ML19308B908
| ML19308B908 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/11/1979 |
| From: | Heltemes C Office of Nuclear Reactor Regulation |
| To: | Gammill W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19308B903 | List: |
| References | |
| FOIA-80-587, RTR-NUREG-0460, RTR-NUREG-460, TASK-TF, TASK-TMR NUDOCS 8001170564 | |
| Download: ML19308B908 (15) | |
Text
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1 JAN 111979 g
MENGRAND'Ji: FOR-William P. Garxnfil, A'ssistant Director for Standardization and Advanced Reactors Division of project Management i
FRT..
C. J. Heltemes, Jr., Chief, Standardization Branch, Division of Project Management
SUBJECT:
RECOMMENDED IMPLEMENTATION PROGRAM FOR ATWS FIXES ON STANDARD PLANTS i
As you knor: the Standardization Branch has reviewed the ictplementation progra= for ATWS in both the draft and final versions of i:UREG-0460, Volume 3.
The draft vers 10n of the report, which we recierad in Eovecher 1978, took special note of standard plants and percitted all plants utilizing the sa ne standard design to have a common ATWS fix. This is j
c',ar.istent with the standardization program and therefore, we agreed with j
that implementation plan.
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The final version of the report, issued in Dece ber 1978, had a radically i
different implementation plan which, in effect, ignores standard plants and in certain instances, requires plcnts utilizing the same standard design to implerant different ATES fixes. See Enclosure 1 for a su=:ary of the effect of the HUREG-0460, Volume 3 icplementation plan ca stcad:rd i
plants. t!e were not consulted about this change and, if we had boca, would-have taken exception. Since the publication of GUREG-0460, Vole =e 3, the RRRC has r.et to consider, among other things, its implementation In R. Boyd's presentation'to the RRRC, he recocoended that the program.
RRC disapprove the EUREG-0460 icplecentation plan and parait stendard plent designs to bs co::an from plent-to-plant eith respect to the req:: ired i
ATWS fix. As a result, the RRRC, while approving the implementation pro-gram for custom plants, was unable to cske a recoc=endation to the ERR Office Director for icple:entation of ATlfS for standard plents.
Subsequently, wa have parforced a study of various icplementation plans for stcndard plcots. This study is providad in the Enclosure 2 to this comorandum. We have considered six options rcnging from Option 1, which closely approxicates the implementation plan in the draft report, to Option 6, the one that we now erecom:nend. These options differ cainly in g%r 0**
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the icngth of time that the Alternative 3 fix could be U;cd en It'.nd:.rd de icns and the canner in which the Alternative 4 fix is p5:.:cd 'nto
- .p;reved PDA's. Under Option 6, our recc=cn:'ed irpler.catiticn ; rc;rc,
Lo :.undard plcnts docketed Leyond 12/31/78 uuld be ' crc.ndMh rcd' dth respc-et to the Alternative 4 fix and thcrefore, til :.uch p1;.nts tre t.:x hnoen. All replicate plants sould h:ve a ccmon fix cith the bue plcnt cnd c11 duplicate plcnts s:ould have a comon fix. A total of 19 tatt: t 3uld f
be shifted froc the Alternative 4 fix required by I UREG-0460 to the Altcrn:-
tive 3 fix under the reco= ended Option 6.
These units cre idcntified in.
Option 6 can be expressed as follows:
All three-year NSSS cnd HI PDA's that hcVe been referenced in c utility application that received a CP prior to Jcnuary 1,1978 s chall be backfit to Alternative 3.
The cxtended PDA's, cad c11 other current cnd future NSSS cnd NI cpplicctions, :hc11 tcplczent Alternative 4.
The FDA-l's for the three-year NSSS cnd NI PDA's thtt have been referenced in a utility application that received a CP prior to January 1,1978 shall include both Altcrnctive 3 cnd Alternative 4 fixes. Only the FDA-1 design eith the Alternttive 4 j
fix chall be referenced in CP cppitections. All CDP cnd TI TDA's chall be consistent with the tuting !!SSS or !!I. All current dup 11-ccto plcnts end repitcate plants, with the cxecption of !!cren, shall inplement en Alternative 3 fix. All future duplictte end replicate plants shall impic:> ant the ATES fix required for the lead plcnt. All current cnd future I;L cpplications shall icplc :nt an Alternative 4 fix.
1.'e belicyc Option 6 best caots the collcettre toc 1s of the entiro stcff.
He believe these goals cro to icplement the cost desireble ATWS fix. frc:a both the safety cnd practicality standpoints, thile et the cats tice, p:rr.itting cpproved ettndard dasicns to rencin co=on frca plcnt to plcnt.
!'o recomend that in light of the significtnce of this r.stter cnd its importance to the vitality of the NRC standardizction prograo, that this proposed icpler:ntation plan for stcndard plcnts t>e considered for cdoption j
by TRR r.:nct:::nt.
Cricir.nl signed bn F= Me.
J C. J. Holtc es. Jr., Chief
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Standcrdization Brcnch Division of Project Management
'Ndiccures:
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1.
Effect of RUkEG 0460.Yol. 3 Icplementation Flen on Std.
(1cnts z.
Ir.vc:tigaticn of Options JPM :S_
DPM Cp//g79,_
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um 6
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STANDARD PLAT,'TS WITH CP PRIOR TO 1/1/78
_ Pia n_t !;are Reference System Replicate Duplicate South Texas 152 RESAR-41 Yes Byron 152 Ye5 Braidwood 1&2 Yes Callaviay 1&2 Palo Verde 1,2&3 CESSAR Hartsville 1,2,354 GESSAR-238HI Yes Wolf Creek Yes Sterling Yes Tyrone Yes l
Cherokee 1,253 CESSAR i
(21 Units) l STANDARD PLANTS WITH CP BETWEEN 1/1/78 and 1/1/79 i
Plant Name Reference System Replicate Duplicate Phipps Bend 1&2 GESSAR-238NI l
fiarble Hill 1&2 Yes WPPSS 3&5 CESSAR Yellow Creek 1&2 CESSAR I
(8 Units) i l
STANDARD PLANTS UNDERG0ING REVIEW Plant Name Reference System Replicate Duplicate Yes Perkins 1,2&3 CESSAR t
Black Fox 1&2 GESSAR-238 NSSS t
Erie 1&2 BSAR-205 Palo Verde 4&5 CESSAR Yes New Haven 1&2 CESSAR SWESSAR/CESSAR Yes Jamesport 1&2 Yes New England 1&2 Yes Haven (16 Units) l
Ef fect of NUREG 0450, Volu. e 3 Ic-lerer,tation Plan en SETcTiirTrarcs m
SUMMARY
FOR REFERENCE SYSTEMS System Name CP's Prior to 1/1/78 CP's After 1/1/78 GESSAR-238 NI Hartsville 1, 2, 3 & 4 Phipps Send 1 & 2 CE SS AR.
Palo Verde 1, 2 & 3 WPPSS 3 & 5 Cherokee 1, 2 & 3 Yellow Creek 1 & 2 Perkins 1, 2 & 3 Palo Verde 4 & 5 New Haven 1 & 2 RESAR-41 South Texas 1 & 2 SWESSAR/RESAR-41 BRAUNSAR New Haven 1 & 2 SWESSAR/CESSAR RESAR-35 SWESSAR/RESAR-3S GESSAR-25; Black Fox 1 & 2 GESSAR-238 NSSS BOPSSAR/RESAR-41 Erie 1 & 2 BSAR-205 RESAR-414
SUMMARY
FOR DUPLICATE PLANTS _
Plant Names CP's Prior. to 1/1/78 CP's After 1/1/78 l
l Byron /Braidwood Byron 1 & 2 Braidwood 1 & 2 4
SNUPPS Callaway 1 & 2 Wolf Creek Sterling Tyrone Cherokee /Perkins Cherokee 1, 2 & 3 Perkins 1, 2 & 3 I
i - Page 2
_ -c o rur e a m p i er e n :n gtrvTa n on st a n fsWFW5iit s
SUMMARY
FOR REPLICATE PLANTS Pl ant f.ames' CP's Prior to 1/1/78 CP's After 1/1/78 Millstone /Jamesport Millstone 3 Jamesport 1 & 2 Byron / Marble 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, 2 & 3 Palo Verde 4 & 5 e
- Koshkonong withdrawn i
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l - oace 3
ENCLOSURE 2 INVESTIGATION OF OPTIONS HUREG-0460, Volume 3 provides an implementation Problem:
program for ATWS fixes for standard plants that is not consistent with the Standardization Branch's I
perception of the Commission's goals for standard-ization.
The purpose of this study is to define the extent of i
tac negative impact of the NUREG-0460 implementation
Purpose:
p.agram on the Commission's standardization program, to propose and justify an alternate implementation anu Tar '+andard plants.
progr o.'
A draft copy of NUREG-0460, Volume 3, dated November 24, 1978 was issued by DSS to the remaining three NRR divisions
Background:
The implementation section for review and concurrence.
in that document contained specific provisions for custom and standard plants.
It provided that Alternative 3 would be implemented on all plants referencing approved standard designs existing at the time the requirements are promulgated, including administratively extended Alternative 4 would be applied to future standard PDA's.
The Standardization Branch reviewed this imple-designs.
mentation and concluded that it properly accounted for standard oesigns in that, for a given standard design, the alternative fix was defined in such a manner that it would be consistently applied to all plants using that standard design.
Subsequently, in December 1978, the final version of NUREG-0460, Volume 3 was issued. This version had a radically different implementation plan, which, in effect, ignores standard plants and, in certain instances, requires plants utilizing the same standard The Standardi-desian to implement different ATWS fixes.
zation Branch was not consulted about this change prior l
to publication of the final version of NUREG-0460. We, of course, have taken exception to the implementation Since the publication of the final version of plan.
the report, the RRRC met to consider, among other things, the implementation program.
The Director of DPM, in his presentation to RRRC, recommended that the RRRC disapprove the NUREG-0460 implementation and permit standard plant designs to be common from plant-to-plant with respect 6
to the required ATWS fix. As a result, the RRRC, while approving the implementation plan for custom plants, was unable to make a recommendation to the NRR Office Director for implementation of ATWS fixes for standard plants.
Due to the relatively short period of time between the issuance of the final version of the report and the RRRC meeting, specific alternatives to the implementation plan could not be documented.
Subsequent to the RRRC meeting, the Standardization Branch performed a study of various alternative implementation plans for standard plants that are acceptable to us. We have studied six i
options and selected one of these for management consid-eration as an alternative to the implementation plan in the final version of NUREG-0460, Volume 3.
Discussion:
The standardization program provides a number of advan-tages to the staff and industry. While some of these advantages have already been achieved, others have potential for the future. A list of some of the advantages considered to be important to the staff follow:
(1)
A greater concentration by industry and the staff on a limited number of designs (usually one per vendor) provides for a greater understanding of the designs and a greater degree of assurance that they meet all requisite safety criteria.
(2)
The commonality of designs achieved by standardiza-tion provides for a reduced licensing effort.
That is, a single review can apply to a population of plants, thereby reducing the staff manpower required for separate reviews.
(3)
The commonality of designs permits generic fixes on plants should problems develop. This should also have application to standard operating plants.
(4)
Standardization provides the opportunity for single l
stage licensing that is not achievable with custom l
designs.
As a consequence, since the advent of standardization, the staff has made every attempt to assure that standard designs remain common. We recognize that this has not I
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been fully achieved either by the staff or industry.
There have been a number of reasons for this, not the least of which has been the lack of a focal point such as the newly formed Standardization Branch, for addressing these matters.
We do not feel that because deviations J
have occurred in the past that they are justified for the future. We plan to make every attempt to assure that industry deviations from approved standard designs t
are minimized.
We also believe that the "grandfathering" of regulatory requirements on standard plants has never really been tested. We believe such "grandfathering" is justified, and we believe that the concept is justified, and we l
believe that ATWS provides an appropriate forum for the Commission to address it.
Simply stated, it is our belief that without "grandfathering" of regulatory requirements, standardization will erode and eventually die.
If the staff is unwilling to permit standard designs to be common from plant to plant with respect to regula-l tory requirements, then we have little reason to expect industry to maintain standard designs consistent from i
plant to plant.
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Summary of Options:
The six options provided below are based on the RRRC decision that both Alternative 3 and 4 fixes are to be
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applied to custom and standard plants and that it is not necessary to backfit Alternative 3 to plants receiving CP's prior to January 1,1978. The six options differ primarily on the number of real and potential standard phnts that would be " grandfathered" with respect to the Alternative 4 ATWS fix, i.e., the number of standard plante, that would receive CP's beyond January 1,1978 that would still be permitted to implement an Alternative 3 fix.
Each of these options is based on the consideration of two basic principles of standardiza-tion, i.e., backfitting of a standard design, if required, should be based on the most limiting plant referencing that design, and the commonality of all plants referencing a given standard design should not be precluded by l
backfitting decisions.
The options that follow range from Option 1, which closely approximates the implementation plan specified in the draft version of NUREG-0460, Volume 3 which involves the j
largest number of grandfathered plants, to Option 6, l
which involves the least.
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.4.
OPil0N 1 All current PDA's, extended PDA's, and FDA-l's for current or extended
(
PDA's for NSSS or NI applications should be backfit to Alternative 3.
All B0P All future NSSS or N1 PDA's should implement Alternative 4 All current or TI 'PDA's should be consistent with the mating NSSS or N1.
duplicate plants and replicate plants, with the exception of Haven implement an Alternative 3 fix.
All current and future ML plants should be consistent with the lead plant.
applications shall implement the Alternative 4 fix.
Grandfathered Plants Phipps Bend I & 2 Marble Hill 1 & 2 WPPSS 3 & 5 Yellow Creek 1 & 2 Perkins 1, 2, & 3 Black Fox 1 & 2 Erie 1 & 2 i
Palo Verde 4 & 5 j
New Haven 1 & 2 Jamesport 1 & 2 i
l New England 1 & 2 i
New Plants Potentially Thru 12/22/83 GESSAR-238 NI 12/31/83 CESSAR 12/31/83 RESAR-41 12/30/84 RESAR-35 3/10/85 GESSAR-238 NSSS 3/31/85 GESSAR-251 5/31/86 BSAR-205 11/4/86 RESAR-414 Summary - 23 plants plus potential new plants thru 11/4/86 4
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OPTION 2 All NSSS or NI PDA's that have been referenced in a utility application docketed prior to January 1,1978 shall be backfit to Alternative 3.
The extended PDA's and FDA-l's for such PDA's should also implement an Alternative 3 fix.
All other current or future NSSS or NI applications should implement and Alternative 4 fix.
Ali B0P or TI PDA's should be consistent with the mating NSSS or NI.
All current duplicate plants and replicate plants,with the exception of Haven, shall implement an Alternative 3 fix. All future duplicate plants and replicate plants shall be consistent with the lead pl a nt. All current and future ML applications shall implement an Alternative 4 fix.
Grandfathered Plants I
Phipps Bend 1 & 2 Marble Hill 1 & 2 WPPSS 3 & 5 Yellow Creek 1 & 2 i
i Perkins 1, 2, & 3 Black Fox 1 & 2 l
Erie 1 & 2 Palo Verde 4 & 5 New Haven 1 & 2 Jamesport 1 & 2 l
New England 1 & 2 GESSAR-238 NI New Plants Potentially Thru 12/22/83 CESSAR 12/31/83 RESAR-41 12/31/83 1
GESSAR-238 NSSS 3/10/85 BSAR-205 5/31/86 Summary - 23 plants plus potential new plants thru 5/31/86 6
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OPTION 3 5
All NSSS or N1 PDA's that have been referenced in utility applications that received a CP prior to January 1,1978 shall be backfit to Alternative 3.
The extended PDA's and FDA-l's for such PDA's should also implement an Alternative 3 fix.
All other current or future NSSS or NI applications should implement an Alternative 4 fix.
All BOP or TI PDA's should be consistent with the mating NSSS or NI.
All current duplicate plants and replicate plants, All future with the exception of Haven, shall implement an Alternative 3 fix.
duplicate plants and replicate plants should be consistent with the lead plant.
All current and future ML applications shall implement an Alternative 4 fix.
Grandfathered Plants Phipps Bend 1 & 2 Marble Hill 1 & 2 WPPSS 3 & 5 Yellow Creek 1 & 2 Perkins 1, 2, & 3 Palo Verde 4 & 5 New Haven 1 & 2 Jamesport 1 & 2 New England 1 & 2 GESSAR-238 NI New Plants Potentially Thru 12/22/83 12/31/83 CESSAR 12/31/83 RESAR-41 Summary - 19 plants plus potential new plants thru 12/31/83 i
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7-4 OPTIO" 4 All threc-year and five-year NSSS and NI PDA's that have been issued prior The extended PDA's to January 1,1979 shall be backfit to Alternative 3.
and all future PDA's for USSS and NI applications shall implement an In such cases, only Al ternative 4 fix.
implement both Alternative 3 and Alternative 4 fixes.
the FDA-1 design with the Alternative 4 fix shall be referenced in new CP All BOP or TI PDA's should be consistent with the mating All current duplicate plants and replicate plants, with a ppl icati ons.
All future USSS or NI.
the exception of Haven, shall implement an Alternative 3 fix.
duplicate plants and replicate plants should be consistent pl a n t.
4 fix.
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Grandfathered Plants _
Phipps Bend 1 & 2 Marble Hill 1 & 2 WPPSS 3 & 5 Yellow Creek 1 & 2 Perkins 1, 2, & 3 Black Fox 1 & 2 Erie 1 & 2 Palo Verde 4 & 5 New Haven 1 & 2 Jamesport 1 & 2 New England 1 & 2 New Plants Potentially Thru 12/30/79 RESAR-35 3/10/80 GESSAR-238 NSSS 3/31/80 GESSAR-251 5/31 /81 BSAR-205 10/4/86 RESAR-414 11/4/86 Summary - 23 plants plus potential new plants thru k
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'Ofi10:, 5 All three-year PDA's that have been referenced in a utility application docketed prior to January 1,1978 shall be backfit to Alternative 3.
The extended PDA's and 611 future PDA's for NSSS and NI applications snould implement an Alternative 4 fix.
The FDA-l's for the three-year NSSS and NI PDA's shall include both Alternative 3 and Alternative 4 fixes.
In such cases, only the FDA-1 design wit.1 the Alternative 4. fix shall be referenced in new CP applications. All BOP or TI PDA's should be consistent All currer.t duplicate plants and replicate with the mating NSSS or NI.
plants, with the exception of Haven, shall implement an Alternative 3 fix.
All future duplicate plants and replicate plants should be consistent with the lead plant. All current and future ML applications shall implement an Alternative 4 fix.
Grandfathered Plants Phipps Bend 1 & 2 i
Marble Hill 1 & 2 WPPSS 3 & 5 Yellow Creek 1 & 2 Perkins 1, 2, & 3 i
Black Fox 1 & 2 Erie 1 & 2 l
Palo Verde 4 & 5 New Haven 1 & 2 Jamesport 1 & 2 hew England 1. & 2 GESSAR-238 NSSS New Plants Potentially Thru 3/10/80 5/31/81 BSAR-205 Summa ~y - 23 plants plus potential new plants thru 5/31 /86 t
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_0PTION 6 All three-year NSSS and NI PDA's that tave been referenced in a utility application that received a CP prior t.' January 1,1978 shall be backfit to Alternative 3.
The extended PDA's, and all other cur ent and future NSSS and NI applications, shall implement Alternative 4 The FDA-l's for the three-year NSSS and NI PDA's that have been referenced in a utility application that received a CP prior to January 1,1978 shlll include both Alternative 3 and Alternative 4 fixes.
Only the FDA-1 design with the Alternative 4 fix shall be referenced in CP applications. All B0P and TI PDA's shall be consistent with the mating NSSS or NI, All current duplicate plants and replicate plants, with the exception of Haven, shall implement an Alternative 3 fix.
All future duplicate and replicate plants shall implement the ATWS fix required for the lead plant.
All current and future ML applica-tions shall implement an Alternative 4 fix.
Grandfathered Plants i
Phipps Bend 1 & 2 sUC t
Marble Hill 1 & 2 v WPPSS 3 & 5 Jt Yellow Creek 1 & 2 C f i
Perkins 1, 2 & 3 c'E j
Palo Verde 4 &_5_-
New Haven 1 & 2 JE l
Jamesport 1 & 2 New England 1 & 2 u
Summary - 19 plants with no potential new plants 1
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We have utilized the following criteria in our
- ecc.Tmen da t i on_:
evaluation of the relative merits of the six options:
(1)
The health and safety of the public should be adequately protected.
(2)
The implementation plan should not preclude commonality of plants referencing the s ime standard design.
Implementation plan should be reasonably consistent (3) with RRRC decisions to date on ATWS implementation for custom plants.
(4)
Future applications should implement the most complete ATWS fix.
Standard plants should not realize a more severe (5) penalty than custom plants in the implementation plan.
l The number of plants that would receive a different (6)
ATWS fix than that specified in NUREG-0460, Volume 3 should be minimized and quantified with reasonable certainty.
Backfitting of a standard design should be determined
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(7) based on the most limiting plant referencing that i
design.
We believe an implementation plan consistent with these criteria can best meet the collective goals of the entire staff.
In our view, Option 6 best these criteria and we therefore recommend meets that it be selected as the implementation program for backfitting of the ATWS fixes to standard plants.
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