ML19308B918
| ML19308B918 | |
| Person / Time | |
|---|---|
| Site: | Crane, Atlantic Nuclear Power Plant  |
| Issue date: | 03/07/1977 |
| From: | Minogue R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19308B919 | List: |
| References | |
| RULE-RM-50-12, TASK-TF, TASK-TMR SECY-77-126, NUDOCS 8001170626 | |
| Download: ML19308B918 (34) | |
Text
W,OFRCHAL,nUSE ONE w
M ch 7, 1977 UNITE 3 STATES SECY-77-126
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NUCLEAR REGULATORY COMM!SSION CONSENT cal.END AR ITEM I er:
The Co==issioners Robert 3. Minogue, Director, Office of Standards De elopment
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Thru:
Execurive Director for Operations Nhh Iggym LJ Subj ect:
PETITION FOR RULE MAKING FILED BY TEE ATLANTIC COUNTY CITIZENS g ~
COUNCIL ON ENVIRONE (ACCCE):
PROPOSED AMENDMENTS TO 10 CFR M
PART 50 TO REQUIRE OPERATIONAL TESTING OF PILOT MODEL OR PROTO-TTPE VERSIONS OF NUCLEAR POWER PLANTS PRIOR TO ISSUANCE OF A LICENSE TO MANUFACTURE (PRM 50-12)
?urnose:
To secure Co-4ssion approval of a proposed notice of denial of a petition for rule making.
s Categorv:
This paper covers a major policy question.
Issue:
Should 10 CFR Part 50 be amended to require f"T1 scale opera-tional system testing of pilot =odel or prototype versions of nuclear power plants, in the configuration expected in situ, before issuance of a license to =anufacture.
Decision L:.
c-it er12 :
1.
Would the proposed regulations significantly i= prove the 1
protection of public health and safery or of the environment?
m 2
Would the proposed regulations provide sufficient benefits
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to justify the associated delay in licensing time and the increased costs and administrative burden that would be placed on industry and the NRC staff?
s atives:
1.
Continue present policy of not requiring operational.
testing of a pilot model or prototype of nuclear power plants prior to issuance of a license to =acufacture and deny the ACCCE petition.
2.
Publish for coc=ent a proposed rule that would require ful.T. scale operational systect testing of pilot model or proto-type versions of nuclear power plants,. in the configuration
=P expected in situ, before a license to manufacture can be issued.
Contact:
M. R. Fleist-=
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Th2 Co d sioners
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I ' INS ussion:
In June 1974, the ACCCE petitioned the U.S. Atomic Energy Com-
=f mission (PRM 50-12) (see Enclosure "A") for a rule that would
- Q6 require full scale operational system testing of pilot model or
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prototype versions of nuclear power plants, in the cenfiguration
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expected in situ, before a license to manufacture can be issued.
.Jizsh The ACCCE petition is based on the conviction that the offshore 35EQ power system (OPS) type application, with the likely prolifera-
- .JsE tion of mass produced plants, warrants more extensive testing E;;;; ;;..
' than has been accorded individual or single-sited land-based
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While the petition refers to the OPS type applicatiori, the staff
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paper will treat the. subject.as a generic issue concerning all 2.. :
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baseload electric generating stations that may be licensed
.M pursuant to Appendix h of 10 CFR Part 50.
Furthermore, while we realiz. the petition only addresses the license to manufacture 7
regulations, the petitioner also has concerns relative to in situ
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conditions at the site. Therefore, the following material will also address site related considerations.
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The task for developing a response to the petition has been ke,cd
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to the staff review related to the periding licensing actions for the offshore nuclesr power plants.
The results generat'ed during
.I the case review have been used in formulating the proposed NRC position presented in the paper.
The identification of the novel features of the floating plants as well as the nethods to be used for design verification (see pages 9 - 13 of Enclosure C) relied extensively on infor=ation gathered during the licensing phase.
M_._
Alternative 1:
Continue present policy of not requiring opera-A tional testing of a pilot model or pratotype of nuclear power
. #j plants prior to issuance of a license to manufacture and deny the Lidi ACCCE petition.
&u ~ Ej Pro: (1)
Currently required testing programs adequately demon-strate functional capability of safety-related systens and prototype testing would not produce any significant SFr '
additional assurance of safe operation.
(2) There will be no added expenditures (N$1B) or time bEEiE delays (N7 years) associated with the production and
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testing of a pilot plant.
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(3) No basis has been presented for the request for rule making other than a belief that the different circum-stances of the mass produced plants requires more
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extensive testing than is presently done. No facts have been presented to indicate that the present NRC procedures are inadequate in any way to protect public
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health and safety.
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D Con: (1) Would not allay the fears and concerns of some members
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E of the public relative to the safety of mass produced
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nuclear power plants.
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!E Alternative 2 Modify the regulations to require full scale operational system testing of pilot model or prototype versions h.+
E of nuclear power plants, in the configuration expected in situ, before a license to manufacture can be issued.
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Pro: (1) Would provide some members of the public with greater F='
assurance that the safety of mass produced plants will j
be adequate to protect the public.
H Con: (1)
There.will be a significant cost (N$1B) in,.ved in building a pilot plant-or prototype, siting it, testing it and subsequently having to resite the plant if it is approved.
(2) There will be a time delay (N7 years) in getting plants on line due to the time required to manufacture the pilot plant (44 years), deliver, site. and check out the plant (41 year), and test the plant (N2 years).
15 (3) Design improvements will essentially be frozen for seven years and, if approved, the license to manu-facture will be for seven-yaar old designs.
i (4) The ti=e delay and additional costs resulting from
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imposition of the rule change will likely result in p3.
H eliminating requests for a license to manufacture and, k
- 0 hence, would eliminate the advantage to be accrued from
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.. S (5) No basis has been presented to indicate that the pre-R sent NRC regulatory procedures and extensive test n;y program that are required are inadequate to protect ui=j public health and safety.
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(6)
In the case of the mass produced offshore plants modifica-?
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tion of the regulations is unnecessary because they primarily employ features that have been utilized in.
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' land-based nuclear power plants and their operational
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aspects and anticipated abnormal occurrences are the
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same as for land-based plants.* Some of the novel
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features of the offshore plants, while new to nuclear
.=J power plant design, such as the breakwater and floating 6:;.(({p platform, do not employ new technology but rather
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technology that has bean developed for other engineering
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endeavors such as the design of harbors and offshore b,.
drilling rigs.-
[;:;....g Ei 'EEE The staff believes that Alternative 1, to continue with the
==d present HRC procedures which require, among other things, testing E?
of the specific power plant under consideration, both prior to and
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after operation, is preferable because it provides the greatest
- t=h7f assurance that that particular power plant will function in a safe
~=1 manner. Adding an extra requirement for prototype testing is not J71 :.g likely to provide any significant increase in this assurance. NRC
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has emphasized functional testing of finf ahed systems in the fully
- +> =-!!i assembled plant in order to provide real assurance of adequate rM design and construction for safety. Many months are devoted to preoperational testing and a slow and careful approach to power, and then many more months are spent in extensive programs of start-up tests to assure that all of the individual components i:.+
function together properly as a system and do their required job.
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In addition to these preoperational and start-up tests NRC requires
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that nuclear reactors be des _1gned to permit the conduct of extensivei B"E testing during the life of the plant to verify continual capability =i of system operation.
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A specific level of surveillance testing for safety-related fI systems is specified'in the operating. license for every reactor.
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NRC inspectors perform selective reviews of surveillance testing
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procedures and results and from time to time observe the conduct
[.:2 of tests to assure adequacy of such testing.
Besides functional testing NRC also requires qualification testing of. individual components to assure adequate performance under all service conditions, especially those highly unlikely ones such as extreme
$1..~ i environmental conditions and post-accident conditions that cannot M......_
be readily simulated in preoperational and start-up tests. In if.7 those cases where testing cannot be performed detailed analyses E=d@g are mada, using extremely conservative. assumptions, to predict the
=EE!H behavior of structures, systems, and cemponents important to
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NUREG-75/100 Safety Evaluation Report related to Offshore Power Systems Floating E
Nuclear Plants (1-8), Docket No. STN 50-437, September 30,. 1976.
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In summary, NRC utilizes various techniques to verify the adequacy.
O of a given design.
These techniques include functional testing during the preoperational and startup phases, qualification testing
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of individual items, and surveillance and testing during the con-
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struction and operational phases.
These testing techniques are
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combined with extremely conservative design analysis.
The advan-tage of this philosophy of design verification is that it provides the greatest assurance that the specific power plant under consid-T..
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eration will function safely. On the other hand, the successful
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version of a nuclear power plant will not guarantee the safe hi operation of a similar, but different, plant.
Prototype testing T~
can recult in the testing of designs that are out-of-date and not representative of what is actually being installed. The NRC
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approach is an on-going approach which results in verification of r" HE" the design of the plant actually being installed at the site.
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Recommendation:
That the Commission:
1.
Approve Alternative 1:
Continue present policy of not requiring operational testing of a pilot nodel or prototype versions of nuclear power plants prior to issuance of a license to manufacture and deny the ACCCE petition.
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2.
Approve publication df a notice of denial of the petition
[i_g for rule making in the form of Enclosure "C".
1..:..J, 3.
Note that:
N a.
The Notice in Enclosure "C" will be published in the Federal Register.
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Following publication of the Notice, a letter (Enclo-
- dF sure "D") will be forwarded to the ACCCE stating that
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the petiti:n has been disapproved.
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The Joint Committee on Atomic Energy and the House Subcommittee on Energy and the Environment will be (p
jj informed.
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A public announcement will not be issued when the
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Notice is filed with the Office of the Federal Register.
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Tha Comissioners
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The Offices of the Executive Legal Director, Inspection and 1..
Enforcement, and Nuclear Reactor Regulation. concur in the recom-mendation of this paper. The Office of Public Affairs has stated that a public announcement is not required.
The. Office of the General Counsel had no legal objection.
The Office of Policy Evaluation coments of January 18, 1977 and the response thereto are attached as Enclosure "E".
The comments have been discussed
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with OPE and the paper has been modified in response to the
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comments and discussion.
OPE is in agree =ent with the resolution.
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....E Sunshine Act:
Recommend an open session if discussion necessary.
OGC and OPE concur.
Anticioated
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N Meg Seneduline: Week.of April 4, 1977.
Robert B. Minogue, DiEector
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Office of Standards Development
Enclosures:
"A" - Letter dated June 19, 1974, from Atlantic
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Couary Citizens Council on Environment "3" - Background Information and Snmary of Public Co-ants of the ACCCE Petition for aule Making "C" - Proposed Faderal Recister Notice "D" - Lc Ger to the Atlantic County Citi= ens Council on Environment frc= the Secretary of the Commission "E" - OPE Co=ents with Response
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Coc=issioners ' co._ ents or consent should be provided directly to the Office of the Secretary by close of business Wednesdav. March 23. lo77 12 DISTRIBUTION:
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Cocrissioners Connission Staff Offices
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