ML20055F144
| ML20055F144 | |
| Person / Time | |
|---|---|
| Issue date: | 06/13/1990 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9007130344 | |
| Download: ML20055F144 (4) | |
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N0TATI0N y.o u.................
nacASED TO THE PDR RESPONSE SHEET! 7f///9 T0:
SANutt J. CHILK, SECRETARY OF THE CONMIssION FROM:
COM4ISSIONER CURTISS
SUBJECT:
SECY-90-016 - EVOLUTIONARY LIGHT WATER REACTOR (LWR) CERTIFICATION ISSUES AND THEIR RELATIONSHIP TO CURRENT REGULATORY REQUIREMENTS x
x APPROVED in part DISAPPROVED in part ABsTAII; NOT PARTICIPATING RE0utsr Discussion COM4ENTS:
See attached comments.
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SIGNATURE RELEASE VOTE
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6/13/n DATE WITHHOLD VOTE
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ENTERED'ON "AS" Yes /
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Commissioner Curtiss' comments on SECY-90-016:
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As discussed below, I approve in part and disapprove in part the staff's proposed positions on the Evolutionary LWR Certification
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issues addressed in the subject SECY paper.
Additionally, I concur in the recommendation of the Chairman that in those cases where the staff proposes to go beyond current regulatory requirements, consideration should be given to incorporating these requirements into our regulations.
In this regard, I look forward to receiving the paper which the Commission previously directed the staff to prepara on this issue (see SRM dated May 22, 1990).
Finally, I would encourage the staff to strive to sustain the level of attention and resources that have been devoted recently to the review process for the EPRI requirements document.
The recent comments of the EPRI representatives at the June 4, 1990 Commission briefing suggest that such a commitment, if sustained, can be most beneficial in assisting EPRI and the NRC staff in our respective efforts to reach a common understanding on the key technical issues.
General Issues A.
ALWR Public Safety Goal I disapprove.
I agree with the Chairman's comments.
B.
Source Term While I approve the staff's current approach, I would encourage the staff to expedite development of aa updated, standardized approach to source term based upon source term research results.
In this regard, I agree with the Chairman's comments.
Preventive Feature Issues A.
ATWS L
I agree with the ACRS that a demonstration that a given L
plant design can survive an ATWS with acceptable consequences should be an acceptable alternative to diverse scram logic.
Further, the staff should yetain the flexibility to accept designs with non-diverse scram logic in those instances where it is demonstrated to the staff's satisfaction that the reliability of the scram function is such that the risk attributable to ATWS is insignificant.
B.
Mid Looo Ooeration I approve the staff's position, subject to incorporation of
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the ACRS's recommendations.
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Station Blackout I approve the staff's position and agree with the chairman that the staff should clarify what is meant by
" diverse".
In my view, that clarification should focus on limiting common mode failure potential, but need not go so far as to require completely different generator driver 3
technologies (jtcat should not necessarily require both diesel-and gas turbine-driven generators where diesels and associated auxiliaries of diverse design, coupled with the procurement of fuel from diverse suppliers, may suffice).
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Fire Protection l
I approve the staff's position, as supplemented in the April 27, 1990 memorandum from the EDO to the Commission providing the staff's response to ACRS conclusions regarding evolutionary light water reactor certification issues.
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Intersystem LOCA I agree with the Chairman's comments.
l Mitigative Features Issues I
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Hydrocen Generation and Control l
I approve the staff's position, but encourage the staff to continue to evaluate available information, including that provided by EPRI, to reduce the uncertainty associated with hydrogen detonability and to permit any warranted deviations from the requirements of 10 CFR 50.34 (f) (2) (ix).
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B.
Core-concrete Interaction - Ability to cool core Debris Pending the completion of confirmatory r'esearch in this area, I approve the staff's proposed approach.
C.
Hiah Pressure Core Melt Eiection I agree with the Chairman's comments.
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D.
Containment Performance As discussed in my vote on SECY-89-102, I approve the use of a 0.1 CCFP for e volutionary designs subject to the followings o
The containment performance objective should be used to judge the adequacy of containment design requirements but should not be imposed as a requirement in and of itself.
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o The CCFP should not be applied in such a manner as 1
to discourags accident prevention.
o The staff should accept suitable alternative, deterministically-established containment j
performance objectives providing comparable mitigation capability.
E.
ABWR Containment Vent Desian I agree with the Chairman's comments, F.
Eculement Survivability I approve the staff's position.
Non-Severe Accident Issues A.
ODeratina Basis Earthauake / Safe Shutdown Earthauake I approve the staff's position.
B.
Inservice Testino of Pumos and Valves I approve the staff's position, as supplemented in the April 27, 1990 memorandum from the EDO to the Commission providing the staff's response to ACRS conclusions regarding evolutionary light water reactor certification issues.
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