ML16314B933

Procedure for Documentation of Deviations from the Standard Review Plan

ML16314B933
Person / Time
Site:	Diablo Canyon
Issue date:	11/09/2016
From:	Office of Nuclear Reactor Regulation
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Download: ML16314B933 (20)

Text

"ATTACHt1ENT 'D-1 PROCEDURE 'OR'DCUl IWc TATX&3 OF Dr,WATXOMS FBOi< THE SZAbDPZU) REVXB7 PLAN Introduction Wze staff review of nuclear plant designs describe in Safety Analysis

. geports is perforred within the guidelines established by the Standard Review Plan (MJBEG-75/087), issue in Septemb r 1975, and as since a-mended.

Use of the acceptance criteria of the Standard Baview Plan as a measure of the acceptability of plant design featuies assures both a consistent evaluation of proposed plant designs arid an acceptable level Y

pf safety for all plants licensed.

We Standard I&view Plan also de-scribes and documents the acceptability of specific design aooroaches to satisfy certain of the acceptance criteria.

he recognize, ho~erg

'hat alternate design approach s may satisfy these acceptance criteria

'equally well.

Further, we recognize Hat, with proper justification/

applicants may be able to de'rnonstrate that particular p ovisions of the acceptance criteria need not be met at'all.

Currently, significant difficulties arise when the Standard Review plan is used during the operating license review of a plant design, 'hese difficulties stem from the fact that the plant design at its consL~uc-

'ion permit stage of licensing was reviewed am3 aporoved against differ-ent, guidelines due to the lack of the Standard Review Plan at that earlier stage of review some future reviews will encounter the same difficulties due to the sane reason or to changes to. the Standard review

. Plan that have occurred during the intervening period.

In either event,

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I' deviations will exist in the plant design relative to the then current Standard Review Plan, and the staff's'br will be faced with licensing decisions regarding the acceptability of the design described in the Final Safety Analysis Report.

Zn the past, applicants have ex~nded'considerable-efforts justifying, and the staff has sp.mt considerable tiJne evaluating, particular plant, design features to assure an acceptable level of safety.

Often these efforts have not ~n properly documented to clearly indicate tne bases

'for acceptability of the design.

ib improve the us fulness of our Safety Evaluation R ports as a record of such decisions and to minimize the need for future reassessments of operating plants to demonstrate adequate. levels of safety relative to current criteria, it is desirable

~ that the bases for such licens decisions be clearly uocuvarted in tbe Safet Evaluation Reports that surrarize the staff review of the F~al Safety Analysis Report..M this end, any deviations from current "Standard Review Plan acceptance criteria will need to be lisM and

.'ustified in the Final Safety Analysis Report and.in the staff's Safety Evaluation Report prior t:o ccmpletion of.the operating licens stage C

of review.:

A problem of similar type but of much less magnitude may exis spect to scme construction permit and standard design agplicatlns and r

associated staff review.

Since all new applications for construction

. permit or for preliminary design approval of.standard designs must ad-dress the information needs identified in Revision 2 to the Standard Format and Content of Safety Analysis Reports, deviations from the

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acceptance criteria of the Standard R view Plan are expected to b non-ex-istent or ninimized.

F}owever, alternate design approaches my be proposed by the applicant, and it is possible that deviations may arise during the course of the revie~.

Xn any event; any d viations or alternate design 0

approaches, whether initiallyproposed or developed during the course of 40 the staff review, will need to be listed and justified in the Preliminary 4

Safety Analysis Report and in the staff's Safety Evaluation Report prior to

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canpletion of this stage of review

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~ This document presents the procedures that should be follow (1) by appli-cants and (2) by 'staff reviewers and Licensing Project Hanagers to assure

~ that adequate documentation of deviations and alternate approaches in plant designs'elative to the Standard Review'Plan is, provided in Safety Analysis

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Reports and in Safety Evaluation Reports, respectively.

Definition of D viation For the purposes of this procedure, a d viation is defined as a lac}: of con formance of a plant design feature to one or'ore provisions of the accept ance criteria given in'the Standard Review Plan.

An alternate and acceptable design approach to satisfying the Standard Review Plan acceptance criteria is not considered to b a deviation, but the bases for acceptability must also be documented in the Safety Analysis Report and in the Safety Evalua00 tion Report.'

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procedure The procedure for doc~sting deviations from the 'Standard Review plan requires the applicant initially'to identify the deviation and provide the bases for accepLability.

Tnis information snoukd be included in the Safety Analysis Report and reviewed by the staff as a part of the.

normal review process.

The results of th review should b described in the Safety Evaluation Report to provide clear documentation of all deviations, including the base.'.for acceptability.,

Vae same procedure sho~d b followed for alternate design approaches.

The procedure is based on the implicit assumption that a program will be established whereby p ants licensed for operation willbe mainlined continuously-Up-to-date with regard to changes.in licensing requirements (i.e., at i

the. time a new staff position is developed, a decision regarding its.

p applicability on a generic basis or.on each plant, on a case-by-case

~ basis, villalso be made and implemented) h C

'The specific steps in the procedure for a new application are:.

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'Xhe applicant wi11 identify and provide bases for all deviations

'L from the. acceptance criteria given in the Standard R view p3.an.

~he information should be contained in those Safety Analysis Report sections that describ the systems, components, or struc-tures..in which the deviations exist.

should provide in Chapter 1 a surrnary and an identification of the sections Xn addition, the applicant 1

listing of the deviations in the Safety Analysis Report wherein the oeviations are described and justified.

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fl ATTACHE~ D-5 2.

During the acceptance review of the Safety Analysis Report, the staff hould determine that this information has ~n provided and should inform the applicant of any obvious deficiencies'.

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pollowing docketing of the Safety Analysis Report, the staff tshould perform a review of the deviations and their bases, iden-'

tify other deviations that shou'3 be discussed in the Safety.

Analysis Report, and 'request additional information as necessary at the first round request for'additional information (Q-3.) stag 4

~ of review.

At the second round request for additional information stage of review, the staff should inform the apolicant positions on the deviations and their bases.

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'Following review of the a~licant's resoonse, draft Safety Evaluation Report inputs should be prepared that describe each deviation and the results of the staff review of the bases'for their acceptability; the Safety Evaluation Report inputs should, also include a general statement denoting acceptability of the applicant's design relative to the grouping of acceptance criter-ia given in the Standard'R view Plan sections.

As stated previous-ly-, the Safety Evaluation Report inputs should also include dis-,

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cussions of any alternate aoproaches

'to staff positions that have been adopted by the applicant and the bases for acceptability.

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A'xiACE.KNT D-6 6.

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The Licensing Project Hanager'shbuld include a section in e

Safety Evaluation Report that notes that the review has been made using the Standard Peview Plan criteria as of the appli-cation docket date, tabulates all deviations. from those criteria',

and identifies the location in the Safety Evaluation Report where the discussion may be found..

The procedural steps given above relate to future applications.

Hodifications to these procedural steps will be made in order to implement the procedure for applications currently in 'the licensing process.

Specific steps will be taken to assure that the implementation 0

weal be consistent with the Corrnission's standardization and replication nolicies.

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ATTACEZyr D-7 XPL~LBIMiATXGA plants Curxentl

'Under Review for ratin Licenses Three plants have Safety Evaluation Report issuance dates currently acheauled b yond January 1, 1977.

Tn"ae are Shorehata (Harch 1977), Zimtar 1 {July 1977),

and Hatch 2 (December 1977).

ge will request the applicants for Shoreham

'and Zi~er to suhjj.t their listing of deviations with justification in our second round reques'm for additional information scheduled for Septem-b r 1976.

Reviewers should Regin independent reviews of these

'lants at this time to permit completion of effort in tim for

. Safety Evaluation Report issuance.

A letter will be sent to t'ne

~ applicant for Hatch to request submittal of the needed iCorma-

'tion.

One plant, 'watts Bar 1/2, has recently been tendered for docLet-

'ing.

We'equest for the list of deviations with justification will be included in our initial request for additional informa-

'ion.

One'plant, Fermi 2, will have its Safety Evaluation Report issued 3.ate this year.

However, it will be incomplete since operation

'is not contemplated until 1980.

A major supplement willbe issu-ed a year or so before operation.

A letter to the a@pl.icant vill inform him that the matter 'of deviations wil~ be incluced at that time.

Other plants currently under review will not be considered even though schedule changes may slip the Safety Evaluation

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~ Reports beyond January 1, 1977.

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Arkansas -2, and Y~Guire 1/2: ~

AT1'ACHlM4T D 8 These plant incluce Davis Besse-l, 2.

plants with'Construction Permits and ffnich Mill Ape for rating Licenses The LaSalle 1/2 and HPPM 2 applications are scheduled for CESAR submittal in September. and October 1976, respectively.

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can implement the'procedure for these plants at the accepLance review stage.

For the other 27 plants beyond these two that currently. have a construction permit, a letter will request inclusion of the de-viation information'n the Final Safety Analysis Report.

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plants Carrentl Under Review for Constraction'Permits

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Letters vill be sent to applicants for plants which have issuance dates for Safety Evaluation Reports,. or major supplem n~ to up-

~'at delayed plants, currently scheduled beyond August l, 3.977, to orm them that their Safety Analysis Reports or sumlements and our Safety Evaluation Reports vill need to co~tain the list-ing of deviations and justification.

Ho non-delayed plant is in this status.

The delayed plants incluch Douglas point 1/2, Greenwood 2/3, Aliens Creek 1/2, Hontague l/2, and Barton 1/2.

Hew England I/2 has been tendered for docket~~

Tne requirement on the list of oeviations and justification villbe included in

'ur initial request for additional informat'on.

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ATIRCEBKLVZ D-9

'Other plants (25 in number, 15 of" which are in the, post-ACRS stage) will not be considered at this time even though schedule changes may slip the Safety Evaluation Reports or supplements beyond Hay 1, 1977.

Future Construction Permit A

1ications

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4 The requirement for the list of deviations and justification gill be included in our acceptance review letter-for thoge

. app1ications submitted within six months of issuance of the

~ change to the Standard Format, discussed in item 6 below.

The information will be expected to be in a Safety Analysis Report.

~ submitted after such a period of'ime'.

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Construction Permit A lications Referencin rovea=%anahrcr Desi ns'or Re licatin Base Plants h

The requirement for providing the list of deviations and justifi-.

'ation in the Preliminary Safety Analysis Report will be imole-mented only for those portions of the Preliminary Safety Analysis Report that require a de novo review in accordance with the Standardization Policy or the Replication Policy', as applicable.

The requirement will be applied fully to the reviews of reference:

desi'gns for which the scheduled issuance date of the Safety Evaluation Report is beyond August I, 1977.

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ATTACEMqT D yo 6..

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A change to the Standard Format Mill be processed to require the inclusion of the listing of deviations and justification in Safety Analysis Reports

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