ML19308B907
| ML19308B907 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/29/1979 |
| From: | Boyd R Office of Nuclear Reactor Regulation |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19308B903 | List: |
| References | |
| FOIA-80-587, RTR-NUREG-0460, RTR-NUREG-460, TASK-TF, TASK-TMR 791029, NUDOCS 8001170559 | |
| Download: ML19308B907 (5) | |
Text
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HEMORAUDUM FOR:
Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM:
Roger S. Boyd, Director j
Division of Project !!anagement, NRR
SUBJECT:
CONFLICTS OF NUREG-0460 IMPLEtlENTATION PLAN WITH COMilSSION POLICY STATEllENTS ON STANDARDIZATION r
s In the ATUS meeting on January 24, 1979, a number of questions were raised concerning the differences between the implementation plan of UUREG-0460 Volume 3 and that proposed in the memo C. Heltenes to i
/
W. Gamill dated January ll,1979. Some of these questions really focused on the central question regarding the spectfic nature of the NRC's standardization policies, and whether or not the innlementation plan of NUREG-0460 Volume 3 would be considered consistent with those policies.
The Standardization Branch has reviewed the recent Commission policy statements from this viewpoint, cnd believes that the NUREG-0460 implementation conflicts with the NRC standardization policies.
SB has the following co,ments:
(1) Reference Systems SB believes the clear intent of the Commission's policy on standardization is that standard plants are to have a cormon design.' For example, the June 1977 policy statement stated that the FDA-1 was
" Acceptable fbr referencing by operating license applicants who have previously referenced the PDA i
I on which the FDA-1 is based, and remain in effect l
until those referencing applications have resulted l
in the granting of operating licenses or have been l
disqualified for good cause as reference applications."
l This statement implies that the PDA/FDA plants were to be a coEon design, and that approval of final design via the FDA would cover all plants unless there were unusual circumstances severe enough to dis-qualify a plant as a standard.
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liarold R. Denton J3 2 91979 The question on ATUS rodification is not whether to backfit an ATVS fix to standard plants, but whether we should impose differ-ent ATWS fixes for applications that reference valid three-year PDA's, and subsequently, the FDA-1 at the OL stage.
r The implerentation plan proposed in fiUREG-0460 would require plants referencing valid PDA's to have different fixes:
Per flUREG-0460 Volume 3 Alternative 3 Alternative 4 GESSAR-238 NI 4 units 2 units i
CESSAR 6 units 11 units r
Per SB Recomendations Alternative 3_
Alternative 4 GESSAR-233 !!I 6 units CESSAR 17 units I
In this regard, it can be noted that the flVREG-0460 implementation plan makes no distinction between custom and standard plants, and thus, there is no relationship between this plan and expiration dates of PDA's. The SB recomer.dation would permit all plants referencing the three-year PDA to retain a comon design.
Since i
the Comission has endorsed the imposition of Category II, III, and IV matters on the extended PDA's, the SB recomendation 1
involving applying an Alternative 4 fix to the extended PDA's is consistent with the Comission'.s standardization policy.
.Thus, the SB recomendation treats the PDA extensions and the forward reference of the FDA for CP applications as different j
reference designs while maintaining all plants referencing valid 1 T".
three-year PDA's to be comon.
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..*i Further, in approving the August 1978 Policy Statement, the Comission specifically emphasized a need for the staff "... to
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more effectively limit changes to approved standard designs to S
those required f6r public health and safety." Thus, it would seem that in requiring two different fixes for an approved design, l
the staff may be naking or implying a finding that an Alternative 4 fix is required for public health and safety for a given plant design in some cases, but in other cases, an Alternative 3 fix is acceptable; i.e., that the Alternative 4 fix is required for some plants of comon design but not required for others of the i
same design, in order to assure public health and safety.
It is our understanding from coments at the meeting that this is not the case.
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Harold R. Denton g.3 7. gg (2)
Duplicate Plants We also believe that the clear intent of the Comission's policy is that duplicate plants are to have a comon design. For example, the August 1978 Policy Statement stated:
"A docunent termed the final duplicate design approval, or FDDA, will be included in the SER for each application referencing the duplicate plant final design. The FDDA will be applicable to any docketed operating license appli-cation referencing the duplicate plant final design, and for which the construction permit was based on referencing of the duplicate plant preliminary design, unless disquali-fled for good cause as a standard design application. An extensive delay in construction of the plant with an appli-l cation for an operating license much later than norcally expected, could, for example, constitute one such good cause."
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However, the implementation schedule of HUREG 0460 would require duplicate plants to have different fixes:
l Per NUREG 0460 Volume 3 Alternative 3 Alternative 4 I
Cherokee 1, 2 & 3 3 units 3 units Perkins 1, 2 & 3 The SB recomendation is that all units of Cherokee and Perkins implement the Alternative 3 fix.
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- Since the Perkins units reference the CESSAR PDA reference system, N.
these units are included in the total for Alternative 3 presented 7",
above for the reference systems. Thus, they do not represent M'
additional units.
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(3)
Replicate Plantsf
.'3 As for reference plants and duplicate plants, we believe the Comission policy intended that replicate plants have, to the r-degree practical, a design cormon to the base plant. For y,
example, the August 1978 policy statement stated:
"The natters referred to in items (7) and (S) above, (these refer to RRRC Category II and III natters) are applicable to the base plant and it is preferred that, I
if practical, they be resolved on the base plant with required changes replicated on the replicate plant."
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Harold R. Denton JMl ? 9 !l'4 However, the implenantation plan of f;UREG 0460 Volu~,e 3 uould require different fixes for the replicate plant from the base plant:
Per flUREG 0460 Volume 3 Base / replicate Alternative 3 Alternative 4 tiillstone/Jamesport Millstone 3 Jamesport 1 & 2 Byron /liarble Hill Byron 1 & 2 Marble Hill 1 & 2 Seabrook/New England Seabrook 1 & 2 New England 1 & 2 Haven Koshkonong/ Haven Palo Verde /Palo Verde Palo Verde 1, Palo Verde 4 & 5 2&3 I
Per SB Recommendation - All replicate plants would have the l
same fix as the base plant - except for Haven, which is not a i
true example of repitcation. However, in tems of substance, l
this consideration is not very important, since all replicate plants, except Palo Verde 4 & 5, are W units and for these units there is no design difference biitween Alternative 3 and Alternative 4.
Thus, there should be no change in risk for
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the W t. nits between Alternative 3 or Alternative 4.
In addition, Palo Verde 4 & 5 references the CESSAR reference system covered in the totals for Alternative 3 fix under reference systems (item 1) above and thus, these units do not represent additional units.
Thus, dropping the W units fron consideration, the SB recomendation i
actually involves tiie shifting of thirteen units (11 CESSAR and
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2 GESSAR-238 NI) from Alternative 4 to Alternative 3.
This number f.f ?
is believed to be so small as to be well within the band of
[h y' uncertainty, with' regard to the overall risk in terms of public I
health and safety.
I (2 ' 7,?
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5fJ Based on our review of the Comission's policy statements we believe Y
the following points should be considered:
3'.
(1) The Comission's policy on standardization supports the concept that imposition of new regulatory requirements should pemit i
standard designs to remain comon from plant to plant.
l (2) The Comission is very concerned with the nanner in which the staff applies new regulatory requirenants to approved standard designs. This remains an open matter as far as we know, i
l y
3. ^ 9 m:*
Harold R. Denton,
a (3) The N'JREG-0460 implementation plan conflicts with the Comission's standardization policy.
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' In light of the above, we believe the implementation plan delineated in Option 6 of the memorandum C. Heltemos to W. Gamill dated 1/11/79, generally sumarized in this memo, should be adopted for standard plants.
Beyond consideration of the above recomendation, several other thoughts are worth considering.
l....
1.
Regardless of your decision in this matter it is essential that the effect on standardization be considered knowingly.
2.
It is important that any Commission oaoer on this matter deal specifically With the impact on standardization.
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3.
An attempt to resolve the question by deciding that all standardized
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plants should abide by Alternative 4 should, in itself, be con-i sidered vis-a-vis its impact on standardization.
If we are to i
signal the industry that, in hindsight, they would have been better off with custom plants, then that same signal would serve j
to so advise them for the future.
4.
We thought enough of standardization to update and revitalize
.s' our policy. To police it we created a separate Standardization Branch. The effort on this issue, reflected in the January 11
. memo and this memo, is a fine example of the Standardization Branch doing its job.
0@1 DO t '.. ". -
cc:
E. Case Neu S Bd
.. "'t R. Mattson Roger S. Boyd, Director c
R. DeYoung Division of Project Management M.;c.,
V. Stello Office of Nuclear Reactor Regulation M'
We l
DISTRIDUTION:
i DOCKET FILE l,' '
NRR RDG j
SB RDG DPM:SB DPM:SB DPM:SAR DPM DPM WKane:ms CJHeltemes WPGamill DFRoss RSBoyd 1/26/99 1/ /79 1/ /79 1/ /79 1/ /79