ML19247E112

Discusses Use of Independent Design Reviews in Regulatory Process

ML19247E112
Person / Time
Issue date:	03/12/1981
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
TASK-PII, TASK-SE SECY-81-161, NUDOCS 8103240199
Download: ML19247E112 (40)

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5 SECY-81-151 serch u,1981 POLICY ISSUE (Information)

FOR:

The Commissioners FROM:

William J. Dircks, E) utive Director for Operations

SUBJECT:

USE OF INDEPENDENT DESIGN REVIEWS (IDR's) IN THE REGULATORY PROCESS PURPOSE:

To inform the Commission of NRR's use of independent design reviews in the regulatory process.

DISCUSSION:

At a January 1950 IEEE/NRC jointly sponsored conference, Working Conference on Advanced Electrotechnology Applications to Nuclear Power Plants, a design review process as used by NASA Goddard Space Flight Center was described.

During that meeting the feasibility of applying such a system review management technique (therein referred to as Independent Design Reviews) to the licensing review of nuclear power plants to enhance reliability and safety was endorsed (Enclosure 1).

IDR is a systematic, technically-oriented, and documented evaluation of a system and associated equipment against requirements by a team of independent specialists.

Al thou gh many utilities perform initial reviews of designs provided by the NSSS vendor and the AE; these reviews are not usually rigorous evaluations against criteria nor are they documented.

The use of an IDR is seen as having two major benefits.

First, it involves the applicant, who will ultimately operate the nuclear f acility, in a detailed safety evaluation of the facility against the NRC regulations which results in a greater extent of understanding than that gained in the current process.

Second, it results in potential manpewer savings to the NRC.

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Contact:

Frank P.iraglia, NRR

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Since a severe resource shortage exists for OL casework in NRR over the next few years, NRR has been examining ways to 4mprove the efficiency in the licensing process.

Our experience to date with the IDR orocess is encouraging and it appears that IDR's have the potential for mitigating some of the expected resource shortf all in NRR. The staff has been using Mr. Herman LaGow a former NASA consultant, to assist in developing IDR guidelines.

Mr. LaGow has been participating in the actual IDR's conducted to date.

Specifically, NRR has begun, with Arizona Public Service Company, in the conduct of (IDR's) of selected systems of the Palo Verde project (DC Power Systems, AC Power Systems, Auxiliary Feedwater Systems and Equipnent Quali-fication Systems). The cbjective of these reviews was to determine the adequacy of these systems with regard to compliance with Commission requirements.

A brief summary of the initial ef f orts is contained in Enclosure 2.

A summary of the procedures utilized in the conduct of these meetings is contained in Enclosure 3.

Basic guidelines have been developed to assure effective use of she process by applicants and by NRR.

CELD has been involved to assure that the process would provide an adequate basis for the staff's positions at a hearing.

Based on the experience gained to date in the conduct of these meetings, the staf f is making several modificaticns to the current procedures to enhance the effectiveness of these reviews to ensure that these procedures can be incorporated into the regulatory review process (See ).

h NRR plans to continue the experimental use Jf IDR's along the approach that follows:

1.

Carefully direct the potential uses of tne IDR process to areas where the Palo Verde reviews have proven to be productive.

2.

Develop implementing procedures, along the lines discussed in Enclosure a, wnich will increase NRC participation in the front-end of tne IDR process.

3.

Present seminars to NRR staff on tne IDR concept to ensure a well-understood and disciplined process.

4.

Brief the ACRS on the IDR prccess and ciscuss experience to date.

5.

Monitor and evaluate +he use of IDR's in the licensing process.

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William DT Dircks, Executive Director for Operations

Enclosures:

1.

IEEE/NRC Mtg. Excerpt 2

Sunnary of Palo Verde IDR's 3.

IDR Procedures Used to Date.

4.

Use of Indepencent Design Reviews in Regulatory Process DISTRIEUTION Connissioners Commission Staff Offices Exec Dir for Cperaticns ACRS Secretariat

EllCLOSURE ]

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SYSTEMS MANAGEMENT TECHNIQUES PANEL r w r.. -V ' 7 ' F t ment. The pamapants were asked to read and study this b"

matenal to be better prepared for panel dehberanons J."j

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PANEL DISCUSSIONS f.' $i U

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The panel's sesion began with memducnons by the pama-M es==

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pants. This was followed by adepnon of an agenda for the

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5 wrwr 1 of informanen among the technolopsts, the mdustry pamo-p' 7 9

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pants. and the reculators to enabie the pame: pants to under-9 i

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,g stand the problems faced by the three groups The

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% fj $y tuhnolensts desmbed the way the renew technique and w..-

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,s assocated techmques are used to reduce problems m the

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acquismon of rehanle aerospace and defense equipment. The JG \\

industry representanves desenbed the ddnculty of acquzrmg m

i snd operan g nuclear power p; ants wben the design pude-Co-che mg tec 5prems '.bage,mt Tech m.~nn pene! ace Ha-old hnes are constant!y charged to taic advantage of the expen.

R. Det.m and EJu ard A %: ' Dr. Dents is J: vector d the O Rcr ence acquired. The regulators desenbed the statutory and d Nuc! car Rcactor Regahna at the Nucl car Reg:,Sto y Commrs-pohncal requtrementi to assure a high depee of safety in sum. a positwn he has hcid smcc 1?'S Smce yammg the c.,mmisswn nuclear pow er cightem yea s age, he has held m?casmg!u recponsaNr positons sn Once the en:har ges of mformation and idenn5 canons the hcesmg.md merem rg ams. Dr. m:4 :s reaccf study of problems w ere completed. the pane! tumed its attennon to ma" age-at the NASA Cad.b d S;* ace Thght Cmte Cran.9;t, straw men scenanes of how a renew techruque m:ght be prsc-Ab.Mnd, a pat he has held smcc 19'! Dr NlF has se-:cd as a ncaUy apphed to pow er plant design const acnon. and opera-dr crt.'* d IEEE and h.d had crteser pa terstm ervene-ce m non. The creation of these seraw men w as fachtated by the fact mes M ds of1EEE.

that several pamarants completed the homework ass:gn-rnent and brought their work to the confe e nee, where it was Rapporteur Stuart Peale repmduced and distnbutei P* I"'*d I 5'~

Pane'.sts and Pamcpants are bsted at the end of this report.

stature the w ord " plant" for sys: ems" m des:nbmg the renew INTRODUCTION techruque since the industry uses the word " system" to de-The obrectne of the Systems Management Techniques Panel scnbe w hat the technolopst cans a,ubsystem.'

was to esplore the feasibthtv of applymg a sy stem renew Foilowmg the discussion of straa man scenanos. the management techmque to the design, acquisition, consnuc-panel discussed the advantaces and disadsantages of the tion, and operanon of nuclear pow er p! ants to enhance rena-plant renew proce<s The ongnal straw nan hst w as agStb-bihty and safety mc dthed and then expanded The fmal hst of advantages and Pamepants in the panel consisted of technolopsts with disadvantages was developed By this nme, there was a gen-a workmg knowledge of system renew techniques. members eral wnsensus that Strawman Scenano 3 was prefer ed of the staff of the Nuclear Regulatory Commission, and peop:e fmm the nuclear industry, pnmanly unhne.

RECOMMENDATIONS The system renew techruque, w hich was the subject of Fea!!y the panel considered recommendanons that could be this panel's dehberaton, was desenbed to the ent:re confer-made and found it had a consensus on what should be rec-ence by Herman LaCow (see Part :).

ommended. These unarumous recommendanons are pren In order to pve the panel a head start m explanng the Selow.

prac*icaby of the techmque, a brainstormeg session was held

1. There should be an interdisophnarv plant rrnew a month m advance with some of the technology and the NRC pmcess, as desenbed by Strawman Scenano 3 (see fouoweg panel par-icpants This brainstormeg poduced a strawman desenpnon).

impic nentanon scenano, an anlaysis of that scenano, and

2. NRC should esamine what pa-ts of custmg ynxe-straw man pnonnzation cntena for use m comparmg decrent dares can be simphhed or ehmmated w hen renew is im-scenanos to be developed at the cenference Also pnor to the plemented.

conference, the parnopants were sent a homewed assign-

3. There should be a task force to espand Strawman 47

Scenano 3 mto a total syste n management concept that ac-Preudes w n!!en record of estenswe edart to assure commodates the nuc! car busmess (a)Invohe svstems pecple safe'v and nuclear people, (b) Task terce should usit mstaManons. (c)

Prendes mdependent adnce to decsion mac-s.

Shuuld be considered by Atoruc indus:nal foram7Mi os er-Prondes prompt. m-depth renew of project at each sight commmittee step

4. There should be an esenase betw een unhn and arm-Can ncnase NRC con 6dence m saft % and reduce other space systems people to see how the process m:ght be appbed regu:atory burdens in one case. This wdl be pursued by NRC.

WiU remforte other contnbutions to safety includr.g thorough use of past espenence and adequate test preg-ams.

STRA%31AN SCENARIO 3:

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IMPLEMENTATION, Requi e mams management at NRC.

Helps dehne rea.i safety issues 1.There is a utthn P: ant Renew Manager a ho reperts to a Corporate OtScer. There ts an NRC P! ant Renew Manager DISADVANTAGES w ho reports to NRC Management

2. The p: ant rewws are daided into the fonowmg Costs animes m<m Rtyuirt$ regu!Jtory of prArduraj charge, ge$

Phasel Inmal Rege ements through operatmg hcense E""" M' terme N RC tet nmcal statt.

(pt).

Could lead to es essn e layers ut renew Phase 2. P: ant eperanons (annualk )

Renew s are epen to the pubhc.

Phase X M:scenaneous renew bv NRC Phne31 and: are conducted 5 the uto 1 w ith the NRC Ren-w Manager a, cr.en er ROSTER Of PARTICIPANTS Phase X is held a hen NRC is &swar:sned w:th Phase 1 or 2 renews.

Dan E Andrew 5. Jr Leonard 1 k h P esenters are utity and con actor people n' Howard Arnold He* man E. LaGow

3. The Plant Renew Manager recemmends whether plant-(spec 6 cation adequate, cenceptual ac> ten adequate.

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• nna! des:gn adepate. con macnon pbn aJcquate te-t pbn h i3'n I LmMad adequate, test adequate, cperanon p!an onc!uire son-C h Chdds C O Mdler nrgency and eme genev plan) adecuate-n creranonaih.

ready.

Dr Harald R Denton Aar en Ow en The consmaction permit (CP) is tssued aher Phase 1 entical design renew fCDR) and the OL tssued arter hnal Phase l renew Richard M E,rert n.iam R Pecue

4. The P: ant Renew Manacer has authonry to sciect T N ~ Tom" En mc Corde3 Reed team members tram anous 1 c:pimes <mectamcal.:e.:en.

structur*s matenals. geoices. for eumplei and organ:aanons (projects. inspecnon and eN!creement. INPO. legal. FEMA.

James Creen Denny Ross state regulato unhn rnanacement) naner P Haa*s Joseph F Shea

5. Renew Fi,r-.at L~nhty prn ec. p esens to renew team accordme to acenda set h reuew manacer at emes and piaces set by n neImanager Actual designers wdl prewnt to DW Chuck ~ Ha:hgan Rade'ph A. Stampfl despn renew s L"0"d'd Id ?

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6. The renew encompasses the enta hfe cycle of the plant.

~ Obg-ctn es. Reuen cntena Plant wiU sansfy success cntena or owner hnancer and NEC (Safen) NRC cntena hsed at CJR.

STRA%3 TAN SCENARIO 3:

ANALYSIS OF ADVANTAGES AND DISADVANTAGES ADVANTACES Provides earber idennScanon of problems P-ovides forum for communicanng past espenence in umely fashion.

He!ps opum:ze design and avoid patrans.

Assures interisc:phnary and m!ct-organtcanon mterac-non.

Insures tr!'poMant safe *Y func* ions adequcte!y destpned and tested.

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Co-Chairing the Systees Managerent Techniques e

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Panel were Harold F. Penton and Edward A. Wolff.

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i Dr. De nton is director of the Office of Nuclear

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Cc=tission, a position he has held since 1978.

j Since joining the commissien eighteen years aF0, h

he has held increasingly responsible positions in

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Dr. Wolff N%7 UYI is projitt study =anager at the NASA Coddard Space Flight C 7ter, Greenbelt, Maryland, a post he has held since 1978.

Dr. Wolff has served as a director of IEEE and has had extensive particip1 tory experience in various boards of IEEE.

SYSTEMS MANACEMENT TECHNIOUES Co-Chairman:

Dr. Harold E. Denton Dr. Edward Wolff Directvr, Office of Nuclear Project Study Manager Eeactor ReFulation Ceddard Spa:e Flight Center Nuclear Regulatery Ce:missien Rapporteur:

Stuart Peale, IEEE Staff Panelist:

Dr. Dan Andrews Dr. Joe Shea Ncval Ocean Syste=s Center Paythe:n Ccepany Mr. Robert Arnold Mr. Rudi A.

Starpfl General Public Utilities haval Ai r Dev(loprent Center Mr. Herern LaCow Consultant Goddard Space Flight Center 1.

INTPCDUCTION The objective of the Systees Management Technicues Panel was to explore the feasibility of applying a system review eanagerent technique to the design, acquisition, construction, and operation of nuclear poser plants to enhance reliability and safety.

Participants in the panel consisted of technologists with a vo: king knowledge of system review techniques, reebers of the staff of the Nuclear Regulatory Co= mission, and people from the nuclear industry, primarily utilities. These participants are shown in Table 1.

The system review technique that was the subject of this panel's deliberation was described to the entire conference by Mr. Herran LaCcw.

(See Table of Contents of this Conference Record.) This description of the technique as it is irplemented at the NASA Coddard Space Tlight Center is su==arized in Table 2.

In order to give the panel a head start in exploring the practicality SS

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of the technicue, a brainstorminF session was held a conth in advance with acre of the technology and NFC panel participants.

T..is br ain>t orming produced a stravran implementation scenario, an analysis of that ccenario, and t r,.--a n prioritization criteria for use in corparing different scenarios to 3e developed at the conference. The stravran scenario is stievn in Table 3, the analysis in Table 4, and the prioritization raterial in Table

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Prior to tne conference, the participants were sent a hc.-evsrh j

atsi nrent.

An instruction sheet for this assignrent is given in Table 6.

F Attached to Table 6 were Tables 2 through 5.

ne ecrticipants were esked to read and st ady this caterial to be better prepared for canel deliberations.

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SYSTEMS M.ANALEMENT TECHNTOUES PANEL PARTICIPANTS Dan E..

Arirews, Jr.

Leoaard J. Koch Naval Ocean Systems Cent er Illinois Power ~ 3rpany V. Howard Arnold Herman E. LaCov Ves t ingho us e /Nucl ea r 5"s t ems Coni u hant Irternational Febert M.

Futler Williae J. Linb.'ad Foston Edisen Portirad Cencral Electric C.V. Chi'de C. O. !' iller Fisk Manayment Association Syster Safety, Inc.

Harold F. Jenton Verrcn Ower Nuclea r Repla t ory Corissier Suke Power Company Fichard P. Eckert Williac F. PoFue Public Se rvic e Elce t ric 1 Cas Public Service Corpar.y Co.

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.lahcre T. N. " Tor." Ewing Cordel1 Feed Public Se rv ic e Cerpany of Cer.conwealth Ediser. '

Cklabora Jim Creen Denny Foss Tennessee Valle:,

'ut horit y Nuclear Ferulatory Com i s s ion Waiter P. Haass Jos pS F. Shea Duci ar Fegulate y Cor:m i s s i o n Faytheon Cou.pa n y D. W.

'ehuck" Falligen Fuhlph A.

Ftarpfl Becht.2 Power Naval A:- Develcyrrnt Center Leonard J i'fe Edward A. Wolff NASA, Pr. r. TMI Cer 2 s s ion NASA Staff 87

An.t e SYS.rwe o r \\. r..-. r r.u. r.. s. r_

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SP ACECF AFT OESIGN FE'.'1E*. ?FCCEA.9 1.

FCEPOSE This instructice defines the polic y an d gene r a'.

pro:edures for the design reviev of projects at Goddard Spa:e Fligh: Center.

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The previsions of :his instruction are a p p '. i c a b l e :: ali CSTC space:raf:

projects, in:!udinc ex;erirents and unique supp::: aquip-ent.

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and d::u en:ed Design Feview is a sys : erat i:, :ech-ital'v :-

2, evaluation of spa:e: raft and asse ia:ed e;uiprent by a tear of specialists.

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The Oire:ter of S.vs:ers Feliabilitv. 'as everall responsibility for the 5;a:e:raf resige Feview Pr:gra- (5:F?), and vill appoin: the rerbers and Chair an of er:5 Design Feview Tean

(!FT) by rer:randur.

b.

The Chief, Systers Feview Cf fi:e is res;cnsible for i plererting and executing desirn reviews and generating desirn reviev plans and -rece;ures.

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All CSFC spa:e:raf: and rajer flight experirents

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The 5 FP shall be supper:ed by all CSTC Directorates who will furnish.he EFT v; 5 senior personnel experitti:ed in :ne recuired technical dise:plin.s.

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.rary Obie::ives of the SIFp is t: enhance :ne r:babilit Of r

success of CSFr. spa:e: raft rissions. This objet:ive vill be achieved by s

1 ringing :: bear en each nre,ie:t the curula:ive kn:vled:e of a :ea-ef P

engineers and scientists who have had extensive prior experien:e with :he particular types of systers and fun:tions involved.

'Wh il e the design review is te:hnically crierted, proper :ensidera: ice vill be givec ::

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I coratraints operating on the projects, particularly those involving prieary mission objectives and progran costs and schedules.

These reviews shall assure that each project has the benefit of Centerwide experience

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pained on other projects. They shall also provide the Center's review of the project s' Sysers Safety Program.

7.

STRUCTUFE AND FL*NCTION OF THE DESIGN REVIEW TLAN FEMEEFSEIP a.

The Design Feview Tese The DFT will include personnel experienced in design, systsees enrineering and integration, reliability, quality assurance, testinr.

raterials, and other applicable disciplines. The personnel vill be selected frer throughout the Center with the approval of the appropriate Directors.

b.

Nurber of Feviews (1) The Chief, Systems Feview Cffice, Systers Feliability Directorate, in conjunction with the individual Project Manager will develop a total desi n review p1rn.

Except F

in cases of repeat eissions, the following reviews will nc eally be held:

(e) Design Feviews - these reviews occur during the design phase and prior to the start ef asserbly.

They will erphasize ieplerentations of design approaches resulting from the study phase as well as test plans for the prototype and flight systers.

Fer new systers, I

generally two design reviews will be conducted.

(b) Environe ent al Review - this review occurs after prototype qualification testiny, cr redor to acceptance testing, if no prototype is used.

The prirary purpose of chis review is to determine the qualifiestion status of the hardware and to evaluate flight acceptance rest plans.

(c) Flight Feadiness Feview - this review will usuallf take place prier to shiprent of the flight spacecraft to the launch range, and will con:entrate on

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f spacecraft perforeence durinF acceptance testinF.

(d) Flight Operational Feadiness Feview -

this review will be corducted when a flight operations plan is available. While all of the previous reviews involve operations, this review will erphasize the final orbital operations plans, as well as the corpatibility of the spacecraft with ground support equiprent and ground network, including summary results of the network I

corpatibility tests.

(2) Major fliF t experiments stich are required h

for mission success are subject to this review prograe.

One or i

two Experirent design reviews, depending on ne ed, shall be held prior to integration.

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Design Feview Schedule l

The several reviews will be conducted en a schedule detereired by the

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Chief. Systers Feview Office after consultation with the incividual l

Project Manager.

The major reviews shall be depicted in the CSFC Project Manage =ent Inforration Control report (PMIC).

d.

Docurentation

(1) At che cerpletion of each review a forral report to the Deputy Director, CSFC will be prepared by the EFT.

Minirus recuirerents of the report are:

(a) a su mrary st a:erent of the DRT findiers; (b) re :r.rendations rade by the DFT to the project; and (c) corrents er re spenses of the proje:t to the findines and recorrendatiens of the IFT.

(2) The corple:ed design review report will contain the results of each review condue:ed for the project together with a rissien laun:b readiness stcteren; issued by the Chairran of the OFT.

(31 ihe desipn review reper: will be issu.4d and ferrally accepted by the Deputy Director, CSFC, prior to the launch operation.

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FUCLEAR POWER PLANT SYSTEM FEVIEW TABLE 3 STRAWMAN IMPLEMENTATION SCENARIO #1 1.

System Review Manager reports t o NRC (Chairman, EDO, Dir. NER) 2.

System review eanager recocmend s whether plant (spec. adequate, conceptual design adequate, final design adequate, construction plan adequate, test plan adequate, test adequate, operation plan (including contingency and e=erfency plan) adequate, operationally ready, (prepared for centrol operator) 3.

System Feview Manager has authority to select pe opl e (team eeebers) free various disciplines.

(Pechanical design, structures, materials, Feology, hydrology, reteorology, reac tor systems, core design, containeert systers, auxilliary systers, human factors, operational e x pe r i e n c e, instrurentation & control, electrical Mesign, reliability, quality assurance, radiation protection, chemit'-, e,nagerent controls, testing, security, procedures, traininF, safety, control room operators).

And organizations (projects, inspection and enforcerent, INF0, legal, TEMA, st ate re gulator, ut ility managecent ).

4 Review Format:

Utility project presents to review team according to aFenda set by review eanager at tires and places set by review manager. Actual designers will present to design r views.

5.

Review Criterion:

Will the project satisfy the NRC success criteria?

TABLE 4 INITIAL ANALYSIS OF STRAWMAN IMPLEMENTATION SCENARIO #1 Nuclear Power Plant Systems Feview Advantages Disadvantages Provides earlier identification Costs utilities reney problems Provides forur for coerenicating Requires regulatory or past experience in tirely fashion precedural change Helps optimize design and avoid Requires bolstering NFC pitfalls Technical Staff Assures interdisciplinary and Recuires estrix canate-interorganizational interaction cent at NFC Insures important safety functions i

adequately desi ned and tested F

Provides written record of exten-sive effort to assure safety Provides independent advice to decision enkers.

Provides prorpt, in-depth review v!

project at each step.

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TABLI 5 PRIORITIZATION CRITERIA TO CCMPARE DIFFEFENT IMPLEMENTATION SCENARIOS - NUCLEAR POWIR PLANT SYSTEM REVIEW l.

Contributes to safety.

2.

Contributes to reliability.

3.

Provides independence of thought.

4 Provides efficient use of resources.

Requires a minicum of new legislation or rule change.

6.

Provides a record of NRC overview.

TABLE 6 HOMEWChK ASSIGNMENT This panel vill focus on techniques for the review of the canagement of a project from early concept design to final operation.

Of special interest are c ana ge cen t techniques to insure that all aspects of a sy+. tem are integrated to produce a safe system.

Such techniques have been successfully erployed by the

'd 5 A to take a project free initial specificatien through the final launch of a satellite using panels of experta to insure that all technolcgies have been adequately integrated through a continuing review of systers ranagercnt.

Experts in system review techniques are needed to share the rest successful canageeent techniques with regulators and nuclear power plant leaders to d e t e rmine the practicality of applying such techniques to resolving issues in nuclear power plan' safety.

Attacned is a descrinf ion of how the syste= review technique is i=pleranted at the NASA Goddard Space Flight Center (Management Instructor CMI S010.13).

Attach ent 1.

This is an exa=ple of the System Review Concept that the planel vill try to apply to the nuclear power plant problem.

You are asked to review, critique, and create other optiens for the followi g enclosed ite=s:

1.

The 3trav=an Ieplementation Scenario - Attachrent 2.

This describes one way the concept could be ieplerented for the nuclear power plant safety problem.

2.

The Analysis of the Strav=an Implementation Scenario Attacheent 3.

3.

The Prioritization Criteria to compare different I plecentation Scenario - Attachment 4 1

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4 Please bring your herevork to the conference registration desk on January 15 so it can be reproduced and distributed to vuur fellow panel reebers at the start of the deliberation.

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PANEL DISCUSSIONS e

The panel's session began with introductions by the participants.

This was followed by adoption of an agenda for the panel, shown in table 7.

The initial panel discussions focused on the exchange of infor=ation among the tecnologia:s, the industry, and the regulators to enable the 92

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i participants to understand the problees faced by the three groups.

The j

technologists described the way the review technique and associated techniques l

are used to reduce problems in the acquisition of reliable aerospace and defense equipment.

The industry described rae difficulty of acquirinF and operating nuclear power plants when the desiFn Fuidelines are constantly chat.ged to take advantage of the experience acquired.

The regulators described the statutory and political requirerents to assure a high degree of safety in 6

nuclear power.

Once the exchange of information and identification of problems was completed, the panel turned its attention to stravren scenarios of how a review technique might be practically applied to power plant design, construction, and operation. Additional stravren inplementation scenarios suggested during tre brainstorming are shown in Tables 8 through 11.

The creation of theca s*:avren was facilitated by the fact that several participants completed the herework l

assignrent and brought their work to the conf erence where it was reproduced and distributed.

Early in the discussion the technologists learned to substitute the word " plant" for "systecs" in describing the review technique, since the industry uses the word " system" to describe what the technologist calls a

" subsystem."

TAELE 7 SYSTEMS MANAGEMENT TECHNIOUES PANEL ACENDA 1.

Introductions

i 2.

Explznation of Nuclear Regulation 3.

Clarification of NASA System Review Technique presented

)

in apen session 4

Presentation of ether variations of system review (DCD, etc.)

5.

Erainsterring:

Develeprent of possible feasible irplementation scenarios 6.

Analysis of scenarios (advantages and disadvantages) r 7.

Develop =ent of scenario prioritization criteria 8.

Scenario prioritization 9.

Fecoerendations:

Is any future action desirable?

(study, larFer more intensive panel, experiment )

Reco= rended plan for any future action 10.

Preparation of Panel report TABLI 8 STRAL* MAN IMPLEMENTA!aCr ECEhARIO #2 1)

Plant review =anager in utility reports to V.P. of Nuclear Production or V.P. of Engineering / Construction 2)

- 4) Saee as Strawman #1 TABLE 9 STRAWMAN IMPLEwENTATION SCENARIO f3 1)

Plant Fr.ic' Manager reports to a Corporate Officer 2)

NRC Ceview Mac4ger reports to NRC Management 3)

Phase 1:

Initiai Fequirerents through operating license (OL)

Phase 2:

Plant operations fannually)

Phase X:

Miscellaneous review by NRC 4)

Phases 1 & 2 by utility with NEC Review Manager asobserver 93

Phase X when 5'RC dissatisfied with Phase 1 or 2 reviews utility and contractor people Presenters are 5)

Construction Fermit /CF) issued after Fhase I critical I review design review (CDR) OL issued af ter Phase Review criteria: Plant will satisfy success Objectives:

6)

NFC criteria criteria of owner /financer and NRC (Safety).

fixed at COR.

7)

Re 'iew encompasses entire life cycle items 2, 3, and 4 of Strav=an #1 B)

Includes TABLE 10 STEAWMAN IMPLEMENTATION SCENARIO d4 U

1)

Specification of rission N

2)

Specification of Risk; characteristic design goals U,N 3)

Interaction of Mission with Eisk Characteristic C,N 4)

Specification of Fisk Evaluation Pethodology U,N 5)

Preliminary Design criteria / cree =ent FFEEZE 1 U,N 6)

Preliminary Design (CP) iterate; U,N 7)

Syster Interaction Feview; pre-OL (NEV) - TFEEZE 2 U,N Final Design Review Againsts Criteria

?)

STFAVMEN IMPLEMENTATION SCENARIO TAELE 11 the utility reviews experience annually and After the construction permit assesses changes required for safety.

Following the discussion of stravran scenarios, the panel discussed review process. The original advantages and disadvantages of the plantslightly modified and then expanded The final the of Table 4 was and disadvant,es is geren in Table 12.

By this tire, there strawran list list of advantages was a general consensus that Strav=an Sc io d3 was preferred.

iter of the agendr of Table 7 3.

CCSCLUSICNS Finally, the panel turned to the final could be cade.

and considered recorrendations that had a cor sensus en what should be recorrended.

The panel found it reco=rendations are given in Table 13.

These unanirous ANA LYSIS OF STRAVMAN IMPLEMENTATION SCENARIO A 3 TABLI 12 Nuclear Power Plant Systems FevieuDisadvantages Advantages Costs utilities coney Provides earlier identification of proble=s Requires re gulatory or Provides forum for corrunicating procedural change experience in tirely fashion Fequires bolstering FRC past Helps optiri:e design and avoid technical staff pitfalls c,

Assures interdisciplinary and Could lead to excessive I

interorFanicational interaction layers of review Insures icportant safety Feviews are oper. to the L,

functions adequately designed public and tested Provides written record of extensive effort to assure safety Provides independent advice to decision makers Provides proept, in-depth review of project at each step Can increase NFC confidence in sefety and reduce other regulatory burdens k'ill reinforce other contributions to safety, including thorough use of past experience and adequa t e test programs Record can reduce 1eFal liability Eequires eatrix ranagerent at NEC Helps define re,1 safety issues TA512 13 FICOMMEND ATI C! S 1.

"here should be an interdisciplinary plant reviey process, as described by Stravean #3 (See Table 9).

2.

NRC should exar.ine what parts of existinF procedures can be simplified or clielinated when review is implerented.

3.

There should be a task force to expand Stravean #3 int o a total systee canagerent concept that accermodates the nuclear business.

Involve systers people and nuclear people s.

j b.

Task force should visit installations Should be considered by Atoeic Industrial Forue/TMI a

c.

oversight coreittee 4

There should be an exercise between a utility and aerospace systees people to see how the process eight be applied in one case.

This shall be pursued by NEC.

6 l

i I

e e

e

9 EfiCLOSURE 2

Summary of Inderendent Cesign Review Meetine For Selected Systers Conducted Dy Arizona Public Service In dll reetings held to date, the design review board was corposed primarily of Arizona Public Service ( APS) engineering staff rembers alcng with representatives of other organizations (e.g., Bechtel, CE, EPRI, NRC).

Ed Van Brunt, Jr., APS Vice President of Nuclear Projects, has been the Board Chairman for all of the meetinos.

A formal presentation of the system under review was nade ir each case by Bechtel.

The board rerbers asked questions of Bechtel throughout the meeting. Questions which could not be answered were included on a list of open items which Bechtel committed to respond to in writing at a later date.

A stenotypist has been available at all neetings so that transcripts of the proceedings can be made available.

The folicwing are brief summaries of the previous four reetings.

DC Pcwer Systen Review Meeting Date and Place: May 8,1980 - Phoenix, Arizona NRC Observer:

F. Rosa Submittals Available:

06/04/80 - Meeting Transcript 06/30/80 - Bechtel Response to Board Open Iters 09/04/80 - Additional Board Ouestions to Bechtel 09/lF/80 - Bechtel Response to Additional Board Ouestions 10/14/80 - APS Close-out Letter 12/22/80 - SER input received A summary of this meeting is discussed in a trip report dated June 2,1980 from F. Rosa to D. Ross. Basically, F. Rosa stated that the Bechtel team was questioned intensively on all aspects of the design er.d he felt that the Board Ouesticas were essentially equivalent to the NRC First Round Ouestions.

The Power Systems Branch (PSB) stated in a memo from Paul Check to R. Tedesco on Decerter 22, 1980 that a time saving of ap,roximately 10% was realized in the preparation of the SER input. The SER received from PSB had only two minor open issues.

AC Power Systen Review Meeting Date and Place: July 8,19F0 - Bethesda, Md.

NRC Observer:

F. Rosa Submittals Available:

09/11/80 - Meeting Transcript 12/09/80 - Bechtel Initial Respcnse to Board Open Items 02/10/81 - Bechtel Final Response to Board Open Items; APS Close-cut letter Estimated SER Input date:

April 6,1981

. This meeting began with a general discLssion of the overall syster.

Fechtel t',en A.;cribed at length the ranrer in which the syster reets NRC recuirerents and CESSAR interface requirerents. The third topic covered was a description of the instrurentation and controls for the diesel gererators.

Auxiliary Feedwater Systen Review Meeting Date and Place:

August 21-22,19PD - Phoenix, Arizona NRC Board Fembers:

0. Parr J. Werniel Submittals Available:

10/17/E0 - Meeting Transcript Expected Close-Cut Date: Mi d-April,19P1 Estimated SER Input Date:

Ea rly-Pay, 19P1 The format of this reeting was essentially the sare as the AC power systers

reeting, i.e., a general overview of the syster followed by a discussion on the ranner in which the systen reets MRC and CESSAR interface recuirerents.

r!PC representatives were, for the first tire, included on the parel as board rerbers.

This was also the first reeting in which it was concluded that the system did not meet one of NRC's positicns on syster design.

This aspect of the design was classified as an "Open Iter" recuiring further Bechtel investigation and resolution.

Upon receipt of Eechtel's response, the NRC staff will determine whether any design modifications are recessary.

Ecuipment Oualification System Review Peeting Date and Place:

September 25-26, 1980 - Phcenix, Arizona NRC Board Members:

Z. Ros2toczy V. Noonan Submittal s Available:

12/0E/80 - Meeting Transcript Expected Close-Cut Date: April,1982 Estimated SER Input Date:

April,1982 Eechtel described the method that they Oie using to assure that the installed eouipment will be qualified both environmentally and seismically.

The PRC board rembers were active participants in this reetirp. The other board eerbers did not appear co be intimately familiar with NRC requirements in this area.

Bechtel expects to have all recuired supportinc docurentation available by April 1982, at which tire NRP can cceplete its final audit.

ENCLOSURE 't

CURRENT PROCEDURES USED TO DATE IN PALD VERDE SYSTEM DESIGN REVIEW CF SELECTED SYSTEMS There have been four Palo Verde design review meetings (IDR'3; held to date. The following describes the procedures that have and are currently being used in the conduct of these meetings.

PROCEDURES 1.

System to be reviewed is selected.

2.

Applicant chooses panel members and sets neeting date.

A senior management representative of the applicant acts as chairman of the review panel.

3.

NRC Project Manager issues meeting notice and contacts the NRC review branches that should be involved.

4.

Cognizant NRC reviewers are chosen to participate as panel members.

Other NRC attendees participate as observers.

5.

A dri.f t meeting agenda is sent to NRC by the applicant for review and concurrence. The finalizing of the agenda normally involves meetings or telecons between NRC and the applicant.

6.

Conduct of the meeting:

a)

The AE or Vendor makes a presentation to the panel.

The presentation begins with a general system overview followed by a discussion by the At or Vendor on the manner in which the system meets applicable NRC and applicant requirements.

b) Questions are asked by the panel during pre-selected time periods.

Questions that cannot be answered by the AE or Vendor are listed as open items by the panel.

All open items are read by the chairman at the end of the meeting to avoid any la*er misunderstandirgs.

c) A transcript cf the proceedings is kept.

d) Handouts of the slides are given to all panel members.

e) All meetings are open to the public and most take place in the vicinity of the plant site.

. 7.

The transcript is formally submitted to NRC and sent to all ;anel memoers after proof-reading by the applicant.

Ini s normally takes 6-12 weeks.

8.

The AE cr Vendor submits its responses to applicant, no tnen formally submits these responses to NRC.

Tnese responses are also sent to all panel board members who are asked for accitional Ccoments.

this process has resulted in one or tao rounds of questions by the review panel to the AE or Vendor.

9.

The applicant suomits to NRC a letter stating tnat all issues have been resolved to the panel's satisf action.

10.

The staff writes an SER, based on its attendance curing the panei review, the transcript of the review aeeting and the resolutic: cf tre issues identifiec by tne review panel.

9 ENCLOSURE 4

Use of Ince;encent Design Reviens Enclosure '

in tne Aegulaccry Process Objective The principal cbjective of an indepencent design review in tre regulatory process is to cetermine tnat the system under revie. ceets tne applicable regulatory design criteria. The mechanism for achieving this CDjective is through the use of a technically cor.petent team of specialists.

Sucn a design review process is ccnsistent witn the requirements cf Section :::

of Appendix 3 of 10 CFR Part 50.

Advantages Enhance the design and operation of nuclear ;cwer plants

- Inter-disciplinary review ensures the adequate design and testing of safety systems

- Provides forum for relating past exravience in review

- Prevides for early identificatico and resolution cf pecDiens Drovices for an independent review of design Increase the involvement of the applicant (utility) in establishing the basis or demcnstrating to liance with NRC safety regulaticns.

- Responsibility always rested =itn utility, the conduct of ::R by tre utility can increase ARC's conficence in tre cafety of tr.e design Streanline the Licensing Process

- Can result in early SER input for certain disciplines

- Can result in a more in-depth audit of safety system with minimal expenditure in resources Disadvantages Added costs to applicants / utility May require regulatory change (rules and practices)

May require additional NRC senior technical staff Assessment of Experience to Date Based on the four design reviews conducted on the palo Verde project to date it appears that the safety of the systems reviewed will be ennanced.

For the systems reviewed it appears that some reduction af rascurces and time to complete the NRC review will be realized.

The comments of the NRC participants in the four IDR's regarding their views for improving the process has been requested. The consensus view of the staff participants in these IDR's was very positive.

In most areas of review the staff participants indicated the applicant's review board were technically competent and provided a thorough review of the subject matter.

It appears that STR inputs will be able to be prepared by the staff participants based on the IDR meetings and subsequent documentations.

SER input on D. C. power systems has been completed and it is estimated that use of the IDR process resulted in a 10" savings in staff resources.

However it is not clear at this time whether NRC staff resources will be reduced in all review areas.

The use of the !DR concept was used in the safety evaluation of the San Dnofre Unit 1 steam generator sleeving cperations.

This evaluation was written by the staff primarily on the IDR conducted by the applicant.

This IDR involved a nunber of disciplines (materials engineering, mechanical engineering and radiation protection) and the consensus view or stuff participants was very positive.

We have been informed that the conduct of participants was very positive.

We have been informed that tne conduct of the IDR oeeting cost the utility apnroximately 5150,000 dollars.

The successful use of the IDR technique in the regulatory process will not be completely demonstrated until the product of these reviews is tested in all pnases of the process (i.e., the technique will produce an SER that would be acceptable througn the ACRS and hearing process to licensing).

Recommendations to Achieve the Potential of IDR's in Imoroving the Regulatory Process The following Table lists issues which have been identified to date in the application of the IDR concept. The accompanying narrative witn each issue contains recommended improvements.

Identi fl(ation and lilutns ion of t w en Pe:

Ibit fer' ed in D yelatory Prviews 1ha h.e of the w

ill u u u l on l_ n ue A.

Iter e must l e anurant.e th.:t the r eviews (ninider To auure that all important e.afety l u nes a r e t orn idee rd, t he ut i l i t y all the leiportant saf et y luucs.

Of fic ial e rsponsitile for the IDR l'rngram and reprnentittiver, of the ournirant review tiranth or 1,v andwn should hold tret ings to es tablish a mut ually a(teptable a'lenda for the IOR.

It would generally be empetted that the f.ener al ikwlyn f:ri ter ia pequlat ory r,uldes

'st an f ard Pr view Plans, pr ant h Tec hnic al Pos i t ions, it ltulle tins, and v et en t r eview e spet tent e would tonstitute the Iasts for the agenda, if a partl(ular l une or t opi t-Is not addre n ed dueing thr if!R. the NI 0 will pursue the topic or t une outside the IDR pense n.

11 thete mt.st t= anot ant e that tte review I* (ondo( ted in an ure the epiality of the IDR pa.;'l and that the panet will etfettively l.y te(hnttally aiumplishe<t and knowlelqable sevirwers ump lewn t the role of the NPC staff, the NRC should adopt anri e nneiun i t a t e who effettively fulfill the role previno.ly perfor w d to the April (ant the followinq pollt.y:

tiy the NRC staff.

If NPC obser vers t an c ontludn that the Applirant lpR is an siteptable sub stltute for the review that would have ta en pet f orwd t y the NPt'. In a ylven area or for a ylven inple.. t he n t he IDR will tw' tradited in the Statl !.lP as the tesolution nf t ha t t eview ar ea nr topic i f t he NtsC nh.er ver s i nnelnde that the r eview is insuf fit lent lit a particular area or top 6i. the NPL will pur w the t u ne out.ide the IDH pe ni cu.

The N Rt. will wor 6 with the Applit ant to anur e tha t a lieview Doar d of e venplar y ter bn ti a l i nmpe t ent e an,I Independon(c is t onvened; wit h suf fit tent innwie tqe of the regulations to an uve that the impact of the IDit is maximited.

('. A determinatinn emnt tw-made regardir"; the dntuw ntallen to provide an adequate technical and legal basis in, li<ensing the Apriltant's n ihr neteuary to meet vethnical and legal r equi r emen t s n f t he destyn. the NPC will require that the f ollowing dm uwnf ation f a-provtded litPnsing prn(e u,

dotbet!

(1 le anu r ip t'.

nf the IDH rico t Ings.

(?

Written statee nts destribinq how open itew. have teen t esni ve.t. and

. 7 (1) A statenent f r om t he Arpttrant inficating:

(a) Thnse NFC temsla t ion +., Gin, ',PPs, pomela t or y Gu lites, !!!!.,

if Itulletins, ett.. with which the tesign is i n f u l l < nop l i.mt e ;

(b) Those NPC regulations f or whith there is not f ull timoliam e; a mt (c ) The justification for non-ce*plian<c.

D.

The te(hnit 1 anal legal role of the NPC past le lhe role of the NPC in the llut prm ess shall tio a*. follows i.te t e r m i ne d.

(1) the NPC will wn,>

with the AlTlltant to develop the a ge mf a for the IDR nu et inen

(?) ihe NPC will worlt w6th the Appfltant to enharv e the tc< hnic al q+ti t t y an't initopenlen<e of the ll1P finar d of Peviewers.

The NkC nh,er ver s enay par t i -

tirate wi th t he finar et in ques t lons and (onew nts on the s y s t e.r: it..s t yn.

(3) The NPC will audi t the pe nt en the nuyh obser ver s at IDR wetinT., through czamination of the t r an'.t ripts of t he me t tnys, ami the resolutton-of open i tem.

(4) The NUC will wetie i ts ',l R ha.ed on t he 89110winq:

(a) The "t emple teness" an 1 "<rea li t y" of the r eview per f or w<t liy t ier Applieant; (b) lhe jus t i f ic at ion pr oviiimt f or non-weri t an< e with estahlt*.het NPC pn,1tton, arul (t ) leaditional NPL veviews as neeteit.

O

- 3 L.

The role of the public in the rmw protess raust be in attordante with the recimanenda tions of NnP[G-02q2, t he i nreni s s i nn de t e r1ni ned.

published a polic y Statenent in January 1918, r egar ding the condut-t of technical pret tnqs in licensing cases, lho policy ind hated that to the extent ponible technical meetings hotwocn tha Staff and Applicants should be held in the vicinity of tha site and opan to the public. The applic ation of this pollty to thn IDR meetings needs clarific ation. On orm hanf, these nvetinqs may te viewod as Applic ant poetings in whic h the $taf f is an invitet nbserver participant. In this case, should the Applic ant nde tte dot ision reqar ding pntelic participation? On the other hand, if the NRC takes a more active role, a *. r er ryina ndo d, in the preparation of the mreting, wnuld tha polic y statenent mate it mandatory for opentnq the mretinqs to the publit 7 In the interim, the staf f plans to ma6e thesn trw etings open to tte publie and woqld issue meeting not at es.

f.

The applicability of IDRs to more challenging r eview the applicability nf tha IDR cone ept to multi-dl*,ciplinary r eview areas, suth ar eas should te deterinined.

as accident analysis, site suitability (trology, hydrulogy, mnternlogy) and enregency planning nunt be determinnd. At this tine, it is not clear whether the ipr concept can be successf ully applied to these review areas.

In addition, any review topic for which at t eptance c riter ia have not previously been d"veloped would te poor tandidates for an IDR.

Thus, a li6ely outume is that 58R inputs may te prepared using dif ferent techniqtes [lDR, @A ot her (i.e., tetent Ml H enimrience)].

A*, a result, the mannar in whir.h to sr.hedule and integrate tha 5[R inputs produced mint tio established. An estimate of a s(hedula template for the conduct of an IDR, based on nur experiente in dato, is shown in At tac harnt 1.

The question of maintaining tha viability of an SIR input pr odur ed ear ly in the review prot:ess must te addressed.

In sur.ressfully address the manner in whic h IDRs t an le inteqratnd into tha review prnte n it is necessary to dotermina the numter and the extent to which other review areas can apply the IDR contept. An initial survey has identified a number of eeview areas which nuy te am nable to IDP's (AttacErrnt 2).

A nor e detailed sur vey and/or a:.tull a prr tent.c in ea<h area will le required to dntermine sc ope and schedulo of thesp reviews then integrated project u hedules tan be pr epar ed, in addition, (nnsidoration shnuld le given to the ept imitation of the initiation of IDR's.

It appears that initiation of IDR's cat-ly in t he Ot phne, or per haps pos t-f p s t aqo, may t esu l t in ma r imi t ire, the hormfits tn the utilities in tha tiondue.t nf such revirws 4

to Enclosure 4 Independent Design Review Temclate*

Total Milestone d-Weeks Weeks IDR Meeting 0

0 Receipt of Transcript 6

6 AE/ Vendor Response to Open Items 3

9 Additional Board Questions 8

17 AE/ Vendor Response 2

19 Soard Closecut 4

23

-a f

4 t& i$

Attachrent 2 to Enclosure 4 BRANCH:

POWER SYSTEMS IDE SRP MEETIf;G SECTIO!

TITLE 1

8.2 Offsite Power Systems 8.3.1 AC Power Systems (Onsite) 2 8.3.2 DC Power Systems (Onsite) 3 9.5.4 D/G Auxiliary Systems and to Electrical Controls 9.5.8 4

9.5.2 Conmunications Systems 9.5.3 Lighting Systems 10.2 Turbine Generator (Speed Control and Overspeed Prote: tion System) 10.4.4 Turbine Sy-Pass System 5

Fire Review (as scheduled by the Chemical Engisering Branch)

RQ(F" LsI u I!

SYSTEMS WHERE THE IDR PROCESS r. Y BE EFFECTIVELY USED BRANCH:

AUXILIARY SYSTEMS IDR SRP MEETING SECTION TITLE 1

3.4.1 Flood Protection 3.5.1.1 External Missiles (Onside Cont) 3.5.2 External Missiles 9.3.3 Floor Drainage

10. t. 5 Circulating Water System 2

9.1.1 New Fuel Storage 9.1.2 Spent Fuel Storage 9.1. 3 Spent Fuel Cooling 9.1. 4 Fuel Handling 3

9.2.1 Service Water 9.2.2 Component Cooling Water 9.2.5 Ultimate Heat Sink 4

5.4.11 Pressurizer Relief Yalve 9.2.3 Demineralized Water Syster.

9.2.4 Potable and Sanitary Water System 9.2.6 Condensate Storage 9.3.1 Compressed Air 10.3 Main Steam 10.4.7 Condensate and Feed Water 10.4.9 Auxiliary Feedwater 5

3.6.1 Protection Against High arm Moderate Energy Line Ereaks 6

9.4.1 Control Room Ventilation 9.4.2 Fuel Pool Area Ventilation 9.4.3 Auxiliary Radwaste Area Ventilation 9.4.4 Turbine Area Ventilation 9.4.5 ESF Area Ventilation I

F-""

L t

SYSTEMS WHERE THE ICR PROCF.SS FA.Y BE 3

\\IL EFFECTIVELY USED B RANCH: INSTRUMENTATION & CONTROL SYSTEMS i

IDR SRP MEETING SECTIO" TITLE 1

7.2 Reactor Trip System 2

7.3 Engineered Sa fety Features 3

7.4 Systems Required for Safe Shutdown 4

7.5 Safety Related Display Instrumentation 5

7.6 All Other Instrumentation Required for Safety 6

7.7 Control Systems Not Required For Safety e

8

b L hy!

F L1JA2 s. a SYSTEMS WHERE THE IDR PRCCESS AY BE EFFECTIVELY USED BRANCH: REACTOR SYSTEM 5 i

ICR 5RP MEETING SECTION TITLE 1

4.4 Thermal Hydraulic Design 2

4.6 Functional Design of Reactivity Control 3

5. 2.1.1 Reactor Coolant Pressure Ecundary 5.2.2 Overpressure Protection System 5.2.5 React:r Coolant Pressure Boundary Leakage Detection 4

5.4.5 Reactor Core Isolatien C: cling System (SWR) 5.4.7 RHR Systen 5

15.1.1 Primary Cociant System 15.1.2 Pressure Decrease 15.1.3 Transients 15.1.4 15.1.5 Steam Line Sreaks (PWR) 15.2.1 Reactor Pressure 15.2.2 Increase Tr.ansients 15.2.3 15.2.4 15.2.5 5

15.2.5 Los, of Non-Emergen:y AC Power to Station Auxiliaries 15.2.7 Loss of hor:21 F.W. Flow 15.2.8 F.W. Systen Pipe Breaks (PWR) 15.3.1 Loss of Flew Transients 15.3.2 15.3.3 15.3.4 15.4.4 Increase Flow Transients 15.4.5

• O K I~

)I:'i'*r-d SYSTEMS ilHERE THE IDR PROCESS AY SE 6*

EFFECTIVELY USED BRAriCH: REACTOR SYSTEMS IDR SRP MEETING SECTION TITLE 15.4.6 Boron Concentration Decrease Increase Reac.or Coolant 15.5.1 Increase Reactor Coolant 15.5.2 Inventory Transient 7

15.4.9 Rod Drop Accident (BWR) 15.6.1 Inadvertent Opening of Safety Relief Yalvas-15.6.5 LOCA B

15,8 ATWS

. h.'.a! a' Branch Containment Systems Branch IDR 1 SRP F.EETING SECTION__

____ __ TITLE 1

6.2.2 Containment H;st Removal Systems 2

6.2.4 Containment Isolation Systems 3

6.2.5 Combustibile ses Contrcl S stem

/

(compliance wi:n 10 (CFR 50.44)

}

i Branch:

Core Performance IDR SRP f4EETING SECTICf1 TITLE 1

4.3 fluclear Desig -

2 4.4 Thennal Hydra;lic Design

d,7L TL FF Branch:

Effluent Treatment Systems Branch IDR SRP IEETING SECTION fTLt i

I Chap. 11 Radioactive t'.:ste Management

5

%3ML Branch:

Radiation Assessment Branch IDR

-SRP MEETING SECTION TITLE Chap. 12 Radiation Prc:ection i

i l

.