ML19308B930
| ML19308B930 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/07/1977 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | |
| Shared Package | |
| ML19308B919 | List: |
| References | |
| RULE-RM-50-12, TASK-TF, TASK-TMR SECY-77-126, NUDOCS 8001170638 | |
| Download: ML19308B930 (15) | |
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- 23 NUCLEAR REGULATORY COMMISSION
[ Docket No. PRM-50-12]
ATLANTIC COUNTY CITIZENS COUNCIL ON ENVIRONMENT Notice of Denial of Petition for Rule Making By letter dated June 19, 1974', the Atlantic County Citizens Council on kngc ia:
Environment (ACCCE), 2 Old Turnpike,'Pleasantville, New Jersey, petitioned i=
the U.S. Atomic Energy Commission
- to amend its regulations in 10 CFR
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Part 50 to require full scale operational system testing of pilot model or prototype versions of nuclear power plants, in the configuration they are expected to be employed in situ, prior to licensing for production manufac-ture wherein it is evident that such plants are to be assembly line manufac-tured, cass produced, or otherwise turned out in substantial quantity for distribution on a wide scale.
The petitioner recommended that the license
=..+ x to manufacture, in such cases, be limited to a pilot =odel or prototype until systems operations testing has been successfully completed.
The petitioner suggested also that the amendment be made to Section XI, test 3
control, of Appendix B of 10 CFR Part 50.
1 The basis fo'r this request is the ACCCE conviction that the different circu= stances of the OPS type application,** in terms of likely prolifera-tion and widespread implementation of future assembly line or mass production
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The Atomic Energy Comnission was abolished by the Energy Reorganization Act il of 1974, which also created the Nuclear Regulatory Commission and gave it the licensing and related regulatory functions of the AEC.
7; Application filed by Offshore Power Systems (OPS) (Docket No. STN 50-437) for a license to manufacture eight floating nuclear power plants under Appendix M of 10 CFR Part 50.
This application is still undergoing NRC review.
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methods for ccustruction of the nuclear power plants, warrants more extensive T ;_.
or f,21 scale operational testing of a pilot model or prototype version
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than has been accorded individual or single sited land based plants. While lisyss-
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the petitioner is primarily concerned with the floating nuclear plants, w*:.m.T.,
the discussion in this notice may be considered to apply to all plants i:6Z licensed under Appendix M of 10 CFR Part 50.
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A notice of filing of petition for rule making was published in the
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.M]i FEDERAL REGIS~~ER on August 9, 1974 (39 FR 28662).
The comment period J.
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expired on October 3,1974 and was extended to November 7,1974 at the
]:y request of the ACCCE as noted in the FEDERAL REGISTER on October 3,1974 e/N;d
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(39 FF. 35700).
Sixty-five interested parties have submitted cccments
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the petition.
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3e NRC has evaluated the need for full scale operational testing of p11ct models or prototype versions of nuclear power plants in the context
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of the overal' nuclear regulatory program, with particular e=phasis placed
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on :he testing and analysis aspects of the program.
Before describing the
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Cor=1ssion's progras it would be worthwhile to briefly discuss the overall jj{
philosophy of nuclear power plant design verification. The primary purpose of design verification is to provide assurance that a nuclear power plant
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includin;; accident modes, and in all environments, including extremes.
' i?sj EU 3 ere are different ways to accomplish design verification depending
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upon the infer:ation available and the particular application being considered.
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=n At the early stages of a developing technology, such as nuclear energy O
power develop =ent during the late fif ties and early sixties, experimental D
prototypes are used to provide needed scientific and engineering informa-
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tion and to essentially " prove the principle" of the design. As the
.x technology matures, and a broad base of experience and large body of
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engineering data is accumulated, experimental prototypes are no longer 7 47 f:L necessary to " prove the principle" and it becomes more advantageous to b
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verify the design on the actual, as-built hardware.
This is the present status of the nuclear power progran.
The proposed offshore floating nuclear plants, even with some novel features, do not represent basic new technology but are based on many years of experience with many power reactors and nunerous harbors, ocean going tankers and ocean oil drilling rigs.
Thus, rather than reliance on an experimental prototype for design verification, the NRC approach relies ou a multi-faceted program culminatit.g in a detailed testing and qualification phase on the actual, as-built plant.
It is felt that this approach provides the greatest assurance that the public will be protected. The salient features of the NRC regulatory
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program that pertain to eta subject of the petition are described in the following paragraphs.
f A paramount purpose of the NRC's regulatory program is the protection of both the public health and safety and the environment.
This purpose is fji achieved with a licensing and inspection program that governs a nuclear power plant throughout its lifetime, from initial. siting and design through i+
to deconmissioning and ulti= ate disposal.
This includes inspection during
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the manufacturing process to veri 5y that the conditions of the license T
are being satisfied.
The basic approach of the regulatory program relative
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V to insuring reactor safety r,
- e described as one of " defense in. depth".
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It essentially in cl.ves three Ic als of safety which may be described as
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follows:
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First Level of Safety - Design and build the plant so that it
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will operate as intended with a high degree of reliability. The ff.!:#
h.5 object is to prevent accidents through intrinsic features of the plant design including quality, redundancy, testability and inspectability of components.
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Second Level of Safety - Despite the care taken under the first level of safety relative to design, construction and operation, it is assumed that safety problems still occur.
Protective L..
isvices and systems are provided to assure that such incidents
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Extensive testing programs
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Third Level of Safety - Provide additional safety systems as 1:.
appropriate, based on evaluation of effects of hypothetical accidents, where some protective systems are assumed to fail
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This supplements the first two levels of safety through features
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which add rargin to the plant design by providing protection to 4-Enclosure "C" O
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the public even in the event of the occurrence of extremely unlikely and unforeseen circumstances.
Several esvere hypo-
.. a thetical accident sequences, called Design Basis Accidents, are selected for this evaluation.
The NRC's regulatory program for the protection of the public health
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and safety involves numerous specific requirements related to the testing of nuclear power plants.
For example, in the Commission's regulation,
" Licensing of Production and Utilization Facilities," 10 CFR Part 50, paragraph (b)(6)(iii) of 5 50.34, " Contents of applications; technical
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infor=ation," requires that the final safety analysis report, which is to hb:*
be included with each application for a license to operate a facility, include plans for preoperational testing and initial operations.
In Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," of 10 CFR Part 50, Criterion II, " Quality Assurance Program," requires that an applicant establish a quality assurance program that, among other things, takes into account "the need for verification of quality by inspection and test."
Appendix B, Criterion XI, " Test Control,"
5"l of the same appendix, requires that a test program be established which "shall include, as appropriate, proof tests prior to installation, preopera-1.
tional tests, and operational tests during nuclear power plant or fuel
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t reprocessing plant operation." Test procedures are to include provisions f.3 '
for assuring "that the test is performed under suitable environmental conditions."
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Appendix A, " General Design Criteria for Nuclear Power Plants,"
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requires that various structures, systems, and components important to b;s (O
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safety be designed such as to permit appropriate periodic inspection and testing of their operability and functional performance.
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Under the Commission's regulations relative to preoperational and Initial startup testing programs for water-cooled nuclear power plants, an
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applicant is responsible for the development of suitable preoperational and faitial startup test programs for its facility, the preparation of adequate procedures for carrying out the programs, the proper corduct of the test programs, and assuring the validity of the test results.
The test programs typically include the following features:
(a)
Simulation of equipment failures and control system malfunctions that could reasonably be expected to occur during the plant life time.
(b) Testing for interactions such as the perfor=ance of interlock circuits in the reactor protection systems.
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(c) Tests conducted prior to fuel loading to demonstrate the capa-bility of structures, systems, and components to meet safety-
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related perfor=ance requirements.
Included would be tests of the reactor coolant system, the reactivity control systems, the F
i;r protection system, the emergency core cooling systems, the
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radiation protection system and the radioactive waste system.
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Initial startup testing consisting of precritical tests, low-
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power tests (including critical tests), and power-ascension tests
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performed after fuel loading and before commercial operation.
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These tests confirm the design bases and demonstrate, where
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practical, that the plant is capable of withstanding the antici-
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pated transients and postulated accidents.
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The test programs are monitored ~ by the' NRC Office of Inspection and Enforce-ment by selective review of test procedures, examination of test results, ju"~h=
!.il nu25 and witnessing of tests.
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A number of regulatory guides' have been issued by the NRC staff that
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These include:
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Regulatory Guide 1.15, " Testing of Reinforcing Ba es for Category
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d.n' I Concrete Structures" Qe (b)
Regulatory Guide 1.22, " Periodic Testing of Protection System Actuation Functions"
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Rsgulatory Guide 1.30, " Quality Assurance Requirements for the
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Installation, Inspection, and Testing of Instrunentation and l
2E1 Electric Equipment"
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Regulatory Guide 1.41, "Preoperational Testing of Redundant On-
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Regulatory Guide 1.52, " Design, Testing, and Maintenance Criteria t
for Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants" E
m#Esss-(f) Regulatory Guide 1.68, "Preoperational and Initial Startup Test
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Programs for Water-Cooled Power Reactors" T:5":?.".1
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Regulatory Guide 1.68.1, "Preoperational and Initial Startup Testing of Feedwater and Condensate Systems.for Boiling Water arr-:
Reactor Power Plants" (h)
Regulatory Guide 1.79, "Preoperational Testing of Emergency Core 3
=h "M;mt Cooling Systems for Pressurized Water Reactors" "ENE)
(1) Regulatory Guide 1.80, "Preoperational Testing of Instrumenc Air
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Systems"
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(j) Regulatory Guide 1.108, " Periodic Testing of Diesel Generators
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Used as Onsite Electric Power Systems at Nuclear Power Plants"
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Regulatory Guide 1.118, " Periodic Testing of Electric Power and Protection Systecs" These regulatory guides are not regulations but reflect NRC staff judg.ents as to acceptable methods of satisfying the regulations.
As seen above, the NRC has emphasized functional testing of finished
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systems in the fully assembled plant in order to provide real assurance of
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adequate design and construction for safety.
Many months are devoted to EE preoperational testing and a slow and careful approach to power, and then many more months are epent in extensive programs of start-up tests to
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assure that all of the individual components function together properly as a system and do their required job.
In addition to these preoperational and start-up tests the NRC requires that nuclear reactors be designed to permit the conduct of extensive testing during the life of the plant to verify continual capability of system operation.
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i:=.r A specific level of surveillance testing for safety-related systems is A specified in the operating licensa for every reactor.
NRC inspectors -
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=p' perform selective reviews of surveillance testing procedures and results and from time to time observe the conduct of tests to assure adequacy of N
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such testing.
Besides functional testing the NRC also requires qualifica-c,i.Q.5
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tion testing of individual components to assure adequate performance under E =Fr all service conditions, especially those highly unlikely ones such as
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extreme environmental conditions and post-accident conditions that cannot be readily simulated in preoperational and start-up tests.
In those cases where testing cannot be performed detailed analyses are required, using
-mi extremely conservative assumptions, to predict the behavior of structures, 7-systems, and conponents important to safety.
For example, in the case of an earthquake, qualification testing is combined with a very conservative analysis of earthquake motion te predict the structural behavior of the nuclear plant during the course of the earthquake.
The preceding sections have discussed the general aspects of the EE:
overall NRC regulatory program.
In view of the concerns of the petitioner regarding the offshore floating nuclear plants, considerations relative to these plants will now be discussed.
Floating nuclear plants are essentially the same as land-based plants
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stean supply system on a floating foundation.
The nuclear steam supply
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system is similar to those that have been previously licensed for land-
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W2 based systens especially the McGuire Nuclear Station Units 1 and 2 (Docket 11 Enclosure "C" O
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s-Nos. 50-369 and 50-370), and the Catawba Nuclear Station Units 1 and 2 (Docket Nos. 50-413 and 50-414). The safety evaluatium of these other m
facilities have previously been published and are available for public
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{;hha described at the end of this Notice.
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As mentioned above, major aspects of the floating nuclear plants are ff="
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The parts B.g
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E-1 preoperational and startup testing, as discussed previously, will continue
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The prit:ary novel features of a floating nuclear plant to be located offshore are:
a.
A breakvater, if required, which protects the plant against storm generated waves and ships.
b.
A floating platforn to support the nuclear power plant.
c.
A mooring svstas to restrict platform notion to acceptable
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levels.
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An environmental contrel'sysren to control airborne salt, mist and fog and thus prevent the degradation of important safety
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systems.
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An electric nower transmission system that utilizes a flexible ih;"
connection at the plant und a high voltage cable embedded in the J.1l 5Fi:
seabed.
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Vibratory mocion which is different than that for land-based N
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plants both as a result of overall platform rocking as well as f-machinery induced vibrations such as from the' turbine generator.
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These novel features are required to be design qualified.
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to the usual extensive testing performed on all nuclear power plants, b
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==s f'.oating plants function properly. This is done by regt iring a combination of extensive detailed analyses, qu'lification testing, model testing,
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special system tests and verification tests to provide final assurance as to the functional capability of the features.
The specific measures required will vary on a case-by-case basis depending, among other things, upon the features being considered and the different siting and environ-nental conditions.
For examp1.e, extensive analysis is being required in the design of the breakwater.
Impact calculations are required to be per-formed, using typical ship and breakwater parameters, to determine the ability of the breakwater to withstand a ship collision.
In addition,
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scale model tests are being required in order to investigate ship colli-W sions as well as to determine the effects on the breakwater of extreme storm conditions.
Wind tunnel tests have been required to study the effect 3-that different breakwater designs have on the wind loads produced on the nuclear plant.
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The floating platform is also receiving much attention to assure its
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proper functioning.
It has been designed utilizing experience gained in
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the design of ocean oil drilling rigs, oceangoing barges and supertankers.
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J Detailed three-dimensional analyses are being required to assure adequate
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during actual construction to verify that the design is adequate and non-destructive testing and visual inspections must be carried out af ter con-3k.[k 55 9 atruction. Finally, special protective coatings will be required to be
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used to prevent corrosion in the splash zone and non-wetted areas while a F:
cathodic protection system is to be used to prevent underwater corrosion.
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Scale model tests are being required of the total floating system co=bining the platform, mooring system, mooring basin geometry and break-E=:
water design to verify that the various parts interact properly. Model tests are also being required for different mooring system arrangements,
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along with extensive analysis, in order to choose a final moor 4.ng system design.
The vibratory socion likewise is being treated as a special case for the floating nuclear plants.
The dynamic testing and analysis techniques that will be used are receiving detailed review and approval by NRC.
Extensive analyses must be carried out on the total turbine generator /
turbine foundation / platform system to verify that the turbine is effec-c' tively decoupled from the platform. A precperational dynamic effects test program will be required to measure the machinery induced vibrations simi-lar to that developed during actual operations.
Based on the test program, p
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design modifications will be made as needed, with corrective restraints or other damping measures added, to assure that motions are within acceptable levels. Verification tests are to be performed to assure that the
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Spscial turbian rotor daficction and
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bearing load tests are also planned to provide further assurance that the turbine vill function properly.
It should be emphasized that these tests will be performed on the actual, as-built floating plant at the manufacturing facility.
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Sum =arizing, the !ritC utilizes various techniques to verify the adequacy 7
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of a given design.
These techniques include functional testing during the f:
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preoperational and startup phases, qualification testing of individual items,
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and surveillance and testing during the construction and operational phases.
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These testing techniques are combined with extremely conservative design
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analysis.
The advantage of this philosophy of design verification is that it provides the greatest assurance that the specific -power plant under consideration will function safely.
On the other hand, the successful construction and operational testing of a pilot model or prototype version
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of a nuclear power plant will not guarantee the safe operation of a similar, but different, plant.
Prototype testing can result in the testing of H
designs that are out-of-date and not representative of what is actually being installed. The NRC approach is an on-going approach which results in verification of the design of the plant actually being installed at the site.
The land-based plancs are the basic prototype for the floating
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nuclear plants and all the novel features of the floating plants will receive detailed case-by-case consideration, to assure safe and reliable operation.
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The Co= mission has considered the petition for rule making as sub-ritted by the ACCCE, as well as the comments that were received during the
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public co==ent pericd. The CoCmission agrees with the petitioner that the
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floating nuclear plants require extensive testing and. that duign qualifi-F
== xx' cation of these plants is needed.
Eowever, the Co=nission does not agree vi:h the approach that ful.1 scale operational system testing of pilot
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figuration expected in situ, is the best way-to meet this need.
Rather, it
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is the opinion of the Co==ission that the previously described approach of de: ailed design qualification of each of the novel features on a case-by-
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case basis, along with the usual NRC procedures that are followed on all nuclear power plants, is core' effective and will provide a greater degree
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ef assurance that the health and safety of the public will be protected.
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J.dding an extra requirecent for prototype testing is not likely to provide any significant increase in this assurance. The petitioners have not shown
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that the requested rule changa would enhance the public health and safety er lessen the impact on the environ =ent.
The requested rule change would i=pede the licensing process and prove costly to the industry, both in time
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and noney, without any cor esponding benefit or improvecent in the regula-Cory process.
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Hence the Ccmission has decided to deny the petition for rule making.
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. 3...:.1 A copy of the petition for rule making and copies of the letters of
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co=ent concerning the petition are available for public inspection at the y-di.
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Cccission's Public Document Room at 1717 E Street, NW., Washington, D.C.
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l Dated at this day of 1977.
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For the Nuclear Regulatory Commission.
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Samuel J. Chilk
- =f Secretary of the Commission lis;,'
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