ML19323B883

Procedure for Documentation of Deviations from Srp. Implementation Program Encl

ML19323B883
Person / Time
Site:	Crane
Issue date:	12/31/1977
From:	Office of Nuclear Reactor Regulation
To:
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ML19323B881	List: ML19323B880 ML19323B883
References
TASK-TF, TASK-TMR NUDOCS 8005140377
Download: ML19323B883 (11)

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P)4XEDGE FOR DXUl*ENTATIQ7

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~k, OF DEVIATICNs FFX4 TE STANDARD EVIfA PIM iAasi

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Introduction w

O The staff review of nuclear plant designs oescriced ir Safety Analysis

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Reports is performed witnin the gsidelines establisned by the Standard

,4,_g Review Plan (NOREG-75/087), is' sue 6 in Septemoer 1975, and as since

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amenced.

sl Use of the ' acceptance criteria of the Starkiard Revie~w Plan as

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[d a measure of the acceptability of plant design features assures both a.

.:A consistent evaluation of proposed plant designs and an acceptable level

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in scribes and documents the acceptacility of specific design approaches

S,y to satisfy certain of the acceptance,, criteria.

We recognize, however,

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that alternate design approaches. cay sadisfy these acceptance criteria

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,.9 ecually well.

Purther, we recognize that, with prcper justification,

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.,iy applicants may oe able to demonstrate that particular provisions of the f

.j acceptance criteria need not be met at all.

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...g Currently, significant difficulties'arise when the Standard Review Plan is useo during the operating licenss review of a pla.: 6esign.

These

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cifficulties stem from the fact that the plant design at its construc-

,"[.y tion permit stage of licensing was reviewed and approvec against differ-

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ent guidelines due to the lack of the Standard Review Plan at that i../i I'.

earlier stage cf review; some future reviews will encounter the same.

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'. -h cifficulties cue to tne same reason or to changes to the Standard Review 3

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Plan that have occurred curing the intervening perico.

In either event, sy

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p fg.v. r yQ; ceviatioris,will exist in the' plant design relative to the then current m,3 :

. Standard Review Plan, and the staff is or will oe f aced witn licensing 4.w

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6ecisionsr6rdingtheacceptacilityofthedesigndescrioecinthe

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'E Final Safety Analysis Report.

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g ;g In the past, applicants have expenoed consideraole efforts justifying, 9~~fs and the ' staff has spent.consideraole time evaluating, particular plant 3.w

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Often these N((

efforts have not been properly documented to clearly indicate the bases

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for acceptacility of the design.

To inprove the usefulness of our

5 jQ Safety Evaluation Reports as a record of such decisions and to ' minimize

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acecuate levels of safety relative to currrent criteria, it is cesiracle

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that the bases for such licensing cecisions De c.Learly documented in the

..g Ci Safety Evaluatien Reports that summarize the sta.ff review of the Final Safety Analysis Report. To this end, any deviations from current

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lik Stancarc Review Plan acceptance criteria will need to oe. listed and 4 -;

.{jj justified in the staff's safety Evaluation Report prior to cenpletion of

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[.5 the operating license stage of review.

Further, such deviations will

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.3 also need to be listed and justified in the licensee's Final Safety

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, -j.3 Analysis Report for any facility reviewed to the recuirements of the w

Stancard Review Plan at th'e construction permit stage o'f review, L

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A proolem of similar type but of much less magnitude may ex'ist with re-spect to some construction permit anc stancaro design applications and

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associated staff reviews. Since all new applicaticas for construction 48"3

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' permits or, for preliminary design approval of standard oesigns must ac-dress.the information needs identified in Revision 2 to the Stancard ass,.

Format and Content of Safety Analysis R,epor.ts, deviations from the

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acceptance criteria of the Standard Review Plan are expected to be non-wg-existent or minimized. However, t.a.nate design approaches inay be proposed

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M;;g by the applicant, and it is possible that deviations may arise curing tne.

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E In any event, any deviations or alternate design

. course of the review.

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approaches, whether initially proposed or developed during the course of 13.:$j tne staff review, will need to be listed and justified in the Preliminary 4-b C)

K Safety Analysis Report and in the staff's safety Evaluation Report prior to l.':25 exgi ccepletion of this stage of review.

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@. :'f This occument presents tne procedures that should be followed (1) by appli-

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cants and (2) oy staff reviewers arc Licensing Project Manacers to assure s,,.

2;fj that acequate documentation of cevia.tions and alternare approaches in plant

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designs relative to the Standard Review Plan is provided in Safety Analysis Reports and in Safety I., valuation Reprrts, respectively.

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AFJ Definition of Deviation

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.i~h For the purposes of this procecure, a deviatien fs defined as a lack of con-

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fermance of a plant cesign feature to one or rcre provisions of the accept-l 'M...$..

ance criteria given in the Stancard Review Plan. An alternate anc acceptable Wi$

design approach to, satisfying the Standard Review Plan acceptance criteria

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also oe documented in the Safety Analysis Report anc, as appropricte, in the

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M Procedure For Construction Permit Aeolications

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Tne procedure for documenting deviations 'from the Stancarc Review Plan ds for construction permit applications requires the applicant a... lly to M-nitia

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-%25 ictintify the~ deviation and provide the bases for acceptability., This L '-

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. information should be included ir) the safety Analysis Report and reviewed

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by the staff.as a part of tne 'n'ormal review process. The results of the M

-review snould be descr bed in the Safety Evaluation Repor.t to provide clear i

%= ;-i docurrentation of all oeviations, including the bases for acceptability.

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L,'.!.Q Tne same procecure should be followed for alternate design approacnes.

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25-2 established whereby plants licensed for operation will be maintained

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,J3 continuously up-to-date with regard to changes in licensing requirements

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Its applicability on a generic basis or on each plant, on a case-cy-case 2.W2

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oasis, will also be made and implemented).

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The specific steps in the proceoure for a construction permit application M

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Tne applicant will identify and provide bases for all' deviations lre.

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from be acceptance criteria given in the Standard Review Plan.

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Tne information should be contained in tiiose ' Safety Analysis

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-if Report sections that describe the ' systems, co ponents, or struc-

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tures in dich the deviations exist.

In addition, the applicant

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should provide in Cnapter 1 i sumrt.ary listing of the deviations

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and an identification of the sections in the Safety Analysis

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Report wherein the deviations are described and justified, s.u

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Dur'ing the acceptance review of the Safety Analysis Report, the m

staff should determine that this information has oeen provi6ed Nyh1 ww T

and should inform the applicant of any oovious deficiencies..

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Following docketing of the Safety Analysis Report, the staff 70 2.:

'should perform a review of tfie deviations ano their bases, iden-'

==.a tify other deviations that should oe discussed in the Safety

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at the first round request for additional information (0-1) stage

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At the second round request for acditional intormation (0-2)

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stage of review, the staff should inform the applicant of its 9

• u positions on the devictions and their bases.

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Following review of the app 1'icant's response, draft Safety

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Evaluation Report inputs should be prepared that descrioe each

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ceviation and the results of the staff review of the cases for m

l,.'j tneir acceptability; the safety Evalection Re, ort inputs should

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's applicant's cesign relative to the grouping of acceptance criteria

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. ;j given in the Standard Review Plan sections. The Safety Evaluation

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approaches to staff positions that have been adopted oy the ap;[licant 5

anc the bases for acceptability.

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The' Licensing Project Manager snould incluoe a section in the

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M Safety Evaluatier, Report that notes that the review has oeen mace Ti2

.using the Standard Review Plan criteria as of the application I4:5

. docket cate, tabulates all deviations from those criteria, and r"

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icentities the location in the Safety Evaluation Report where

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the discussion may be f'ound.

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-p.a The procedural steps, given above relate tio future construction permit

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-dy applications.

Some slight modifications to these procedural steps will '

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be maae in order to inplement the procedure for construction permit

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applications docxeted after Septemoer 1,1976, and currently in the

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..d. a.9 licensing. process.

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Procecure for coeratine Lic'ense A lications Tne procedure for accumenting deviations from the Standard Review Plan

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for operating, license applications docketed after January 1,1977, ano 4...- :j for which the construction permit review was conducted in accorcance

-n with the Standard Review Plan is to be identical to that ' described aoove S....

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for a new construction permit a,cplication.

The following procecure shall 7,W 4f be followed for other operating license applications docketed af ter h;

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January 1,1977:

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The staff should perform its review of the Safety Analysis Report so as to id.entify any deviations from the Standard Review Plan.

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The Safety Svaluation Report' inputs provided by the technical M}"

review groups snould describe'each deviation and the bases

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not De requireu to jus'ify its oesign oy co.: paring it to an id t

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a1 ternate oesign cevelopeu of the applicant utilizing tne Wa...

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Tne Licensing Project nanager snoulc inciuoe a section in tne w

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... an mme using the Stanuarc Aeview Plan criteria as of the appli-h:

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=,.n cation cocket cate, taculates all oeviations from tnose criteria,

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. ?..:.cy anu icentifies tne location in tne safety Evaluation ile. port

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As with tne p*ocecure for construction.Dermit a.c.clications, specific

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=fy steps will ce taken to ' assure that tne imolementation will oe con-

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-.s s W-y sistent witn tne Conmission's stancarci::ation ana replication policies.

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E*?E LI

/f,3 ENCLOSURE 2 a

..m 22E IMPLEMENTATION PROGRAM 5

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PLANT INVOLVEMENT.

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Plants Currently Under Review for Operatino Licenses

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Plants for which applicatipns for an operating license have been docketed but.for which we will not implement the policy estab-yp(

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lished in Office Letter No. 9 are:

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.or D. C.. Cook 2 Arkansas 2 7sf; Salem 2 McGuire 1 & 2 Davis Besse 1 Fermi 2

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North Anna 1 & 2 Zimmer 1

.rY Farley 1 & 2 Hatch 2 Diablo Canyon 1 & 2 Shoreham 1 d

~:35 Sequoyah 1 & 2 Watts Bar 1 & 2 5g73 Three Mile Island 2

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2.

Plants With Construction Permits and Which Will Acolv for Ooeratino 7:t.E Licenses IUI

.'$[3 All plants with const'ruction pennits which were not reviewed in

.33 accordance with.the Standard Review Plan and for which appli-cations for operating lic'enses are to be docketed after January 1, 1l;j.

1977, will be included in thos.e for which we will implement the

~ ~i policy established in Office Letter No. 9.

Such plants are:

gjU LaSalle 1 & 2 North Anna 3 & 4 atih.'

San Onofre 2 & 5 Forked River i fe:

.Surmer 1 WPPSS 1

'i j Hanford 2 Callaway 1 & 2

' '/, 3 South Texas 1 & 2 Seabrook 1 & 2

@Ei Susquehanna 1 & 2 Millstone Point 3 314 Waterford 3 Beaver Valley 2 G,.76 Braidwood 1 & 2 Palo Verde 1, 2 & 3 "52 Byron 1 & 2 Nine Mile Point 2 uu Catawba 1 & 2 Limerick 1 & 2 Comanche Peak 1 & 2 Hope Creek 1 & 2 l,J4 Midland 1 & 2 Surry 3 & 4 l D3.-

Grand Eulf 1 & 2 Voetle 1 & 2 J.E Bellefonte 1 & 2 Bailly 1

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.'is Clinton 1 & 2 tf?

In addition, those plants listed in items 3.b. and

, rf 3.c. on page 2 of this enclosure should be included

.i in this list as they are issued construction permits.

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3.

Plants Currently Under Review for Construction Pemits a.

The only plants for which applications for a construction si T_T pemit were docketed after September 1,1976, and for which we will implement the policy established in Office

'M Letter No. 9.are:

=:4 New England 1 & 2 g,

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Plants for which applications for a construction permit have 5:is been docketed, for which our review is complete, nearly com-O plete, or significantly in process, and for which we will not implement Office Letter No. 9 are:

yu Harris 1, 2, 3 & 4 Pebble Springs 1 & 2

?$y St. Lucie 2 Davis Besse 2 & 3 f.f; Perry 1 & 2 Koshkonong 1 & 2 River Bend 1 & 2 Jamesport 1 & 2 30

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lis WPPSS-4 Hartsville 1 & 2

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Pilgrim 2 Skagit 1 & 2

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Atlantic 1 & 2

. Clinch River 1 Wolf Creek i Ft. Calhoun 2-El Cherokee 1, 2 & 3 Parble Hill 1 & 2 ifi-Perkin's 1, 2 & 3 Greene County 1

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Tyrone'l Phipps Bend 1 & 2

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Sterling i Black Fox 1 & 2 Montague 1 & 2 Yellow Creek 1 & 2

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WPPSS'3 & 5

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.%:.l Plants for which applications for a construction pennit have c.

been docketed, for which a significant portion.of our review

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has been completed, for which a long delay in the need for W

construction pennits has occurred, for which the Safety

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Evaivation Report or a substantive update of that report Tj is expected to be issued after January 1,1978, but for ic which we will not implement the policy established in Office Letter No. 9 are:

~.2. j 7Jr Allens Creek 1 & 2 Barton 1 & 2 Si Montague 1 & 2 Greenwood 2 & 3 i:?-

Douglas Point 1 & 2

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Future Construction Permit Aeolications

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The policy established in Office Letter No. 9 will be imple-mented for all future construction permit applications.

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swa applications currently listed to be tendered during 1977 include:

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Erie 1 & 2 Sears Island 1 & 2

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Sundesert 1 & 2 Central lowa 1

.EM Summit 1 & 2 San Joaquin 1, 2, 3.& 4 RC Carroll 1 & 2

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Constructio'n Permit Aeolica.tions Referencino Acoroved Standard

@h.gg5 Desions or Reolicatina Base Plants

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"?.73 The policy established in Office Letter No. 9 will be imple-

.:.rG mented only for those portions of the Preliminary Safety Analysis 15.M Report that require a de novo review in accordance with the

]:G..P Standardization Policy or the Replication Policy, as applicable.

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Desian Acoroval and Manufacturino License Acolications

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The policy established in Office Letter No. 9 will be imple -

.pq mented for all design approval and manufacturing license appli-7T.n cations docketed after September 1,1976.

On this basis it is 4:*:;

expected that the policy will be implemented for RESAR 414,

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GIBBSAR, and all later submitted applications.

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. IMPLEMENTATION METHODS 43 ijg 1.

Construction Permit and Preliminarv Desion Acoroval Acolications

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-94 New England 1 & 2, a replicate plant, will be the first construction jff3 permit plant to be subjected to this review.

Although the appli-citj cation has been docketed, the review was not scheduled to begin

f.id until January 1977.

We will discuss the Office Letter No. 9

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-requirements with the applicant as soon as practical and will 4.g fomalize our infomation needs in a letter signed by the appro-E; priate DPM Branch Chief.

Until six months after the Standard

M5 Format is changed to require the needed information in the Safety

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Analysis Report, all subsequent construction pemit and prelimi-

'2.g nary design approval applications will be handled in a similar

,.273 manner.

The discussions with the applicants will be held in as timely a manner as practical in order to provide the appli-

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. d cants with as much time as possible to respond to our needs.

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Operatino License and Final Desion Acoroval Aeolications i b.U.

Qt in order to fully infom the first several applicants in this t q, youp of the basis of the requirements that.we will impose upon -

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Nm and to try to assuage their concerns as to the extent of q

th2 infomation we will require from them, we will arrange discussions with them as soon as practical. These will be

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arranged in the order of their docketing, which is expected to be Watts Bar 1 & 2, San Onofre 1 & 2, LaSalle 1 & 2, Summer.1, M-Hanford 2, Comanche Peak l' & 2, Midland 1 & 2, and Grand Gulf-Sds. -

1 &.2.

Our infomation needs will be femalized in a letter T2G to the applicant. The letters will be signed by the appropriate

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DPM Branch Chief.

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Modification of the Standard Format will require the needed Jjs,C information in the Final Safety Analysis Reports for plants 9.5.i having ' construction pemits based on a review in accordance c '/J.';

with the Standard Review ~ Plan.

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Conduct of Discussions 7J)4

.G The discussions. referred to in Sections 11.1 and 23.2 above

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I are to be conducted by the DPM Assistant Director for Light

..M Water Reactors.

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Standard Format 7:r4 3-2 The Office of Standards Development will be requested to modify

'E the Standard Fomat to require the Safety Analysis Report to 58 include the infomation needed to confom to the policy estab-lished in Office Letter No. 9.

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Chances Reovired in the Standard Review Plan G.G

...:. a gg The Directors of DPM, DSS, and DSE are to provide to the Director, J.G NRR, by May 1,1977, a list of items in the Standard Review Plan that should be modified to assure that all recuirements

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therein are necessary, realistic, and practical of achievemen' i

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The Directors will at that time recommend a program to devel'op

' Wlf the required changes to the Standard Review Plan and obtain i

the necessary management approval for such changes.

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