ML19318C837
| ML19318C837 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1977 |
| From: | Rusche B Office of Nuclear Reactor Regulation |
| To: | Boyd R, Heineman R, Stello V Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19318C826 | List: |
| References | |
| FOIA-80-359 NUDOCS 8007020336 | |
| Download: ML19318C837 (15) | |
Text
{{#Wiki_filter:- ATTACHMENT 3 1p. k d UNITED STATES M1 NUCLEAR REGULATORY COMMISSION Z." ^Jj .. 3,e 1 1 j WASHINGTCN. D. C. 20555 .[. / 3p,y s. C ?.5 0 p
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. 1. ...d j MEMORANDUM FOR: 'R. Boyd, Director, Division of Project Management
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R. Heineman, Director, Division.of Systems Safety i V. Stello, Director, Division of Operating Reactors ~~~ H. Denton, Director, Division of Site Safety and 1 Environmental Analysis -i ..k FROM: Ben C. Rusche, Director, Office of Nuclear Reactor EEd Regulation m$ Er=1
SUBJECT:
REVISED PROCEDURE FOR DOCUMENTATION OF DEVIATIONS
- " "i FROM THE STANDARD REVIEW PLAN E==4 i35
- nt-s NRR Office Letter No. 2, issued on August 12, 1975, directed the staff
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to use the Standard Review Plan to assure consistent evaluation of E"d .....:~2 all applications. It also directed that, except for clarification ~~ and correction of errors, the Standard Review Plan would remain fixed T.~.~ until any proposed change of substance was considered by the Division -~ Directors, reviewed by the Regulatory Requirements Review Committee, and then. authorized by the Director, NRR. .a NRR Office-Lettar No. 9, issued on June 18, 1976, addressed the special -- 4 problem associated with implementation of Office Letter No. 2 in H operating license reviews when the construction permit reviews were not conducted on the basis of the Standard Review Plan guidelines. It noted the necessity to document decisions made on bases other than those defined in the Standard Review Plan and, of equal importance, 2-4 the reasons for the acceptability of such bases. It then directed x:.:d the staff to develop, for my ap' proval, procedures for documenting -... d the bases for deviations from the Standard Review Plan in each oper-
==q ating license Safety Evaluation, and to implement those procedures for all operating license Safety Evaluation Reports issued after January 1,1977. My memorandum of September 20, 1976, approved an implementing procedure recommended to me by the NRR Division Directors. This procedure addressed both operating license and construction per-
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mit applications. ~] [ The experience gained in attempting to use the implementing procedure
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~ m... for operating license reviews nearing completion has shown that, .....j + = =i contrary to our expectation at the time the procedure was developed,
===-1 the staff is unable at this time to conform to the requirements of = the implementing procedure without incurring a substar.tial delay in =:=:+
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N :.==] ' Multiple Addressees JU.s f: j.2=. k""N s......; h completing the reviews for. these applications. While there is no
==@j concern as to the safety level established by the staff review, the ....;;j fact remains that a significant effort would be required at this g:;;) time for the staff to identify, for vi ongoing operating license M review, all devi.ations from the acceptance criteria set forth in
===$ the Standard Review Plan and to document the bases for the accepta-
===5 bility of these deviations. The Division Directors have now recom-E==5 mended that I withdraw the directive set forth in my memorandum of
==.; September 20, 1976, and in its stead issue a superseding dire'c~tivs !"!!!s establishing an alternate program that would:- ?""".] EEN (1) Require the staff to assess the Standard Revie.w Plan, detemine [.liii any changes needed to assure that all
- requirements therein are
===d realistic and practical of achievement, and initiate the actions
==:j needed to implement those changes ir accordance with the policy
==i.1 established in NRR Office Letter No. 2.
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(2) Require the staff to implement the policy es'tablished in NRR =i " Office Letter No. 9 for all construction pemit applications . = = docketed after September 1,1976.
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(3) Require the staff to implement the policy established in NRR hj~i.i-Office Letter No. 9 for all operating license applications ~ r~ docketed after January 1,1977. F= The Division Director's have indicated that approval of the proposed [....f alternate program would pemit the staff to conduct its review of operating license applications,'almost from the start *of such reviews, ~~J.: ~ with the knowledge that confomance to Office Letter No. 9 would be J a requisite for licensing. Such timely knowledge should limit the impact of this requirement on the schedule for completion of the. staff review. I have also been infomed that if the alternate program is .==! approved, then four operating license applications that would have otherwise been required to conform to Office Letter No. 9 will not
- s=d be required to so conform.
- 21 5$ I have decided to approve the recortmended alternate program. This Egij approval is based on (1) the conviction that the siigular issue is ~ ~ = = one of documentation and not safety, (2) the knowledge that the a! ternate program will permit a limited number of operating license .?.?. applications (four) to be added to the number reviewed without the ,~21 need to completely confom to the procedure, and (3) the staff itself !==s r:::2 d e. _.m jj=_.*.': - 5 5:. ?::
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is not prepared to implement the procedure in a timely tranner for the four applicatie - involved. Accordingly, my memorandum of September 20, 1976, is withdrawn and is superseded in its entirety by this memorandum. In essence, tha procedure for Jocumentation (Enclosure 1) remains unchanged for construction pennit reviews but
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modified so that only limited participation will be required of licensees involved in operating license reviews, and the implemen- . ~.. tation program (Enclosure 2) has been nodified so that the appro-5 priate Safety Evaluation Reports, including those associated with operating license, construction pemit, and design approval appli-cations, will document deviations from the Standard Review Plan and the bases for the acceptance of such deviation. vl c( ~,s ~' Ben C. Rusche, Director Office of Nuclear Reactor Regulation =
Enclosures:
2 1. Procedure for Documentation of Deviations from the i' Standard Review Plan 2. Implementation Program
== cc w/ enclosures: NRR Technical Personnel
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Tl = ::: =[u._ ESCWSUE 1 . =.3 PIOCEDORE FOR DDCUMDTTATION
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- nu OF DEVIATICNS' FP34 TifE STANDARD REVIER PLAN
.... j ~.. :.: ..a ~:1 Introduction. 'J.. ......g The staff review of nuclear plant designs oescribed in Safety Analysis . 'j ~ i Reports is performed within the guidelines estaolisned by the Standard = Review Plan (NUREG-75/087), issueo in Septercer 1975, and as since ~ 1 amenced. Use of the acceptance criteria of the Standard Review Plan as a measure of the acceptability of plant design features assures both a ...i .. 3 .nn:q consistent evaluatioh'of proposed plant designs and an acceptable level
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of safety for all plants licensec. Tne Standard Review Plan also de-
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..y scribes and documents the acceptaoility of specific design approacnes -i to satisfy certain of the' acceptance criteria. We recognize, however, .== ".~.::... ~ =q 52 that alternate design approaches may satisfy these acceptance criteria 3333gjj
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Further, we recognize that, with proper justification, .5 applicants may oe able to demonstrate that particular provisions of the acceptance criteria need not be met at all. .y ...j ..A Currently, significant difficulties arise when the Standard Review Plan is useo during the operating license review of a plant design. These difficulties stem from the fact that the plant design at its construc-I.I=z[ tion permit stage of licensing was reviewed and approved against differ-a ent guidelines due to the lack of the Standard Review Plan at that ...]
- l earlier stage of review; some future reviews will encounter the same
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cifficulties oue to tne same reason or to changes to the Standard Review Plan that have occurred during the intervening period. In either event, 3" =- d n: E! i 2ib -
, ~.. ... f.1=i Ed T.: [gy oeviations will exist in the plant design relative to the then current ~ hi.:.:) Cf# .j.~5 Standard Review Plan, and the staff is or will be faced with licensing ""i decisions regarding the acceptaoility of the design describea in the 53
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J Final Safety Analysis Report. In the past, applicants have expenaed considerable efforts justifying, and the staff has spent consideraole time evaluating, particular. plant 3l.[: design features to assure an acceptable level of safety. Often these Ph [=55 = efforts have not been properly documented to clearly. indicate the base.s q = i!.1 for acceptacility of the design. To improve the usefulness of our 3.=1 3 Z'.'.*.*."J Safety Evaluation Reports as a record of such decisions and to minimize lE? the need for future reassessments of operating plants to demonstrate .g acequate levels of safety relative to current criteria, it.is oesirable ~~ r--- fdh !!Mi
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that the bases for such licensing decisions.be clearly documented in the Safety Evaluation Reports that summarize the staff review of the Final ._y
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E 5 Safety Analysis Report. To this end, any deviations from current 9 Stancard Review Plan acceptance criteria will need to De listed and [.] [... justified in the staff's Safety Evaluation Report prior to compietion of e the operating license stage of review. Further, such deviations will .== Ei== also need to ce listed and justified in the licensee's Final Safety ir._ hi:~s Analysis Report for any facility reviewed to the requirements of the' fjj-Stancard Review Plan at the construction permit stage of review.
===4 Eis! A proolem of similar type out of much less magnitude ray exist with re,- , 7.j
===4 g.g spect to some construction permit and standard design applications and
=s associated staff reviews. Since all new applications for construction (55 r
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== permits or for preliminary design approval of standard cesigns must ac-dress the information needs identified in Revision 2 to the Stanaard < = =. .. 3 Format anC Content of Safety Analysis Reports,' deviations from the acceptance criteria of the Standard Reiriew Plan are expected to be non-existent or minimized. However, alternate design approaches may be proposed '"1 E E?i-by the applicant, and it is possible that deviations may arise curing tne
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course of the review. In'any event, any dev!ations or alternate design "===E1 approaches, whether initially proposed or developed during the course of "j{j tne 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
- =:4 cor:pletion of this stage of review.
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- ==4 EE" This oocument presents tne procedures that should be followed (1) by appli-cants and (2) Dy staff reviewers ana Licensing Project Managers to assure
=:2:=: that adequate documentation of deviations and alternate approaches in plant designs relative to the Standard Review Plan is provided in Safety Analysis ..:A Reports and in Safety Evaluation Reports, respectively. -......"] EQ b Definition of Deviation
==q For the purposes of this procedure, a deviation is defined as a lack of con- [. ......j formance of a plant design feature to one or more ' provisions of the accept- .1 '::l ance criteria given in the Standard Review Plan. An alternate and acceptable 2 design approach to satisfying the Standard Review Plan acceptance criteria ..G is not considered to be a deviation, but the bases for acceptaoility must also ce documented in the Safety Analysis Report and, as appropriate, in the .::p
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a:.=unq S [:) t s;. Procedure For Construction Permit Apolications "~~ [. "I [ ** i".i . f..." Tne procedure for cocumenting deviations from the Standaro Review Plan
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..J for construction permit applications recaires the applicant initially to identify the deviation and provioe the bases for acceptability. This-information should be. included in the Safety Analysis Repcrt and reviewed !g:- by the staff as a part of tne normal review process. The results of the
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review snould.be described in the Safety Evaluation Report to provide clear ~ '::j 6:==j documentation of all deviations, including the bases for acceptability. "j The same procedure should be followed for alternate design approaches. The proceaure is cased on the implicit assu::ption that a program will be established whereby plants licensed for operation will be maintained continuously up-to-date with regard to enanges in licensing requirements ,[ (i.e., at the time a new staff position is developed, a decision regarding - g its applicability on a generic basis or on each plant, on a case-by-case oasis, will also be made and implemented). The specific steps in the proceoure for a construction permit application
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are: 1. The applicant will identify and provide bases for all deviations from the acceptance criteria given in the Standard Review Plan. ..c.g ) Tne information should be contained in those Safety Analysis 4 ~" ':.
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Report sections that describ'e the systems, components, or struc- .9 tures in which the deviations exist. In addition, the applicant - ::d snould provide in Cnapter 1 a sm My listing of the deviations ,,_,fil and an identification of the sections in the Safety Analysis E" Report wherein the deviations are described and justified. 55)) E:=E l l
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== 2. During the acceptance review of the' Safety Analysis Report, the
== staff should determine that this information has oeen provided = $550 and should inform the applicant of any obvious deficiencies. -~ .= 3. Following docksting of the Safety Analysis Report, the staff should perform a review of the deviations anc their bases, iden-EE EE tify other deviations that should be discussed in the Safety -{ Analysis Report, and request accitional information as necessary at the first round request for additional information (Q-1) stage 9:= of review.
== At the second round request for additional information (0-2) 4. stage of review, the staff should inform the applicant of.its .3.@ Gw" positions on the deviations and their bases. 5. Following review of the applicant's response, draft Safety !55l =.y Evaluation Report inputs should be prepared that describe each
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deviation and the results of the staff review of the cases for C::.~." tneir acceptability, the Safety Evaluation Report inputs should Ef":T M3 also include a general statement cenoting' acceptability of the
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applicant's cesign relative to the grouping of acceptance criteria
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given in the Standard Review Plan sections. The Safety Evaluation .=s
==4 Report inputs should also inciace discussions of any alternate
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--S approaches to staff positions that have been adopted oy the applicant and the bases for acceptability.
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y==y 6. The Licensing Pcoject Manager snould incluoe a section in the !!#7). 5I i;.4 [s :l Safety Evaluation Report that notes that the review has oeen made [EQ t=T:. < using the Standard Review Plan criteria as of the apolication Jih
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.::: l docket date, tabulates all deviations from those criteria, and EEE
===. identifies the location:in the Safety. Evaluation Report where iEE ^ ~
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g-.g:;i !lMEI p?. The procedural steps given above relate to future construction permit o applications. Some slight modifications to these procedural steps will E:;=; be mace in order to inplement tne procedure for construction permit 5.P =.:": t ~.t j applications docketed after September 1, 1976, and currently in the isE: Eii=' licensing process. @g . =.? Procedure For' Ooerating License Applications ...... ;=..
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Tne procedure for cocumenting deviations from the Standard Review Plan E'.i
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for operating licen.3e applications docketed after January 1,1977, ana [=m1 for which the construction permit review was conducted in accordance hh i:.* ::2 Lt... with the Standard Review Plan'is to be identical to that described above Ei5 .IE...E for a new const.ruction permit application. The following procedure shall IEjs 5.5.. be followed for other operating. license applications docketed after 2 51
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January 1,1977: D 1. The staff should perform its review of the Safety Analysis Report
- .1 so as to identify any deviations from the Standard Review Plan.
f$ $5Y 2. The Safety Evaluation Report inputs provided by the technical
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review groups snould describe each' deviation and the basies j.jM
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== .estaolisnea oy the staff for its acceptaoility; tne Safety cvalua-
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==j acceptaoility of the applicant's aesign relative to the grouping j 4 of acceptance ' criteria given in the Sta:xiard Review Plari sections. 2ne safety Evaluation Report inputs sL1ould also'incluoe ais~cussions ) of any alternate approacnes to staff positions tnat nave:been acoptea oy tne applicant ana the cases for acceptacility.-
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3. 22e assistance of tne applicant snoula not oe reqairea witn respect to ioentification of ceviations from tne Starcaro review Plan.
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- j If specific acceptance criteria now in tne Stancard Review Plan
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pnase of review, even tnough tne Stanaard Review-Plan either did , {1 not exist as. such at tne time of that review, or was not useo at tnat time, then applicaole requests for information may oe maoe ..g of the applicant proviaed tnat tne use of the specific acceptance ".] '1 criteria at that stage of review is accumented in the recora of i tae construction permit review ano deviations from those criteria are loentifieo oy the staff during its operating license stage of review. In accition, for all otner acceptance criteria useu in tne cesign of tne facility, applicaole requests for infor-ration may oe made or tne applicant to tne extent neeced to par-mit tne staff to inuepenaently Juage tne current acceptaoility ~EE .1.. of tne aesign wnien was cased upon sucn criteria. In enese latter instances, however, the applicant, wnile it may, shoulo .ee 2
===< -a- -gi"5:"-- _ = ~:i i;: V. %2= not ce requireo to Justify its oesign oy comparing it to an-
== a1 ternate oesign oevelopeo oy tne applicant utilizing tne g@Mj .....s acceptance criteria currently in toe Stancarc Review Plan. -- I-] 4. .Tne Licensing Project Manager snould incluoe a section in tne. p.... ' Safety Bvaluation Report that notes tnat tne review nas been ...2)4 g.. maue using the Stanoaro Jeview P.Lan criteria as of the appli- ... 21 cation oocket cate, taoulates all oeviations from tnose criteria, ).. ..i .4 ano iaentifies tne location in tne safety Evaluation Report p;.m
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{ g=== t...: As with tne proceoure for construction permit applications, specific !===:l L.:i= =.{ steps will oe.taken to assure that the 4Tlemntation will be con- [ 1 ' E== ja =iij sistent witn ene concission's stancaroization ana replication policies.
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a" .~.Z" ENCLOSURE 2 5j
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IMPLEMENTATION PROGRAM ~
== I. PLANT INVOLVEMENT =i.==g 1. Plants Currently Under Review for Operatino Licenses Ed
- =.q Plants for which applications for an operating license have been
== =j docketed but for~ which we will not implement the policy estab-E=d lished in Office Letter No. 9 are. .54
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-0. C.-Cack 2 -- Arkarca: 2 -1 Salem 2 ' #- McGuire 1 & 2 / '"i -Dav45-Besse-1-- Fertni 2 < Er.5 North Anna 1 & 2 / Zimmer 1 / ~~-: Farley 1 & 2 / -Match-2= '.N Diablo Canyon 1 & 2 / Shoreham 1 / '==l Sequoyah 1 & 2 < Watts Bar 1 & 2 / 5=?: -Thr:0 Mile I:1:nd "='l. .3 2. Plants With Construction Perinits and Which Will Aoolv for Operating .gfy n;, Licenses sa .... z = i$ All plants with construction permits which were not reviewed in
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- t. g accordance with the Standard Review Plan and f6r which appli-
==.=q cations for operating licenses are to be docketed after January 1, ad 1977, will be included in those for which we will implement the
====4 policy established in Office Letter No. 9. Such plants are: ! eel
== sd LaSalle 1 & 2 -North-Anna a a+ >=="4 San Onofre 2 & 3 Forked River 1 =9:l Summer 1 WPPSS 1 EEid Hanford 2 Callaway 1 & 2-1 South Texas 1 & 2 Seabrook 1 & 2 ..l =. = Susquehanna 1 & 2 Millstone Point 3 = = = - Waterford 3 Beaver Valley 2 Braidwood l & 2 Palo Verde 1, 2 & 3 =gi Byron 1 & 2 Nine Mile Point 2 -.J"- Catawba 1 & 2 Limerick 1 & 2 Comanche Peak 1 & 2 Hope Creek 1 & 2 Midland 1 & 2 Surry 3 & 4 Grand Gulf 1 & 2 Vogtle 1 & 2 4 95 Bellefonte 1 & 2 Bailly 1 s#s Clinton 1 & 2 EGa 55 In addition, those plants listed in items 3.b. and 5:= 3.c. on page 2 of this enclosure should be included =. in this list as they are issued construction per. nits. 5: 1 =+ ~
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_.......a +: 3. Plants Currently Under' Review for Construction Pemits
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The only plants for which applications for a construction EEs pemit were docketed after September 1,1976, and for ll5 which we will ir.plerent the policy established in Office ff= Letter No. 9 are: =g: f5 --New Ensilend I i 2 [5H sr b. Plants for which applications for a construction pemit have =i been docketed, for which our review is complete, nearly com-E plete, or significantly in process, and for which we will [. ~. not 1mplement Office Letter No. 9 are: .g Harris 1, 2, 3 & 4 Pebble Springs 1 & 2 [5.h St. Lucie 2 -Jcvis Besset at - EE Perry 1 & 2 -40shkonong+& j@ River Bend 1 & 2 --dc=wur t 1 L2--- =.; WPPSS-4 Hartsville 1 & 2 Esfi Pilgrim 2 Skagit 1 & 2 E=5 - At4antie--l 4 2 - -GMnch-RTVdr-1-- If
== Wolf Creek 1 --FtcCalhoun I"E5 Cherokee 1, 2 & 3 Marble Hill 1 & 2 iE i==: Perkins 1, 2 & 3 M reene-Gounty 1 -Tyrone-1-- Phipps Bend l & 2 ~ EE -Sterling Black Fox 1 & 2 EEi --Hontegue--l-&-t-- Yellow Creek 1 & 2 jij WPPSS 3 & 5 p:; rZi Ei c. Plants for which applicatior.s for a construction pemit have jEs been docketed, for which a significant portion of our review F has been completed, for which a long delay in the need for 5"i construction pemits has occurred, for which the Safety EEE Evaluation Report or a substantive update of that report EE is expected to be issued after January 1,1978, but for !E which we will not inplement the policy established in Office Letter No. 9 are: l51 EE Allens Creek 1 & 2 -Berton-1-&2-- E== -Nontague-1 T T- -Greenwood-2-& E --Bottghsiaint44 EE as EE EE b E.Eh .F=~5
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5 .3-1 3,;. =_" g + Jui =.B 4. Future Construction Pemit Applications 555 The policy established in Office Letter No. 9 will be imple-EE mented for all future construction pemit applications. The ~.T.T applications currently listed to be tendered during 1977 include: =s -E+ie 1 & 2- -Sears-Is-l a nd-1-&-2-- EE Sundesert i & 2~ -Centrat-Iowa.1-M . Summi t-1-&. San Joaquin-1,-2,-3 4 4-5 . Carroll -l -&,;
==.: 5. Construction Permit Applications Referencing Approved Standard ].;.5 Desians or Replicating Base Plants
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The policy established in Office Letter No. 9 will be imple-mented only for those portions of the Preliminary Safety Analysis ~~~T . Report that require a de novo review in accordance with the Standardization Policy or the Replication Policy, as applicable. 2 . 5'":!.5 6. Design Approval and Manufacturing License Aoplications ...'.:1. The policy established in Office Letter No. 9 will be imple-
==- =~ ~?.T mented for all design approval and manufacturing Ticelse appli-cations docketed after September 1,1976. On this basis it is expected that the policy will be implemented for RESAR 414, T~~ GIBBSAR, and all later submitted applications. ~~~ II. I W LEMENTATION METHODS 1. Construction Permit and Prelimirary Design Approval Apolications g g. c.E New England 1 & 2, a replicate plant, will be the first construction . " ~ pemit plant to be subjected to this review. Although the appli-cation has been docketed, the review was not scheduled to begin until January 1977. We will discuss the Office Letter No. 9 TEE requirements with the acplicant as soon as practical and will
== fomalize our infomation needs in a letter signed by the appro-
- 2E priate DPM Branch Chief.
Until six months after the Standard "EE Fomat is changed to require the needed infomation in the Safety E =" Analysis Report, all subsequent construction pemit and prelimi-nary design approval applications will be handled in a similar 1..... manner. The discussions with the applicants will be held in ~T.- as timely a manner as practical in order to provide the appli- "5.5.. '~~~ cants with as much time as possible to respond to our needs. 5
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=.=y . ("" Z=;% 2. Oceratino License and Final De' sign Approval Apolications In order to fully infom the first several applicants in this group of the basis of the requirements that we will impose upon ~~~ them and to try to assuage their concerns as to the extent of 5{f. the infomation we will require from them, we will arrange bs=y discussions with them as soon as practical. These will be = arranged in the order of their docketing, which is expected to ~~1 x, be Watts Bar 1 & 2, San Onofre 1 & 2, LaSalle 1 & 2, Sumer 1, =J Hanford 2, Comanche Peak 1 & 2, Midland 1 & 2, and Grand Gulf =ll;l 1 & 2. Our infonnation needs will be formalized in a letter ~ to the applicant. The letters will be signed by the appropriate 4 DPM Branch Chief. Modification of the Standard Format will require the needed [ inforration in the Final Safety Analysis Reports for plants b.3.., having construction pemits based on a review in accordance [. with the Standard Review Plan. E=== i;.=.= 3. Conduct of Discussions kE:= f.= The discussions referred to in Sections II.1 and II.2 above =f=- i:: -
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are to be conducted by the DPM Assistant. Director for Light -Water Reactors. = =. E=~"'. by n-4. Standard Fomat f.=::. ~ [@ The Office of Standards Development will be requested to modify the Standard Fomat to require the Safety Analysis Report to ~ include the infonnation needed to confom to the policy estab-C. lished in Office Letter No. 9. =_ 5. Changes Reouired in the Standard Review Plan ~~ I::D The Directors of DPM, DSS, and DSE are to provide to the Director, !sa NRR, by May 1,1977, a list of items in the Standard Review Plan that should be modified to assure that all requirements "=9 - therein are necessary, realistic, and practical of achievement. The Directors will at that time recommend a program to develop
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the required changes to the Standard Review Plan and obtain the necessary management approval for such changes.
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