ML19329F020

Procedure for Documentation of Deviation from Std Review Plan (NUREG-75/087)

ML19329F020
Person / Time
Site:	Midland
Issue date:	07/15/1977
From:	NRC COMMISSION (OCM)
To:
Shared Package
ML19329F015	List: ML19329F014 ML19329F020
References
RTR-NUREG-75-087, RTR-NUREG-75-87 PROC-770715, NUDOCS 8006190806
Download: ML19329F020 (9)

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DJCIuSURE 1

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PlOCEDORE FOR DOCO:4ENTATIOri OF DEVIATIONS FROM TffE STANDARD REVIEd PIM

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Introduction

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The staff review of nuclear plant designs oescrioeo in Safety Analysis m:5 Reports is performed within the guidelinee, estaolisned by the Standard Review Plan (tidREG-75/U87), issueo in Septemoer 1975, and as since amenced. Use of the acceptance criteria of the Standard Review Plan as a measure of the acceptacility of plant design features assures both a consistent evaluation of proposed plant designs and an acceptacle level of safety for all plants licensed. The Standard Review Plan also de-scribes and documents the acceptacility of specific design approacnes to satisfy certain of the acceptance criteria. We recognize, however, that alternate design approaches may satisfy these acceptance criteria equally well. Further,'we recognize that, with proper justification, applfcants may oe able to demonstrate that particular provisions of the acceptance criteria need not be met at all.

A Currently, significant difficulties arise when the Standard Review Plan is useo during the operating license review of a plant design. These cifficulties stem from the fact tnat the plant design at its construc-tion permit stage of licensing was reviewed ano approved against differ-ent guidelines due to the lack of the Standard Review Plan at that earlier stage of review; some future reviews will encounter the satte

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cifficulties cue to tne same reason or to changes to the Standard Review

-Plan that'have occurred during the intervening perioo.

In either event, 8006'190 [ C d

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ceviations will exist in the plant design relative to the then current Standard Review Plan, and the staff is or will oe faced witn licensing cecisions regarding the acceptacility of the design cescrioea in the 4:i Final Safety Analysis Report.

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In the past, applicants have expenced consideraole efforts justifying, and the staff has spent consideraole time evaluating, particular plant design features to assure an acceptacle level of safety. Often these efforts have not been properly documented to clearly inaicate the cases

':L' for acceptanility of the design. To improve the usefulness of our

=1 Safety Evaluation Reports as a record of such decisions and to minimize

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the need for future reassessments of operating plants to degenstrate acequate levels of safety relative to current criteria, it is cesirable that the cases for such licensing aecisions be clearly documented in tne Safety Evaluation Reports that summarize the staff review of the Final Safety Analysis Report. To this end, any deviations from current Stancarc Review Plan acceptance criteria will need to be listed and justified in the staff's Safety Evaluation Report prior to completion of the operating license stage of review. Further, such deviations will also need to De listed and justified in the licensee's Final Safety Analysis Report for any facility reviewed to the requirements of the Stancarc Review Plan at the construction permit stage of review.

A'proolem of similar type out of much less magnitude may exist with re-spect to some construction permit and standara design applications ano associated staff reviews. Since all new applications for construction I e p

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t' permits or ror preliminary design approval of standard designs must aa-dress the information needs identified.in Revision 2 to the Stanaard

ir c'ormat and Content of Safety Analysis Reports, deviations from the

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

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existent or minimized. However, alternate design approaches may be proposed by the applicant, and n is possible that deviations may arise curing tne course of the review. In any event, any deviations or alternate design approaches, whether initially proposed or developed during tne course of 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 completion of this stage of review.

This cocument presents tne procedures that should be followed (1) by appli-cants and (2) Dy staff reviewers and Licensing Project Managers to assure that adequate cocumentation of deviations and alternate approache.] in plant designs relative to the Standard Review Plan is provided in Safety Analysis

. Reports and in Safety Evaluation Reports, respectively.

Definition of Deviation For the purposes of this procedure, a oeviation is defined as a lacx of con-formance of a plant cesign feature to one or core provisions of the accept-ance criteria given in the Stancard Review Plan. An alternate ano acceptacle cesign ' approach to satisfying the Standard Review Plan acceptance criteria is not considered to be a deviation, but the bases for acceptaoility must also oe docu:nented in tne Safety Analysis Report ano, as appropriate, in the Safety Evaluation Report.

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Procecure For Construction Permit Applications Tne procecure for. cocumenting deviations from the Standara Review Plan for' construction permit applications requires the applicant initially to

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icentify the deviation ano provice the bases for acceptability. This information should De included in the Safety Analysis Report and rev'iewed Dy.tne staff as a part of tne normal review process. The results of the

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review snould De described in the Safety Evaluation Report to provide clear occunentation of all deviations, including tne bases for acceptability.

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Tr,e same procedure should. be followed for alternate design approacnes.

The procecure is cased on the implicit assumption that a program will be established whereby plants licensed for operation will be maintained continuously up-to-date with regarc to changes in licensing requiremnts (i.e., at the time a new staff position is developed, a decision regarding its applicability on a generic basis or on each plant, on a case-by-case casis, will also ce mace and implemented).

The specific steps in the procecure for a construction permit application are:

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The applicant wil) identify and provide bases for all deviations from' tne acceptance criteria given in the Standard Review Plan.

Tne information should be contained in those Safety Analysis Report sections that describe the systems, components, or struc-

~ In addition, the applicant tures in whien the deviations exist.

snould provide in Chapter 1 a summary listing of the deviations and an identification'of the sections in the Safety Analysis H

Report wherein the deviations are described and justified, u

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During the acceptance review of the Safety Analysis Report, the staff should determine that this information has oeen provided

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and should inform the applicant of any obvious deficiencies.

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Following docketing of the Safety Analysis Report, the staff should perform a review of the deviations ana their bases, iden-tify other deviations that should be discussed in the Safety Analysis Report, and request aoaitional information as necessary at the first round request for additional information (0-1) stage of review.

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At the second round request for additional information (Q-2) stage of review, the staff should inform the applicant of its positions on the deviations and their bases.

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Following review of the applicant's response, draft Safety Evaluation Report inputs should be prepared that describe each

. deviation and the results of the staff review of the bases for

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tneir acceptability; the Safety Evaluation Report inputs should also include a general statement denoting acceptability of the applicant's oesign relative to the grouping of acceptance criteria given in the Standard Review Plan sections. The Safety Evaluation Report inputs should also incluca aiscussions of any alternate approaches to staff positions that have been adopted oy the applicant and the cases for acceptability.

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The Licensing Project Manager snould incluoe a section in the Safety Cvaluation Report that notes that he review has oeen maae

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using the Standard Review Plan criteria as of the application ll:;l docket date, tabulates all deviations from those criteria, and

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identifies the location in the Safety Evaluation Report where the aiscussion may be found.

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The procedural steps given above relate to future construction permit

-applications. Some slight modifications to these procedural steps will be mace in order to implement the procedure for construction permit ap lications docketed after Septemoer 1, 1976, and currently in the licensing process.

Procedure For Operating License Apolications Tne procedure for oocumenting deviations from the Standard Review Plan for operating license applications docketed after January 1, 1977, and for which'the construction permit review was conducted in accorcance with the Standard Review Plan is to be identical to that described above for a new construction permit application. The following procedure shall ce followed for other operating license applications docketed after January 1,1977:

1.

The staff shoulo perform its review of'the Safety Analysis Report so as to identify any deviations from the Standard Review Plan.

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The Safety Evaluation Report inputs provided by the technical review groups should describe each leviation and the bases 9

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- t-estaolisneo oy the staff for its acceptaoility; tne Safety Evalua-77 tion Report inputs shoula also incluae a general statement cenoting acceptaoility of the applicant's aesign relative to tne grouping of acceptance criteria given in the Stancard Review Plan sections.

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Tne dafety Cvaluation Report inputs snould also include oiscussions of any alternate approacnes to staff positions tnat nave been aooptea oy tne applicant ano the cases for acceptaoliity.

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Tne assistance of tne applicant snoulo not ce requirea witn respect to identification of ceviations from tne Stanaaro Peview Plan.

If specific acceptance criteria now in tne Stancard Review Plan wre usea tor evaluating tne application at tne construction permit pnase of review, even tnough tne Stancarc Review Plan either cia j

i not exist as such at the time or that review, or was not useo at tnat time, then applicaole requests for information may oe mace of tne applicant proviaed tnat tne use of tne specific acceptance criteria at that stage of review is accumented in the recora of the construction permit review ano aeviations from those criteria are' ioentifieo oy the staff curing its operating license stage of review.

In accition, for'all otner acceptance criteria useu in tne cesign of tne facility, applicaole requests for infor-mation may oe made of tne applicant to tne extent neeceu to per-mit tne stati to inuepenaently Juoge tne current acceptaoility 3

of tne cesign wnicn was cased upon sucn criteria. In tnese latter insEances, however, tne applicant, wnile it may, snoulo I.

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not ce requireo to' Justify'its cesign oy comparing it to an y,:

alternate oesign oevelopeo oy tne applicant utilizing tne 9i acceptance criteria currently in tne Stancara Review Plan.

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'Ine Licensing Project Manager snould incluce.a section in tne safety t; valuation Report tnat notes tnat tne review nas been maae using tne stanuarc seview Plan criteria as of tne appli-cation cocket cate, tabulates all oeviations from tnose criteria, ano ioentifies tne locauon in tne dafety Evaluation Report wnere tne discussion may oe found.

As with tne proceoure tot construction permit applications, specific steps wiJ.1 oe taken to assure that the implementation will De con-sistent witn tne Connission's stancaraization ana replication policies.

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Distribution w/ enclosure:-

(Docket File NRCP0 &

Local'PDR-Branch File LEM LA E. Case R. Boyd' R.~DeYoung 4

D. Vassallo EID I&E.(2)

J. Knight D. Ross R. Tedesco R. Vollmer W. Gamill H. Smith F. Williams bec w enclosure:

ACRS (16)

NSIC

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