ML20055F274

Presents Options for Commission Consideration Re Implementation of Provisions of 10CFR52 That Address Level of Design Detail.Guidance Requested on Issue

ML20055F274
Person / Time
Issue date:	07/11/1990
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
FRN-53FR31462, FRN-55FR31462, RULE-PR-52, TASK-PINV, TASK-SE SECY-90-241, NUDOCS 9007160186
Download: ML20055F274 (33)

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POLICY ISSUE July 11, 1990 (Notation Vote)

SECY-90-241 For:

The Commissioners From:.

James M. Taylor Executive Director for Operations

Subject:

' LEVEL OF DETAll REQUIRED FOR DESIGN CERTIFICATION UNDER PART 52

Purpose:

To present options for Commission consideration regarding the _implementction of the provisions of 10 CFR Part 52 that address the level of design detail.

The staff requests Commission guidance on this issue.

Background:

On liay 18, 1909, the Commission issued a new rule, 10 CFR Part 52, that provided for early site permits, certified standard designs, and combined construction permits and operating licenses. The intent of Part 52 in providing for the review and licensing of rtandard designs is to reform the licensing process by effecting early resolution of safety issues and to enhance the safety and relictility of nuclear power plants through standardization.

In the April 27, 1990 Commission meeting, the issue of the level of detail required by Part 52 was discussed briefly.

Af ter the sneeting, Staff Requirements Memoranda were issued which directed the staff to present a paper examining the level of detail required by Part 52 to facilitate design certification of en essentially complete design.

In response, the staff examined the requirements of part 52 and discussed the subject with industry representatives.

The staff is presenting the Commission with four levels of design deteil in this paper. Our objectives are to present the technical and regulatory considerations pertinent to actions that might be taken by the applicant and the NRC NOTE:

TO BE MADE PUBLICLY AVAILABLE WHEN THE FINAL SRM IS MADE CONTACT:

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at each level. The level of detait associated with a design certification can be considered in terms of three i

c variables: (1) the contents of an application for design i

J certification, (2) the material to be developed by the applicant and made available for audit, and (3) the

'j information certified by rulemaking.

Part 52 is clear regarding the scope of an application for design certifi-i cation stating that, with some exceptions for reactors of i

advanced design, "Any person may seek a standard design i

certification for an essentially complete nuclear power plant design..." An essentially complete design includes all structures, systems, and components which can affect safe operation of the plant except for site-specific elements such as the service water intake structure and l>

the ultimate heat sink." Accordingly, scope is not addressed in this paper.

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Discussion:

A.

DESIGil DETAIL IN A CERTIFICAT10t! APPLICATION

-l Section 52.47(a)(1) requires that an application for a O

design certification include a level of detail that would J

satisfy the regulatory requirements for technical informa-tion in an FSAR, except'to the extent that particular requirements are technically. irrelevant or site specific.

Section 52.47(a)(?) addresses level of detail from three perspectives.

First, the level of detail must permit NRC to rrech a final conclusion on all safety questions associated with the design befare certification. Second, the level of detail must be such to allow the applicant's proposed means of assuring that-construction conforms to the dcHgn. The staff believes this, in conjunction with other provisions of Pcrt 52, to require and define the l

purpose of inspections, tests, analyses, and acceptance criteria (ITAAC).

Third,Section52.47(a)(2)requiresa invel of detail in the application such that the application itself would contain sufficient information to permit the preparation of procurement and construction and installation specifications.

The staff believes this provision should be y

met without recourse to significant additional design engineering.

The staff reads this to require, for example, that ranges of values for analyses and tolerances for j

structures, systems and components be provided in the application.

B.

DESIGNDETAILTOBEAVAlfABLEIFREQUESTEDBYNRC Section52.47(a)(2)requiresthatinformationnormally conteined in certain procurement and construction and i

installation specifications be available *or audit if the NRC needs to review the information in order to make a safety finding.

The staff reads this to require a level of detoil (e.g., value ranges and tolerances) refined beyond thtt included in the application.

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DESIGN DETAIL IN THE CERTIFICATION The rule indicates the information required to be in ar application and to be developed and available for auditi it is, however, silent on the level of design detail that is to l

be a-part of the certification itself. On this point, the S~

Statements of Consideration says that "just how much [ design detail]ispresentwillbeanissuewhichwillhavetobe

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resolved in each certification rulemaking. The Commission does expect, however, that there will be less detail in a certification than in an application for ccrtification, and that a rule certifying the design is likely to encompass roughly the-same design features that Section 50.59 prohibits changing without prior NRC approval." The information. pre-sent in a design certification will control the degree of y

standardirttion that can be achieved at the design certifi-L cation stage.

Some of the information contained in an application for design certification may represent commer-l ciel, proprietary information.

If information of this type l

is included in the certification, the material will no longer be considered proprietary; instead it becomes part of the NRC's public requirements. Thus decisions.about level of i

detail in the certification itself could have important l.

consequences for the commercial value-of vendor design i

information.

D.

ITAAC L

The applicant must develop) inspections, tests, analyses, and L

acceptance criteria (ITAAC and submit them for staff review as specified in Part 52.47(a)(1)(vi).

ITAAC will provide reasonable assurance that a plant which references the design l

is built and will operate. in accordance with the design certification.

ITAAC are not a design tool to be used in lieu of the detailed information needed to satisfy the i

requirements for an application, as discussed above. The subject is discussed further in the enclosure to this paper.

E.

POLICY ISSUE REGARDING "TWO-TIERED" CERTIFICATIONS One other policy issue that is closely tied to the issue of level of design detail is whether the Commission should accept the "two-tiered" approach proposed by industry for design certification.

In this approach, the top tier certified design would include essential safety performance criteria that, once certified, could only be changed by the receiving of an exemption through 10 CFR 50.12. A second tier of material would include more detailed design infor-netion. This second tier would be associated with the rule certify)ing the design (but not be part of the ccrtification itself and woulo include a change process like the current 10 CFR 00.59, that would allow changes without prior NRC reviw so long as no unreviewd safety question is presented.

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except under 10 CFR 2.750 or to the extent the design is changed after the rulemaking under the Section 50.59 flexibility provisions.

The constraints on backfitting and other provisions of Part 52 intended to foster stan-dardization would not apply to the design approved in O

Tier 2.

Although the two-tiered concept is presented in this paper in conjunction with the industry approach (Level 3), it may be applied to any of the options.

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F.

THE FOUR OPTIONS FOR LEVEL OF _ DESIGN DETAIL The rule as promulgated allows for interpretation that could lead to a different body of information in each certification resulting in varying degrech of standard-i ization.

The more specific the engineering detail embedded in the design certification rule is, ;he greater the degree of standardization for that design.

The staff has examined four levels of detail, the corre-sponding degree of standardization achieved, compliance with Part 52, and the safety and economic benefits derived from each. The staff discusses each of these levels in the next few pages. These levels are merely examples of the level of detail that can be included in the application and the degree of standardization that can be achieved through-the certifi-cation process and are not necessarily the only options available to the Commission under part 52.

It is not clear that the design detail necessary to realize a Level 1 degree

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of standardization is consistent with Part 52 regarding the i

content of the application.

Notwithstanding a rule change to Part 52, the first level is probably not commercially

' feasible, because the level of detail required in a Level I certification would make it difficult to assure continued availability of components with all the certified attributes L

over the life of ;crtification.

Level 2 provides the maximum 1

degree of standardization while avoiding to some extent the aforementioned concern. The third level of detail presented l

characterizes the industry proposal (incorporating the two-tiered approach) as the staff understands it.

NUMARC are the only ones who can speak definitively on their position.

The fourth level of detail (product-line standardization) would not constitute an acceptable applica-tion for design certification under the current provisions of Part 52, because it is not sufficient to allow the staff 7

to reach its final conclusion on all safety issues in a one-step process.

However, it is provided to exemplify a r

level of detail and standardization achieved under the Part 50 process.

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In Lnels 1, 2, and 3, the content of the application in terms of infornation germane to our safety findings is the l

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same; however, the scope and desth of detail required for Levels.1 and 2 will be beyond wiat the staff has tradition-

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ally needed to conduct licensing reviews under NUREG-0800 theStandardReviewPlan(SRP). This greater level of detail will_ be provided for the sake of standardization.

To the extent the greater level of detail is approved by rule in the certification process, there is also an earlier resolution of any safety issue associated with the design.

Staff licensing review of an application for design certi-fication for all levels will deviate somewhat from tradi-i tienal practice, with the addition of the ITAAC, and in i

Levels 1 end 2, the standardization portion of the review l 1

as well. Additional guidance will have to be developed to support staff review. Information normally contained in procurement specifications and in construction and instal-lation specifications and audited will be included or referenced in the application for a design certification if it is necestery for the staff to make its safety findings.

In Levels 1 and 2 essentially the entire application will be certified.

In Level 3 the design certification will contain much less detail than provided in Levels 1 and 2, l

plus the rulemaking approval of Tier 2 along with the l

industry-proposed Section 50.59-type change mechanism.

Using the HVAC system as an example, Table 1 shows how much detail we would expect for each of the four levels.

LEVEL 1 The degree of standardization resulting fron this level of detail and the certification process will provide identical physical, functional, and performance characterid it@cf all structures, systems and components except for site specific characteristics.

In the Applic6 tion l

The application trust satisfy the requirements of 10 CFR 52.47(a) and (b) (invoking Parts 20 50,73,and100) andmustprovideresolutionsforthetechnIcalissuesdis-cussed in SECY 90-016. The depth of design detail in the application for design certification will be all the infor-mation contained in a completely designed plant. This includes' procurement specifications as well as construction and installation specifications for all structures, s and components (not including site-specific details) ystems, appro-pritte for soliciting fixed-cost construction bids. The design could be advanced through the procurement specifica-tion stage for all plant equipment.

In some cases these procurement specifications will need to be more detailed and specific than is current practice to be at.le to ensure thtt the georctries, as well as the capabilities, of

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components are within specified ranges. The application will contain, for example, performance characteristics for ell systems and their components; exact piping routing and support details for all systems; 'and physical location, characteristics, configuration, and orientation for all components on those' systems.

In other words, for all pumps on all systems not site related, the type (positive displacement or centrifugal), location, and pumping capacity' and head will be specified, as well as the exact locations of the inlet and outlet nozzles, weight, size, shape, and mounting / supporting details.

If information.obtained'during the Staff r.' ".s question and answer process forms the basis for. J e

..Ndgment or contributes to standardization, it < li 4 at..ided in the application.

Available for Audit Information normally contained in procuic w specifications and in construction and insta..etion speci-fications will be included in the application. Therefore, audits should not be necessary,

,In the Certification The design certification will include essentially all of the material in.the amended application, including the ITAAC,

-necessary for the staff to (1) determine design acceptability, (2) ensure design criteria and. performance requirements are satisfied (3) make a safety (determina' tion, and (4) ensure total plant standardization minus site specific aspects) and its resulting safety benefits, pemarks To ensure that future plants will have identical physical, functional, and performance characteristics, the design will be developed and certified to a level of detail that includes all engineering data for a completely designed plant except for that data relating to site specifics.

The application and design certificttion process will drive the design development and solidify it to a point where total plant standardization (except for site specifics) is achieved.

As previouly stated, certain procurement specifications will have to be note detailed than is current practice.

In some instances vendors may have to custom build such com-ponents as pumps, to fit the specifications. To require this much design detail is the most costly (greater than

$600 million), initially, and may discourage NSSS vendors fron entering the market; however, this much design detail wil' also result in more accur6te determination of cost to the customer (utility).

Certifying this itvel of detail i

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• i provides the greatest regulatory stability (protection against unwarranted backfits) and early and final resolution of issues through design certification.

Unavailability of-specific components, resolution of construction deviations, and instances of highly desirable upgrades in technology

'that would provide equivalent or improved functionality or i

reliability can only be accommodated to a very limited extent through the granting of an exemption to the rule certifying the design via 10 CFR 50.12. The application will include a substantial amount of information beyond that traditionally needed to conduct a licensing review in F

accordance with the SRP.

Staff review will deviate'signi-1 ficantly from traditional practice, with the addition of the-ITAAC and standardization portiens of the review. Additicnal I-staff guidance would need to be developed to support the i

review of this information.

Because the level I status of design may exceed the requirements of Part SP, changes to the regulations would need to be considered were this option r

selected.

i LEVEL 2 The degree of standardization resulting from this level of detail and the certification process will provide physically similar, and identical functional and performance charac-teristics of all structures, systems, and components affecting safety, except for site specific characteristics.

In the Application The application must satisfy the requirements of 10 CFR 52.47(a) and (b) (invoking Parts 20,50,73,end100) as well as provide resolutions for the technical issues discussed in SECY 90-016. The depth of design detail submitted in the application for design certification will be similar to that of a final safety analysis report (FSAR)attheoperatin

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' licensed (1989 - 1990)g license (0L) stage for a recently plant minus site-specific and as-built information. The application will provide design criteria and bases, system descriptions, performance requir6ments, and component descriptions and characteristics L

in enough detail for the staff to make its final conclusions on all safety questions; it will also contain information necessary to provide enhanced safety benefits from standardization.

This includes a significant amount of design development and information necessary to finalize procurement specifications and construction and installation specifications for structures, systems, and components affectirs sefety.

The application will contain, for example, perfornance characteristics for systems affecting safety and their components; general pipe routing (one line diagrams, such es F&lDs) for systems affecting safety; and relative n

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physical location and characteristics of components on those systems. This di.lers from the Level 1 option which requires the same detail for all systems as well as' exact physicel location, configuration, and orientation of components end supports.

In other words, for all pumps on systems affecting safety, the type, pumping capacity and head, and certain generalphysicalattributes(e.g.,centrifugalpump)willbe specified; but the exact locations of the inlet and outlet nozzles, exact weight, and mounting / supporting details will not be supplied.

If information obtained during either the Staff review question and answer process or the audit forms the basis for a safety judgment, it will be included or r:ferenced in the application.

Available for Audit Con'sistent-with part 52, that information normally contained in procurement specifications and in construction and installation specifications shall be completed and available

' upon staff request. Audits will be conducted as necessary to support safety judgements and further standardization.

In the Certification The design certification will include all of the material lication, including the ITAAC, submitted in the inicial app (1) determine design accept-for the staff to necessary(2) ensure design criteria and performance require-ability,-

ments are satisfied, (3) make a safety determination, and (4) advance standardization and its resulting-safety benefits.

Remarks To ensure that plants will have physically imilar, and identical functional and performance characteristics, the design must be developed and certified to a level of detail that includes all engineering data necessary to permit the preparation of procurement specifications as well as construction and installation specifications except for data that must be site-specific.

Unlike the Level 1 option that will standardize essentially the entire plant to the component level (with physical attributes, orientation, and location specified), the Level 2 option will result in stan-dardizing component descriptions and performance characteris-tics for all systems affecting shfety. Although to require this amount of detail is initially costly (more than 1400 million) and may discourage vendors from entering the market, cost can be more accurately determined, a benefit to the custor.or (utility).

Certifying this level of detail provides regulatory stability and early and fint.1 resolution of issues

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through design certification. l Unavailability'of specific l

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new technologies) that wocid provide equivalent or improve (

functionality or reliability, will, to some extent, require the granting of an exemption to the rule certifying the design via 10 CFR 50.12. However, pursuant to f

Section.52.63(a)(2), r> change may be made under.the pro'-

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1 visions of Section 50.59 "unless it involves a' change'to the 1

4i design as' described in the rule' certifying.the' design."

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the. Level 2 option, only a small amount of information will.

7iig not be certified, thus only a small' portion will be subject" l

to Section 50.59 changes. The application will include; s

some additionn' information beyond. that trac'itionally..needed

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standardization and provide the safety benefits derived from standardization. Staff ~1icensing. review of the application

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will deviate somewhat from traditional practice, with'. addition y

.of the ITAAC and standardization portions of the' review.

1 Additional guidance will have to be developed for these

' portions of the~ review.

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' LEVEL 3 3

The degree of-standerdization resulting from this level of detail and the certification process will provide identical functional and performance characteristics of all systems, structures,-and components, except for site-specific

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characteristics.

In tne Application l

The application must satisfy the requirements of f, -

10'CFR 52.47(a) and (b)' (invoking Parts 20,50,73,and.100) 1

^s well as provide resolutions for the technical-issues discussed in SECY 90-016. The depth of design detail submitted in the application for design certification will be similar-to that of an FSAR at the OL stage for a recently licensed 1

(1989 - 1990) plant minus site-specific _and as-built infor-p mation. The application will contain design bases, system Y

descriptions, performance requirements, design criteria, and.other information in sufficient detail for the' staff toL;aake its final conclusions on all safety questions.

This includes information necessary to permit the preparation of procurement specificaticns as well as construction and r

instellation specifications for structures, systems, and 3

i components affecting safety. 'The application will contain, for example, performance characteristics for systems affecting safety; general piping locations for systems affecting' safety; W

and general physical locations :f major components for those systems affecting' safety.

Unlike the Levei 2 option where we expect to hue information (physical characteristics) for i

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components on-systems affecting! safety, in the L'evel 3 approach,~we_will have performance characteristics on the J

major components for systems affecting safety..

If'information obtained during either the staff review

. question and answer process or the-audit forms the basis-for a safety _ judgement, it will' be included or referenced in the application.

Available for Audit E

Consistent with Part 52, that information normally contained in procurement; specifications and in construction and-o installation specifications shall be completed and avail-able on request. Audits will be conducted as necessary to-support safety judgments and will not-be u' sed to further standardizationc

-In the Cer ification l

As in Levels 1 and 2, the design certification (Tier 1) and the associated appr_ oval considered together will include all information submitted in the initial application, including the ITAAC, necessary for the staff to (1)' determine:

design acceptability, (2) ensure design criteria and per-

'formance : requirements are satisfied, and (3) make a safety-determination, Unlike Levels1 and 2, ' lier 2 will inc'lude -

a change mechanism, similar to the Section'50.59 process,.

to facilitate changes.that do not decrease-safety. The design material subject to this change mechanism-(Tier 2),

will be specified, by reference, and:the remaining?infor-'

nation in the design certification (Tier-l') will'be changed only through the granting of an exemption via 10 CFR 50.12.

The staff envisiens that the material subject to the e

Section 50.12 process (Ttc 1) will include only top level design = criteria and performance standards similar to that presented in Chapter 1.2 of-an FSAR at the OL stage.

Rer is A significant amount of design information is still required to be submitted in an application for design ~ certification.

However, as a reeult of introducing the "two-tierec'" concept and allowing changes to Tier 2 information similar to those allowed in Section-50.59, the degree of standardization ensured by the rr.gulatory arocess in this approach will be confirmed essantially^ to tie degree of detail in Tier 1 and will be lower than that realized by the Level 1 and 2 approaches.

However, at a minimum, Level 3 still provide's

. identical functional and performance characteristics'. The initial cost to the applicant ($150 million - $350 million) is low compared to the cost of a developing Level 1 application, t,

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Solidifying only the top level design criteria and perfor-mance standards (Tier 1) will yield greater flexibility to modify, via the Section 50.59-type change process, the remaining Tier 2 information.

This will allow for construc-tion fit-up changes, and greater opportunity to implement technological improvements after certification. On the other hand, this approach will reduce the safety and cc:;t benefits of standardization. Although all issues in Tier 1 and Tier 2, the separation by tier, and the test controlling the changes, will be subject to public comment and oppor-tunity for hearing in the certification rulemaking, changes

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made could be challenged later on the basis that they did e

net satisfy the Section 50.59-type test. The staff's review of a Level 3 application will be more traditional as di-rected by the SRP, focusing on that information necessary to make its safety determination. The staff will not L

request mat.crial necessary solely for advancing

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ttandardization.

There are threr attributes of this approach that bear special attention: (1) it will require substantial amount of design engineering to be completed after certification (This infor-nation may be subject to adjudication at some later time os part of a combined li'ense proceeding or later prior to operation (Section 52.103); (2) changes made to the Tier 2 information would be subject to challenge in f

hearings prior to Commission apprrval for operation; and (3) there is a potential for customized changes using the Section 50,59-type change mechanism and, therefore, poten-

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tial for loss of standardization.

LEVEL 4 The degree of standardirahon resulting f rom this level of detail and the cc.tification process will provide at least a product lint type of standerdizetion.

This degree level of standardization is described here for completeness because it represents a level achieved among e group of four piants that mminally used the same " product" piant design off erec by a vendor (i.e., the BWR/6-Mark 111 combination of r.uclear steam supply system and containment).

The organizations that joined and set their courses to produce these p'ents were different for each of the four projects, and CL was the only organization common to all prcjects.

Nomithstanding the fact that these plants are nominally the same " product," they differ in very funda-mental characteristics of their designs. The power levels y

vary among the four plar,ts, but the configuration differences are far greatcr then the different power levels dictate.

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ments were the ser, r all the plants, completely different 1

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construction' methods were used, and the containment volumes

-were.all different. Condensate and feedwater systems are markedly different-in the numbers of booster and feed pumps,

-and the combinations of feed pump drives used.

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The degree of standardization achieved by the four BWR/6-Mark III plants is less than would be.obtained by the

-least standardization accomplished under Part 52.

For that reason, Level 4 is not compared further with Levels 1, 2, i

and 3.

Coordination:

The Office-of General Counsel has reviewed this paper and:

has no legal objection.

Recommendations:

-(1) -lhe staff recommends that the Cor.ission provide guidance to the staff regarding the level of detail.

to ce required in an application for design certifi-cation end subsequent rule certifying the design under 10 CFR Part 52.

(2) The staff recommends that the Commission provide guidance regarding the two-tiered aroposal and the 50.59-type change mechanism descri)ed in this paper, and its acceptability as an approach to providing flexibility.for a design certification under Part 52.

(3) The' staff recommends that the Commission authorize'the prompt placement of this paper in the.Public Document Room to. facilitate the staff-discussion of the various options with interested members of the public.

'Q f J,es M. Tay1 xecutive Dir ctor:

for Operations

Enclosure:

Background on Level of Detail

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Commissioners' comments'or consent.should be provided cizectly

.to)the Office of'the Secretary by. COB Friday, August 31, 1990.

Commission Staff-Office; comments, if.any, should be submitted to the.. Commissioners NLT Friday, August 17, 1990, with an infor-mation copy to the Office of the Secretary.. If the paper is of such'a nature that.it requires additional time for analytical s-review and comment, the. Commissioners and theLSecretariat should be apprised of when comments may be expected; LThis paper is-tentatively' scheduled for discussion at en'Open

- Meeting during the Week of_ July 16, 1990.

Please refer to the appropriate Weekly Commission Schedule for a specific date and time.

SECY understands that the ACRS intends to provide comments following their August 1990 Committee meeting.

DISTRIBUTION:

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FILTER TYPE te g..CNAfDCOAL) 1 A&C A&C N.

N l

t CHILLED WATER CIRC. PUMPS (RAfeGE FOde CAPACITV)

A&C A&C

8. PHYSICAL ATTIMBUTES AND COSIFIG. OF EACH COMPOIENT A&C

9. GEOMETRec ASPECTS OF SUSPE8EDED COMPONENTS A&C N

N N

10. COMPONE9tT AfsD STRUCTURAL SUPPORT DATA A&C

'N 9e.

Se '

11. AS-PROCUIIED COMPOIEleT PERFOltMAfeCE DAT A ps -

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N-N A=APPLICATIOle C= CERTIFICATIOf6 FRExtBLE/CNAfeGE W#O 50.12 fosseOT EMPECTES IIe APPLICATmet F*

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Enclosure 4

['

' BACKGROUND ON 11 VEL OF DETAIL L,

r Standardization as it exists today ranges from plants that are physically and j

Lfunctionally identical (except for site-related differences) to ' plants witn functionally similcr principal components only. The greatest degree of physical

.and functional standardization, aside from identical units on the same site, is exemplified by the SHUPPS plants--Wolf Creek and Callaway. The degree of_stan-

'dardization' achieved by-those plants was realized through the specific actions and cooperation of the participating organizations. SNVPPS plants were designed r

and. built 'by an entity acting as an agent for several utilities.

The same architect / engineer (AE) and builder was used, -utility input was included in the oEsign,.and identical parts were purchased for boti. plants at the same q

time--all this-contributed to their similarity..

Additionally, individual' util_ity preferences were deferrbd for the sake of standardization.

Although Lidentically built, these plants are operated differently, in part because of differences 'in ultinate heat-sink (e.g., Wolf Creek's higher heat rejection-l capabi_lity'~ allows it to operate more efficiently than Callaway).

i

' Strict. control over design and construction does not necessarily ensure.that

. features initially standardized will rwain constant throughout the life of an operating. plant.

In order to :r.ue the benefits inherent in the standardi-t.

zation _ cf multiple plants av ad r operated by several _ utilities, those utilities will need continuing mutual aprewent to work together to share

_ operating dato, evaluate events, pier. ano execute identical or similar plant r

(: i

's w

3 2

=.

Enclosure-

' modifications, share experience and plans for maintenance and training programs,

.m and 'e/en to share costs of identical procurement actions.

Upon_ receiving:

full-power licenses,- the Wolf Creek and Callaway-plants began to diverge-in design and operating practices.

However, recognizing the potential benefits of' 1

standardization,.:the two utilities cecided to coordinate many of their1

_ activities.

Currently, the utilities share the costs of certain major modi-

.fications, lessons-learned, and training of outage personnel for specialized outage work.

At the other end of the spectrum, standardization to a _ point that achieves a functionally similar design is exemplified by the GE BWR/6-Mark III plants.-

These - plants demonstrate a product line type cf standardization' with only containment, major components, and system functionality standardized.

See Attachment I for comparisons _ between the-four-BWR/6-Mark III plants.

When these plants were built, standardization was not a high-prior.ity. objective, but' ithe vendor. sold the reactor type and containment general con-figuration as a

' generic product in large nunbers over a short span of-tiec (more than 40 orders within.2 years; domestic and foreign, some of which were canceled). The vendor

. recognizedi the benefits of standardization and established programs to guide the company's offering toward a more standardized product at a -time when utilities wanted greater power levels.

-The result of utility management's desires for custom-built features and other narket forces was a product line standardization that resulted in four somewhat different domestic BWR/6-Mark III plants:

Grand Gulf, Perry, Clinton, and F,iver Bend, for a comparison of standardization as seen today, ice Attachment II.

e i

?

y 3

Enclosure-DESIGtt DEVELOPMEllT

g.

. In _ proceeding. toward a license under Part 50, certain traditional. factors influenced design development and the level of detail to which that design is taken; NSSS vendors and AEs developeo che design to the point that there was reasonable assurance of being able to deliver a product that would perform as specified for a predetermined cost.

Design wcs developed to the extent that a manufacturer could provi.de equipment to meet performance specifications.

The amount of design detail available at any on; time during the design / construction process was. dependent upon how critical that information was to continuing design / construction in other areas of the plant.

Additionally, the utility's contracting preferences and design traditions were accommodated during the -

design process under Part 50.

The FSAR was developed during construction as an output of the design and licensing process, constantly being revised to reflect the pronress of. design and construction at the facility.

At the time of licensing,.the FSAR reflected a completed design and contained a considerable-amount of as-built detail.

Inte"riewing various industry representatives revealed the same traditional factors discussed above and son'e new factors influencing design development and level of detail in an application for a design certification under Part 52.

In contrest to the traditional Part 50 design and licensing process in which

.the FSAR was a prcduct of ongoing design and construction and contained as-built details, under ' Part EP the Standard Safety Analysis Report (SSAR) will' act les input to the final design document.

Potential applicants for design s

\\:

. ; _. 7 y

4-x a:

1 Enclosure certification 'are developing their design !to the point. at 1which they - are

.)

confident =they can deliver a product suitable /for licensing that will perform 1

as specified for..a ' predetermined price.

Costs to rt ach this level.are-considered reasonable -investments by. potent.ial applicants.

However, there 1

f

-remains'a considerable amount of engineering to finalize the design.

A

\\

=

, COST in order to gain a perspective on the cost of design certification and degree of engineering (ompleteness, the staff examined the engineering costs and accomplishments associated with various. milestones of a recently licensed rlant.

-At this facility,'by the time the construction permit was issued, approximately 600,000 man-hours ior 4% of the total engineering; hours - had been expended

(,

-(42 million 1990Ldo11ars).

Approximately 9 million eng'ineering man-hours or

=D

60% of the total, engineering hours were expended by the time the FSAR was first y

docketed (630 millior, 1990 dollars).- and 15.6 million engineering man-hcars.

4 were -required to develop a complete plant (l'092 billion 1990 dollars).

" Engineering" as used here, refers to total AE and utility engineering (design and Edesign ' implementation) to the point of fuel load, not including site and

'QA/QC engineering.

2 c6 0n the basis of staff discussions with industry representatives, it appears that

,q, the prospective applicants for design certification of evolutionary light-water

-reactors expect certification will require' 50% - 60% of all design to be l

=

.q 5

s,

>< 3 Enclorxre complete for a cost of $150 million - $350 million. Certain applicants believe that-they currently have or will have more engineering completed than.is.

necessary to support certification.

This appeat s to vary with the amount of outside participation the applicant has been able to attract.

Certain prospec-tive applicants have designs under way for evolutionary LURs to be built overseas that afford them the AE and utility funding to develop more design detail based l

l on-a complete design on a specific site.

Some of the applicants have-entered into joint ventures with AEs to provide engineering design.

One of the prospective applicants now developing an advanced design for certi-fication' expects completion of certification will require approximately 40% of design engineering to be completed for a cost of about $135 million.

This l applicant-_also. expects utility participation approximately two years before the design is certified.

It shou'Id. be noted in considering the percentage of engineering complete, the industry believes a large portion of the ' safety-significant engineering associated with the design will be' completed' earlier under part 52 than in the traditional part 50 process.

Although a considcrable amount of detailed engineering. design will remain to be translated into specifications and con-

.struction drawings - af ter design certification, more design information will be : developed and translated. into engineering drawings, specifications, and analysis at the time of certification, than is now in a first-docketed FSAR under the,Part 50 process.

1

jr<

I 6-

+

'[

d Enclosure

-ITAAC

~ Inspections,. tests,. analyses, and acceptance criteria- (ITAAC) must be

developed by the applicant - end submitted for staff review as specified in

. Sectio'n 52.47(a)(1)(vi)..

ITAAC will provide reasonable assurance that a-plant which references the design is built and will operate in accordance with the' design certification.

i Under Appendix B to Part 50, which is invoked by Part 52, design and construc-

. tion attributes will be verified by various processes.

'Ne design of the-L facility will be validated by the design and document control process, procure-ment and construction verification will be performed as part of the applicant's

?

- construction' quality assurance / quality control program, system performance will be.-verified through. preoperational and start-up tests, and deviations;between J.

the - as-designed and as-built facility will be evaluated and' dispositioned through.the design: reconciliation - and corrective action : process.

What is

' unique to the Part 52. process is the preconstruction identification of key elements of.these programs that, in the past, evolved during the~ course of ~

. construction.

i I:

u- -

As defined in Part 52, the ITAAC must be necessary and sufficient to provide

- reasonable -assurance that a plant that references the design is built and i

will operate in accordance with the design certification.

Depending on how

se' e

F 7

,7 y.

J lf Enclosure

~

the terms " reasonable assurance" and "necessary and sufficient" are interpreted,

.l the ITAAC scope can rbege from the verification ~ of every design and construction

- attribute. include'd in the design certification to verdication cf directly

. measurable process oarameters (e.g.,

flow, temperature, pressure, = voltage, current) that demonstrate system performance / functionality.

For the Level 1 option.. the ITAAC at one end of the spectrum, could be very detailed, since they aay. entail verification of a large number. of design and construction 1

attributes.

-Given that ITAAC will functionally duplicate other programs that verify

. hundreds if_ not. thousands of design and construction attributes, the scope of ITAAC can be restricted to a set of principal attributes that are necessary

- and-sufficient to provide - reasonable assurance at the design certification

~

_4 ctoge that the plant will,be built and will operate consistent with the design certification. -It is the staff's view that the ITAAC were.not meant to be a

. one' for-one check of detailed design and construction attributes (e.g., the embedment length of anchor bolts) that are verified in the quality programs-already-in place.

Basically, there. are two types of, ITAAC.

The first includes direct.

verification of performance and construction attributes through field L

inspections, measurements, and tests; for example, pump operability; tests including pump flow and ' discharge pressure measurements.

The second type

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I 8

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. Enclosure 1

validates performance and functional requirements that do not:' lend themselves to direct measurements; for. example, the validation of containment performance 3

analyses' results (e.g... maximum temperature ano pressure under postulated.

' ~

accident conditions) by ' direct measurement of analyses assumptions such as

- containment net-free volume.

As the level of detail available at design

'ccrtification. becomes utore specific (i.e.,- standardization at Level 1)', the j

I ITAAC can, to a greater degree, call for verification of a greater number of specific.. numerical values of design and construction attributes, since these o

& d be available. The proportion of named attributes for which quantitative 1

values could be identified will be less at Levels 2 and 3.

However, as discussed f

above, the ITAAC for. Levels 1, 2, or 3 can contain the same attributes to be j

verified.

For all three levels, actual values determined during - the post-combined operating license (COL) construction period would be reconciled with

-j l

system design requirements through ITAAC at the post COL stage, j

i.i ITAAC at the most detailed ' level will not provide additional verification of design or' construction beyond that achieved in the construction phase of a

.j

. project licensed under'Part 50.

However, an adjunct and important function of-

.i

-i the ITAAC is-to ensure, at the-design certification stage, the-integrity and

-credibility of a one-step licensing process.

4 5

i l

n..

9=

Enclosure The ITAAC becomes an early, binding commitment to elements of existing quality programs and serves as an independent final-check, similar to the independent design verification programs (IDVPs) and r6adiness reviews-that were conducted on recent operating license applications.

The ITAAC, like the IDVPs and-readiness reviews provide additional assurance that the design and construction

-processes and the quelity programs functioned adequately.

From this approach to ITAAC, several objectives are attained: (1) reasonable assurance is provided at the design certification stage that design and construct'on processes will be conducted and :the plant will operate in accordance with the certification; (2) during and following construction, the-principal performance criteria' specified'in the ITAAC will provide highly visible checkpoints for measuring and ensuring -the as-built facility is in accordance with the-certified design;

-(3) through-a progressive and. sequential implementation of the ITAAC, problems, will be promptly identified and addressed; and (4) throughout the plar.t's operating life, the 1TAAC will ensure the design remains consistent with the certification.

1:

j7 6

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ATTACHMEilT I:

p o; 1

4 BWR/6-fiARK III-

'The BWR 6/MarkilII plants =that ;.e compared on'the chart are in many areas

,similar with a pattern of differences due to an increase in power output on:

later models.

Examples are noted below for each of the are'as on the comparison charts..

.. w

-Reactor Vessel end Internals:

l i.

Clinton and River Bend are. virtually identical.

Perry and Grand 0 'f are

]

. notably larger and higher rated. - Void coefficients, fuel temperath,2, il doppler, minimum critical power ratio, initial U-235 enrichment, etc. are

'l 2

u slightly different.

diam.

Thick Height Rating.-

j

' Clinton 18'2" 5.3" 69"'

2894 MWt l

')

River Bend 18'2" 5.3"-

69" 2894 MWt '

. Perry 19'10 6.0"

'70" 3579 MWt Grand Gulf 20'11 6.14" 73" 3833 MWL.

)

)

Fuel / Control' Rods:

i Although the fuel elements and control rods are similar, the same' pattern of increasing qucntity.is evident, i

Fuel Assemblies Control Rods LPRfis-g

Clinton-624 145 132 j

P,iver Bend 592 145 132 j

Perry 748 177 164

~

Grand-Gulf 800 193 176-i

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-BWR/6-MAPK Ill

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Reactor Coolant-System.

,g Similar.withshesame.increasepattern.

~

1. -Jet Pumps

'Recirc Pump' Flow (gpm);

l Clinton 20

'32,500 River Bend

20 32,500 LPerry

20 42,000 l

Grand Gulf-24 44,900.

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f

.L0nlyg noted' difference was an increase in pipe diameter.

3 7

m

Clinton 24" T

eRiver Bend 24"'

Perry.

26" Grand. Gulf ^

28" "p'

. Condensate and Feedwater:

Th' differences in the design of'the'se were more significantithan the i

e Lprevious'. areas as noted below.

l H :.

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1. Cond.

fCond.

.# Feed..

Feed Pump 1

"e P_ umps Booster Pumps Drive Types

[

'e Clinton

-4 4

'3 2 Turbine /l Motor River Bend -

3 0

3 All Motor a.z Perry 3-3 3

2 Turbine /1 Motor Grand Culf 3

3

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Both Turbine 4

2

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o ATTACHMENT I o

t BWR/6-MARK III.

' Containment:

' Although.the design pressure and temperature were the'same for all four plants, the style of construction varied significantly.

Clinton-Reinforced concrete cylindrical structure.with hemispherical dome, steel lined, enclosing drywell and suppression pool.

River Bend Cylindrical freestanding steel with ellipsoidal head.

Perry

' Cylindrical freestanding steel with ellipsoidal head with reinforced concrete shielo building.

Grand Gulf Similar to Clinton Leak Rate-(%/ day)

Volume (E6 ft3)

Clinton 0.65 1.55 River Bend 0.26 1.19 Perry 0.20 1.14 Grand Gulf 0.35 1.4

'R". actor' Pf' tt : tion System:

Clinton is significantly different from the others since they have the solid

. state reactor protection system.

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ATTACHMENT 1:

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BWd/6-MARK 111

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Dio

Radwaste System

Gaseous Process' Treatment

1. Beds-Release point Clinton-Chilled charcoal' 2

199.5' River Bend Chilled charcoal 8-190' Perry ~

.Recombiner &

8 134' chilled charcoal-

]

'GrandLGulf Chilled Charcoal 8

31.5' j

Eletrical systems:'

Clinton River Bend Perry Grand Gulf ~

1. Offsite 4(1 units) 6(2 units) 5 3(1 unit)

Circuits.

4(2 units)'-

1. Aux Power 2 Aux,-

4 Unit' Aux.

4 Unit Aux ~

.3 Service Sources 1 Rsrv Aux 1 Startup/-

1 for ESF

-1 Emerg.

4 Rsrv Aux.

Unit

1. Preferred Pwr

-2 2

2 3

to ESF' Buses

1. ESF Buses 3

3 3-3~

1. 'Stby'A-C Pwr.

3 6

6 6

3 Supplies (1/ESF)

-(1/ESF)

(1/ESF)-

(1/ESF) y

1. l'5 V DC Systems 3 6

6 6

2

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gi ATTACHMENT I y.

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. BWR/6-MARK III

- Safe'ty Syster,is:

ECCS are similar in design but again' sized up.

Totsl LPCS(gpm)

HPCF' d RCIC(gpm)

ADS SRVs f!

i Clinton 5010 1400 600 7

16 River Bend 5010 1400-600 7

19 S:

Perry.

,6000

.1550 700 8

19 Grand-Gulf 7115 1650 800 8

20 Residual Heat Ren: oval-A Pumps LPCI (gpm/ pump)

Clinton-2 5050

' River Bend 2

5050

[

Perry 2

6500 1 Grand Gulf 4

7450

- Emergency Service Water System:

Design of-load allocation varied significantly from plant to plant resulting

.t

in.'a significant difference in ESils flows..

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..Clinton

.34,100 gpm

. River Bend 34,100 gpm l

-- q Perry 22,700 gpm Grand Gulf-25,300 gpm i

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ATTACHttENT:'I ni 9

<BWR/6-MARK.111 -

'Ultimale~ Heat - S' ink: -

E

' fVaried based'on ulocation'.

- # Cire. Water Pumps Clinton'-

Lake-3:

" ' [-

River Bend' River 4'

J/

~.

Perry:

Lake Erie

-3 Grand Gulf River 2

'Seisn.ic/ Structural ~ Design:

Clinton River Bend Perry Grand Gulf;.

SSE horiz..g' O.25 0.10 0.15 0.15 vert. g 0.25 0.10 0.15 L 0.10

' ~

I0BEhoriz.ig,

,0.10 -

0.075-0.075 0.075 0.050 v ert'. ' g -

0.10 '-

-. Wind Speed:

05-100-90

-. 90

- (mph')"

Tornados.((mph)'

!T0ansl.

70

' 70 70 60

'4 Tangen.

290 290 290 300 Technical Specifications:

~ All TS: are uriique hybrids incorporating BWR standard TS and plant specific designs.

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ATTACHMENT II.

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: STANDARDIZATION SEEN TODAY-1 s

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p SYSTEM DESCRIPTION SNUPPS

. BYRON /BRAIDWOOD' BWR/6-MARK III I k-

-}lolf Creek Grand Gulf-E Callaway Perry p

'Clinton-p River Bend i

v

,t

.ReactorLVessel and Internals I

I S.

Fuel / Control Rods I

I C,RB:S GG,P:D LReactor. Coolant System f>'

incl.-.flajor= Components Pumps / Valves /SG.

I I

C.RB:1 GG,P:S i

MainJStean 1

'I C,RB:I-3 i

GG,P:S Condensate and I

I D

'Feedvtater Main Turbine and.

I I'

D LContr'ol: Valves '

E' Containment and w

l'

- flajor Components-

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GG,C:S.

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g7 STANDARDIZATION SEEN TODAY l

-i 1

SYSTEM DESCRIPTION SNUPPS BYRON /BRAIDWOOD BWR/6-MARK-111 Wolf Creek Grand Gulf:

Callaway

- Perry,

.Clinton.

River Bend J

1 Reactor Protection.-

RB,GG,P:S.

Systen 4I I

C:D

.Radwaste System 1

1.

- C,RB:S' GG,P:D Electrical Systera S-S D

L (diff, lines)

(diff lines)

'AC/DC Onsite_

1 I

RB,P,GG:S

C:D Safety Systems

-l ECCS I-

'I C,RB:I GG,P:S o

.SLIC/RCIC NA NA C,RD:I v

. GG,P:S

.AFW I

I NA lr

.RHR Systera 1

1 C,RB:I

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GG,P:S 2

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ATTACHMENT 111 4

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STANDARDIZATIONSEENTODd i

A-SYSTEM DESCRIPT!0N' SNUPPS BYRON /BRAIDWOOD.

BWR/6-MARK III Wolf Creek Grand Gulf

+

-[,.

Callaway Perry

.Clinton-River-Bend <

(Process Control:

. Turbine

.I I

D

-Feedwater I

I D

Control Rods I

1 S

[ServiceWaterSystems-

-D D

D

' Component Cooling Water D.

D D

Ultimate Heat Sink-D D.

D o,

oi

.Cu = Clinton GG'= Grand Gulf ERB:= River Bend

,P

= Perry.

s I=' Identical S = Similar D = Different 3

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' STANDARDIZATION'SEEN TODAY-IL I

i lD SYSTEM DESCRIPTION-

-SNUPPS

. BYRON /BRAIDWOOD

-BWR/6-MARK III J

~

Wolf Creek, Byron

-Grand Gulf 1

4,

l3 NSSS

'W-W

'GE l AE,

Bech S&L Bech CONST Dani CWE Callaway Braidwood.

Perry-W'

-W GE Bech

-S&L' Gil Dani CWE Kais Clinton GE S&L Bald j

1 River Bend ij i

GE-l

1 S&W.

.jj S&W.

q

,GE:

General Electric-j

(

.-U:-

Westinghouse.

]

Bald: Baldwin Associates i

Bech:.Dechtel

'?

CWE:

Commonwealth Edison lDani:. Daniel International lS&L:

Sargent and Lundy

'S&W:.-Stone end. Webster Y.

4 l

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