ML19318C830

Forwards Procedure for Documentation of Deviations from Srp. SERs Issued After 770101 for Plants Under OL Review & Issued After 770801 for CP Applications Under Review Are to Document Deviations from SRP

ML19318C830
Person / Time
Issue date:	09/20/1976
From:	Rusche B Office of Nuclear Reactor Regulation
To:	Boyd R, Heineman R, Stello V Office of Nuclear Reactor Regulation
Shared Package
ML19318C826	List: ML19318C824 ML19318C830 ML19318C837
References
FOIA-80-359 NUDOCS 8007020331
Download: ML19318C830 (11)

Text

ATTACHMENT 2 ff;ll UNITE 3 5TATES

.f[

"4 NUCLEAR RE2ULATORY COMMIS$10N

,,j p WASHINGTON. D. C. 20565

]=l jug %.3 e

g

3

=

k

,d September 20, 1976 g~;

O 2

si i==.

MEMORANDUM FOR: Roger S. Boyd, Director, Division of Project Management E@

Robert E. Heinenan, Director, Division of Systems Safety EM Victor Stello, Jr., Director, Division of Operating.

("55 Reactors t-Harold R. Denton, Director, Division of Site Safety Y77

,pg and Environmental Analysis

(

g.......

2E FROM:

Ben C. Rusche, Director, Office of Nuclear Reactor

}iEE Regulation

!==

SUBJECT:

DOCUMENTATION OF DEVIATIONS FROM THE STANDARD REVIEW

• 2.5 PLAN EEE iE E Reference NRR Office Letter No. 9 which established NRR policy with

[55 respect to documentation of departures from the Standard Review Plan.

.a 2

~ ' *..:;

L'~~~.-'

MQ::

I now have approved the implementing procedure for documentation of EE{k these deviations. A copy of this procedure is enclosed.

g:

Safety Evaluation Reports issued after January 1,1971, for plants under review for operating licenses and issued after August 1,1977, for applications under review for construction permits or preliminary

.'..;;.I design approvel are to incorporate documentation of the deviations from the Standard Review Plan.

lBenC.Rusche, Director F;=.=

Office of Nuclear Reactor Regulation

[;;llll

Enclosure:

Procedure

.....g cc w/ enclosure:

NRR Technical Personnel

""T]

==.q

.==.J

=5;

===&

. =. =.

-e N$5.I ENEEh

=:;

o 9

t. :.

== Ei

- 5:1 k:s 8007020 1

~

~

~

o s.:=

6-.

.E*"E

.:a' PECEDURE'MR' DOCUMENTATION

~~:;.y OF DWIATIONS-FICM

• TEE' STANDARD

• REVIDi* PIAN

"~"T ~i

.... J

......R Introduction W

.._.. 9 T"~'

Se staff review of nuclear plant designs described in Safety Analysis Reports is performed within the guidelines established by the Standard Review Plan (NUREG-75/087), issued in September 1975, and as since a-

_.... a mended. Use of the acceptance criteria of the Standard Review Plan as

~.::!

==g a measure of the acceptability of plant design features assures both a

~

q consistent evaluation of proposed plant designs and an acceptable level 1

=

of safety for all plants licensed. We Standard Beview Plan also de-

=;

scribes and documents the acceptability of specific design approaches

-g to satisfy certain of the acceptance criteria. We recognize, however, J

=

that alternate design approaches may satisfy these acceptrnce criteria equally well. Further, we recognize that, with propar justification,

==0 applicants may be able to demonstrate that particular provisions of the

-~]

4

m acceptance criteria need not be met at all.

~~

Currently, significant difficulties arise when the Standard Review Plan l

is used during the operating license review of a plant design, Rese

-- T difficulties stem from the fact that the plant design at its construc-

.. j tion permit stage of licensing was reviewed and approved against differ-

..i ent guidelines due to tne lack of the Standard Review Plan at that

___]

earlier stage of review; some future reviews will enco:nter the same "f

......3 4

W#

difficulties due to the same reason or to changes to t;.e Standard Review

..p=

Plan that have occurred during the intervening period.

In either event,

~~!

• k

,-e

+

_. ~ -, -

M d

U.'.

fgj

==

a=.

-P

%=

l deviations will exist in the pl:nt design relative to the then current M

l Standard Review Plan, and the staff is or will be faced with licensing

==i

.......g decisions regarding the acceptability of the design described in the S

..... y

...T Final Safety Analysis Report.

p-In the past, applicants have eeded considerable efforts justifying',

f.sq s....

..a and the staff has spent considerable time evaluating, particular plant i=:1 k.:*&

design features to assure an acceptable level of safety.

Often these

[=$

' =j efforts have not been properly h=ted to clearly indicate the bases

)

for acceptability of the design. To iczprove the usefulness of our t==

Safety Evaluation Reports as a record cf such decisions and to minimize F~~=

951

[ggg EE the need for future reassesssents of ooerating plants to demonstrate dis 91 t==

adequate levels of safety relative to current criteria, it is desirable js=

~"

y:=.9 that the bases for such licensing decisions be clearly documented in the 4

Essii Safety Evaluation Reports that s:ssarize the staff review of the Final

"" l, Safety Analysis Report. To this end, any deviations from current i'.

1 Standard Review Plan acceptance criteri.a will need to be listed and

.j justified in the Final Safety Analysis Report and in the staff's Safety

.=...l.l Evaluation Report prior to es:pletion of the operating license stage

.:i!$l}

of review.

_.. :q TEd

.. =

A problem of similar type but of much less magnitude may exist with re-i}i.5:

spect to some construction par =it and s*&d design applications and EE1 associated staff reviews. Since all new applications for construction g=..==

permits or for preliminary design appreval of standard designs must ad-

=.

22 dress the information needs identified in Revision 2 to the Standard

=

Format and Content of Safety A. alysis Reports, deviations from the

..h 5:...

==

- 3

.=-

' ' ~"1..

.. _. ~ -.= =

acceptance criteria of the Standard Review Plan are expected to be non-ex-

~~~.7.'.=..

istent or minimized. However, alternate design approaches may be proposed

- 7; by the applicant, and it is possible that deviations may arise during the course of the review. In any event, any deviations or alternate design approaches, whether initially proposed or developed during the course of

-~~

the staff review, will need to be listed and justified in the Preliminary

.=~",

Safety Analysis Report and in the staff's Safety Evaluation Report prior to sma canpletion of this stage of review.

==i7

~~'9 This documnt presents the procedures that should be followed (1) by appli-cants and (2) by staff reviewers ard Licensing Project Managers to assure

$f:

El

~"

that adequate documentation of deviations and alternate approaches in plant designs relative to the standard Review Plan is provided in Safety Analysis

==

Reports and in Safety Evaluation Reports, respectively.

g;.

~~~9 Definition of Deviation

=27 For the purposes of this procedure, a deviation is defined as a lack of con-

=3

==r formance of a plant design feature to one or more provisions of the accept-

==l

=w ance criteria given in the Standard Review Plan. An alternate and acceptable

=

=

design approach to satisfying the Standard Review Plan acceptance criteria

=

is not considered to be a deviation, but the bases for acceptability must n

also de documented in the Safety Analysis Report and in the Safety Evalua-

=j]

==

[.'.I tion Report.

.EU ee

.T

^:'.

Ea II555

,c c

.a

4 h=.....

t,-

L.=..

g.:. =

..===

=.

y=g

=--

4 Procedure

==f

......g

.g

'Ibe procedure for doc men iag de7iati cs from the Standard Review Plan

.. -d a

requires the applicant initially to identify the deviation and provide Gli i

the bases for acceptability.

mis infornation should be included in

.1

.y

....g the safety Analysis Report and reviee$ ty the staff as a part of the

-~~q

...a normal review process. 'cae results of the review should be described

.~:

C: 2 r...

a in the Safety Evaluatico Report to provide clear documentation,of all j

i

...y deviations, including tne bases fer ac=eptability, me same procedure

=

===g should be followed for al:e nate 6esig 1 approaches. We procedure is

...a based on the implicit asst sion that a program will be established whereby plants licensed for operatica will be maintained continuously

!:=.. s..

(.. q up-to-date with regard to changes in licensing requireme.nts (i.'e., at h- :h g

..j

• ~:

r...

the time a new staff pesitien is 6eveloped, a decision regarding its I;.;!....;

b.---

applicability on a generic basis or on. each plant, on a case-by-case

-.4 basis, will also be ca5e and i.:plemented).

4

...j The specific steps in tne procedure fer a new apolication are:

===Ij 1.

We applicant will identify a-d p ovide bases for all deviations

-9 from the acceptance criteria give: in the Standard Review Plan.

~

~]

..q

-~ ~1 me information sicdd be co sined in those Safety Analysis

...i "0

Report sections that descrios ne systerns, components, or struc-

_ q tures in which tne 657iaticris exist. In addition, the applicant C[

should provide in Chzp:ar 1 a emmary listing of the deviations

~~-1 n=n=q and an identificatio cf the secticas in the Safety Analysis

, c..

j Report wherei. -.e dwiations are described and justified.

g-

i

.=

, CC

====;

[..[.$

=:-

.::i

==

= Y=2

.. =

gg S5h

~ Ek GM 2.

During the acceptance review of the Safety Analysis Report, the

=h

.=.5 staff should determine that this information has been provided

.=

and should inform the applicant of any obvious deficiencies, g

aa 3.

Following docketing of the Safety Analysis Report, the staff should perform a review of the deviations and their bases, iden-

..l.

tify other deviations that should be discussed in the Safety Analysis Report, and request additional information as necessary g]

g_

at the first rotad request for additional information (0-1) stage 5@

""E:

of review.

4.

At the second round request for additional information (0-2) h n -.. ::.

.._4 stage of review, the staff should inform the applicant of its positions on'the deviations and their bases.

f,~h 9

1 5.

Folleving review of the applicant's response, draft Safety

--t Evaluation Report ircuts should be prepared that describe each N[

=1 devittion and the results of the staff review of the bases for

!=-3

.==

y::::.::

their acceptability; tile Safety Evaluation Report inputs should ff IEE also include a general statement denoting acceptability of the EEi EM applicant's design relative to the grouping of acceptance criter-

!5==,

.

ia given in the Standard Review Plan sections.

As stated previous-55E.4 ly, the Safety Evaltntion Report inputs shou ~d also include dis-cussions of any alternate approaches to staff positions that have h

.=

~9 been adopted by the applicant and the bases for acceptability.

E==1 E..E.

e

~ E.E:

55 EE SE 3-E I~~

.a.

L:

o.--. v v--

=::.

. =.... = = y=:7

'="

dt:+.:"

M 6.

The Licensing Project Manager should include a section in the

'*[

Safety Evaluation Report that notes that the review has been

,]

made using the Standard Review Plan criteria as of the appif-

... 4 cation docket date, tabulates all deviations from those criteria, and identifies the location in the Safety Evaluation Report

['E j t=::=: A where the discussion may be found.

g;g f5=E The procedural steps given above relate to future applications.

...:.'.;1 E=a!

Modifications to these procedural steps will be made in order to

~ H implement the procedure for applications currently in the licensing

~

process.

Specific steps will be taken to assure that the implementation ---

p

.r.._

===:

will be consistent with the Comission's standardization and replication

== =

===-

policies.

...]

s

'.:Ek

!.i

===rt

..q E'.5.

e =4 sE:d

=EEi

.1

... :::{

..==q s==:1

.:1

......q

.e rrr; -$

==

e.

e

E c.i

...a &.se. q

Z~... _..,

= =9 IMPIIMENTATION

==.m 555 1.

Plants Currently Under Review for Operating Licenses

.f

.===.4 Three plants have Safety Evaluation Report issuance dates

==j1 currently scheduled beyond January 1,1977. Diese are Shoreham

~1

-3 (March 1977), Zinrner 1 (July 1977), and Hatch 2 (December 1977).

We will request the applicants for Shoreham and Zinmer to submit

-- 2!

q 1

their listing of deviations with justification in our second 5M round requests for additional information scheduled for Feotem-ber 1976. Reviewers shocld begin independent reviews of these Ni plants at this time to permit completion of effort in time for

=._=g hf=c.

Safety Evaluation Report issuance. A letter will be sent to the

j y

applicant for Hatch to request subnittal of the needed informa-y tion.

...~.3

.:~ ::5 E=5 One plant, Watts Bar 1/2, ha.s recently been tendered for docket-ing.

The request for the list of deviations with justification will be included in our initial request for additional informa-

$.[.$

==s tion.

- --g

==a One plant, Fermi 2, will have its Safety Evaluation Report issued

[

. =. =

=.=

late this year. Bowever, it will be incomplete since operation isii;L

!.E2 is not contemplated until 1980. A major supplement will be issu-Eh E=$

ed a year or so before operation. A letter to the applicant will

===g

_.a inform him that the matter of deviations will be inclu6ed at that hh time. Other plants currently under review will not be considered

=E-

=...=..

' l"'

even though schedule changes may slip the safety Evaluation

== :.

$d-~Nk-.

=g r=

, fr:A

=

{22 !--_5 5 q:L.=g.

2 {E@

.y=

Reports beyond January 1, 1977. 2 ese plant include Davis Besse-1, Arkansas -2, and M:Geire 1/2.

... =

2.

Plants with-Constrtrticn-Permits and Nhich-Will Acoly' for

=

Ooerating Licenses The LaSalle 1/2 and WP. CSS 2 applications are scheduled for

{==

b" FSAR sutraittal in September and October 1976, respectively. We can implement the procedure for these plants at the acceptance

}===

review stage.

For the other 27 p:. ants beyond these two that currently have a

~..

construction permit, a letter will request inclusion of the de-viation information in the Final Safety Analysis Report.

E 3.

Plants-Currently Under Review for Constraction-Permits

= ui

'==

14tters will be seat to applicants for plants which have issuance

)==

dates for Safety E7aluation Reports, or major supplements to upa-

=

date delayed plants, currently seneduled beyond August 1,1977, to q:g inform them that their Safety Analysis Reports or supplements EE

~~

.. ~

and our Safety Evaluation Reports will need to contain the list-

==

==

ing of deviations and justification. No non-delayed plant l=l.~.~

Z T.

is in this status. 3e delayed plants inclu6a Douglas Point 1/2, E

l Greenwood 2/3, Allens Creek 1/2, Montague 1/2, and Barton 1/2.

New England 1/2 ha.s ree.n tendered for docketing. Tne requirement

d on the list of deviations and justification will be included in

=Er

$k=!

.=

=..

[._I[

~

I our initial reques: for additional information.

=

y

==

.. ~

gg:

=.:--

+tfi 3-h..

}. y.,

E?:?

t-liiE Other plants (25 in number,15 of which are in the post-4CRS

r J

. :. ::7 stage) will not be considered at this time even though schedule

-..y changes may slip the Safety Evaluation Reports or supplements

(

~

beyond May 1,1977.

~

4.

Future Construction Permit Applications

==jp

. :==

The requirement for the list of deviations and justification 5N will be included in our acceptance review letter for those g

applications submitted within six months of issuance of the 5hb

=

change to the Standard Format discussed in item 6 below. The M

information will be expected to be in a Safety Analysis Report

.ggiss:

" " = =

submitted after such a period of time.

5.

Construction Permit Applications Referencing Approved Standard Designs or Replicating Base Plants

- --l

.. :3 The requirement for providing the list of deviations and justifi-Sgg cation in the Preliminary Safety Analysis Report will be imple-i==i tssi mented only for those portions of the Preliminary Safety Analysis

[:1..~

EEEh Report that require a de novo review in accordance with the 15ss]

DEE.iij Standardization Policy or the Replication Policy, as applicable.

The requirement will be applied fully to the reviews of reference h=g

. = = =

designs for which the scheduled issuance date of the Safety 5

= = - -

Evaluation Report is beyond August 1,1977.

5

.===

==?d

--==

• "bb

.V j

..f e.

=

x...

=

4_

-..;=.

l.=. :

==

?.~~..

6.

General

---.1

==g

. ~ra A change to the Standard Fomat will be processed to require

=.

the inclusion of the listing of deviations and justification

~~~

r..

in Safety Analysis Reports.

..j

..k

=..m r.==

m=?

li5i.$

\\4fk nai

=.*..

L*::::.

h::=

(

~~*"

. =..q 4

=...;..=.......d

~,

.aise V::=5

.q

=...g

...q

.9 m

=.)

==

sad

l i

" j

.:J

.=:=

-...i sad

.....g

....q

lj_.

....q

==.=E

{.

..,.

E..=.== :::

=.

.==

e 4..--

e e-