built and as procured information may not be available until after the COL review is completed. It should not be expected that applicants procure I&C equipment, valves, etc. prior to receipt of the COL. As-built information may not.be available until the construction phase; which is authorized by the COL.
In other forums, NRC has consistently and correctly recognized that DAC may be completed after the COL is issued.
We recommend that the first two sentences of this paragraph be deleted.
Accepted