ML20055H295
| ML20055H295 | |
| Person / Time | |
|---|---|
| Issue date: | 07/16/1990 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9007260014 | |
| Download: ML20055H295 (158) | |
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U N I T E D S T A T E S. O F A M E R I C A ?-
NUCLEAR REGULATORY ~ COMMIS SION.-
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6 k$l BRIEFING BY NUMARC ON ESSENTIALLY COMPLETE DESIGN ISSUE FOR PART 52 SUBMITTALS LOCatiOD:
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1-NEALR.GROSSANDC0.,INC.
1 COURT REPORTERS AND TRANSCRIBERS 1323 Rhode Island Avenue, Northwest Washington,-D.C.
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4 L f DISCLAIMER 1
This is an unofficial transcript of-a meeting _of the United States ' Nuclear Regulatory Commission held on l-July 16, 1990, in the Commission's offico at One White Flint North, Rockville, Maryland._
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies, l
{_
i The transcript is intended solely for general 1
informational purposes.
As provided by 10 CFR 9.103, it~is not.part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this
-l l-transcript do not necessarily reflect final determination or beliefs.
No pleading or'other paper may be filed with the commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may autnorize.
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. UNITED-STATES OF AMERICA
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' NUCLEAR REOULATORY COMMISSION BRIEFING BY.NUMARC ON ESSENTIALLY COMPLETE DESIGN ISSUE FOR PART 52 SUBMITTALS PUBLIC MEETING Nuclear Regulatory Commission One White Flint North Rockville, Maryland'
-t'.
V.'.2 Monday, July 16, 1990 The Commission met in open
- session, pursuant to notice, at 2:00 p.m.,
Kenneth M.
- Carr, Chairman, presiding.
COMMISSIONERS PRESENT:
KENNETH M.
CARR, Chairman of the Commission
-KENNETH C.
ROGERS, Commissioner JAMES R.
CURTISS, Commissioner
-FORREST J.
REMICK, Commissioner
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n STAFF AND PRESENTERS ~ SEATED AT THE COMMISSION TABLE:
SAMUEL'J. CHILK, Secretary hILLIAM C.
PARLER, General Counsel.
BYRON LEE,.JR.,-President.and CEO, NUMARC-SHERWOOD H.
- SMITH, JR.,
Chairman and President Carolina Power and Light' DAVID L.
REHN,= Division Manager, Catawba Engineering j
Division,. Duke Power
~"
- MARCUS A.
ROWDEN, Esquire Fried, Frank, Harris, Shriver and Jacobson Chairman, NUMARC Lawyers Committee f
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2 2:00 p.m.
3 CHAIRMAN CARR:
Good afternoon, ladies and
'.4' gentlemen.
5 An issue currently. before the Commission 6-is the question of how detailed an application and 7
design certification must be under Part 52 in order to l
8-support both a safety review by NRC and to: encourage 9
standardization.
10
- Today, representatives of the Nuclear
'll Management and Resources Council will provide the 12 Commission with their views on this subject.
The
,t 13 Commission will be also briefed on this matter by the
(.._.
14 NRC staff this coming Wednesday.
15 I understand that copies of the -briefing -
16 slides to be used today are available at the entrance 17 to the meeting room.
-18 Do any of my fellow Commissioners-have 19 opening comments?
20 I
would like to welcome -the industry i
21
. representatives here today, i
22 Mr. Lee, please proceed.
23 MR.
LEE:
Thank you, Mr.
Chairman.
We 24 were talking a
little
- before, this is the first 25 meeting that anybody can remember whe'e each of the i,
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1 participants was ' given a copy of the Code of! Federal 2-Regulations.
I hope we'll not get bogged down-in i
3 legal terms.
4 COMMISSIONER ' ROGERS :
Don't try to read.
S them all before we begin.
-l 6
MR.
LEE:
But again, we thank you for 7
~the ---
8-CHAIRMAN-CARR:
Did we furnish that?.
9 MR. LEE:
We appreciate the opportunity to 10 talk about. another segment of the industry's. advanced 11 light water reactor program.
You've heard from the 12 EPRI ALWR Steering Committee about its requirements r--
13 documents several weeks ago.
- Today, we want to
't 14 discuss the utilitier' view of future electricity 15 needs and what we believe needs to be done for nuclear 16 power to-play a role in those needs.
17 We also want to cover NUMARC's 18 standardization working group efforts to develop 19 guidance on the implementing the requirements of your 20 new Part 52 rule.
.21 Let me begin by introducing the-speakers 22 who are with me today, while I think you know most of 23 them.
Sherwood Smith, to my left, Chairman, President 24 and CEO of Carolina Power and Light, and is also the 25-Chairman of the industry's Nuclear Power Oversight i
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1 Committee, or NPOC..
Sherwood will-discuss the i-
~
projected future electricity demands and 2
project:--
f 3
capacity and where t'he nuclear utilities stand on the 4-future of the option.
5 Dave Rehn, on my right, is the Division 6
' Manager at Duke Power and Chairman..of our task group 7-on inspections,
- tests,
.;alysis and acceptance 8
criteria of ITAAC.
Dave will describe the results of 9
his task group's efforts to develop an industry 10 approach to the implementation of Part 52, including:
11 the level of detail required for design certification 12 and the role of the NUMARC ITAAC report.
i 13
.Last, Marc Rowden, Chairman of our NUMARC
-)
14 Lawyers Committee, and a member of the NUMARC working
-15
. group and the task
- group, Marc will explain-'the 16 industry's two-tier approach and how it relates to 17 Part 52 based on our active involvement in this U
18 rulemaking process for several years.
19 Also, I'll introduce behind me and inside-20 the
- rail, we have members from each of the 21 manufacturers and Ed Kintner representing the EPRI i
22 ALWR Steering Committee.
Joe Quirk is from General 23
- Electric, Ernie Kennedy 'from Combustion and Bill 24 Johnson from Westinghouse.
25' Before we begin, I have a few introductory y
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-1 comments.about the; process in general.
The -industry's 2
approach.to implementation of Part 52 supports:three 3
goals' that we believe are embedded in the rule and 4
desired by industry.
One is t l.e preserved-5=
standardization of design.
Two is to aseure that S
issues raised at the design certification stage ~are 7
resolved and thereby precluded from being reconsidered
'8 at the. COL and the preoperational stages.
And-three, 9
to assure'the practicality of the design certification 10 rule at the time of the COL 1ssuance during facility 11 construction and at the preoperational stage.
In
.12 other words, it must take into account the realities g
13 of a.large complex construction
- process, which
-a h
14 nuclear plant is.
)
15 The LWR design work undertaken by.the 16 industry, which includes EPHI, DOE and the individual 17 suppliers, is moving along very well.
The.
18 certification reviews, however, appear to be following i
19 the course of the past, uncertainty.
This observation 20 deepens the industry's fear that we won't have this :
21 predictable licensing process needed to support the 1
22 future nuclear plant orders.
We hope that as a result-23 of our briefing today that we will be able to reduce 24 that uncertainty.
25 At this point, I'd like to ask Sherwood to l..
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to;l 4' ' 1" '
l' talk'about the supply,. demand and future.
2=
.MR.
SMITH:
Mr. Chairman and members of 3
the' Commission,- as Byron Lee stated.
I'm-here as 4
Chairman of-our Nuclear Power Oversight Committee, or 5
NPOC as it's called.
I wish to discuss very briefly,_
6 but it's fundamental to our being here, the question 7
of will we, and I think the answer is yes, and how 8
will we continue to have-an adequate supply of' 9
electricity in this country through the 1990s' and 10 beyond.
11 For about the last 25 years, in one way or 12
- another, I've been involved in the
- planning, feJ 13 designing, litigating, licensing, managing an O lj -
14 organization that has owned and operat'ed nuclear power-15 plants.
Our company _ built the f.irst plant in 'the 16 Southeastern part of the United States.
We now offer 17 a four units and we operate both BWRs and PWRs.
18' I'.ve seen many national questions raised 19 from time to time over that career period and have 20 served in a number of industry trade associations and 21 similar capacities.
All of that experience, over and 22 over again, has indicated to me one t h.t n g, that delay 23 can be disastrous in-the planning, design, licensing 24 and construction of nuclear power plants.
25 Providing a new electric supply for this y'v NEAL R.
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~ matter that 1
country for the -'90s and beyond is a
2 involves many risks and many uncertainties.
Certainly 3
'one of the major uncertainties is how much' electricity j
4 will we need?
We now have an' adequate ' supply of 5
electricity in many parts of the-country, but'we also 6-have.seen parts of the country this yea,r where~we have
-7 had voltage reductions or rolling _ blackouts in the 8
Northeast in March, more recently here-near the place 9
we're located today earlier this summer.
10 I think our industry, the electric utility 11
- industry, is commi t ed to meeting the future demand.
12 The question is how will we be.able to meet that
' e x-13 demand?-
For environmental as well as economic y
14 reasons, we think it's fundamentally important to'our-15 success in providing an adequate and r,,l i ab l e supply 16 of electricity that we can again-consider the nuclear 17 option.
18 In preparation for our meetiag this 19
- morning, as some of us were talking, I " aid that! I 20
-don't think by any matter or means thei we've reached
[
21 the end of the development of nuclear power in this-22 country, nor have we seen the beginning of the end, j
l; 23 but I think we've come to a place where we're at the 24 end of the beginning.
I think it's now incumbent on 1.
[
25 us to move forward and do the job right and, Mr.
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1 Chairman, we concur the job must -be done.~ right.
We 2
cannot afford to repeat the many. mistakes and problems 3
and difficulties that we've had over the last 10 to 12 4
to 15 years.
5 But by the same token, I think we-must do
- it right in an orderly and expeditious time frame.
I 6
.7
.think that the complexity of certification of new 8
designs, the certification rulemaking proceedings-that 9
will follow those, all of the other things mean that 10 unless we set a very challenging achedule,,a schedule 11 that some would call optimistic, we're not going to be j
12 able to-have the availability of a certified design l
y, 13 that we can consider ordering in the mid-1990s.
And I j
u-14 think in the mid-1990s we, the -industry, need to be in j
i 15 a position to consider placing orders for plants that 16 would come in perhaps not.before the turn of the-17 century but shortly after the turn of the century.
I I
18 do think that any delay in certification, as delays in 19 the other issues we must address, can extend on a 20-linear basis the date when we-will be able to order a 21 new nuclear plant.
i 22 When one looks at the power supply in this 23
-country and the rates of growth which often are stated
)
24 to be two to three percent' a
- year, regardless of i
25 whether it's closer to two percent or up closer to O' l NEAL R.
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1-three-percent, we're going to needf a substantial-2 amount ' of new capacity. in the next ten years.
The 3-last official report of' the North = American Elect' ic r
4 Reliability Council published'last year indicated that' 5-we would need between 100 and 200,000 megawat t's.
If 6
you take the low end of that b a n'd, if-you take the 7
100,000 megawatts and you assume that some; of-- it 8
should be peaking capacity, some of it will be' fossil 9
capacity, there is still a large amount of capacity as 10 to which no decisions-have been made, that decisions-11 soon.should be made if we're going to have that 12 generation in place around the turn of the century.
r f-13
- Today, we can't consider the nuclear
(
14 option.
We must consider either coal, oil or gas.
15
. Utilities have embraced the concepts of conservation, 16 demand management, energy efficiency and.I think that 17 we will be able to do a
great deal with those 18 concepts.
But even in spite of those we're going to 19 need a great deal more base load ' capacity than. we 20 currently have planned.
21 If one looks at the base load capacity 22 that was committed for at
.he beginning of this year,
' 2 3 ~-
some 7,200 megawatts 72,000, 72,200 in the-24' nuclear business, you have to remember to keep moving.
25 the decimal point to the right.
One of the things I
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1 we're trying to. do is stop that-from the-cost 2'
standpoint.
3 If you look at that 72,200 megawatts, 4
about 41 percent of that had not been placed under 5
construction.
About-25' percent of that capacity is 6
being built by non-utility generators.
Those non-7 utility generators don't have the same public service 8
legal obligation that utilities do to have that 9
capacity in place to serve the load and some of'that 10 capacity. is probably more susceptible to ' delays than 11 would the utility planned capacity be.
12 About 11 percent of that planned capacity 5
13 is under construction, but less than 50 percent s'-
14 complete and only 23 percent of that capacity is under 15 construction and more than 50 percent complete.
But 16 that capacity includes Watts Bar and Bellefonte and 17
-certainly those schedules are open to question.
18 The fossil plant construction that is 19 either underway or committed is certainly ' subject - to 20 cost and schedule delays because of what may happeri 21 with clear air legislation and global climate 22 uncertainties if tl.ere's mor'e legislation or more 23' activity on the environmental front in that area.
We 24
- see, at
- NEARC, the likelihood that we may. have 25 capacity shortages in the Eastern United States by the i
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1 turn _of the century and those capacityfshortagesineed 2
not, occur.
The public need not be burdened by those 3
if we take proper action now.
q 4
In my written statement, I made reference 5.
to several sentences.that appeared in a letter sent:by 6
the President to the Nuclear Power Assembly in mid-May 7
of this. year and I'd just like to' quote three of those-8 sentences, if I may.
9 "Just as America gave birth to nuclear 10 technology in the 194 0s,' we can lead the world into a 11 new
. era of
- safe, reliable, economical and 12 environmentally clean nuclear power in the 1990s.
jf -
13.
This clean, domestic source of power lessens the risk i
1 14 of energy dependence on foreign sources.
At the same.
15
- time, environmentally harmful emissions are -reduced i.
16 and economic growth is fostered."
17 Rhetorically, I would ask what do we need, 18.
particularly what do we need from this Commission in 19 order to move forward 7 We need a
stable and 20 predictable regulatory process and I think the actions 21 taken by the Commission within the last 18 months or L
22 so go a long ways toward stabilizing the process and L
~23 making it more predictable.
24 We, as I said before, and I use "we" in a l
25 very broad sense and certainly to include the
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industry, cannot repeat the problems of the past.
We o
2 will need early site appraval, we will need designs-3 that are-certified, we will need standardization, we 1.
4 will need combined construction and operating permits.
5 All of these steps are essential, but the-purpose of.
6 our meetings with you today-is to discuss the 7
certification of standardized designs.
8 To be specific, our position is simply 9
that we agree with the Commission on the need for 10
. parallel review of the CPRI ALWR Steering Committee 11-requirements document and the two evolutionary. ALWR 12 utility designs that are now before the Commission.
13 As to the passive designs',- we feel that the EPRI ALWR i
14 Utility Steering Committee requirements document 15 should have the highest priority.
That's sort of our 16 polar. star-of navigation as we look, at the passive 17 designs.
These should be the mechanism to resolve any 18 inajor technical issues l and policy issues.
19 We agree with the Commission that the 20 staff should review information and activities that i.
21 are related to specific passive designs that could be 22 useful as it conducts the EPRI review and to prepare s
23 for the review of specific designs.
Design 3
1 24 certification is the linchpin of all the other issues 25 before our industry, because as our industry seeks to i
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address -the other issues and they are significant:but 2
we think_ that they are' resolvable, unleps therelis a 3
product that has been certified by the NRC - then we 1
4 have'notting upon which to focus.
5 Again, Mr. Chairman, we must get it right 6
this +ime.
We know that will mean there will have to k
7 be a rery thorough, painstaking review.
We enderstand 8
that it will require a commitment of Agency resources 9
that is equal to the task and commensurate with the 10 job that must be done.
11 We commit ourselves to do our part.
We 12 feel that we have a responsibility-to this country to 13 maintain an adequate supply of electricity.
We feel 14 that in order to do that and to do it on the basis of 15
- economy, safety, reliability, environmental 16 compatibility, that we must exert every possible 17
- effort to include nuclear power as a part of that 18 energy supply for the future.
19 Thank you very much.
20 MR.
REHN:
Mr.
Chairman, members of the 21 Commission, I appreciate the opportunity to discuss 22 several aspects associated with the design 23 certification process as defined in Part 52.
24
- Industry, through
- NUMARC, established 25 approximately a year and a half ago a task group to r-l L
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1 propose guidance on implementing the
-inspections, 2
tests, analysis and the-essociated acceptance criteria 3
'o r so-called.ITAAC, that are necessary to demonstrate 4
that after the issuance. of a combined' license, a
5 nuclear facility is built and will operate according
'ncluding the 6
to the terms of the combined license, i
7 certified design referenced therein.
8 This effort necessarily included 9
formatting a position on the form and content of a 10 design' certification applicat'.on, a
design 11 certification rule and a combined license so as to 12 provide a
framework within which to address-the 13 implementation of ITAAC.
Proposals of the task group 14 have been embodied in a report which is currently 15 undergoing final review by NUMARC's Standardization-16 Oversight Working Group.
We anticipate having this i
17 report issued in the near future.
18 During the development of the report,=
19 emphasis was placed on providing guidance that would i
20 result in a
faithful implementation of our 21 understanding of the Part ' 52 requirements since the 22 task group relied heavily on the content of both Part 1
23 52 and the statement explanation contained in the 24 statements of consideration that accompanied the rules 25 issuance.
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.While acknowledging that Part 52' process-2 would be different from the past Part~ 50 licensing 3
- process, the task group sought to build upon the 4
established and tested NRC and industry. practices-
- Si which were relevant.
We wanted-to simply learn from
.6 the mistakes and the lessons that we had learned,in 7
the previous process.
8 The task group strived to satisfy three 9
major goals and I'll reiterate what Byron had said 10 earlier.
First of
- all, to preserve-the 11 standardization of design.
- Second, to assure.that I
12-
' issues raised at the design certification. stage were 13 resolved and thereby precluded from being considered i
14 at the combined license and preoperational stages.
15 And finally, to assure that design certification rule 16
'is crafted so as to be. practicably usable at the time 17 of.the combined license issuance, during the facility.
18-construction, at the preoperational stage, and during 19 plant operation, taking into account the complexity of-i 20~
large construction projects.
21 I would - like to provide you now with a 22 summary of some of the key points contained in our 9
23 report.
Guidance and recommendations were developed t
24 on specifically level of design detail which should be 25 contained in a
design application, design
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1 certification application, the treatment o l' that 2
design information in,the, design certification rule 3:
and the role of ITAA'C in this process.
4 Starting f i'r s t-with-the design 5
certification application, let's quickly review what 6
Part 52 hae to say concerning level of design detail 7
associated with.the design _ certification application.
8' Referring to Section 52.47(a)(2), guidance'is provided 9
on the level of design information to-be submitted as d'esign cer'tification, 10 a part of the application for a 11 and
- quoting, "It's a
level of -design information 12 sufficient to enable the. Commission to. judge the F
13 applicant's proposed means of assuring.
that L_
14 construction conforms to -the design and to reach' a 15 final conclusion on all safety questions associated 16 with the design before certification is' granted."
)
17 Further, Part 52 also provides guidance on 18 the type of design information that must be-submitted.
19 It can be characterized as follows.
-The design 20 information analogous to that typically contained;
'21 today in a final FSAR, minus site-specific details.
22 Since we have not yet built the plant or proceeded 23 into the final stages of procurement, it would not 24 include as-built construction information or as-25 procured details, so-called nameplate data.
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1 In addition to tdth,we will have a couple of, 2
other items that we have not historically provided, j
3 certainly a detailed. delineation of the inspections, 4
- tests, analyses and the associated.
acceptance 5
criteria, or ITAAC, which is a new element that has b
been added to Part 52, and also the results of ' a u
7
-probablistic risk assessment.-
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8 Further, Part 52 defines this information-9 must be sufficient to accomplish a variety of tasks, i
10 First, it must allow to define the systems, structures 11 and components for the certified portion of the pl an t,-
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' including those which can effect-plant. safety.
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14 certified portion of the plant, typically the site-l 15 specific elements of the plant.
16 It must be suf ficiently detailed to= allow 17 the NRC to accomplish three things.
First, complete-18 their safety evaluations and resolve all associated 19 safety questions, Judge the adequacy of the 20 applicant's proposed means of assuring construction' 21 conformance with
- design, and the preparation and 22 scheduling of their inspection requirements.
y 23 And
- finally, it must be sufficiently 24 detailed to permit preparation of performance-based L
25 procurement, construction and installation specs.
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- Thus, a -Part 52 design cer'tification
-2 application will contain more design information than 3
current operating license ~ applications filed under 4
Part 50.
5 In-order to maybe better understand what
'6 these requirements mean and to evaluate what impact i
7 nameplate and site-specific issues might have on 8
design details, we want to quickly review with you two 9,
examples.
In particular, we'd like to-look at a
10-containment building and an HVAC system.
11 (Slide)
First let's examine the 12 containment building for a
proposed BWR.
The 13 application would include various types
.of 14 information, as shown ont the accompanying overhead.
15
. Dimensional detail would be final'and precise and this 16 is due to the fact that' nameplate information and the 17 design details associated with typically a concrete
.18 -
structure of this nature, have little or no impact on 19 that structure.
20 (Slide)
Moving. on to the HVAC system,'
21 similar types of information are provided.
What's the I
22 noticeable differences?
Codes and standards are more 23 extensive.
System performance requirements are and-24 will be defined in detail and equipment type and 25 functional requirements are also defined.
Layouts I
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must necessarily make provisions for the envelope of 2
equipment dimensions for that equipment which-has not 3
yet been specified at the procurement level.
While 4'
some variations in dimensions would occur ' based-upon-5 the supplier that is ultimately
- chosen, all the~
6 functional requirements must be. satisfied.
Those are 7
the functional' requirement's specified in the certified 8
design application.
9
- Thus, if we were to -look at a specific 10 system contained in a specific ~ room within
- a. plant, 11 certain characteristics would be readily observable.
12 In looking at this example in maybe a little. more 13
' detail, assume for a moment that we' re looking at a y-
.e 14 fluid system that contains a pump, a heat exchanger 15
,and a valve.
The-design c e r t i f'. c a t i o n application 16 would define in detail the safety-functions and 17 performance requirements of each component, as well as
'18 of the complete system.
The specific location of the 19,
room with the envelope dimensions of the equipment, 20' complete with orientation, would be provided.
21 The level of detail supp' lied must be l
22 sufficient to resolve safety questions related to this 23 particular system, such issues as fire protection, 24 seismic interaction, seismic qualification, security 25 and environmental quali fication.
t c
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e ' sl ls ',
1
/
21
(,
1 Thus,. specific locations 2
COMMISSIONER REMICK:
Can I
ask a
3 ques, tion?
You made a
statement something about 4
components. orientation and I can understand that if it-o.
was a turbine generator.
But suppose it's a pump or a 6
heat,. exchanger?
?
MR.
REHN:
. Typically, the major 8
orientation.ot that particular-component would be-9 defined to allow for the necessary definition on pipe 10 routings and that type-of thing.
Certain minor 11 variations obviously will occur.when aLspecific. vendor 12 has been selected such that a nozzle location on a heat j,
13 exchanger might be slightly above or below.
But L,--
14 typically for space considerations and otLer.
15 interaction considerations, the envelope dimensions 16 would be shown on that layout.
17 COMMISSIONER REMICK:
So, in a room, if 18 you had a pump and a heat exchanger, you would expect 19 that roughly the location would be in the 20 certification?
21 MR. REHN:
Yes.
22 COMMISSIONER REMICK:
Okay.
23 MR.
RERN:
Specific locations of major 24
- piping, HVAC ductwork and cable
- tray, as well as
'25 specified corridors or layout zones or envelopes for
!b4 NEAL R.
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22 3'1; '
~
l=
the routings of other components must also~be defined.
2 The only difference then that would be observable if 3
you- 'were to go to different plants-would be those 4
differences in appearance that are due to the 5
potential for different component suppliers.
6 Typically, this would be' local variations in pipe 7
routings, cable routings, cable = drops going into the 8
equipment, and those necessary to simply al-low a
(
9 particular supplier-specific component to be utilized 10 in the overall system configuration.
'11
- Now, given that. this is the level of
'2 design information that's going to be submitted as.a y-13 part of the application and/or available.for audit as
-i
'14
-defined in part 52, should the design certification 15 rule encompass all of it, i.e.,
should the entire SSAR 16 become
'a part of the design certification rule?
4 17 Clearly, that is one option.
But let's evaluate the 18 practical we,rkability that's required to construct'and 19 operate one of these plants.
20 There are several issues that we believe 21 are associated with practical workability.
Let me t
22 briefly cover these.
First of
- all, as-built 23 deviations.
We believe that even the most complete-24 design will require some flexibility to handle l
L 25 devintions identified during construction.
Certainly lg L
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-l 23 p.
i; b-1 the-proper utilization of tolerances and the 2
development and utilization of modern' day CAD or-CAE J
3 techniques will minimize the needs for this type of a 1
'4 situation.
But it will not eliminate all of these.
5 In some cases, large tolerances-cannot be specified 6
due to cumulative or interactive effects or
'7 limitations of practical design; i'. e., as one begins 1
8 to try to open up tolerances, there is'a price to be 9
paid in terms of the engineering considerations.
10' Also during start-up, operation and. then 11 the. routine maintenance, problems arise.
Sometimes 12 components do not perform as designed.
Minor i
13 modifications to these components might be required to 1
14 ensure that they satisfy their functional 15 requirements.
16 Obsolescence.
During the time between the i
17 issuance of the design certification rule and' the 18 initiation and completion of plant construction, as 19 well as during the life of the facility, equipment may.
20 become obsolete and require an ultimate selection.
21 Lastly, equipment improvements.
Referring 22 to the Commission's statement of consideration, w e -.
^
23
.believe equipment improvements were anticipated.
24 Quoting again, "Moreover, the level of design-detail 25 and certification should afford licensees an FD NEAL R.
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r 7
- . - /_
. O,.
i 24 h'-.
1~
opportunity -
.to.
take - advantages of improvements in 4
2-equipment."
(
3 With consideration-for the above issuea, 8
4 we believe care 'must be taken to ensure that the 5
design-informatior.
contained in the design 6
certification rule was structured in such a manner so 7
as to achieve the safety and the standardization 8
objectives of Part 52, but do so'in a workable manner.
9 That ' leads to an obvious question.
What 10
' form r.hould the design certification rule follow to 11 accomplish this?
Marc Rowden will now describe a 12 p r o c e's s that achieves these objectives.
1 13 MR. ROWDEN:
Mr. Chairman and members of 14 the Commission, I'm here to present -the industry's 15 recommendations for what I would call the architecture-16 of the design certification rule.
That is the 17 framework for the. rule's design description and ITAAC s
18 content.
+
19 I think it appropriate to observe at the 20 outset that our task group did not inv'ent the so-l 21 called two-tier approach that I'm going to describe.
22
- Rather, that approach, through the structure of the-s 23 design certification rule, is based on the specific 24 requirements of Part 52 as explained by the 25 Commission's statements of consideration.
They J..
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25 r-1 distinguish between what will be-submitted forf NRC 4
2 review -in the design certification-application' and' 3
what' will be contained in the-design certification 4
rule itself.
5
- Now, the two-tier structure, I
would 6
emphasizs, is central to our recommendatione since it 7
provides the framework for certified-design and j
8 related ITAAC development and their design 9
certification and combined license implementation.
1 10 As to the design content of a
design-11 certification rule, the Commission explained that_and 12
- here, if you'll indulge me, I will quote from the 13 statements - of considerations,
- that, "There will be g
14 less detail in a certification than in an application
' 15 for-a certification and that a
rule certifying a l
16-design is likely to encompass roughly the same design 17 features that Section 50.59 prohibits changing without l
18-prior NRC approval."
19 Regarding the ability of a
combined 20 licensee or applicant for a combined license to make.
21' design changes, the Commission went on to explain that E
22 it would not adopt an industry proposal that Section
' 23 50.59 be made applicable for facility-specific changes 24 from the certified design and that it would also not 25 adopt recommendations by other commenters that no
(
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.l changes-from the certified designibe allowed.
- ~
2 Instead:the Commission stated, and again I L
3 quote, "The final rule prohibits a licensee of.a plant 4
_ built according.to a certified-design from making any W
5-change to any part of the plant which is described in c
6 the' certification unless the licensee has been granted l
7 an exemption under 10 CFR 50.12; while 50. 59. will' 8
continue to apply to the uncertified portion."
That's 9
the end of the quotation.
10 After recognizing these distinctions, the 11 Commission went on to' state, and again I quote, "How 12 much detail is present in a design certification will 7T 13 be - an issue that will' have to be resolved in each
. 'y 14 certification rulemaking."
And as earlier stated, and 15 again I quote, "The.( ommiss ion expects that there will u
16 be less detail in a
certification than' in an 17 application for certification and that a
rule 18 certifying a design is-likely to encompass roughly the f
19 same design features that 50.59 prohibits changing 20 without prior NRC approval."
21 And then the -Commission added, asE David E
22' Rehn has. also stated, "Moreover, the level of design 23.
detail in a certification should afford licensees an
.24 opportunity 'to take advantage of improvements in 25 equipment."
6.,
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c h.l 1-I want to emphasize that the.two-tier 2
structure which the industry recommende :is simply a 3
means for formatting and - documenting in the: design i
s 4
certification rule the certified and the non-certified
?
t 5
parts of the
- design, and specifying. the change 6'
mechanisms governing each, all in accordance'with the.
7 requirements of Part 52 which I've,just described.
8 The first tier would contain a description 9
of the certified design which we recommend-be based on.
10 SSAR Section 1.2 with detail comparable. to that.in 11 current SERs; the full array of inspections, tests, 12 knalyses and acceptance criteria which Part 52 f-~
13 requires; and any information which the NRC has 1
i.;._.
14 determined should not be subject to change under 15 Section 50.59.
16 The second tier would reference-the entire 17 SSAR design description.
Now, the SSA3 is the primary 18 technical document of the design certification 19 application and will, as a practical as well as a 20-regulatory matter, be the bas.is for the NRC's final 21 design approval and design certification reviews.
By
]
22 referencing the SSAR in the design certification 23 rule's second
- tier, the NRC would document the 24 features and commitments that were the basis for NRC 25 approval beyond those certified in the first tier and i
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.[2-
-I
. document as well, and here again I quote, this time 2
from the rule, Section 52.63(a)(4), " matters - resolved
~3 Lin connection with the.
issuance of a
design 1
4 certification."
5
- Now, the second tier would also contain-6 what we characterize as validation attributes: which 7
the NUMARC report proposes.
as a
bridge to 8
demonstrating compliance with those -
first tier 9
acceptance criteria that are not readily measurable or 10 otherwise verifiable by direct field inspection or 11 test.
David Rehn will deal with this later in more 12 detail.
I y
13
- Now, the design certification _ rulemaking-0, 7
14 would consider and resolve all issues covered by both l
15 tiers, including among these issues the design detail 16 to be included in each tier.
This is in - accordance 17 with Section 52.63(a)(4).
- Now, this resolution of 18 issues will be binding on later combined license l'
19 applicants and combined license holders.
It will be 20 binding on the NRC and it will be binding on any L
21 interveners in subsequent combined license and l
22 preoperational proceedings.
o 23 Fow, as to the two-tier desigt description 24 in the design certification rule, combined license 25 applicants and licensees will be obligated to comply I
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1 with all provisions in both tiers absent an exemption, 2
an amendment or another form of-permitted change which 3
I'll-describe in a moment, i
4
- Now, more specifically, the matters 5
covered by the first
- tier, that is the design.
6 described in that tier and the. ITAAC, those mattern 7
can only be changed through an NRC-approved' exemption 8
or amendment proceeded by a hearing opportunity a.id 9
.this is in accordance with Sections 52.63(b)(1) and 10 52.97(b).
11 Second tier matters can be changed without 12 NRC approval only if a change meets the requirements 13 of Section 50.59, again as prescribed by.
the 14 Commission's regulations.
15 COMMISSIONER CURTISS:
- Marc, on that-16
- point, if a second tier change is made through the 17 50.59 process.that you described, would that have to t
18 be proceeded by an opportunity for hearing?
19 MR.
ROWDEN:
50.59 would apply as it is
.f 20 presently formulated.
If it is a change which is 21 permitted under 50.59 without NRC approval, it would' 22 not have to be proceeded by an opportunity for I
23 hearing.
As a matter of fact, by definition, it would 1
24 not require NRC approval.
25 But let me interject something at this lL.
NEAL R.
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30 N {'-
clarify' our l
.l.
point because-I think that it will 2
proposal and.our un d'e rs t a ndin g of. how our proposal 3
. would operate in the ' design certification process and 4
.the later combined licensing-and preoperational i
5 processes.
6
- First, the NRC would determine initially 7
to what extent 50.59 would be applicable because it 8
'will be the NRC that determines what'goes in tier 1 l
9 and wh'at goes.in tier 2.
10 Second, that determination will be subject 11 to rulemaking consideration.
In other words, the L
12 rulemaking proceeding will consider not only what 13
. design content shall be in tier 1 and what design 14
. content shall be in tier 2, but the corollary, to what 15 extent 50.59 will-be applicable.
There will be an
'16 opportunity for public participation in that process, 47 something which does not now exist with regard to the 18 application of 50.59 to present' day operating 19 licenses.
20
- Third, I
do not view 50.59 as being-a 21-license to make unbridled changes to the design.
22 Number one, I don't think 50.59, as it's presently 23 structurod, allows that.
Number
- two, and I've 24 discussed this with my colleagues, I
believe that 25 there's going to be a
practical-disincentive for
{
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'l 31
[' ~ " '
1
' design certification applicants and combined license v
2 holders to overload the second
' tier with design E'
3 description that will be subject to 50.59 for several.
4 reasons.
5 One, there's no assurance that the staff 6
is going to approve a 50.59 change.
If it doesn't, i
7 then it will require an amendment and that would have-8 to be preceded by a hearing opportunity.
9.
- Secondly, there is a price you pay for 10 making a
50.59 change and that is
-that at a
11 preoperational hearing,' an intervenor can claim that i
12 the acceptance criteria have not been met because a 13 change that has been made under 50.59 did not comply i_.
14 with the criteria of 50.59.
So, as I say, there are 15 -
costs and benefits at tached to usirig that and I think 16 there's safeguards in the process.
That's a fuller 17 answer to the specific
- question, but I
think i t 18 requires a total appreciation of what we're proposing 19 to understand that proposal.
20
- Now, the two tiers
'of the design 21 certification rule would be incorporated by reference 22 in any combined license utilizing that certified 23 design.
The combined license would also contain a i
24 comparable two-tier description of the site specific 25 plant features and of operation related features I
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including the exte r ge n cy planning program and their
+-
N' 2
corresponding' cont Paatory specifications.
We believe i.
l 3
that the two-tier
- format, with the. contents as
-i 4
described and with the substantial constraints which j
5 I've also summarized, that that format produces a
r j
~6.
result which is fully consistent with the specific 7
requirements of Part 52.
8 Further and again I
would pick up_ the 9
thought that Dave Rehn initially emphasized.
'We have 10 tried hard to meet our understanding of the 11 standardization, issue preclusion and workability w.
12 objectives which we saw inherent in the Commission's 13
.Part 52 regulations.
14 MR..REHN:
Let's assume for the moment i
15 that the format and the content of the design l
16 certification applicati_ons and the associated rule 17 have been agreed upon.
An important part of the 18
-design-certification application and the associated 19 rule is the so-called ITAAC, the inspection,
- tests, 20 analysis and associated acceptance criteria that'are 21' deemed necessary and sufficient to_ provide reasonable s
22 assurance that if they are performed and the 23 associated acceptance criteria are met, that the plant 24 which references the design is built and will operate 25 in accordance with design certification.
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\\
1
- Thus, ITAAC forms the basis for the 2
verification process that will occur during 3
construction and preoperational testing.
Therefore, 4
we believe ITAAC is not a substitute for either lack 5-of design, lack of design details or for failure to i
6
. resolve safety issues.
7 Now, in defining the scope and the so1rce j
1 8
and the content of the basic elements of ITAAC, the.
1 9
tests were built upon existing regulatory requirements 10 and verification programs and made only those 11 modifications necessary to meet the requirements of 12-Part 52-or otherwise further the objectives of v
13 standardization and early resolution of issues.
The
~
14 concept of design features of a constructed facility 15 should be verified by inspections, tests and/or i
16 analysis is not_new to Part 52.
Indeed, in Part 50 17 licensing, applicants had to demonstrate and the NRC 18 had to find that a facility had been constructed in s
19 substantial compliance with the design as described in j
20 the FSAR.
i 21 Acceptance criteria, for example, should 22 be based upon and derived ~ from the general design 23 criteria of 10. CFR Part 50, Appendix A and similar i
l 24 high-level safety criteria, such as 10 CFR Part 100.
25' Although basically derived from the
- GDCs, the L-p NEAL R.
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t ii 34 r-1 acceptance criteria spplied under Part 52 will be more l
2 specific and more quantifiable.than the high-level 3
safety criteria contained in 10 CFR, Appendix A.
4 The standard review plan end modern FSARs 5
also contain numerous examples where some - of the 6
acceptance
- criteria, as well as the associated:
7 inspections, tests and analysis, can be abstracted and; 8
used as the starting point in developing the Part 52 9
ITAAC' requirements.
10 In the specific area of inspections', tests i
11 and analysis, an extensive and well defined systems i
12 testing program has been developed over the past 20 13 odd -years.
Chapter 14 of each SAR specifically-t 14 defines the testing to be: performed to demonstrate.-the 15 operational adequacy of
- each important system.
t 16 Chapter 17 of the SAR similarly documents the quality s.
17 assurance program and the referenced topical reports 18 which will provide the overall framewor'k for a
' 19 construction verification program.
We believe that 20 the Part 52 application should retain the Chapter 14 21 test program and the. Chapter 17 quality assurance 22 program.
23 The principal new program element 24 represented in ITAAC is a requirement for the pre-25 construction identification of and subsequent 9
L._
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v k
.;)'
4
,g+
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.f-.-
'L" I
documentation of concurrence with those inspections,.
2 tests' and analysis and their associat'ed acceptance 3
criteria.
To facilitate early and sequential t
i 4
verification of the adequacy of construction' by both 5
the. combined license holder and the NRC, we believe
't 6
the ' ITAAC should be organized to correspond.to the.
7 sequence o f con's t ruc't ion.
This will better support t
8 the combined licensee's sequential determination that
.l 0
'the ' segments of the ITAAC have been met and facilitate i
whst we have characterized as a sign-as-you-go process i
10 11 on the part of the NRC.
12 The key ITAAC programs resulting from the 13 considerations discussed above are:
m. _.
14
. Specification by the design' certification 15
-or the combined licens.e applicant of the pertinent 16 ITAAC.and their subsequent approval by the NRC; 17 Formulation and documentation of such 18 ITAAC principally from existing requirements and 19 verification programs; j
i 20 Sequential arrangement of these ITAAC to 21 promote early identification and resolution of 22 problems as they emerge; 23 Reliance on an effective quality assurance J
24 program for successful implementation of ITAAC; and 25 A complementary sign-as-you-go inspection i
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36
'F~
1 program with periodic public notices of the successful-1 completion of the ITAAC milestones.
3-Although'ITAAC in a sense are principally 4
a reformatting of information that is contained in the 5
SSARs and to -some extent existing verification 6:
programs, this discipline reiteration is necessary in 7
order to fulfill the ITAAC purpose, namely to provide 8
an expressed delineation of those inspections,- tests
'i 9'
and analyses and their companion acceptance criteria 10 that are necessar*
and sufficient to provide.
11 reasonab'le assurance that if met, the plant has been j
12 built and will operate in conformance with the design-l 17 described in the upper tier of
.the design l
t 14 certification rule and that of a combined license.
- i 15 It must be recognized,
- however, that
^
16 numerous inspections, tests and analyses beyond those 17 identified in ITAAC are part of an established quality i
18 assurance program and the associated-implementing-19 procedures will be performed in the course of 20 construction to verify all aspects of a plant design 21 residing in the lower tier of the design certification 22 rule, or the like tier of a combined license.
23 At the same time, the implementation and
.1 24 documentation of the quality assurance program 25-supports the upper tier inspections, tests and
+
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l analyses in establishment of conformance with the 2-acceptance criteria.
3 During the course of our work, it became 4
evident that certain acceptance criteria, typically 5
associated with analyses, may not always be amenable 6
to
. direct verification by-one or more field 7
inspections or tests.
An example of this might be the 8
seismic analysis that is performed on a.
building 9
structure.
Typically, these analytical methods, the-10 computer programs, the acceptance criteria and the 11 associated inputs or assumptions that will be employed 12 in these analyses are provided as part of the design i
13 certification, will be reviewed and approved as part i-14 of the design certification process.
15 However we find many.of-the analytical 16 inputs are associated with physical plant 17 characteristics, therefore the task group developed a 18 concept of what we call v'alidation attributes.
We
-19 chose these words simply to differentiate between 20 those inspections, tests and analyses that are defined i
21 as ITAAC within Part S2.
They are proposed to reside-22 in the second tier of the certification rule.
23 Functionally they reside excuse me, functionally 24 they can be thought of as a field measurable element i
25 that are more capable of being quantified and thus i
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i 38 I-1 readily measurable and otherwise verified through the 2
established quality assurance program the overall j
i 3
implementation of ITAAC.
They are a
- link, then, 4
between the traditional quality-assurance' program and 5
the acceptance criteria in those situations' where
'6 because of the nature of certain analysis acceptance 7
criteria direct verification by ' field inspection or.
8 test is not possible.
- Thus, validation attributes 9
serve to verify the validity of design inputs or 10 assumptions utilized in analyses previously approved.
la certainly we recognize that many 12 attributes may need to be included in-the overall l
13 ITAAC..
The thought for the thrust in f 't i s particular t-14 discussion was to differentiate between those of I
15 critical importance in assuring the safety and the 16 compliance with the plant and the variety of other 17 elements contained in a
typical quality assurance 18 program.
19 COMMISSIONER CURTISS:
Are there any other 20 differences that would attach to that distinction,.
21 procedural or otherwise?
22 MR. REHN:
Typically we are allowing them 23 to reside in the second tier and would be handled as 24 such as other elements of the second tier.
25 COMMISSIONER CURTISS:
Would you have any t
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. f t=
a f
i 39
- 7
' '~
l ITAAC in the second tier or would they all be --
f 2
MR. REHN:
No.
We propose.and view ITAAC 3
as residing totally in tier 1.
I 4
COMMISSIONER CURTISS:
Okay.
5 MR.
REHN:
Thus the challenge, the key-6-
challenge ci these Part 52 concepts is to identify 1 -
7 those critical inspections.. tests, and analyses which y
8-are truly necessary and sufficient to demonstrate f
9
'conformance with the acceptance criteria specified in 10 the upper tier of the design certification rule and
'll then to evaluate those inspections,
- tests, and 1
r-12 analyses and ultimately to demonstrate compliance with i
/-
13 the acceptance criteria-f L _.
14 Before I summarize on level of detail, I'd 15-like to briefly return to an earlier example that we-10 had on the HVAC system to draw your attention to a 17 couple of key point s.
In looking. at the definition of 18 information that we believe would be. supplied with the-19 system performance, we see a
variety of details 1
20-consistent with the functional definition of this 21
- system, such things as heat
- load, air flow rates, 22 cooling water flow rates, cooling water temperature, 23 and a variety of other information associated with-24 this functionality of this particular system.
1 25 In
- addition, if we are to look. at a
?~
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1 particular component contained in' one of the HVAC l
2
- systems, we propose and believe that the type of 3
information to be supplied would be very. specific, 4
such' things ' as the type of fan;- as we said ~ earlier, 5
the mounting orientation; flow rates; flow heads;.
6' motor types; motor ' sizes; service environment and I
c 7'
other key functional parameters.
-{
8 It is.our belief that this level of detail 9
as proposed satisfies all of the requirements of Part i
10 52.
Further, we believe that this level of detail i
11 will result in a standardized plant that meets not 12 only those specific requirements but also the l
r-13 standardization goals of Part 52.
Hence we believe I
14' plants will be built which are virtually the same from 15 a safety review, physical arrangement,. operating:end 16 training perspective.
17 Thank you.
I'd like to turn the program 18 back'over to Byron for some concluding remarks.
19 MR. LEE:
Thank you, Dave.
20 In conclusion, I want to thank you for 21 allowing us the opportunity to discuss first the 22 industry's interest in the future of nuclear power 23 what role we can and should play, we think, and our 24 implementation approach which we believe is consistent 25 with the new Part 52 Rule.
ll a
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The industry shares the' Commission's f
~
.2 desire to avoid building future generations of one of
-3' a kind plants.
The industry believes that the NRC's p
4 Part 52 Rule, coupled with the implementation. approach 5
that we've worked hard on for over a year and a half.
I 6
. and described today, will provide.the needed level of-7 safety and provide the predictable regulatory process p
8 also needed to allow utilities to include the nuclear 9
option in their near-term planning.
We also believe 10 it will produce a high level of standardization.
11 As you've he~ard this afternoon, the 12-industry believen timely completion of the design
~13 certification process is a necessary prerequisite to a 14 new order for a nuclear unit in this country.
It's 15 been.suggewted that there's no urgency to completing.
16 this process because no utility has stepped forward to 17 order a
new nuclear plant.
From the utilities' 18 perspective, the situation is just the opposite.
19 As Sherwood Smith has said, iae utilities 20 have a real need to begin plann'ing new base-load' 21 capacity, and for base load capacity the planning time 22 is now for the end of this decade and the early parts 23 of'the next decade.
But we feel unable to consider 24 the nuclear option until we've demonstrated that the i
25 design certification process works.
Until then, the
- p.,
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~
r l' r 42 1
j-1 regulatory uncertainty ma.\\es - the financial risks too 2
great.
i 4
3 I hope we've helped you understand the 4
utilities' position and our strong desire t o' move
{
and I want to-5 ahead steadfastly.
To do that the industry and we believe the NRC 6-emphasize here p
7 staff needs policy decisions from the Commission soon t,
)
8 in two areast
- one, the viability. of our -approach, O
9 especially the two-tier concept; and second, the level f
10 of design detail the Commission believes is necessary
.a 11 to meet the Part 52 Rule.
12 For nuclear power to figure in utility 13 planning in the 1990s for units in the first decade of
-\\L 14
.the next century we must set tough schedules.
The 15 industry urges the Commissioners to make meeting 16 schedules a high priority and to apply the necessary i
17 resources to do so.
l
'18 We conclude by stressing the need.for I
l 19 parallel review, which Sherwood mentioned before, of I
20 the EPRI ALWR utility steering committee requirement
\\
21 document and the two evolutionary ALWR plant design 22 certifications.
We believe that that can be completed 23 by.the end of 1992.
There has been an amazing amount.
c.
E" 24 of work done and we are, we believe, fairly close.
h 25 For passive plants we concur with the
^
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"M 1
' Commissioners' position that the passive requirements i
s 2
document review should be given the highest priority 3-to formally resolve the tiaj o r technical and policy
~4' issu-o prior to specific design reviews.
At the same f
5
- time, resources should be applied by the-staff' to 6-resolve. other necessary issues for passive plants i
7-which are not affected by the resolution of these.
8-issues.
We believe this approach is fully consistent 9
with the current Commission guidance in your June 6,
t 10 1990', SRM and is essential to - enable passive plant 11 certification to be accompliched consiotent with the
.12 utility needs.
We believe it's possible to learn from i
U 13 the evolutionary plant experience and to complete both
' kL I
14 passive plant design certifications by the end of 15 1995.
l 16 We ask that the NRC staff SECY paper. on 17 the level of design detail -- which you mentioned in 18 your opening rerarks, Mr. Chairman, will be discussed 19 this Wednesday -- be made public as soon as possible, i
'20 as the industry should have an opportunity to comment 21 on this paper since it will be of such critical 22 importance to the large ongoing efforts that we have 23 underway.
24 And now we have passed a
lot of 25 information on and we ask for any questions and L..s NEAL R.
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< c:
'~
l hopefully we can clarify anything that need be.
2 CHAIRMAN CARR:
Commissioner Remick?
3 COMMISSIONER REMICK:
First question for j.-
4 Mr. Smith.
You indicate -
you made a statement that
[.
5 you would hope that the NRC would allocate resources 6
consistent with the task at hand.
And. realizing l
7 that's really a matter for us, do you or industry have 8
a view on resources that you see us allocating?
Do 9
you feel that they're adequate for the task?
10 MR.
SMITH:
- Well, Mr.
Remick, we don't 11 have a number of people in mind.
My statement was s
12 intended as stated to encourage that an a ' equate
,r -
13 number of resources in terms of people, well-qualified-p 14 people, the right sort of project manager who can take 15 this*and drive it to a conclusion -- I personally have 16 no information that indicates that you have done 17 otherwise or would do otherwise.
It was just a
18 statement to underscore the urgency with which we feel t
19 this process should move along if we're going to do 20 it.
And we think we need to do it on a timely basis, 21 do it right but do it on a timely basis and don't let 22 it drag on interminably.
23 COMMISSIONER REMICK:
Okay.
Mr. Rowden, 24 is at safe for me to infer that your proposed two-tier 25 would not require any kind of rule change?
Do you
.F Li NEAL R.
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7
~-
,9 1 m 3
i i
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45 j'~,
I have en opinion on that?
.In other words, is it 2
consistent with current rules?
{
3 MR.
ROWDEN:
I quoted.. the ' Commission's.
L 4
language with some calculation.
Yes, sir, it is'my
[
5 Judgement that this structure is' fully consistent with.
6 the Commission's regulations and 'its explanation of 7
the regulations.
I 8
COMMISSIONER.REMICK:
And certainly it f
v 9
seems like the success of a two-tier would be the 10 ability to adequately specify what's in the two-tiers, 11 to do it concisely so there are few questions in the h
j 12 ture.
I think there are probably bound to be some t
13 f.,uestions that come up.
Has thought been given to L._
14 whether that can be done in a logical technical sense 15 to clearly identify what's in tier I and tier 2?
16 MR. REHN:
We have attempted to do that
.17 through the utilization of examples.
Clearly what we 18 found is once we had developed the process and the 19 guidance that we thought we were going to utilize, the 20 most difficult part began in terms of taking a
21 specific example and working it through this criteria.
22 We've done that to date and have in our report two
.23 examples.
One is a containment system structure, if
(
24 you will, and that was probably the easier example 25-that we chose.
There were a lot of issues there that k.2 NEAl, R.
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1 lend themselves to this.
And then we tackled a fluid 2
system.
That was a little bit more difficult.
3 It becomes probably even more difficult 4
when you get into such things as control sys6 ems, and 5
we're in the process of working through some of those G
examples now utilizing the real time work that is 7
ongoing by the various suppliers that are in the 8
design certification design process right now.
9 Yes, we believe it is workable.
10' MR. LEE:
I would edd, Forrest, I believe-11 that the three manufacturers and the gentlemen sittir.g 12 behind me here have all been actively involved in this 77 13 effort and that it's been developed in such a way that hs 14 they believe it can be applied practically and are in 15 fact in the process of trying to utilize it.
16 COMMISSIONER REMICK:
So you feel that 17 you've looked at enough examples that you feel that it 18 can be done so that there would be few questions later 19 on?
What's in tier l?
What's in tier 2?
20 MR. LEE:
Well, the primary objective, I.
21 think, as Mare had pointed out, is to avoid questions 22 later on.
23 COMMISSIONER REMICK:
I
- realize, but I
24 also realize these things are very complicated and 25 somebody reading it five years from now might read it vk.
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I differently than somebody might specify today.
I'd 2
anticipate there-would be a few questions arise at 3
least in the future, but I would hope that not a lot 4
of questions.
5 MR.
ROWDEN:
The - advantage of the two-6 tier, Doctor Remick, is that one specifies with great 7
particularity what is in each tier.
I'm sure there 8
are going to be questions between the design 9
certification applicants and the staff as to what is 10 appropriate or desirable to put in one tier or the t
11 other from-the standpoints I mentioned, not the least 12 of which is the latitude for making changes.
I 13 The challenge now is to get on with the 14 Job and the critical path item that we have to 15 confront is the need for guilance as to, A,
whether 16 two-tier is acceptable and, B,
how it interfaces with 17 the level of detail requirements of Part 52.
18 COMMISSIONER REMICK:
If there wa= a two-19 tier system -- and let's say that you had an item ; hat i
20 was in tier 2 and during construction there was some 21 problem arose and the utility or the constructor 22 decided to modify that going through the 50.59 process 23 appropriately would that open up that being 24 s ub,i e c t,
- though, to discussion in a hearing on the 25 combined license on whether the plant was built I
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{-
i 1
according to the --
l 2
MR. ROWDEN:
That would be something that 3
would not arise, I believe, at the combined license t
4 stage but at the preoperational stage.
f-5 COMMISSIONER REMICK:
Preoperational.
6 MR. ROWDEN:
It opens the possibility that
'7 an intervenor can come in and make a substantiated
.' 8 claim that this change did not meet the requirements 9
of 50.59 and tie that to a further claim that as a 10 result the acceptance criterin'have not been met.
And 11 that is a risk which, as I've indicated, we are very 12 sensitive to.
So this is not a process that we would r-13 adopt or apply in a cavalier fashion, simply from a
.(,
14 standpoint of wel f-interes t.
15 COMMISSIONER REMICK:
Okay.
Another 16 aspect you mentioned.is this -- yes?
17 MR.
LEE:
It seems to-be consistent, 18 again, with practice today that 50.59 alterations are 19 reported periodically.
So there is an opportunity for 20 somebody to challenge tnat and hopefully the system 21 would be such that they'd have to challenge those 22 early, again, that we can't, again, afford to wait-to 23 get through all of the allegations at the end of the 24 process.
25 MR.
PARLER:
Of
- course, Commissioner NEAL R.
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6-o; 49 l-Remick..most of the 50.59
- issues, at least as I
2 understand it, come up after an operating license has 3
been issued.
And the purpose of the 50.59 was to 4
distinguish between changes which could be made 5
without prior commission approval and amendments to 6
the license which might require an opportunity for a 7
hearing and indeed a hearing.
8 COMMISSIONER REMICK:
No, I
understand 9
that.
But under the Part 52 it seemed to me we're 10 locking in very tightly changes could be made, and it 11 seems to me that in the items that were in the second 12 tier during a
construction you might encounter a
r 13 problem with other 50.59 you could make the necessary N
14 changes without going back to the Commission and 15
-asking for an exemption under 50.12 or something like 16 that.
And I was just wondering if this was done 17 doesn't that open up the possibility for litigation 18 and a hearing?
19 MR.
ROWDEN:
It's not an open-ended 20 pessibility, but it is a risk which any licensee who 21 makes such a change has to confront, also has to 22 confront the prospect of the staff disagreeing that 23-that change is appropriate.
24 COMMISSIONER REMICK:
Sure.
25 MR. ROWDEN:
Again, this regime, if I may k.-l l
I l
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j 50 i
I characterize it as such, is I think preferable to and 2
more disciplined than the.present 50.59 regimp which 3
applies to operating licenses, not that that regime is 4
inadequate.
It's that in reviewing the application 5
and in conducting the hearing, the role of 50.59 is 6
not an issue in present operating license proceedings, 7
whereas it would be a matter very carefully looked at 8
by the staff and examined in the course of the design 9
certification proceeding.
Again, another check on the 10 process.
11 COMMISSIONER REMICE:
Do you foresee any 12 need for change in 50.59 for this to be usable?
13 MR.
ROWDEN:
We looked at that very 14 carefully and it's our conclusion that 50.59 is 15 adaptable as it's written.
16 COMMISSIONER REMICK:
One other item you 17 mentioned that fascinates me because I've been in 18 favor of it for a number of years is sign-as-you-go.
19 Has anybody looked at the questions there from the 20 standpoint.of our regulations?
Do they permit sign-21 as-you-go, the current regulations?
I realize that 22 part 52 is new and perhaps would, but has anybody 23 looked at that closely?
24 MR.
ROWDEN:
We've taken a preliminary 25 look at that.
We've addressed it-in a preliminary AI :.
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i 51 1
fashion in the ITAAC report that this is one of the 1
1 2
areas that we identified for further study.
3 It is our view that Part 52, as applied in 4
large part to the staff inspection processes that are 5
presently in place, would lend themselves to a sign-6 as-you-go process.
As you may recall, in the Vogtle 7
proceeding there was a type of sign-as-you-go.
Much 8
useful experience has been gained from - that.
We 9
believe it can be ef fectively applied here, but we do 10 need to do m6re work on that before a specific process 11 can be put in place.
12 COMMISSIONER REMICK:
It was the Vogtle 1
13 experience that made me feel that that was a very good
\\a 14 concept.
15 MR.
REHN:
We've had quite a
bit of 16 discussion on the Vogtle experience and we are in the 17 process of developing that to a greater extent than 18 what we have to address some of the items that we 19 believe should be at least discussed prior to entering 20 into that process.
But, yes, we think there's a good 21 healthy precedent there.
22 COMMISSIONER REMICK:
Kind of a couple 23 comments.
One on the level of design detail.
It's no 24 question it's an important issue and it came up, as I 25 recall, several years ago with ACRS in a letter to the I,.k,_
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e.
52 1
Coumission.
And I
must admit I'm a
little 2
disappointed that about five months before the i
3 previously scheduled date for the FDA for the first j
i 4
plant going under certification that we're still 5
discussing it, but that's understandable, I
- guess, 6
when we get into the detail.
But I am disappointed at 7
this late date we are just discussing it.
8 I am convinced that in the process we need 9
some kind of a controlled flexibility.
I find the I
10 two-tier concept an interesting one.
I'm not sure I r
a 11 completely understand it, but I
certainly have a
12 better understanding after today's discussion.
And I r
13 bring L.41s up to urge my colleagues.
\\.
I think it is an 14 extremely important subject that we should give our 15 top priority to resolving, because I think it's going 16 to influence the schedule for the certification review 17 by the staff and certainly in the submittal from 18 applicants.
19 On the broader issue that, Mr. Smith, you 20 brought up, a stable predictable regulatory process, I-21 feel compelled to make a
couple comments.
Since 22 joining the Commission, I've become concerned that 23 we've lost our awareness in the Agency of the amount 24 and the type of effort that it takes to do a thorough 25 and timely licensing review of nuclear power plants.
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We've gotten kind of rusty.
.I think, and we've lost 2
some people and we have peopl 9 doing things other than 3
- reviews, 4
And as I see it, by mid-1992 we expect to 5
have in-house four applications for design 6
certification of several evolutionary and several 7
. passive plants, and these are all new designs and 8
they're being reviewed under new regulations both for 9
certification and for licensing.
And I see for the 10 first time in a decade international interest in'U.S.
11 nuclear technology.
There's a considerable amount of 12 interest overseas in what we're doing both in the 13 evolutionary but also in the passive areas, and people 14 are extremely interested in what are the NRC views on 15 these designs.
And for the first time in a decade I 16 see the opportunity for' the U.S.
to be a leader in 17 this technology.
18 Now you folks today and the Department of 19 Energy tells us that certified designs are essential 20 for any orders and that industry is interested in 21 having the nuclear option as one of the options for 22 providing electricity to the country.
However, I am 23 concerned because I
think we mide some recent 24 decisions which cause all of these design 25 certification reviews to slip.
i k-1 NEAL R.
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'~
l And so I
can't help but express my i
2 personal concern that this Agency might be the one 3
that precludes certified designs being available at 4
the time, perhaps, when
.U. S.
utilities would like to 5
have that as one option to consider.
And if we do 6
- that, I'm afraid we're going to be derelict in our 7
duty and that concerns me very much as a commissioner.
8 I make those comme.ts at this time mostly for the 9
benefit of my colleagues and I do it respectfully, but 10 I do have a personal concern that we are not finding 11 the resources necessary to come anywhere close to 12 meeting the schedcles that you folks are telling us 13 that.you're dependent upon to make the proper orders.
r-3-
14 With that speech, Mr. Chairman, I pass.
'15 CHAIRMAN CARR:
Commissioner Rogers?
16 COMMISSIONER ROGERS:
I wonder if you-17 could comment on a couple of things.
One is how do 18 you see proprietary questions dealt with here in the 19 two-tier approach and in the
- well, in the 20 certification,- you know, document *t 21 MR.
HOWDEN:
It's a
question that 22 transcends one-cier or two-tier.
The Commission's 23 regulations deal very specifically with the 24 appropriate protection to be given to proprietary 25 information.
There may need to be some further l
L__
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implementation, internal implementation of those 2
regalations, but we believe that' they provide an-3
' appropriate framework for safeguarding ortmaintaining 4
the proprietary status of that-information and at the 5
sama '.ime conducting a meaningful design certification 6
pro ~,,ing.
7 COMMISSIONER ROGERS:
Well it sounds good, 8
but I'm not sure I understand ~ exactly how it's going 9
to work because the design certification is a public 10 document.
11 MR. ROWDEN:
That's one of the issues that 12 we addressed in the comments that we submitted to the 13 Commission on proposed Part 52.
The Commission w_
14
-initially proposed that proprietary information be 15 dealt with in design certification proceedings in the 16 same fashion that they're dealt with in other 17 rulemaking proceedings.
Those were the provisions 18 that were "on the books" with regard to protection of 19 proprietary information rulemaking proceedings.
20 We urged and the Commission agreed to 21 treat proprietary information in design certification 22 proceedings in the same fashion that they would be 23 treated in licensing proceedings, with the same-right 24
-of access and the same degree of privacy.
Those 25 proprietary ground rules, so to speak, in licensing 1 i
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56-
{:
'l' proceedings have' proved to be effective 'in practical 2
usage and that is what.I'm referring to specificall.y 3
as. the basis for application in design certification 4
proceedings.
l l
5 So I hope.--- and I share your concern that
[
6-it doesn't.just sound good, but there.is basis in-
.7 experience'to believe that we have the framework for a 8
workable process.
9 COMMISSIONER ROGERS:
It seems to me that U
10 some: systems for example,. fire protection may-11 require more specification of the.
detailed i
12 configuration than other sys tems.and that it may be 13 acceptable to have some systems that are specified f'
14 only at a functional level while others really have to 15
,o detailed design configuration to answer certain 10 saietyr outstions.
How have you dealt with that in 17 ovr ng?
18 MR. REHN:
Well, I guess in a couple of.
19 m-irst of
- all, we agree that the types of 20 information that we've described and the level of 21 opecificity associated with'that will probably tend to
~!
22 very from some systems to others.
Clearly, we believe 23-Part 52 states that that level of detail that the
-i 24 staff needs to make its safety determinations must be
.25 available and must be provided.
And to the extent 3L_
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'~
1 that that has an: impact on the resolution of a safety.
2 issue,-then it must be made available, and that is the 3
direction, that we are headed in with that 4
anderstanding that on some systems that_ level of 5
2nft;mation-is necessary and yet.on others it is not, t
-6 CCWu %IONER ROGERS:
Is it conceivable 7'
that for some designs what you might include in tier l 8'
-and tier 2 would-be different from other designs?
Can 9
you settle that question of what goes into T-1 or T-2 10 independent of design?
11 MR.
ROWDEN:
I take the Commission's.
12_
guidance at face value.
That's exactly what you said-13 and I think :that's the guidance we have to, live with, w__
14 It may well be different from-one design to another.
15 COMMISSIONER ROGERS:
You admit that 16
-possibility?
17 MR.
ROWDEN:
Yes.
- Well, the Commission 18 itself has specified that possibility.
We accept that 19 as a reality.
20 MR. LEE:
And especially with the BWR and 2'l PWR, obviously there would be some changes.
22 COMMISSIONER ROGERS:
I think I'll turn it 23 over to you.
24 CHAIRMAN CARR:
Commissioner Curtiss?
25 CHAIRMAN CARR:
I do have a number of NEAL R.
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.1 questions.
Let me begin with the comments that'I-have i
2 in picking up on the remarks that Commissioner Remick 3
made.
4-There's been a good deal-of discussion of-S the schedule question.over the past couple of months-6 and you picked up that and emphasized that point here.
7 Additionally, we've just received a letter from the
'8 Department of Energy dated July 16th from. Assistant 9
Secretary Young.
10 I agree with Commissioner Remick that we 11 ought to' commit the entire range of. resources that we 12
.need to keep these reviews on schedule and I think the 13 Commission is committed to doing that, and if'we're 14-not doing that I guess I'd like to hear from your-15 perspective whether~you think reviews are slowing down 16-to-a greater degree than we're aware of so that we can 17 redouble our commitment to apply the necessary 18 resources.
19-At the same time, there are some complex 20 questions that go beyond just the commitment of 21 resources that the Commission has addressed' in a
22 series of SRMs that the staff received last year, and 23 I take it that you're familiar with.
24 I must say I'm frustrated by the comments 25 on the schedule, particularly in the DOE letter, but I l
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1 gather is suggested ' here.
You're familiar with the 2
SRMs and if-you take a look at'what they do it seems 3
to me they boil down the Commission interest.to=three 4
basic objectives:
number-one, the Commission
'ha s -
5 expressed an interest,in being involved i n.- t h e major 6
technical inoues that arise in these. design. reviews; 7
number 'two, at an early. stage in the process-as a
8-opposed to waiting for a design ~ certification; and 9
number
- three, with the EPRI requirements document 10 serving ns the vehicle for resolving technical issues 11-that
'are common to a
given.
class of
- plants, 12 evolutionary and passive.
i 1.
13 Now the question that I guess I have, is L._
14 there anything in the guidance and-you're certainly 15 familiar with it to one. degree or another -- that you 4
1 16' think-the Commission has laid out that would implement 17 those;three objectives that in your judgement needs to 18 be modified or changed in some respect?
19 MR. LEE:
I guess in general -- and'I'll
'20 ask others here to expand -- I think that the approach 21 that the Commission has taken in the recent past, 22 there was concern initially that involvement would 23 cause additional delay and slippage.
I think that in 24 fact the understanding I get from the various people 25
- involved, including the EPRI requirements document, 3
4
- 1...
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, ]='
1
.that things are moving' ahead on-a fairly rapid and 2
~ escalated scale at this point in time.
So they~seem-3-
to be' moving ahead on a steadfast manner.
4 I think that there was one question that 5
is-in one of the SRMs related to th'e 1-icensing' review I
r 6-basis document,'and I think that.the.EPRI and'_ GE 'and 7
Westinghouse are looking ' at.thst issue and trying to 8
develop what they consider to-he the proper approach 9
and which is what I've tried to say here.
There are 10 things that can be reviewed and should be reviewed.in 11 the -- - wi th regards 1t o schedules that ought not be
'I
-r 12.
held back, that can be done in parallel in that effort r-13 also, commissioner.
1 14.
I don't know i f Dave - or Marc --
15 MR.
ROWDEN:
- Well, I'll offer some 16 observations. from my own. perspective.
One is simply 17 to speak the reality of the time -that's consumed in s
18 the process of Commission / staff interaction.
Sorting
'19 these watters - out has taken time.
That
- time, 20 particularly on the part of the staff, has invol'ved 21 people who would otherwise be working on-design J
22 reviews and I think we have to confront that reality 23-and recognize what the price is that you have to pay 24-for this process of defining exactly what the -- the 25 process of defining what the process is.
That's i.
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- )
di
.p 61
,g
-l'
. observation number one, p
2, Observation number two.is my sense of
-3 surprise, frankly, that the level of detail issue has t
4 at-this stage become such'a major impediment to moving 5
forward, and I = say this as someone who is involved-6-
intensively over a period of some. two years if not.
7 more in interaction on behalf of the. industry with the' 8-Agency in helping to define and commenting on' the 9
_ contents of Part 52.
And Part 52 is not a blueprint 1
7 10 for everything.
Nobody claimed that it was.
But i f-l~1 '
there was an issue that was ever identified,.
12 discussed, comment'ed on between the-Commission and:the
- 13
- staff,
-between the Commission and the
- industry, 14 between the ACRS and the Commission it was level of 15 detail.
And frankly, we.believe that Part 52 coupled 16 with the statements - of' considerations gave.rather 17' explicit' guidance on level of detail.
18 I'm not saying that this is not n
19 legitimate issue and that standardization concerns are 20.
something that should be dismissed.
I am saying that' 21 l'evel of detail has been an enormous consumer of time 22 and now it's become a very critical, critical path
-23 item.
24 COMMISSIONER CURTISS:
- Well, I guess I'd 25 encourage you if you -- in fact, I brought them along.
- y
' i U_
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1:
here' just. to refresh my; own memory on what we've 2
wrought over the'last year or so if you have any 3
suggestions :after reviewiug the staff requi~rements-4 memorandum and the SECY paper in more -detail as to 5
procedural process questions that you think -- and by 6
that I mean.the Commission process vis a vis the-staff 7
and the ACRS that you think need to be redressed, 8
I'd like to.know the particulars of that so that we 9
can wrestle that down.
10 I must say I am frustrated,
.f o r' example,
11 that with some of the complex questions that-we' re 12 dealing with now like level of design detail -- and I-
. r--
13 share your frustration that - we're still dealing with
\\.
14
-i t a year and a half later: -- the NEPA question on 15 design certification, -the emergency planning exercise 16 question, Part 52 is a significant difference in the
-17 way that we' ve done-business - around'- here and I think 18 we all positively agree with that.
19 It's frustrating then in turn for the 20 schedules that were agreed to two years before Part 52 21 was promulgated to be the focus of or the
-22 benchmark, if you will, from which departures -are 23 measured now.
I suspect there are going to be some 24 changes in the schedule for those schedules that were 25 reached at that point in time.
And as I say, I think I~ki NEAL R.
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[O g _
o4 9
4 63 l-the Commission is committed. --
or at least-I 2:
personally am and I think the others can. speak for 3
themselves -- to committing the. resources necessary on 4.
'our end to make sure that resources aren't the pacing n
5 item.
6 But-as I say, if you have any' comments'on 7
the process th'at we've established, I'd be interested 8
in your particular suggestions.
9 Let me get-to actually-the subject of this i
[
10 meeting, because I do have a number of questions.
The
=6 11 topic that's puzzled me let m'e go back to the ACRS 12 meeting of last week..
In reviewing the transcript of j
/
13 that meeting, one of the NUMARC ptesenters in talking y
14 about the relationship of the Part 52 process of 15 standardization and the level of design detail made 16 the following statement.
"However, we feel 'at this j
t 17 time that standardization should not be imposed. by 18 regulation."
That's a comment that we heard. earlier.
19-Can you expand on that?
Because, frankly, 20 I
thought that was what Part 52 and design 21 certification.was all about.
What's your perspective-22 on that?
23.
MR. LEE:
I'm not sure where that comment 24 came from, but I guess that may have been a comment 25 out of frustration on the definition of what i.
' Y.,,..
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.i.L-1 standardization-means, and w e m a y -. b e talking about
'2
-that for.the next five years also.
3 COMMISSIONER CURTISS:
Wel1, I'Il read you 4
some.of the background.
It's by Mr. Eng from NUMARC.
5 "In other
- words, for the staff to make' its-1 4
U 6
determination of adequate safety of design,- it's not' i
1
,~7 our intent-during our' briefing," referring to the-ACRS' 8
- briefing, "today.to discuss standardization.
We 9
certainly recognize that there is a significant. amount 4
10 of work that needs to be done with regards: to 11-standardization.
The Nuclear Power.
Oversight l
12 Committee has asked NUMARC to.
coordinate varlaus r- -
13 activities with regards to assessing options for 14 enhancing standardization."
Then the
- comment,
'15 "However, we feel et this time that standardization 16' should not be imposed by regulation."
17 MR. LEE:
I'm not sure what the basis for-18-that was.
19 COMMISSIONER CURTISS:
Okay.
I guess I 20 raised that question because I think Doctor Murley i
21 raised the same point in 'the earlier briefing in
.22
- April, and I
gather that there are some economic
-23 considerations that may be involved in the ' extent to 24 which standardization is driven by the regulation.
25 And what I hear you saying here is that the safety a.k2 e
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4 65 Fm.
iO
- l' information -- that information which is'necessary for 2
the1 Commission to make its safety findings -- ought to-3.
be what we focus on, with requirements beyond that 4
that might' achieve standardization or continue to 5
foster it, I guess, being outside ofc ' the - regulat ion 6
itself.
~7 MR.
LEE:
- Well, I think that,. as we'.ve 8
tried to say several
- times, we think that the 9
utilizailon of Part 52 and the appronch that we're
- 10 talking about here will in fact result-in
'a high 11-
- degree, a
high level of standardization in these 12
- plants, that the - variations from the first, second, 13 and third units are going to be very small' for the
\\._
14.
reasons that I think Mare has discussed before.
The 15 hazards of that are'very great.
16 And I just have a note that we're talking 17 really -- and I think Ray Eng'was talking beyond the 18 design situation but into some of the additional areas 19 o f standardization.
20 COMMISSIONER CURTISS:
Beyond Part 52 21 issues.
22
- Marc, let me turn to the two-tier 23 approach, because I have a couple of questions about 24 that.
25
- First, if I
understand what you're 3
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.o;e 66 PS
- ~.3 c:
11 proposing here, t h e. t i e r.- l information1that wotild b'e 2-submitted-both ifor the design certificate and with a 3'
parallel approach for' the COL would _ be could-be 4
modified only through-an amendment or an exemption 51
=under part 52 --
6 MR.-ROWDEN:
Right.
7 COMMISSIONER CURTISS:
which would in 8
. turn' require-the opportunity for a hearing under --
9-MR.-R0WDEN:
52.97.
10 COMMISSIONER CURTISS:
-- 52.97, right..
11 I guess the first question I have is.what:
12 level of-detail nre you talking about in ' tier 17 I
+-
13 read your statement here that the first. tier would
~
y 14 contain.'a description of the certified design based on 15 SSAR section 1.2 with detail comparable to that in 16,
current SERs.
SERs on section 1.2 or the entire SER?
17.
How much are we talking about?
18-MR.
R0WDEN:
The comparable section of 19' l.2.
When we began to prepare our-recommendations 20 with regard to the specific contents of a desie.
21 certification rule, it became clear to us tnat it was 22 going to be difficult to deal with this simply in 23 conceptual terms.
We do have in an appendix to the 24 NUMARC ITAAC report e description in conceptual terms 25 of what the c acents of tier 1 would be.
It's based
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- u 1
on 1.70.
It's' based on'the contents oflthe standard.
2 --
review' plan, and it relates to SSAR:section 1.2 --
.~3' COMMISSIONER CURTISS:
Right.
4 MR. ROWDEN:
--- which we concluded was too i
^5 sketchy.
We wanted at -least a-level'~of ' detail 6
equivalent to that in an: SER.
That's a proposal.
1.<
7 That's not required by Part 52.
That's a: negotiation,-
8.
if I might say,. thats going to take' place between the 9-applicants and the staff and the Commission.
10 so b a s i c all y ~, what I'm saying is it ought-11 to be sufficiently detailed to assure the Commission i
12 that - we are appropriately applying the very severe r
13 constraints that 'are. contained in 52.63 and 52.97(b)
Q.:
14-and appropriately applying to the secon'd tier with.a 15 greater latitude which is allowed by 50.59.
16.
We have
- given, beyond the conceptual
\\
17 description of level of detail, examples in our report 1
18 of how we would deal with level of detail, I believe,
-19 for an ~ aspect of the containment and the RHR, if I'm 20 correct in that regard, David, of what would be in 21 level 1 and'what would be in level 2.
.So we've tried i
l 22 to give that specific content.
Beyond that, it's 23 going to be a matter -- it's going to be an iterative 1
24 process between design certification applicants.and 25 the staff --
p
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~
1-COMMISSIONER CURTISS:
If we wanted to get o
2 a - representative. idea ofJwhat kind of level of detail 3.
was contained-in tier 1, what you're saying is we'd go
'SER-for chapter 1.2 of the - FS AR and'that's-the-4 to an 5
kind of detail we could expect'to see?
6 MR.
ROWDFN:
That's
- right, as we have.
L
7 translated that into a specific example in an appendix 8
to'our ITAAC' report..But again, as I say, this is not.
9 something that we derive froe Part 52.
q 10 The only guidance, if you're looking for j
- 11 Commission guidance, I quoted it several' times in the l
12 course of my presentation because it's the only l
13 guidance that the Commission has
- given, that what.
L q
14 would. be in the design certification are those
]
15 elements of the design that couldn't be changed under 16 50.59.
I t.
17 COMMISSIONER CURTISS:
Okay.
-I guess I l
I 18 have one other comment.
You make a
forceful 19 presentation for the tier 2 approach.and, in fact, quoting l
l l
20 from the language of the Commission set forth in the i
21 statement of considerations.
What I gather you're.
22 talking -- what I gather you're proposing here is that 23 true standardization would consist of level one-24 information or, to put it differently, to the extent 25 that level two could be changed through a
50.59 i
P t
L..:
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}-
'c
.g 69.
a..
.1-process.
And'to the extent that changes l'n the design 2
move us a w a'y from~ standardization, in~ focusing on the 3
degree'of standardization we want to achieve, we.ought 4
t'o look at the four corners of tier 1 information.
5 MR.
.ROWDEN:
No,.
air, 'that is not my' S
-position.
7 COMMISSIONER CURTISS:
He's shaking his 8
head.-
e 9
MR.
ROWDEN:
- Well, I
take respectful 10-exception to that.
I believe one has to look attboth 11 tiers.
I tried to make it clear that what.the 12 Commission reviews, what the Commission approves,.the 13 obligations which later. applicants for a-combine j'
A __
14 license and combined license holders ac cept are the 1
15 requirements of both tiers.
Both tiers are hinding.
~
16 The;e is greater latitude, not unfettered latitude,-
17 greater. latitude for change in tier 2, but you cannot 1
18 look at the standardization effect of the two-tier i
19-process.
f 20 Forget about the t *:o-t i e r process.
The 21 two-tier process simply is a formatting of what the 22 Commission says in Part 52.
You cannot look at that y
i 23 without looking not only at what the Commission 1
24 certifies in the
- design, but what the Commission 25 approves in the application and in the total design I
',=
L t
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< ?.9... -
m
} i' u
-d!
70 4
ys
~j
- 1 certification proceeding.
That is what you look at-P f
2:
to,determinefwhether you have an. appropriate: degree of 1
3 standardization.
)
4 MR. REHN:
But I think the point you were
.5-making certainly was~along the lines. that if you have f4 6
something in tier 2 that you know -is going to be 7
subjected to the possibility of changes under 50.59.
t 8
and' to the extent that that is-not a consideration
~l l
9 that you deem appro.priate, then consideration would be 10 given to move it into tier =1.
I think I agree with 11 what Marc is saying.
12 MR. ROWDEN:
That=I agree with.
r-,,
13 MR.
REHN:
I'm. Just going,. I think, on
- .l 14 what I heard commissioner Curtiss say.
i 15-COMMISSIONER CURTISS:
All right.
1 16 That's all I have, Ken.
17:
CHAIRMAN CARR:
Well --
18 COMMISSIONER CURTISS:
That's really 'not 19 al'1 I have, but I'll turn it over here.
I have more 20.
that I would pursue if we had' the time, but I'll 21 pursue it individually.
22 CHAIRMAN CARR:
Nobody's pressed you.
23 COMMISSIONER CURTISS:
I'll come back if 24 we do.
25 CHAIRMAN CARR:
As far as commenting on
.!L._
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~
1-the
- schedule, with -all due respect to my fellow 2
Commissioner over here, the schedule is nat'nearly as 3
.important to L me as doing it right because what we're 4
going to do in this particular situation we're going 5
to have to live with for the next 40_or 50 years for G-sure and I don't want it to do like the last 40 or 50
- 7' years.
So,-
it's more important to me to make sure i
8 that what we put in place here i s what we really want' i
i 9
to put in place than to fret about whether we lose-a 10 month or two months or three months on the' schedule.
11 My experience with-schedules and buildings,of plants, 12 two'or three months has not been critical in most of-13 the plants we've built anyway.
i L _._
14 It seems to me the' big question here we're 15:
discussing in all this is -- the numbers may be wrong, 161 but it costs about
$600 million to get the final I
17 design that somebody can start cutt-ing. metal and l
j
~ 18 building a plant.
The question we're arguing about is 19 who's going to put up the money, whether the guy who j
20 is going to design the plant is going to put it up and i
21 then the utility is going to buy it or whether it's
. l 22 going to be a cooperative venture or just the buyers j
t 23 are not saying to me, "I'd buy it if it was 24 certified."
I gucas that's what I heard today, "I'd 25 buy it if it was certified."
i
}
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4 72
]' '~ -
f
'l My ques tioni to - the vendors :is, why_ don't 2
- you ' get n'. plant-certified so they can buy-it,-
a-j 3
complete, ' fully equipped design so they. know what 4
they're putting their money out for?
That puts it 5
right where it: is today, who's going to put up the 6
money to buy the design.
7 That's my opiniion.
Do you want to comment 8
on that?
9 MR. LEE:
Well, I think that is the major 10
- question, Mr.
Chairman, as to where do we find the 11 money to do that.
I'think it's_ highly unlikely that 12 the utilities in today's situation will be able to or 13 can --
- e- --
t 14 CRAIRMAN CARR:
But they're going to pay i
15 that bill-somewhere.
That design doesn't come for 16 free.
.l
' i, 17 MR. LEE:
I understand --
18 CRAIRMAN CARR:
It's a question of whether 19 they pay it up front or they pay it at the end.
20-MR.
LEE:
Oh, 3 think what Sherwr sd was i
21 saying.
-there's a
significant difference between 22 making a commitment before
'ie know that the precess 23 can get something through the design certification and 24 making it after that in terms of prudency with the 25 public utility commissions.
I think that's they've i-L__
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i b
1 all been burned very badly in that respect.
2 CHAIRMAN CARR:
The~ object of'ihis drill 3'
was to get that design certified-before anybody 4-started spending billions of dollars building a plant.
.a :
5 MR. LEE:
Well,- I understand, but I hate 6
to sound naive, but hundreds of millions of dollars-is 7
also large amounts of money.
I don't think that 8
the 9
CHAIRMAN CARR:
Let me-rephrase the 10 question.
What peicent of the total plant engineering l
11 do you expect to be complete at design certification
-l 12 using your tier 1,
tier 2. proposal?
How much of the:
i 1
13 design engineering is going to be done?
What cm I 4 L--
]l 14 certifying?
15 MR. LEE:
Design ~ engineering.
)
=i 16 CHAIRMAN CARR:
Something a guy can build.
17 MR. LEE:
Pardon?
18 CHAIRMAN CARR:
Something a guy can go out 1
19 and start building.
20 MR. LEE:
Dave o r --
21 MR. REHN:
Well,'that's a question I know i
22 we've wrestled that and it's been asked to be i
23 quantified in terms of dollars, in terms of numbers of 24 drawings
- released, in terms of the size of the 25 calculations that may back it up or the specifications i
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i 7_4 _
' h-I that are --
ti 2
CHAIRMAN CARR:
It would mean more to-me-3 if you'd just say percent of drawings that are issued 4
to the guy who is building.
Let's put it that way.
~
5 MR. REHN:
We made the~ distinction when.we 6
were working through this process of separating what t
.7 we call design details and what I
would call 8
construction details.
I'll give you just a
real-9 simple-example.
10 In a fluid system, the piping analysis 11 itself, there is a certain : element of the design which 12 will be
- done, and will be don'e at the design-
"7-13 certification stage, that will complete define the I
14 functional characteristics of this particular system, 15 the performance requirements of the components', a lot i
16-of detailer' documentation, pipe routings.
What won't 17 be-avai lable-is the final set of drawings, as an 18
- exarple, that would contain the details for the 19 individual pipe supports.
~20 CHAIRMAN CARR:
- Well, just take' t ha ti 21 example then.
How much design work is involved in the 22 first part versus how much in the second part?
You 23 know, my architect gives me his big picture, then he l
24
- says, "We turn it over now to the guys who are going 25 to implement it,"
and I find out he's got seven more i
s L.-
l~
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75 7,
~_l-people working twice as-hard on that.
So, I owe him-2
- ten. times as much money as I-did to get his original 3
picture of the house.
4 MR.
REHN:
Pipe supports have probably 4
5 been
-the.
extreme example.
As a
percentage, we:
6 probably have spent more of the total design on ' a 7
fluid system in the final specification a'nd detailing 8
of pipe hangers.
Clearly, that's not the case'for a 9
building structure, _ where I
would say typically ' a 10 significant portion of all drawings, those necessary
.I 11 for the design and for the construction, would :be 12 available.
But looking at a fluid: system, I' d ' say f
13 there's-about - a 50/50 split between that-which is 1
L_.
14 necessary to do all the. front end design work and the 15 final i'asuance of the construction details associated 16 with the pipe hanger schedules.
17 CHAIRMAN CARR:
Do you want to 'take a 18 guess at how much engineering let's just say 19 manhours of engineering.that are going to have to be l
t 20 charged off to this design when it's built are going i
f 21 to be available at the certification stage?
Maybe l
22 I'm --
23 MR. REHN:
I understand the question.
24 CHAIRMAN CARR:
If one
'o f those vendors 25 wants to take a guess at it, I don't care.
Maybe I'm i
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76 V;
- '~
'l asking the wrong guy'.,
2 MR. REHN:
We've' sampled the industry _and-3 we've gotten a
variety of responses.
A lot.is 4 -_
dependent upon the-particular
' design and_
the-5 particular architect
- engineer,
.for
- instance, chat
.6' would be designated to complete the= balance'of plant.
Many of the designs that the major manufacturers are 8:
currently undertaking involve a-teaming relationship 9
with at particular AE or utility or= combination,of both 10 to complete a lot of what is essentially _ complete 11 design.
That's the point-and I
guess that_'s the 12 thoughts that we have, is ' that the design. process r- - '
13 would be essentially complete.
Now, the construction l
- 14-details are the --
or is the portion that would
-15
-remain.
16 An estimate that we'have, I guess, at the 17 time that we would be looking at preparing for a COL, i
I 18 we would probably have about -30 percent, a little
=19 less, of total hours maybe necessary to develop these-20' construction details and support the procurement' 21 process associated with procuring those individual 22 components that were defined in the original 23 specification.
That's an element, if you will, of the 24 engineering aspect that typically does not result in 25.
an issuance of a drawing process.
a L_._
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(
, 4' #
l.
MR. ROWDEN:
.Mr.
C h a i r.ma n, if I may, and-2:
I'm very humble on this issue as a lawyer:andinot an 3
engineer, but.make a suggestion.
What you raise is,an 4-important. question.
I think it's too important to 5.
Just wing it.
We made it;a strong suggestion to the
'6' staff which Byron Lee has reinforced, that the I
7 industry have an opportunity-to comment on' the.
8
' alternatives
_to the design detail the -staff, is 9
presenting.
It seems to me in that context' a l
10-carefully considered and accurate, or at least more i
11 accurate answer than something that Just top of the 12 head or seat of the pants --
7 13 CHAIRMAN CARR:
That's fair enough-14 MR. ROWDEN:
-- would-be more helpful to 15 you.
'Let me make it one more observation, since I do 16 have the floor.
-Although the cost factor is t
17 important, it would.be disingenuous to disregard it, 18 who pays and
- when, particularly when there's-no j
19 particular order that a vendor has on the horizon.
20-There are other' considerations which the
'lready considered.important in the 21 Commission has a
22 past.
The Commission was very mindful, as
.I was 23 brought to recall when I went over some of the past 24
. statements, policy statements, of the anti-competitive 25 aspects of having too much design detail certified in l'
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4 s
78-
'1.
terms of the constraints it'would place on competitive 2:
procurement.
Whether that is still an important
~3 issue, well, this 1978. policy. statement -was an issue
.4
.that.
.was given considerable attention
.b y the:
5-Commission.
There was a
s t af f. report,
there.was-6' discussion with_the Department of Justice.
- This. is' a 7
very material, consideration, we believe today, if not 8.
from an anti-trust standpoint, at 'least from.the 9
standpoint of utility procurement.
I'll let. the 10 utilities speak to that,.but they're certainly not-11 unmindful of the - desire to have competitive < sources 12 apply.
13 All I'm saying is that there are a variety Y
14 of factors.that go into the question from a policy 15 standpoint of what is the appropriate level of design 16 detail.
You've. talked about one, I've talked about 17 another.
I think we'd like to have an opportunity to 18 contribute o u r.
views on those and others befo're -the 19 Commission reaches a
decision on the proposals or 20 their --
21 CHAIRMAN CARR:
You're asking for delay.
22 MR. ROWDEN:
I'm not asking for delay, I'm 23 asking for an opportunity to be a
part of the 24 decisional process.
25 CHAIRMAN CARR:
I think that's proper.
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i s
79'-
['~,.
~1 MR. LEE:
I think I have to a'dd one other 2
commen t'.als o, Mr.
Chairman.-
I think that. again we t
3I
-have to look at, that' the program - right now, that 4
there has been' hundreds'of millions of dollars spent 5
on already, involves four designs.-
I think again 6
consistent with the ~ comments that' Mare made, I.think -
7 that in this country we do need; alternatives, I t'hink 8
the alternatives in size, the alternatives in designs.
i 9
After all, if this market or when this-10 market I should be more optimistic -- when this
.i 11 market-comes back, the market in.this country is much 12 bigger than anything any place else.
And I think we t
-13 do need alternatives.
We can't' depend on: a single 14 source.
That's the whole problem =that.the utilities 15 wrestle with all the time.
16 CHAIRMAN CARR:
I don't disagree with 17 that.
18' As I understand, your major' piping runs 19 and cable tray routing will be identified in this 20 design descr.iption that you're planning to put out.
21 MR. REHN:
Well, it will be as a part of I
22 the design certification application.
23 CHAIRMAN CARR:
Yes.
That would be in 24 tier 1, as I understand it.
25 MR. REHN:
Well, to the extent that it's
+
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i:
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e{.
- necess'ary to define-those safety issues.
Typically, l'
2 issues such as separation and what not.would require 3'
-you to have that level of' detail.
lc 4
CHAIRMAN CARR:
Once we' certify a design, p
6 if I visit' plant 2,
I'd find the components,in - the 6
same location.
Would I find the same cable -in ' thei f
7 same' cable tray?
8 MR. REHN:
I would have to say. typically j
-9 yes, but that's not-necessarily an absolute.
10-MR.
LEE:
But
-you'd have all-the 1
11 requirements of separation,and all'other requirements 12 met.
7-13 MR. REHN:
Yes.
There may be a bank of 3
14 trays in a given location and through separation the k
15 other train is existing on another side of a building.
L 16 Well, within that: bank of specified trays, that cable 17'
'would reside on all plants.
18 CHAIRMAN ' C ARR:
Piping supports might be 19 or might not be in the same general location then?
l 20 MR.
REHN:
- Well, I
guess typically ~ we
-21 would expect them te be in the same location.
22 Certainly there's going to be an economy associated 23 with utilizing the same analytical techniques that 24 were used on the first plant.
- However, piping i
p 25 analysis again is probably an extreme example where 1
k 1
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~ 81*
. T( '
1 vendor' 'information, specific supplier l'nformation has made perturbations on it, particularlyLonlyour seismic 3:
analysis.
Changes in valve weights or sizesi 4
orientations.
can affect-that_ and can require-sn r
'5
. additional support or move it over slightly..
6 CHAIRMAN CARR:
Let's look at the-tier,
7-tier 2 thing.
Both tiers are going to be ce r t i f.i e d.
8-MR. ROWDEN:
No, sir.
The first tieriwill-9 be certified.
The other will be documented in the.
10' design certification rule as matters which were. - the 11 basis for the. Commission's review and they've formed 1
12 the-basis for the issues that have been resolved in-13-the design certification proceeding.
Only ' tier 1
i 1_.
i 14 would be certified.
That would be the certified-15' des'ign.
The balance, as we've described it, ' are the 16-balance of-the contents of the application.
17 CHAIRMAN CARR:
And industry-has the-18 option of changing that, but I' don't have.
19 MR.
R0WDEN:
Industry,-
under the f
20 Commission's regulations, is given the latitude to 21 apply 50.59, which is exactly the way it works now.
22 The difference is that the Commission, the staff, the 23 Commission, interveners in the design certification 24 proceeding, would examine the appropriateness of 25 50.59's applicability to what we propose.
1
' (.1 -
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l CHAIRMAN CARRi
- Yes, I understand that.
i 2 --
But!we'veLset.Part 52 up pre t ty-- specifically to keep 3L me.from making any-changee unless they're really:
4 critical to safety.
i
'5-MR' ROWDEN:
In tier 1,.
that is exactly 6
the case.
-c i
7 CHAIRMAN CARR:
Well, in the whole design-r.
8 after-it's certified.
9-MR.
ROWDEN:
- Well, tier 1 would be the 10 o'n'l y part of the. design that is~ certified.
Let me N
11 also point out --
12 CHAIRMAN CARR:
Oh, so I can now make 13 changes.in tier 2?
j 14 MR. R0WDEN:
The ability of the Commission 15 to make changes in tier 2 is not as limited as its 16-ability under ' ier 1.
.Under tier 1, the Commission is 17-.
obliged to apply. the much more stringent backfit 18 requirements that they have incorporated in ' Part 52.
19 Tier 2 would be subject to-50.109, which provides for 20
- less, significant but nevertheless lesser backfit' 21' constraints.
This is another difference.
22 COMMISSIONER CURTISS:
Let me clear th9t 23 up.
What you.would get in tier 2, if I understand the 24 process you've described, is issue preclusion.
That 25 is to say tier 2 issues would be litigated -- could be
' l:
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I litigated at the front end and if changed through a r
is 2-50.59 process, a hearing would not have-to precede t
f t
3 that
- change, and you would get backfit protection i
l 4
under Part $2.snd'50.109.
I 5
MR.-ROWDEN:
No, 50.109 would app 1'y only 6
to tier 2,
not Part 52.
Part 52, as-I read the f
71 literal requirements, and I
believe this is-the 8
sensible reading of Part 52, applies the more 9
s t rin ge rs t backfit requirements contained in 52.63 to
(
10 the ' certified design, which as we have ' proposed it i
'll:
would be tier 1.
i 12 Now, it's not simply a question of issue
- j '
13 preclusion under tier 2.
Later combined license 14 applicants would be obliged to comply, as would later 15 combined license holders would be obliged to comply 16 with the contents of what is in tier
_2.
- Now, the 17 staff similarly or the NRC similarly would' be 18 precluded from making any backfit changes to the il9 '
contents of what's described in tier 2 unless they l
20 meet the requirements of 50.109, which I said are 21 lesser in the'r severity than the requirements of the 22 Part 52 backfit.
73 COMMISSIONER CURTISS:
Eight.
24 MR.
ROWDEN:
So, there are differences, 25-We think the differences not only comply with what the i
L-U-
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1 Commission has prescribed, but that it's a sensible l-2 differentiation.,
3 MR. LEE:
There seems to be a real concern 4
that with the use of 50.59 there's going to be 5
wholesale changes in the designs and. what haveLyou.
6 Again, I think.ns Mare-had reiterated before, I don't-7 think.that there's no doubt in'my mind that it's
\\
8 not - in the. best interest of-the utilities - nor the-t
-9 manufacturers.
- Secondly, I'll,look back at the 10 existing plants and'if you look at the plants in the a
11 terms that I think that you're worrying about, Mr.
y 12
- Chairman, we haven't seen those kinds of wholesale 7--
13 planto.
I
. p
' 14 CRAIRMAN CARR:
Well then, I guess I don't 15 understand 'why you need that flexibility that you're f
16 talking about.
Why not -
you know, tier 1 -- to me, 17 the flexibility we afforded,-the certified design was
~ 18 -
going to have everything in it but site specific l
19 problems.
y 20 MR.
ROWDEN:
Mr.
- Chairman, that's the 21
' flexibility that the Commission afforded.
We think 22 sensibly, but we are --
23 MR. LEE:
Well, it's necessary, right.
4 24 MR. ROWDEN:
The Commission specified that 25-50.59 would apply to what it characterized as the l
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uncertified part of the design and the. uncertified 2
part of the design --
e 3
CHAIRMAN CARR:
Is the site specific part.
4 MR. ROWDEN:
No, sir, it's the contents of it's the-contents of-. t he.
5 the
. application 6
application that were not certified.
f l
7 CHAIRMAN CARR:
Well, we're arguing.about i
8 what the application is' going to consist of.
9 MR. ROWDEN:
Well, that's true.
That gets 10.
down to what the appropriate level of detail is going i
11 to be.
12 MR. LEE:
And I might say that 50.59 has i
13 L; i been useful and necessary in the existing process, but
.i 14 yet has not resulted in these wholesale changes in the 15 plant that seem to be of concern.
l 16 MR. ROWDEN:
We have to have a flexibility
- 17 mechanism, Mr. Chairman.
18 CHAIRMAN CARR:
Give me an example of.the 19 flexibility that you're going to use.
20 MR. REHN:
Well, we talked about several 21~
potential issues that may come up.
I guess focusing 22 on pre-operational testing issues that may be-9 23 identified in the early phases of the maintenance I
24 aspects associated with a piece of equipment, may 25 define a
need to modify locally part of that s:
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ip t
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component.
To-the extent that all of those details i
I~
'2-are defined in tier 1 and if we need to m ak es tha,t.
3 change, we would then have-to go through the exemption 4
or change process associated'--
I S
CHAIRMAN CARR:.
Well, what 's ' wrong with 6
that?
P 7
MR.
REHN:
I don't know that there's' j
8 significant concerns, b'ut the potential in there to i
9 have a series of hearings every time we encounter one 10 of those ' situations.
And to the extent that we're 11
. arguing about a small change to a design --
12 MR. ROWDEN:
Not safety significant.
t13,
MR.
REHN Not safety significant, we 14 believe is going to be utworkable.
15 MR. ROWDEN:
Yes, Mr. Chairman, I'said we r.
16.
shouldn't be disingenuous on the industry side about 17 the cost factor.
I think that we also - have to be
[
t
?
18' realistic in facing-up to the practical consequences 19 of procedural obstacles.
The fact of the '. mat ter is
+
20:
52.97(b) poses a very substantial procedural hurdle, n'
y 21 daunting one, to anyone who is constructing a facility 22 in terms of making a
change that constitutes an
]
23 amendment.
We're very sensitive to that in devising' 24 the implementation approach-which we are proposing to I
25 the Commission, and I think appropriately so.
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CHAIRMAN CARR:
- Well, I
agree.
I 2-
, understand that.
What I'm trying to get fix in my-3 mind is what kind of a flexibility do you, suddenly 4
find you need?
If you're already in the test phase 1
5 after you've built-the plant,.you're tellingime that 6
we certified a design that.didn't work-very well.
Is 7
that standard?
I mean, you know, I don't have
'a 8
practical example, I guess, of what you're thinking 9
about.
10 COMMISSIONER REMICK:
Would changes due to 11 obtolescence be --
12 MR.
LEE:
- Yes, I was' just, going.to say
-r--~
13 that-in the whole proces,s it may be that the equipment L
14 that you consider initici --
15 CHAIRMAN CARR:
Dut we don't certify the 16 nameplate on the equipment.
That's outside the 17 certification.
The equipment i tself is not.part.of 18 the certification.
We've agreed to that, I think.
19 MR.
LEE:
- Well, that's' a
major 4
20 clarification, if in fact that's --
21 CHAIRMAN CARR:
I mean that.'s what your.
22 thing says here.
23 MR. LEE:
Yes.
Yes, that's our position.
.24 CHAIRMAN CARR:
If they want to update the 25 equipment, that's not part of thr. certified --
o i.
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1 MR. LEE:
.But when you.do that, you have 2
to make some changes in design that Dave was talki.ng 3
about.
If I
now have a
different slightly 4,
different configuration on that component, then I may' i
5 have to make some changes.
Or if, in fact, for some
(
6 reason or other I do not meet one of the acceptance 3
7
. criteria,- I have-to make some changes that fits in 8
the-same category rather than having that opportunity, 9
as long as it is not a safety-significant issue.
10 COMMISSIONER REMICK:
But, suppose you
.11 1
needed to change cabling at some future time and there l
12 was a new insulation out, would that be one of the p
13 cases.you would use the 50.59?,
b:-
> ~
14 MR.
REHN:
If that level of detail was
~:
1 15.
specified in our application and contained as'part of o16 tier 2, then the answer would be yes.
Furthermore,'if
..s.
17 that level of detail had been provided and was 18 contained within tier 1, then that would require us t o.-
19 get into the hearing and exemption or amendment i
20 process.
i 21' COMMISSIONER CURTISS:
It seems to me the 22 key question is what's the difference between tier-1 23 and tier 2.
I guess my question, we've got 50.59s
[
i 24 today where we change out steam generators under 25 50.59.
I'm not concerned with the interferences that y
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l
- you' re l talking about where the cable tray runs up 2
against the pipe and-you have to apve it six inches.
[
3 But if I recall correctly. didn't we 50.59 the Diablo 4
- Canyon containment under that procedure?
5 What I'm looking for is a way to -- -I 6-
.think the Chairman is picking up on this, to address 7
the legitimate kind of. interferences that you would-i
~
8 encounter in construction without seeing 50.59 applied
(
f f
5 9
in the way,
- frankly, that it is today.-
I'm-not t
10 objecting..to the way it's applied.
I'm not suggesting 11 that there's anything improper about 50. 59. in steam
?
12 generator replacements, but doing that in the context
- }
13
'of a custom-built plant versus doing it in the context i
'14 of a Part 52 certified design it seems to me involves 15 different questions.
16 Additionally, the safeguards' mark that you' 17 referred to that attach up to the point of the COL, I
- i, 18 don't..think, if I
urderstand the ones that you t
19 enumereted, have the same kind of force after issuance 20 of the COL and where 50.59 for the same reasons could 21 be used to -- well, take Wolf Creek and callaway, for L
22 instance, which were two identical plants at the time 23 of licensing but with the 50.59 proc 3ss look 24 significantly different today.
25 MR.
ROWDEN:
I understand our proposal, i
b
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y W)
{
90 5
t-ia s 1-bat also as I understand the Commission's regulations, i
2 Part 52,- 50.59 would not be applicable until a COL is.
i 3
-issued.
The Commission has s' aid that a: licensee may w
.i 4
utilize 50.59 to make changes to the uncertified f
5 portion of the design.
50.59 is not applicable.before l
'f 6
a combined license.is issued.
7 7
COMMISSIONER CURTISS:
I understand that.
I
-l 8
MR. ROWDEN:
Now, in terms of the concern y
9 that you've expressed, we've attempted to be very p
10-forthright in stating that this is a matter which is 11 legitimately going to occupy the staff, assuming the l
12 two-tier approach is acceptable, legitimately going to
+
r-13 occupy th'e staff and the design certification I
14 component in determining, proposing on one part and s
15 determining on the other what will be in tier 1 and 16 what will.be in tier 2.
I can't give you anything 17 more definitive than that.
It's going to be an 18 iterative process that's going to have to proceed t
19 under general guidelines.
20-CHAIRMAN CARR:
What would you think of a.
21 two-tier approach for the first plant only and then I
22 that design is certified as built, except for he 23 component you can buy from some other supplier?
24 MR. LEE:
Then you truly run --
1 25 CHAIRMAN CARR:
I mean I can see then 3.L._
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v i
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" y"'
I at'the end of that period, I'd know exactly what.you.
2 were talking about that, needed to be changed during -
n
[,
3 construction, but those problems are behind us.
h 4
MR. LEE:
But then you truly run into-the l,
5' obsolescence or-unavailability, not. obsolescence in.
g,,
E 6
the sense.that the manufacturer decides not to build i
L t-it;anymore..
8 CHAIRMAN CARR:
But you don't have to buy 9
'i t from' the same manufacturer.
You want that 10 flexibility.
L
~ 11 MR. LEE:
Yes, but then you'd have to make 1
12 some of the other changes we're talking about, g
13 CHAIRMAN CARR:
I'm not certifying the.
X._.
14
-manufacturer.
'16 MR.
LEE:
I understand that.
But
'I
!l 16.
believe you would then have to make some of the other s
17 changes that Davo was referring to to accept this new
~ 18 pump or heat exchanger.or whatever it happens t o _ b'e,
19
.very minor maybe in some in most cases; I believe.
20-I mean you're certainly not going to change the 21 general configuration or layout of the whole r o o m '.
22 MR.
ROWDEN:
If standardization means 23 generic pre-approval of designs, I certainly would say 24 that we ought to stick with the concept and the 25 program of generic pre-approval of design and that
- t. -
l t:
(
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02 f^^-
~ these-issues ought to be confronted at the outset to 1
2 determine the' viability of what we're we call it 3
two tier.-
That.'s just our way of formatting the way q;
C 4
' it's going to operate.
)
S.
5 It would operate -the -same way as the p.
6; Commission has described i t ', -but perhaps under n-
'1 But I think the - same, issues would' l
7.
different-guise.
8 have to be addressed.the extent to which you're going t
9 to apply. 52.97(b) to th'e parts of the design, the i
10 extent to which you're prepared to see 50.59 applied-11
'to the balance-of'the design.
12 Our view is that that ought to be'
\\
13
. addressed -up front in the applicatione-that
'are 9
14 pending before the Commission now and we believe you i
15.
have a viable framework for doing that.
[
16 CHAIRMAN CARR:
Commissioner'Remick?
17-COMMISSIONER REMICK:
Just.one response.
18 You indicate that we should do it right and I surel'y
'19
- agree, That's part of my concern.
To do it right, it-20:
requires good people and 'a number of them to do i t.-
-21:
I'm very much in favor of doing it right.
I'm nit 22 sched'ule-driven.
23 CHAIRMAN CARR:
I knew you weren't.
24 COMMISSIONER REMICK:
I like the fact of 25 predictability.
- i L:
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20005 (202) 234-4433 4
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.9,.
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4 4
??
i 93 p1-L.
1 Thank you.
b 2
CHAIRMAN.CARR:
Commissioner Rogers?
,3 COMMISSIONER ROGERS:
Nothing.-
4 CHAIRMAN CARR:
Commissioner =Curtiss?
h 5
COMMISSIONER CURTISS:
No more..
6 CHAIRMAN CARR:
- Well,
.I'd like to thank.
I 7
'NUMARC for.providing. your views on the essentially 8
complete design issue.
I can assure' you
'the
[
9 Commission will give appropriate consideration of the 10 need for flexibility in plant designs as we pursue 11 the goals of preserving public health and safety and-12 achieving standardization for the next generation of a
13.
plants built in this country.
.O 14' The Commission will consider'your views as 15 it develops'a reasoned approach to divining the level 16 of duign detail necessary for design certification.
m o
17 As I've said before, we shouldn't build
~18 the next generation of plants like we built the first i
19_
hundred.
Among other potential problems, excessive 20 diversity on design can increase the complexity of i
21--
maintenance, can exacerbate the potential for human 22-error and can make the supply and availability of 23 spare components more difficult.
I 1,
L, 24' Providing the right mechanism for L
25 achieving standardization in the next generation of
]',
H.'.;_
1
'NEAL R.
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plants;is one of my highest priorities.-
In my view, j
2; ParttS2 provides a sensible and stable framework to 5
f 3
-ensure safety and achieve standardization.
l
't
.4 Are there any-other comments from -my L;
5 fellow Commi'asioners?
i':
I i.
6-.
If not, we stand adjourned.
E m 7.
- (Whereupon, at 4:01-p. m'.,-
the above-
'l bE' 8.-
entitled matter'was. adjourned.)
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e a
i CERTIFICATE OF TRANSCRIBER i
(
1 This is to certify that the attached events of a meeting t
of the United States Nuclear Regulatory Consission entitled:
TITLE OF MEETING: BRIsFING BY NUMARC ON ESSENTIALLY COMPLETE DESIGN ISSUE FOR PART 52 SUBMITTALS PLACE OF MEETING: ROCKVILLE MARYLAND DATE OF MEETING:
JULY 16, 1990 were transcribed'by me. I further certify that said transcription is accurate and complete to the best of my ability, and that the t
transcript is a true and accurate record of the foregoing events.
() J' fs i
AA A K %
suu1
%6
+
Reporter's name:
Peter Lynch
\\
P 8
5 e
(
NEAL R. GROSS COURT RfDOefft$ AND TRANSCRittRS 1323 RHODE ISLAND AYINyt, N.W.
(202) 234 4433 WASHINGTON. D.C.
20005 (202) 232-6600
["
7/16/90
(
i' SCHEDULING NOTES
Title:
Briefing by NUMARC on Essentially Complete Design Issue for Part 52 Submittals Scheduled:
2:00 p.m., Monday, July 16, 1990 (OPEN)
Duration:
Approx 1-1/2 hrs
Participants:
- Byron Lee, Jr.
- Sherwood H. Smith, Jr.
15 mins-Chairman and President Carolina Power and Light
- David L. Relin, Division Manager 25 mins Catawba Engineering Division Duke Power
- Marcus A. Rowden 10 mins Fried, Frank, Harris, Shriver and Jacobson Chairman, NUMARC Lawyers Committee
4 4
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j IMIARC DESIGN CERTIFICATIONS, LEVEL OF DETAIL
.1 g
i SPEAKERS BvRoM Lus, Ja.................PRESIosNT & CEO l
-l I
Sunnuooo H. SnITu, Jn.....CuAIRMAN &
PRESIDENT OF CAROt.INA POWER.& LIGNT i
MARcus A.
- ROuoEN, Esa... FRIED,
- FaANK, HARRIS, SuaIvsa & JAcossou.........CuAInnan or Tus IMIARC LAuvERs' ConnITras i
i DAVID l.: RENN..... DIVISION MANAGER, CATAMBA ENGINEERING DIVISION..... DUKE.PoWEn 1
i
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2 t
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t OBJECTIVES OF INDUSTRY'S APPRGACH t
o IMPLDGENT-PART 52 sWILDINs ON ESTABLISHED PRACTICES
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REALIZE THREE GOALS l
l' l
PREssRvATION OF STANDARDIZATION t
DESIGNS i
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l EARLY DEFINITIVE RESOLUTION OF l
ISSUES l
PRacTZcAL IMPLEMENTATION OF DESIGN 1
1 CERTIFICATION FROM CERTIFICATION l
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INronsEATXON THAN UNDER.PART 50-ANALOGOUS To FSAR MINUS AS BUILT i
i NAME PLATE AN9 SITE SPECIFIC
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LEVEL OF DETAIL i
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DESIGN MUST BE SUFFICIENTLY DETAILED TO*
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m.e Table G2 CONTAINMENT DESIC.N PARAMETTJLS i
A. Demti mad weisenu)
W gang L lasernalDesip Prumurs (psis) 45 45
- 2. % Dmip Premurs W
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- 3. DesignTemperseers(er) 20 219 3
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Not Pres Vdune(h )
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s G) camsponds to miculmed puk maalament prus= reisted to abs da isw basis I
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REBAR RATIOS USED IN THE DE51GN EVALUATION REthTORCING STEEL m)
MERIDIONAL CIRCUM.
SIREAR BECDON RADIAL FERENmL TIES
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Coatalamest waU above D/F slab (D/W)
LO9 L721 0.30 5
Containment wali saar old i
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Costainment wallbelow top aleb(D/W) 0.M 1.343 0.30 p
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aentainnsat mall 0377(2) 0377(2) 0,$6 41 Costainment top alab under l
teaser well pool 0405(1) 123 (2) 0.56 13" Foundation mat osat inside inas of ooetainmaat enD
& 457 4A07 0.42 l
34 Foundation mat osar aid spani between the
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EQUIPMENT ASME/ ANSI AG-1-1988 MANUFACTURING Su nt NETAL'AND AIR L
DUCT WORK CoNoITIONING CONTRACTORS NATIONAL ASSOCIATION (SMACNA)
WATER-COOLING & NEATING AIR CONDITIONING AND COIL RATINGS REFRIGERATION INSTITUTE (ARI) 10
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SPECIFICLLOCATION OF ROOM AND GENERAL ARRANGEMENT OF MAJOR COMPONENTS O
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O DIFFERENCES IN APPEARANCE DUE TO THE POTENTIAL FOR-DIFFERENT COMPONENT VENDORS O
DIFFERENCES IN LOCAL PIPE AND CABLE ROUTING TO SUPPORT VENDOR-SPECIFIC COMPONENT CONFIGURATIONS 1
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~ CRITERIA DERIVED FROM REGULATORY GENERAL DESIGN CRITERIA'OR SIMILAR SAFETY / REGULATORY REQUIREMENTS-O NON-CONFORMANCES ARE UNACCEPTABLE, ABSENT NRC APPROVAL
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I.: j TWO TIER STRUCTURE OF DESIGN CERTIFICATION RULE t
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THE APPLICATION AND THE DESIGN j
CERTIFIED BY THE RULE i
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-- i DESIGN.-CONTENT OF DC RULE l "...THERE WILL BE LESS DETAIL IN-A i CERTIFICATION THAN IN AN APPLICATION FOR A. l CERTIFICATION' (AND) A RULE CERTIFYING A ] i DESIGN IS LIKELY TO ENCOMPASS ROUGHLY THE SAME DESIGN FEATURES THAT SECTION: 50.59 1 PROHIBITS CHANGING WITHOUT PRIOR.NRC APPROVAL." (54 F.R. 15377) . 1 .22 m . ~,. ~,-.-, .r,. .,_.,....+.__,..__--,.,.4 ... - +
[ = '~ .[ DESIGN CHANGES i ? O NRC DID NOT ADOPT:- m PROPOSED INDUSTRY POSITION - 50.59 i ~ APPLIES-TO CERTIFIED DESIGN d OTHER' PROPOSALS... --NO CuANGES l ALLOWED TO CERTIFIED DESIGN O-NRC FINAL POSITION - RULE I NO CHANGESTO CERTIFIED DESIGN c UNLESS EXEMPTION GRANTED UNDER l 50.12 1 "WHILE 50.59 wILL CONTINUE TO APPLY I TO-THE UNCERTIFIED PORTION" (54 FR. 15377) .l i. 3 I i -mu.- .n ..--.w .-+%.,,- .,.i%,,
? ^ : LEVEL OF DETAIL - CERTIFIED AND NONCERTIFIED DESIGN ~ o "HOW MUCH DETAIL...IN A DESIGN CERTIFICATION "AN ISSUE THAT WILL HAVE TO BE RESOLVED IN-EACH CERTIFICATION RULE MAKING" "CoNNISSION EXPECTS LESS DETAIL IN A CERTIFICATION THAN IN-AN. APPLICATION FOR-CERTIFICATION" l l 24
l LEVEL 0F DETAIL - CERTIFIED AND NONCERTIFIED DESIGN (CONT'D) ~ O "A RULE CERTIFYING.A DESIGN IS'LIKELY j TO ENCOMPASS ROUGHLY THE SAME DESIGN FEATURES THAT 50.59: PROHIBITS CHANGING i WITHOUT PRIOR NRC APPROVAL..
- MoREOVER, THE LEVEL OF DESIGN' DETAIL IN 1
CERTIFICATIONS SHOULD AFFORD ~ LICENSEES AN OPPORTUNITY TO TAKE ADVANTAGE OF .} l IMPROVEMENTS IN EQUIPMENT" (54F.R.15377). i 25 1 ^ l 1
- 5
.m si t t .{ FUNCTION OF TWO-TIERS O PROVIDES A'MEANS'FOR-FORMATTING.AND DOCUMENTING 1 THE CERTIFIED AND NON-CERTIFIED j PARTSLOF THE DESIGN THE CHANGE MECHANISMS THAT GOVERN 1 THE CERTIFIED'AND NON-CERTIFIED PARTS OF THE DESIGN IN ACCORDANCE l WITH PART 52 REQUIREMENTS l -[ l 26 i l . ~. _. _,. _, _. _ . = _ _., _. :_ E. ? '1__
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= ' " 4:f9f; -g M- , i, {.)_ [g} ".,.. ~,. y.-; ' h-C'. .7 wy I CONTENTS OF.FIRST. TIER j o DESIGN DESCRIPTION OF CERTIFIED. DESIGN BASED'ON SSAR SECTI'ON 1.2 WITH DETAIL COMPARABLE ~TO THAT IN CURRENT SER y o FULL ARRAY OF : INSPECTIONS, TESTS, ANALYSES AND ACCEPTANCE CRITERIA-(ITAAC) uMICH PART 52~ REQUIRES i o ANY INFORMATION uMICH-THE NRC HAS DETERMINED SHOULD NOT BE SUBJECT TO CHANGE UNDER'50.59 I ~ i .. } f 27 .~
L + g , q: CONTENTS OF SECOND TIER o SSAR DESIGN DESCRIPTION (BY REFERENCE) o THE QUALITY ASSURANCE PLAN (OAP) (BT REFERENCE) ~ o CHAPTER 16 SSAR TECH SPECS. (BY REFERENCE) o SPECIFICATION OF " VALIDATION ~ ATTRIBUTES" WHICH ARE.A' BRIDGE To DEMONSTRATING COMPLIANCE WITH FIRST TIER ACCEPTANCE CRITERIA NOT CAPABLE OF DIRECT VERIFICATION ~ 28
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7 y 4 m .r> 1 L a 1 'I l CONTENTS OF SECOND TIER (CONT'D)- ~ j i o SECOND TIER SPECIFICALLY DOCUMENTS
- I FEATURES AND COOGEITNENTS IN APPLICATION i
THAT-WERE BASES FOR: NRC REVIEW.AND APPROVAL OF l APPLICATION 'l " MATTERS... RESOLVED IN COOWEECTION WITH THE ISSUANCE.. 0F A DESIGN ) CERTIFICATION" (10CFR52.63(A)(4)) ~ t ,i l { 29 l i
' ~~ ' y. W 1 L _ ~ = 41 ~ l 3.. I' ; _ 1* p ?y; y TWO TIER RIGHTS AND OBLIGATIONS l l 1 l O DC RULE MAKING' CONSIDERS-AND RESOLVES ALL ISSUES COVERED BY BOTH TIERS, ~ i-INCLUDING DESIGN DETAIL TO BE INCLUDED l IN EACH TIER. j i O ISSUE RESOLUTION BINDS COL 1 APPLICANTS / LICENSEES, NRC AND INTERVENORS IN COL AND PREOPERATIONAL PROCEEDINGS i i 0 COMBINED LICENSE APPLICANTS / LICENSEES OBLIGATED TO COMPLY WITH.ALL PROVISION IN BOTH TIERS. ABSENT EXEMPTION, j AMENDMENT OR OTHER PERMITTED CNANGE j l 1 1 30 l j s-g " " ' ~. - -. _________-_-____-____________=.y ~-
~ s. A 1140 TIER RIGHTS AND 0BLIGATIONS ~ (cont'D) o CNANGES TxER ONE - ExEB8MrION OR ANENDOWDET PRECEDED BY HEARING OPPORTUNITY (10CFR52.63 (B)(1) AND 52.97 (B)) TrER Two - cuaNGs ONLY rr meers 10CFR 50.59 neourassesNTs (10CFR 152.63(B)(2)) 4 31 .mw.
.; ;; 1; .p 'h -44 COMBINED LICENSE TCOL) - CONSIDERATIONS O Two-TIER INCORPORATED IN COL sv REFERENCE O COL CONTAINS-COMPARABLE Two-TIER DESCRIPTION OF. SITE-SPECIFIC PLANT FEATURES AND OF OPERATION-RELATED MATTERS (INCLUDING THE EPP) ANo THEIa CONFIRMATORY SPECIFICATIONS O COL CnANsES sOVERNEo av EARLIEn-DESCRIBED REGIME O GENERAL COL FORMAT WERY SIMILAR TO PRESENT-DAY OPERATING LICENSES 32 4 ~^
MW6hd&dttWdWWW6dWdWWWW6WWW;(44dWfWgggg TRANSMITTAL.. TO: Document Control Desk. 016 Phillips ADVANCED COPY TO: The Public Document Room hi DATE: 7/A M/94 I g; j FROM: SECY Correspondence & Records Branch 5 I: Attached are copies of a Comission meeting transcript and related meeting i document (s). They are being forwarded for entry on the Daily Accession List and g j placement in the Public Document Room. No other distribution is recuested or g .)q 3 required. Meetir.g Titie: N A ' n-A k/ba h % l b L e h f M sx & / !!**:eL<J Meeting Date: 7 6/90 Open Y Closed I i Item Descri', tion *: Copies ( ! Advanced DCS h 's
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- 1. TRANSCRIPT 1
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- PDR is advanced one copy of each document, two of each SECY paper.
3 C&R Branch files the original transcript, with attachments, withcut SECY jjl OFo2 papers. e.i %i aF an_ h [
4t4
- 3. ;
- a s *} OPENING AND' CLOSING REMARKS BY BYRON LEE, JR. PRESIDENT AND CHIEF' EXECUTIVE OrrICER NUCLEAR MANAGEMENT AND RESOURCES COUNCIL -BEFORE THE NUCLEAR - REGULATORY COMISSION JULY 16, 1990
l i? Q './ ( l^ l Opening Remarks 1 Thank you, Mr. Chairman, for giving NUMARC the opportunity to discuss another segment of the industry's Advanced Light Water i Reactor Program. You heard from the EPRI-ALWR Steering Committee about its Requirements Document several weeks ago. Today we i want to discuss the utilities' view of future electricity needs and what they believe needs to be done for nuclear power to play a role in those needs. We will also cover the NUMARC Standardization Working Group efforts to develop guidance on implementing the requirements of your new Part 52 Rule. Let me begin by introducing the other speakers who are with me today: l 0 Sherwood Smith... Chairman, President, and.CEO of l Carolina' Power & Light... and Chairman of the industry's Nuclear Power Oversight Committee (NPOC). L He'll discuss projected future electricity demand and capacity and whern the nuclear utilities stand on the future of the nuclear option. i o David Rehn... Division Manager, Duke Power... and Chairman of our Task Group on the Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) established by our Working Group. Dave will describe the result of his Task Group's efforts to develop an industry approach to the implementation of_Part 52, including level of detail required for design certification and the role of the NUMARC ITAAC Report. igr\\ speeches \\ln cert.sph I
4 = 2 And Harcus Rowden-... Chairman of the NUMARC Lawyers Committee and a'~ member of the NUMARC Standardization Oversight Working Group and. Task Group. Marc will explain the industry's two-tier approach and how it relates to Part 52 based on our active involvement in the rulemaking process for many years.. Before we begin'these presentations, I have a few introductory comments on the design certification process in general. The. industry's approach to implementation of Part 52 supports the-three goals we believe. are embedded in the rule and desired by the-industry: i o' - Qagi Preserve standardization of designs; o Ing.t. Assure that issues raised at the design certification stage are resolved and thereby precluded from being reconsidered at the COL .and pre-operational stages; and o: Three: Assure the practicality of the design certification rule at the time of COL issuance, during facility construction, and at the pre-operational stage. In other words, it must take into account' the realities of a large complex l construction process. The ALWR design vork undertaken by the industry... EPRI, L DOE and the individual suppliers... is moving along very well. The certification reviews, however, appear to be following the course of the past: Uncertainty. This observation deepens the igr\\ speeches \\tnacert.sph
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,e ' ;p u. 6 3 a.. industry's fear that we won't have the predictable licensing a. C process needed to support future nuclear plant orders. We hope j that as a result of our briefing today we will be able to reduce that uncertainty. Oli O' At this point, I'd like to turn the meeti c over to Sherwood
- 1 ;::
$mith. 4 I 1, I i!j ' l i 4 l l l Igr\\ speeches \\ln cert.sph l l l; t. ~
o 4 Closing Remarks In closing, Mr. Chairman, I want to thank you and your fellow commissioners for giving us this opportunity to discuss the industry's interest in the future of nuclear power and the implementation approach we believe is consistent with the new Part 52 Rule. The industry shares the Commission's desire to avoid building future generations of one of a kind plants. The industry believes that the NRC's Part 52 kule coupled with the implementation approach we've described will provide the needed level of safety and provide the predictable regulatory process also needed to allow utilities to include the nuclear option in their near term planning. We also believe it will produce a high level of standardization. As you've heard this afternoon, the industry believes timely completion of the design certification process is & necessary prerequisite to a new order for a nuclear unit in this country. It has been suggested that there's no urgency to completing this process because no U.S. utility has stepped forn rd to order a new nuclear plant. From the U.S. utilities perspective, the situation is just the onnosite: As Sherwood Smith said, the utilities have a real need to begin planning new baseload generating capacity, but they feel unable to consider nuclear plants until we've demonstrated that the design certification process works. Until then the regulatory uncertainty makes the financial risks too great. I hope we have helped you understand the utilities' position and their strong desire to save ahead steadfastly. To do that, the industry and the NRC staff needs policy decisions from the Commission soon in two areas: igr\\ speeches \\ln cert.sah I
o i o One: the viability of our approach, especially the two tier ioncept; and o Two: the level of design detail the Commission believes is necessary to meet the Part $2 Rule. For nuclear power to figure in utilities' planning in the - 1990s for units in the first decade of the next century, we must set tough schedules. The industry urges the Comissioners to make meeting schedules a high priority... and to apply the necessary resources to do so. We conclude by stressing the need for parallel review of the EPRI-ALWR Utility Steering Committee Requirements Document and the two evolutionary ALWR plant design certifications. We believe that can be completed by the end of 1992. For passive plants, we concur with the Commissioners' position that the passive Requiree nts Document review should be given the highest priority to formally resolve the major technical and policy issues prior to specific design reviews. At the same time, to expedite the schedule, there should be interaction between the staff and the specific passive plant suppliers throughout that period. As stated in your SRM of June 6, 1990: "... the staff should not be precluded from keeping abreast of information and activities related to a specific design which could prove useful in conducting the EPRI review and in preparing for review of that specific design. Additionally, in conducting its review of the EPRI Requirements Document and then specific designs, staff may continue with its review activities on any matters which are igr\\ speeches \\ln cert.sph 1
6 unaffected by technical or policy issues awaiting ACRS review and comment or Commission decision." We believe it is possible to learn from the evolutionary plan experience and complete both passive plant design certifications by 1995, t We ask that the NRC staff SECY paper on level of design detail, which will be discussed at your Staff Briefing on Wednesday, be made public as soon as possible. The n iustry should have an opportunity to comment on this paper because it is of critical importance to our large ongoing efforts. And now, we'll be happy to respond to any questions the Commissioners may have. (pr\\ speeches \\ln cert.sph
e-g ELECTRIC POWER SUPPLY AND DEMAND NEW NUCLEAR ORDERS L JULY 16, 1990 STATEMENT BY SHERWOOD H. SMITH, JR.
- CHAIRMAN, NUCLEAR POWER OVERSIGHT COMMITTEE AND CHAIRMAN AND CHIEF EXECUTIVE OFFICER CAROLINA POWER AND LIGHT COMPANY BEFORE THE NUCLEAR REGULATbRY COMMISSION 4
s s Mister Chairman, members of the Commission: I appreciate the l opportunity to be here today to discuss one of the most important issues facing this country -- the task of supplying the electricity that will be l i needed in the 1990s and beyond to sustain our economic growth. In one way or j another for the last 25 years, I have been involved in planning, siting, licensing, financing, rate making,,and managing of organizations with nuclear 1 power plants. My Company was the first to have a commercial nuclear power j plant in the Southeastern United States. Today, we have four nuclear units l and operate both BWRs and PWRs. Over the years, I've been involved in many national questions about nuclear power having served as Chairman of the American Nuclear Energy Council, the Edison Electric Institute, and on the L Boards of the Institute of Nuclear Power Operations Electric Power Research l l Institute, American Nuclear Society, and United States Council for Energy Awareness. All of my experience manifests concern about the disastrous l effects which can be caused by delays in the planning, design, licensing and 1 J construction of nuclear plants. Providing the new electric supply that will be needed by our country is a complex business involving the balancing of many risks, many uncertainties and many competing interests. No single fuel can satisfy all circumstances, and the U.S. will need all three -- nuclear, coal and natural gas -- in the next 10-15 years. Fuel diversity is one of the great strengths of the U.S. electric supply system. The electric utility industry wants -- and needs - to be able to include nuclear energy in its planning for new baseload capacity. America's electric consumers -- for economic and environmental reasons -- need this option and opportunity. Specifically, our industry would like to be able to 1 l 1
I ? plan for, and order, new nuclear plants within the next several years and l start construction on them in the 1990s, so they can be on line by, or very soon after, the end of the decade. In y opinion, we need to be able to place a new order in the mid 1990s. To do this, many issues need to be resolved. Unfortunately, we cannot consider realistically ordering new nuclear units until new designs are certified by the Nuclear Regulatory Commission. Design certification is an essential first step toward creating the regulatory i predictability needed for new nuclear plant construction. Any delay in certification will probably be a delay in the time when utilities can order l plants. Let me seek to provide some perspective on electricity supply and demand l in the 1990s. I have recently completed a two year term as Chairman of the Southeastern Electric Reliability Council (SERC) and as a Trustee of the North American Electric Reliability Council (NERC). While our industry has embraced conservation, load management and energy efficiency, still all the data shows that we have a strong growing need for new electric supply. No one knows ' exactly" how much new electric capacity we'll need in the next 10 years but it will be substantial. We do know that if our economy grows by 2-3 percent a year then demand for electricity will probably grow at about the same pace -- 2-3 percent a year. That works out to between 100,000 and 200,000 megawatts of new capacity -- in only 10 years. Some of this will need to be peaking capacity; but as we reach the mid 1990s more and more new baseload capacity will need to be in our plans and orders. The electric industry has plans and commitments for new capacity of various types over the next 10 years, which plans take into account a significant amount of conservation, and demand management by electric 2 i
[ a o j 4 s. utilities. The annual 10 year assessment by the North American Electric I Reliability Council (NERC) published late last year identifies about 72,200 ) t megawatts of new generating capacity planned to be completed for the 1989 g8 period, although there are completion risks associated with elements of this planned as.ount of capacity. Some additional unannounced peaking and new fossil baseload capacity might be added at other locations in a short time frame, but there is growing pressure on utilities to develop more new baseloads capacity than is presently scheduled. As in the past, our utility industry is committed to meeting this growing demand, but there are many challenges, o About 41 percent of the planned additions are utility owned units that are not yet under construction. Given the amount of time it takes to site, secure permits for and build new power plants, it l 1s possible that some of this capacity will not be completed on L schedule. o About 25 percent of the planned capacity additions are projected to be built by non utility generators. This raises additional concerns because utilities then will not have direct control over the scheduling and construction of those projects. These units are not being built by utility organizations obligated to serve the public and thus are more subject to schedule changes because of economic, financial and other causes, o About 11 percent of the planned capacity is under construction but less than 50 percent complete, o Only 23 percent of planned capacity additions are under construction and more than 50 percent complete. But even this 3
e- + t 4, i capacity has some risk: it includes a numbe< of nuclear units - i j including Watts Bar and Bellefonte whose future schedules and l t operating status are uncertain. o Future fossil plant costs and schedules are sub. ject to substantial adverse impacts under pending air quality legislation and global climate change concerns, There are other uncertainties, too. The NERC assessment relies on the e utilities' current estimates of growth in peak electricity demand. For several years running, actual demano in some areas has exceeded the forecasts l - largely because of unpredicted extreme changes in weather conditions. If growth in peak demand continues to exceed the forecasts, NERC sees supply problems in the early 1990s in the eastern half of the U.S. and Canada, unless more new capacity is added. We've already seen the early signs of problems at times of rapid increases in peak demand with voltage reductions and service interruptions in several areas. ? To meet this load growth in the 1990s and beyond, the electric utility industry needs and wants to be able to include new nuclear capacity in its plans. It is very much in the public's interest to do so. As stated by President Bush in his letter of May 18, 1990, to the Nuclear Power Assembly: l 'Just as America gave birth to nuclear technology in the 1940s, we can lead the world into a new era of safe, reliable, economical, and environmentally clean nuclear power in the 1990s. This clean, domestic l source of power lessens the risk of energy dependence on foreign sources. At the same time, environmentally harmful emissions are reduced and economic growth is fostered.' 4
a O I t What do we need -- particularly from this Commission -- in order to be f able to cons'ider nuclear? j In simple terms, we need a stable, predictable regulatory process. We strongly endorse the Commission's work in this direction. We believe that new nuclear plants, built under stable regulatory conditions, can compete with new coal-fired power plants and should be able to produce lower cost electricity over their lifetimes than oil fired or gas fired capacity. But at the same time we cannot risk repeating the problems of the late 1970s and 1980s -- when construction schedules stretched out to 10, 12 and 14 years and when costs l j escalated two, three and four times original estimates. We cannot expect state regulators to authorize such projects, or our customers to pay unnecessarily higher costs, and we cannot expect our investors to accept the risk of not being able to recover those higher costs. We are all accountable, in various ways, for the problems of the past and we must learn much from that past experience and take maximum advantage of new improved designs and achieve shorter schedules. This Commission's April 1989 rule making should go a long way to solving some of the problems we faced in the 1980s. Early site approval, designs that are certified as meeting all requirements before constructior, begins, combined construction / operating permits -- all these are necessary steps in the right direction. Let me focus briefly on certification of standardized designs. The electric power industry must have certified designs before we can consider nuclear energy again. We are concerned at the schedule uncertainties we've seen building over the last year, and we are concerned by the prospect of significant new delays. 5
a n To be specific: o The industry agrees with NRC on the need for parallel review of the EPR!-ALWR Utility Steering Committee Requirements Document and the two evolutionary ALWR plant design certifications. o For the passive designs, n agree that the EPRI-ALWR Utility Steering Cosaittee Requirements Document should have the highest priority and should be the mechanism to resolve major technica'i and policy issues. o We also agree with the Cotamission that the NRC staff should keep abreast of information and activities related to specific passive designs that could be useful in conducting the EPRI review and in preparing for the review of the specific designs. Design certification on a timely basis is the linchpin of all the other issues before our industry as we seek to re establish the nuclear option. We agree with you, Nr. Chairsan, that this time we must "get it right.' The process of design certification must be thorough, painstaking and impervious to challenge. But it should also proceed on a rapid and timely schedule. The speed and efficiency with which the NRC reviews and approves the advanced nuclear plant designs will make an enormous difference. It will tell the public, the electric utilities, the financial community, and state regulatory commissions a lot about whether there is a future for nuclear power. It's up to all of us to ensure that we'll have the electric capacity we'll need. To do so, I believe, we must overcome the obstacles that stand in the way of new nuclear plant orders. In a recent poll, 80 parcent of the American people recognized that nuclear energy should play an important role 6
. ___.~.. _ _ _ _...__ _ _ l e e I
- l in the Nationkl Energy Strategy now being developed by the Department of Energy. The American people are counting on us to do what's necessary to continue to provide an adequate amount of electric power for this country in a way that is safe, economic, and compatible with our environment. To do so, i
l nuclear energy should be a substantial ptrt of our new electricity supply, and we must make it so. L 1 l k 7 1 1.
l 1. h l' i r INDUSTRY's TWO' TIER APPROACH TO IMPLEMENTING 10CFR PART 52 L l' t STATEMENT.BY MARCUS A. ROWDEN, Eso. FRIED, FRANK, HARRIS, SHRIVER, JACOBSON CHAIRMAN, NUMARC LAWYERS' COMMITTEE JULY 16, 1990 ~ ? e 4
i ? l .,e j y j '. ROWDEN PRE $DITATION The two-tier approach to the structure of the Design certification Rule is based en the specific j requirements of Part sa (as explained by the i , consission's statements'of consideration) which t' distinguish between what v111 be submitted for NRC review in the design certification application and what will be contain in the Design cartifloation i Rule itself. The two-tier structure is central to our report's recommendations, providing the framework for certified design and related ITAAC development and their Dc and COL implementation. As to the design content of a DO Rule, the Commission explained that: ... there will be less detail in a certification [ than in an application for a certification (and 4 that) a rule certifying a design is likely to encompass roughly the same design features that Section 50.59 prohibits changing without prior NRC approval." (54 F.R. 15377). Regarding tho ability of a COL licensee (or applioent) to make design changes, the commission first explained that it would not adopt an industry proposal that t $50.59 be made applicable for facility-specific i changes from the certified designs and that it also o 5
- fs
0 o j j 2 I i l.* would not adopt recessendations by other commenters I that no changes from the certified design be allowed. 1 Instead, the Commission stated ]
- ... the final rule... prehlbits a licensee of a l'
plant built according to a certified design from making any change to any part of the plant which j is described in the certification unless the licenses has been granted en exemption under 10 howeveh,850.59willcontinueto i CFR 50.128 apply to the uncertified portion". (54 F.R. 15377). After recognisi g these distinctions, the Commission went, on to state: "[H)ow much detail is present in a design certification... will be an issue which will have to be resolved in each' certifica+. ion rulemaking". And, as earlier stated, "the comission expect (s) that there will I be less detail in a certification than in an application for certification, and that a rule certifying a design is likely to encompass roughly the same design features that $50.59 prohibits changing without prior NRC approval." The Commission then added:
- Moreovar, the level of design detail in certifications should afford licensees an opportunity to take advantage of improvements in equipment." (54 F.R. 15377).
. -. - _ ~ -,. -
o The two-tier structure which industry recommends is i simply a means for formatting and documenting in the l Oc Rule the certified and the non-oertified parts of the design, and specifying the change mechanisms governing each -- all in accordance with the e l above-described part sa requirements. The first tier would oontains a description of the oartified design based on + l 88AR emotion 1.3,, with detail comparable to that in current'sERs; and the full array of inspections, tests, analyses and acceptance criteria which Part 52 requires i l The socored tier would Reference the entire SSAR design description. The SSAR is the primary technical document of the design certification application and vill be the basis for the NRC's Final Design Approval and Design Certification reviews. By referencing the i S8AR in the DC Rule's second tier, the NRC would document the features and commitments that were l the basis for NRC approval (beyond those j l certified in the first tier) and document the
- matters... resolved in connection with the issuance... of a design certification" (per 6 52.63 (a) (4)).
The seoond tier would also contain the l
o~->o e 4- 'velisation attributes', which the NUMARC report proposes as a bridge to demonstrating compliance with those first-tier acceptance criteria that are not readily measurable or otherwise verifiable by direct field inspection or test. (Rahn to deal with this later in greater detail) The De rulemaking would consider and resolve all 8 issues covered by here tiers -- including the design detail to be include,4 in such tier - for purposes of I. later col and preoperational proceedings (per section 52.d3 (a) (4) ). This resolution of issues vill be binding on later col applicants and licensees, the NRC 1 and any intervenors in subsequent COL and l preoperational proceedings. ~ t As to the two-tiered design description in the DC Rule, COL applicants and licensees will be obligated to comply with all provisions in helb tiers, absent an exemption, amendment or other pernitted change. More l specifically Matters covered by the first tier (that is, the design described in that tier and the ITAAC) can only be changed through an NRC-approved exemption or amendment, preceded by a hearing opportunity (per Sections 52. 63 (b) (1) and 52.97(b)). i +n,- --p,--- yyv,y g-w w- -ve-t-wwoew .-m -* - e
_ _ 7 e. Ot '.n, ] 'second tier matters can be changed without 4 waC approval only if a change meets the j i requirements of section so.se (per section
- 52. 63 (b) (2) ).
The two-tiers of the DC Rule would be incorporated by L reference in tny COL utilising that certified design. The col would also contain a comparable two-tier L description of the site-specific plant features and of operation-related mat,ters (including the Emergency Planning Program) and their corresponding confirmatory i specifications. Overall, the col format would be very similar to 1 present-day 014. l 1 NUMARC believes that the two-tier forisat, with contents cs described, produces a result fully J consistent with the specific requirements of Part 52; further, we have tried hard to meet our understanding I of the standardination, issue preclusion, and workability objectives inherent in the commission's ] Part 52 regulations. 1 8e 4 i 2 .}}