ML20035F209
| ML20035F209 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-93-097, SECY-93-97, NUDOCS 9304210030 | |
| Download: ML20035F209 (20) | |
Text
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POLICY ISSUE April 14,1993 SECY-93-097 (Informat. ion)
For:
The Comissioners From:
James M. Taylor Executive Director for Operations
Subject:
INTEGRATED REVIEW SCHEDULES FOR THE EVOLUTIONARY AND ADVANCE 0 LIGHT WATER REACTOR PROJECTS Puroose:
To provide the Comission with the staff's revised estimates of the integrated schedules for completing its reviews of the evolutionary and advanced light water reactor projects, including Electric Power Research Institute's (EPRI's)
Advanced Light Water Reactor (ALWR) Utility Requirements Document for passive reactor designs, GE Nuclear Energy's (GE's) Advanced Boiling Water Reactor (ABWR) and Simplified Boiling Water Reactor (SBWR), Asea Brown Boveri-Combustion Engineering, Inc.'s (ABB-CE's) System 80+, and Westinghouse Electric Corporation's (Westinghouse's) AP600.
Backcround:
I In SECY-91-161, " Schedules for the Advanced Reactor Reviews and Regulatory I
Guidance Revisions," May 31, 1991, the staff submitted its estimated schedules i
for completing its reviews of the evolutionary and advanced reactor projects.
In its staff requirements memorandum, the Commission directed the staff to l
inform it of changes to the schedules.
In its quarterly status reports and semi-annual briefings, the staff has kept the Commission informed of the current status of these reviews.
CONTACT:
NOTE:
TO BE MADE PUBLICLY AVAILABLE T. Kenyon, NRR IN 3 WORKING DAYS FROM THE 504-1120 DATE OF THIS PAPER 210125 1
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4 The Commissioners P In SECY-92-294, " Acceptance Review of the Westinghouse Electric Corporation's Application for Final Design Approval and Design Certification for the AP600 Design," August 24, 1992, the staff submitted an estimated schedule for the review of the Westinghouse AP600 design based on an application completion date of December 15, 1992, and the schedular milestone interval assumptions of SECY-91-161.
In SECY-93-041, " Advanced Boiling Water Reactor (ABWR) Review Schedule,"
February 18, 1993, the staff submitted a proposed timeline for its review of the ABWR indicating the duration between significant milestones leading to the notice of design certification rulemaking for the ABWR.
The timeline was based on milestones unique to that review because the design certification application is the first to be reviewed under 10 CFR Part 52, and because much of the results of the review has already been documented in several draf t versions of the safety evaluation report (SER).
l Discussion:
In SECY-91-161, the staff presented its estimates of the review schedules for the evolutionary and advanced reactors based on certain assumptions regarding dates of submittal of information by the applicants, resolution of policy and technical issues, and availability of staff resources.
The staff has reevaluated those schedules, factoring in actual milestones reached since SECY-91-161 was issued, the status of the reviews of the policy and technical issues, the experience gained from the performance of the reviews, planned versus actual Nuclear Regulatory Commission budget commitments, and the schedular inter-relationship of the projects with each other.
The enclosure provides detailed information on the staff's reevaluation and presents the revised schedules resulting from this effort. The schedules presented in this paper supersede any previous schedules provided for the evolutionary and advanced light water reactor (LWR) projects.
When preparing the schedules, the staff considered its review experience base 1
for determining the duration between milestones.
In addition, it made certain asnmptions about the reviews that are beyond the control of the Office of Nuclear Reactor Regulation (NRR); that is, quality of the applicants' submittals, duration of response time by the applicants, and duration of review time by the Advisory Committee on Reactor Safeguards (ACRS) and the Office of the General Counsel (0GC). To achieve these schedules, the applicants must provide timely, high-quality information in the standard safety analysis report (SSAR) and the inspections, tests, analyses, and acceptance criteria (ITAAC) document. Reviews of the final safety evaluation report (FSER) and final design approval (FDA) package for the ABWR by OGC and ACRS will have to be completed in a shorter time than that previously requested by those organizations. The staff believes that this can be accomplished because of the extensive reviews =nd interaction resulting from the issuance of the ABWR draft FSER. Reviews by these organizations of the other evolutionary and advanced LWR projects are scheduled to be performed in accordance with their requested time allotments.
The Commissioners,
The revised schedules are very aggressive and can only be attained if the evolutionary and advanced LWR reviews retain their priority with the review staff.
Coordination:
OGC and the ACRS have received memoranda dated February 9, 1993, requesting them to meet their respective review milestones for the ABWR.
The schedules for the other evolutionary and advanced LWR projects are in accordance with these organizations' requests.
In its memorandum of February 22, 1993, OGC stated that it had no objection to the proposed review procedure, with the understanding that "OGC's final review may result in significant problems involving coordination between sections i
being identified which require additional work of the FSER."
In its letter of March 18, 1993, the ACRS stated that "it is still our view that three months will be needed to perform a meaningful review [of the ABWR design certification application], given the proposed schedule for F
transmitting the information to us." to the enclosure is a copy of the letter. However, the schedule and timeline for the ABWR review i
provided in this paper assume a 6-week final review period for the ACRS.
The staff will work with the ACRS to expedite resolution of its concerns.
==
Conclusions:==
i Considering the assumptions discussed in the enclosure, the staff proposes the following agressive schedules for the evolutionary and advanced LWRs.
Completion Date Completion Date for FDA/ Federal Completion Date Pro.iect for FSER Reaister (FR) Notice for Rule /FR Noticg i
EPRI Passive November 1993 Not applicable Not applicable l
Utility Re-i quirements Document GE ABWR March 1994 May 1994 June 1994 ABB-CE System 80+ June 1994 August 1994 September 1994 W AP600 November 1995 January 1996 February 1996 GE SBWR March 1996 May 1996 June 1996 Attachment I to the enclosure shows the key milestone intervals for the evolutionary and advanced LWR schedules (including a comparison with the i
assumptions of SECY-91-161). Attachment 2 shows a comparison of the revised,
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The Commissioners '
projected dates for the evolutionary and advanced LWR projects with the dates projected in SECY-91-161. Attachment 3 is a chart showing the timelines for i
these reviews through the time when the FDA, the proposed rule, and the Federal Reaister notice are issued. The staff discussed possible her. ring schedules in SECY-92-170, "Rulemaking Procedures for Design Certification,"
May 8,1992, and SECY-92-381, "Rulemaking Procedures for Design Certifica-tion," November 10, 1992.
These milestones can be achieved only if the vendors submit high-quality SSAR and ITAAC information, and NRR, OGC, and the ACRS expedite their reviews. The e
staff will continue to assess the resources it needs to ensure that it can l
adequately support the schedules presented in this paper.
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Note:
Senator Johnston and Congresswoman Lloyd have shown an interest in these
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matters. Therefore, copies of this paper will be submitted to the appropriate congressional committees. Copies will also be submitted simultaneously to the Office of Management and Budget and the U.S. Department of Energy. The staff 1
recommends that this paper be made publicly available within 3 workdays from i
the date of this paper.
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7.esM.Ja or Executive Director for Operations i
Enclosure:
Schedule Assumptions for the Review of the Evolutionary and Advanced Light Water Reactor Designs l
f DISTRIBUTION:
Cormnissioners OGC OCAA OIG OPA I
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=
I SCHEDULE ASSUMPTIONS FOR THE REVIEW OF THE EVOLUTIONARY AND ADVANCED LIGHT WATER REACTOR DESIGNS INTRODUCTION Discussed below are the process and assumptions the staff used in establishing the schedules for completing its reviews of the evolutionary and advanced light water reactor (LWR) projects, including Electric Power Research l
Institute's (EPRI's) Advanced Light Water Reactor (ALWR) Utility Requirements Document for passive reactor designs, GE Nuclear Energy's (GE's) Advanced Boiling Water Reactor (ABWR) and Simplified Boiling Water Reactor (SBWR), Asea Brown Boveri-Combustion Engineering, Inc.'s (ABB-CE's) System 80+, and Westinghouse Electric Corporation's (Westinghouse's) AP600.
BACKGROUND In SECY-91-161, " Schedules for th'e Advanced Reactor Reviews and Regulatory l
Guidance Revisions," May 31, 1991, the staff submitted its estimated schedules for completing its reviews of the evolutionary and advanced reactor _ projects.
In its staff requirements memorandum, the Commission directed the staff to R
inform it of changes to the schedules. -In quarterly status reports and semi-annual briefings, the staff has kept the Commission informed of the current status of these reviews.
In SECY-92-294, " Acceptance Review of the Westinghouse Electric Corporation's Application for Final Design Approval and Design Certification for the AP600 i
Design," August 24, 1992, the staff submitted an estimated schedule for the review of the Westinghouse AP600 design based on an application completion
-I date of December 15, 1992, and the schedular milestone interval assumptions of j
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i i
In SECY-93-041, " Advanced Boiling Water. Reactor (ABWR) Review Schedule,"
February 18, 1993, the staff submitted a proposed timeline for its review of ll the ABWR indicating the duration between significant milestone' intervals l
1eading to the notice of design certification rulemaking.for the ABWR. The j
timeline was based on milestones unique to that review because the design 1
certification application is the first to be reviewed under 10 CFR-Part 52, l
and because much of the results of the review has already been' documented.in
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several draft versions of the safety evaluation report (SER). These milestones are not expected to be directly applicable to the other projects.
]
DISCUSSION l
When it developed the integrated schedules for the evolutionary and advanced l
LWR projects, the staff.first evaluated modifications to the assumptions of SECYm91-161 that were driven by historica1' precedent, the resolution schedule 1
of first-of-a-kind issues that are. being resolved on a-lead-project basis, l
- requests by the Advisory Committee on_ Reactor Safeguards (ACRS) and the Office of the General Counsel (OGC), and procedures established since SECY-91-161 was issued. These modifications _were incorporated into the timeline presented in SECY-93-041.for the ABWR review.
ENCLOSURE
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. The staff then evaluated the schedules on a project-specific basis, taking into account resource availability resulting from overlap of project efforts, reallocation of resources resulting from budget constraints, proposed submittal schedules of applicants, and the schedular relationship of the i
projects to one another.
How these considerations affected the integrated schedules is discussed below.
Attachment I to this enclosure shows the key milestone intervals for the evolutionary and advanced LWR review schedules (including a comparison with the assumptions of SECY-91-161). Attachment 2 shows a comparison of the revised, projected dates for the evolutionary and advanced LWR projects with the dates in SECY-91-161. Attachment 3 shows a timeline of the review schedule for these projects.
GENERAL CONSIDERATIONS Effect of the ABWR Review on Other Pro.iects The ABWR review is affecting the other evolutionary and advanced LWR reviews because the ABWR design is serving as the " lead" plant for resolving certain first-of-a-kind issues (inspections, tests, analyses, and acceptance criteria (ITAAC); design acceptance criteria; policy issues). Other applicants and the Nuclear Regulatory Commission (NRC) staff are incorporating the lessons learned from the ABWR review in an effort to improve the efficiency and quality of the other reviews.
In addition, the resource impact of the ABWR review varies because some of the technical branches have finished the review while others are expending many resources on closing issues.
i The unique, interim measures taken during the ABWR review (preliminary draft safety evaluation report (PDSER) and draft final safety evaluation report (DFSER)) are not expected to be taken for the other projects because these interim steps were initiated to facilitate resolution of first-of-a-kind' issues for the ABWR (piecemeal submittals, ITAAC, policy issues).
Certain remaining milestone intervals are assumed to be shorter for the ABWR because these-interim measures have served to resolve many of the issues that will need to be resolved during the more typical review milestone intervals of the i
other evolutionary and advanced LWR projects. Therefore, certain ABWR milestone intervals are not expected to be directly applicable to the other reviews.
Historical Precedent The time between certain milestones has been modified to account for historical precedent and the effect of first-of-a-kind issues.
For example, the vendors have demonstrated the ability to respond to requests for l
additional information (RAls) within 3 months. Therefore, the staff assumed a.
3-month turnaround time to respond to the last of the RAls. However, i
experience with the ABWR and System 80+ reviews has shown that the vendors need more than 4 months to submit the final, verified standard safety analysis report (SSAR) and ITAAC (see Attachment 1). Although the staff and industry r
have learned from the ABWR and System 80+ experience and should be able to improve the time interval necessary to finalize the SSAR and ITAAC, the unique j
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. i and more complex technical issues of the passive designs are expected to counter-balance some of the gains made by this experience. Therefore, the staff has estimated that it will (optimistically) take the passive plant i
vendors 6 months to resolve issues identified in the draft safety evaluation report (DSER) (including the ITAAC) and submit the final, verified SSAR and t
The staff has increased the amount of time to assemble the DSER for the passive LWR designs because it will be addressing unique, difficult topic i
areas.
In addition, these DSERs will include a detailed discussion of the proposed ITAAC and severe accident concerns (the DSERs for the ABWR and System 80+ did not).
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Finally, the time intervals estimated in SECY-93-041 are not based on historical precedent and represent the staff's best estimate for completing the remaining review milestones for the ABWR.
PROCEDURAL CONSIDERATIONS
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In its February 28, 1992, memorandum to R. Fraley, the Commission forwarded new procedures that provide for the public release of SECY papers dealing with t
advanced reactor design issues 3 days after they are issued to the Commission.
This change of procedure has been incorporated into the schedule for the i
evolutionary and advanced LWRs with no impact on the schedules.
Development of the Final Safety Evaluation Report (FSER)
The applicants must resolve all DSER (and DFSER, in the case of the ABWR) open issues in order to prepare the final, certified SSAR. The technical staff is conducting and will continue to conduct intensive meetings with the applicants f
to agree on what is required in the SSAR and Tier 1 document for resolving all of the open issues. Resolution will be agreed on by submitting marked pages of the SSAR and ITAAC. Once resolution is agreed on, the applicants will submit a final, certified SSAR and Tier 1 document, under oath or affirmation, for their' design.
Interactions With Other Oroanizations The inter-relationship of the final reviews of other special groups, offices, l
and participants is discussed below.
Independent Quality Assurance Review f
To resolve possible inconsistencies between the SSAR, Tier 1 information (including ITAAC), and Tier 2 information on the ABWR, the staff.:ill perform an independent quality assurance review. The 6-week review can be accom-plished on schedule only if the review team does not find any significant differences between the SSAP., Tier 1 information (including ITAAC), and Tier 2
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information. The staff will determine the need to perform a similar review on i
the other w olutionary and advanced LWR projects on a case-by-case basis.
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. i Legal Review OGC informed the Office of Nuclear Reactor Regulation (NRR) that it needs I month to review the consolidated FSER. The staff proposed that OGC review portions of the FSER as they are being prepared. To compensate for this staggered review, the staff scheduled OGC's final review of the entire FSER in parallel with the ACRS's review. The comments from this review will be incorporated into the version of the FSER that will be published. This will save approximately 1 month.
In its memorandum of February 22, 1993, 0GC stated that it had no objection to the proposed review procedure, with the understanding that "OGC's final review l
may result in significant problems involving coordination between sections i
being identified which require additional work of the FSER."
ACRS Review As discussed in SECY-93-041, the staff requested that the ACRS accept an advance copy of the FSER for the ABWR review without final approval from OGC l
and the technical editor. The staff also requested that the ACRS complete its i
review of the FSER in 1 month, which is much less than the 3 months the ACRS stated was necessary in its July 18, 1991, letter. The staff expects that the i
ACRS will find only minor problems with the ABWR FSER during this final review because the staff has been interacting with it continually throughout the review and has submitted several versions of the SER for its review.
In its letter of March 18, 1993, the ACRS stated that "it is still our view that three months will be needed to perform a meaningful review [of the ABWR design certification application], given the proposed schedule for transmitting the information to us." is a copy of the letter.
However, the schedule and timeline for the ABWR review provided in this paper assume a 6-week final review period for the ACRS. The staff will work with the ACRS to expedite resolution of its concerns.
The staff has allotted 3 months for the ACRS to complete its final reviews of the other evolutionary and advanced LWR projects.
Issuance of Final Desian Aporoval (FDA1 and Review of Desion Control Document i
E 01
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When the FDA is issued to support design certification, the technical review of the application by the staff and the ACRS ends.
In an SRM of April 21, 1992, the Commission noted that " consistent with the policy of finality reflected in [10 CFR] Parts 50 and S2, once the staff issues an FDA, the staff will be bound by the safety decisions that are rendered in the FDA." There-1 fore, the staff will be able to make changes to the design after the FDA is i
issued only by instituting an analogue rulemaking process.
Although the Director of NRR can legally issue an FDA without staff approval of the DCD, the DCD must be approved by the staff before a rulemaking can begin. The DCD controls the design of all plants that reference the certification. Therefore, the staff needs to verify that the DCD fully i
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t r conforms to the SSAR and FSER, as modified by the requirements of the Office of the Federal Register. Although this verification should not affect the staff's reviews, such a review has not been done before and the staff believes that it should be performed on the ABWR application before the FDA is issued.
Therefore, the staff has allotted time to review and approve the DCD before the FDA is issued. After the ABWR review is completed, the staff will evaluate the lessons learned from that review and determine whether it is necessary to perform the DCD reviews for the other evolutionary and advanced LWR designs before issuing the FDA. For the purposes of estimating the review schedules, however, the staff assumed that these reviews will take place before the FDAs are issued.
f Hearino Schedule The time required for the rulemaking hearings is difficult to estimate without previous experience.
In SECY-92-170, "Rulemaking Procedures for Design Certification," May 8,1992, and SECY-92-381, "Rulemaking Procedures for Design Certification," November 10, 1992, OGC estimated that a hearing could take from 1 to 2 years to complete. As discussed in the November 23, 1992, Commission meeting with OGC on this subject, 18 months is a good estimate of the time to complete the rulemaking hearings and is consistent with the estimate in SECY-91-161.
DESIGN-SPECIFIC ADJUSTMENTS The adjustments that the staff made to the basic schedule assumptions to account for the specific aspects of the projects are discussec below.
Evolutionary Proiect Schedules 1
The staff scheduled the reviews for the evolutionary plant designs (ABWR and System 80+) on the basis of the dates received from the applicants for submitting their final SSAR and ITAAC. With the exceptions noted below, the staff used the assumptions discussed in SECY-93-041 for the scheduling of the reviews of the evolutionary projects.
Resolution of Policy Issues Applicable to Evolutionary LWRs l
The staff discussed policy issues for the. evolutionary LWRs in SECY-90-016,
" Evolutionary Light Water Reactor Certification Issues and Their Relationship to Current Regulatory Requirements," January 12, 1990, and the draft Comis-sion papers, " Issues Pertaining to Evolutionary and Passive Light Water Reactors and Their Relationship to Current Regulatory Requirements," and
" Design Certification and Licensing Policy Issues Pertaining to Passive and Evolutionary Advanced Light Water Reactor Designs," that were forwarded to the..
Comission on February 20 and June 25, 1992, respectively.
In the SRM of June 26, 1990, the Commission gave guidance on those issues l
discussed in SECY-90-016. The final paper consolidating the staff's positions on remaining policy issues that affect the evolutionary LWRs is expected to be issued to the Comission in April 1993. The staff needs the Comission's guidance on these issues before completing the technical reviews for the
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. i evolutionary LWRs. This will ensure that any guidance that departs from the staff's positions can be resolved in a timely manner on these applications.
Review of the GE ABWR The staff's assumptions for the review of the ABWR are discussed in SECY-93-041.
In its March 8, 1993 letter, GE states that it will submit "a final SSAR, verified and reformatted, which will resolve all DFSER outstanding items; a non-proprietary Tier 1 design description; and a complementary integrated set of ITAAC," by July 31, 1993. The staff assumed that discussions and marked-up page changes of the SSAR and the ITAAC will be submitted before the July 1993 submittal to ensure GE has satisfactorily resolved the outstanding issues before submitting its final SSAR and ITAAC.
Because the staff assumed that the July 1993 submittal will reflect the resolution of all Tier 1 and ITAAC outstanding items as well as the design-l related outstanding items in the DFSER, it allocated no time in the timeline of SECY-93-041 for the Tier 1 and ITAAC review.
t The staff has adjusted the schedule to accommodate those portions of the review that will occur at the end of December 1993 to account for the impact caused by the holidays. However, interim milestones for the DCD review and FDA development have been adjusted to ensure that the overall completion schedule will be met in accordance with the time intervals of SECY-93-041.
Review of the ABB-CE System 80+
With the exceptions noted below, the staff used the same milestones discussed in SECY-93-041 in developing the schedule for the System 80+.
In its February 2, 1993 letter, ABB-CE indicated that it will submit the updated SSAR and ITAAC by April 1993. However, certain milestones in the February 1993, letter were not met on schedule. The letter further indicated that additional information concerning source term, structural, and seismology issues will be provided by June 1993.
Therefore, the staff assumed that all information necessary for it to develop its FSER will be available by July 1,1993, because of the uncertainty associated with these concerns. The staff concludes that it will take longer to develop its FSER on the. System 80+ than on the ABWR because there are more issues in the DSER on the System 80+ than in the DFSER on the ABWR, and because it is just beginning its detailed review of the ITAAC. Additionally, as discussed above, the ACRS will require 3 months to complete its review of the System 80+.
Although the GE ABWR and ABB-CE System 80+ FSER. schedules overlap, the technical review staff consists of generally different personnel, with the overlap occurring mainly at the management review level. However, the milestones are sufficiently apart to allow adequate management review.
1 Passive Proiect Schedules In SECY-91-161, the staff estimated the review schedule for the AP600 and the SBWR on the basis of the applicants' proposed schedules provided in early I
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. 1991.
In making these initial schedule estimates, the staff assumed that it would receive complete applications by June 1, 1992, and August 3, 1992, respectively.
In SECY-90-146, " Process, Schedule, and Resources for the Review of Evolutionary and Passive Advanced Light-Water Reactors," April 20, 1990, the staff stated that it had determined from the experience gained from the review of the ABWR and EPRI Requirements Document that a modular review approach was inefficient and was not desirable for future reviews. Therefore, it stated that it would not begin the passive LWR design certification reviews until it received a complete application.
The staff reiterated this proposed approach to the review process in the enclosure to SECY-91-161 and in SECY-92-120, "NRC Staff Review Schedales for the Westinghouse AP600 and the General Electric Simplified Boiling Water Reactor Designs," April 7, 1992.
In addition, the staff continues to endorse its recommendation in SECY-91-210, " Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Requirements for Design Review and Issuance of a Final Design Approval (FDA)," July 16, 1991, that the review and approval of ITAAC be completed before an FDA is issued. The staff's review of the evolu-tionary designs has demonstrated the importance of performing the ITAAC and design reviews concurrently.
The staff used the assumptions of SECY-91-161 and SECY-93-041 as the basis for the schedule estimates for the passive LWR projects and modified these assumptions as discussed below.
Resolution of Policy Issues - Passive LWRs The staff discussed policy issues for the passive LWRs in the draft Commission papers, " Issues Pertaining to Evolutionary and Passive Light Water Reactors and Their Relationship to Current Regulatory Requirements," and " Design Certification and Licensing Policy Issues Pertaining to Passive and Evolutionary Advanced Light Water Reactor Designs," that were forwarded to the Comission on February 20 and June 25, 1992, respectively.
The resolution of the issue pertaining to the regulatory treatment _ of non-safety active systems (RTNSS) is the critical path for the passive design reviews.
Depending on the resolution, this issue has far-reaching implications for the designs.
In its December 15, 1989, SRM, the Comission instructed the staff to resolve policy issues through the review of the EPRI ALWR Utility Requirements Document. The staff is working with EPRI to resolve this issue. However, without knowledge of the final resolution, the effect of this issue on the schedule for the passive LWRs is difficult to predict.
The final paper consolidating the staff's positions on this and related policy issues that affect the passive LWRs is expected to be issued to the Comission in May 1993. The staff needs the Comission's guidance on these issues before completing the technical reviews for the passive LWRs. This will ensure that any guidance that departs from the staff's positions can be resolved in a timely manner on these applications.
. Review of the EPRI ALWR Utility Requirements Document The staff has scheduled the review of the EPRI ALWR Utility Requirements Document to be completed first because the allotted time falls within the window of opportunity before submittal of the final SSARs and ITAAC by the ABWR and System 80+ applicants.
EPRI has addressed all of the issues identified in the DSER.
Evaluation of its proposal to address the RINSS issue is expected to be completed in a timeframe (May 1993) to support issuing the FSER on the schedule projected for this project. However, the schedule for issuing the FSER may be delayed if the Commission provides guidance that differs from the staff's position.
Completion of this project will release resources to work on other evolu-tionary and advanced LWR projects. This review will be completed within 2 months of the schedule given in SECY-91-161.
Review of the Westinghouse AP600 The staff accepted the AP600 application for docketing on December 31, 1992.
It has been issuing RAIs where sufficient information and resources have been available. However, the staff has delayed the end date for issuing the RAls to accommodate availability of resources in certain technical areas.
The staff is ensuring that its review of test information required for design certification is being performed to support the applicant's test schedules, now expected to be completed in early 1994. The staff will not be able to address the results of all of the tests in the DSER because of the test schedules. However, the tests are expected to be finished in time to be reviewed and addressed in the FSER.
Review of the GE SBWR GE submitted a supplement to the SBWR application on March 1, 1993, to respond i
to the staff's initial acceptance review (see SECY-92-403, " Acceptance Review of GE Nuclear Energy's Application for Final Design Approval and Design Certification of the Simplified Boiling Water Reactor Design," December 3, 1992). The staff has delayed completion of its acceptance review until May 1993, because of the resources being applied to the ABWR.
In addition, the period for developing the RAls has been adjusted to account for its overlap with the ABWR review because many of the technical review staff are the same for the two projects. The SBWR schedule was adjusted to prevent interference with the ABWR schedule and represents the earliest dates that could be met should the staff find the application acceptable during the acceptance review.
The staff understands that testing required to support design certification of.
the SBWR will be completed in early 1994. The staff will ensure that it will review this test information on ' schedule that will support the applicant's test schedules.
Depending on the completion dates, the staff may be able to address the tests in the DSER. Nevertheless, the tests are expected to be finished in time to be reviewed and addressed in the FSER.
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FACTORS THAT COULD ADVERSELY AFFECT THE SCHEDULES The design certification reviews are the first'of their kind, for which many of the assumptions are best estimates that are not supported by historical precedent. The staff assumes that all open items will be resolved before the final SSARs and ITAACs are submitted.
It believes that it must review the ITAAC while considering the results of the design-related review (including severe accident considerations and the resolutions of issues discussed in SECY-90-016).
i The staff will dedicate individuals to perform a thorough review of the information to be submitted by the applicants to resolve open issues. The i
reviews will require high-quality, timely, and consistent information in the i
various documents associated with the application. Assumptions have been made i
regarding external forces that are not controlled by NRR (schedules that must i
be met by the applicants, ACRS, and OGC).
These aggressive schedules are optimistic and have no margin for slips.
However, any perturbation could cause them to slip.
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ATTACHMENT 1 KEY MILESTONE INTERVALS FOR THE EVOLUTIONARY AND ADVANCED LWR SCHEDULES Months SECY-Milestone 91-161
[PRI ABWR Sys. 80+
AP600 SBWR RAls to PM 4
C C
C 6*
7*
PM issues RAls 0.5 C
C C
0.25 0.25 Applicant Responds 4
C C
C 1
3 to RAIs t
i DSER to PM 4
C C
C 5
5 PM Prepares DSER PM Prepares DSER (in-S**
C C
C 2
2 cluding chapter-by-chapter edit & OGC review)
DSER to ACRS/ Commission 2
C C
C 1
1 DSER to Applicant 0.5 C
C C
0.1 0.1 Applicant Responds to 4
C 9
9 6
6 DSER (final SSAR &
ITAAC update submitted) e FSER to PM 4
- 7. 5***
1.5 4
4 4
PM Prepares FSER PM Prepares FSER (in-S**
2 2
2 2
2 cluding chapter-by chapter edit & OGC review)
FSER to ACRS/ Commission 2
1 1
1 1
1 i
FSER to Applicant 0.5 0.1 0.1 0.1 0.1 0.1 ACRS Review (with con-2 3
1.5 3
3 3
current integrated editorial & OGC review)
Commission Decision 1
1 1
1 1
1 FSER' Issued for 0.5 0.25 0.5 0.5 0.5 0.5 Publication C= complete; S= simultaneous review I
End date chosen to accommodate resource availability.
Simultaneous review projected in SECY-91-161.
Delayed because of policy issue resolution.
1 Page 1 of 2 I
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KEY MILESTONE INTERVALS FOR THE EVOLUTIONARY AND ADVANCED LWR SCHEDULES (CONTINUED)
Months SECY-Milestone 91-161*
EER1 ABWR Sys. 80+
AP600 SBWR DCD Submitted by N/A 0.5" 0.5" 0.5" 0.5" Applicant Staff Drafts FDA &
N/A 0.75 1
1 1
ER Notice FDA & EB Notice N/A 0.50 0.75 0.75 0.75 Issued Staff Drafts Proposed N/A 0.5"*
- 0. 5*"
0.5"*
- 0. 5*"
Rule Commission Review of N/A 0.5 0.5 0.5 0.5 Proposed Rule Proposed Rule & F.R.
N/A 0.1 0.1 0.1 0.1 Notice Issued i
i P
i b
N/A=not applicable.
l These steps were not included in the SECY-91-161 schedule assumptions.
The DCD will be submitted 2 weeks after the FSER is published.
Development by the applicant is expected to have taken place throughout the period when the FSER is being developed.
Two-week period reflects time after the FDA and Federal Reaister notice are issued. Development.of the proposed rule is expected to have taker place throughout the development of the FDA and Federal Reaister notice.
Page 2 of 2
ATTAtliMENT 2 COMPARISON OF REVISED SCHEDULES WITH THOSE OF SECY-91-161 EPRI Passive GE ABWR CE System 80+
W AP600 GE SBWR i
i i
i i
SECY-SECY-SECY-SECY-SECY-i i
Milestone 91-161 ! Revised 91-161 Revised 91-161! Revised 91-161 Revised 91-161 Revised Receipt of Appl.
9/90 9/90C 3/89 3/89C 4/91 4/91C 6/92
!12/92C 8/92 3/93 RAls to PM 6/91
!10/91C 12/90 12/90C 10/91 10/91C 10/92
!? : 6/935-12/92 h 1' /93 -
0 l10/91C l 12/90C l 10/91C l:
l::
RAIs Issued to Applicant 6/91 1
12/90 1
10/91 1
10/92 6/93-12/92
- 10/93 Policy Paper to l!
h h.
l 5/93; ll Commission /ACRS 9/91
!, ; 5/93-3/91
!, ~ 14/93 3/91 4/93' 9/92 11/92
- t. y S/93 Applicant Responds l
l 10/91C l
l I;
to RAls 10/91 1/92C 7/91 2/92 2/92C 2/93 t'
9/93-4/93 1/94-DSER to PM 2/92 3/92C 8/91
!10/910 6/92 9/92C 6/93 h 2/94 8/93 l
6/94 DSER to Comm/ACRS 4/92 4/92C 9/91
!10/91C 8/92 9/92C 8/93
!L5/94L 11/93 l-9/94 DFSER to Comm/ACRS 10/92C L
- 1.
ls' '.3/95[
Applicant Responds to DSER (DFSER -
9/92 9/92C 2/92 17/93 1/93
!7/93:
1/94 L12/94 3/94 ABWR only)
L-FSER to PH 4/93
!i L4/93 6/92 h!9/931 5/93 li11/931 5/94 l c4/95 8/94
!!07/95-i in i
7 FSER to Conn /ACRS 6/93
!? #7/93i 8/92
!B12/93' 7/93 2/941 8/94 L7/95 10/94
!'10/95 T
T E
I FSER Issued for E
h E
I!
h l!11/932 12/92 3/94(
11/93
! T6/944 11/94
!L11/95 1/95 l L3/961 3
Publication 9/93 FDA/B Notice h.
l.
I'1/96-l 5/96-Issued 12/92 l-5/94-11/93 8/94#
11/94 l
1/95 l-t 8-t I
t-Rule /B ti,otice l
U..
l :. 2/96 '
l ?6/96 l<
Issued 6/94L-l ; 9/94?
[ This step not included in the SECY-91-161 schedule assumptions.
Interim step for ABWR review only - this step not included in the SECY-91-161 schedule assumptions.
Shaded [ dates-milestonestobecompleted u
m E
w 4
e m
.. m-
ATTACllMENT'3
^
TECHNICAL REVIEW SCHEDULES FOR EVOLUTIONARY AND PASSIVE LWR REVIEWS KIN ! l I ! 1[l2! IIIII'! l'! l'! ! I l'! I f! ! !-I ! ! ! ! ! l'!!!_ ! !"! Fl'!'! !0 i!!!!!?!l-!kI!2I'!hi'!!!!.lI! Il ! !'f !!O'! is !! ! !-!i lll'! [_j ! [{] ! P
^
I/93 2/93 3/93 4/93 5/93 6/93 1/93 8/93 9/93 10/93 11/93 12/93 1/94 2/94 3/94 4/94 5/94 6/94 1/94 e/94 9/94 16 F5tR F5ER to F5tR to to PM Come/ACRS Applicant EPRI Req. Dec.
k!I!2!!!!!I!!!Il$N!l!!!!!!!!!!! !!!!!!!!!!!!!!!!! l FDA/FR Bule/TR 55AR F5tR F5ER (Adv. Copy)
F5ER Motice Notice Update to PM to Coom/ACR5 Published Issued Issued RpWR e
! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! l ?!!!!U!:l_l ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! l FDA/FR Rule /FR 55AR F5tR F5tR (Adv. CePy)
F$tt Motice Motico Update to PM to Conse/ACR$
Published Issued Issued System 80+
I ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! l_! !Il ![!!I.}Ill! ! ! ! ![IIl ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !
RAls W Responds CSER OSER to to PM to RAls to FM Cona/ACR$
AP600 lf!?!1tTf !11%!JIIf I?!1!.l ! ! ! ! ! ! ! ! ! ! ! ! l._! ! 13 til ! !'! 13 !J El 111_!.l ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !..
RAls GE Responds Dsta OstR to to PM to RAls to PM Cosm/ ACES Shm b!"!-1.1 l'!$! ![! ! !?! I"! ! ! ! !'l !_ l' l'! l 1.1 l.!'! l'! ! l ! ! ! ! ! ! ! ! ! ! ! ! l i 1:1 ! l !_ ! t'l 1-!'! l l'! l'! ! ! l ! ! ! ! ! ! ! ! ! l ! l!!!!
l!!11!!! !- 1 !c! l !'1!'!'imf!! !1;f '!'! !2!>!!!;l !*!'!!!it '! '! t1 i'i'! ! !-! _! ! !'!:_l'!!! 111T!'!11:! 1 !1! ! l'td F1 i ! ! !i t ! !;! ! ! ! 1:1 d ! !U t!_! ! !!!]
i 4
1 1
11 T
1/93 2/93 3/93 4/93 5/93 6/93 1/93 8/93 9/93 10/93 II/s) 12/93 1/94 2/94 3/94 4/94 5/94 6/94 1/94 8/$4 9/94 10/94 Page 1 of 2
+.
O 9
TECHNICAL REVIEW SCHEDULES FOR EVOLUTIONARY AND PASSIVE LWR REVIEWS (CONTINUED) kl.! ! l.1 ! ~l tilll'.! l d!!!!IN51. I I-N i lll! ! l11 ! I l_Ildlil13 !!!$.l-.! ! !$11!.lS!!!-!$l l'l'l l _l'i'l MJ11I!N !I11!l! l..lil !!!ll l'11,LII N It'IM
~~
~
~
I I I
_' ~
10/94 11/94 12/94 1/95 2/95 3/95 4/95 5/95 6/95 1/95 8/95 9/95 10/95 ll/95 12/95 1/96 2/96 3/96 4/96 5/96 6/96 FDA/FR Rule /TR SSAR F5tR F5tR (Adv. Copy)
F5tR Notice Mottco Update to PM to Comm/ACR5 Published issued Issued 313II}$!'f!!![11211fl!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !!!!!!!l I
5 AP600 FDA/FR Rule /TR 15AR F5tR F5tR (Adv. Copy)
F5tR Notice Notice Update to PM to Cens/ACR5 Pubitshed Issued issued
! ! ! ! ! ! ! I' ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !.'l ! l_ l!'l ~! !.l:1[l'!.Illt. l ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! ! !!!!!
~
[1_Ul lihrif illdi'lf]Oll?L12]Il l'1 t l ill!!?!'_l'lil'!!'lil't !'l'l'l I li_!Il_lIlil'll!'! O l[I liisl[Il'l.!bt !; dbl'IM115 Ni'!Md f
i h ! fl.13 Il i
i l
I t-10/94 11/94 12/94 1/95 2/95 3/95 4/95 5/95 6/95 1/95 8/95 9/95 10/95 !!/9b 12/95 1/96 2/96 J/96 4/96 5/96 6/96
.... mi Page 2 of 2
ATTACHMENT 4
[...
c UNITE D ETATES P
3, g
NUCLEAR REGULATORY COMMISSION 2
.t ADVISORY COMMITTEE ON HEACTOR SAFEGUARDS o,
I w ASHINGTON. D. C. 20556
/
March 18, 1993 The Honorable Ivan Selin Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Chairman Selin:
SUBJECT:
ADVANCED BOILING WATER REACTOR (ABWR) REVIEW SCHEDULE During the 395th meeting of the Advisory Committee on Reactor Safeguards, March 11-12, 1993, we discussef +he staff's revised estimate of the schedule (proposed in SECY-96,.al) for completing its review of the ABWR design.
We also had the benefit of the documents referenced.
We note that in SECY-93-041, the time proposed for our review of the Final Safety Evaluation Report (FSER) is one month.
In our July 18, 1991, report to you on " Schedules for Advanced Reactor Reviews," we agreed with the staff's estimate of three months for completing cur review of the FSER.
It is still our view that three months will be needed to perform a meaningful review, given the proposed schedule for transmitting the information to us.
Regarding our present ABWR review status, our work on the ABWR design certification application stalled in November 1992, pending the development of additional technical information by General Electric Nuclear Energy (GE) and decisions by the NRC staff on a number of important areas such as:
)
design acceptance criteria / inspections, tests, analyses and e
acceptance criteria, digital control systems, control room and human factor provisions, and severe accident /probabilistic risk assessment considerations j
interface requirements and representative conceptual designs e
for uncertified portions of the design technical resolution of Unresolved Safety Issues and Generic e
Safety Issues as required by 10 CFR 52.47 closure of open and confirmatory items in the October 1992 e
draft of the FSER
7 The Honorable Ivan Selin 2
March 18, 1993 e
closure of open items and concerns from the ACRS Advanced.
Boiling Water Reactors Subecmmittee meetings of August 19, October 21, and November 18-19, 1992 Our subcommittee meetings with the NRC staff and GE vere, in general, limited to consideration of the October 1992 draft of the FSER and the initial submittal and first twenty amendments (through March 13, 1992) of the ABWR Standard Safety Analysis Report (SSAR).
We have not met with the staff or GE on these matters since November 1992, although we have planned a subcommittee meeting on severe accidents on March 18, 1993.
We will meet again to complete our review when the staff and GE provide us with reasonably complete final documentation for our consideration.
There are now several additional voluminous amendments to the SSAR to consider, and extensive revision of the FSER is likely.
From the nature of past ACRS open items and concerns on the ABWR and the uncertainty concerning their resolution, we believe that significant problems may still persist.
If it would expedite the schedule, we would be willing to meet with the staff and GE to review portions of the final FSER and associated SSAR beyond Amendment 20 as they are completed and made available.
This would ensure a more timely resolution of any remaining concerns and could shorten the three months otherwise needed for our review of the advance copy of the complete FSER package (referred to in SECY-93-041) and preparation of our final
. report required by 10 CFR 52.53.
Sincerely, Paul Shewmon Chairman
References:
1.
Letter dated February 9, 1993, from Dennis M.
Crutchfield,
- NRR, to Paul
- Shewmon, Chairman,
- ACRS,
Subject:
Review Schedule for the Advanced Boiling Water Reactor (ABWR) 2.
SECY-93-041, dated February 18, 1993, for the Commissioners from James M.
- Taylor, Executive Director for Operations,
Subject:
Advanced Boiling Water Reactor (ABWR)
Review Schedule